K Number
K180165
Device Name
Habib EndoHPB
Manufacturer
Date Cleared
2018-03-20

(57 days)

Product Code
Regulation Number
876.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Habib EndoHPB is a radiofrequency (RF) catheter which provides bipolar energy to perform partial or complete ablation of tissue in the pancreatic and biliary tracts. The Habib EndoHPB is also intended for use to ablate malignant or benign tissue, notably to perform endoscopic biliary drainage or decompression, prior to stent placement or afterwards, to clear occluded stent.
Device Description
The Habib EndoHPB is an 8F RF bipolar catheter that consists of a catheter with 2 ring electrodes, introduced via an endoscope's biopsy channel. It has an attached cable which connects the device to an RF Generator. RF is applied to the two electrodes at the top of the catheter so that heat is applied to tissue surrounding the catheter.
More Information

Not Found

No
The summary describes a radiofrequency ablation catheter and its intended use and performance testing. There is no mention of AI or ML technology in the device description, intended use, or performance studies. The "Mentions AI, DNN, or ML" field is explicitly marked as "Not Found".

Yes

The device is designed to perform "partial or complete ablation of tissue" and "to ablate malignant or benign tissue" in the pancreatic and biliary tracts, which are therapeutic interventions.

No

The device is an ablation catheter, meaning its primary function is to destroy tissue, not diagnose conditions. It is used for therapeutic purposes, such as clearing occluded stents or performing tissue ablation.

No

The device description explicitly states it is a physical catheter with electrodes and a cable, connecting to an RF Generator. This indicates it is a hardware device, not software-only.

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

Here's why:

  • Intended Use: The intended use clearly describes a device used in vivo (within the body) to perform tissue ablation in the pancreatic and biliary tracts. IVD devices are used in vitro (outside the body) to examine specimens derived from the human body (like blood, urine, tissue samples) to provide information for diagnosis, monitoring, or screening.
  • Device Description: The description details a catheter introduced via an endoscope's biopsy channel to apply energy directly to tissue within the body. This is consistent with an in vivo therapeutic or surgical device, not an in vitro diagnostic device.
  • Lack of IVD Characteristics: There is no mention of analyzing biological specimens, using reagents, or providing diagnostic information based on laboratory testing.

Therefore, the Habib EndoHPB is a therapeutic/surgical device used for tissue ablation, not an IVD.

N/A

Intended Use / Indications for Use

The Habib EndoHPB is a radiofrequency (RF) catheter which provides bipolar energy to perform partial or complete ablation of tissue in the pancreatic and biliary tracts.

The Habib EndoHPB is also intended for use to ablate malignant or benign tissue, notably to perform endoscopic biliary drainage or decompression, prior to stent placement or afterwards, to clear occluded stent.

Product codes (comma separated list FDA assigned to the subject device)

KNS

Device Description

The Habib EndoHPB is an 8F RF bipolar catheter that consists of a catheter with 2 ring electrodes, introduced via an endoscope's biopsy channel. It has an attached cable which connects the device to an RF Generator. RF is applied to the two electrodes at the top of the catheter so that heat is applied to tissue surrounding the catheter.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Pancreatic and Biliary Tracts

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Compared to the predicate device, there has been no change or modification in design, material, energy source or manufacturing process in the subject device. The only modifications that have required performance testing are the following:

  • New claimed shelf-life; and
  • Compatibility with new generators.

The results obtained support the claimed 3-year shelf-life and the compatibility with new generators.

The subject device indications for use is significantly different when compared to the predicate device. Therefore, multiple clinical studies are being submitted to demonstrate that the Habib EndoHPB is as safe and effective as the predicate. All the clinical studies provided within this submission have been performed using the subject device and clearly support the new intended use.

