K Number
K171869
Device Name
Sutter CURIS RF Generator
Date Cleared
2018-02-23

(246 days)

Product Code
Regulation Number
878.4400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sutter CURIS® RF Generator is intended for: Orthopedic, arthroscopic, spinal and neurosurgical: For resection and coagulation of soft tissues and hemostasis of blood vessels in orthopedic, arthroscopic, spinal and neurosurgical procedures For soft tissue resection and coaqulation during arthroscopic surgical procedures of knee, shoulder, ankle, elbow, hip and wrist Cutting: Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin incisions, biopsy, cysts, abscesses, tumors, cosmetic repairs, development of skin tags, Blepharoplasty Blended Cutting and Coagulation: Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin tags, papilloma Keloids, Keratosis, Verrucae, Basal cell carcinoma, Nevi, Fistulas, Epithelioma, cosmetic repairs, cysts, abscesses, development of skin flaps Hemostasis and nonablative Coagulation: Control of bleeding, Epilation, Teleangiectasia Bipolar: Pinpoint. Precise Coagulation. Pinpoint Hemostasis in any field (wet or dry), snoring. submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage Contraindications: This device is not intended for vessel sealing.
Device Description
The Sutter CURIS® RF Generator is a compact source of high radiofrequency RF energy to be employed for a variety of electrosurqical procedures. This is achieved by the selection of different wave forms and power levels on the front panel of the device. All selections are effected through pushbuttons and knobs. Lamps give the operator feedback on the status. The power level for each mode is indicated by front-panel digital displays. During self-test or for error messages these digital displays also serve as indicators. Activation of output power is performed through foot switch and/or hand switch. Monopolar and bipolar electrodes are available for use. The maximum power output of the device in CUT mode is 100 watts (at 400 Ohms load), and 80 watts maximum in COAG mode at 50 Ohms. Operating frequency of the device is maintained at 4.0 MHz. The device offers both monopolar and bipolar output wave forms. In monopolar mode it offers two CUT wave forms and two COAG wave forms. In bipolar mode it offers three CUT wave forms and three COAG wave forms. The Sutter CURIS® RF Generator is packaged together with power cord and instruction manual. Optional accessories are a foot switch with cable and appropriate monopolar and bipolar cables.
More Information

Not Found

No
The device description focuses on the selection of waveforms and power levels via physical controls (pushbuttons and knobs) and digital displays, indicating a traditional electrosurgical generator without mention of adaptive or learning algorithms. The performance studies listed are standard electrical, mechanical, and functional safety tests, not studies related to AI/ML performance metrics or training/test data.

Yes
The device is intended for various medical procedures, including resection, coagulation, hemostasis, and tissue modification, which are all therapeutic interventions aimed at treating conditions or symptoms.

No

The device description and intended use clearly state that the Sutter CURIS® RF Generator is used for surgical procedures involving resection, coagulation, cutting, and hemostasis of tissues. It generates radiofrequency energy for therapeutic actions, not for diagnosing conditions or diseases.

No

The device description clearly states it is a "compact source of high radiofrequency RF energy" and describes physical components like pushbuttons, knobs, digital displays, and connections for foot and hand switches, and electrodes. This indicates it is a hardware device that utilizes software for control, but is not software-only.

Based on the provided information, the Sutter CURIS® RF Generator is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly describes the device's function in surgical procedures for cutting, coagulation, and hemostasis of tissues within the body. This is an in vivo application.
  • Device Description: The description details a radiofrequency generator used to deliver energy to tissues via electrodes. This is consistent with surgical electrosurgical devices, not devices used to test samples outside the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue samples, etc.) or providing diagnostic information based on such analysis.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The Sutter CURIS® RF Generator's function is therapeutic and surgical, not diagnostic.

