AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Veloxion System is intended for intrauterine use by trained gynecologists for endoscopically controlled tissue chip resection and coagulation, and removal of intrauterine polyps and myomas via suction channel under continuous flow conditions following resection using a bipolar resectoscope. It is also intended to distend the uterus by filling with saline to facilitate viewing and to monitor the volume differential between fluid flowing into and out of the uterus.

Device Description

The Veloxion System consists of the Veloxion Controller (with Integrated Fluid Control), Footswitch, Veloxion Resectoscope, Veloxion Fluid Control Set, Veloxion Video Control Unit, and Veloxion Roll Stand. It also includes Class I accessories for waste handling: Waste Management Tubing, Tissue Catch, and Waste Management Bags. The system provides bipolar resection and coagulation, distends the uterus with saline, controls intrauterine pressure, and monitors fluid deficit.

AI/ML Overview

Based on the provided text, here's a detailed breakdown of the acceptance criteria and the study conducted for the Veloxion System:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state quantitative "acceptance criteria" in a pass/fail format for specific performance metrics. Instead, it describes performance characteristics that were tested and compared to the predicate device. For the purpose of this request, I will extract the performance characteristics that were "tested" and the reported "performance" from the "Technological Characteristics" table (Table 1) and the "Performance Data" section.

Acceptance Criteria/Performance CharacteristicReported Device Performance (Subject Veloxion System)Notes / Comparison to Predicate
Fluid Deficit Monitoring
Set Fluid Deficit RangeFrom 250 to 2500mlSame as Predicate
Fluid Deficit Rate ≥ 300ml/min notificationYESSame as Predicate
Notification when Actual fluid deficit is 1000mlYES (no pause, notification only)Same as Predicate
Notification & pause when Actual fluid deficit is 2000mlYESDifferent (Predicate: NO)
Notification when Actual fluid deficit is within 250ml of Set LimitYESSame as Predicate
Device Stops when Set Limit or 2500ml is reachedYESSame as Predicate
Pressure Control
Set Pressure Range35 to 120mmHgSlightly different (Predicate: 35 to 125mmHg)
Positive Action to Increase Above 100mmHgYESSame as Predicate
Pressure SensorDual, independent sensing of cavity pressureSame as Predicate
Over-pressure condition detectionYESSame as Predicate
Maximum Allowable Actual Cavity Pressure135mmHg for 5 secondsSame as Predicate
Primary mitigation for risk of over-pressurizationReverse rotation of irrigation wheelSame as Predicate
Ultimate mitigation for risk of over-pressurizationNon-defeatable, continuous notification tone; Notification displayed: "Remove device from cavity. Check for Clog."Same as Predicate
Fluid Flow and Management
Continuous FlowYESSame as Predicate
Irrigation fluidSalineSame as Predicate
Maximum # of saline bag(s) hung on saline load cellFour (4)Different (Predicate: One (1))
Load cellsSeparate load cells to weigh the saline bags and the waste bagsDifferent (Predicate: One load cell for combined saline and waste)
Pump TypeDual Pump (Irrigation, Aspiration)Same as Predicate
Irrigation Flow Rate (Programmed for each mode)Steady State = 100ml/min, Cut = 380ml/min, Coag = 100ml/min, ASPIRATE = 650ml/minDifferent (Predicate: ASPIRATE = 400ml/min)
Suction for aspiration of waste from patient drapeFacility SuctionDifferent (Predicate: Waste Accessory Pump)
Able to Monitor saline remaining?YESSame as Predicate
Imaging/Optics
OpticsIntegrated, Sterile, 10° EndoscopeDifferent (Predicate: Compatible with reusable 30° marketed Endoscope)
ImagingIntegrated CMOS sensorDifferent (Predicate: External CCD camera)
Total # Pixels160,000(Predicate: Unknown)
Pixels/mm2160,000(Predicate: Unknown)
Light SourceLED lightDifferent (Predicate: Xenon, Halogen, LED)
Resectoscope/Electrode
Energy TypeRadiofrequency, BipolarSame as Predicate
Monopolar or BipolarBipolarSame as Predicate
Shaft OD (Sheath)With Sheath Assembled: 25Fr (8.3mm)Slightly different (Predicate: 26Fr (8.6mm))
Electrode OD0.019"Slightly different (Predicate: 0.015")
Electrode MaterialTungsten (99.95% purity)Same as Predicate
Electrode InsulationFEPSame as Predicate
Electrode ActuationLinear Oscillating LoopDifferent (Predicate: Circumferential Oscillating Wire)
How Supplied (Sterility)Sterile, Single Use (Resectoscope, Fluid Control Set)Same as Predicate

