K Number
K202443
Device Name
Smart Kit Basic, Smart Kit Pro
Manufacturer
Date Cleared
2021-03-11

(197 days)

Product Code
Regulation Number
878.5040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Smart Kit is disposable and is indicated for autologous fat transfer is also technically called as autologous fat grafting or reinjection of concentrated adipose-tissue into the recipient body areas. The Smart kit can be used for concentration and transfer of homogenous adipose tissues with legally marketed lipoplasty system when the concentrated and homogenous fat tissue is re-injected into the recipient body areas of the same patient autologously. This device is intended for autologous fat transfer. The Smart Kit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired. Neurosurgery / Gastrointestinal Surgery / General surgery / Orthopedic Surgery / Gynecological Surgery / Thoracic Surgery / Laparoscopic Surgery / Arthroscopic Surgery / Plastic and reconstructive surgery
Device Description
The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics and etc. In addition, the harvested fat tissues are not homogeneous and contain bigger fibrotic tissues. Smart kit is designed and developed for harvest of a variety of sizes of homogeneous adipose tissues in a closed sterile way for autologous fat transfer surgical technique. Using a separate cannula, Manual handheld suction unit, and plunger, aspirate the adipose tissue or fill the syringe with adipose tissue and centrifuge with the cap in front of the syringe. Centrifuged adipose tissue is divided into blood and fluid layer, adipose tissue layer, and free oil layer. Those are located at the bottom of the piston. After centrifugation, the plunger is pushed unlocked to the piston and free oil is drained to the outside of the syringe as the free oil moves to the top of the piston through the hole at the front of the piston. Open the cap in front of the syringe, lock the plunger completely and push it, the blood and fluid layers at the bottom of the adipose tissue will be drained and only the adipose tissue will remain inside the syringe. Depending on the syringe capacity, there are three types of piston: 10ml, 20ml, 60ml. The built-in filter adapter consists of a filter for separating the fiber and adipose tissue to facilitate movement through needles of lumpy adipose tissues and a body for receiving it. Connect the syringe containing the adipose tissue and the empty syringe to the connection parts at both ends of the built-in filter adapter and push the plunger of the syringe containing the adipose tissue to allow the adipose tissue to pass through the filter. Fiber and adipose tissues larger than the pore size is filtered, and adipose tissue smaller than the pore size of the filter is passed through to separate adipose tissue.
More Information

Not Found

No
The device description details a mechanical process for filtering and concentrating adipose tissue using centrifugation, syringes, plungers, and filters. There is no mention of any computational analysis, algorithms, or learning processes that would indicate the use of AI or ML.

Yes

This device is used for surgical procedures involving autologous fat transfer for various medical specialties, including orthopedic and reconstructive surgery, which are therapeutic applications.

No

Explanation: The device is intended for the concentration and transfer of adipose tissue for autologous fat transfer, not for diagnosing any medical condition.

No

The device description clearly details physical components like syringes, plungers, filters, and a manual handheld suction unit, indicating it is a hardware-based medical device.

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

Here's why:

  • Intended Use: The intended use is for the processing and transfer of autologous fat tissue for surgical procedures. This is a surgical device used in vivo (within the body) for therapeutic purposes.
  • Device Description: The description details a system for separating and concentrating fat tissue from lipoaspirates. This is a physical processing method applied to a biological sample, but it's not for the purpose of diagnosing a disease or condition.
  • Lack of Diagnostic Function: There is no mention of the device being used to analyze a sample to provide information about a patient's health status, disease, or condition. It doesn't perform any tests or measurements on the sample for diagnostic purposes.
  • Performance Studies: The performance studies focus on the physical characteristics and functionality of the device (water tightness, centrifugation compatibility, cell viability, etc.), not on diagnostic accuracy or performance metrics like sensitivity or specificity.

IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnostic, monitoring, or screening purposes. This device is used to prepare a biological material for re-introduction into the same patient for a therapeutic purpose.