N/A

Intended Use / Indications for Use

The Sutter CURIS® RF Generator is intended for:

Orthopedic, arthroscopic, spinal and neurosurgical:

For resection and coagulation of soft tissues and hemostasis of blood vessels in orthopedic, arthroscopic, spinal and neurosurgical procedures

For soft tissue resection and coaqulation during arthroscopic surgical procedures of knee, shoulder, ankle, elbow, hip and wrist

Cutting:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin incisions, biopsy, cysts, abscesses, tumors, cosmetic repairs, development of skin tags, Blepharoplasty

Blended Cutting and Coagulation:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin tags, papilloma Keloids, Keratosis, Verrucae, Basal cell carcinoma, Nevi, Fistulas, Epithelioma, cosmetic repairs, cysts, abscesses, development of skin flaps

Hemostasis and nonablative Coagulation:

Control of bleeding, Epilation, Teleangiectasia

Bipolar:

Pinpoint. Precise Coagulation. Pinpoint Hemostasis in any field (wet or dry), snoring. submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage

Contraindications:

This device is not intended for vessel sealing.

Product codes

GEI

Device Description

The Sutter CURIS® RF Generator is a compact source of high radiofrequency RF energy to be employed for a variety of electrosurqical procedures. This is achieved by the selection of different wave forms and power levels on the front panel of the device. All selections are effected through pushbuttons and knobs. Lamps give the operator feedback on the status.

The power level for each mode is indicated by front-panel digital displays. During self-test or for error messages these digital displays also serve as indicators. Activation of output power is performed through foot switch and/or hand switch. Monopolar and bipolar electrodes are available for use.

The maximum power output of the device in CUT mode is 100 watts (at 400 Ohms load), and 80 watts maximum in COAG mode at 50 Ohms. Operating frequency of the device is maintained at 4.0 MHz.

The device offers both monopolar and bipolar output wave forms. In monopolar mode it offers two CUT wave forms and two COAG wave forms. In bipolar mode it offers three CUT wave forms and three COAG wave forms.

The Sutter CURIS® RF Generator is packaged together with power cord and instruction manual. Optional accessories are a foot switch with cable and appropriate monopolar and bipolar cables.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

soft tissues, blood vessels, knee, shoulder, ankle, elbow, hip, wrist, palatal, skin

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

Non-Clinical Performance Data

As part of demonstrating safety and effectiveness of Sutter CURIS® RF Generator and in showing substantial equivalence to the predicate device that are subject to this 510(k) submission, Sutter Medizintechnik GmbH completed a number of non-clinical performance tests against applicable standards.

(1) Electrical safety: Compliance to IEC 60601-1: 2005 - Passed
(2) Electrical safety: Compliance to IEC 60601-2-2:2009 - Passed
(3) Electromagnetic compatibility: Compliance to IEC 60601-1-2: 2007 - Passed
(4) Risk Management: Compliance to ISO 14971:2007 - Passed
(5) Software Performance: Compliance to IEC 62304:2006 - Passed

To demonstrate that the Sutter CURIS® RF Generator meets all design specifications and performance requirements, nonclinical bench testing has been performed in accordance with the internal R&D process in compliance with the proposals and recommendations of FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" - Guidance for Industry and Food and Drug Administration Staff, August 15, 2016. In particular, tests have been planned and carried out with respect to the following subject areas:

  • Mechanical safety
  • . Functional safety Testing
  • . System Performance Testing
  • . Thermal effects on tissue
  • Usabilitv ●
  • Drop Tests ●

Mechanical safety:
Protection against mechanical hazards of ME equipment and ME systems has been tested in compliance with IEC 60601-1:2005. The testing demonstrated that all applicable requirements have been met.

Functional safety testing:
The appropriate delivery of energy from the CURIS® RF Generator to the accessory and patient is controlled by software. The functional safety concept of the CURIS® RF Generator has been tested in compliance with IEC 60601-1:2005, IEC 60601-2-2:2009 and IEC 62304:2006.

System Performance Testing:
System performance testing has been performed in accordance with the internal R&D process and in compliance with the proposals and recommendations of FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" - Guidance for Industry and Food and Drug Administration Staff, August 15, 2016.

The review of design requirements was based on the following test methods:
Control of labeling and packaging, control of weight and external dimensions, visual inspections, functional inspections and measurements of the generator. The corresponding performance testing demonstrated that all design specifications and performance requirements have been met.