2. Sample Size for the Test Set and Data Provenance

The document lists various performance tests and comparative testing to the predicate, but it does not specify the sample sizes (n) used for each test set.

The data provenance is not explicitly stated regarding country of origin or whether the studies were retrospective or prospective. The studies appear to be benchtop performance and engineering tests conducted in-house by the manufacturer rather than clinical trials involving patient data. This is implied by tests such as "Comparative visualization testing in a simulated model" and "Simulated Use: Tissue resection and spot coagulation of cavity pressure, O imaging."

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts

The document does not mention the use of experts or their qualifications for establishing ground truth for any of the performance tests described. The "performance data" section primarily describes engineering and benchtop tests, not clinical evaluations requiring expert interpretation.

4. Adjudication Method (e.g. 2+1, 3+1, none) for the Test Set

As the document does not describe studies involving human readers or interpretation of results that would require adjudication (e.g., image reading), no adjudication method is mentioned or implied.

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

There is no mention of an MRMC comparative effectiveness study, nor any evaluation of AI assistance or human reader improvement. The device described is a medical instrument (hysteroscope system), not an AI-powered diagnostic or interpretive tool that would typically involve such studies.

6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done

This question is not applicable as the device is a physical medical instrument, not a standalone algorithm. Its performance is inherent to its mechanical, electrical, and optical functions.

7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

For the engineering and performance tests:

  • Physical/Engineering Standards: Measurements against known physical properties or engineering specifications (e.g., pressure, flow rates, dimensions, temperature, electrical safety).
  • Predicate Device Performance: Direct comparison to the performance of the legally marketed predicate device (K180752), establishing its performance as a de facto "ground truth" for equivalence.
  • Simulated Models: For visualization and tissue interaction tests ("Comparative visualization testing in a simulated model," "Simulated Use: Tissue resection and spot coagulation").

There is no mention of expert consensus, pathology, or outcomes data being used to establish ground truth for the technical performance data provided.

8. The Sample Size for the Training Set

This question is not applicable as the document describes a medical device, not a machine learning model that would require a "training set."

9. How the Ground Truth for the Training Set Was Established

This question is not applicable for the same reason as point 8.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food & 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.

April 24, 2019

Corinth MedTech, Inc. Sandeep Saboo Vice President, Quality Assurance & Regulatory Affairs 1601 S. De Anza Blvd., Suite 200 Cupertino, CA 95014

Re: K190113

Trade/Device Name: Veloxion System Regulation Number: 21 CFR§ 884.1690 Regulation Name: Hysteroscope and Accessories Regulatory Class: II Product Code: HIH, HIG, GEI Dated: January 22, 2019 Received: January 24, 2019

Dear Sandeep Saboo:

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. 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.

U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov

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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 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.

Jason Roberts -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

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Indications for Use

510(k) Number (if known) K190113

Device Name Veloxion System

Indications for Use (Describe)

The Veloxion System is intended for intrauterine use by trained gynecologists for endoscopically controlled tissue chip resection and coagulation, and removal of intrauterine polyps and myomas via suction channel under continuous flow conditions following resection using a bipolar resectoscope. It is also intended to distend the uterus by filling with saline to facilitate viewing and to monitor the volume differential between fluid flowing into and out of the uterus.

