K Number
K173085
Device Name
invendoscopy E210 System
Date Cleared
2018-01-08

(101 days)

Product Code
Regulation Number
876.1500
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The invendoscopy E210 System is intended to provide visualization and diagnostic / therapeutic access to the adult lower gastrointestinal tract (including but not limited to, the anus, rectum, sigmoid colon, cecum and ileocecal valve) for endoscopy and endoscopic surgery. The colonoscope component of the invendoscopy E210 System, the invendoscope SC210, is a sterile single use disposable device. The invendoscope SC210 cannot be reprocessed.
Device Description
The invendoscopy E210 System consists of an invendoscope SC210, an invendo E210 Processing Unit, an invendo E210 Power Unit, an invendo ScopeController and an invendo Drying Adapter. The invendo E210 Processing Unit and the invendo E210 Power Unit together form the invendo SPU E210. The invendoscope SC210 is a sterile single-use disposable colonoscope. The distal tip of the colonoscope is deflectable and equipped with a CMOS camera and LEDs for illumination. A working channel is incorporated for biopsies and polypectomies. The invendoscope SC210 is furthermore equipped with insufflation, irrigation and suction functions. The invendo E210 SPU (consisting of invendo E210 Processing Unit and invendo E210 Power Unit) contains the video signal processing technology which enables the endoscope to illuminate, view, record and transmit video data of endoscopic images. The invendo SPU E210 supplies the colonoscope and controls its functions according to the commands of the operator. The operator uses the invendo ScopeController unit to control the invendoscopy E210 System. The invendo ScopeController allows the operator to control following functions of the colonoscope: deflection of the tip; insufflation; irrigation and suction. The invendo ScopeController also allows the user to record images. The invendo Drying Adapter is intended to support drying of the inner parts of the invendo SPU E210. It is used to connect a waste container to the invendo SPU E210.
More Information

Not Found

No
The summary describes standard video signal processing for visualization and recording, but does not mention any AI/ML capabilities for analysis, detection, or other functions.

Yes
The 'Intended Use / Indications for Use' section states that the system is intended to provide "therapeutic access" and the device description mentions a working channel for "polypectomies," which are therapeutic procedures.

Yes

The "Intended Use / Indications for Use" section explicitly states that the system is "intended to provide visualization and diagnostic / therapeutic access."

No

The device description clearly outlines multiple hardware components including a colonoscope, processing unit, power unit, and scope controller. While it includes software for video signal processing and control, it is not solely software.

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

Here's why:

  • Intended Use: The intended use clearly states that the system is for "visualization and diagnostic / therapeutic access to the adult lower gastrointestinal tract... for endoscopy and endoscopic surgery." This describes a procedure performed in vivo (within the living body) for direct observation and intervention.
  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body (like blood, urine, tissue) to detect diseases, conditions, or infections. This device does not perform such tests on samples.
  • Device Description: The description details a colonoscope with a camera, illumination, and channels for biopsies and polypectomies. These are tools for direct examination and intervention within the body, not for analyzing samples outside the body.
  • Lack of IVD-related components: There is no mention of reagents, assays, or other components typically associated with IVD devices.

The device is an endoscopic system used for direct visualization and procedures within the body, which falls under the category of medical devices, but not specifically In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The invendoscopy E210 System is intended to provide visualization and diagnostic / therapeutic access to the adult lower gastrointestinal tract (including but not limited to, the anus, rectum, sigmoid colon, cecum and ileocecal valve) for endoscopy and endoscopic surgery.

The colonoscope component of the invendoscopy E210 System, the invendoscope SC210, is a sterile single use disposable device. The invendoscope SC210 cannot be reprocessed.

Product codes

FDF

Device Description

The invendoscopy E210 System consists of an invendoscope SC210, an invendo E210 Processing Unit, an invendo E210 Power Unit, an invendo ScopeController and an invendo Drying Adapter. The invendo E210 Processing Unit and the invendo E210 Power Unit together form the invendo SPU E210.

The invendoscope SC210 is a sterile single-use disposable colonoscope. The distal tip of the colonoscope is deflectable and equipped with a CMOS camera and LEDs for illumination. A working channel is incorporated for biopsies and polypectomies. The invendoscope SC210 is furthermore equipped with insufflation, irrigation and suction functions.

The invendo E210 SPU (consisting of invendo E210 Processing Unit and invendo E210 Power Unit) contains the video signal processing technology which enables the endoscope to illuminate, view, record and transmit video data of endoscopic images. The invendo SPU E210 supplies the colonoscope and controls its functions according to the commands of the operator.

The operator uses the invendo ScopeController unit to control the invendoscopy E210 System. The invendo ScopeController allows the operator to control following functions of the colonoscope: deflection of the tip; insufflation; irrigation and suction. The invendo ScopeController also allows the user to record images.

The invendo Drying Adapter is intended to support drying of the inner parts of the invendo SPU E210. It is used to connect a waste container to the invendo SPU E210.

