K Number
K201174
Device Name
TruDi Curette
Manufacturer
Date Cleared
2020-08-12

(103 days)

Product Code
Regulation Number
882.4560
Panel
EN
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

TruDi™ Curette is intended for use with the TruDi™ Navigation System to manipulate, dissect and/or remove tissue, cartilage and bone during surgical procedures in ENT and ENT skull base surgery.

Device Description

The subject device, TruDi™ Curette (K201174), is a single-use and sterile electromagnetically (EM) navigated instrument, which is intended for use with the TruDi™ Navigation System (K192397) to manipulate, dissect and/or remove tissue, cartilage and bone during surgical procedures in ENT and ENT skull base surgery. The TruDi™ Curette consists of one configuration (straight 0°). The TruDi™ shaft, and a curette cup, which is located at the distal tip and houses a magnetic sensor. The device is sold in sterile packaging. Each package includes one TruDi™ Curette in conjunction with a disposable bending tool. The bending tool is provided to allow the user to customize the shape of the distal shaft as needed.

The TruDi™ Curette incorporates a sensor at the distal tip, which is tracked by the TruDi™ Navigation System. The location of the distal tip of the device is identified by the navigation system and displayed in real-time view over the patient's pre-operative CT/MRI scan to confirm access, and to locate anatomical structures during ENT and ENT skull base surgery.

AI/ML Overview

The provided document is a 510(k) summary for the TruDi™ Curette, which seeks to demonstrate substantial equivalence to a predicate device. While it includes a lot of information about bench testing and design validation, it does not detail a study involving AI performance or human readers. Therefore, several requested sections, particularly those related to AI and human reader studies, cannot be extracted from this document.

Here's a summary of the available information:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance CriteriaReported Device Performance
Non-Clinical Performance Data:
Dimensional specificationsMet all acceptance criteria
Connector joint separation forceMet all acceptance criteria
Distal shaft deflection/flexureMet all acceptance criteria
End to end joint strengthMet all acceptance criteria
Cable strain relief separation forceMet all acceptance criteria
Tip sharpnessMet all acceptance criteria
Bending tool functionalityMet all acceptance criteria
Navigational location accuracyMet all acceptance criteria; Accuracy of TruDi™ Curette in conjunction with TruDi™ Navigation System is ≤ 2mm RMS over the entire navigation volume.
Electrical safety and EMCCompliance with IEC 60601-1 (3rd Edition) and IEC60601-1-2 (4th Edition)
Sterilization processValidated per ISO 11135:2014, demonstrated a sterility assurance level of 10^-6
Ethylene oxide residualsMet ISO 10993-7:2008 requirements
BiocompatibilitySuccessfully completed per ISO 10993-1
Packaging shelf lifeEstablished for three months via accelerated aging (ASTM F1980-07, ASTM F88/F88M-09, ASTM F2096-11)
Design Validation (Simulated Use Testing):
Functionality in simulated clinical settingSuccessfully conducted and verified that the TruDi™ Curette functions in accordance with its intended use and design specifications
Packaging and instructions for use assessmentSuccessfully assessed by evaluators
Overall Product PerformancePassed all intended criteria in accordance with appropriate test criteria and standards

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

The document mentions "Design validation testing (simulated use testing) on cadavers" but does not specify the sample size (number of cadavers or test cases) used for this test set nor the detailed provenance beyond "cadavers". It is a prospective study in a simulated clinical setting.

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

Not specified in the provided document. The document mentions "evaluators" for assessing packaging and instructions for use, but not for establishing ground truth regarding clinical performance.

4. Adjudication method for the test set

Not specified in the provided document.

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. The TruDi™ Curette is a physical surgical instrument, not an AI or imaging diagnostic device that would involve human readers or AI assistance in the way typically assessed by MRMC studies.

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

Not applicable. The TruDi™ Curette is a physical surgical instrument, not an algorithm. Its navigation capability is part of the TruDi™ Navigation System, which has a stated accuracy of ≤ 2mm RMS. This accuracy is a standalone measurement of the system's ability to track the instrument's tip.

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

For the navigational location accuracy, the ground truth would typically be established through precise metrological measurements using a known standard or reference system. For the simulated use testing on cadavers, the "ground truth" or successful performance would be based on the device functioning as intended in manipulating, dissecting, and/or removing tissue, cartilage, and bone, as verified by the evaluators. Specific methods for establishing this ground truth (e.g., expert observation, quantitative assessment of tissue removal) are not detailed.

8. The sample size for the training set

Not applicable. The TruDi™ Curette is a physical device, and the document describes performance testing and design validation, not the development or training of an AI algorithm.

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

Not applicable. There is no mention of a training set or AI model in the context of this device.

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).