K Number
K222001
Date Cleared
2023-06-08

(336 days)

Product Code
Regulation Number
878.4400
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Irreversible Electroporation Ablation Generator is indicated for the surgical ablation of soft tissue.

The Irreversible Electroporation Probe is used in conjunction with Irreversible Electroporation of CuraWay indicated for the surgical ablation of soft tissue.

Device Description

The Irreversible Electroporation Ablation Generator consists of a generator, foot switch and power cord. The generator will be used together with the Irreversible Electroporation Probe and Neutral Electrode.

The Irreversible Electroporation Probe has two types: monopolar probe and bipolar probe. Monopolar probe also has two types: Standard Probe and Activation Probe.

The Irreversible Electroporation Ablation Generator has three working modes:

  • A Mode 1: Monopolar steep pulse mode;
  • A Mode 2: Bipolar steep pulse mode;
  • A Mode 3: Needle Track Coagulation.

Mode 1 and Mode 2 are used for soft tissue ablation, the working principle is that the generator transfers non-thermal energy to electrodes which are placed at the target area, it will release high-voltage electrical pulses forming nano-scale permanent perforations on the soft tissues to disrupt the intracellular balance and induce cell apoptosis. The cells die and are removed by the human body's own lymphatic system.

The Mode 3 is used for the soft tissue coagulation during the process when the probe is pulled out. This module works at 480kHZ, the high frequency flows to the probe's tip and then is applied to the tissue. Frictional heat occurs and causes the ions to move between the negative pole and the positive pole 40,000 to 50,000 times per second. Heat generated from the tissue impedance induces tissue necrosis.

Subject device can work at ECG synchronization trigger mode. During this mode, an external R-wave detector must be connected. R-wave detector monitors the patient's cardiac rate and transfers it to R waves which will be detected by the generator and then a pulse will be triggered. Every time a R wave is detected, one pulse is triggered such that every time the heart beats, a pulse will be triggered, so that the electroporation pulses can be triggered and delivered in proper synchronization with the patient's cardiac rhythm.

AI/ML Overview

This document is a 510(k) summary for a medical device and does not contain detailed acceptance criteria or a study proving the device meets specific acceptance criteria in the manner typically presented for AI/ML performance. The information provided focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing.

However, based on the information provided, we can infer some "acceptance criteria" through the comparative non-clinical studies.

Here's an analysis based on your request, adapting to the provided document's content:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state quantitative performance acceptance criteria in a dedicated table for the device's efficacy. Instead, it describes non-clinical tests designed to demonstrate "substantial equivalence" to a predicate device. The performance is assessed by comparing the subject device's effects to those of the predicate and reference devices in specific animal and ex-vivo models.

Metric/Criteria (Inferred from Non-clinical Tests)Acceptance (Inferred)Reported Device Performance
Ex-vivo tissue testing (swine muscle, liver, kidney): Ablation effect and ablation zonesSubstantially equivalent to predicate and reference devices."The result showed the ablation effect and ablation zones of the subject device is substantial equivalent to the predicate device and the reference device."
ECG synchronization trigger mode testing: Comparison to predicate device.Performance is comparable to predicate device."ECG trigger mode testing was conducted to compare ECG synchronization trigger mode of subject to that of the predicate device." (Implies comparable performance was observed)
In-vivo animal testing (swine): Blood routine, blood biochemistry, myocardial enzymes, and diameter of ablation (compared to predicate device).No significant adverse differences in blood parameters between groups. Ablation diameters are comparable."The long ablation diameter and short ablation diameter of subject device group was compared to those of predicate device." (Implies comparable results were found to support substantial equivalence).
Compliance with recognized standards:Device complies with all relevant standards.The device passed specific IEC, ISO, and ASTM standards (listed in the document).

2. Sample Size Used for the Test Set and Data Provenance

  • Test Set Sample Size:
    • Ex-vivo tissue testing: Swine muscle, liver, and kidney tissue. The specific number of tissue samples or experiments is not provided.
    • In-vivo animal testing: Swine. The specific number of animals used in the subject device group and predicate device group is not provided.
  • Data Provenance: The tests were conducted internally by the manufacturer or a contracted lab. The document does not specify a country of origin for the data beyond the manufacturer being based in China. The studies are non-clinical (ex-vivo and in-vivo animal), not human clinical.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

This information is not provided as the studies are non-clinical. The assessment of "ablation effect and ablation zones" or "blood parameters" would typically be performed by trained lab personnel, veterinarians, or pathologists, but specific details on their qualifications or number are not available in this regulatory summary.

