K Number
K190331
Date Cleared
2019-11-22

(281 days)

Product Code
Regulation Number
878.4750
Panel
SU
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Applied Medical Laparoscopic Linear Cutter has applications in open and/or minimally invasive general, urologic, gynecologic, pediatic and thoracic surgery for resection and or creation of anastomosis. The instruments may also be used for transection of liver parenchyma (hepatic vasculature and biliary structures), pancreas, kidney and spleen. It can be used with staple line or tissue buttressing materials.

Device Description

The Applied Medical Laparoscopic Linear Cutter (LLC) is a sterile, single-use stapling system that is intended to be used for mechanically transecting, resecting, and sealing tissue during laparoscopic and open surgical procedures. The stapler places six staggered rows of titanium staples, three on either side of the transection line. The shaft can rotate freely in both directions and the jaws articulate to facilitate access to the operative site. The Applied LLC is available in 3 different shaft lengths (20cm, 37cm, 50cm) that can each accommodate 3 different industrystandard reload lengths (60mm, 45mm, 30mm). Each of the reload lengths is available in three industry-standard reload colors and formed staple heights to accommodate various tissue thicknesses: 1.0mm (white reload), 1.5mm (blue reload), and 2.0mm (green reload).

AI/ML Overview

This document describes the FDA's 510(k) clearance for the Applied Medical Laparoscopic Linear Cutter (LLC), asserting its substantial equivalence to a predicate device. As such, the information provided focuses on the performance testing conducted to demonstrate this equivalence rather than a study proving a device meets specific clinical acceptance criteria for an AI/CADe device.

Therefore, many of the requested categories for AI/CADe systems (e.g., number of experts, adjudication methods, MRMC studies, training set details) are not applicable to this type of medical device submission. The device in question is a surgical stapler, not an AI or imaging diagnostic tool.

However, I can extract the information relevant to establishing the substantial equivalence of this device based on the provided text.

Here's a breakdown of the available information:

1. Table of Acceptance Criteria and Reported Device Performance

The document states that "All performance testing acceptance criteria were met." It does not provide the specific numerical acceptance criteria for each test or detailed quantitative results, but rather lists the tests performed and their objectives.

Test CategoryTest NameTest ObjectiveReported Performance (Qualitative)
Bench TestsFiring ForceTo evaluate the input force required to actuate the triggerAcceptance criteria met
Leak TestTo evaluate staple line leak pressuresAcceptance criteria met
Articulation TestingTo evaluate device performance when fully articulatedAcceptance criteria met
Reinforcement Material CompatibilityTo evaluate device performance with reinforcement materialAcceptance criteria met
Shelf Life TestingTo evaluate device performance after simulated transit and storage conditionsAcceptance criteria met
Staple FormationTo evaluate staple formation in media and out of mediaAcceptance criteria met
Formed Staple HeightTo measure the formed staple heightAcceptance criteria met
Radiograph ImagingTo evaluate location and quality of staple formation in mediaAcceptance criteria met
Tissue Compression EvaluationTo evaluate tissue effects associated with application of the deviceAcceptance criteria met
Crossed Staple LineTo evaluate device performance when fired across existing staple lineAcceptance criteria met
Preclinical Tests21-Day Porcine Chronic Survival StudyTo evaluate in vivo device performance including in vivo hemostasis and histopathological evaluationsAcceptance criteria met
Acute Porcine In-Vivo StudyTo evaluate device performance on high pressure arteries and thin-walled veinsAcceptance criteria met
Biocompatibility TestsEthylene Oxide ResidualPer ISO 10993-7Acceptance criteria met
Material Mediated PyrogenicityPer USP 40-NF 35:Acceptance criteria met
CytotoxicityPer ISO 10993-5Acceptance criteria met
SensitizationPer ISO 10993-10Acceptance criteria met
Acute Systemic ToxicityPer ISO 10993-11Acceptance criteria met
Intracutaneous ReactivityPer ISO 10993-10Acceptance criteria met
Intramuscular Implant Testing (2 & 13 week)Per ISO 10993-6Acceptance criteria met
Toxicological Risk AssessmentReproductive and Developmental ToxicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met
Subacute ToxicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met
Subchronic ToxicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met
Chronic ToxicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met
GenotoxicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met
CarcinogenicityBased on chemical characterization (per ISO 10993-18)Acceptance criteria met

2. Sample size used for the test set and the data provenance

  • Test Set (Preclinical Studies): Two porcine studies were conducted. The specific number of animals or cases in these studies is not detailed in the provided text.
  • Data Provenance: The studies are described as "preclinical testing" which typically implies laboratory animal studies. The country of origin is not specified but implicitly within the context of an FDA submission, the testing would be expected to meet U.S. regulatory standards. These are prospective studies given they are conducted specifically for the regulatory submission.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

  • Not applicable / Not specified. This device is a surgical instrument, and its performance evaluation involves physical and biological testing, not expert interpretation of diagnostic images.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

  • Not applicable. This concept pertains to establishing ground truth for diagnostic image interpretation, which is not relevant to the testing of a surgical stapler.

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 study design is for evaluating AI/CADe systems in diagnostic imaging. The Applied Medical Laparoscopic Linear Cutter is a surgical device.

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

  • Not applicable. This device is a manual surgical instrument. No algorithm is involved.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

  • For Bench Tests: Ground truth is established through physical measurements, engineering standards, and biological models (e.g., media, tissue analogues).
  • For Preclinical Tests: Ground truth is established through direct observation of in-vivo performance (e.g., hemostasis) and histopathological evaluations of animal tissues post-procedure.
  • For Biocompatibility Tests: Ground truth is established by standardized biological assays (e.g., cytotoxicity, sensitization, systemic toxicity) and chemical characterization following specific ISO standards.

8. The sample size for the training set

  • Not applicable. This device is not an AI/machine learning system. There is no concept of a "training set."

9. How the ground truth for the training set was established

  • Not applicable. As above, no training set for an AI/ML model exists for this device.

§ 878.4750 Implantable staple.

(a)
Identification. An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.(b)
Classification. Class II.