(70 days)
The New Deantronics E Green™ Electrosurgical Monopolar Pencils are intended to remove tissue and control bleeding by use of high-frequency electrical current.
The E Green™ Reusable Monopolar Cord is an electrosurgical accessory used with E Green™ Disposable Electrosurgical Pencil. Electrosurgical Pencils are intended to remove tissue and control bleeding by use of high-frequency electrical current. This product is a monopolar, electrosurgical pencil which is used for most open surgeries. The pencil can be divided in two parts, one is a gamma sterilized disposable electrosurgical pencil and another is a reusable cord which needs to be autoclaved by the user before use in a standard operating room environment. The E Green™ Reusable Monopolar Cord is used ONLY in combination with E Green™ Disposable Electrosurgical Pencil. The number of uses of the Reusable Monopolar Cord following steam sterilization is 100 times.
The provided document is a 510(k) premarket notification for a medical device: New Deantronics E Green™ Electrosurgical Monopolar Pencils. This document describes the device, its intended use, and substantial equivalence to a predicate device based on non-clinical testing. It does not contain information about a study involving expert readers assessing AI performance, human improvement with AI assistance, or data provenance, as would be typical for an AI/ML medical device submission.
Therefore, many of the requested elements (especially those related to AI/ML device studies like MRMC studies, training/test set details, expert ground truth establishment, and adjudication methods) cannot be extracted from this document, as it pertains to a traditional electrosurgical device.
However, I can extract information related to acceptance criteria and performance based on the non-clinical testing described.
Here's the breakdown of what can be extracted and what cannot:
1. A table of acceptance criteria and the reported device performance
The document states: "All the test results demonstrate the performance of New Deantronics E Green™ Electrosurgical Monopolar Pencil meet the requirements of its pre-defined acceptance criteria and intended uses." However, it does not provide a specific table listing the acceptance criteria and the numerical reported performance for each criterion. It only lists the standards to which the device was tested.
Table of Acceptance Criteria (Inferred from standards tested) and Reported Device Performance
| Acceptance Criteria Category (Inferred from Standards) | Reported Device Performance Statement |
|---|---|
| Electrical Safety (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2) | "meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Biocompatibility (ISO 10993-1, -5, -10, -12) | "meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Sterilization Assurance (ISO 11137-2, ISO 17665-1, AAMI TIR30, ANSI/AAMI ST81, ASTM F1980-07) | "meet the requirements of its pre-defined acceptance criteria and intended uses." (Specific SAL 10-6 reported for both Gamma and Steam sterilization methods mentioned in comparison table) |
| Packaging Integrity (ISO 11607, ISTA 2A) | "meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Risk Management (ISO 14971) | "meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Usability Engineering (IEC 62366-1) | "meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Overall Safety and Effectiveness | "is as safe and effective as the predicate devices." |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Sample Size: The document does not specify sample sizes (e.g., number of devices tested) for the non-clinical tests.
- Data Provenance: The tests are non-clinical, likely bench testing or lab testing to ensure compliance with standards. The company is based in Taiwan (New Deantronics Taiwan Ltd.). No mention of human patient data or its origin.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)
- This information is not applicable and not present in the document. This is a traditional medical device, not an AI/ML device requiring expert-established ground truth from medical images or clinical data.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- This information is not applicable and not present in the document.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No, an MRMC study was not done. This device is not an AI/ML diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No, this is not an AI/ML algorithm. The performance evaluation is based on non-clinical testing against pre-defined standards for an electrosurgical pencil.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the non-clinical tests described, the "ground truth" would be compliance with the technical, safety, and performance specifications established by the listed international and national standards (e.g., IEC, ISO, AAMI, ASTM). There isn't a "ground truth" derived from patient data or expert consensus in the typical sense applied to AI/ML in diagnostics.
8. The sample size for the training set
- Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
- Not applicable.
{0}------------------------------------------------
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized representation of a human figure, with three profiles overlapping to create a sense of depth and connection. The figure is positioned to the right of the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA", which is arranged in a circular pattern around the figure.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 29, 2017
New Deantronics Taiwan, Ltd % Mr. Lewis Ward Consultant L.W. Ward and Associates Incorporated 4655 Kirkwood Court Boulder, Colorado 80301
Re: K170161
Trade/Device Name: New Deantronics E Green™ Electrosurgical Monopolar Pencils Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: March 16, 2017 Received: March 22, 2017
Dear Mr. Ward:
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
{2}------------------------------------------------
Form Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below.
