K Number
K203119
Device Name
ClearPetra Suction-Evacuation Sheath
Date Cleared
2020-12-09

(54 days)

Product Code
Regulation Number
876.1500
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The ClearPetra Suction-Evacuation Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. It is designed to establish a conduit for the treatment of urinary stones or other urinary diseases during endoscopic procedures.
Device Description
The ClearPetra Suction-Evacuation Sheath consists of a straight distal tube and a proximal bifurcated tube. The distal straight tube of the ureteral access sheath is reinforced with metal wires for torque resistance. One segment of the proximal bifurcated tube is straight and is contiguous with the distal tube. The other is constructed in an oblique angle with a longitudinal pressure control vent. An obturator is included for the insertion of the sheath. The obturator can be locked to the proximal end of the straight tube using a luer lock mechanism. A rubber cap with central aperture is included as an accessory. It is to be placed at the proximal end of the straight tube after the removal of the obturator. The oblique tube is to be connected directly to a negative pressure aspirator with a clear tube or alternatively, connected to a specimen collector (packed separately) then onto a negative pressure aspirator.
More Information

Not Found

No
The description focuses on the mechanical components and function of a suction-evacuation sheath, with no mention of AI or ML capabilities.

No.
The device facilitates a medical procedure, but it does not directly treat a disease or medical condition.

No

Explanation: The device is described as a "Suction-Evacuation Sheath" used to "establish a conduit" and facilitate the passage of instruments for the "treatment of urinary stones or other urinary diseases." Its function is mechanical (establishing access and suction/evacuation), not to collect or analyze data for diagnosis.

No

The device description clearly outlines physical components like tubes, metal wires, an obturator, and a rubber cap, indicating it is a hardware device.

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 used to "establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract." This describes a surgical or procedural device used in vivo (within the body) to aid in treatment.
  • Device Description: The description details a physical sheath, obturator, and connections for suction and potentially a specimen collector. This aligns with a surgical access device, not a device used to perform tests on biological samples in vitro (outside the body).
  • Lack of IVD Characteristics: There is no mention of the device being used to analyze biological samples (like urine, blood, etc.) to diagnose, monitor, or predict disease. The focus is on facilitating access and removal of materials during a procedure.

IVD devices are specifically designed to perform tests on samples taken from the human body to provide information for diagnosis, monitoring, or treatment decisions. This device's function is purely procedural.

N/A

Intended Use / Indications for Use

The ClearPetra Suction-Evacuation Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. It is designed to establish a conduit for the treatment of urinary stones or other urinary diseases during endoscopic procedures.

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

FED, FAJ, FGA

Device Description

The ClearPetra Suction-Evacuation Sheath consists of a straight distal tube and a proximal bifurcated tube. The distal straight tube of the ureteral access sheath is reinforced with metal wires for torque resistance. One segment of the proximal bifurcated tube is straight and is contiguous with the distal tube. The other is constructed in an oblique angle with a longitudinal pressure control vent. An obturator is included for the insertion of the sheath. The obturator can be locked to the proximal end of the straight tube using a luer lock mechanism. A rubber cap with central aperture is included as an accessory. It is to be placed at the proximal end of the straight tube after the removal of the obturator. The oblique tube is to be connected directly to a negative pressure aspirator with a clear tube or alternatively, connected to a specimen collector (packed separately) then onto a negative pressure aspirator.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

urinary tract

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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)

The following performance testing comparing the modified device to the predicate device was conducted.

  • A Performance Bench testing has been conducted to verify that the performance of the proposed ClearPetra Suction-Evacuation Sheath is substantially equivalent to the predicate device, and that the ClearPetra Suction-Evacuation Sheath will perform as intended. Bench-top testing was conducted to assure conformance to the following standards:
    • Product Specification
  • A The following Biocompatibility testing was performed in accordance with ISO 10993-1.
    • Cytotoxicity
    • Sensitization
    • Irritation/ Intracutaneous reactivity
    • Acute System Toxicity
    • Material Mediated Pyrogencity
  • A Sterilization by ethylene oxide has been validated for ClearPetra Nephrostomy Sheath.

Conclusions Drawn from the Non-Clinical Testing:
The performance and biocompatibility testing provided in this submission demonstrate that the modified ClearPetra Suction-Evacuation Sheath is as safe and effective and performs as well as the predicate device and therefore supports the determination of substantial equivalence.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K161110

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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 9, 2020

Well Lead Medical Co., LTD. Jenny Zhu RA Specialist C-4# Jinhu Industrial Estate, Hualong, Panyu Guangzhou, Guangdong 511434 China

Re: K203119

Trade/Device Name: ClearPetra Suction-Evacuation Sheath Regulation Number: 21 CFR§ 876.1500 Regulation Name: Endoscope and Accessories Regulatory Class: II Product Code: FED, FAJ, FGA Dated: October 14, 2020 Received: October 16, 2020

Dear Jenny Zhu:

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.

