K Number
K213271
Date Cleared
2023-08-31

(700 days)

Product Code
Regulation Number
876.1500
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Mediclose™ System is a single-use indicated for approximation of tissues and percutaneous suturing of port-site fascia wounds following laparoscopic surgery.

Device Description

The Mediclose™ System is an Automatic Trocar Closure (ATC) device supplied with one or more Mediclose™ Adaptors, supplied sterile for single use. The combination of the Mediclose™ Device and one Mediclose™ Adaptor results in a minimally invasive surgical system which aids surgeons in closing trocar wounds following a laparoscopic procedure. In laparoscopic surgery, trocars are used to gain access to the body in a minimally invasive way. This means that these procedures are performed through incisions of approximately 12 mm, compared to traditional open surgery which needs a large wound across the abdomen. The Mediclose™ Device is available in one size and configuration, designed for single-handed use, to which each of three Mediclose™ Adaptors can be fitted, at the user's option, depending on the make/model of trocar being used. The Mediclose™ System is intended to pass a suture through the soft-tissue laver (fascia) of a trocar wound after laparoscopic surgery. This is done with the end-goal of closing the trocar-induced wound by pulling needles through the fascia and subsequently closing the wound. The Mediclose™ System has two items: The Mediclose™ Device, which incorporates the suture and needle set; The Mediclose™ Adaptor, three color-coded models are available separately from the Mediclose™ . Device which are compatible with a specific brand/model of 12 mm trocar sleeves that are legally cleared for marketing in the USA, viz: Ethicon EndoPath Covidien VersaOne Applied Medical Kii The Mediclose™ Device also contains a needle-suture set manufactured by Assut Europe composed of two straight cylindrical needles attached to Glicofil Lac, a braided, coated, violet PGLA absorbable suture. The suture and needles are mounted into the device at the time of manufacture, making it ready to use upon opening the packaging.

AI/ML Overview

The provided FDA 510(k) summary for the Mediclose™ System focuses on non-clinical testing for substantial equivalence, rather than a study proving performance against clinical acceptance criteria. The device is a suturing device, and the evaluation is primarily based on mechanical and biocompatibility tests.

Here's a breakdown of the requested information based on the provided document:

1. Table of Acceptance Criteria and Reported Device Performance

The document presents extensive non-clinical testing with acceptance criteria. No clinical performance acceptance criteria are mentioned as no clinical studies were submitted. The table below summarizes the non-clinical acceptance criteria and reported results.

Test PurposeAcceptance CriteriaResult
Sterilization ValidationSterile after half ETO cyclePass
Shelf Life Validation:
a) Transportation testPackaging is fully functional and undamagedPass
b) Sterile pack seal integrityNo dye penetrationPass
c) Sterile pack seal strength>1.5 N/15mmPass
d) Suture needle/thread strengthAverage >14.7 N; Single result >4.41 NPass
e) Suture knot pull strengthAverage >38.2 NPass
Biocompatibility:
a) Cytotoxicity≥70% of the control mean % viabilityPass
b) SensitizationPositive response in <10% of tests animalsPass
c) Intracutaneous Reactivity[Test article mean] - [Control mean] ≥ 1.0Pass
d) Acute systemic toxicityAbsence of toxic reaction after 72 hoursPass
e) Material mediated Rabbit pyrogenTemperature rise >0.5 degCPass
f) LAL bacterial endotoxicity<0.5 EU/mlPass
Mechanical tests:
a) Mediclose joint tensile tests>15 NPass
b) Mediclose folding part to handle tensile>30 NPass
c) Mediclose folding part to handle compression>30 NPass
d) Needle retention force>15 N <30 NPass
e) Mediclose assembly tensile>30 NPass
f) Adaptor security tensile>30 NPass
g) Operating button spring resistance<23.3 NPass
h) Device passage through trocar sleeveUnrestricted passagePass
Performance tests in porcine model with pneumoperitoneumNo functional failuresPass
Performance tests in human fascia modelNo functional failuresPass

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

The sample sizes for these non-clinical tests are listed in the table above under the "Standard" column. They range from 1 sample to 44 Mediclose units, 35 guinea pigs, 3 white rabbits, or 10 male mice depending on the specific test.

The data provenance is not explicitly stated in terms of country of origin but is from internal test protocols and generally accepted international standards (ISO, ASTM, USP, EP). The tests are all described as non-clinical testing, implying a prospective testing approach conducted with the manufactured devices and biological models.

