(90 days)
The ECHELON LINEAR™ Cutters have application in gastrointestinal, thoracic, and pediatric surgery for transection, resection, and the creation of anastomoses.
The ECHELON LINEAR™ Cutter delivers two, double-staggered rows of staples while simultaneously dividing the tissue between rows. The instrument has a safety lockout feature that is designed to prevent firing if either no reload or a used reload is installed. An unclamp lockout feature prevents knife exposure by allowing the instrument to open only when the Firing Knob is in the home position. A clamp lockout feature prevents closure of the jaws when the knife is not in the home position. A Staple Retaining Cap on the reload protects the staple leg points during shipping and transportation.
This device may be used on the general population for routine wound closure via stapling.
The 60 mm reload creates a 61 mm staple line and cuts tissue approximately 52 mm beyond the tissue stop.
The 80 mm reload creates an 81 mm staple line and cuts tissue approximately 72 mm beyond the tissue stop.
The 100 mm reload creates a 101 mm staple line and cuts tissue approximately 92 mm beyond the tissue stop.
The instruments are shipped without a reload and must be loaded prior to use. The instrument may be loaded eight times for a maximum of eight firings per instrument during a single procedure.
This document describes the premarket notification (510(k)) for the ECHELON LINEAR™ Cutters, demonstrating its substantial equivalence to a predicate device. As such, the "acceptance criteria" and "device performance" in this context refer to the results of bench and animal testing that demonstrate the new device functions as intended and is safe and effective when compared to existing, legally marketed devices.
It's important to note that this is a 510(k) summary, not a detailed study report. Therefore, some granular details like exact sample sizes for each specific test might not be explicitly stated, but the types of tests and the overall conclusion are provided. The document specifically states that no clinical studies were performed.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
For a 510(k) submission, "acceptance criteria" for performance data typically refers to demonstrating that the new device performs comparably to the predicate device and meets functional requirements (e.g., staple formation, strength, operational forces). The document states that the testing demonstrated substantial equivalence, implying the "acceptance criteria" were met by the "reported device performance."
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Bench Testing: | |
| Device Stapling Performance (Formed Staple Height (FSH), Staple Form Quality (SFQ), Staple Line Integrity (SLI)) comparable to predicate. | Performance demonstrated as substantially equivalent to the predicate device. Specific quantitative values for each performance metric are not provided in this summary but would have been demonstrated to be within acceptable ranges or comparable to the predicate. |
| Device Functional Requirements (Force to Close/Clamping Force, Force to Fire, Force to Couple/Decouple Device Halves, Force to Press Clamp Release Button, Human Factor Report) met. | Functional requirements were met. Specific force values or Human Factor report details are not provided in this summary. |
| Product Characterization (Staple line Strength Test) met. | Staple line strength was demonstrated. Specific strength values are not provided. |
| Animal Testing: | |
| Acute Hemostasis achieved. | Acute Hemostasis was successfully evaluated. |
| Appropriate Tissue Healing response observed in Survival Study. | Tissue Healing response was evaluated in survival studies using gastrointestinal and pulmonary models. |
| Biocompatibility: | |
| Biocompatible for intended patient contact profile. | Studies performed and confirmed the device is biocompatible. |
2. Sample Sizes Used for the Test Set and Data Provenance
- Sample Sizes for Test Set (Bench and Animal Testing): The specific sample sizes for each bench test (e.g., number of staples tested for FSH, SFQ, SLI; number of devices for force measurements) and for the animal studies are not explicitly stated in this 510(k) summary. These details would be contained in the full submission, but not in this public summary.
- Data Provenance: Not explicitly stated. For bench and animal testing typically conducted internally or by contract research organizations, the country of origin is usually the manufacturer's location or the location of the testing facility. The data would be considered prospective as it's generated for the purpose of the submission.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable/not provided in this context. For a device like a surgical stapler, "ground truth" is established through engineering specifications, scientific principles, and established methods for evaluating device performance (e.g., measuring staple dimensions, tensile strength, in-vivo tissue response). There isn't a subjective "expert read" or "adjudication" in the same way there would be for an AI diagnostic algorithm.
4. Adjudication Method for the Test Set
This information is not applicable/not provided. As explained above, for a mechanical device, performance is evaluated against objective, measurable criteria, not subjective expert opinion requiring adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not done. The document explicitly states: "The premarket submission did not rely on the assessment of clinical performance data to demonstrate device performance and equivalence." This device is not an AI diagnostic tool and does not involve human readers for interpretation.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
No, a standalone algorithm study was not done. This device is a mechanical surgical stapler, not an AI algorithm.
7. Type of Ground Truth Used
The "ground truth" for this device is based on:
- Engineering specifications and design parameters: For bench testing (e.g., desired staple height, cutting length, force requirements).
- Biomechanical principles: For staple line strength and integrity.
- Physiological outcomes: For animal testing (e.g., hemostasis, tissue healing).
