K Number
K173431
Device Name
Towako Transmyometrial Embryo Transfer Set
Date Cleared
2018-05-18

(197 days)

Product Code
Regulation Number
884.6110
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Towako Transmyometrial Embryo Transfer Set is indicated for transfering IVF embryo(s) into the endometrial cavity through the myometrium for patients undergoing Assisted Reproductive Procedures.
Device Description
The Towako Transmyometrial Embryo Transfer Set is comprised of an echo tipped stainless steel 19 Gauge needle, matching stainless steel stylet and a 2 Fr polyethylene transfer catheter. The stylet fits into the needle with both bevels flush, and is inserted with the stylet in-situ to prevent blockage of the needle lumen and provide stiffness to the needle during insertion. When the needle is positioned correctly, the stylet is removed and the transfer catheter with the embryos loaded is inserted to allow embryo transfer. The device is used when difficulty is experienced in transferring embryos into the uterine cavity using a standard trans-cervical route. The Towako Transmyometrial Embryo Transfer Set is a sterile and single-use device.
More Information

Not Found

No
The device description and performance studies focus on mechanical and material properties, with no mention of AI/ML or related concepts like image processing, training sets, or performance metrics typically associated with AI/ML algorithms.

No
The device is used to assist in the transfer of embryos, not to treat a disease or condition. Its purpose is procedural assistance in IVF rather than therapeutic effect.

No

The device is described as an embryo transfer set used for "transferring IVF embryo(s) into the endometrial cavity through the myometrium." This is a therapeutic procedure, not a diagnostic one. While it mentions an "echo tipped" needle, this seems to be for guidance during the transfer, not for diagnosing a condition.

No

The device description clearly outlines physical components (needle, stylet, catheter) and performance studies related to mechanical properties and biocompatibility, indicating it is a hardware-based medical device.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to provide information for diagnosis, monitoring, or screening.
  • Device Function: The description clearly states that the Towako Transmyometrial Embryo Transfer Set is used to transfer embryos into the uterus. It is a physical device used in a medical procedure, not a test performed on a sample.
  • Intended Use: The intended use is for "transferring IVF embryo(s) into the endometrial cavity through the myometrium." This is a procedural use, not a diagnostic one.

The device is a surgical/procedural instrument used in assisted reproductive technology, not a diagnostic test.

N/A

Intended Use / Indications for Use

The Towako Transmyometrial Embryo Transfer Set is indicated for transferring IVF embryo(s) into the endometrial cavity through the myometrium for patients undergoing Assisted Reproductive Procedures.

Product codes

MOF, MQF

Device Description

The Towako Transmyometrial Embryo Transfer Set is comprised of an echo tipped stainless steel 19 Gauge needle, matching stainless steel stylet and a 2 Fr polyethylene transfer catheter. The stylet fits into the needle with both bevels flush, and is inserted with the stylet in-situ to prevent blockage of the needle lumen and provide stiffness to the needle during insertion. When the needle is positioned correctly, the stylet is removed and the transfer catheter with the embryos loaded is inserted to allow embryo transfer. The device is used when difficulty is experienced in transferring embryos into the uterine cavity using a standard trans-cervical route.
The Towako Transmyometrial Embryo Transfer Set is a sterile and single-use device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

endometrial cavity, myometrium, uterine cavity

Indicated Patient Age Range

patients undergoing Assisted Reproductive Procedures.

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

The following design verification and validation activities were performed:

  • Biocompatibility per ISO 10993-1:2009
    • Cytotoxicity (ISO 10993-5:2009)
    • Sensitization (ISO 10993-10:2010)
    • Irritation (ISO 10993-10:2010)
  • Mouse Embryo Assay (MEA) Two cell mouse embryos were exposed to device extracts and cultured at 37°C in an atmosphere containing 5% CO2. The percent of embryos developed to the expanded blastocysts stage within 72 hours were assessed in comparison with the control group. The acceptance criteria for this test is ≥80% development to blastocyst at 72 hours.
  • Endotoxin testing per USP (

§ 884.6110 Assisted reproduction catheters.

(a)
Identification. Assisted reproduction catheters are devices used in in vitro fertilization (IVF), gamete intrafallopian transfer (GIFT), or other assisted reproduction procedures to introduce or remove gametes, zygote(s), preembryo(s), and/or embryo(s) into or from the body. This generic type of device may include catheters, cannulae, introducers, dilators, sheaths, stylets, and component parts.(b)
Classification. Class II (special controls) (mouse embryo assay information, endotoxin testing, sterilization validation, design specifications, labeling requirements, biocompatibility testing, and clinical testing).

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Image /page/0/Picture/0 description: The image contains 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 is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

May 18, 2018

William A. Cook Australia PTY LTD Gordana Pozvek Senior Regulatory Affairs Specialist 95 Brandl Street Eight Mile Plains, 4113 Queensland AUSTRALIA

Re: K173431

Trade/Device Name: Towako Transmyometrial Embryo Transfer Set Regulation Number: 21 CFR 884.6110 Regulation Name: Assisted Reproduction Catheters Regulatory Class: Class II Product Code: MOF Dated: April 17, 2018 Received: April 20, 2018

Dear Gordana Pozvek:

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

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manufacturing practice requirements as set forth in the quality systems (OS) 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 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.