Thermal effects on tissue:
The Sutter CURIS® RF Generator has been tested for thermal effects on tissue with commercially available electrosurgical accessories which are widely used and cleared for marketing in the USA. For comparison reasons the predicate device was included.
The experimental arrangement was carried out in line with FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" -Guidance for Industry and Food and Drug Administration Staff, August 15, 2016.
In all modes, the CURIS® RF Generator delivered adequate coagulation and cutting performance. Generally, CURIS® RF Generator and the predicate device performed similarly.

Usability:
The CURIS® RF Generator has been investigated in order to show that design specifications and performance requirements are met. The results of the thermal effect performance testing, system performance testing, market acceptance tests, and user scenarios tests have been evaluated. It has been assessed that the CURIS® RF Generator fulfills the intended usability and meets the respective design input.

Drop Tests:
Drop tests with the CURIS® RF Generator in its designated packaging have been executed to demonstrate that design specifications and performance requirements are met.

Internal verification and validation testing confirms that product specifications are met which are equivalent to the predicate device in design and technological characteristics. The testing results support that the requirements for performance and electrical safety testing were met for the acceptance of the device. The CURIS® RF Generator passed all testing and supports the claims of substantial equivalence to the predicate device.

Key Metrics

Not Found

Predicate Device(s)

K100390

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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.

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

February 23. 2018

Sutter Medizintechnik GmbH % Andre Kindsvater Senior Consultant, RA/QA Emergo Global Consulting LLC 2500 Bee Cave Road, Building 1, Suite 300 Austin, Texas 78746

Re: K171869

Trade/Device Name: Sutter CURIS RF Generator Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: January 10, 2017 Received: January 19, 2018

Dear Andre Kindsvater:

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, 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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820);

1

Page 2 - Andre Kindsvater

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

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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

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

Indications for Use

510(k) Number (if known) K171869

Device Name Sutter CURIS® RF Generator

Indications for Use (Describe)

Orthopedic, arthroscopic, spinal and neurosurgical:

For resection and coagulation of soft tissues and hemostasis of blood vessels in orthopedic, arthroscopic, spinal and neurosurgical procedures.

For soft tissue resection and coagulation during arthroscopic surgical procedures of knee, show, hip and wrist.

Cutting:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin incisions, biopsy, cysts, abscesses, tumors, cosmetic repairs, development of skin flaps, skin tags, Blepharoplasty.

Blended Cutting and Coagulation:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin tags, papilloma Keloids, Keratosis, Verrucae, Basal cell carcinoma, Nevi, Fistulas, Epithelioma, cosmetic repairs, cysts, abscesses, development of skin flaps.

Hemostasis and nonablative Coagulation: Control of bleeding, Epilation, Teleangiectasia.

Bipolar:

Pinpoint, Precise Coagulation, Pinpoint Hemostasis in any field (wet or dry), snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage.

Contraindications:

This device is not intended for vessel sealing.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

3

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4

510(k) Summary Sutter CURIS® RF Generator K171869

1. Submission Sponsor

Sutter Medizintechnik GmbH Tullastraße 87 Freiburg Germany +49 (0) 761 51551-14 +49 (0) 761 51551-30 CONTACT: Ulrike Zeissler, Title: Manager Regulatory Affairs Email: Zeissler@sutter-med.de

2. Submission Correspondent

Emergo Global Consulting, LLC 2500 Bee Cave Road Building 1, Suite 300 Austin, TX 78746 Office Phone: (512) 327.9997 Contact: André Kindsvater, Senior Consultant, RA/QA email: project.management@emergogroup.com

3. Date Prepared

February 19th, 2018

4. Device Identification

Trade/Proprietary Name:Sutter CURIS® RF Generator
Common/Usual Name:RF Generator
Classification Name:Electrosurgical, cutting & coagulation & accessories
Regulation Number:21 CFR 878.4400
Product Code:GEI
Device Class:Class II
Classification Panel:General and Plastic Surgery

5. Legally Marketed Predicate Device(s)

Electrosurgical Generator Surgi-Max by Elliquence LLC; K100390

5

6. Indication for Use Statement

The Sutter CURIS® RF Generator is intended for:

Orthopedic, arthroscopic, spinal and neurosurgical:

For resection and coagulation of soft tissues and hemostasis of blood vessels in orthopedic, arthroscopic, spinal and neurosurgical procedures

For soft tissue resection and coaqulation during arthroscopic surgical procedures of knee, shoulder, ankle, elbow, hip and wrist

Cutting:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin incisions, biopsy, cysts, abscesses, tumors, cosmetic repairs, development of skin tags, Blepharoplasty

Blended Cutting and Coagulation:

Snoring, submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage, skin tags, papilloma Keloids, Keratosis, Verrucae, Basal cell carcinoma, Nevi, Fistulas, Epithelioma, cosmetic repairs, cysts, abscesses, development of skin flaps

Hemostasis and nonablative Coagulation:

Control of bleeding, Epilation, Teleangiectasia

Bipolar:

Pinpoint. Precise Coagulation. Pinpoint Hemostasis in any field (wet or dry), snoring. submucosal palatal shrinkage, traditional uvulopalatoplasty (RAUP), myringotomy with effective hemorrhage control, epistaxis treatment and turbinate shrinkage

Contraindications:

This device is not intended for vessel sealing.

7. Device Description

The Sutter CURIS® RF Generator is a compact source of high radiofrequency RF energy to be employed for a variety of electrosurqical procedures. This is achieved by the selection of different wave forms and power levels on the front panel of the device. All selections are effected through pushbuttons and knobs. Lamps give the operator feedback on the status.

The power level for each mode is indicated by front-panel digital displays. During self-test or for error messages these digital displays also serve as indicators. Activation of output power is performed through foot switch and/or hand switch. Monopolar and bipolar electrodes are available for use.

The maximum power output of the device in CUT mode is 100 watts (at 400 Ohms load), and 80 watts maximum in COAG mode at 50 Ohms. Operating frequency of the device is maintained at 4.0 MHz.

The device offers both monopolar and bipolar output wave forms. In monopolar mode it offers two CUT wave forms and two COAG wave forms. In bipolar mode it offers three CUT wave forms and three COAG wave forms.

The Sutter CURIS® RF Generator is packaged together with power cord and instruction manual. Optional accessories are a foot switch with cable and appropriate monopolar and bipolar cables.

6

8. Sterilization

The Sutter CURIS® RF Generator is not distributed as a sterile device, and is not intended to be sterilized at any time.

9. Biocompatibility

The Sutter CURIS® RF Generator is a table-top device which has no contact with the patient.

10. Technological Characteristics

Mains supply100-240 V; 50/60 Hz
Power consumption without RF outputapprox. 50 VA
Power consumption at max. output powerapprox. 500 VA
Protection classI
LF and RF
leakage currentsaccording to IEC 60601-2-2
TypeCF; defibrillator safe
Weightapprox. 5.0 kg
Dimensions W x H x D320 mm x 170 mm x 385 mm
Environmental conditions for transportation
and storage:
Ambient temperature25 °C to +70 °C
Relative humidity10 % to 100 %
Atmospheric pressure500 hPa to 1060 hPa
Environmental conditions for operation:
Ambient temperature+10 °C to +40 °C
Relative humidity30 % to 75 %
Atmospheric pressure700 hPa to 1060 hPa

11. Non-Clinical Performance Data

As part of demonstrating safety and effectiveness of Sutter CURIS® RF Generator and in showing substantial equivalence to the predicate device that are subject to this 510(k) submission, Sutter Medizintechnik GmbH completed a number of non-clinical performance tests against applicable standards.

