K Number
K181756
Device Name
Gangi-SoftGuard Coaxial Needle, Gangi-HydroGuard Coaxial Needle
Manufacturer
Date Cleared
2018-12-18

(169 days)

Product Code
Regulation Number
876.1075
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
As a guiding needle in obtaining core biopsy samples from soft tissue such as liver, kidney, spleen, lymph nodes and various soft tissue lesions.
Device Description
Gangi-SoftGuard Coaxial Needle together with Gangi-HydroGuard Coaxial Needle forms the Gangi Coaxial Needle family. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are manually operated, sterile, single use coaxial guiding needles with a spring loaded blunt-tip stylet, to be used as a guiding needle for biopsy instruments in procedures in soft tissue. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle has the same intended use. Coaxial Needle and Gangi-SoftGuard Gangi-HydroGuard Coaxial Needle are gastroenterological, manually operated, sterile, single use coaxial introducer needles. Both Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle consists of three parts: a needle (cannula) provided with a trocar stylet, and a spring-loaded blunt tip stylet. The difference from Gangi-SoftGuard Coaxial Needle is that Gangi-HydroGuard Coaxial Needle has a Luer hub located on the blunt stylet housing and the blunt stylet is hollow and has a distal tip hole. This enables injection of fluid without the need to remove the blunt stylet.
More Information

No
The device description and performance studies focus on the mechanical and material properties of a manually operated biopsy needle, with no mention of AI or ML capabilities.

No
The device is used as a guiding needle for obtaining biopsy samples, which is a diagnostic procedure, not a therapeutic one.

Yes

Explanation: The device is used to obtain core biopsy samples from soft tissue. Biopsy is a procedure performed to obtain tissue for examination, which is a diagnostic purpose to determine the presence or characteristics of a disease.

No

The device description clearly details physical, manually operated needles with hardware components (cannula, stylets, hubs). There is no mention of software as the primary or sole component.

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

Here's why:

  • Intended Use: The intended use is "As a guiding needle in obtaining core biopsy samples from soft tissue...". This describes a surgical or interventional procedure to collect a sample from the body.
  • Device Description: The description details a "coaxial guiding needle" used for "biopsy instruments in procedures in soft tissue." This is a tool used during a medical procedure, not for testing samples outside the body.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine or test biological samples (blood, tissue, etc.) in vitro (in a lab setting). The focus is on the collection of the sample itself.

IVD devices are specifically designed to perform tests on samples taken from the human body to provide information for diagnosis, monitoring, or screening. This device's function is to facilitate the collection of the sample, not the analysis of it.

N/A

Intended Use / Indications for Use

As a guiding needle in obtaining core biopsy samples from soft tissue such as liver, kidney, spleen, lymph nodes and various soft tissue lesions.

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

FCG

Device Description

Gangi-SoftGuard Coaxial Needle together with Gangi-HydroGuard Coaxial Needle forms the Gangi Coaxial Needle family. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are manually operated, sterile, single use coaxial guiding needles with a spring loaded blunt-tip stylet, to be used as a guiding needle for biopsy instruments in procedures in soft tissue. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle has the same intended use.

Coaxial Needle and Gangi-SoftGuard Gangi-HydroGuard Coaxial Needle are gastroenterological, manually operated, sterile, single use coaxial introducer needles. Both Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle consists of three parts: a needle (cannula) provided with a trocar stylet, and a spring-loaded blunt tip stylet. The difference from Gangi-SoftGuard Coaxial Needle is that Gangi-HydroGuard Coaxial Needle has a Luer hub located on the blunt stylet housing and the blunt stylet is hollow and has a distal tip hole. This enables injection of fluid without the need to remove the blunt stylet.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Conventional imaging guidance equipment excluding MRI

Anatomical Site

liver, kidney, spleen, lymph nodes and various soft tissue lesions.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

The users are physicians trained in percutaneous image-guided biopsy sampling of soft tissue.
Standard clinical setting for percutaneous imaging-guided biopsy sampling excluding in Magnetic Resonance Imaging (MRI) equipment.

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)

Testing in the form of bench testing was performed to evaluate the performance and functionality to evaluate the device against requirements specification. The devices have been subjected to compliance testing to voluntary standards e.g. ISO 7864, ISO 9626, ISO 10993-7, ISO 10993-1, ISO 11607-1.

Results from verification and validation testing demonstrates that conformance to applicable technical requirements specification and user needs have been met and substantial equivalence has been demonstrated.