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
Device Name
New Deantronics E Green™ Electrosurgical Monopolar Pencils
Indications for Use (Describe)
The New Deantronics E Green™ Electrosurgical Monopolar Pencils are intended to remove tissue and control bleeding by use of high-frequency electrical current.
| 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) |
| CONTINUE ON A SEPARATE PAGE IF NEEDED. | |
| This section applies only to requirements of the Paperwork Reduction Act of 1995. | |
| DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW. | |
| of this information collection, including suggestions for reducing this burden, to: | The burden time for this collection of information is estimated to average 79 hours per response, including thetime to review instructions, search existing data sources, gather and maintain the data needed and completeand review the collection of information. Send comments regarding this burden estimate or any other aspect |
| Food and Druq AdministrationOffice of Chief Information OfficerPRAStaff(@fda.hhs.gov | Department of Health and Human ServicesPaperwork Reduction Act (PRA) Staff |
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
Section 5 510(k) Summary
Submitter:
New Deantronics Taiwan Ltd. 12F., No.51, Sec. 4, Chong Yang Rd., Tu Cheng Dist, New Taipei City 23675, Taiwan R.O.C. (886) 2-2268-1726 Phone
大瓏企業股份有限公司
New Deantronics Taiwan, Ltd.
新北市土城區中央路4段51號12樓
12F., No.51, Sec. 4,
Chong Yang Rd., Tu Cheng Dist.,
New Taipei City 23675,
Taiwan R.O.C.
Tel: 886 2 2268-1726
Fax: 886 2 2268-3800
US
I.
II.
(886) 2-2268-3800 Fax
Contact Person:
Lewis Ward L.W. Ward and Associates, Inc. 4655 Kirkwood Court Boulder, CO 80301 USA 303-530-3279 lwward@qwest.net Date Prepared: Jan. 11, 2017
Trade Name: New Deantronics E Green™ Electrosurgical Monopolar Pencil
Common Name: Electrosurgical accessory, Electrosurgical Monopolar Pencil
Classification: 21 CFR 878.4400, electrosurgical cutting and coagulation device and III. accessories. Class 2, General and Plastic Surgery Panel 79
IV. Product Code: GEI
V. Indications for Use:
The New Deantronics E Green™ Electrosurgical Monopolar Pencils are intended to remove tissue and control bleeding by use of high-frequency electrical current.
VI. Predicate Device
510(k) 982744. New Deantronics Disposable Hand Switching Pencil, Push Button, 2 Piece With and Without Holster.
Device Description and Technological Characteristics VII.
The E Green™ Reusable Monopolar Cord is an electrosurgical accessory used with E Green™ Disposable Electrosurgical Pencil. Electrosurgical Pencils are intended to remove tissue and control bleeding by use of high-frequency electrical current.
{4}------------------------------------------------
Image /page/4/Picture/2 description: The image shows the logo for New Deantronics Group. The logo features a blue letter 'D' with a red circle inside, followed by the text 'DEANTRONICS' in blue, bold letters. Below the main logo, the words 'New Deantronics Group' are written in a smaller, less bold font.
This product is a monopolar, electrosurgical pencil which is used for most open surgeries. The pencil can be divided in two parts, one is a gamma sterilized disposable electrosurgical pencil and another is a reusable cord which needs to be autoclaved by the user before use in a standard operating room environment. The E Green™ Reusable Monopolar Cord is used ONLY in combination with E Green™ Disposable Electrosurgical Pencil. The number of uses of the Reusable Monopolar Cord following steam sterilization is 100 times.
This device and the predicate devices have the similar technological characteristics, operating principles and performance characteristics. The proposed device is equivalent to the identified
大瓏企業股份有限公司
New Deantronics Taiwan, Ltd.
新北市土城區中央路4段51號12樓
12F., No.51, Sec. 4,
Chong Yang Rd., Tu Cheng Dist.,
New Taipei City 23675,
Taiwan R.O.C.
Tel: 886 2 2268-1726
Table 1: New Deantronics E Green™ Reusable Monopolar Cord
| Item | Catalog No. | ND P/N | Description |
|---|---|---|---|
| 1 | GMC01 | P0001NE1 | E Green™ Reusable Monopolar Cord, 10ft |
| 2 | GMC015 | P0001NE2 | E Green™ Reusable Monopolar Cord, 15ft |
Table 2: New Deantronics E Green™ Disposable Electrosurgical Pencil
predicate device with respect to technological characteristics and function.
| Item | Catalog No. | ND P/N | Description |
|---|---|---|---|
| 1 | GPEN01 | P0101SE1 | E Green™ Disposable Electrosurgical Pencil |
VIII. Non-Clinical Testing
IEC 60601-1: 2005 + CORR. 1:2006 + CORR. 2:2007 + AM1:2012: Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
IEC 60601-1-2:2014: Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Disturbances - Requirements And Tests.
IEC 60601-2-2: 2009 + C1:2014, Medical electrical equipment = Part 2-2: Particular requirements for the safety of high frequency surgical equipment.
ISO 14971:2007, Medical Device- Application of Risk Management to Medical Devices
ISO 10993-1: 2009. Biological Evaluation of Medical Devices - Part 1: Evaluation and testing within a risk management process.
ISO 10993-5: 2009, Biological Evaluation of Medical Devices - Part 5: Tests for In Vitro Cytotoxicity.
ISO 10993-10: 2010, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization
ISO 10993-12: 2012, Biological Evaluation of Medical Devices - Part 12: Sample Preparation and Reference Materials.