4. Adjudication Method for the Test Set

This information is not provided. Given that these are non-clinical studies evaluating physical effects and physiological parameters, typical clinical adjudication methods (like 2+1 or 3+1 consensus) are not directly applicable. The "ground truth" is derived from direct measurements and observations in the experimental setup.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

No. This document describes a medical device, not an AI/ML diagnostic or assistive tool. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant or applicable to this submission.

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

Not applicable. This device is an Irreversible Electroporation Ablation Generator and Probe, which is a physical medical device used for surgical ablation. It is not an AI algorithm. While it has embedded software, its performance is assessed as part of the overall device system, not as a standalone AI algorithm.

7. The Type of Ground Truth Used

For the non-clinical studies mentioned:

  • Ex-vivo and in-vivo tests: The "ground truth" for evaluating ablation effect and ablation zones, blood parameters, etc., would be based on direct measurement, observation, and analysis by laboratory techniques (e.g., macroscopic and microscopic examination of tissue, blood tests). It's a form of objective measurement/pathology from the experimental models.

8. The Sample Size for the Training Set

Not Applicable. The device is not an AI/ML algorithm that requires a training set in the conventional sense. The "development" of the device would involve engineering design, prototyping, and iterative testing, not machine learning model training.

9. How the Ground Truth for the Training Set Was Established

Not Applicable. As explained above, there is no AI/ML training set for this device.

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Image /page/0/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 is in blue and includes the letters "FDA" followed by the words "U.S. Food & Drug Administration" in a larger font and the word "Administration" in a smaller font.

June 8. 2023

Zhejiang CuraWay Medical Technology Co., Ltd. Xiaoyu Guan Regulatory Affairs Manager Building 1, No.600, 21st street, Qiantang New Area Hangzhou, Zhejiang 310018 China

Re: K222001

Trade/Device Name: Irreversible Electroporation Ablation Generator, Irreversible Electroporation Probe Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: OAB Dated: May 8, 2023 Received: May 8, 2023

Dear Xiaoyu Guan:

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,

Digitally signed by Mark Mark Trumbore -S Trumbore -S Date: 2023.06.08 11:40:14 -04'00'

Mark Trumbore, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control 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)

Device Name

Irreversible Electroporation Ablation Generator Irreversible Electroporation Probe

Indications for Use (Describe)

The Irreversible Electroporation Ablation Generator is indicated for the surgical ablation of soft tissue.

The Irreversible Electroporation Probe is used in conjunction with Irreversible Electroporation of CuraWay indicated for the surgical ablation of soft tissue.

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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K222001 510(K) Summary

Company Name/OwnerZhejiang CuraWay Medical Technology Co., Ltd.
Contact person/AuthorXiaoyu Guan(Miss)
Date prepared06/06/2023
Contact details AddressRoom 106, Building 1, No. 600, 21st Avenue, BaiyangSub-district, Qiantang New District, 310018, HangzhouCity, Zhejiang Province, China
Trade nameIrreversible Electroporation Ablation GeneratorIrreversible Electroporation Probe
Common nameLow energy direct current ablation device
Classification nameLow Energy Direct Current Thermal Ablation System
Review panelGeneral & Plastic Surgery (SU)
Regulation number878.4400
Product codeOAB
Predicate deviceNanoknife system (K183385)
Reference deviceThe VIVA combo RF System (K163450)

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Device Description

The Irreversible Electroporation Ablation Generator consists of a generator, foot switch and power cord. The generator will be used together with the Irreversible Electroporation Probe and Neutral Electrode.

The Irreversible Electroporation Probe has two types: monopolar probe and bipolar probe. Monopolar probe also has two types: Standard Probe and Activation Probe.

The Irreversible Electroporation Ablation Generator has three working modes:

  • A Mode 1: Monopolar steep pulse mode;
  • A Mode 2: Bipolar steep pulse mode;
  • A Mode 3: Needle Track Coagulation.