Biocompatibility testing: The material used in Gangi-SoftGuard Coaxial Needle and Gang-HydroGuard Coaxial Needle has been tested for biocompatibility in accordance with ISO 10993 for externally communicating devices in contact with tissue for 24 hours or less. The material in direct patient contact is the cannula needle and stylets made of stainless steel AISI 304 and stainless steel AISI 302. Gangi-SoftGuard Coaxial Needle and Gang-HydroGuard Coaxial Needle have successfully been tested for:

  • Cytotoxicity
  • Sensitization
  • Intracutaneously irritation
  • Acute Systemic Toxicity
  • Pyrogenicity
    The test results verify that the biocompatibility criteria given in ISO 10993 are fulfilled. AprioMed concludes that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is non-toxic and biocompatible.

Performance testing - Bench:

  • Qualification metal tubing: The stainless-steel tubing is qualified in compliance with ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods, and conformity demonstrated.
  • Qualification of Needle component: The needle used for Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are qualified in compliance with ISO7864:2016 Sterile hypodermic needles for single use -Requirements and test methods.
  • Conical Fittings: The Luer lock fittings used for Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are qualified in compliance with ISO 594 Conical fittings with a 6% (Luer) taper for syringes, needles and certain other medical equipment, and conformity demonstrated.
  • Mechanical performance: The mechanical performance testing of Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle has passed all design requirements.
  • Verification of penetration force and spring: The penetration force and the spring force have been evaluated and passed all design requirements.

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.

K936194

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.

K863330

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

§ 876.1075 Gastroenterology-urology biopsy instrument.

(a)
Identification. A gastroenterology-urology biopsy instrument is a device used to remove, by cutting or aspiration, a specimen of tissue for microscopic examination. This generic type of device includes the biopsy punch, gastrointestinal mechanical biopsy instrument, suction biopsy instrument, gastro-urology biopsy needle and needle set, and nonelectric biopsy forceps. This section does not apply to biopsy instruments 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 (performance standards).(2) Class I for the biopsy forceps cover and the non-electric biopsy forceps. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.

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 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.

December 18, 2018

AprioMed AB Katrin Svensson Director Quality & Regulatory Affairs Virdings Allé 28 Uppsala, 75450 Sweden

Re: K181756 Trade/Device Name: Gangi-SoftGuard Coaxial Needle Gangi-HydroGuard Coaxial Needle Regulation Number: 21 CFR§ 876.1075 Regulation Name: Gastroenterology-urology biopsy instrument Regulatory Class: II Product Code: FCG Dated: November 12, 2018 Received: November 16, 2018

Dear Katrin Svensson:

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 mav, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be avare that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see

https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,

Daniel G. Walter Jr -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

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K181756

Device Name Gangi-SoftGuard Coaxial Needle Gangi-HydroGuard Coaxial Needle

Indications for Use (Describe)

As a guiding needle in obtaining core biopsy samples from soft tissue such as liver, kidney, spleen, lymph nodes and various soft tissue lesions.

☑ Prescription Use (Part 21 CFR 801 Subpart D)□ Over-The-Counter Use (21 CFR 801 Subpart C)
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

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

3

5 510(K) SUMMARY

As Required by 21 CFR 807.92(c) 510(k) Summary

Submitter/510(k) Holder 5.1

AprioMed AB Virdings Allé 28 Uppsala, SWEDEN 754 50

Contact Person: Katrin Svensson, Director Quality & Regulatory Affairs Telephone: +46 (0) 73- 345 14 40

Date Prepared: December 12, 2018

5.2 Device

| Proprietary Name: | Gangi-SoftGuard Coaxial Needle
Gangi-HydroGuard Coaxial Needle |
|----------------------|-------------------------------------------------------------------|
| Common/Usual Names: | Biopsy Needle |
| Regulation number: | 21 CFR 876.1075 |
| Classification Name: | Gastroenterology-Urology Biopsy Instrument |
| Class: | II |
| Product Code: | FCG |
| 510(k) number: | K181756 |

Predicate Devices and Reference Device identification 5.3

Predicate device:

Proprietary Name:Bard TruGuide Disposable Coaxial Biopsy Needle
Common/Usual Names:Biopsy Needle
Regulation number:21 CFR 876.1075
Classification Name:Gastroenterology-Urology Biopsy Instrument
Class:II
510(k) number:K936194
Product Code:FCG

Reference device:

Proprietary Name:Surgineedle™ Pneumoperitoneum Needle
Common/Usual Names:Pneumoperitoneum Needle
Regulation number:21 CFR 876.1500
Classification Name:Endoscope and accessories
Class:II
510(k) number:K863330
Product Code:FHO

4

5.4 Device Description

Gangi-SoftGuard Coaxial Needle together with Gangi-HydroGuard Coaxial Needle forms the Gangi Coaxial Needle family. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are manually operated, sterile, single use coaxial guiding needles with a spring loaded blunt-tip stylet, to be used as a guiding needle for biopsy instruments in procedures in soft tissue. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle has the same intended use.

