K Number
K221898
Device Name
Gastrointestinal Boundary Identifier (GIBI HD)
Date Cleared
2022-07-28

(28 days)

Product Code
Regulation Number
876.5980
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The GIBI HD™ is indicated for use in gastric and bariatric surgical procedures to decompress the stomach, drain and remove gastric fluid, irrigate, and act as a sizing guide.
Device Description
The Gastrointestinal Boundary Identifier, or GIBI HD™, is a flexible gastric tube designed to be used in gastric and bariatric surgical procedures. The catheter provides visible and tactile delineation of the antrum of the stomach along with the ability to decompress the stomach, drain and remove gastric fluid and size a gastric pouch. The dual lumen GIBI HD utilizes one lumen for drainage, suction and irrigation and the second lumen to inflate/deflate the balloon. The catheter is attached to a 32-inch suction tubing and a 6inch tubing with a stopcock for filling the balloon.
More Information

ViSiGi 3D®, K130483

No
The summary describes a mechanical device (a flexible gastric tube with lumens and a balloon) and its function. There is no mention of software, algorithms, image processing, AI, ML, or data sets, which are typically associated with AI/ML devices.

No
The device primarily aids in surgical procedures by decompressing, draining, and sizing, rather than directly treating a medical condition or disease.

No
The device description indicates its functions are primarily interventional (decompression, drainage, irrigation, sizing guide) rather than diagnostic (detecting, monitoring, or predicting disease).

No

The device description clearly describes a physical, flexible gastric tube with lumens, tubing, and a balloon, indicating it is a hardware device, not software-only.

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

Here's why:

  • IVD devices are used to examine specimens taken from the human body. The GIBI HD™ is a surgical instrument used within the body during gastric and bariatric procedures.
  • The intended use and device description clearly state its function in surgical procedures for decompression, drainage, irrigation, and sizing in vivo.
  • There is no mention of analyzing biological samples or providing diagnostic information based on such analysis.

The GIBI HD™ is a surgical tool, not a diagnostic test performed on samples outside the body.

N/A

Intended Use / Indications for Use

The GIBI HD™ is indicated for use in gastric and bariatric surgical procedures to decompress the stomach, drain and remove gastric fluid, irrigate, and act as a sizing guide.

Product codes

KNT

Device Description

The Gastrointestinal Boundary Identifier, or GIBI HD™, is a flexible gastric tube designed to be used in gastric and bariatric surgical procedures. The catheter provides visible and tactile delineation of the antrum of the stomach along with the ability to decompress the stomach, drain and remove gastric fluid and size a gastric pouch.

The dual lumen GIBI HD utilizes one lumen for drainage, suction and irrigation and the second lumen to inflate/deflate the balloon. The catheter is attached to a 32-inch suction tubing and a 6inch tubing with a stopcock for filling the balloon.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

gastric

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

Test Performed: Balloon leakage test
Purpose: The balloon component of the GIBI HD shall inflate to a minimum volume of 100 cc without exhibiting fluid leak or air egress.
Acceptance Criteria: Samples retained 100 cc of fluid at least 1 minute without leakage.
Results: Pass

Test Performed: Fluid removal test
Purpose: The GIBI HD shall remove a minimum of 500 cc of saline or clean water in under 1 minute.
Acceptance Criteria: Samples evacuated a minimum of 500 cc of fluid in under 1 minute.
Results: Pass

Test Performed: Balloon bond joint strength test
Purpose: The mated joint between the GIBI HD 's Balloon and Tubing shall withstand a minimum of 13 lbf prior to separation.
Acceptance Criteria: Samples did not exhibit balloon separation under 13 lbf.
Results: Pass

Test Performed: Distal tip bond joint strength test
Purpose: The mated joint between the GIBI HD 's distal tip and Tubing shall withstand a minimum of 19.5 lbf prior to separation.
Acceptance Criteria: Samples did not exhibit sensor tip separation under 19.5 lbf.
Results: Pass

Test Performed: Stopcock separation test
Purpose: The stopcock component of the GIBI HD shall withstand a minimum of 1 lbf prior to separation from the fill tube.
Acceptance Criteria: Samples did not exhibit stopcock separation under 1 lbf.
Results: Pass

Test Performed: Fill tube separation test
Purpose: The fill tube attached to the stopcock of the GIBI HD shall withstand a minimum of 1 lbf prior to separation from the y connector.
Acceptance Criteria: Samples did not exhibit fill tube separation under 1 lbf.
Results: Pass

Test Performed: Adapter tubing separation test
Purpose: The proximal tubing of the GIBI HD shall withstand a minimum of 1 lbf prior to separation from the y connector.
Acceptance Criteria: Samples did not exhibit adapter tube separation under 1 lbf.
Results: Pass