Mentions image processing

The invendo E210 SPU (consisting of invendo E210 Processing Unit and invendo E210 Power Unit) contains the video signal processing technology which enables the endoscope to illuminate, view, record and transmit video data of endoscopic images.

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

lower gastrointestinal tract (including but not limited to, the anus, rectum, sigmoid colon, cecum and ileocecal valve)

Indicated Patient Age Range

adult

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)

The following non-clinical testing was performed to validate the design and to assure conformity with the following design standards:

  • IEC 60601-1 "Medical electrical equipment part 1 General requirements for safety" incl. national deviations
  • -IEC 60601-2-18 "Medical electrical equipment part 2 - Particular requirements for the basic safety and essential performance of endoscopic equipment"
  • IEC 60601-1-2 "Medical electrical equipment part 1-2: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic compatibility –Requirements and tests"; including national deviations FCC CFR 47 part 15
  • -ISO 10993-5; -7; -10 "Biological evaluation of medical devices -- Part 5: Tests for in vitro cytotoxicity"; Part 7: Ethylene Oxide Sterilization Residuals"; Part 10: Tests for irritation and skin sensitization"
  • -IEC 62366 "Medical devices: Application of usability engineering to medical devices"
  • -ASTM 4169 "Standard Practice for Performance Testing of Shipping Containers and Systems"
  • -ASTM F88 "Standard Test Method for Seal Strength of Flexible Barrier Materials"
  • ASTM F1886 Standard Test Method for Determining Integrity of Seals for Flexible -Packaging by Visual Inspection
  • ASTM F1929 "Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration"
  • ASTM F2096 Standard Test Method for Detecting Gross Leaks in Packaging by -Internal Pressurization (Bubble Test)
  • -ISO 11135 "Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices"
  • -Evaluation of insertion forces

In all instances, the invendoscopy E210 System functioned as intended, performed as well as or better than the predicate and met individual test specifications.

Risk analysis was carried out in accordance with established in-house acceptance criteria based on ISO 14971:2007. The design verifications tests and their acceptance criteria were identified and performed as a result of this risk analysis assessment.

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

Not Found

Predicate Device(s)

K161355, K100584

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 876.1500 Endoscope and accessories.

(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.

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January 8, 2018

invendo medical GmbH Oliver v. Ruepprecht Head of QA/RA Peterhofstr. 3b Kissing, Bavaria 86438 Germanv

Re: K173085

Trade/Device Name: invendoscopy E210 System Regulation Number: 21 CFR§ 876.1500 Regulation Name: Endoscope and Accessories Regulatory Class: II Product Code: FDF Dated: September 27, 2017 Received: September 29, 2017

Dear Oliver v. Ruepprecht:

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.

1

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); 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 mediation-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,

Charles Viviano -S

For Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K173085

Device Name invendoscopy E210 System

Indications for Use (Describe)

The invendoscopy E210 System is intended to provide visualization and diagnostic / therapeutic access to the adult lower gastrointestinal tract (including but not limited to, the anus, rectum, sigmoid colon, cecum and ileocecal valve) for endoscopy and endoscopic surgery.

The colonoscope component of the invendoscopy E210 System, the invendoscope SC210, is a sterile single use disposable device. The invendoscope SC210 cannot be reprocessed.

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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3

510(k) Premarket Notification
invendoscopy E210 System

Image /page/3/Picture/4 description: The image shows the logo for "invendo medical" with the tagline "STERILE SINGLE-USE ENDOSCOPY" underneath. The text is in a sans-serif font and is gray in color. To the right of the text is an orange graphic element that appears to be a stylized swirl or abstract shape.

Applicant Information

Name:invendo medical GmbH
Address:Peterhofstr. 3b
86438 Kissing
Germany
Contact:Oliver v. Ruepprecht
Head of QA/RA
Phone : +49 – 8233 – 744 98 16
Fax : +49 – 8233 – 744 98 15
Mail : oliver.ruepprecht@invendo-medical.de

Date Prepared: September 27,2017

Identification of the proposed device

Device Nameinvendoscopy E210 System
Componentsinvendoscope SC210 (SC210 colonoscope)
invendo E210 Processing Unit
invendo E210 Power Unit
invendo ScopeController
invendo Drying Adapter
Common NameColonoscopy System
Classification/nameClass II (876.1500) / Endoscope and Accessories
Product CodeFDF
Review PanelGastroenterology/Urology

Predicate Devices

K161355Invendoscopy E200 System
K100584Olympus EVIS EXERA II 180 SYSTEM

4

Intended Use

The invendoscopy E210 System is intended to provide visualization and diagnostic / therapeutic access to the adult lower gastrointestinal tract (including but not limited to, the anus, rectum, sigmoid colon, colon, cecum and ileocecal valve) for endoscopy and endoscopic surgery.

The colonoscope component of the invendoscopy E210 System, the invendoscope SC210, is a sterile single-use disposable device. The invendoscope SC210 cannot be reprocessed.

