K Number
K220318
Date Cleared
2022-10-14

(253 days)

Product Code
Regulation Number
878.5040
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The PAL® Infiltration System is indicated for the purpose of aesthetic body contouring.

Device Description

The MicroAire® Power Assisted Liposuction (PAL®) Infiltration System is a medical device intended for aesthetic body contouring. The PAL Infiltration System is a stand-alone peristaltic Infiltration Pump, with the ability to control ON/OFF function to the PAL Handpiece (sold separately), the Infiltration Pump, or a Foot Switch (INF-FOOT-1) depending on the doctor's preference.

The PAL® Infiltration System is comprised of the following components that are subject to this 510K:

  • INF-PUMP PAL Infiltration Pump
  • Accessories
    • o PAL-INF-1600 Infiltration Tubing
    • o PAL-INF-XXXXX Single-Use Infiltration Cannulas
    • o PAL-INF-RXXXXX Multi-Use Infiltration Cannula
    • o INF-CBL-5020, Infiltration Pump to 5020 Console Connector Cable
    • o INF-FOOT-1, Infiltration Foot Switch
AI/ML Overview

The provided document is a 510(k) Pre-Market Notification for a medical device (MicroAire PAL Infiltration System). This type of submission focuses on demonstrating "substantial equivalence" to a legally marketed predicate device, rather than proving novel safety and effectiveness through clinical trials or performance studies with acceptance criteria in the typical sense of AI/algorithm performance.

Therefore, the requested information regarding acceptance criteria, study design for proving device performance (especially related to AI/algorithms), sample sizes for test/training sets, expert ground truth establishment, MRMC studies, or standalone algorithm performance, is not applicable to this type of regulatory submission.

The document describes engineering and biocompatibility testing, primarily against established standards, to demonstrate that the new device performs similarly and is as safe as its predicate. It does not involve AI, image analysis, or diagnostic/prognostic output that would require the typical performance study elements you've listed.

Here's a breakdown based on the document's content, explaining why your specific questions are not directly answerable in this context:

1. A table of acceptance criteria and the reported device performance:

  • Not Applicable in the AI/algorithmic sense. The "acceptance criteria" here are met through demonstrating compliance with recognized standards (e.g., ISO 10993 for biocompatibility, IEC 60601 for electrical safety) and internal specifications for functional parameters (e.g., flow rate). The document states: "Results confirm that the design inputs and performance specifications for the device are met. The PAL Infiltration System passed the testing in accordance with internal requirements, national standards, and international standards shown below, supporting its safety and effectiveness, and its substantial equivalence to the predicate device."
  • Reported Performance (Functional, not diagnostic):
    • Infiltration Pump Flow Rate: "meets internal specifications" (No specific numerical target or range is given in the public summary, only that it passed).
    • Biocompatibility: Passed Cytotoxicity, Sensitization, Irritation, Pyrogenicity, Acute Systemic Toxicity per ISO 10993-5, -10, -11, and USP <151>.
    • Electrical Safety: Passed per IEC 60601-1.
    • Electromagnetic Disturbance (EMD) testing: Passed per IEC 60601-1-2.
    • Transportation Testing: "Demonstrates package integrity maintained" per ASTM D4169.

2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

  • Not Applicable. This device is a mechanical pump and associated cannulas/tubing. Performance testing refers to engineering tests on a limited number of manufactured units or materials, not a "test set" of patient data for an algorithm. There is no patient data involved in these performance tests.

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

  • Not Applicable. No "ground truth" in the clinical/interpretive sense is established as there's no AI or diagnostic component.

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

  • Not Applicable. No clinical/interpretive test set or adjudication is relevant here.

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 is not an AI-assisted device.

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

  • Not Applicable. This is not an AI device.

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

  • Not Applicable. No ground truth for clinical outcomes in this context. Performance is measured against engineering specifications and international standards.

8. The sample size for the training set:

  • Not Applicable. No training set, as there is no AI/machine learning component.

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

  • Not Applicable. No training set or associated ground truth.