ISO 11137-2:2013, Sterilization of health care products -- Radiation -- Part 2: Establishing the sterilization dose.
U.S.
{5}------------------------------------------------
Image /page/5/Picture/2 description: The image contains the logo for New Deantronics. The logo features the word "NEW" in a light gray outlined font, followed by a blue circle with a red dot in the center. To the right of the circle is the word "DEANTRONICS" in a bold, dark blue font. Below the logo is the text "New Deantronics Group" in a smaller, dark blue font.
ISO 11607:2006, Packaging for terminally sterilized medical devices -Part 1: Requirements for materials, sterile barrier systems and packaging systems [Including: Amendment 1 (2014)]; Part 2: Validation requirements for forming, sealing and assembly processes [Including: Amendment 1 (2014)].
ISTA 2A Packaged-Products 150 lb (68 kg) or Less
U.S
大瓏企業股份有限公司
New Deantronics Taiwan, Ltd.
新北市土城區中央路4段51號12樓
12F., No.51, Sec. 4,
Chong Yang Rd., Tu Cheng Dist.,
New Taipei City 23675,
Taiwan R.O.C.
Tel: 886 2 2268-1726
Fax: 886 2 2268-3800
criteria for cleaning reusable medical devices. ISO 17665-1:2006/(R) 2013, Sterilization Of Health Care Products -- Moist Heat -- Part 1:
AAMI TIR30:2011, A compendium of processes, materials, test methods, and acceptance
Requirements For The Development, Validation, And Routine Control Of A Sterilization Process For Medical Devices.
ANSVAAMI ST81:2004/(R) 2010, Sterilization of medical devices - Information to be provided by the manufacturer for the processing of resterilizable medical devices.
IEC 62366-1:2015, Medical devices -- Part 1: Application of usability engineering to medical devices
ASTM F1980-07:2011, Standard guide for accelerated aging of sterile barrier systems for medical devices. (Sterility)
Non-clinical testing conclusion:
All the test results demonstrate the performance of New Deantronics E Green™ Electrosurgical Monopolar Pencil meet the requirements of its pre-defined acceptance criteria and intended uses. The results confirm that the New Deantronics E Green™ Electrosurgical Monopolar Pencil is as safe and effective as the predicate devices.
IX. Substantial Equivalence
The New Deantronics E Green™ Electrosurgical Monopolar Pencil is substantially equivalent to the New Deantronics Disposable Hand Switching Pencil, Push Button, 2 Piece With and Without Holster (K982744) based on intended use, technology, materials, and performance. The claim of substantial equivalence is supported by information the information provided in this submission.
| X. Key Features Comparison | ||
|---|---|---|
| FEATURE | New Deantronics E Green™Electrosurgical Monopolar Pencil | New Deantronics Disposable HandSwitching Pencil, Push Button(K982744) |
| Intended Use | E Green™ Electrosurgical MonopolarPencils are intended to remove tissue andcontrol bleeding by use of high-frequencyelectrical current. | Electrosurgical Pencils are intended toremove tissue and control bleeding by use ofhigh-frequency electrical current. |
| Use | E Green™ Disposable ElectrosurgicalPencil is single use.E Green™ Reusable Monopolar Cord isreusable. | Single Use |
X. Kev Features Comparison
{6}------------------------------------------------
| FEATURE | New Deantronics E Green™Electrosurgical Monopolar Pencil | New Deantronics Disposable HandSwitching Pencil, Push Button(K982744) |
|---|---|---|
| Use Environment | Hospital, clinic | Hospital clinic |
| Dimensions | Pen body length : 12.3 cmCord length : 10 ft and 15 ft | Pen body length : 16.2 cmCord length : 10 ft and 15 ft |
| Rated Voltage | 4600 V | 4600 V |
| Material | Electrode: stainless steel, HDPE overmoldPen body: ABS, NylonCord: Silicone, TPV, PPSU | Electrode: stainless steel, HDPE overmoldPen body: ABS, NylonCord: PVC |
| Specification | Button switch Two piece body | Button switch Two piece body |
| Energy SourceType | RF Energy | RF Energy |
| Sterile methodand SAL | E Green™ Disposable ElectrosurgicalPencil: Gamma irradiation, SAL 10-6.E Green™ Reusable Monopolar Cord:Steam, SAL 10-6. | Gamma irradiation, SAL 10-6. |
Taiwan
大瑞企業股份有限公司 New Deantronics Taiwan, Ltd. 新北市土城區中央路 4段 51 號 12 樓 12F., No.51, Sec. 4, Chong Yang Rd., Tu Cheng Dist., New Taipei City 23675, Taiwan R.O.C. Tel: 886 2 2268-1726 Fax: 886 2 2268-3800
U.S.
New Deantronics Ltd. 1990 North California Blvd. Suite 1040 Walnut Creek, CA. 94596 Tel: (925) 280 8388 Fax: (925) 280 1788
4
§ 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.