Mode 1 and Mode 2 are used for soft tissue ablation, the working principle is that the generator transfers non-thermal energy to electrodes which are placed at the target area, it will release high-voltage electrical pulses forming nano-scale permanent perforations on the soft tissues to disrupt the intracellular balance and induce cell apoptosis. The cells die and are removed by the human body's own lymphatic system.

The Mode 3 is used for the soft tissue coagulation during the process when the probe is pulled out. This module works at 480kHZ, the high frequency flows to the probe's tip and then is applied to the tissue. Frictional heat occurs and causes the ions to move between the negative pole and the positive pole 40,000 to 50,000 times per second. Heat generated from the tissue impedance induces tissue necrosis.

Subject device can work at ECG synchronization trigger mode. During this mode, an external R-wave detector must be connected. R-wave detector monitors the patient's cardiac rate and transfers it to R waves which will be detected by the generator and then a pulse will be triggered. Every time a R wave is detected, one pulse is triggered such that every time the heart beats, a pulse will be triggered, so that the electroporation pulses can be triggered and delivered in proper synchronization with the patient's cardiac rhythm.

Indications for use

The Irreversible Electroporation Ablation Generator is indicated for the surgical ablation of soft tissues.

The Irreversible Electroporation Probe is used in conjunction with Irreversible Electroporation Ablation Generator of CuraWay indicated for the surgical ablation of soft tissue.

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Substantial equivalence comparison with predicate device

Detailed substantial comparison was made between subject device and predicate device. Please refer to below tables for details.

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Substantial equivalence Comparison table

Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
Classification Regulation878.4400878.4400878.4400Identical
Product CodeOAB, GEIOABGEIIdentical
510(k) Number-K183385K163450Identical
Indications for useThe IrreversibleElectroporation AblationGenerator is indicated for thesurgical ablation of softtissues.The NanoKnife System withsix outputs is indicated forthe surgical ablation of softtissue.The VIVA combo RFSystem is intendedfor use inpercutaneous andintraoperativecoagulation andablation of tissue.Identical
PrincipleThe IrreversibleElectroporation AblationGenerator has three workingmodes: Monopolar steeppulse mode (Mode 1), Bipolarsteep pulse mode (Mode 2)and Needle Track Coagulation(Mode 3).Mode 1 and Mode 2 are usedThe Nanoknife System usesa series of microsecondelectrical pulses to open"pores" in the cellmembranes. The electricalpulses are deliveredthrough several needle-likeprobes placed into oraround the ablation zoneunder CT or ultrasoundThe RF generatorworks at 500kHz.The frequency flowsto the electrode'stip and then isapplied to thetissue. Frictionalheat occurs andcauses the ions tomove from theIdentical
Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
for soft tissue ablation, theworking principle is that thegenerator transfersnon-thermal energy toelectrodes which are placed atthe target area, it will releasehigh-voltage electrical pulsesforming nano-scalepermanent perforations onthe soft tissues to disrupt theintracellular balance andinduce cell apoptosis. The cellsdie and are removed by thehuman body's own lymphaticsystem.guidance. By applyingenough high voltageenergy, the open porescause irreversible damageto the cells. The cells dieand are removed by thehuman body's ownlymphatic system.negative pole to thepositive pole andfrom the positivepole to the negativepole forty tofifty thousand timesper second. Tissuenecrosis is theprinciple thatoccurs by usingheat generatedfrom the tissueimpedance.
The Mode 3 is used for thesoft tissue coagulation duringthe process when the probe ispulled out. This module worksat 480kHZ, the high frequencyflows to the probe's tip andthen is applied to the tissue.Frictional heat occurs and
Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
causes the ions to move fromthe negative pole to thepositive pole and from thepositive pole to the negativepole 40,000 to 50,000 timesper second. Tissue necrosis isthe principle that occurs byusing heat generated from thetissue impedance.
Working modeMode 1: Monopolar steeppulse modeMode 2: Bipolar steep pulsemodeMode 3: Needle trackcoagulationSteep pulse modeCoagulationIdentical
Prescription or OTCPrescriptionPrescriptionPrescriptionIdentical
ComponentIrreversible ElectroporationAblation Generator,electroporation probes,neutral electrode, foot switchNanoKnife Generator,Electrode Probes, FootPedalElectrosurgical unit,active electrode,grounding pad,peristaltic pumpand footpedal
ESUBipolar or monopolarBipolar and MonopolarBipolarMonopolarDifferent. Thesubject device has
Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
twoconfigurations. Itdoes not impactdevice safety andeffectiveness
Pulse Amplitude/Voltageoutput500 ~ 3000V500 ~ 3000VN/A, no pulse modeIdentical
Pulse amplitude precision$\pm$ 5%$\pm$ 5%N/A, no pulse modeIdentical
Pulse mode~50A~50AN/A, no pulse modeIdentical
MaximumOutputCurrentNeedleTrackCoagulationMode1AN/A2ADifferent. Theworking current isless than that ofthe Referencedevice.
Pulse widthmonophasicpulse mode20 ~ 120μs20 ~ 100μsN/A, no pulse modeDifferent. Thepulse width ofmonopolar modeis wider than thatof predicate
biphasicpulse mode5 ~ 40μsN/A, no biphasicconfigurationN/A, no pulse modedevice. Animaltest resultsprovided to