N/A

Intended Use / Indications for Use

The Smart Kit is disposable and is indicated for autologous fat transfer is also technically called as autologous fat grafting or reinjection of concentrated adipose-tissue into the recipient body areas. The Smart kit can be used for concentration and transfer of homogenous adipose tissues with legally marketed lipoplasty system when the concentrated and homogenous fat tissue is re-injected into the recipient body areas of the same patient autologously.

This device is intended for autologous fat transfer. The Smart Kit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

Neurosurgery / Gastrointestinal Surgery / General surgery / Orthopedic Surgery / Gynecological Surgery / Thoracic Surgery / Laparoscopic Surgery / Arthroscopic Surgery / Plastic and reconstructive surgery

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

MUU

Device Description

The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics and etc. In addition, the harvested fat tissues are not homogeneous and contain bigger fibrotic tissues. Smart kit is designed and developed for harvest of a variety of sizes of homogeneous adipose tissues in a closed sterile way for autologous fat transfer surgical technique.

Using a separate cannula, Manual handheld suction unit, and plunger, aspirate the adipose tissue or fill the syringe with adipose tissue and centrifuge with the cap in front of the syringe. Centrifuged adipose tissue is divided into blood and fluid layer, adipose tissue layer, and free oil layer. Those are located at the bottom of the piston. After centrifugation, the plunger is pushed unlocked to the piston and free oil is drained to the outside of the syringe as the free oil moves to the top of the piston through the hole at the front of the piston. Open the cap in front of the syringe, lock the plunger completely and push it, the blood and fluid layers at the bottom of the adipose tissue will be drained and only the adipose tissue will remain inside the syringe. Depending on the syringe capacity, there are three types of piston: 10ml, 20ml, 60ml. The built-in filter adapter consists of a filter for separating the fiber and adipose tissue to facilitate movement through needles of lumpy adipose tissues and a body for receiving it.

Connect the syringe containing the adipose tissue and the empty syringe to the connection parts at both ends of the built-in filter adapter and push the plunger of the syringe containing the adipose tissue to allow the adipose tissue to pass through the filter. Fiber and adipose tissues larger than the pore size is filtered, and adipose tissue smaller than the pore size of the filter is passed through to separate adipose tissue.

Smart Syringe:

Filter piston syringe is equipped with a piston built-in filter. After the filter piston syringe is filled with aspirated adipose tissue, filter piston syringe capped with a syringe CAP, centrifuged and divided into blood and fluid layers, adipose tissue layer, and free oil layer due to differences in specific gravity. During the centrifugation process, the weight valve in the piston operates to open the oilpassage, and the free oil passes through the filter of the piston. The adipose tissue that is larger than the pore of the filter can not pass through, so it stays between the front of the filter piston and the blood & fluid layer. The Adipose tissue and free oil are separated. After the centrifugation is completed, push the piston built-in filter through the filter piston plunger to remove blood and fluid layer, leaving only adipose tissue in the device.

Smart Lock

A separate handheld suction unit that is reusable.

Syringe Connector

Luer to Luer connector between two syringes for fat transfer, that is disposable

Syringe Handle

Assist in fat processing, disposable

Adinizer

Concentrates adipose-tissue passes through (4000-400 um) mesh outlet into the reconstructing area.

Smart Kit (System) - The device comes is available either as a) Smart Kit Basic, b) Smart Kit Pro

    1. Smart Kit Basic:
    • a. Piston
    • b. Plunger
    • Syringe CAP C.
    • d. Syringe Handle
    • Syringe Connector e.
    • Smart Syringe f.
  1. Smart Kit

Pro:

  • g. Piston
  • h. Plunger
    1. Syringe CAP
  • Syringe Handle i.
  • k. Syringe Connector
  • Smart Syringe l.
  • m. Adinizer (Mesh Filter)

Smart kit is recommended to be used by the well-trained physicians for liposuction and fat transfer technique. This device is sterile and for single-use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

recipient body areas

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Physician

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)

Smart Kit was tested in accordance with established protocols and met the acceptance criteria for all tests performed.