Test Performed: Adapter separation test
Purpose: The adapter of the GIBI HD shall withstand a minimum of 1 lbf prior to separation from the adapter tube.
Acceptance Criteria: Samples did not exhibit adapter separation under 1 lbf.
Results: Pass

Test Performed: Visual Inspection and Measurement verification test
Purpose: The dual lumen catheter component of the GIBI HD, from the distal edge of the Y connector to the end of the dual lumen catheter, shall have a minimum length of 75 cm.
Acceptance Criteria: Minimum length of measured sample is 75 cm.
Results: Pass

Test Performed: Visual Inspection and Measurement verification test
Purpose: The dual lumen catheter component of the GIBI HD shall include indication marks on the surface of the tube at 30, 35, 40, 45, 50, 55 and 60 cm with respect to the distal portion of the component.
Acceptance Criteria: Indicator marks are located 30, 35, 40, 45, 50, 55, and 60 cm with respect to distal portion of the component.
Results: Pass

Test Performed: Visual Inspection and Measurement verification test
Purpose: The dual lumen catheter component of the GIBI HD shall have three size configurations: 0.42" (32 Fr), 0.47" (36 Fr) and 0.53" (40 Fr).
Acceptance Criteria: Outer diameter of 32Fr, 36Fr and 40Fr samples are 0.42", 0.47" and 0.53", respectively.
Results: Pass

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

Not Found

Predicate Device(s)

Lap-Band® System Calibration Tube, K220455

Reference Device(s)

ViSiGi 3D®, K130483

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 876.5980 Gastrointestinal tube and accessories.

(a)
Identification. A gastrointestinal tube and accessories is a device that consists of flexible or semi-rigid tubing used for instilling fluids into, withdrawing fluids from, splinting, or suppressing bleeding of the alimentary tract. This device may incorporate an integral inflatable balloon for retention or hemostasis. This generic type of device includes the hemostatic bag, irrigation and aspiration catheter (gastric, colonic, etc.), rectal catheter, sterile infant gavage set, gastrointestinal string and tubes to locate internal bleeding, double lumen tube for intestinal decompression or intubation, feeding tube, gastroenterostomy tube, Levine tube, nasogastric tube, single lumen tube with mercury weight balloon for intestinal intubation or decompression, and gastro-urological irrigation tray (for gastrological use).(b)
Classification. (1) Class II (special controls). The barium enema retention catheter and tip with or without a bag that is a gastrointestinal tube and accessory or a gastronomy tube holder accessory 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 (general controls) for the dissolvable nasogastric feed tube guide for the nasogastric tube. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 876.9.

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July 28, 2022

ReShape Lifesciences Michelle Ravert Regulatory Affairs Manager 1001 Calle Amanecer San Clemente, CA 92673

Re: K221898

Trade/Device Name: Gastrointestinal Boundary Identifier (GIBI HDTM) Regulation Number: 21 CFR 876.5980 Regulation Name: Gastrointestinal tube and accessories Regulatory Class: Class II Product Code: KNT Dated: June 28, 2022 Received: June 30, 2022

Dear Michelle Ravert:

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

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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-safetyreporting-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-devices/medical-device-safety/medicaldevice-reporting-mdr-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/medical-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-devices/device-advicecomprehensive-regulatory-assistance/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,

April Marrone, Ph.D., MBA Assistant Director (acting) DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Indications for Use

510(k) Number (if known) K221898

Device Name

Gastrointestinal Boundary Identifier (GIBI HDTM)

Indications for Use (Describe)

The GIBI HD™ is indicated for use in gastric and bariatric surgical procedures to decompress the stomach, drain and remove gastric fluid, irrigate, and act as a sizing guide.

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

I. Basic Information

| 510(k) Owner | ReShape Lifesciences
1001 Calle Amanecer
San Clemente CA 92673
Phone: (844) 937-7374
Establishment Registration No: 3013508647 |
|--------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person | Michelle Ravert, Regulatory Affairs Manager |
| Date summary
Prepared | July 26, 2022 |
| Trade Name | Gastrointestinal Boundary Identifier (GIBI HD™) |
| Common Name | Introduction/Drainage Catheter |
| Classification name | Gastrointestinal tube and accessories (21 CFR 876.5980) |
| Regulatory Class | Class II |
| Product Code | KNT |
| Predicate Device | Lap-Band® System Calibration Tube, K220455 |
| Reference Device | ViSiGi 3D®, K130483 |

DEVICE DESCRIPTION II.

The Gastrointestinal Boundary Identifier, or GIBI HD™, is a flexible gastric tube designed to be used in gastric and bariatric surgical procedures. The catheter provides visible and tactile delineation of the antrum of the stomach along with the ability to decompress the stomach, drain and remove gastric fluid and size a gastric pouch.

The dual lumen GIBI HD utilizes one lumen for drainage, suction and irrigation and the second lumen to inflate/deflate the balloon. The catheter is attached to a 32-inch suction tubing and a 6inch tubing with a stopcock for filling the balloon.

