(197 days)
Used to establish a percutaneous tract into the renal pelvis for catheter placement or stone manipulation.
Used under fluoroscopy or ultrasound for initial location and positioning within the renal collecting system during a percutaneous nephrostomy.
The Percutaneous Entry Set is comprised of a Skinny Needle® with Chiba Tip, a Disposable Two-Part Trocar Needle, 8 dilators and a wire guide.
The Skinny Needle® is comprised of a stainless steel stylet inserted through a hubbed stainless steel cannula. The cannula has gauge size of 22 with a length of 20 centimeters. The distal end of the cannula is a Chiba tip, beveled at a 30° angle.
The Disposable Two-Part Trocar Needle is comprised of a stainless steel beveled stylet which can be inserted through a hubbed stainless steel cannula. The cannula comes in a gauge of 18 with lengths in 15 and 20 centimeters. When the beveled stylet is inserted through the cannula, the length from the distal endpoint of the cannula to the proximal starting point of the bevel on the wire is 0-2 millimeters. Needles have an optional Echotip® design, consisting of a series of very small dimples on the surface of the needle tip that enables it to be visible under ultrasound.
The dilators are manufactured from polyethylene tubing in 6.0, 7.0, 8.0, 9.0, 10.0, 12.0, 14.0 and 16.0 French sizes. All dilators measure 20 centimeters in length and have 8 to 15 millimeter taper with a 0.040 inch diameter thru hole.
The wire guide is characterized by a heavy-duty shaft, with a gradual transition to a very flexible distal tip. This wire guide type is manufactured in a 0.038 inch diameter, and measures 80 centimeters in length with a 3 millimeter Safe-T-J tip. This wire guide is constructed of a polytetrafluoroethylene coated stainless steel.
The Percutaneous Entry Set will be supplied sterile and is intended for one-time use. The set is packaged in a peel-open pouch with a 3-year shelf life.
The Skinny Needle® with Chiba Tip is also available for sale individually.
The Skinny Needle® with Chiba Tip will be supplied sterile and is intended for one-time use. The set is packaged in a peel-open pouch with a 3-year shelf life.
The Disposable Two-Part Trocar Needle is also available for sale individually.
The Disposable Two-Part Trocar Needle will be supplied sterile and is intended for onetime use. The set is packaged in a peel-open pouch with a 3-year shelf life.
Here's an analysis of the provided text regarding the acceptance criteria and study for the medical device:
Please note that this document is a 510(k) summary, which focuses on demonstrating substantial equivalence to a predicate device. It is not a detailed clinical study report evaluating the performance of a new AI algorithm. Therefore, many of the typical questions regarding AI-specific acceptance criteria, test sets, ground truth establishment, or clinical effectiveness studies are not applicable directly to this submission.
The device in question is a Percutaneous Entry Set, Skinny Needle® with Chiba Tip, Disposable Two-part Trocar Needle, which is a physical medical device (needles, dilators, wire guides), not an AI software.
Therefore, the provided document does not contain information to answer questions 1, 2, 3, 4, 5, 6, 7, 8, and 9 in the context of an AI-powered device.
Instead, the document details performance data of the physical device to demonstrate its safety and effectiveness and substantial equivalence to a predicate device.
Acceptance Criteria and Study for the Percutaneous Entry Set and Needles (Physical Device)
This section outlines the performance testing done to ensure the physical device meets its intended design requirements and is substantially equivalent to a predicate device.