In summary: The provided document is a direct FDA 510(k) submission that demonstrates substantial equivalence for a physical medical device (an infiltration pump) through engineering and biocompatibility testing against established standards, not through AI/algorithm performance studies or clinical trials involving patient data analysis. Your questions are tailored for AI/ML device submissions, which is a different regulatory pathway and type of evidence.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

10/14/2022

MicroAire Surgical Instruments, LLC Glenn Gerstenfeld Vice President, OA/RA and Compliance Officer 3590 Grand Forks Blvd Charlottesville, Virginia 22911

Re: K220318

Trade/Device Name: PAL Infiltration System Regulation Number: 21 CFR 878.5040 Regulation Name: Suction Lipoplasty System Regulatory Class: Class II Product Code: QPB Dated: June 19, 2022 Received: June 21, 2022

Dear Glenn Gerstenfeld:

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,

Deborah Fellhauer RN, BSN 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

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Indications for Use

510(k) Number (if known) K220318

Device Name MicroAire PAL Infiltration System

Indications for Use (Describe)

The PAL® Infiltration System is indicated for the purpose of aesthetic body contouring.

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

MicroAire PAL Infiltration System

1. Submission Sponsor

MicroAire Surgical Instruments, LLC. 3590 Grand Forks Boulevard Charlottesville, Virginia 22911 USA Glenn Gerstenfeld Vice President, QA/RA, and Compliance Officer Glenn.gerstenfeld@microaire.com Phone: (434) 975-8344 Fax: (434) 975-4144

2. Submission Correspondent

Glenn Gerstenfeld Vice President, QA/RA and Compliance Officer MicroAire® Surgical Instruments, LLC Phone: (434) 975-8344 Fax: (434) 975-4144 Email: Glenn.gerstenfeld@microaire.com

3. Date Prepared

10/13/2022

4. Device Identification

Trade/Proprietary Name:PAL® Infiltration System
Common/Usual Name:Infiltration System
Classification Name:Suction Lipoplasty System
Regulation Number:21 CFR 878.5040
Product Code:QPB
Class:II
Classification Panel:General and Plastic Surgery Devices

5. Legally Marketed Predicate Device(s)

Device name: Vitruvian Infiltration Pump 510(k) number: K170629 Manufacturer: Black & Black Surgical, Inc.

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Device name: Liposuction Aspiration and Tumescent Infiltration Cannulae and Needles 510(k) number: K113795 Manufacturer: Black & Black Surgical

Device name: Single Spike 15' Large Bore Tubing 510(k) number: N/A – 510K exempt Manufacturer: Black & Black Surgical

Reference Devices:

Device name: Wells Johnson Infusion System, Mode 20-6000-00 510(k) number: K991437 Manufacturer: Wells Johnson Co.

Device name: PAL System 510(k) number: K212024 Manufacturer: MicroAire Surgical Instruments, LLC

Device name: PAL Single-Use Cannulas 510(k) number: K192694 Manufacturer: MicroAire Surgical Instruments, LLC

Device name: PAL Multi-Use Cannulas and PAL Manual Wand 510(k) number: K171286 Manufacturer: MicroAire Surgical Instruments, LLC

Device name: MicroAire LipoFilter System 510(k) number: BK220674 Manufacturer: MicroAire Surgical Instruments, LLC

Device name: INEX Lipoplasty/Liposuction and Tumescent Infiltration Cannulae/Needles 510(k) number: K132353 Manufacturer: INEX

6. Indications for Use Statement

The PAL® Infiltration System is indicated for the purpose of aesthetic body contouring.

7. Device Description

The MicroAire® Power Assisted Liposuction (PAL®) Infiltration System is a medical device intended for aesthetic body contouring. The PAL Infiltration System is a stand-alone peristaltic Infiltration Pump, with the ability to control ON/OFF function to the PAL Handpiece (sold separately), the Infiltration Pump, or a Foot Switch (INF-FOOT-1) depending on the doctor's preference.