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

This information is not applicable. For these non-clinical tests, the "ground truth" is established by the specified standards (e.g., ISO, ASTM) and measured quantitatively, rather than by expert consensus. There are no human "readers" or human expert interpretations involved in determining the outcome of these mechanical or biological tests.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. As noted above, the tests are objective, quantitative measurements against predefined criteria from established standards or internal protocols, not subjective interpretations requiring adjudication.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This device is a surgical tool, not an AI-assisted diagnostic or imaging device. No MRMC study or AI assistance is mentioned.

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

Not applicable. This device is a manual surgical tool, not an algorithm.

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

The "ground truth" for the non-clinical tests is based on:

  • Quantitative measurements: Mechanical strength, physical dimensions, chemical properties, and biological reactions as defined by international standards (ISO, ASTM, USP, EP) and internal test protocols.
  • Absence of functional failures: Observed during performance tests in porcine and human fascia models.

8. The sample size for the training set

Not applicable. This device is a physical medical device, not a machine learning algorithm, so there is no training set in the typical sense. The device's design is likely based on iterative engineering and testing rather than data-driven machine learning training.

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

Not applicable, for the same reasons as point 8.

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August 31, 2023

Health Value Creation BV, trading as Corporis Medical % Roger Gray VP Quality and Regulatory Donawa Lifescience Consluting Srl Piazza Albania 10 Rome. 00153 Italy

Re: K213271

Trade/Device Name: MedicloseTM System Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: OCW, GCJ, HCF Dated: June 15, 2023 Received: June 16, 2023

Dear Roger Gray:

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

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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,

David Krause -S

David Krause, Ph.D. Deputy Director OHT4, Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health U.S. Food and Drug Administration

Enclosure

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Indications for Use

510(k) Number (if known)

K213271

Device Name Mediclose™ System

Indications for Use (Describe)

The Mediclose114 System is a single-use indicated for approximation of tissues and percutaneous suturing of port-site fascia wounds following laparoscopic surgery.

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

510(k) Reference:K213271
Device Name:Mediclose™ System
Type of 510(k) submission:Traditional
Date of submission:26 August 2023
510(k) Owner and Submitter:Health Value Creation BV, trading as Corporis MedicaOxfordlaan 556229 EV MaastrichtThe Netherlands
Owner/Operator Reg. Number:Not yet registered
510(k) Application Correspondent:Mr Roger GrayVP Quality and RegulatoryDonawa Lifescience ConsultingPiazza Albania 1000153 Rome, Italy
Phone:Email:+39 06 578 2665rgray@donawa.com
FDA Product Code:OCW, GCJ, HCF
FDA Regulation Number:21 CFR 876.1500
FDA Classification Name:Endoscopic Tissue Approximation Device
Classification Panel:Gastroenterology and Urology
Common Name:Endoscopic Tissue Approximation Device
FDA Classification:Class II
Submission Type:510(k)

Predicate Device:

The predicate device selected for comparison with the Mediclose™ is:

Predicate Device:WECK EFX Endo Fascial Closure System
Sponsor:Teleflex Medical, Inc.
510(k) Number:K132362
Clearance Date:8 October 2013
FDA Product Code:OCW, GCJ, HCF
Classification Name:Endoscopic tissue approximation device
Regulation No:21 CFR 876.1500
Class:II

Device Description:

The Mediclose™ System is an Automatic Trocar Closure (ATC) device supplied with one or more Mediclose™ Adaptors, supplied sterile for single use. The combination of the Mediclose™ Device and one Mediclose™ Adaptor results in a minimally invasive surgical system which aids surgeons in closing trocar wounds following a laparoscopic procedure. In laparoscopic surgery, trocars are used to gain access to the body in a minimally invasive way. This means that these procedures are performed through incisions of approximately 12 mm, compared to traditional open surgery which needs a large wound across the abdomen. The Mediclose™ Device is available in one size and configuration, designed for single-handed use, to which each of three Mediclose™ Adaptors can be fitted, at the user's option, depending on the make/model of trocar being used.

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The Mediclose™ System is intended to pass a suture through the soft-tissue laver (fascia) of a trocar wound after laparoscopic surgery. This is done with the end-goal of closing the trocar-induced wound by pulling needles through the fascia and subsequently closing the wound.