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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K_190113__: 510(k) Summary

I. Submitter Information

Submitter name:Corinth MedTech, Inc.1601 S. De Anza Blvd, Suite 200Cupertino, CA 95014
Contact person:Sandeep SabooVice President, Regulatory Affairs and Quality AssurancePhone: (408) 996-2517Fax: (408) 996-0621
Date Prepared:21 January 2019

II. Product Classification

Device Name:Veloxion System
Common Name:Resectoscope
Regulation:21 CFR 884.1690
Regulation Name:Hysteroscope and accessories
Class:II
Product Code:HIH
Additional Product Codes:HIG, GEI
Subject Device

III. Predicate Devices

The predicate device is the system comprised of the following legally marketed devices as used in combination to which substantial equivalence is claimed:

Primary Predicate: Veloxion System (cleared per K180752) Predicate: Hysteroscope A22002A Olympus Corp. (cleared per K897003)

Predicate devices have not been a subject of a design related recall.

IV. Device Description

The Veloxion System consists of the following components:

  • · Veloxion Controller (with Integrated Fluid Control)
    • 0 Footswitch
  • · Veloxion Resectoscope
  • · Veloxion Fluid Control Set
  • · Veloxion Video Control Unit
  • · Veloxion Roll Stand

The Veloxion System also includes the following Class I accessories for handling of waste collected from the patient (these items only handle waste after it is already outside the patient), which includes:

  • · Waste Management Tubing: To provide a conduit for transfer of aspirated fluids and tissue from the patient and from under the patient's buttocks drape
  • · Tissue Catch: For collection of gross resected tissue pieces for pathology.
  • · Waste Management Bags: To provide bags for final collection of outflow.

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The Veloxion System provides bipolar resection and coagulation of intrauterine tissue, it distends the uterus by filling with saline, it provides pressure control of the intrauterine cavity for insufflation to facilitate viewing with the integrated hysteroscope and it monitors the fluid deficit (potential fluid absorbed by the patient's body) to the physician established limit. The components of Veloxion System perform the following functions:

  • · The Veloxion Controller provides bipolar radiofrequency outputs (for cut and coagulation) and fluid/pressure control through the use of two integrated peristaltic pumps, provides the user interface to establish the desired set pressure, monitors intracavitary pressure using dual independent pressure sensors mechanically connected to the Veloxion Fluid Control Set irrigation lumen. The software then monitors, controls and notifies the user when the limits are reached or when specific conditions are met.
  • · The Veloxion Resectoscope is a sterile single use hand held bipolar radiofrequency device configured to provide camera and light for visualization of the anatomy for the resection of tissue and aspiration of resected chips. Fluid inflow and aspiration of the resected chips are controlled by the Controller's peristaltic pumps.
  • · The Veloxion Fluid Control Set is a sterile single use device that provides conduits for fluid inflow, aspiration of resected tissue and fluids and a diaphragm (pressure membrane) that provides mechanism for the Controller to measure cavity pressure (through the irrigation lumen) during the procedure thereby facilitating the insufflation function.
  • · The Veloxion Video Control Unit provide control of the camera, light, display image to a commercially available monitor, stores image and video selected by the user from a session, and provides a USB connection for a USB Stick download of stored media by the user.
  • The Veloxion Roll Stand enables monitoring of saline remaining in the saline bag and facilitates the fluid deficit function.

V. Indications for Use

There is no difference in the indications for use for the modified Veloxion System (subject device) when compared to the predicate device (cleared Veloxion System, per K180752)

DeviceIndications For Use
ModifiedVeloxion System(Subject Device)The Veloxion System is intended for intrauterine use by trained gynecologists forendoscopically controlled tissue chip resection and coagulation, and removal ofintrauterine polyps and myomas via suction channel under continuous flow conditionsfollowing resection using a bipolar resectoscope. It is also intended to distend the uterusby filling with saline to facilitate viewing and to monitor the volume differential betweenfluid flowing into and out of the uterus.
Veloxion SystemK180752(Predicate Device)The Veloxion System is intended for intrauterine use by trained gynecologists forendoscopically controlled tissue chip resection and coagulation, and removal ofintrauterine polyps and myomas via suction channel under continuous flow conditionsfollowing resection using a bipolar resecting device. It is also intended to distend theuterus by filling with saline to facilitate viewing with a hysteroscope and to monitor thevolume differential between fluid flowing into and out of the uterus.