1

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-regulatoryinformation/postmarketing-safety-reporting-combination-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 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,

Mark J. Antonino, M.S. Acting Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology 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) K203119

Device Name ClearPetra Suction-Evacuation Sheath

Indications for Use (Describe)

The ClearPetra Suction-Evacuation Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other into the urinary tract. It is designed to establish a conduit for the treatment of urinary stones or other urinary diseases during endoscopic procedures.

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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510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92.

1. Submitter Information

Date:11/18/2020
Submitter:WELL LEAD MEDICAL CO., LTD.
Address: C-4 # Jinhu Industrial Estate, Hualong, Panyu, Guangzhou
511434, P.R. China
Jenny Zhu
RA Specialist
Contact Person:WELL LEAD MEDICAL CO., LTD.
Email: jenny_zhu@welllead.com.cn
Tel: +86-20-84758878-8029
Device Name:ClearPetra Suction-Evacuation Sheath
Regulation Number:21 CFR 876.1500
Regulation Name:Endoscope and Accessories
Product Code:FED-Endoscopic Access Overtube, Gastroenterology-Urology
FAJ-Cystoscope And Accessories, Flexible/Rigid
FGA-Kit, Nephroscope
Regulatory Class:Class II

Predicate Device(s): K161110- ClearPetra Suction-Evacuation Sheath

2. Indications for use

The ClearPetra Suction-Evacuation Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. It is designed to establish a conduit for the treatment of urinary stones or other urinary diseases during endoscopic procedures.

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3. Device Description

The ClearPetra Suction-Evacuation Sheath consists of a straight distal tube and a proximal bifurcated tube. The distal straight tube of the ureteral access sheath is reinforced with metal wires for torque resistance. One segment of the proximal bifurcated tube is straight and is contiguous with the distal tube. The other is constructed in an oblique angle with a longitudinal pressure control vent. An obturator is included for the insertion of the sheath. The obturator can be locked to the proximal end of the straight tube using a luer lock mechanism. A rubber cap with central aperture is included as an accessory. It is to be placed at the proximal end of the straight tube after the removal of the obturator. The oblique tube is to be connected directly to a negative pressure aspirator with a clear tube or alternatively, connected to a specimen collector (packed separately) then onto a negative pressure aspirator.

Modification:

The ClearPetra Suction-Evacuation Sheath differs from the predicate device as below:

(1) Product Size Change: Add 24Fr, 26Fr in product model of ClearPetra Nephrostomy Sheath;

(2) Product Length Change: Add 15cm in product model of ClearPetra Nephrostomy Sheath.

The intended use of the modified device, as described in its labeling, has not changed as a result of the modification.

4. Substantial Equivalence-Comparison to Predicate Device

The predicate device to which we claim equivalence is the ClearPetra Suction-Evacuation Sheath (K161110).

The ClearPetra Suction-Evacuation Sheath maintains the same intended use as the predicate device. It is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. It is designed to establish a conduit for the treatment of urinary stones or other urinary diseases during the endoscopic procedures. The proposed device and the predicate device consist of the same fundamental technology.

The ClearPetra Suction-Evacuation Sheath differs from the predicate device in product model of ClearPetra Nephrostomy Sheath as below:

(1) Product Size Change: Add 24Fr, 26Fr in product model of ClearPetra Nephrostomy Sheath; (2) Product Length Change: Add 15cm in product model of ClearPetra Nephrostomy Sheath. The modification has not altered the fundamental scientific technology of the predicate ClearPetra Suction-Evacuation Sheath. It has well-established methods are available to evaluate the change as well as all performance data necessary to support SE can be reviewed in a summary or risk analysis format.

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Therefore, the modified ClearPetra Suction-Evacuation Sheath is substantially equivalent to the current legally marketed ClearPetra Suction-Evacuation Sheath (K161110) device. The differences between the ClearPetra Suction-Evacuation Sheath and the predicate device raise no different issues of safety and effectiveness.

A Risk Analysis was conducted and is detailed in the Design Control Summary Section. No new issues of safety and effectiveness were identified during this process.

The ClearPetra Suction-Evacuation Sheath and the predicate device consist of the same fundamental technology and are sterilized with acceptable methods. Below is a comparison table that summarizes the technological characteristics of the proposed and predicate device.