Page 2 of 10 K220318

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The PAL® Infiltration System is comprised of the following components that are subject to this 510K:

  • INF-PUMP PAL Infiltration Pump
  • Accessories
    • o PAL-INF-1600 Infiltration Tubing
    • o PAL-INF-XXXXX Single-Use Infiltration Cannulas
    • o PAL-INF-RXXXXX Multi-Use Infiltration Cannula
    • o INF-CBL-5020, Infiltration Pump to 5020 Console Connector Cable
    • o INF-FOOT-1, Infiltration Foot Switch

8. Substantial Equivalence Discussion

The following table compares the subject device to the predicate device with respect to indications for use, principles of operation, technological characteristics, and performance, and forms the basis for the determination of substantial equivalence. The minor differences in the subject device does not raise any new questions of safety or effectiveness as compared to the predicate device.

AttributeSUBJECT DEVICEPREDICATE DEVICE /510(k) HOLDERComparison
510(k) NumberK220318K170629N/A
Product CodeQPBQPBN/A
Regulation Number878.5040878.5040N/A
Indications For UseThe PAL® InfiltrationSystem is indicated forthe purpose of aestheticbody contouring.The Vitruvian InfiltrationPump is intended to beused for: Aesthetic BodyContouringSame
Mechanism of Operation
Pump typePeristalticPeristalticSame
Maximum flow rate630 mL/min – with HKSurgical ITS-10 tubing1300 mL/min – withMicroAire PALInfiltration Tubing PAL-INF-1600475 mL/min*999 mL/min**Different; The flowrate is determined bythe peristaltic pumpgeometry and speedas well as the innerdiameter of thesection of tubingwhich is placed insideof the pump.Lower flow rates canbe achieved using theSubject Device if asmaller diametertubing is connected.
Table 5A - Comparison of Characteristics for Pump
-------------------------------------------------------

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AttributeSUBJECT DEVICEPREDICATE DEVICE /510(k) HOLDERComparison K2203
Housing/MaterialsSteelABS PlasticHigher flow rates canbe achieved using theSubject Device if alarger diameter tubingis connected.Different; TumescentInfiltration pumps arenon-patientcontacting devices.They are utilized andmaintained outside ofthe sterile field.Although the housingmaterials aredifferent, this has noimpact on theperformance or theIntended Use of thepump.
FootswitchElectricAir poweredDifferent; Bothfootswitches activatethe rotation of thepump. The differencebetween air poweredand electric activationdoes not change thefootswitch interactionwith the device orhow user interfaceswith the footswitchesduring its use.
Pressure controlKnob to control RPMKnob to control RPMSame
DisplayLEDLEDSame
Complies with ISO10993-1YesYesSame
Electrical SafetyTesting PassedYesYesSame

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AttributePredicate DeviceSubject Device:Reference DeviceComparison
#J
Device NameVitruvianPAL InfiltrationWells Johnson InfusionN/A
Infiltration PumpSystemSystem, 20-6000-00
DeviceBlack & BlackMicroAire SurgicalWells JohnsonN/A
ManufacturerSurgical, Inc.Instruments, LLC
510(k)K170629K220318K991437N/A
Reference
Maximum flow475 mL/min*630 mL/min — withMaximum flow rateSimilar; The flow
rate999 mL/min**HK Surgical ITS-101300mL/min (per IFU)rate is determined
tubingby the peristaltic
pump geometry and
1200 mL/min - withspeed as well as the
MicroAire PALinner diameter of
Infiltration Tubingthe section of tubing
PAL-INF-1600which is placed
inside of the pump.
Lower flow rates
can be achieved
using the Subject
Device if a smaller
diameter tubing is
connected. Higher
flow rates can be
achieved using the
Subject Device if a
larger diameter
tubing is connected.