Device Description

The invendoscopy E210 System consists of an invendoscope SC210, an invendo E210 Processing Unit, an invendo E210 Power Unit, an invendo ScopeController and an invendo Drying Adapter. The invendo E210 Processing Unit and the invendo E210 Power Unit together form the invendo SPU E210.

The invendoscope SC210 is a sterile single-use disposable colonoscope. The distal tip of the colonoscope is deflectable and equipped with a CMOS camera and LEDs for illumination. A working channel is incorporated for biopsies and polypectomies. The invendoscope SC210 is furthermore equipped with insufflation, irrigation and suction functions.

The invendo E210 SPU (consisting of invendo E210 Processing Unit and invendo E210 Power Unit) contains the video signal processing technology which enables the endoscope to illuminate, view, record and transmit video data of endoscopic images. The invendo SPU E210 supplies the colonoscope and controls its functions according to the commands of the operator.

The operator uses the invendo ScopeController unit to control the invendoscopy E210 System. The invendo ScopeController allows the operator to control following functions of the colonoscope: deflection of the tip; insufflation; irrigation and suction. The invendo ScopeController also allows the user to record images.

Technology/SpecificationComparison to predicate devices
Deflection technology and
deflecting capabilityDeflecting technology and capability are similar to the
invendoscopy E200 System (K161355); the bending
diameter of the deflecting of the invendoscope SC210 is
between the bending diameters of the predicate devices;
an additional passive deflecting part is integrated in the
invendoscope SC210.

The invendo Drying Adapter is intended to support drying of the inner parts of the invendo SPU E210. It is used to connect a waste container to the invendo SPU E210.

5

Technology/SpecificationComparison to predicate devices
IrrigationIdentical to the invendoscopy E200 System (K161355)
InsufflationIdentical to the invendoscopy E200 System (K161355)
SuctionAs the invendoscopy E200 System (K161355) the
invendoscopy E210 System uses a pinch valve to control
the suction.
Light SourceSame technology as invendoscope SC200 (same LED) but
different light control methodology.
CameraSame technology (CMOS) as invendoscope SC200
(K161355); the invendoscope SC210 works with high
definition (HD) resolution as the Olympus EVIS EXERA II
180 SYSTEM.
DiameterIdentical to the invendoscope SC200 (K161355)
Working LengthIdentical to the invendoscope SC200 (K161355)
Working channel ØThe working channel of the invendoscope SC210 is 3.2mm,
the working channel of the invendoscope SC200 is 3.1mm.
Insertion technologyIdentical to the invendoscope SC200 (K161355)
SterilityIdentical to the invendoscope SC200 (K161355)
MaterialThe materials of the invendoscope (synthetic plastics) and
the predicate devices are different but the whole device is
biocompatible as required by the ISO10993-1 Standard.

Performance testing

The following non-clinical testing was performed to validate the design and to assure conformity with the following design standards:

  • IEC 60601-1 "Medical electrical equipment part 1 General requirements for safety" incl. national deviations
  • -IEC 60601-2-18 "Medical electrical equipment part 2 - Particular requirements for the basic safety and essential performance of endoscopic equipment"
  • IEC 60601-1-2 "Medical electrical equipment part 1-2: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic compatibility –Requirements and tests"; including national deviations FCC CFR 47 part 15

6

  • -ISO 10993-5; -7; -10 "Biological evaluation of medical devices -- Part 5: Tests for in vitro cytotoxicity"; Part 7: Ethylene Oxide Sterilization Residuals"; Part 10: Tests for irritation and skin sensitization"
  • -IEC 62366 "Medical devices: Application of usability engineering to medical devices"
  • -ASTM 4169 "Standard Practice for Performance Testing of Shipping Containers and Systems"
  • -ASTM F88 "Standard Test Method for Seal Strength of Flexible Barrier Materials"
  • ASTM F1886 Standard Test Method for Determining Integrity of Seals for Flexible -Packaging by Visual Inspection
  • -ASTM F1929 "Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration"
  • ASTM F2096 Standard Test Method for Detecting Gross Leaks in Packaging by -Internal Pressurization (Bubble Test)
  • -ISO 11135 "Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices"
  • -Evaluation of insertion forces

In all instances, the invendoscopy E210 System functioned as intended, performed as well as or better than the predicate and met individual test specifications.

Risk analysis was carried out in accordance with established in-house acceptance criteria based on ISO 14971:2007. The design verifications tests and their acceptance criteria were identified and performed as a result of this risk analysis assessment.

Substantial Equivalence

The invendoscopy E210 System has the same intended use and indications for use, and similar technological characteristics and principles of operation as the predicate devices.

The minor technological differences between the invendoscopy E210 System and its predicate devices raise no new issues of safety or effectiveness.

Performance data demonstrate that the device is as safe and effective as the predicate devices. Thus, the invendoscopy E210 System is substantially equivalent to its predicate devices.