- Comparison to predicate device performance: The core of a 510(k) is demonstrating substantial equivalence to a legally marketed predicate device, implying that the predicate's established safe and effective performance serves as a benchmark for the new device.
8. Sample Size for the Training Set
This information is not applicable/not provided. This is a mechanical device, not an AI/ML algorithm that requires a "training set."
9. How the Ground Truth for the Training Set Was Established
This information is not applicable/not provided. As above, there is no "training set" for a mechanical device.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food & 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.
March 15, 2023
Ethicon Endo-Surgery Alicia Butler Senior Regulatory Affairs Specialist 475 Calle C Guaynabo, PR 00969
Re: K223760
Trade/Device Name: ECHELON LINEAR™ 60 mm Cutter (GLC60):ECHELON LINEAR™ 80mm Cutter (GLC80);ECHELON LINEAR™ 100 mm Cutter (GLC100);ECHELON LINEAR™ Cutters 60mm Blue Reload (GLCR60B);ECHELON LINEAR™ Cutters 60mm Green Reload (GLCR60G):ECHELON LINEARTM Cutters 80mm Blue Reload (GLCR80B):ECHELON LINEAR™ Cutters 80mm Green Reload (GLCR80G);ECHELON LINEAR™ Cutters 100mm Blue Reload (GLCR100B);ECHELON LINEAR™ Cutters 100mm Green Reload (GLCR100G) Regulation Number: 21 CFR 878.4750 Regulation Name: Implantable Staple Regulatory Class: Class II Product Code: GDW Dated: December 15, 2022 Received: December 15, 2022
Dear Alicia Butler:
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
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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 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: 2023.03.15 08:05:38 -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
Submission Number (if known)
Device Name
| ECHELON LINEARTM 60 mm Cutter (GLC60); |
|---|
| ECHELON LINEARTM 80mm Cutter (GLC80); |
| ECHELON LINEARTM 100 mm Cutter (GLC100); |
| ECHELON LINEARTM Cutters 60mm Blue Reload (GLCR60B); |
| ECHELON LINEARTM Cutters 60mm Green Reload (GLCR60G); |
| ECHELON LINEARTM Cutters 80mm Blue Reload (GLCR80B); |
| ECHELON LINEARTM Cutters 80mm Green Reload (GLCR80G); |
| ECHELON LINEARTM Cutters 100mm Blue Reload (GLCR100B); |
| ECHELON LINEARTM Cutters 100mm Green Reload (GLCR100G) |
| Indications for Use (Describe) |
| The ECHELON LINEARTM Cutters have application in gastrointestinal, thoracic, and pediatric |
| surgery for transection, resection, and the creation of anastomoses. |
| 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
I. SUBMITTER
Company: Ethicon Endo-Surgery, LLC 475 Calle C Guaynabo, PR 00969
Contact: Alicia Butler Senior Regulatory Affairs Specialist Ethicon Endo-Surgery, Inc. Phone: 513-337-1633 Email: abutler9@its.jnj.com
Date Prepared: December 15, 2022
II. SUBJECT DEVICES
Trade Names:
- ECHELON LINEAR™ 60mm Cutter and Reloads ●
- ECHELON LINEAR™ 80mm Cutter and Reloads ●
- ECHELON LINEAR™ 100mm Cutter and Reloads .
| Common or Usual Name: | Surgical Stapler with Implantable Staples | Classification Name: | Implantable staple (21 CFR 878.4750) |
|---|---|---|---|
| Regulatory Class: | Class 2 -Staple, Implantable | Product Code: | GDW |
| Common or Usual Name: | Surgical Stapler with Implantable Staples | Classification Name: | Surgical Stapler (21 CFR 878.4740) |
| Regulatory Class: | Class 2 - Stapler, Surgical | Product Code: | GAG |
III. PREDICATE DEVICES
| Predicate Device510(k) Number | Predicate Device Name | Predicate Device Product Codes |
|---|---|---|
| K020779 | PROXIMATE® Linear Cutters with SafetyLockout and Reloads | Devices: TLC55, TLC75, TLC10Reloads: TCR55, TCT55, TCR75,TCT75, TCR10, TCT10 |
These predicates have not been Subjected to a recall related to these design modifications.
