(231 days)
The ASPIVIX v1.1 Cervical Suction Tenaculum is indicated to snare, grasp, hold and manipulate cervical tissue.
ASPIVIX v1.1 is a sterile, single-use, one-piece device that consists of four non-removable parts: a reloadable vacuum reserve embedded inside the main body, an activation / deactivation slider ring, a sliding tube to generate vacuum in the main body and an anatomic suction pad to put in contact with the cervix.
This document describes a 510(k) premarket notification for the ASPIVIX v1.1 Cervical Suction Tenaculum. It details the device's indications for use, comparison to a predicate device, and performance data provided to support substantial equivalence.
Based on the provided text, the device itself is a manual instrument, not an AI device. Therefore, many of the requested elements pertaining to AI device validation (e.g., sample size for test/training sets, data provenance, expert ground truth establishment, MRMC studies, standalone performance, etc.) are not applicable to this submission. The 510(k) summary focuses on demonstrating that the new manual device is as safe and effective as a legally marketed predicate device.
However, I can extract the information relevant to the performance data and acceptance criteria as described for this manual device.
1. Table of Acceptance Criteria and Reported Device Performance
The document broadly states that "All test results were in accordance with the test acceptance criteria." However, it does not explicitly list the specific numerical acceptance criteria for each test. Instead, it lists the types of performance tests conducted and the general conclusion.
| Performance Test Category | Specific Tests Conducted | Reported Device Performance and Acceptance Criteria |
|---|---|---|
| Biocompatibility | Cytotoxicity (ISO 10993-5:2009) | Non-cytotoxic |
| Sensitization (ISO 10993-10:2010) | Non-sensitizing | |
| Vaginal Irritation (ISO 10993-10:2010) | Non-irritating | |
| Sterilization | Sterilization validation (e-beam irradiation) | Performed in accordance with ANSI/AAMI/ISO 11137-2: 2013 |
| Performance Testing | Release traction force | In accordance with test acceptance criteria (specific values not provided in this summary) |
| Mechanical traction (pull) | In accordance with test acceptance criteria (specific values not provided in this summary) | |
| Bend strength | In accordance with test acceptance criteria (specific values not provided in this summary) | |
| Tissue safety | In accordance with test acceptance criteria (specific values not provided in this summary) |
2. Sample Size Used for the Test Set and Data Provenance
This information is not provided in the given text. The document refers to "testing" but does not specify the number of units or samples used for each test, nor the provenance (country of origin, retrospective/prospective) of any clinical data, as this is a physical medical device clearance, not an AI/software as a medical device (SaMD) submission.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable and not provided. As this is a manual medical device, there is no "ground truth" to be established by experts in the context of image interpretation or diagnostic accuracy. The testing involves physical and biological properties.
4. Adjudication Method for the Test Set
This information is not applicable and not provided. Adjudication methods like 2+1 or 3+1 are typical for human reader studies with AI, which are not relevant for this manual device.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
This information is not applicable and not provided. MRMC studies are used to evaluate diagnostic performance of AI or human readers, which is not the type of claim being made or evaluated for this manual device.
6. Standalone Performance (Algorithm Only)
This information is not applicable and not provided. This is a manual physical device, not an algorithm or software.
7. Type of Ground Truth Used
This information is not applicable in the AI/diagnostic sense. For this manual device, the "ground truth" or reference standards are the established performance metrics and biocompatibility standards (e.g., ISO standards for cytotoxicity, sensitization, irritation; mechanical testing standards for traction and bend strength).
8. Sample Size for the Training Set
This information is not applicable and not provided. This device does not involve machine learning or AI models with training sets.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable and not provided. As above, there is no training set as this is not an AI device.
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September 3, 2021
Aspivix S.A. Julien FINCI CTO & Co-founder Chemin du Closel 5 Renens, Renens 1020 SWITZERLAND
Re: K203820
Trade/Device Name: ASPIVIX v1.1 Cervical Suction Tenaculum Regulation Number: 21 CFR 884.4530 Regulation Name: Obstetric-gynecologic specialized manual instrument Regulatory Class: II Product Code: HDC
Dear Julien FINCI:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated 8/17/21. Specifically, FDA is updating this SE Letter to correct the contact's name as an administrative correction. The issued letter did not reflect the change in contact person that occurred during the agency review.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Jason Roberts, OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices, (240) 402-6400. Jason.Roberts@fda.hhs.gov.