Performance testing include:
Test Item, Test Requirement
Appearance, There should be no visible scratches, damage, or foreign material
Measurement, When measuring with Vernier calipers, according to the dimension of "shape and structure" part, the stated should be within $\pm$ 5%
Water Tightness, When tested according to the test method, there should be no leakage
Centrifugation Compatibility Test (Leakage), When tested according to the test method, it should be aspirated to the maximum capacity without leakage
Cell Viability Test, The finally filtered adipose tissues for autologous fat transfer should maintain at least over 85 % of the cell viability.
Pore Size, When measuring with Vernier calipers, according to the dimension of 'shape and structure' part, the stated should be within $\pm$ 15 %.
pH, Difference of pH $\leq$ 1.5
Potassium permanganate reducing substances, Difference of the consumption $\leq$ 2.0 mL
Evaporating residue, Difference of residues $\leq$ 1.0mg
Heavy Metals, The test solution should not be darker than blank solution.
Ultraviolet-visible, Difference of the maximum absorbance at (250~350) nm $\leq$ 0.1

Sterilization and Shelf Life:
Smart Kit was verified for validation for 3 years (36 months) by testing physicochemical changes and packaging of the materials and the product before, middle, and after acceleration aging according to ISO 11607.
Sterilization was conducted on the Smart Kit Fat Separator with Ethylene oxide gas.
Sterilization is performed with the cycle validation on the report in accordance with EN ISO11135:2014 Sterilization of medical devices validation and routine control of sterilization by Ethylene oxide gas. The sterilizing cycle has been validated to ensure our products to be sterilized to an S.A.L. of at least 10-6 by EN ISO11135:2014 by the method of over-kill.

Biocompatibility:
Biocompatibility testing for Smart Kit was performed in accordance with the requirements of ISO 10993-1:2009 for external communicating devices having contact

§ 878.5040 Suction lipoplasty system.

(a)
Identification. A suction lipoplasty system is a device intended for aesthetic body contouring. The device consists of a powered suction pump (containing a microbial filter on the exhaust and a microbial in-line filter in the connecting tubing between the collection bottle and the safety trap), collection bottle, cannula, and connecting tube. The microbial filters, tubing, collection bottle, and cannula must be capable of being changed between patients. The powered suction pump has a motor with a minimum of1/3 horsepower, a variable vacuum range from 0 to 29.9 inches of mercury, vacuum control valves to regulate the vacuum with accompanying vacuum gauges, a single or double rotary vane (with or without oil), a single or double diaphragm, a single or double piston, and a safety trap.(b)
Classification. Class II (special controls). Consensus standards and labeling restrictions.

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March 11, 2021

BSL Co., Ltd % James Monroe President & CEO Global RQC Med Device Solutions, LLC. 319 Shilling Dr. Somerset, New Jersey 08873

Re: K202443

Trade/Device Name: Smart Kit Basic, Smart Kit Pro Regulation Number: 21 CFR 878.5040 Regulation Name: Suction Lipoplasty System Regulatory Class: Class II Product Code: MUU Dated: February 3, 2021 Received: February 5, 2021

Dear James Monroe:

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.

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

1

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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Cindy Chowdhury, Ph.D., M.B.A. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K202443

Device Name

Smart Kit

Indications for Use (Describe)

The Smart Kit is disposable and is indicated for autologous fat transfer is also technically called as autologous fat grafting or reinjection of concentrated adipose-tissue into the recipient body areas. The Smart kit can be used for concentration and transfer of homogenous adipose tissues with legally marketed lipoplasty system when the concentrated and homogenous fat tissue is re-injected into the recipient body areas of the same patient autologously.

This device is intended for autologous fat transfer. The Smart Kit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

Neurosurgery / Gastrointestinal Surgery / General surgery / Orthopedic Surgery / Gynecological Surgery / Thoracic Surgery / Laparoscopic Surgery / Arthroscopic Surgery / Plastic and reconstructive surgery

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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510(k) Summary