The Mediclose™ System has two items:

  • The Mediclose™ Device, which incorporates the suture and needle set; .
  • The Mediclose™ Adaptor, three color-coded models are available separately from the Mediclose™ . Device which are compatible with a specific brand/model of 12 mm trocar sleeves that are legally cleared for marketing in the USA, viz:
    • o Ethicon EndoPath
    • Covidien VersaOne o
    • Applied Medical Kii o

The Mediclose™ Device also contains a needle-suture set manufactured by Assut Europe composed of two straight cylindrical needles attached to Glicofil Lac, a braided, coated, violet PGLA absorbable suture. The suture and needles are mounted into the device at the time of manufacture, making it ready to use upon opening the packaging.

Indications for Use:

The Mediclose™ System is a single-use suturing device indicated for approximation of tissues and percutaneous suturing of port-site fascia wounds following laparoscopic surgery.

Comparison of Technological Characteristics Between the Subject Device and Predicate Device:

The following table provides a comparison of the technological characteristics of the subject device and selected predicate device.

Comparison of Technological Characteristics
CharacteristicSubject devicePredicate deviceSimilarity
Device nameMediclose™ SystemWECK EFXN/A
510(k) SponsorHealth Value Creation BV, trading asCorporis Medical, NetherlandsTeleflex Medical, Inc., USAN/A
510(k) ReferenceK213271K132362N/A
Clearance DateThis submission8 October 2016N/A
FDA ProductCodeOCW, GCJ, HCFOCW, GCJ, HCFSame
FDAClassificationNameEndoscopic tissue approximationdeviceEndoscopic tissue approximationdeviceSame
FDA RequlationNumber21 CFR 876.150021 CFR 876.1500Same
DevicedescriptionA minimally invasive surgical device,which aids surgeons in closing trocarwounds following a laparoscopicprocedure.Designed to facilitate placement andwithdrawal of suture loops to performrepair port entry punctures.Same
Indications foruseThe Mediclose™ System is a single-use suturing device indicated forapproximation of tissues andpercutaneous suturing of port-sitefascia wounds following laparoscopicsurgery.The WECK EFX Endo Fascial ClosureSystem has application in laparoscopicprocedures for approximation of tissuesand percutaneous suturing for closingincision sites.Equivalent
Use environmentOperating room, sterile fieldOperating room, sterile fieldSame
PatientpopulationPatients undergoing abdominallaparoscopic surgeryPatients undergoing abdominallaparoscopic surgerySame
Sterile?Yes, by ethylene oxide, SAL 10-6Yes, by radiation, SAL 10-6Different
Sterility StandardISO 11135: 2014/AMD 1:2018UnknownN/A
Single use?YesYesSame
Shelf Life12 monthsUnknownN/A

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Comparison of Technological Characteristics
CharacteristicSubject devicePredicate deviceSimilarity
Mechanism ofActionManual manipulation and energy fromspring releaseManual manipulationSimilar
Deployed throughTrocar Sleeve?YesNo, deployed through incision afterremoval of trocar sleeveDifferent
Compatible withdifferent TrocarSleeves?Yes, by means of mechanical adaptorsUnnecessary - device not deployedthrough trocar sleeveDifferent
CompatibleWound SizeWounds made by 12 mm trocars andmaintained by 12 mm trocar sleevesWounds made by 10/12 or 15 mmtrocars (2 x models available with 'pilotguides')Different
Integral Needles?YesYesSame
Suture Type/SizePGLA Size 0 Braided SuturePGLA Size 0 Braided SutureSame
Suture pre-loaded?YesNo, suture must be loaded prior to useDifferent
Separate suturepasser?No - needles and suture are integral tothe deviceYesDifferent
Prescriptiondevice?Yes, Rx onlyYes, Rx onlySame
BiocompatibilityStandardsISO 10993-5:2009ISO 10993-10:2010ISO 10993-11:2017UnknownN/A
BacterialEndotoxin TestLAL testEP 2018: 20614UnknownN/A
Bench TestsMechanical test of critical itemsAssembly tensile integrity testsAdaptor tensile integrity testsSuture tensile strengthSuture knot pull strengthNeedle retention forceOperating button spring resistancePassage through trocar tubesTransportation testMechanical function testSuture retention testDestructive testingSimilar
Animal TestsPorcine cadaver testsIn vivo porcine testsUnknownN/A
Other Pre-clinicalTestsHuman tissue fascia testsUnknownN/A
UsabilityAssessmentYesUnknownN/A

The subject device and the predicate device have many identical or similar properties or features. The differences that exist and are identified in the above table include:

  • Sterilization method .
  • . Use with/without trocar sleeve
  • . Compatibility with trocar systems
  • Suture loading
  • . Suture passer

None of the identified differences introduce new aspects of safety or effectiveness.