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| SubjectDeviceProductCode | Product CodeDescription | StapleLineLength | CutLineLength | SubjectDeviceReloads | Predicate DeviceProduct Code | Predicate Knumber |
|---|---|---|---|---|---|---|
| GLC60 | ECHELONLINEAR™ 60mmCutter | 61mm | 55mm | GLCR60BGLCR60G | TLC55CompatibleReloads:TCR55 (Blue)TRT55 (Green) | K020779 |
| GLC80 | ECHELONLINEAR™ 80mmCutter | 81mm | 75mm | GLCR80BGLCR80G | TLC75CompatibleReloads:TCR75 (Blue)TRT75 (Green) | K020779 |
| GLC100 | ECHELONLINEAR™ 100mmCutter | 101mm | 95mm | GLCR100BGLCR100G | TLC10CompatibleReloads:TCR10TRT10 | K020779 |
Table 5-1: ECHELON LINEAR™ Cutters Product Configuration
Table 5-2: Reload codes and corresponding reload color
| Reloads Codesfor60mm | Reload Codes for80mm | Reload Codes for100mm | Corresponding ReloadColor |
|---|---|---|---|
| GLCR60B | GLCR80B | GLCR100B | Blue |
| GLCR60G | GLCR80G | GLCR100G | Green |
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DEVICE DESCRIPTION
The ECHELON LINEAR™ Cutter delivers two, double-staggered rows of staples while simultaneously dividing the tissue between rows. The instrument has a safety lockout feature that is designed to prevent firing if either no reload or a used reload is installed. An unclamp lockout feature prevents knife exposure by allowing the instrument to open only when the Firing Knob is in the home position. A clamp lockout feature prevents closure of the jaws when the knife is not in the home position. A Staple Retaining Cap on the reload protects the staple leg points during shipping and transportation.
This device may be used on the general population for routine wound closure via stapling.
The 60 mm reload creates a 61 mm staple line and cuts tissue approximately 52 mm beyond the tissue stop.
The 80 mm reload creates an 81 mm staple line and cuts tissue approximately 72 mm beyond the tissue stop.
The 100 mm reload creates a 101 mm staple line and cuts tissue approximately 92 mm beyond the tissue stop.
The instruments are shipped without a reload and must be loaded prior to use. The instrument may be loaded eight times for a maximum of eight firings per instrument during a single procedure.
IV. INDICATIONS FOR USE
The ECHELON LINEAR™ Cutters have application in gastrointestinal, thoracic, and pediatric surgery for transection, resection, and the creation of anastomoses.
COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE V. PREDICATE DEVICE
ECHELON LINEAR™ Cutter is substantially equivalent to PROXIMATE® Linear Cutters with respect to operating principle of device and Intended Use of the device. Both the devices are sterile, single use manual devices. The key technological difference between the Subject and the predicate device is the change to the reloads with the addition of GST technology and a new 3D style anvil pocket.
The Subject device is a next generation Linear Cutter to be used in open procedures requiring a surgical stapler. To improve stapling performance, the Subject device incorporates proven GST Reload Technology, leveraged from Ethicon Endocutters, and new 3-D B-shaped final staple form into the new ECHELON LINEARTM Cutter Reload as shown in illustration 5-1.
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Illustration 5-1: GST Reload Technology and 3-D Final Staple Form
Image /page/6/Picture/2 description: The image contains two separate images with text below each. The image on the left is a close-up of a blue object with a textured surface, and the text below it reads "GST". The image on the right is a 3-D rendering of a metal object, and the text below it reads "3-D".
The Subject and predicate staplers have the following identical features:
- Indication (the compatibility with staple line reinforcement materials has not been evaluated ● for the Subject device and thus has been removed)
- Intended use
- Contraindications ●
- Materials
- MR compatibility
- Sterilization Method
- Operational principles ●
The following differences exist between the Subject and predicate staplers:
- Reloads: Subject device reloads contain GST technology used in Ethicon Endocutters along with a new 3D style anvil pocket. Also, only the newly designed Green and Blue reloads will be compatible with the device.
- New handle half coupling. The two device halves can be joined proximally or separated when maneuvering on tissue.
- . Clamp arm that latches when the device is clamped closed and unlatches by pressing the clamp release button.
- Firing knob consists of dual foldable firing knobs that can be activated from either the left ● side or the right side of the assembled device.
VI. PERFORMANCE DATA:
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The following performance data demonstrate that the Subject device is substantially equivalent to the predicate device and the differences between the devices were found not to affect safety or performance.
Bench Testing:
- Device Stapling Performance and Comparison to Predicate ●
- Formed Staple Height (FSH) O
- Staple Form Quality (SFO) O
- Staple Line Integrity (SLI) о
- Device Functional Requirement ●
- Force to Close/Clamping Force O
- O Force to Fire
- Force to Couple/Decouple Device Halves о
- Force to Press Clamp Release Button O
- Human Factor Report o
- Product Characterization ●
- o Staple line Strength Test
Animal Testing: In-vivo testing evaluations included
- Acute Hemostasis evaluation study
- Tissue Healing response, Survival Study using both gastrointestinal and pulmonary models.
Clinical studies: The premarket submission did not rely on the assessment of clinical performance data to demonstrate device performance and equivalence.
Biocompatibility: studies were performed and confirmed that the Subject device is biocompatible for the intended patient contact profile.
Electrical Safety and Electromagnetic Compatibility: This device is not powered and therefore this does not apply.
VII. CONCLUSIONS
The conclusions of the testing criteria demonstrate that the Subject device: ECHELON LINEAR™ CUTTER performs substantially equivalent to the predicate device and does not raise new questions of safety and effectiveness.
§ 878.4750 Implantable staple.
(a)
Identification. An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.(b)
Classification. Class II.