1. A table of acceptance criteria and the reported device performance
The document lists types of tests performed but does not provide specific numerical acceptance criteria (e.g., "tensile strength must be > X N") nor the quantitative results ("tensile strength was Y N"). It only states that the devices "met applicable design requirements" and that "the results of these tests provide reasonable assurance that the devices will perform as intended."
| Acceptance Criteria Category | Reported Device Performance Assessment |
|---|---|
| Biocompatibility | Met applicable design requirements |
| Sterilization | Met applicable design requirements |
| Packaging: Distribution & Stability | Met applicable design requirements |
| Shelf-life | Met applicable design requirements |
| Component Compatibility | Met applicable design requirements |
| Dilators: Tensile Test | Met applicable design requirements |
| Dilators: Tip Integrity Test | Met applicable design requirements |
| Dilators: Radiopacity Test | Met applicable design requirements |
| Needles: Hub Union Strength Test | Met applicable design requirements |
| Needles: Fluid Injection Test | Met applicable design requirements |
| Needles: Echogenicity Test | Met applicable design requirements |
| Needles: Corrosion Test | Met applicable design requirements |
2. Sample size used for the test set and the data provenance
The document does not specify the sample sizes used for each test. It mentions that testing was performed internally by the manufacturer (Cook Incorporated) and in accordance with recognized standards (ASTM F 623-99 (2013) and FDA's Guidance for the Content of Premarket Notifications for Conventional and Antimicrobial Foley Catheters). There is no mention of external data provenance (e.g., country of origin, retrospective/prospective clinical data) as these are non-clinical, bench-top, and lab-based tests of a physical device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This device is a physical medical instrument, and its performance is evaluated through engineering and materials testing, not by expert interpretation of images or data to establish a "ground truth." The ground truth for these types of tests is generally defined by engineering specifications and recognized test methods.
4. Adjudication method for the test set
Not applicable, for the same reasons as point 3. Testing involves objective measurements against established specifications.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is not an AI device, and therefore no MRMC study was performed to assess AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is a physical device, not an algorithm.
7. The type of ground truth used
For the safety and performance tests (e.g., tensile strength, corrosion, biocompatibility), the "ground truth" is typically defined by:
- Engineering specifications: Pre-defined thresholds and requirements based on the intended use and material properties.
- Recognized standards: Compliance with industry standards like ASTM F 623-99 (2013) and FDA guidance documents.
- Predicate device characteristics: Performance levels comparable to the legally marketed predicate device (K844090).
8. The sample size for the training set
Not applicable. This is not an AI device that requires a training set.
9. How the ground truth for the training set was established
Not applicable. This is not an AI device that requires a training set.
Summary for the Substantial Equivalence Determination:
The submission demonstrates substantial equivalence by showing that the subject devices (Percutaneous Entry Set, Skinny Needle® with Chiba Tip, Disposable Two-part Trocar Needle) have:
- Similar indications for use.
- Similar methods of operation.
- Similar fundamental technological characteristics as the predicate device (Percutaneous Nephrostomy Trocar System, American Edward Laboratories, K844090).
- Differences in design specifications, dimensions, and materials are supported by a battery of performance tests that confirm the devices "met applicable design requirements" and "will perform as intended," without raising new questions of safety or effectiveness.
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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 seal of the Department of Health & Human Services. To the right of that is the FDA logo in blue, with the words "U.S. FOOD & DRUG" stacked on top of the word "ADMINISTRATION".
May 17, 2019
Cook Incorporated Yan Li Regulatory Affairs Specialist 750 Daniels Way Bloomington, IN 47404
Re: K183035
Trade/Device Name: Percutaneous Entry Set, Skinny Needle® with Chiba Tip, Disposable Two-part Trocar Needle Regulatory Class: Unclassified Product Code: LJE Dated: April 10, 2019 Received: April 11, 2019
Dear Yan Li:
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. Although this letter refers to your product as a device, please be aware 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. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unfinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit. 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.
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); 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,
for
Glenn B. Bell, Ph.D. Assistant Division Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
K183035
Device Name
Percutaneous Entry Set
Indications for Use (Describe)
Used to establish a percutaneous tract into the renal pelvis for catheter placement or stone manipulation.
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)
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."
Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.