Coaxial Needle and Gangi-SoftGuard Gangi-HydroGuard Coaxial Needle are gastroenterological, manually operated, sterile, single use coaxial introducer needles. Both Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle consists of three parts: a needle (cannula) provided with a trocar stylet, and a spring-loaded blunt tip stylet. The difference from Gangi-SoftGuard Coaxial Needle is that Gangi-HydroGuard Coaxial Needle has a Luer hub located on the blunt stylet housing and the blunt stylet is hollow and has a distal tip hole. This enables injection of fluid without the need to remove the blunt stylet.

Technological Characteristics ર્સ્ટ

Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are delivered with the trocar stylet inserted in the needle (cannula). When the trocar is exchanged to the blunt stylet, the blunt tip protrudes out from the distal end of the needle (cannula) which makes the coaxial needle tip non-traumatic. shielding the surroundings from the sharp needle (cannula tip).

The position of the coaxial needle is monitored using imaging technique. If resistance or hard surface is met when using the device, the blunt tip retracts into the needle (cannula), exposing the sharp needle (cannula) tip and enabling cutting through tissue. The retraction of the blunt tip can be prevented by pressing the proximal part of the stylet (covered by a plastic cap) or the proximal Luer hub on the housing.

After cutting through the tissue with the sharp needle (cannula) and the resistance is reduced, the hollow blunt stylet tip springs back i.e., the non-traumatic tip will once again shield the surrounding tissue from the sharp needle (cannula tip).

When the targeted lesion has been reached, Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle enables biopsy to be performed per normal hospital routines.

The materials used for construction of the needles are typical for this type of medical device. The only material in direct patient contact is stainless steel AISI 304 and stainless steel AISI 302. The needles are designed in accordance with ISO 7864 - Sterile hypodermic needles for single use.

5

5.6 Indications for Use

Gangi-SoftGuard Coaxial Needle is intended as a guiding needle in obtaining core biopsy samples from soft tissue such as liver, kidney, spleen, lymph nodes and various soft tissue lesions.

Gangi-HydroGuard Coaxial Needle is intended as a guiding needle in obtaining core biopsy samples from soft tissue such as liver, kidney, spleen, lymph nodes and various soft tissue lesions.

Substantial Equivalence 5.7

AprioMed AB has determined that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are substantially equivalent to the predicate device based on the Indications for Use, compliance with internationally recognized design and performance standards, material specifications, use environments, and performance. The differences between subject devices and the predicate device used for the same Indications for Use do not raise new issues of safety and effectiveness.

A substantial equivalence comparison table of subject devices, Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle and the predicate device, Bard TruGuide Disposable Coaxial Biopsy Needle (K936194) is provided in Table 5-1.

6

Table 5-1: Substantial equivalence table
ParameterSubject DevicesPredicate Device
Proprietary NameGangi-SoftGuard Coaxial Needle
Gangi-HydroGuard Coaxial NeedleBard TruGuide Disposable Coaxial Biopsy Needle
510(k)This 510(k) applicationK936194
Device Classification
NameBiopsy needleBiopsy needle
Product CodeFCGFCG
Regulation
descriptionGastroenterology-Urology Biopsy
InstrumentsGastroenterology-Urology Biopsy
Instruments
Regulation Number21 CFR 876.107521 CFR 876.1075
Intended Use/
Indications for UseAs a guiding needle in obtaining core
biopsy samples from soft tissue such as
liver, kidney, spleen, lymph nodes and
various soft tissue lesions.The Coaxial biopsy needle guide is
intended for use as a guiding needle in
obtaining core biopsy samples from soft
tissue such as liver, kidney, spleen, lymph
nodes and various soft tissue lesions.
Device typeCoaxial introducer needle with a spring
loaded blunt tip stylet/hollow blunt tip styletCoaxial introducer needle with a blunt tip
stylet
Visualization
techniqueConventional imaging guidance equipment
excluding MRIConventional imaging guidance equipment
excluding MRI
Single UseYesYes
SterileYes, Ethylene OxideYes, Ethylene Oxide
Needle materialStainless SteelStainless Steel
Needle HubLuerLuer
Needle sizeGangi-SoftGuard Coaxial Needle:
12G-17G
7,1-17,1 cm
Gangi-HydroGuard Coaxial Needle:
15G-17G
12,1-17,1 cm11G-19G
7.0-17.8 cm
Needle penetration
depth17.1 cm free length17.8 cm free length
Anatomical sitesLiver, kidney, spleen, lymph nodes and
various soft tissue lesionsLiver, kidney, spleen lymph nodes and
various soft tissue lesions

