K Number
K202560
Device Name
AquaPulse Irrigation Tubing
Date Cleared
2020-12-10

(97 days)

Product Code
Regulation Number
876.1500
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The 24 hour use AquaPulse® Irrigation Tubing (tubing and accessories to accommodate various GI endoscopes and irrigation pumps) is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.
Device Description
The AquaPulse® Irrigation Tubing is intended for 24-hour use and then discarded. The irrigation tubing is manufactured for use in conjunction with sterile water bottle, and together with irrigation pumps. The irrigation tubing is individually packed in sealed package, sold as a sterile device. The irrigation tubing is designed to the auxiliary water connector or biopsy irrigation accessory and to be inserted into pump head of the irrigation pump to provide irrigation through the auxiliary water channel to the distal end of endoscope.
More Information

Not Found

No
The summary describes a simple irrigation tubing system and does not mention any AI or ML components or functionalities.

No

Explanation: The device is an irrigation tubing used during gastrointestinal endoscopic procedures to provide irrigation. It is an accessory to a medical procedure, not a device that directly treats a disease or condition.

No
The device, AquaPulse® Irrigation Tubing, is described as providing irrigation during gastrointestinal endoscopic procedures. Its function is to deliver sterile water, not to visualize, measure, or analyze physiological parameters for diagnostic purposes.

No

The device description clearly states it is "irrigation tubing" and describes physical components and their interaction with other hardware (sterile water bottle, irrigation pumps, endoscope). There is no mention of software as the primary or sole component.

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

Here's why:

  • Intended Use: The intended use clearly states that the device is for providing irrigation during gastrointestinal endoscopic procedures. This is a procedural aid, not a diagnostic test performed on samples taken from the body.
  • Device Description: The description focuses on the physical components and how they facilitate irrigation during a procedure. There is no mention of analyzing biological samples or providing diagnostic information.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring specific analytes
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions.

The device is a medical device used to facilitate a medical procedure (endoscopy), but it does not perform an in vitro diagnostic test.

N/A

Intended Use / Indications for Use

The 24 hour use AquaPulse® Irrigation Tubing (tubing and accessories to accommodate various GI endoscopes and irrigation pumps) is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.

Product codes

OCX

Device Description

The AquaPulse® Irrigation Tubing is intended for 24-hour use and then discarded. The irrigation tubing is manufactured for use in conjunction with sterile water bottle, and together with irrigation pumps. The irrigation tubing is individually packed in sealed package, sold as a sterile device. The irrigation tubing is designed to the auxiliary water connector or biopsy irrigation accessory and to be inserted into pump head of the irrigation pump to provide irrigation through the auxiliary water channel to the distal end of endoscope.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Hospital and or clinics

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

The bench testing was performed to support substantial equivalence such as verification tests on flow performances of subject devices and predicate devices. The performance data demonstrated that the subject devices met established specifications.

Key Metrics

Not Found

Predicate Device(s)

K092429

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 876.1500 Endoscope and accessories.

(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.

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December 10, 2020

GA Health Company Limited Cindy Ye Chief Executive Officer Unit 18, 21/F, Metropole Square, 2 On Yiu Street, Shatin Hong Kong, CHINA

Re: K202560

Trade/Device Name: AquaPulse® Irrigation Tubing Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: OCX Dated: November 4, 2020 Received: November 9, 2020

Dear Cindy Ye:

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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's

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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 (OS) 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 mediation-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,

Shanil P. Haugen, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant 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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Indications for Use

510(k) Number (if known) K202560

Device Name AquaPulse® Irrigation Tubing

Indications for Use (Describe)

The 24 hour use AquaPulse® Irrigation Tubing (tubing and accessories to accommodate various GI endoscopes and irrigation pumps) is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.

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)

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K202560 Page 1 of 3

510(k) Premarket Notification: Traditional Irrigation Tubing GA Health Company Limited CONFIDENTIAL

510(k) Summary

The 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of the Safe Medical Devices Act of 1990 and 21 CFR 807.92.

1. Submission Sponsor

Submitter's Name: Submitter's Address:

Establishment Reqistration No.:

2. Sponsor Contact

Cindy Ye Chief Executive Officer Telephone: +852 2833 9010

GA Health Company Limited Unit 18, 21/F, Metropole Square

2 On Yiu Street ,Shatin, N.T,

Hong Kong. CHINA

3014749926

Email: cindv@gahealth.net

Lam Wing Yu Senior Product Compliance Specialist Telephone: +852 2833 9010 Email: rainy@gahealth.net

