(259 days)
The Automatic Tissue Processing Unit is used in medical procedures involving the harvesting and transferring of autologous adipose tissue. The Automatic Tissue Processing Unit is used for concentrating adipose tissue harvested with a legally marketed lipoplasty system. The Automatic Tissue Processing Unit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.
- Neurosurgery Gastrointestinal Surgery Urological Surgery Plastic and Reconstructive Surgery General Surgery Orthopedic Surgery Gynecological Surgery Thoracic Surgery Laparoscopic Surgery Arthoscopic Surgery
The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics etc. In addition, the harvested fat tissues are not homogenous and contain uneven fibrotic tissues. So, for the purpose of in autologous fat transfer surgical technique. ACPU kit is designed and developed for harvest of the fine homologous adipose tissue in a sterile and closed way. ACPU needs to be centrifuged by using exclusive centrifuge (ACS Combo-A-Centrifuge/Product code: JQC) and the kits are single-use only.
Here's an analysis of the provided FDA 510(k) summary regarding the Automatic Tissue Processing Unit, structuring the information according to your requested points:
Device: Automatic Tissue Processing Unit (ACPU-100/ACPU-200)
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly defined by the successful results of the specified tests, indicating that the device meets predetermined standards for each parameter. The "Requirements" column serves as the acceptance criteria.
| Test Item | Acceptance Criteria (Requirements) | Reported Device Performance (Results) |
|---|---|---|
| Appearance | No defects, flaws, breakage, or contamination of foreign objects. | Pass |
| Measurement | Within ±5% of stated dimensions. | Pass |
| Leakage | No leakage. | Pass |
| Residuals of cleaning liquid | Less than 20 ml. | Pass |
| Packaging | Adhesive strength not less than 3N (ASTM F-88). | Pass |
| Nucleated Cell Count | More than 3.86x10^5 per ml of adipose tissue. | "3.86 over" - Implies greater than or equal to, thus meeting the criteria. |
| Nucleated Cell Viability | More than 71.4%. | "71.4% over" - Implies greater than or equal to, thus meeting the criteria. |
| Extraction test: | ||
| Appearance (sample prep extract) | No foreign material. | Pass |
| pH (Difference) | ≤ 1.5 | Pass |
| KMnO4 Reducing agents (Difference in titres) | ≤ 2.0 ml | Pass |
| Evaporating residue (Difference in extractables) | ≤ 1.0 mg | Pass |
| Heavy metal (as Pb) | Not darker than standard solution. | Pass |
| UV-vis Spectrum (Difference in absorbance 250nm-350nm) | ≤ 0.1 | Pass |
| Biocompatibility Tests: | ||
| Cytotoxicity (ISO 10993-5) | Pass (implicitly defined by standard) | Pass |
| Skin Sensitization (ISO 10993-10) | Pass (implicitly defined by standard) | Pass |
| Intracutaneous Reactivity Test (ISO 10993-10) | Pass (implicitly defined by standard) | Pass |
| Acute Systemic Toxicity Test (ISO 10993-11) | Pass (implicitly defined by standard) | Pass |
| Pyrogen Test (ISO 10993-11, Annex F) | Pass (implicitly defined by standard) | Pass |
| Hemolysis Test (ISO 10993-4) | Pass (implicitly defined by standard) | Pass |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the sample size for the "bench tests." The tests listed are primarily physical, chemical, and biological characterization tests performed on the device itself or its materials, rather than a clinical human subject test set. The data provenance is not specified, but these are laboratory tests rather than patient data.
3. Number of Experts Used to Establish Ground Truth and Their Qualifications
Since the tests performed are bench tests (biocompatibility, mechanical, sterility, extraction, cell counts/viability), the concept of "ground truth" established by human experts in a diagnostic or clinical context is not applicable. The ground truth for these tests is based on objective laboratory measurements and established scientific standards (e.g., ISO guidelines, ASTM standards, chemical analysis techniques).
4. Adjudication Method for the Test Set
Adjudication methods like "2+1" or "3+1" are relevant for clinical studies where human interpretation of medical images or outcomes needs consensus. For the bench tests described, adjudication is not applicable. The "results" are objective measurements.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study was done. The document describes bench testing to demonstrate functionality and substantial equivalence to a predicate device, not a human reader study.
6. Standalone (Algorithm Only) Performance Study
Not applicable. This device is an Automatic Tissue Processing Unit, a mechanical/biological processing system, not an AI algorithm.
7. Type of Ground Truth Used
The "ground truth" for the performance data in this submission consists of:
- Objective physical measurements: Dimensions, leakage, adhesive strength.
- Chemical analysis results: Residuals of cleaning liquid, pH, KMnO4 reducing agents, evaporating residue, heavy metals, UV-vis spectrum.
- Biological assay results: Nucleated cell count and viability.
- Standardized biological test outcomes: Biocompatibility tests (cytotoxicity, sensitization, systemic toxicity, pyrogenicity, hemolysis) performed according to ISO standards, where "Pass" is the objective outcome based on the standard's criteria.