Comparison between proposed device and predicate device
Comparison ItemsSubject DevicePredicate DeviceVerdict
Product NameClearPetra Suction-Evacuation
SheathClearPetra Suction-Evacuation
SheathSame
Model NameClearPetra Nephrostomy SheathClearPetra Nephrostomy SheathSame
510k NumberApplyingK161110Same
Product CodeFED, FAJ, FGAFED, FAJ, FGASame
Regulation Number21 CFR 876.150021 CFR 876.1500Same
Regulatory ClassClass IIClass IISame
Review PanelGastroenterology/UrologyGastroenterology/UrologySame
Indications for UseIt is used to establish a conduit
during endoscopic urological
procedures facilitating the passage
of endoscopes and other
instruments into the urinary tract. It
is designed to establish a conduit
for the treatment of urinary stones
or other urinary diseases during the
endoscopic procedures.It is used to establish a conduit
during endoscopic urological
procedures facilitating the passage
of endoscopes and other
instruments into the urinary tract. It
is designed to establish a conduit
for the treatment of urinary stones
or other urinary diseases during the
endoscopic procedures.Same
Patient PopulationPatients undergoing endoscopic
procedures, through percutaneous
passagesPatients undergoing endoscopic
procedures, through percutaneous
passagesSame
Comparison between proposed device and predicate device
Comparison ItemsSubject DevicePredicate DeviceVerdict
MaterialPE, PAPE, PASame
Sterilization MethodEO sterilizedEO sterilizedSame
Size10Fr to 26Fr10Fr to 22FrDifferent.
Since the new product
specification is not far
outside cleared product
specification, the change
could not significantly
affect the device's safety
or effectiveness. The
new product
specifications were
tested as per Product
Specification.
OD of ObturatorCompatible with 10Fr-26Fr sheathCompatible with 10Fr-22Fr sheathSame
Length13cm to 55cm13cm to 55cmSimilar
Although a modified
dimension is within a
range of dimensions
previously cleared for the
original device, the
change could not
significantly affect the
device's safety or
effectiveness. The new
product specifications
were tested as per
Product Specification.
ComponentSheath, Obturator, Connector, Rubber CapSheath, Obturator, Connector, Rubber CapSimilar
Design DrawingImage: Design Drawing of deviceImage: Design Drawing of deviceSame
Sterilization MethodEO sterilizedEO sterilizedSame
Single UseYesYesSame
Comparison between proposed device and predicate device
Comparison ItemsSubject DevicePredicate DeviceVerdict
BiocompatibilityISO 10993-1
Cytotoxicity, Irritation, Sensitization,
Acute System Toxicity, Material
mediated pyrogencityISO 10993-1
Cytotoxicity, Irritation, Sensitization,
Acute System ToxicitySimilar
The subject device's
materials in contact were
tested as per ISO 10993-
11 for Material mediated
pyrogencity.

Table 5-1 - Comparison Between Subject Device & Predicate Device

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Discussion

Although there is a bit difference of the product specification and dimension between the predicate device and subject device, they have the same technological features, performance, intended use and manufactured in the same manner as currently marketed device. The newly change in subject device has been evaluated by a well-established method of bench testing. And the data has been reviewed in a summary or risk analysis format to show that modification does not affect the safety and effectiveness.

5. Summary of Non-Clinical Testing

The following performance testing comparing the modified device to the predicate device was conducted.

  • A Performance Bench testing has been conducted to verify that the performance of the proposed ClearPetra Suction-Evacuation Sheath is substantially equivalent to the predicate device, and that the ClearPetra Suction-Evacuation Sheath will perform as intended. Bench-top testing was conducted to assure conformance to the following standards:
    • � Product Specification
  • A The following Biocompatibility testing was performed in accordance with ISO 10993-1.
    • � Cytotoxicity
    • � Sensitization
    • � Irritation/ Intracutaneous reactivity

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  • � Acute System Toxicity
  • � Material Mediated Pyrogencity
  • A Sterilization by ethylene oxide has been validated for ClearPetra Nephrostomy Sheath.

Conclusions Drawn from the Non-Clinical Testing

The performance and biocompatibility testing provided in this submission demonstrate that the modified ClearPetra Suction-Evacuation Sheath is as safe and effective and performs as well as the predicate device and therefore supports the determination of substantial equivalence.

6. Conclusion

The ClearPetra Nephrostomy Sheath is substantially equivalent to predicate device. Based on the intended use, principle of operation, performance characteristics, and technological characteristics, the proposed ClearPetra Nephrostomy Sheath is substantially equivalent to and as safe, as effective and performs as the legally marketed predicate device.

7. Summary Prepared Date

18 November 2020