Sincerely,
Jason Roberts -S
Jason R. Roberts, Ph.D. 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
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Image /page/1/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
August 17, 2021
Aspivix S.A. Benjamin Klein Regulatory Affairs and Quality Manager Chemin du Closel Renens. Renens 1020 Switzerland
Re: K203820
Trade/Device Name: ASPIVIX v1.1 Cervical Suction Tenaculum Regulation Number: 21 CFR§ 884.4530 Regulation Name: Obstetric-Gynecologic Specialized Manual Instrument Regulatory Class: II Product Code: HDC Dated: June 28, 2021 Received: July 13, 2021
Dear Benjamin Klein:
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 mav, 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.
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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,
Jason Roberts -S
Jason R. Roberts, Ph.D. 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) K203820
Device Name ASPIVIX v1.1 Cervical Suction Tenaculum
Indications for Use (Describe)
The ASPIVIX v1.1 Cervical Suction Tenaculum is indicated to snare, grasp, hold and manipulate cervical tissue.
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
| Submitter: | ASPIVIX SA |
|---|---|
| Chemin du Closel 5 | |
| 1020 Renens | |
| Switzerland | |
| Contact Person: | Julien FINCI, |
| Regulatory Affairs & Quality Manager | |
| Telephone: +41 (0) 76 327 87 97 | |
| E-mail: julien.finci@aspivix.com | |
| Date Prepared: | August 10, 2021 |
| Name of Device: | ASPIVIX v1.1 Cervical Suction Tenaculum |
| Common Name: | Cervical Tenaculum |
| Device Class: | Class II |
| Regulation Name &Number: | 21 CFR 884.4530 - Obstetric-gynecologic specialized manualinstrument |
| Predicate Device: | K073182 - GYN Disposables INC Tenaculum 356T |
| The predicate device has not been subject to a design-related recall. | |
| Product Code: | HDC, Tenaculum, Uterine |
| Reference Device: | Bioceptive Suction Cervical Retractor (K142204) |
| Description of Device: | ASPIVIX v1.1 is a sterile, single-use, one-piece device that consistsof four non-removable parts: a reloadable vacuum reserve embeddedinside the main body, an activation / deactivation slider ring, a slidingtube to generate vacuum in the main body and an anatomic suctionpad to put in contact with the cervix. |
| Indication for Use: | ASPIVIX v1.1 Cervical Suction Tenaculum is indicated to snare,grasp, hold and manipulate cervical tissue. |
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| Comparison ofTechnologicalCharacteristics withthe PredicateDevice: | ASPIVIX v1.1 | Tenaculum 356T(Predicate) |
|---|---|---|
| 510(k) number | K203820 | K073182 |
| Product Code | HDC | HDC |
| Indication for Use | The ASPIVIX v1.1 Cervical SuctionTenaculum is indicated to snare,grasp, hold and manipulate cervicaltissue | Snare, grasp, hold andmanipulate cervical andintravaginal tissue |
| Design | Suction pad grasps cervical tissuetrough vacuum.Handle with one hand.Sliding lock. | Two Tips grasp cervical andintravaginal tissue.Handle with two finger holes.Ratcheting lock. |
| Material | Polycarbonate/Polyester,thermoplastic elastomer, Mixture ofmethacrylic acid esters andphotoinitiator, Polypropylene likematerial and Triethyl O-acetylcitrate | Glass Reinforced Polycarbonate |
| Use Environment | Healthcare professional in ahealthcare facility | Healthcare professional in ahealthcare facility |
| Sterilization | Yes | Yes |
| Single use | Yes | Yes |
| The differences in technological characteristics do not raise differentquestions of safety and effectiveness. | ||
| Indications for UseComparison | The subject and predicate device have the same intended use to snare,grasp, hold, and manipulate cervical tissue. | |
| Performance Data: | The following performance data were provided in support of substantialequivalence. | |
| Biocompatibility testing | ||
| The biocompatibility evaluation for ASPIVIX v1.1 was conducted inaccordance with the FDA guidance "Use of International Standard ISO10993-1, "Biological evaluation of medical devices - Part 1: Evaluation andtesting within a risk management process". Testing included: | ||
