K Number
K163450
Device Name
VIVA combo RF System
Manufacturer
Date Cleared
2017-03-08

(90 days)

Product Code
Regulation Number
878.4400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The VIVA combo RF Ablation System is intended for use in percutaneous and intraoperative coagulation and ablation of tissue.
Device Description
The VIVA combo RF System consists of RF generator, active electrode, grounding pad and peristaltic pump for electrode cooling. This device is designed to produce local tissue heating at the tip of the electrodes causing the coagulation and ablation of tissue. The VIVA combo RF System is capable of delivering up to 200 W of RF power and the available power is limited through software control. This generator monitors the power, resistance, current and temperature. The active electrodes are a sterile, single-use, hand-held electrosurgical instrument designed for use with VIVA combo RF System. Cooling of the electrode is provided by chilled water which is pumped through the inflow tubing, the electrode and out through the outflow tubing. This is an enclosed system within the electrode and the water is not to be in contact with the patient.
More Information

Not Found

No
The summary describes a standard RF ablation system with software control for power and monitoring of basic electrical parameters. There is no mention of AI, ML, or any features that would suggest the use of such technologies for decision-making, image analysis, or adaptive control beyond basic feedback loops.

Yes
The device is used for coagulation and ablation of tissue, which are therapeutic interventions.

No
This device is described as an RF Ablation System intended for the "coagulation and ablation of tissue," which points to a therapeutic function rather than a diagnostic one. Its ability to "monitor power, resistance, current, and temperature" serves to control the therapeutic action, not to diagnose a condition.

No

The device description explicitly lists hardware components such as an RF generator, active electrode, grounding pad, and peristaltic pump, indicating it is not a software-only device.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is "percutaneous and intraoperative coagulation and ablation of tissue." This describes a therapeutic procedure performed directly on the patient's body.
  • Device Description: The device description details a system for delivering radiofrequency energy to heat and destroy tissue. This is a physical intervention, not a diagnostic test performed on samples taken from the body.
  • Lack of Diagnostic Elements: There is no mention of analyzing samples (blood, urine, tissue, etc.) or providing diagnostic information about a patient's condition. The device's function is to treat tissue.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not fit that description.

N/A

Intended Use / Indications for Use

The VIVA combo RF Ablation System is intended for use in percutaneous and intraoperative coagulation and ablation of tissue.

Product codes (comma separated list FDA assigned to the subject device)

GEI

Device Description

The VIVA combo RF System consists of RF generator, active electrode, grounding pad and peristaltic pump for electrode cooling. This device is designed to produce local tissue heating at the tip of the electrodes causing the coagulation and ablation of tissue.

The VIVA combo RF System is capable of delivering up to 200 W of RF power and the available power is limited through software control. This generator monitors the power, resistance, current and temperature.

The active electrodes are a sterile, single-use, hand-held electrosurgical instrument designed for use with VIVA combo RF System. Cooling of the electrode is provided by chilled water which is pumped through the inflow tubing, the electrode and out through the outflow tubing. This is an enclosed system within the electrode and the water is not to be in contact with the patient.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

No clinical studies were considered necessary and performed.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K042216

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 878.4400 Electrosurgical cutting and coagulation device and accessories.

(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

March 8, 2017

STARmed Co., Ltd. Jun-Young Jung Deputy General Manger B-dong, 4F, 158, Haneulmaeul-ro, IlsanDong-gu, Goyang-si Gyeonggi-do, 10355 Korea

Re: K163450

Trade/Device Name: VIVA Combo RF System Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting And Coagulation Device And Accessories Regulatory Class: Class II Product Code: GEI Dated: March 3, 2017 Received: March 7, 2017

Dear Jun-Young Jung:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

1

the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

Jennifer R. Stevenson -S

For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Image /page/2/Picture/1 description: The image contains the logo for STARmed. The logo features a stylized orange circle with the word "STAR" in orange, bold letters inside the circle. To the right of the circle, the word "med" is written in gray, sans-serif letters. The overall design is clean and modern, suggesting a company in the medical or healthcare industry.

| | DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration | Form Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below. |
|--------------------------------|------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|
| | Indications for Use | |
| 510(k) Number (if known) | K163450 | |
| Device Name | VIVA combo RF System | |
| Indications for Use (Describe) | The VIVA combo RF Ablation System is intended for use in percutaneous and intraoperative coagulation and ablation of tissue. | |

Type of Use (Select one or both, as applicable)

× Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

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Image /page/3/Picture/1 description: The image contains the logo for STARmed. The logo consists of the word "STAR" in orange, with the letters arranged inside of an orange circle. To the right of the word "STAR" is the word "med" in gray. The logo is simple and modern.

B-dong, 4F, 158, Haneulmaeul-ro, IlsanDong-gu, Goyang-si Gyeonggi-do, Republic of Korea

510(k) Summary

[As required by 21 CFR 807.92]

1. Date Prepared [21 CFR 807.92(a)(a)]

December 6, 2016

Submitter's Information [21 CFR 807.92(a)[1]] 2.

  • . Name of Sponsor: STARmed Co., Ltd. Address: B-dong, 4F, 158, Haneulmaeul-ro, IlsanDong-gu, Goyang-si, -Gyeonggi-do, Republic of Korea
  • Contact Name: Jun-Young Jung Telephone No.: +82 70-4673-8628 -Fax No.: +82 31-816-4546 -
  • . Registration Number: In process
  • Name of Manufacturer: Same as Sponsor -Address: Same as Sponsor

3. Trade Name, Common Name, Classification [21 CFR 807.92(a)(2)]

  • . Trade Name: VIVA combo RF System . Common Name: Electrosurgical Cutting and Coagulation Device and Accessories
  • . Classification:
Classification NameElectrosurgical, Cutting & Coagulation & Accessories
Classification Regulation21 CFR 878.4400
Product CodeGEI
Device ClassII

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Image /page/4/Picture/1 description: The image shows the logo for STARmed. The logo consists of the word "STARmed" in a stylized font. The "STAR" portion of the name is in orange, while the "med" portion is in gray. To the left of the word "STAR" is an orange circular design that appears to be made of multiple curved lines.