Comparison of Indications for Use

VI. Comparison of Technological Characteristics with the Predicate Device

The subject Veloxion System and the previously cleared Veloxion System (K180752) and Olympus Hysteroscope (K897003) have the same or similar technological characteristics (see Table 1 and Table 2) in terms of basic operating principle and basic design features with a key difference being that the subject Veloxion System includes a sterile, single use camera and light while the predicate uses a commercially available reusable endoscope.

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Veloxion System Traditional 510(k) Premarket Notification

Technological CharacteristicsVELOXION SYSTEM(Subject)VELOXION SYSTEM(Predicate)
Monopolar or BipolarBipolarBipolar
Energy Type:Radiofrequency, BipolarRadiofrequency, Bipolar
Optics:Integrated, Sterile, 10° EndoscopeCompatible with reusable 30° marketed Endoscope
Set Fluid Deficit Range:From 250 to 2500mlFrom 250 to 2500ml
Fluid Deficit Rate ≥ 300ml/min notification to user?YESYES
Notification to user when Actual fluid deficit is 1000ml?YES (no pause, notification only)YES
Notification to user with pause when Actual fluid deficit is 2000ml?YESNO
Notification when Actual fluid deficit is within 250ml of Set Limit?YESYES
Device Stops when Set Limit or 2500ml is reached?YESYES
Set Pressure Range:35 to 120mmHg35 to 125mmHg
Positive Action to Increase Above 100mmHg:YESYES
Pressure Sensor:Dual, independent sensing of cavity pressureDual, independent sensing of cavity pressure
Over-pressure condition detection:YESYES
Maximum Allowable Actual Cavity Pressure135mmHg for 5 seconds135mmHg for 5 seconds
Primary mitigation for risk of over-pressurization of uterus:• Reverse rotation of irrigation wheel• Reverse rotation of irrigation wheel
Ultimate mitigation for risk of over-pressurization of uterus if alldesigned mitigations are unsuccessful• Non-defeatable, continuous notification tone• Notification displayed:"Remove device from cavity. Check for Clog."• Non-defeatable, continuous notification tone• Notification displayed:• "Remove device from cavity. Check for Clog."
Continuous Flow?:YESYES
Irrigation fluid:SalineSaline
Maximum # of saline bag(s) hung on saline load cell:Four (4)One (1)
Load cells:Separate load cells to weigh the saline bags and the wastebagsOne load cell to weigh the combined saline and waste bagload
Pump?Dual Pump (Irrigation, Aspiration)Dual Pump (Irrigation, Aspiration)
Irrigation Flow Rate:Programmed irrigation flow rate constant for each mode:Steady State = 100ml/min, Cut = 380ml/min,Coag = 100ml/min, ASPIRATE = 650ml/minProgrammed irrigation flow rate constant for each mode:Steady State = 100ml/min, Cut = 380ml/min,Coag = 100ml/min, ASPIRATE = 400ml/min
Suction for aspiration of waste from patient drape:Facility SuctionWaste Accessory Pump
Able to Monitor saline remaining?:YESYES
Shaft OD (Sheath):With Sheath Assembled: 25Fr (8.3mm)With Sheath Assembled: 26Fr (8.6mm)
Technological CharacteristicsVELOXION SYSTEM(Subject)VELOXION SYSTEM(Predicate)
Electrode (Dimension/Material/ Insulation/Actuation):OD: 0.019"Material: Tungsten (99.95% purity)Insulation: FEPActuation: Linear Oscillating LoopOD: 0.015"Material: Tungsten (99.95% purity)Insulation: FEPActuation: Circumferential Oscillating Wire
How Supplied (Sterility):Sterile, Single Use(Veloxion Resectoscope, Veloxion Fluid Control Set)Sterile, Single Use(Veloxion Resecting Device Kit, Veloxion Fluid Control Set)