Benjamin R. Fisher -S

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

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Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known)

K173431

Device Name

Towako Transmyometrial Embryo Transfer Set

Indications for Use (Describe)

The Towako Transmyometrial Embryo Transfer Set is indicated for transfering IVF embryo(s) into the endometrial cavity through the myometrium for patients undergoing Assisted Reproductive Procedures.

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.

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.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"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."

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WILLIAM A. COOK AUSTRALIA PTY. LTD. 95 BRANDL STREET BRISBANE TECHNOLOGY PARK, EIGHT MILE PLAINS BRISBANE, QLD 4113, AUSTRALIA PHONE: 1800.777.222 FAX: +61.7.3841.1288 WWW.COOKMEDICAL.COM ABN 79 005 526 723

510(k) Summary - K173431

SUBMITTED BY:

William A. Cook Australia Pty Ltd 95 Brandl Street Eight Mile Plains OLD 4113 Australia

Contact Person:Gordana Pozvek Ph.D.
Tel:+61 (7) 3841 1188
Fax:+61 (7) 3841 3905
E-mail:Gordana.Pozvek@CookMedical.com

Date Prepared: May 17, 2018

DEVICE IDENTIFICATION:

Trade Name:Towako Transmyometrial Embryo Transfer Set
Common Name:Embryo Transfer Catheter
Regulation No:21 CFR 884.6110, Assisted Reproduction Catheter
Product Code:MQF - Catheter, Assisted Reproduction
Regulatory Class:II

PREDICATE DEVICE:

Transmyometrial Embryo Transfer Set (K983595)

The predicate device has not been subject to a design-related recall.

DEVICE DESCRIPTION:

The Towako Transmyometrial Embryo Transfer Set is comprised of an echo tipped stainless steel 19 Gauge needle, matching stainless steel stylet and a 2 Fr polyethylene transfer catheter. The stylet fits into the needle with both bevels flush, and is inserted with the stylet in-situ to prevent blockage of the needle lumen and provide stiffness to the needle during insertion. When the needle is positioned correctly, the stylet is removed and the transfer catheter with the embryos loaded is inserted to allow embryo transfer. The device is used when difficulty is experienced in transferring embryos into the uterine cavity using a standard trans-cervical route.

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The Towako Transmyometrial Embryo Transfer Set is a sterile and single-use device.

INDICATIONS FOR USE:

The Towako Transmyometrial Embryo Transfer Set is indicated for transferring IVF embryo(s) into the endometrial cavity through the myometrium for patients undergoing Assisted Reproductive Procedures.

COMPARISON OF INTENDED USE AND TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE:

The Towako Transmyometrial Embryo Transfer Set is a modification of the Transmyometrial Embryo Transfer Set (K983595).

Intended Use

The indication for use statements of the subject and predicate devices are shown below:

Subject DevicePredicate Device
K173431K983595
The Towako Transmyometrial Embryo
Transfer Set is indicated for transferring
IVF embryo(s) into the endometrial
cavity through the myometrium for
patients undergoing Assisted
Reproductive Procedures.The Transmyometrial Embryo Transfer
Sets are used for transferring IVF
embryo(s) into the endometrial cavity
through the myometrium. These
devices are sterile and intended for one-
time use. The Transmyometrial
Embryo Transfer Set should not be used
on a patient with an active vaginal or
intrauterine infection, a sexually
transmitted disease, a recent uterine
perforation, cervical stenosis or other
cervical abnormalities which would
preclude embryo transfer, a recent
caesarean section, a recent pregnancy
(or is currently pregnant), or if a patient
currently has an intrauterine device.

The indications for use statement has been modified from the predicate device to include wording that describes the patient population, remove descriptive information, and remove contraindication information. These modifications to the Indication for Use statement are for clarification only and do not impact the intended use or safety and effectiveness of the subject device.

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Technological Characteristics

Differences between the subject and predicate devices are as follows:

  • Replacement of the 17 G guide needle with 19 G stylet. The guide needle in the ● predicate device provides stiffness for insertion of the needle into the myometrium. The guide needle has been replaced with a stylet which also provides stiffness to the needle during insertion. In addition, the stylet also limits the introduction of foreign material into the needle.
  • The Transfer Catheter tubing, a fluid contacting material, has changed from Tetrafluoroethylene (NRT [TFE]) to Polyethylene.
  • Minor dimensional changes to the transfer catheter

The modifications listed above do not raise different questions of safety and effectiveness as compared to the predicate device.

PERFORMANCE DATA:

To support the modifications to the subject device, the following design verification and validation activities were performed:

  • Biocompatibility per ISO 10993-1:2009 ●
    • Cytotoxicity (ISO 10993-5:2009) O
    • Sensitization (ISO 10993-10:2010) O
    • O Irritation (ISO 10993-10:2010)
  • Mouse Embryo Assay (MEA) Two cell mouse embryos were exposed to device ● extracts and cultured at 37°C in an atmosphere containing 5% CO2. The percent of embryos developed to the expanded blastocysts stage within 72 hours were assessed in comparison with the control group. The acceptance criteria for this test is ≥80% development to blastocyst at 72 hours.
  • Endotoxin testing per USP (