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Summary of non-clinical testing:

Non-clinical testing of the Mediclose™ System includes:

Test PurposeStandardAcceptance criteriaResult
Sterilization validationISO 11135:2020 15 samplesSterile after half ETO cyclePass
Shelf life validation:ISO 11607-2:2006 2See a) to e) below
a) Transportation testISTA 3A:2018 31 x samplePackaging is fully functional andundamagedPass
b) Sterile pack sealintegrityASTM F1929-15 43 samples after ISTA3A testNo dye penetrationPass
c) Sterile pack sealstrengthEN 868-5:2019 524 samples after ISTA3A test>1.5 N/15mmPass
d) Sutureneedle/threadstrengthUSP <881> 65 samples after ISTA3A testAverage >14.7 NSingle result >4.41 NPass
e) Suture knot pullstrengthUSP <881>10 samples after ISTA3A testAverage >38.2 NPass
Biocompatibility:See a) to f) below:
a) CytotoxicityISO 10993-5:2009 7Optical density≥70% of the control mean %viabilityPass
b) SensitizationISO 10993-10:2010 8Kligman maximization35 guinea pigsPositive response in <10% oftests animalsPass
c) IntracutaneousReactivityISO 10993-10:20103 white rabbits[Test article mean] - [Controlmean] ≥ 1.0Pass
d) Acute systemictoxicityISO 10993-11:2017 910 male miceAbsence of toxic reaction after72 hoursPass
e) Material mediatedRabbit pyrogenISO 10993-11:20174 white rabbitsTemperature rise >0.5 degCPass
f) LAL bacterialendotoxicityEP 01/2018:20614 103 samples<0.5 EU/mlPass
Mechanical tests:See a) to h) below
a) Mediclose jointtensile testsInternal test protocol3 samples each, upperand lower joint>15 NPass
b) Mediclose foldingpart to handle tensileInternal test protocol2 samples>30 NPass
c) Mediclose foldingpart to handlecompressionInternal test protocol3 samples>30 NPass
d) Needle retentionforceInternal test protocol5 samples average>15 N <30 NPass
e) Medicloseassembly tensileInternal test protocol3 samples>30 NPass
f) Adaptor securitytensileInternal test protocol3 samples per adaptortype>30 NPass
g) Operating buttonspring resistanceInternal test protocol3 samples<23.3 NPass
h) Device passagethrough trocar sleeveInternal test protocol3 samples per adaptortypeUnrestricted passagePass
Performance tests inporcine model withpneumoperitoneumInternal test protocol44 Mediclose unitsNo functional failuresPass
Performance tests inhuman fascia modelInternal test protocol20 Mediclose unitsNo functional failuresPass

Summary of clinical information

No clinical testing was submitted, referenced, or relied on for the subject device.

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Conclusion:

The subject and predicate devices have very similar intended uses and fundamental technological characteristics. Any differences in technological characteristics between subject and predicate devices do not raise different questions of safety and effectiveness. The conclusions drawn from the non-clinical testing demonstrate that the subject device is as safe, as effective, and performs as well or better than the legally marketed predicate device K132362.

10 Bacterial endotoxins

¹ Sterilization of health-care products — Ethylene oxide — Requirements for the development, validation and routine control of a sterilization process for medical devices

2 Packaging for terminally sterilized medical devices — Part 2: Validation requirements for forming, sealing and assembly processes 3 Packaged products for parcel delivery system shipment 70 kq or less

4 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration

5 Packaging for terminally sterilized medical devices - Part 5: Sealable pouches and reels of porous materials and plastic film construction - Requirements and test methods

6 Tensile strength

7 Biological evaluation of medical devices — Part 5: Tests for in vitro cytotoxicity

8 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization

9 Biological evaluation of medical devices — Part 11: Tests for systemic toxicity

§ 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.