Identification of Predicate Device(s) [21 CFR 807.92(a)(3)] 4.

The identified predicate devices within this submission are shown as follow:

Predicate Device

510(k) Number:K042216
Applicant:Valleylab
Regulation Name:Electrosurgical cutting and coagulation device and accessories
Trade Name:Cool-tip™ RF Ablation System

There are no significant differences between VIVA combo RF System and the predicate device that would adversely affect the use of the product. It is substantially equivalent to these devices in indications for use and technology characteristics.

5. Description of the Device [21 CFR 807.92(a)[4]]

The VIVA combo RF System consists of RF generator, active electrode, grounding pad and peristaltic pump for electrode cooling. This device is designed to produce local tissue heating at the tip of the electrodes causing the coagulation and ablation of tissue.

The VIVA combo RF System is capable of delivering up to 200 W of RF power and the available power is limited through software control. This generator monitors the power, resistance, current and temperature.

The active electrodes are a sterile, single-use, hand-held electrosurgical instrument designed for use with VIVA combo RF System. Cooling of the electrode is provided by chilled water which is pumped through the inflow tubing, the electrode and out through the outflow tubing. This is an enclosed system within the electrode and the water is not to be in contact with the patient.

Intended Use [21 CFR 807.92(a)(5)] 6.

The VIVA combo RF System is intended for use in percutaneous and intraoperative coagulation and ablation of tissue.

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Image /page/5/Picture/1 description: The image shows the logo for STARmed. The logo features the word "STAR" in orange, with the word "med" in gray next to it. To the left of the word "STAR" is an orange circle with a break in the upper left.

7. Technological Characteristics [21 CFR 807.92(a)(6)]

The VIVA combo RF System is substantially equivalent to legally marketed predicate device with respect to indications for use and technology characteristics. The table below presents side by side comparisons for each major component of each device:

ItemProposed DevicePrimary Predicate
K NumberNot knownK042216
ModelVIVA combo RF SystemCool-tip™ RF Ablation
System
ManufactureSTARmed Co., Ltd.Valleylab
Intended UseThe VIVA combo RF System is
intended for use in
percutaneous and
intraoperative coagulation
and ablation of tissue.The Cool-tip™ RF Ablation
System (Generator and
Accessories) is intended for
use in percutaneous,
laparoscopic and
intraoperative coagulation
and ablation of tissue, such as
partial or complete ablation
of non-resectable liver
lesions.
Type of UsePrescription UsePrescription Use
ComponentElectrosurgical unit, active
electrode, grounding pad,
peristaltic pump and foot
pedalElectrosurgical unit, active
electrode, grounding pad,
peristaltic pump and foot
pedal
Electrosurgical Unit
Output Frequency$480 kHz \pm 10 %$$480 kHz \pm 10%$
Drive on TimeUp to 30 minutesUp to 30 minutes
Maximum Power OutputUp to 200 watts @ 50 ohmUp to 200 watts @ 50 ohm
Active Accessory
Monopolar / BipolarMonopolarMonopolar

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Non-clinical Test Summary

  • . Electrical Safety, Electromagnetic Compatibility and Performance:
    Bench tests were conducted to verify that the proposed device met all design specifications. The test results demonstrated that the proposed device complies with the following standards:

  • Testing to confirm compliance with the safety requirements of standard AAMI -ES60601-1

  • Testing to confirm compliance with EMC requirements of standard IEC 60601-1-2 -

  • Testing to confirm compliance with particular requirements of standard IEC 60601-2-2 -

  • . Software Validation

The VIVA combo RF System contains MODERATE level of concern software. The software was designed and developed according to a software development process and was verified and validated.

The software information is provided in accordance with FDA guidance: The content of premarket submissions for software contained in medical devices, on May 11, 2005.

  • Biocompatibility
    The following biocompatibility tests were performed:

  • Cytotoxicity -

  • Irritation/intracutaneous reactivity -

  • Sensitization -

  • Acute Systemic Toxicity -

  • . Sterilization and Shelf Life

The active electrode of VIVA combo RF System is delivered in a sterile state and is intended for single use only. The sterilization method used is ethylene oxide and this device has a shelf life of 3 years.

Clinical Test Summarv

No clinical studies were considered necessary and performed.

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Image /page/7/Picture/1 description: The image shows the logo for STARmed. The logo consists of the word "STARmed" in a stylized font. The "STAR" portion of the word is in orange, while the "med" portion is in gray. To the left of the word "STAR" is an orange circular design that appears to be a stylized atom.

B-dong, 4F, 158, Haneulmaeul-ro, IlsanDong-gu, Goyang-si, Gyeonggi-do, Republic of Korea

8. Substantial Equivalence [21 CFR 807.92(b)(1) and 807.92]

When compared to the predicate devices, the VIVA combo RF System in this submission presented the same in terms of indications for use, components and technology characteristics.

9. Conclusion [21 CFR 807.92(b)(3)]

In according to with the Federal food & Drug and cosmetic Act, 21 CFR Part 807, and based on the information provided in this premarket notification STARmed Co., Ltd. concludes that VIVA combo RF System is substantially equivalent in safety and effectiveness to predicate device as described herein.