3. Date Prepared

10 Dec 2020

4. Device Identification

  • Trade Device Name: Common Name: Product Code: Produce Code Name: Requlation Number: Requlation Name: Requlatory Classification: Device Panel:
    AquaPulse® Irrigation Tubing Irrigation tubing for endoscope ОСХ Endoscopic Irrigation/Suction System 21 CFR 876.1500 Endoscope and accessories 2 Gastroenterology/Urology

5. Predicate Device Identification

Predicate Device 510(k) No.: Predicate Device Trade Name: Predicate Device Product Code: K092429 EndoGator FEQ

6. Device Description:

The AquaPulse® Irrigation Tubing is intended for 24-hour use and then discarded. The irrigation tubing is manufactured for use in conjunction with sterile water bottle, and together with irrigation pumps. The irrigation tubing is individually packed in sealed package, sold as a sterile device. The irrigation tubing is designed to the auxiliary water connector or biopsy irrigation accessory and to be inserted into pump head of the irrigation pump to provide irrigation through the auxiliary water channel to the distal end of endoscope.

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7. Indications for Use:

The 24 hour use AquaPulse® Irrigation Tubing (tubing and accessories to accommodate various GI endoscopes and irrigation pumps) is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.

8. Technological Characteristics

Table 2 summarizes the irrigation tubing technological characteristics as compared to the predicate devices.

Table 2 Summary of design, features and principles of operation and technological characteristics between the subject device and predicate devices

| Specification | Predicate Device | Subject Device | Substantial
Equivalence |
|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
| Product code | FEQ | OCX | Identical |
| Regulatory
Classification | 2 | 2 | Identical |
| Regulation No | 21 CFR 876.1500 | 21 CFR 876.1500 | Identical |
| Regulation
Description | Endoscope and accessories | Endoscope and accessories | Identical |
| Compatibility | Olympus® AFU-100, Olympus®
OFP, ERBE® EIP2 or EGP-100
Irrigation Pumps | Olympus® OFP, Endo Status™
EGA-500 and Endogator® EGP-
100 Irrigation Pump | Substantial
Equivalent |
| Indications for
Use | The ENDOGATOR® system is
intended to provide irrigation via
sterile water during Gl
endoscopic procedures when
used in conjunction with an
irrigation pump (or cautery unit). | The 24 hour use AquaPulse®
Irrigation Tubing (tubing and
accessories to accommodate
various GI endoscopes and
irrigation pumps) is intended to
provide irrigation via a sterile
water bottle during
gastrointestinal endoscopic
procedures when used in
conjunction with an irrigation
pump. | Substantial
Equivalent |
| Environment
of Use | Hospital and or clinics | Hospital and or clinics | Identical |
| Single Use,
Disposable | 24-hour use then discard | 24-hour use then discard | Identical |
| Material | Polycarbonate and Polyvinyl
Chloride | Polycarbonate and Polyvinyl
Chloride | Substantial
Equivalent |
| Packaging | Irrigation tubing is packaged in a
sealed pouch | Irrigation tubing is packaged in a
sealed pouch | Identical |
| Manufacturing
method | Injection molding and extrusion | Injection molding and extrusion | Identical |

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| Backflow
Prevention
Design | Diaphragm in the connector
allow pressurized water passing
through in one-way but not the
other way | Diaphragm in the connector
allow pressurized water passing
through in one-way but not the
other way | Identical |
|----------------------------------|--------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|---------------------------|
| Sterilization | EO gas | EO gas | Identical |
| Shelf Life | 3 years | 1 year | Substantial
Equivalent |

9. Performance Test

The bench testing was performed to support substantial equivalence such as verification tests on flow performances of subject devices and predicate devices. The performance data demonstrated that the subject devices met established specifications.

10. Sterilization

All the subject devices are sold in a sterile package. The subject devices have been sterilized in a validated EO sterilization cycle. The EO sterilization cycle has a Sterility Assurance Level (SAL) of 10°. EO residuals on the components are below the maximum levels defined in ANSI/AAMI/ISO 10993-7 Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide sterilization residuals.

11. Shelf Life

The subject devices have a one (1) year shelf life, based on the design and existing sterile barrier data from the existing packaging integrity test and performance test were conducted after accelerated aging test. The test result can imply that the subject devices can provide and maintain a sterile barrier and its intended performance for at least the claimed shelf life.

12. Biocompatibility

The biocompatibility of the subject devices was conducted in accordance with the FDA guideline "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The subject devices are classified as surface devices with mucosal membrane contact for a limited duration (not more than 24 hours). The test result shows that the subject devices are biocompatible.

13. Conclusion

The subject devices have the same intended use as the predicate devices. Based on the technological characteristics and overall performance of the devices in bench testing, there are no significant differences exist between the subject devices and the predicate devices. The subject devices do not raise any new issues of safety and effectiveness. From a clinical perspective and comparing design specifications, the subject devices and the predicate device are substantially equivalent.