8. Sample Size for the Training Set
Not applicable. This device is not an AI/ML algorithm that requires a training set. The data presented is for validation and verification of the physical device's performance.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this type of device.
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May 25, 2018
BSL Co. % Peter Chung President Plus Global 300 Atwood Pittsburgh, Pennsylvania 15213
Re: K172717
Trade/Device Name: Automatic Tissue Processing Unit Regulation Number: 21 CFR 878.5040 Regulation Name: Suction lipoplasty system Regulatory Class: Class II Product Code: MUU Dated: April 25, 2018 Received: April 25, 2018
Dear Mr. Chung:
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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820);
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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,
David Krause -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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Indications for Use
510(k) Number (if known) K172717
Device Name Automatic Tissue Processing Unit
Indications for Use (Describe)
The Automatic Tissue Processing Unit is used in medical procedures involving the harvesting and transferring of autologous adipose tissue. The Automatic Tissue Processing Unit is used for concentrating adipose tissue harvested with a legally marketed lipoplasty system. The Automatic Tissue Processing Unit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.
- Neurosurgery Gastrointestinal Surgery Urological Surgery Plastic and Reconstructive Surgery General Surgery Orthopedic Surgery Gynecological Surgery Thoracic Surgery Laparoscopic Surgery Arthoscopic Surgery
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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510(k)Summary [as required by 807.92(c)]
1Applicant
-
- Company: BSLCo.
- Address: 6-13, Chilsan-ro 237beon-gil,Gimhae-si,Gyungsangnam-do, South Korea য
- Tel:82-55-328-9235 3)
-
- Fax:82-55-328-9236
- Prepared date: July 4, 2017 5)
-
- Contact person: Peter Chung,412-512-8802
- Contact person address: 300 Atwood Street, Pittsburgh, PA, 15213, USA 7)
-
- Submission date: August 25, 2017
2. Device Information
-
- Trade name: Automatic Tissue Processing Unit
- 2 Common name: Fat Concentration System
- 3 Regulation name: Suction Lipoplasty System
- 4 Product code: MUU
-
- Regulation number: 878.5040
- റ്റം Class of device: Class II
-
- Panel: General and Plastic surgery
-
- The legally marketed device to which we are claiming equivalence K121005, AdiPrep™Adipose Transfer System
4. Device description
The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics etc. In addition, the harvested fat tissues are not homogenous and contain uneven fibrotic tissues. So, for the purpose of in autologous fat transfer surgical technique. ACPU kit is designed and developed for harvest of the fine homologous adipose tissue in a sterile and closed way. ACPU needs to be centrifuged by using exclusive centrifuge (ACS Combo-A-Centrifuge/Product code: JQC) and the kits are single-use only.
5. Intended Use:
The Automatic Tissue Processing Unit is used in medical procedures involvingthe harvesting and transferring of autologous adipose tissue. The Automatic Tissue Processing Unit is used for concentrating adipose tissue harvested with a legally marketed lipoplasty system. The Automatic Tissue Processing Unit is intended for
use in the following surgical specialties when the concentration of harvested adipose tissue is desired.
- Neurosurgery
- Gastrointestinal Surgery
- Urological Surgery
- -Plastic and Reconstructive Surgery
- -General surgery
- Orthopedic Surgery
- Gynecological Surgery
- Thoracic Surgery
- Laparoscopic Surgery
- Arthroscopic Surgery
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6. Performance data:
-
- Bench test were performed. Bench testing included biocompatibility, mechanical testing,sterility testing including EO residues. The tests demonstrated that the device performs in a substantially equivalent manner to the predicate device. The following bench testing is performed to demonstrate the functionality is substantially equivalent.
| Test item | Requirements | Results |
|---|---|---|
| Appearance | Itshould not be defects inflaws, breakage or contamination of foreign objects. | |
| Measurement | When measuring with Vernier calipers, according to the dimension of 'shape and structure' part, the stated should be within ±5 %. | |
| Leakage | When tested according to the test method, there should be no leakage. | |
| Residuals of cleaning liquid | When tested accordingto the test method, the residuals of cleaning liquid should be less than 20 ml. | Pass |
| Packaging | Adhesive strength shall be tested by ASTM F-88 to be not less than 3N | |
| Nucleated Cell Count | Nucleated cells should have more than 3.86x105 per ml of adipose tissue | |
| Nucleated Cell Viability | Viability of nucleated cells should be more than 71.4% | |
| Extraction test | ||
| Appearance | When observe sample preparation extract with naked eyes, there should not be foreign material. | |
| pH | Difference in pH S: 1.5 | |
| KMn04 Reducing agents | Difference intitres S: 2.0 ml | Pass |
| Evaporating residue | Difference in extractables S 1.0 mg | |
| Heavy metal (as Pb) | Not darker than standard solution. | |
| UV-vis Spectrum | Difference inabsorbance (250nm-350nm) S:0.1 |
2Biocompatibility
| # | Testitem | Test method /Test criteria | Test result |
|---|---|---|---|
| 1 | Cytotoxicity | ISO 10993-5 Tests for in vitro cytotoxicity | Pass |
| 2 | Skin SensitizationTest | ISO 10993-10 irritation and skin sensitization | Pass |
| 3 | IntracutaneousReactivity Test | ISO 10993-10 Test for irritation and skin sensitization, maximization testfor delayed hypersensitivity | Pass |
| 4 | Acute SystemicToxicity Test | ISO 10993-11 Test for systemic toxicity -Acute Systemic Toxicity | Pass |
| 5 | Pyrogen Test | ISO 10993-11Tests for systemic toxicity, Annex(F) Information onmaterial-mediated pyrogens. | Pass |
| 6 | Hemolysis Test | ISO 10993-4 Selection of tests for interactions with blood | Pass |
The performance tests demonstrated that Automatic Tissue Processing Unit performs ina substantially equivalent manner to the predicate device.