2
| Company Confidential |
|---|
| ---------------------- |
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Image /page/3/Picture/0 description: The image shows the logo for Cook Medical. The logo consists of the word "COOK" in white letters on a red square. Below the red square is the word "MEDICAL" in white letters on a dark red rectangle. The logo is simple and clean, and the colors are bold and eye-catching.
Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
K183035
Device Name
Skinny Needle® with Chiba Tip
Indications for Use (Describe)
Used under fluoroscopy or ultrasound for initial locationing within the renal collecting system during a percutaneous nephrostomy.
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."
{4}------------------------------------------------
Image /page/4/Picture/0 description: The image shows the logo for Cook Medical. The logo consists of the word "COOK" in large, white, sans-serif font on a red background. Below the word "COOK" is the word "MEDICAL" in white, sans-serif font on a smaller red rectangle. The registered trademark symbol is located to the right of the word "COOK".
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
K183035
Device Name Disposable Two-part Trocar Needle
Indications for Use (Describe)
Used under fluoroscopy or ultrasound for initial locationing within the renal collecting system during a percutaneous nephrostomy.
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)
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."
4
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
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Image /page/5/Picture/0 description: The image shows the logo for Cook Medical. The word "COOK" is in large, white, sans-serif font on a red background. Below the word "COOK" is the word "MEDICAL" in a smaller, white, sans-serif font on a darker red background.
COOK INCORPORATED
750 DANIELS WAY, P.O. BOX 48
BLOOMINGTON, IN 47402-0489 U.S.A
PHONE: 812.339.2235 TOLL FREE: 800.457.4500
WWW.COOKMEDICAL.COM
K183035 Page 1 of 4
5
2.0 510(k) Summary
Percutaneous Entry Set Skinny Needle® with China Tip Disposable Two-Part Trocar Needle Traditional 510(k) Summary 21 CFR §807.92 Date Prepared: October 31, 2018
Submitted By:
| Submission: | Traditional 510(k) Premarket Notification |
|---|---|
| Applicant: | Cook Incorporated |
| Contact: | Yan LiAndrew Breidenbach |
| Applicant Address: | Cook Incorporated750 Daniels WayBloomington, IN 47404 |
| Contact Phone: | (812) 335-3575 x104987 |
| Contact Fax: | (812) 332-0281 |
Device Information:
Trade Name:
Common Name: Regulation: Product Code: Device Class: Classification Panel: Percutaneous Entry Set Skinny Needle® with Chiba Tip Disposable Two-part Trocar Needle Catheter, Nephrostomy Not available LJE Unclassified Gastroenterology/Urology
Predicate Device:
- Percutaneous Nephrostomy Trocar System, American Edward Laboratories, -K844090
Device Description:
- Percutaneous Entry Set -
The Percutaneous Entry Set is comprised of a Skinny Needle® with Chiba Tip, a Disposable Two-Part Trocar Needle, 8 dilators and a wire guide.
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Image /page/6/Picture/0 description: The image shows the logo for Cook Medical. The logo consists of the word "COOK" in large, bold, white letters on a red background. Below the word "COOK" is the word "MEDICAL" in smaller, white letters, also on a red background.
The Skinny Needle® is comprised of a stainless steel stylet inserted through a hubbed stainless steel cannula. The cannula has gauge size of 22 with a length of 20 centimeters. The distal end of the cannula is a Chiba tip, beveled at a 30° angle.
The Disposable Two-Part Trocar Needle is comprised of a stainless steel beveled stylet which can be inserted through a hubbed stainless steel cannula. The cannula comes in a gauge of 18 with lengths in 15 and 20 centimeters. When the beveled stylet is inserted through the cannula, the length from the distal endpoint of the cannula to the proximal starting point of the bevel on the wire is 0-2 millimeters. Needles have an optional Echotip® design, consisting of a series of very small dimples on the surface of the needle tip that enables it to be visible under ultrasound.