Table 5B – Comparison of Flow Rate against Reference Device

Table 5C – Comparison of Characteristics: Infiltration Single-Use and Multi-Use Cannulas

AttributePredicate Device #2– Black & BlackSurgical Multi-UseSubject Device –PAL InfiltrationSingle-UseSubject Device –PAL Infiltration Multi-UseComparison
Device NameLiposuctionAspiration andTumescentInfiltration Cannulaeand NeedlesPAL Infiltration SingleUse CannulasPAL Infiltration Multi-Use CannulasN/A
DeviceManufacturerBlack & BlackSurgicalMicroAire Surgical, LLCMicroAire Surgical, LLCN/A
AttributePredicate Device #2 – Black & Black Surgical Multi-UseSubject Device – PAL Infiltration Single-UseSubject Device – PAL Infiltration Multi-UseComparison
510(k) ReferenceK113795K220318K220318N/A
FDA Product CodeQPBQPBQPBSame
FDA Classification NameSystem, suction lipoplasty for removalSystem, suction lipoplasty for removalSystem, suction lipoplasty for removalSame
FDA Regulation Number878.5040878.5040878.5040Same
FDA Device ClassClass IIClass IIClass IISame
Indications for UseThe aspiration and infusion cannulae and needles are indicated for aesthetic body contouring and general tissue aspiration.The PAL® Infiltration System is indicated for the purpose of aesthetic body contouring.The PAL® Infiltration System is indicated for the purpose of aesthetic body contouring.Similar
DesignCannula tube;Cannula tip;Cannula hubCannula tube;Blunt tip;Cannula hubCannula tube;Blunt tip;Cannula hubSame
FenestrationMulti-hole:Hole Size - 1mmNumber of holes - 7Hole Pattern - Wrap around in a spiral formation.Basket:Three holes equally spaced radially with remaining material flared.Multi-hole:Hole Size - 1.9mmNumber of Holes - 22Hole Pattern - Straight Formation 11 thru holes 90 degrees apartFlared Mercedes:Three holes equally spaced radially with remaining material flared.Multi-hole:Hole Size - 1.9mmNumber of Holes - 22Hole Pattern - Straight Formation 11 thru holes 90 degrees apartFlared Mercedes:Three holes equally spaced radially with remaining material flared.Different
LengthAvailable in 15cm, 26cm, 32cm, and 40cm lengths.Available in 15cm, 22cm, and 30cm lengths.Available in 15cm, 22cm, 30cm and 40cm lengths.Similar
AttributePredicate Device #2 – Black & Black Surgical Multi-UseSubject Device – PAL Infiltration Single-UseNote: No 40 cm length.Subject Device – PAL Infiltration Multi-UseComparison
DiameterAvailable in 3.2mm (10 Gauge), 4mm, 5mm diametersAvailable in 3mm, 4mm and 5mm diametersAvailable in 3mm, 4mm and 5mm diametersSimilar
StyleStraightStraightStraightSame
MaterialsCannula Tube – Stainless SteelCannula Hub – Stainless Steel and AluminumCannula Tube – Stainless SteelCannula Hub Lexan HPS1R (polycarbonate) and Dupont Zytel ST801 (nylon)Cannula Tube – Stainless SteelCannula Hub –Vectra MT1310 (LCP) and Dupont Zytel ST801 (nylon) and a Dowel Pin made of 410 or 416 Stainless SteelCannula Tube – SameCannula Hub – Different
FunctionBlack and Black Surgical Cannulae and Needles are used to remove fluid, soft tissue, and exudates and for infusion, utilizing a hollow stainless-steel tube and multiple tips, handle and attachment connectors that are in reusable and disposable configuration.The Cannula steel tube is used to provide length and strength.The Cannula Tip is used to provide infiltration through eyelets (holes) in the tip.The hub is used to connect to the handpiece and tubingThe Cannula steel tube is used to provide length and strength.The Cannula Tip is used to provide infiltration through eyelets (holes) in the tip.The hub is used to connect to the handpiece and tubingSimilar
SterileSupplied non-sterile; Steam Sterilized by end userSupplied sterile, Gamma sterilizationSupplied non-sterile; Steam Sterilized by end userDifferent
Single-UseNoYesNoDifferent
Complies with ISO 10993YesYesYesSame
AttributePredicate Device #3:Black & Black Single Spike15' Large Bore TubingSubject Device:PAL Infiltration Tubing,K220318Comparison
Device NameSingle Spike 15' Large BoreTubingPAL Infiltration TubingN/A
DeviceManufacturerBlack & BlackMicroAire Surgical, LLCN/A
510(k) ReferenceN/AK220318N/A
FDA Product CodeGAZQPBDifferent
FDA ClassificationNameTubing, NoninvasiveSuction Lipoplasty SystemDifferent
FDA RegulationNumber880.6740878.5040Different
FDA Device ClassClass IIClass IISame
Indications for UseThe suction and irrigationtubes are intended forinstillation or aspiration offluid to/from a targetedarea of the body duringliposuction procedures.The PAL® Infiltration Systemis indicated for the purposeof aesthetic body contouring.Similar
DesignCharacteristicsAvailable in one length ~15feetAvailable in one length~16feetSimilar
Design3-piece tubingconstruction; oneperistaltic section, twolength sectionsSingle bag spikeluer connection3-piece tubing construction;one peristaltic section, twolength sectionsSingle bag spikeNo luer connectionSimilar
MaterialsPeristaltic section - SiliconePeristaltic Section - PVCLength Section – PVCBag Spike - ABSTubing Connectors - PCDifferent
FunctionThe peristaltic sectioninterfaces with a peristalticpump to provide fluid flow.The length sections of thetubing provide connectionsfor the bag spike, tubingconnectors, and luerconnectorThe peristaltic sectioninterfaces with a peristalticpump to provide fluid flow.The length sections of thetubing provide connectionsfor the bag spike, tubingconnectors, and MicroAireinfiltration cannulaSimilar
AttributePredicate Device #3:Black & Black Single Spike15' Large Bore TubingSubject Device:PAL Infiltration Tubing,K220318Comparison
SterileSupplied Sterile(Gamma Irradiation)Supplied sterile(EtO)Similar
Single-UseYesYesSame
Complies with ISO10993YesYesSame