TestPass / fail criteriaResults
1Electrical safetyCompliance to IEC 60601-1: 2005Passed
2Electrical safetyCompliance to IEC 60601-2-2:2009Passed
3Electromagnetic
compatibilityCompliance to IEC 60601-1-2: 2007Passed

Table 5C - Performance Standards Testing Summary

7

TestPass / fail criteriaResults
4Risk ManagementCompliance to ISO 14971:2007Passed
5Software PerformanceCompliance to IEC 62304:2006Passed

To demonstrate that the Sutter CURIS® RF Generator meets all design specifications and performance requirements, nonclinical bench testing has been performed in accordance with the internal R&D process in compliance with the proposals and recommendations of FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" - Guidance for Industry and Food and Drug Administration Staff, August 15, 2016. In particular, tests have been planned and carried out with respect to the following subject areas:

  • Mechanical safety
  • . Functional safety Testing
  • . System Performance Testing
  • . Thermal effects on tissue
  • Usabilitv ●
  • Drop Tests ●

Mechanical safety:

Protection against mechanical hazards of ME equipment and ME systems has been tested in compliance with IEC 60601-1:2005. The testing demonstrated that all applicable requirements have been met.

Functional safety testing:

The appropriate delivery of energy from the CURIS® RF Generator to the accessory and patient is controlled by software. The functional safety concept of the CURIS® RF Generator has been tested in compliance with IEC 60601-1:2005, IEC 60601-2-2:2009 and IEC 62304:2006.

System Performance Testing:

System performance testing has been performed in accordance with the internal R&D process and in compliance with the proposals and recommendations of FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" - Guidance for Industry and Food and Drug Administration Staff, August 15, 2016.

The review of design requirements was based on the following test methods:

Control of labeling and packaging, control of weight and external dimensions, visual inspections, functional inspections and measurements of the generator. The corresponding performance testing demonstrated that all design specifications and performance requirements have been met.

Thermal effects on tissue

The Sutter CURIS® RF Generator has been tested for thermal effects on tissue with commercially available electrosurgical accessories which are widely used and cleared for marketing in the USA. For comparison reasons the predicate device was included.

8

The experimental arrangement was carried out in line with FDA guidance: "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" -Guidance for Industry and Food and Drug Administration Staff, August 15, 2016.

In all modes, the CURIS® RF Generator delivered adequate coagulation and cutting performance. Generally, CURIS® RF Generator and the predicate device performed similarly.

Usability:

The CURIS® RF Generator has been investigated in order to show that design specifications and performance requirements are met. The results of the thermal effect performance testing, system performance testing, market acceptance tests, and user scenarios tests have been evaluated. It has been assessed that the CURIS® RF Generator fulfills the intended usability and meets the respective design input.

Drop Tests:

Drop tests with the CURIS® RF Generator in its designated packaging have been executed to demonstrate that design specifications and performance requirements are met.

Internal verification and validation testing confirms that product specifications are met which are equivalent to the predicate device in design and technological characteristics. The testing results support that the requirements for performance and electrical safety testing were met for the acceptance of the device. The CURIS® RF Generator passed all testing and supports the claims of substantial equivalence to the predicate device.