The dilators are manufactured from polyethylene tubing in 6.0, 7.0, 8.0, 9.0, 10.0, 12.0, 14.0 and 16.0 French sizes. All dilators measure 20 centimeters in length and have 8 to 15 millimeter taper with a 0.040 inch diameter thru hole.
The wire guide is characterized by a heavy-duty shaft, with a gradual transition to a very flexible distal tip. This wire guide type is manufactured in a 0.038 inch diameter, and measures 80 centimeters in length with a 3 millimeter Safe-T-J tip. This wire guide is constructed of a polytetrafluoroethylene coated stainless steel.
The Percutaneous Entry Set will be supplied sterile and is intended for one-time use. The set is packaged in a peel-open pouch with a 3-year shelf life.
- -Skinny Needle® with Chiba Tip
The Skinny Needle® with Chiba Tip is also available for sale individually.
The Skinny Needle® with Chiba Tip will be supplied sterile and is intended for one-time use. The set is packaged in a peel-open pouch with a 3-year shelf life.
- Disposable Two-Part Trocar Needle -
The Disposable Two-Part Trocar Needle is also available for sale individually.
The Disposable Two-Part Trocar Needle will be supplied sterile and is intended for onetime use. The set is packaged in a peel-open pouch with a 3-year shelf life.
{7}------------------------------------------------
Image /page/7/Picture/1 description: The image shows the logo for Cook Medical. The word "COOK" is in large, white, sans-serif font on a red background. Below the word "COOK" is the word "MEDICAL" in a smaller, white, sans-serif font, also on a red background. The "COOK" logo has a registered trademark symbol.
7
Indications for Use:
-
-Percutaneous Entry Set
Used to establish a percutaneous tract into the renal pelvis for catheter placement or stone manipulation. -
Skinny Needle® with Chiba Tip -
Used under fluoroscopy or ultrasound for initial location and positioning within the renal collecting system during a percutaneous nephrostomy. -
Disposable Two-part Trocar Needle -
Used under fluoroscopy or ultrasound for initial location and positioning within the renal collecting system during a percutaneous nephrostomy.
Comparison to Predicate Device:
The subject devices have similar indications for use, methods of operation, and fundamental technological characteristics as the predicate device. Differences between the subject devices and the predicate device include design specifications, dimensions, and materials. Characteristics of the subject devices that differ from the predicate device are supported by testing.
Performance Data:
Performance testing was performed in accordance with ASTM F 623-99 (2013) and FDA's Guidance for the Content of Premarket Notifications for Conventional and Antimicrobial Foley Catheters. The following testing was performed to demonstrate that the Percutaneous Entry Set, the Skinny Needle® with Chiba Tip and the Disposable Twopart Trocar Needle met applicable design requirements.
-
- Biocompatibility
-
- Sterilization
-
- Packaging: Distribution and Stability
-
- Shelf-life
-
- Component Compatibility
-
- Dilators
- a. Tensile Test
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Image /page/8/Picture/1 description: The image shows the logo for Cook Medical. The word "COOK" is in large, white, sans-serif font on a red background. Below the word "COOK" is the word "MEDICAL" in a smaller, white, sans-serif font on a darker red background.
COOK INCORPORATE 50 DANIELS WAY, OMINGTON, IN 47402-04 12.339.2235 TOLL FREE: 800.457.450 WWW.COOKMEDICAL.CC
8
- b. Tip Integrity Test
- c. Radiopacity Test
-
- Needles
- a. Hub Union Strength Test
- b. Fluid Injection Test
- c. Echogenicity Test
- d. Corrosion Test
Conclusion:
The results of these tests provide reasonable assurance that the Percutaneous Entry Set, the Skinny Needle® with Chiba Tip and the Disposable Two-part Trocar Needle will perform as intended. The subject devices do not raise new questions of safety or effectiveness as compared to the predicate device. In conclusion, the results of these tests support a determination of substantial equivalence to the predicate device.
N/A