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Table 5D – Comparison of Characteristics: Infiltration Tubing

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Table 5E - Comparison of Single-Use Data against Reference Device

AttributeReference Device:INEX Lipoplasty/LiposuctionAspiration and TumescentInfiltrationCannulae/NeedlesSubject Device:MicroAire PAL InfiltrationSingle-Use CannulaComparison
Device NameLipoplasty/LiposuctionAspiration and TumescentInfiltration Cannulae/NeedlesMicroAire PAL InfiltrationSingle-Use CannulaN/A
DeviceManufacturerINEXMicroAire Surgical, LLCN/A
510(k) ReferenceK132353K220318N/A
Single-UseYesYesSame
Supplied SterileYesYesSame

9. Non-Clinical Performance Data

To demonstrate safety and effectiveness of MicroAire PAL Infiltration System and to show substantial equivalence to the predicate device, MicroAire completed the following non-clinical tests. Results confirm that the design inputs and performance specifications for the device are met. The PAL Infiltration System passed the testing in accordance with internal requirements, national standards, and international standards shown below, supporting its safety and effectiveness, and its substantial equivalence to the predicate device:

  • Cytotoxicity testing per ISO 10993-5 – Passed
  • Sensitization and Irritation testing per ISO 10993-10 – Passed
  • Irritation testing per ISO 10993-10 – Passed
  • Pyrogenicity per USP <151> - Passed
  • Acute Systemic Toxicity per ISO 10993-11 - Passed
  • Electrical safety testing per IEC 60601-1 Passed ●
  • Electromagnetic Disturbance (EMD) testing per IEC 60601-1-2 - Passed
  • . Infiltration Pump Flow Rate - -meets internal specifications

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  • Transportation Testing per ASTM D4169 Demonstrates package integrity maintained ●

10. Statement of Substantial Equivalence

Based on the information provided in this submission, it is concluded that the MicroAire PAL Infiltration System has the same indications for use as the Vitruvian Infiltration System. Any minor differences in the technological characteristics of the subject device when compared to the predicate device have been successfully evaluated through appropriate safety and performance testing which demonstrates that the subject device, when compared to the predicate device, does not raise any new questions of safety and effectiveness. Therefore, MicroAire PAL Infiltration System has been determined to be substantially equivalent to Vitruvian Infiltration Pump.

§ 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.