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Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
demonstrateequivalence.
Pulse width precision±2µs or ±2%(whichever islarger)±2µs or ±2% (whichever islarger)N/A,no pulse modeIdentical
Number of pulse(s)1 ~ 20010 ~ 100N/A, no pulse modeDifferent. Thedifference isbetweenallowableadjustment range
Volts/cm500 ~ 3000500 ~ 3000N/A, no pulse modeIdentical
Maximum probes66N/A, no pulse modeIdentical
Pulse frequency, Un-sync30~ 240PPM/every 10 pulse240PPM/every 10 pulse90PPM/every 10 pulseN/A, no pulse modeDifferent. Thehighest pulsefrequency ofsubject device issame as that ofpredicate device.
Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
Pulse frequency, SyncECG, frequency variesdepending on heart rate,<120PPMECG, frequency variesdepending on heart rateN/A, no pulse modeDifferent. Forsubject device,frequency variesdepending onheart rate below120PPM
ECG synchronizationtriggeringYesYesN/A, no pulse modeIdentical
Temperature sensorsNoneNoneyesIdentical toPredicate.
Impedance monitorYesYesYesIdentical
Continuity monitorYesYesYesIdentical
RF Output frequency480kHZ± 10 %N/A (refer to Pulsefrequency)480kHZ± 10 %Identical toReference
WaveformmonophasicSquare wave with steep edge(one direction)Square wave with steepedge (one direction)Square wave withsteep edge (onedirection)Different, both thepredicate deviceand reference
biphasicSquare wave with steep edge(alternative direction)N/A, no bipolarconfigurationN/A, no bipolarconfigurationdevice have nobiphasic waveform.Animal tissueablation testing
Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
demonstrate safetyand effectiveness
Maximum Energy perPulse (normal)Up to 40 watts at 50Ω (18J)15JUp to 200 watts at50 ohmDifferent.The maximumpower output isalmost the samewith thepredicate device.
Drive on timeIt will stop working when theimpedance is up to 800ΩN/A, no needle trackcoagulationUp to 30 minutes,and will stopworking when theimpedance is up to800ΩIdentical to thereference device
Crest factor1.4141.4141.414Identical
Physical dimension460mm(L)×410mm (W)×200mm (H)680mm(L) x 560 mm(W) x1490 mm(H)193mm (W) x60mm(H) x 135mm(D)Different. Sizedifference doesnot impact safetyand effectiveness.
ActiveAccessoryMonopolar or bipolarMonopolar or BipolarMonopolarMonopolarDifferent.The subjectdevice has twoconfigurations, it

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Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
does not impactsafety andeffectiveness
Physical dimensionThe following lengths ofMonopolar Probe areavailable: 13cm, 15cm, 18cm,25cm. Working length isadjustable in 0.5 cmincrements from 0 – 4 cm viathe thumbslide. Probe needlesize: 19GBipolar Probe lengths: 15cm,25cm. Working length is 1cm,2cm, 3cm and 4cm. Probeneedle size: 18G, 15G.Monopolar length: 15 cm,25cm, working length isadjustable in 0.5 cmincrements from 0 – 4 cmvia the thumbslide. Probeneedle size: 19GBipolar: not available.Monopolar length:15 cm, 20cm,working length0.5cm, 1cm, 1.5cm,2cm, 2.5cm and3cm. Probe needlesize: 15G and 17G.Bipolar: notavailable.Different. Moreavailable probedimensions aredesigned fordifferent clinicalapplication. Noimpact safety andeffectiveness.
Connector type6 pin6 pin1 pinDifferent.Connector type isdependent ondesignspecifications.The differencedoes not impactsafety andeffectiveness.