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7.ComparisonTable of ACPU-100/AC PU-200
| Manufacturer | BSL Co. | AdiprepTM | Remark |
|---|---|---|---|
| SIO(K) No. | K121005 | N/A | |
| Indication foruse | The Automatic Tissue Processing Unit is used inmedical procedures involving the harvesting andtransferring of autologous adipose tissue. TheAutomatic Tissue Processing Unit is used forconcentrating adipose tissue harvested with alegally marketed lipoplasty system.TheAutomatic Tissue Processing Unit is intended foruse in the following surgical specialties when theconcentration of harvested adipose tissue isdesired.* Neurosurgery* Gastrointestinal Surgery* Urological Surgery* Plastic and Reconstructive Surgery* General surgery* Orthopedic Surgery* Gynecological Surgery* Thoracic Surgery* aparoscopic Surgery* Arthroscopic Surgery | The AdiPrep™ Adipose Transfer System isusedin medical procedures involving the harvestingand transferring of autologous adipose tissue.The Adiprep system is used for concentratingadipose tissue harvested with a legallymarketed lipoplasty system. AdiPrepTM AdiposeTransfer system is intended for use in thefollowing surgical specialties when theconcentration of harvested adipose tissue isdesired .* Neurosurgery* Gastrointestinal Surgery* Urological Surgery* Plastic and Reconstructive Surgery* Generalsurgery* Orthopedic Surgery* Gynecological Surgery* Thoracic Surgery* Laparoscopic Surgery* Arthroscopic Surgery | Same |
| Model/type | ACPU-100/ACPU-200 | ADI-25-01 AdiPrep Procedure pack | N/A |
| Appearance | Image: ACPU-100/ACPU-200 | Image: ADI-25-01 AdiPrep Procedure pack | Different |
| ProcessingPack:Materials | ACPU-100 kit / ACPU-200 kit | Components - Syringes with removableplunger, centrifuge tubes with filter, aspiration& fat injection cannula,fat injection syringes,skin puncture needles, and oil extractionsyringe & needle. Cannula & syringescomposed of medicalgrade plastics. | Different |
| Fill volumes | 5 to 25ml | 5 to 25ml | same |
| SterilizationMethod | Ethylene-OxideGas(EtO) | Ethylene-Oxide Gas (EtO) | same |
| Autologous Adipose Product | |||
| Nucleated cellcount (x105 mlof product) | 3.86 over | Mean 1.848 | Similar |
| Nucleated cellviability | 71.4% over | Mean 83.5 | Similar |
| Processing capabilities | |||
| Volume | 5 to SOml | Sta 25ml | Similar |
| Low-g-force | Centrifuge to spin for approximately 4 minutes at1250 g-force (ACPU-200 kit)Centrifuge to spin for approximately 5 minutes at375 g-force (ACPU-100 kit) | Centrifuge to spin for approximately 4 minutesat 1250 g-force | Sameanddifferent |
| Laboratorycentrifuge | ACS Combo-A CentrifugeCENTRIFUGES (MICRO, ULTRA, REFRIGERATED)FOR CLINICAL USE or laboratory centrifuge forclinical use | SmartPReP2 centrifuge isa general-purposelaboratory centrifuge for clinical use | N/A |
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Conclusion
The device is investigated for function and effectiveness to compare the operation of function between proposed device and predicate device (K121005). Comparison results demonstrate that the specifications and performance of the device are same as functional and effective as the legally marketed predicate device. Therefore, it is concluded that is Automatic Tissue Processing Unit of BSL Co. substantially equivalent to the legally marketed predicate device.
§ 878.5040 Suction lipoplasty system.
(a)
Identification. A suction lipoplasty system is a device intended for aesthetic body contouring. The device consists of a powered suction pump (containing a microbial filter on the exhaust and a microbial in-line filter in the connecting tubing between the collection bottle and the safety trap), collection bottle, cannula, and connecting tube. The microbial filters, tubing, collection bottle, and cannula must be capable of being changed between patients. The powered suction pump has a motor with a minimum of1/3 horsepower, a variable vacuum range from 0 to 29.9 inches of mercury, vacuum control valves to regulate the vacuum with accompanying vacuum gauges, a single or double rotary vane (with or without oil), a single or double diaphragm, a single or double piston, and a safety trap.(b)
Classification. Class II (special controls). Consensus standards and labeling restrictions.