| ● Cytotoxicity (ISO 10993-5:2009)● Sensitization ((ISO 10993-10:2010) | ||
| • Vaginal Irritation (ISO 10993-10:2010) | ||
| The results of testing demonstrated the subject device is non-cytotoxic,non-sensitizing, and non-irritating. | ||
| Sterilization | ||
| The device is provided sterile via irradiation by e-beam. Sterilizationvalidation was performed in accordance with methods equivalent toANSI/AAMI/ISO 11137-2: 2013. | ||
| Performance Testing | ||
| Testing was performed in order to assess the performance and safety ofASPIVIX v1.1 according to the requirements specified in its designs anduser specifications. All test results were in accordance with the testacceptance criteria. Testing included release traction force, mechanicaltraction (pull), bend strength, and tissue safety. | ||
| Conclusion: | The results of performance testing described above demonstrate that theASPIVIX v1.1 is as safe and effective as the predicate device and supportsa determination of substantial equivalence. |
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§ 884.4530 Obstetric-gynecologic specialized manual instrument.
(a)
Identification. An obstetric-gynecologic specialized manual instrument is one of a group of devices used during obstetric-gynecologic procedures to perform manipulative diagnostic and surgical functions (e.g., dilating, grasping, measuring, and scraping), where structural integrity is the chief criterion of device performance. This type of device consists of the following:(1) An amniotome is an instrument used to rupture the fetal membranes.
(2) A circumcision clamp is an instrument used to compress the foreskin of the penis during circumcision of a male infant.
(3) An umbilical clamp is an instrument used to compress the umbilical cord.
(4) A uterine curette is an instrument used to scrape and remove material from the uterus.
(5) A fixed-size cervical dilator is any of a series of bougies of various sizes used to dilate the cervical os by stretching the cervix.
(6) A uterine elevator is an instrument inserted into the uterus used to lift and manipulate the uterus.
(7) A gynecological surgical forceps is an instrument with two blades and handles used to pull, grasp, or compress during gynecological examination.
(8) A cervical cone knife is a cutting instrument used to excise and remove tissue from the cervix.
(9) A gynecological cerclage needle is a looplike instrument used to suture the cervix.
(10) A hook-type contraceptive intrauterine device (IUD) remover is an instrument used to remove an IUD from the uterus.
(11) A gynecological fibroid screw is an instrument used to hold onto a fibroid.
(12) A uterine sound is an instrument used to determine the depth of the uterus by inserting it into the uterine cavity.
(13) A cytological cervical spatula is a blunt instrument used to scrape and remove cytological material from the surface of the cervix or vagina.
(14) A gynecological biopsy forceps is an instrument with two blades and handles used for gynecological biopsy procedures.
(15) A uterine tenaculum is a hooklike instrument used to seize and hold the cervix or fundus.
(16) An internal pelvimeter is an instrument used within the vagina to measure the diameter and capacity of the pelvis.
(17) A nonmetal vaginal speculum is a nonmetal instrument used to expose the interior of the vagina.
(18) A fiberoptic nonmetal vaginal speculum is a nonmetal instrument, with fiberoptic light, used to expose and illuminate the interior of the vagina.
(b)
Classification. (1) Class II (special controls). The device, when it is an umbilical clamp with or without a cutter, a uterine tenaculum which is sterile and does not use suction and is intended for single use, a nonmetal vaginal speculum, or a fiberoptic nonmetal vaginal speculum, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 884.9.(2) Class I for the amniotome, uterine curette, cervical dilator (fixed-size bougies), cerclage needle, IUD remover, uterine sound, and gynecological biopsy forceps. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 884.9.