12. Substantial Equivalence Discussion

Table 5B - Comparison of Characteristics

| Manufacturer | Sutter Medizintechnik
GmbH | Elliquence LLC | SIGNIFICANT
DIFFERENCES |
|-------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------|
| Trade Name | CURIS® RF Generator | Surgi-Max | N/A |
| 510(k) Number | N/A | K100390 | N/A |
| Product Code | GEI | GEI | same |
| Regulation
Number | 21 CFR 878.4400 | 21 CFR 878.4400 | same |
| Regulation Name | Electrosurgical, cutting &
coagulation & accessories | Electrosurgical, cutting &
coagulation & accessories | same |
| Intended Use | The Sutter CURIS ® RF
Generator is intended for:
Orthopedic, arthroscopic,
spinal and neurosurgical:
For resection and
coagulation of soft tissues
and hemostasis of blood
vessels in orthopedic,
arthroscopic, spinal and
neurosurgical procedures
For soft tissue resection and
coagulation during | Orthopedic, arthroscopic,
spinal, and neurosurgical:
For resection, ablation, and
coagulation of soft tissues
and hemostasis of blood
vessels in orthopedic,
arthroscopic, spinal and
neurological procedures.
For soft tissue resection and
ablation during arthroscopic | similar |
| Manufacturer | Sutter Medizintechnik
GmbH | Elliquence LLC | SIGNIFICANT
DIFFERENCES |
| Trade Name | CURIS® RF Generator | Surgi-Max | N/A |
| | arthroscopic surgical
procedures of knee,
shoulder, ankle, elbow, hip
and wrist. | surgical procedures of knee,
shoulder, ankle, elbow, hip
and wrist. | |
| | Cutting:
Snoring, submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective
hemorrhage control,
epistaxis treatment and
turbinate shrinkage, skin
incisions, biopsy, cysts,
abscesses, tumors, cosmetic
repairs, development of skin
flaps, skin tags,
blepharoplasty | Cutting:
Snoring, submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective
hemorrhage control,
epistaxis treatment, and
turbinate shrinkage, skin
incisions, biopsy, cysts,
abscesses, tumors, cosmetic
repairs, development of skin
flaps, skin tags,
blepharoplasty. | |
| | Blended Cutting and
Coagulation:
Snoring, submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective
hemorrhage control,
epistaxis treatment and
turbinate shrinkage, skin
tags, papilloma keloids,
keratosis, verrucae, basal
cell carcinoma, nevi, fistulas,
epithelioma, cosmetic
repairs, cysts, abscesses,
development of skin flaps | Blended Cutting and
Coagulation:
Snoring, submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective
hemorrhage control,
epistaxis treatment, and
turbinate shrinkage, skin
tags, papilloma keloids,
keratosis, verrucae, basal
cell carcinoma, nevi, fistulas,
epithelioma, cosmetic
repairs, cysts, abscesses,
Development of skin flaps. | |
| | Hemostasis and nonablative
Coagulation:
Control of bleeding, epilation,
teleangiectasia | Hemostasis and Nonablative
Coagulation:
Control of bleeding, epilation,
telangiectasia | |
| | Bipolar:
Pinpoint, precise coagulation,
pinpoint hemostasis in any
field (wet or dry), snoring,
submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective | Bipolar:
Pinpoint, precise coagulation,
pinpoint hemostasis, in any
field (wet or dry), snoring,
submucosal palatal
shrinkage, traditional
uvulopalatoplasty (RAUP),
myringotomy with effective | |
| Manufacturer | Sutter Medizintechnik
GmbH | Elliquence LLC | SIGNIFICANT
DIFFERENCES |
| Trade Name | CURIS® RF Generator | Surgi-Max | N/A |
| | hemorrhage control,
epistaxis treatment and
turbinate shrinkage
Contraindications:
This device is not intended
for vessel sealing. | hemorrhage control,
epistaxis treatment, and
turbinate shrinkage | |
| Material | Metal & plastics | Metal & plastics | Similar- the
differences do
not affect safety
and
effectiveness |
| Battery Operated | no | no | same |
| AC Powered | yes | yes | same |
| Frequency | 4 MHz | 4 MHz / 1.71 MHz | Similar- the
differences do
not affect safety
and
effectiveness |
| Delivery Mode | Monopolar and bipolar | Monopolar and bipolar | same |
| Waveforms | Mono contact Coag: m
Mono Softspray Coag:
modulated
Mono Cut 1: sinusoidal
Mono Cut 2: modulated
Bipo precise Coag:
modulated
Bipo macro Coag: modulated
Bipo RaVoR Coag:
modulated
Bipo Cut1: sinusoidal
Bipo Cut 2: modulated
Bipo Cut Excise: modulated | Mono Hemo: modulated
Mono CUT: sinusoidal
Mono CUT/COAG:
modulated
Bipo Hemo: modulated
Bipo Turbo: modulated | Similar- the
differences do
not affect safety
and
effectiveness |
| Electrical Safety
Testing Passed | IEC 60601-1 all applicable
requirements met | IEC 60601-1 all applicable
requirements met | same |
| Electromagnetic
compatibility | IEC 60601-1-2 all applicable
requirements met | IEC 60601-1-2 all applicable
requirements met | same |

9

10

13. Statement of Substantial Equivalence

The CURIS® RF Generator device is substantially equivalent to the predicate device, and does not raise different questions regarding its safety and effectiveness as compared to the predicate device(s).