Electromagnetic compatibility and electrical safety testing have been performed on the Habib EndoHPB to validate that it meets the requirements of the latest Recognized Consensus Standards:

  • IEC 60601-1 Medical Electrical Equipment - Part 1: General requirements for basic safety and essential performance
  • IEC 60601-1-2 Medical Electrical Equipment -- Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Disturbances -Requirements and Tests
  • IEC 60601-2-2 Medical Electrical Equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
  • IEC 60601-2-18 Medical Electrical Equipment – Part 2-18: Particular Requirements for the Basic Safety and Essential Performance of Endoscopic Equipment

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K083292

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 876.4300 Endoscopic electrosurgical unit and accessories.

(a)
Identification. An endoscopic electrosurgical unit and accessories is a device used to perform electrosurgical procedures through an endoscope. This generic type of device includes the electrosurgical generator, patient plate, electric biopsy forceps, electrode, flexible snare, electrosurgical alarm system, electrosurgical power supply unit, electrical clamp, self-opening rigid snare, flexible suction coagulator electrode, patient return wristlet, contact jelly, adaptor to the cord for transurethral surgical instruments, the electric cord for transurethral surgical instruments, and the transurethral desiccator.(b)
Classification. Class II (performance standards).

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March 20, 2018

EMcision Ltd. % Louis-Paul Marin President LOK North America Inc. 2025 Michelin LAVAL, H71 5b7 CANADA

Re: K180165

Trade/Device Name: Habib EndoHPB Regulation Number: 21 CFR 876.4300 Regulation Name: Endoscopic electrosurgical unit and accessories Regulatory Class: Class II Product Code: KNS Dated: January 17, 2018 Received: January 22, 2018

Dear Louis-Paul Marin:

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

1

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,

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

510(k) Number (if known) K180165

Device Name Habib EndoHPB

Indications for Use (Describe)

The Habib EndoHPB is a radiofrequency (RF) catheter which provides bipolar energy to perform partial or complete ablation of tissue in the pancreatic and biliary tracts.

The Habib EndoHPB is also intended for use to ablate malignant or benign tissue, notably to perform endoscopic biliary drainage or decompression, prior to stent placement or afterwards, to clear occluded stent.

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

1.Type of submissionTraditional
2.Preparation DateJanuary 17, 2018
3.Submitter AddressEMcision Ltd.
Department of Surgery
Hammersmith Hospital
DuCane Road
London W12 0HS
United Kingdom
Phone: 1 (514) 994-9649
Contact: François Poulin
4.Contact PersonLouis-Paul Marin
President of LOK North America Inc.
Phone: 1 (450) 781-1578 ext. 225
Fax: 1 (450) 681-9663
Email: marin.lp@lok-corporation.com
5.Identification of the Device
Proprietary Name/Trade NameHabib EndoHPB
Regulation DescriptionEndoscopic electrosurgical unit and accessories
Device ClassificationII
Regulation Number876.4300
PanelGastroenterology/Urology
Product CodeKNS
6.Identification of the Predicate
Predicate Device NameHabib EndoHPB

7. Purpose of this Submission

510(k) Number

The main purpose of this submission is to gain clearance to expand the indication for use of the previously cleared Habib EndoHPB (K083292) by including a treatment indication and update the original 510(k) submission to current configurations in terms of shelf life duration and insignificant changes to the labeling.

K083292

8. Intended use of the Subject Device

The Habib EndoHPB is a radiofrequency (RF) catheter which provides bipolar energy to perform partial or complete ablation of tissue in the pancreatic and biliary tracts.

4

The Habib EndoHPB is also intended for use to ablate malignant or benign tissue, notably to perform endoscopic biliary drainage or decompression, prior to stent placement or afterwards, to clear occluded stent.

Device Description 9.

The Habib EndoHPB is an 8F RF bipolar catheter that consists of a catheter with 2 ring electrodes, introduced via an endoscope's biopsy channel. It has an attached cable which connects the device to an RF Generator. RF is applied to the two electrodes at the top of the catheter so that heat is applied to tissue surrounding the catheter.

10. Performance Data

Compared to the predicate device, there has been no change or modification in design, material, energy source or manufacturing process in the subject device. The only modifications that have required performance testing are the following:

  • New claimed shelf-life; and -
  • -Compatibility with new generators.