III. INDICATIONS FOR USE

The GIBI HD is indicated for use in gastric and bariatric surgical procedures to decompress the stomach, drain and remove gastric fluid, irrigate, and act as a sizing guide.

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COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH IV. THE PREDICATE DEVICE

| Technical Element | GIBI HD
B-2032, B-2036, B-2040 | Predicate Device
Calibration Tube, K220455 |
|-----------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|-----------------------------------------------|
| Outer Diameter
(OD), inches | B-2032 = 0.420" +0.000" / -0.012"
B-2036 = 0.472" + 0.000" / -0.012"
B-2040 = 0.525" + 0.000" / -0.012" | 0.380" +0.000" / -0.012" |
| OD, French Size | B-2032 = 32 F
B-2036 = 36 F
B-2040 = 40 F | 29F |
| Working length
(distal end of Y -
connector to distal
end of distal tip) | 32.43 ± 0.52" | 24.73" ± 0.52" |
| Tubing Material | Silicone | Silicone |

V. PERFORMANCE DATA

Test PerformedPurposeAcceptance CriteriaResults
Balloon leakage
testThe balloon component of the GIBI HD shall
inflate to a minimum volume of 100 cc without
exhibiting fluid leak or air egress.Samples retained 100 cc of fluid at
least 1 minute without leakage.Pass
Fluid removal testThe GIBI HD shall remove a minimum of 500
cc of saline or clean water in under 1 minute.Samples evacuated a minimum of
500 cc of fluid in under 1 minute.Pass
Balloon bond joint
strength testThe mated joint between the GIBI HD 's Balloon
and Tubing shall withstand a minimum of 13 lbf
prior to separation.Samples did not exhibit balloon
separation under 13 lbf.Pass
Distal tip bond
joint strength testThe mated joint between the GIBI HD 's distal
tip and Tubing shall withstand a minimum of
19.5 lbf prior to separation.Samples did not exhibit sensor tip
separation under
19.5 lbf.Pass
Stopcock
separation testThe stopcock component of the GIBI HD shall
withstand a minimum of 1 lbf prior to
separation from the fill tube.Samples did not exhibit stopcock
separation under 1 lbf.Pass
Fill tube
separation testThe fill tube attached to the stopcock of the
GIBI HD shall withstand a minimum of 1 lbf
prior to separation from the y connector.Samples did not exhibit fill tube
separation under 1 lbf.Pass
Adapter
tubing
separation
testThe proximal tubing of the GIBI HD shall
withstand a minimum of 1 lbf prior to
separation from the y connector.Samples did not exhibit adapter
tube separation under 1 lbf.Pass
Adapter
separation testThe adapter of the GIBI HD shall withstand a
minimum of 1 lbf prior to separation from the
adapter tube.Samples did not exhibit adapter
separation under 1 lbf.Pass

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Test PerformedPurposeAcceptance CriteriaResults
Visual Inspection
and Measurement
verification testThe dual lumen catheter component of the
GIBI HD, from the distal edge of the Y
connector to the end of the dual lumen
catheter, shall have a minimum length of 75
cm.Minimum length of measured
sample is 75 cm.Pass
The dual lumen catheter component of the GIBI
HD shall include
indication marks on the surface of the tube at 30,
35, 40, 45, 50, 55 and 60 cm with respect to the
distal portion of the component.Indicator marks are located 30, 35,
40, 45, 50, 55,
and 60 cm with respect to distal
portion of the component.Pass
The dual lumen catheter component of the
GIBI HD shall have three size configurations:
0.42" (32 Fr), 0.47" (36 Fr) and 0.53" (40 Fr).Outer diameter of 32Fr, 36Fr and
40Fr samples are 0.42", 0.47" and
0.53", respectively.Pass

BASIS FOR SUBSTANTIAL EQUIVALENCE VI.

Substantial equivalence of the GIBI HD to the predicate device (Lap-Band® System Calibration Tube, K220455) was established through an evaluation of the indications for use, principle of operation, device design, materials of construction, and an assessment of usability, safety, and effectiveness via bench studies.

The data presented in this summary demonstrates the technological similarity and equivalency of the GIBI HD to the predicate device (Lap-Band® System Calibration Tube, K220455).

The devices:

  • · have the same intended use,
  • · use the same principle of operation,
  • · incorporate the same basic design,
  • · use similar construction and material, and
  • · are provided non-sterile.

In addition, the GIBI HD and the reference device (ViSiGi 3D, K130483) have the same outer

diameter sizes and are substantially equivalent with respect to working length.

In summary, the Gastrointestinal Boundary Identifier (GIBI HD™) device described in this submission is substantially equivalent to the predicate device, the LAP-BAND System Calibration tube (K220455).