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Comparison ElementsSubject DevicePredicate DeviceReference DeviceComment
PatientcontactMaterialsmonopolarStainless steel, PIStainless steel, PIStainless steel, PIDifferent.All materials meetISO 10993-1
bipolarStainless steel, PI,PTFEN/A, no bipolarconfigurationN/A,no bipolarconfigurationbiocompatibilityrequirement.
NeutraelectrodesConductiveor capacitiveConductiveConductiveIdentical to
MaterialsHydrogelN/A, no neutral electrodesHydrogelReference
FunctionsControl the starting and stopping of theenergy output.Control the starting andstopping of the energyoutput.Control the startingand stopping of theenergy output.Identical
FootSwitchPerformancespecificationSingle trigger, IPX 8Double trigger, IPX 8Single trigger, IPX 8Different. Thedifference doesnot impact safetyand effectiveness.

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Software description

The software is a built-in(embedded) software. The main function of it is to support Irreversible Electroporation Ablation Generator to achieve its intended use. It comprises of 11 submodules including user interface, IRE process control, coagulation process control, sensor measurement, button control, warning judgement, data storage, power output calibration, preoperative plan, postoperative analysis, and ECG synchronization. IEC62304:2015 and Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (Issued on May 11,2005) were used as reference documents during software design verification/validation.

Non-Clinical Tests

Non-clinical tests were conducted to verify that the subject devices met all design specifications and is substantially equivalent to the predicate.

Ex-vivo tissue testing using swine muscle tissue, liver tissue and kidney tissue was performed. The result showed the ablation effect and ablation zones of the subject device is substantial equivalent to the predicate device and the reference device. ECG trigger mode testing was conducted to compare ECG synchronization trigger mode of subject to that of the predicate device.

In-vivo animal (swine) testing was conducted to compare the subject device group and predicate device group in following aspects: blood routine, blood biochemistry, myocardial enzymes and the diameter of ablation. The long ablation diameter and short ablation diameter of subject device group was compared to those of predicate device.

The test results demonstrated that the proposed device complies with the following standards:

  • A ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012 Medical electrical equipment -Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD)
  • A IEC60601-1-2:2014 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
  • A IEC 60601-2-2 Edition 6.0 2017-03 Medical electrical equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
  • A IEC 60601-1-6 Edition 3.1 2013-10 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
  • ISO 10993-5 Third edition 2009-06-01 Biological evaluation of medical devices -Part 5: Tests for in vitro cytotoxicity

  • A ISO 10993-10 Third Edition 2010-08-01 Biological evaluation of medical devices -Part 10: Tests for irritation and skin sensitization

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  • A ISO 10993-11 Third edition 2017-09 Biological evaluation of medical devices -Part 11: Tests for systemic toxicity
  • ISO 10993-11 Third edition 2017-09 Biological evaluation of medical devices-Part 11: Test for systemic toxicity--Pyrogen test

  • A Chinese Pharmacopoeia (2020 version) Bacteria Endotoxins Test
  • A ISO 10993-7:2008 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals
  • A ISO 11135 Second edition 2014-07-15 Sterilization of health-care products -Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices
  • A ISO 11137-2:2019 Sterilization of health care products - Microbiological methods - Part 2: Tests of sterility performed in the definition, validation and maintenance of a sterilization process
  • A ASTM F1980-16 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices

Clinical data

No clinical data was provided.

Conclusion

The indications for use of subject device are equivalent to the predicate device. The standards testing and nonclinical performance testing demonstrates the subject device technological characteristics are equivalent to the predicate device for general soft tissue electroporation. In conclusion, the subject device is substantially equivalent to the predicate device.

§ 878.4400 Electrosurgical cutting and coagulation device and accessories.

(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.