Date of Preparation:February 10, 2021
Submitter:Jun Seok Lee, President
BSL Co., Ltd
6-13, Chilsan-ro 237beon-gil
Gimhae-si, Gyeongsangnam-do, Korea
Phone:+82-55-328-9235
Contact Person:James W. Monroe
President & CEO
Global RQC Med Device Solutions,
LLC
319 Shilling Dr.
Somerset, NJ 08873 USA
Phone: (908) 809-0081
Fax: (908) 540-2084
Email: jmonre@globalrqc.com
Trade/Device Name:
Common/Usual Name:
Classification Name:
Regulation Number:
Regulation Name:
Regulatory Class:
Product Code:
Predicate Device:Smart Kit
Suction lipoplasty system
System, Suction, Lipoplasty
21 CFR Part 878.5040
General & Plastic Surgery
Class II
MUU
Dermapose Refresh (K193363, clearance received April
14,2020)

4

Device Description:

The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics and etc. In addition, the harvested fat tissues are not homogeneous and contain bigger fibrotic tissues. Smart kit is designed and developed for harvest of a variety of sizes of homogeneous adipose tissues in a closed sterile way for autologous fat transfer surgical technique.

Using a separate cannula, Manual handheld suction unit, and plunger, aspirate the adipose tissue or fill the syringe with adipose tissue and centrifuge with the cap in front of the syringe. Centrifuged adipose tissue is divided into blood and fluid layer, adipose tissue layer, and free oil layer. Those are located at the bottom of the piston. After centrifugation, the plunger is pushed unlocked to the piston and free oil is drained to the outside of the syringe as the free oil moves to the top of the piston through the hole at the front of the piston. Open the cap in front of the syringe, lock the plunger completely and push it, the blood and fluid layers at the bottom of the adipose tissue will be drained and only the adipose tissue will remain inside the syringe. Depending on the syringe capacity, there are three types of piston: 10ml, 20ml, 60ml. The built-in filter adapter consists of a filter for separating the fiber and adipose tissue to facilitate movement through needles of lumpy adipose tissues and a body for receiving it.

Connect the syringe containing the adipose tissue and the empty syringe to the connection parts at both ends of the built-in filter adapter and push the plunger of the syringe containing the adipose tissue to allow the adipose tissue to pass through the filter. Fiber and adipose tissues larger than the pore size is filtered, and adipose tissue smaller than the pore size of the filter is passed through to separate adipose tissue.

Smart Syringe:

Filter piston syringe is equipped with a piston built-in filter. After the filter piston syringe is filled with aspirated adipose tissue, filter piston syringe capped with a syringe CAP, centrifuged and divided into blood and fluid layers, adipose tissue layer, and free oil layer due to differences in specific gravity. During the centrifugation process, the weight valve in the piston operates to open the oilpassage, and the free oil passes through the filter of the piston. The adipose tissue that is larger than the pore of the filter can not pass through, so it stays between the front of the filter piston and the blood & fluid layer. The Adipose tissue and free oil are separated. After the centrifugation is completed, push the piston built-in filter

5

through the filter piston plunger to remove blood and fluid layer, leaving only adipose tissue in the device.

Smart Lock

A separate handheld suction unit that is reusable.

Syringe Connector

Luer to Luer connector between two syringes for fat transfer, that is disposable

Syringe Handle

Assist in fat processing, disposable

Adinizer

Concentrates adipose-tissue passes through (4000-400 um) mesh outlet into the reconstructing area.

Smart Kit (System) - The device comes is available either as a) Smart Kit Basic, b) Smart Kit Pro

    1. Smart Kit Basic:
    • a. Piston
    • b. Plunger
    • Syringe CAP C.
    • d. Syringe Handle
    • Syringe Connector e.
    • Smart Syringe f.
  1. Smart Kit

Pro:

  • g. Piston
  • h. Plunger
    1. Syringe CAP
  • Syringe Handle i.
  • k. Syringe Connector
  • Smart Syringe l.
  • m. Adinizer (Mesh Filter)

Smart kit is recommended to be used by the well-trained physicians for liposuction and fat transfer technique. This device is sterile and for single-use only.

6

Intended Use/Indications for Use:

The Smart Kit is disposable and is indicated for autologous fat transfer. The autologous fat

transfer is also technically called as autologous fat grafting or reinjection of concentrated adipose-tissue into the recipient body areas. The Smart kit can be used for concentration and transfer of homogenous adipose tissues with legally marketed lipoplasty system when the concentrated and homogenous fat tissue is re-injected into the recipient body areas of the same patient autologously.