Table 1: Comparison of subject Veloxion System and predicate Veloxion System:

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Veloxion System Traditional 510(k) Premarket Notification

Table 2: Comparison of subject Veloxion System and predicate Olympus Hysteroscope:

Technological CharacteristicsVELOXION SYSTEM(Subject)Olympus Hysteroscope(K897003)
OD:Inner Sheath: 6.5mm4.0mm
Working Length:220mm280mm
DOV:10°30°
FOV:85°57°
Working Distance:5 to 50mm20mm
Light Source:LED lightXenon, Halogen, LED
Imaging:Integrated CMOS sensorExternal CCD camera
Total # Pixels:160,000Unknown
Pixels/mm2:160,000Unknown
Active Area of CCD Chip:714 $\mu$ m x 707 $\mu$ mUnknown

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The main technological differences between the subject Veloxion System and the predicate Veloxion System are the following:

  • The subject Veloxion System includes a sterile, single-use camera and light system while the predicate Veloxion System uses a commercially available reusable Endoscope.
  • The subject Veloxion System includes programmed flow rates that are slightly different than the predicate Veloxion System as a result of an integrated passive flow mechanism.

The differences outlined were evaluated through performance testing to demonstrate safety and effectiveness of the subject Veloxion System.

VII. Performance Data

The following performance data have been provided in support of the substantial equivalence determination.

  • Software Verification and Validation Testing performed per IEC 62304 and . documentation provided per FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
  • . Other Tests were performed per approved test protocols which included:
    • Integrity: System withstands operating pressures o
      • Functional Testing: Cut and coagulation, aspiration, irrigation, pressure control o
      • Dimensional Inspection and Testing O
      • Functional Testing for all components of the system O
      • Maximum LED Tip Temperature O
    • Comparative visualization testing in a simulated model O
    • Simulated Use: Tissue resection and spot coagulation of cavity pressure, O imaging
    • Durability Testing: Electrode durability testing for tissue resection and coagulation. O
    • o Comparative testing to predicate for electrode durability, pressure control, fluid deficit, fluid control, resolution per ISO 8600-5, distortion and photobiologic safety per IEC 62471:2006.
    • Thermal effects evaluation. O
    • Biocompatibility Testing per ISO 10993-1. O
    • Sterilization Validation per ISO 11135 and ISO 11137-1/-2/-3. O
    • Packaging Validation per ASTM D4169. O
    • Accelerated Aging per ASTM F1980 O
    • O Electrical Safety & EMC: In accordance with IEC 60601-1:2005, IEC 60601-1-2:2014, IEC 60601-2-18:2009 and IEC 60601-2-2:2009.
    • Usability Testing: Use related risk evaluation O

VIII. Conclusions

Based on the results of performance tests, the subject Veloxion System is considered to be substantially equivalent and as safe and effective as the predicate Veloxion System (K180752).

§ 884.1690 Hysteroscope and accessories.

(a)
Identification. A hysteroscope is a device used to permit direct viewing of the cervical canal and the uterine cavity by a telescopic system introduced into the uterus through the cervix. It is used to perform diagnostic and surgical procedures other than sterilization. This generic type of device may include obturators and sheaths, instruments used through an operating channel, scope preheaters, light sources and cables, and component parts.(b)
Classification. (1) Class II (performance standards).(2) Class I for hysteroscope accessories that are not part of a specialized instrument or device delivery system; do not have adapters, connectors, channels, or do not have portals for electrosurgical, laser, or other power sources. Such hysteroscope accessory instruments include: lens cleaning brush, cannula (without trocar or valves), clamp/hemostat/grasper, curette, instrument guide, forceps, dissector, mechanical (noninflatable), and scissors. 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 § 884.9.