The results obtained support the claimed 3-year shelf-life and the compatibility with new generators.

11. Clinical Data

The subject device indications for use is significantly different when compared to the predicate device. Therefore, multiple clinical studies are being submitted to demonstrate that the Habib EndoHPB is as safe and effective as the predicate. All the clinical studies provided within this submission have been performed using the subject device and clearly support the new intended use.

12. Electromagnetic and Electrical Testing

Electromagnetic compatibility and electrical safety testing have been performed on the Habib EndoHPB to validate that it meets the requirements of the latest Recognized Consensus Standards:

  • -IEC 60601-1 Medical Electrical Equipment - Part 1: General requirements for basic safety and essential performance
  • -IEC 60601-1-2 Medical Electrical Equipment -- Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Disturbances -Requirements and Tests
  • -IEC 60601-2-2 Medical Electrical Equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
  • -IEC 60601-2-18 Medical Electrical Equipment – Part 2-18: Particular Requirements for the Basic Safety and Essential Performance of Endoscopic Equipment

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13. Substantial Equivalence Determination

The overall technological comparisons between the subject device and the predicate are summarized in the following table:

ItemPredicate DeviceSubject Device
Habib EndoHPB
(K083292)Habib EndoHPB
Substantial Equivalence
ClassificationIIII
Code of Federal
Regulation876.4300876.4300
Prescription Medical
DevicesYesYes
Indications for UseThe Habib EndoHPB is
intended to be used in the
coagulation of tissue during
Endoscopic surgical procedures
in the Gastro-intestinal Tract.The Habib EndoHPB is a
radiofrequency (RF) catheter
which provides bipolar energy to
perform partial or complete
ablation of tissue in the
pancreatic and biliary tracts.

The Habib EndoHPB is also
intended for use to ablate
malignant or benign tissue,
notably to perform endoscopic
biliary drainage or
decompression, prior to stent
placement or afterwards, to clear
occluded stent. |
| Anatomical sites | Gastro-intestinal Tract | Pancreatic and Biliary Tracts |
| Operating Mode | Bipolar RF energy | Bipolar RF energy |
| Active Electrode
Material | Stainless Steel | Stainless Steel |
| Catheter Size | 7.5F | 8F |
| Number of Active
Electrodes | 2 | 2 |
| Electrode Shape | Central electrode assembly and
outer ring electrode | Central electrode assembly and
outer ring electrode |
| Delivery Mode | Endoscopic | Endoscopic |
| Single Use | Yes | Yes |
| Sterilization | ETO | ETO |
| Packaging | Coil inside a Tyvek pouch
mounted in a carton | Coil inside a Tyvek pouch
mounted in a carton |
| Shelf-Life | 6 months | 3 years |
| Compatible
Generators | RITA Medical Systems 1500
RITA Medical Systems 1500X
Radionics Cosman Coagulator
CC-1 | RITA Medical Systems 1500
RITA Medical Systems 1500X
Olympus ESG-100
Genii GI 4000
ERBE VIO 200 |

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ERBATOM ICC 200, 300, 350
---------------------------

The evidence collected in the table above clearly demonstrate that, except for insignificant differences, the subject device, the Habib EndoHPB, is identical to the previously cleared Habib EndoHPB (K083292) in terms of fundamental technology, design attributes, materials, features, functions, and performance.

The differences between the subject and the predicate device are as follows:

  • -Expanded indications for use;
  • Extended shelf-life; and -
  • Compatibility with more generators. -

Performance data provided within this submission support the substantial equivalence of the subject device to the predicate. Additionally, clinical and performance data provided demonstrated the Habib EndoHPB to be safe and effective for the expanded indication for use, extended shelf-life, and compatibility with additional generators.

14. Conclusion

The information provided by EMcision in this submission demonstrates that the subject device Habib EndoHPB is substantially equivalent to the currently cleared predicate device (K083292) and raises no new questions of safety and effectiveness.