This device is intended for autologous fat transfer. The Smart Kit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

Neurosurgery / Gastrointestinal Surgery / Urological Surgery / General surgery / Orthopedic Surgery / Gynecological Surgery / Thoracic Surgery / Laparoscopic/ Arthroscopic Surgery/Plastic and reconstructive surgery.

Summary of Technology Characteristics:

Smart Kit is substantially equivalent to the predicate device. A comparison of technological characteristics is provided in the table below. Both the subject device and the predicate device provide a method of harvesting, concentrating, and transferring of autologous adipose tissue. In addition, both the subject and predicate devices are preassembled systems which are provided sterile (via ethylene oxide) and intended for single use.

| Attribute | Subject
Device
Smart Kit | Predicate
DermaposeTM Refresh
(K193363) | Same/Different |
|--------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|
| Device
Classification | System, Suction,
Lipoplasty | System, Suction,
Lipoplasty | |
| Regulation
Number | 21CFR
878.5040 | 21 CFR 878.5040 | |
| Product Code | MUU | MUU | |
| Intended Use | The Smart Kit is disposable
and is indicated for autologous
fat transfer. The autologous fat
transfer is also technically
called as autologous fat
grafting or reinjection of
concentrated adipose-tissue
into the recipient body areas.
The Smart kit can be used for
concentration and transfer of
homogenous adipose tissues
with legally marketed
lipoplasty system when the
concentrated and homogenous
fat tissue is re-injected into the
recipient body areas of the
same patient autologously.

This device is intended for
autologous fat transfer. The | The DermaposeTM Refresh is a
sterile medical device intended
for the closed-loop processing
of lipoaspirate tissue in medical
procedures involving the
harvesting, concentrating and
transferring of autologous
adipose tissue harvested with a
legally marketed lipoplasty
system. The device is intended
for use in the following surgical
specialties when the transfer of
harvested adipose tissue is
desired: orthopedic surgery,
arthroscopic surgery,
neurosurgery, gastrointestinal
and affiliated organ surgery,
urological surgery, general | |
| Attribute | Subject
Device
Smart Kit | Predicate
Dermapose™ Refresh
(K193363) | Same/Different |
| | Smart Kit is intended for use in
the following surgical
specialties when the
concentration of harvested
adipose tissue is desired.

Neurosurgery /
Gastrointestinal Surgery /
Urological Surgery / General
surgery / Orthopedic Surgery /
Gynecological Surgery /
Thoracic Surgery /
Laparoscopic Surgery /
Arthroscopic Surgery / Plastic
and reconstructive surgery | surgery, gynecological surgery,
thoracic surgery, laparoscopic
surgery, and plastic and
reconstructive surgery when
aesthetic body contouring is
desired. Only legally marketed
accessory items, such as
syringes, should be used with
the system. If harvested fat is to
be reimplanted, the harvested
fat is only to be used without
any additional manipulation | |
| Technological
Characteristics
(Components) | Smart Kit is composed of 4
major parts: 1. Harvester
(Piston, plunger, syringe cap,
luer to luer syringe connector,
filter piston syringe(Smart
syringe) need to remove piston
plunger,2. Builtin filter
adaptor(Adinizers), 3. Syringe
handle 4. Manual handheld
suction unit (Smart Lock)

Smart Kit Variations:

  1. Smart Kit Basic(SKT-
    010,SKT-020, SKT-060,
    SKT-011, SKT-021,
    SKT-061)
    a. Smart Lock
    (PLK-002,
    PLK-003)
    b. Smart
    Syringe
    (SKT-SS-
  1. Smart Kit Pro(SKT-
    14060,SKT-24060, SKT-
    12440, SKT-22440, SKT-
    12460, SKT-22460)
    a. Adinizer
    (SKT- AN-
    100, SKT-
    AN-200,
    SKT- AN-
    400, SKT-
    AN-600,
    SKT- AN-
    1200, SKT-
    AN-
    2400,SKT-
    AN-4000,
    SKT-AN-
    4060, SKT-
    AN-4040, SKT- | 50 mL polycarbonate
    harvesting and
    processing syringe unit
    with vacuum lock and 30
    mL output syringe
    containing a two- stage
    sieve filter on the inletTwo 30 mL
    polypropylene
    luer-lock syringesThree luer capsLuer-to-luer adapter | |
    | Attribute | Subject
    Device
    Smart Kit | Predicate
    Dermapose™ Refresh
    (K193363) | Same/Different |
    | | AN-2440, SKT-
    AN-101, SKT-
    AN-201, SKT-
    AN-401, SKT-
    AN-601, SKT-
    AN-1201, SKT-
    AN-2401, SKT-
    AN-4001, SKT-
    AN-2460, SKT-
    AN-1240, SKT-
    AN-6020, SKT-
    AN-24201,
    SKT-AN-

b. Smart Syringe
(SKT-SS-100) | | |
| Device Size | • BD syringe 10cc (NB
No.0086)
• BD syringe 20cc (NB
No.0050)
• BD syringe 60cc (NB
No.0050) | 50 ml syringe | |
| User
Environment | Physician | Physician | |
| Method of
Harvesting | Cannula | Cannula | |
| Construction | Preassembled | Preassembled | |
| Device
Performs
Harvestin
g | Syringe generated vacuum-
lock | Syringe generated vacuum-
lock | |
| Filter/Mesh | Concentrated adipose-tissue
passes through (4000-400 µm)
mesh outlet into the
reconstructing area. | 1000 and 800 micron mesh at
outlet - collected adipose
tissue passes though both | |
| Sterilization
Method | Ethylene-Oxide Gas (EtO) | Ethylene-Oxide Gas (EtO) | |
| Sterility
Assurance
Level | SAL 10-6
Shelf life: 3 years | SAL 10-6
Shelf life: 3 years | |
| Disposable or
reusable | Single Use, Disposable | Single Use, Disposable | |
| Biocompatibility | Biocompatible | Biocompatibility | |

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Performance Testing:

Smart Kit was tested in accordance with established protocols and met the acceptance criteria for all tests performed.

Performance testing include:

Test ItemTest Requirement
AppearanceThere should be no visible scratches, damage, or
foreign material
MeasurementWhen measuring with Vernier calipers, according to
the dimension of "shape and structure" part, the
stated should be within $\pm$ 5%
Water TightnessWhen tested according to the test method, there
should be no leakage
Centrifugation
Compatibility
Test
(Leakage)When tested according to the test method, it should
be aspirated to the maximum capacity without
leakage
Cell Viability TestThe finally filtered adipose tissues for autologous fat
transfer should maintain at least over 85 % of the cell
viability.
Pore SizeWhen measuring with Vernier calipers, according to
the dimension of 'shape and structure' part, the stated
should be within $\pm$ 15 %.
pHDifference of pH $\leq$ 1.5
Potassium permanganate
reducing substancesDifference of the consumption $\leq$ 2.0 mL
Evaporating residueDifference of residues $\leq$ 1.0mg
Heavy MetalsThe test solution should not be darker than blank
solution.
Ultraviolet-visibleDifference of the maximum absorbance at (250~350)
nm $\leq$ 0.1

Sterilization and Shelf Life

Smart Kit was verified for validation for 3 years (36 months) by testing physicochemical changes and packaging of the materials and the product before, middle, and after acceleration aging according to ISO 11607.

Sterilization was conducted on the Smart Kit Fat Separator with Ethylene oxide gas.

10

Sterilization is performed with the cycle validation on the report in accordance with EN

ISO11135:2014 Sterilization of medical devices validation and routine control of sterilization by Ethylene oxide gas. The sterilizing cycle has been validated to ensure our products to be sterilized to an S.A.L. of at least 106 by EN ISO11135:2014 by the method of over-kill.

Biocompatibility

Biocompatibility testing for Smart Kit was performed in accordance with the requirements of ISO 10993-1:2009 for external communicating devices having contact