Table 5-1: Substantial equivalence table

7

5.7.1 Intended Use/Indication for Use

AprioMed has determined that the intended use of Gangi-HydroGuard and Gangi-SoftGuard coaxial biopsy needle are substantially equivalent to the predicate device.

5.7.2 Materials

AprioMed has determined that the Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are substantially equivalent to the predicate device based on materials. Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle and the predicate is constructed with medical grade stainless steel. Gangi Coaxial Needle material also fulfill the, by FDA, recognized consensus standard, ISO 9626 Stainless Steel Needle Tubing for the Manufacture of Medical Devices.

5.7.3 Use Environment

Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is intended to be used in a standard clinical setting for percutaneous imaging-guided biopsy sampling excluding in Magnetic Resonance Imaging (MRI) equipment. The users are physicians trained in percutaneous image-guided biopsy sampling of soft tissue. AprioMed has determined that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are substantially equivalent to the predicate device based on the use environment.

5.7.4 Size, stylet size and penetration depth

AprioMed has determined that the sizes, stylet size and penetration depth of Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is substantially equivalent to the predicate device.

5.7.5 Tip design

AprioMed has determined that the tip design of Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is substantially equivalent to the predicate device.

5.7.6 Penetration force

AprioMed has determined that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are substantially equivalent to the predicate device with respect to needle penetration.

5.7.7 Safety Features

AprioMed believes that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is substantially equivalent to the predicate device in respect to safety features. Neither Gangi-SoftGuard Coaxial Needle, Gangi-HydroGuard Coaxial Needle nor the predicate has any specific safety features.

Summary of non-clinical and performance testing 5.8

Testing in the form of bench testing was performed to evaluate the performance and functionality to evaluate the device against requirements specification. The devices have been subjected to compliance testing to voluntary standards e.g. ISO 7864, ISO 9626, ISO 10993-7, ISO 10993-1, ISO 11607-1.

Results from verification and validation testing demonstrates that conformance to applicable technical requirements specification and user needs have been met and substantial equivalence has been demonstrated.

8

5.8.1 Biocompatibility testing

The material used in Gangi-SoftGuard Coaxial Needle and Gang-HydroGuard Coaxial Needle has been tested for biocompatibility in accordance with ISO 10993 for externally communicating devices in contact with tissue for 24 hours or less. The material in direct patient contact is the cannula needle and stylets made of stainless steel AISI 304 and stainless steel AISI 302. Gangi-SoftGuard Coaxial Needle and Gang-HydroGuard Coaxial Needle have successfully been tested for:

  • Cytotoxicity ।
  • Sensitization ।
  • Intracutaneously irritation -
  • Acute Systemic Toxicity -
  • -Pyrogenicity

The test results verify that the biocompatibility criteria given in ISO 10993 are fulfilled. AprioMed concludes that Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle is non-toxic and biocompatible.

5.8.2 Performance testing - Bench

5.8.2.1 Qualification metal tubing

The stainless-steel tubing is qualified in compliance with ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods, and conformity demonstrated.

Qualification of Needle component 5.8.2.2

The needle used for Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are qualified in compliance with ISO7864:2016 Sterile hypodermic needles for single use -Requirements and test methods.

5.8.2.3 Conical Fittings

The Luer lock fittings used for Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle are qualified in compliance with ISO 594 Conical fittings with a 6% (Luer) taper for syringes, needles and certain other medical equipment, and conformity demonstrated.

5.8.2.4 Mechanical performance

The mechanical performance testing of Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle has passed all design requirements.

5.8.2.5 Verification of penetration force and spring

The penetration force and the spring force have been evaluated and passed all design requirements.

Summary and Conclusion 5.9

Based on the above discussion, the non-clinical testing supports the safety of the device and demonstrates that the Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle should perform as intended in the specified use conditions. The data supports the substantial equivalence determination between the Gangi-SoftGuard Coaxial Needle and Gangi-HydroGuard Coaxial Needle and the predicate device.