(138 days)
The Disposable Ureteral Access Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract.
The product is composed of sheath tube, sheath tube base, dilator and center base of dilator. The sheath tube base contains a backwater interface. The center base of dilator consists of upper cover of dilator base, lower cover of dilator base , fiber image channel interface F, irrigation channel interface I, equipment channel interface E, obturator, two-way water valve, needle free joint. There is no guide wire. The product is sterilized by EO, it should be sterile and only for single use.
This document describes the premarket notification (510(k)) for the Disposable Ureteral Access Sheath by YouCare Technology Co., Ltd. (Wuhan). The submission aims to demonstrate substantial equivalence to a predicate device, K151084 Well Lead Ureteral Access Sheath.
No human-in-the-loop or standalone AI performance studies were conducted or are mentioned in this submission, as this device is a physical medical instrument, not an AI/software device. The "acceptance criteria" discussed here refer to the performance standards and material safety criteria for the physical device, rather than the performance of an AI algorithm.
1. A table of acceptance criteria and the reported device performance:
| Acceptance Criteria | Reported Device Performance (YouCare Disposable Ureteral Access Sheath) | Predicate Device (Well Lead Ureteral Access Sheath) | Conclusion on Equivalence |
|---|---|---|---|
| Intended Use | To establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. | To establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract. | Same |
| Regulation # | 21 CFR § 876.1500 | 21 CFR § 876.1500 | Same |
| Product Code | FED | FED | Same |
| Classification Name | Endoscope and accessories | Endoscope and accessories | Same |
| Regulatory Class | Class II | Class II | Same |
| Sterility | Yes | Yes | Same |
| Sterilization Method | EO | EO | Same |
| Single Use | Yes | Yes | Same |
| Biocompatible | Yes (Passed Cytotoxicity, Sensitization, Intracutaneous reactivity, Material mediated pyrogenicity, Acute systemic toxicity tests per ISO standards). | Yes | Same |
| Shelf Life | 3 years | 3 years | Same |
| Bending Resistance | Bending any section of the dilator, sheath tube or the assembly of sheath tube and dilator into a ring with a radius of 5cm for 1min, there should be no crease, crack or other undesirable phenomena. | Bending any section of the dilator, sheath tube or the assembly of sheath tube and dilator into a ring with a radius of 5cm for 1min, there should be no crease, crack or other undesirable phenomena. | Same |
| Coefficients of Friction | When the sheath tube is tested for friction, the friction coefficient shall not exceed 0.03. | When the sheath tube is tested for friction, the friction coefficient shall not exceed 0.03. | Same |
| Peak Tensile Force | The peak tensile force of the sheath tube and dilator should not be less than 15N. And the peak tensile force of the junction between sheath tube and sheath tube base, the dilator and center base of dilator also shall meet the requirement. | The Dilator to Hub Tensile Strength > 15N. | Same |
| Additional Performance Tests | Determining the Dimensions, Flow test, Patency, Connection, Luer taper (Details of specific thresholds/results not provided beyond "passed"). | (Implied to meet similar functional performance based on equivalence claim, specific thresholds not detailed in this excerpt for predicate) | (Implied) |
| Sheath ID | 12Fr | 10Fr, 12Fr, 14Fr | Different 1 (Considered not to raise different questions of safety/effectiveness as physicians select based on patient condition). |
| Sheath length | 45cm, 35cm | 13cm, 20cm, 28cm, 35cm, 45cm, 55cm | Different 2 (Considered not to raise different questions of safety/effectiveness as physicians select based on patient condition). |
| Primary Structure | Composed of sheath tube, sheath tube base, dilator and center base of dilator. Sheath tube base contains a backwater interface. Center base of dilator consists of upper/lower cover, fiber image channel interface F, irrigation channel interface I, equipment channel interface E, obturator, two-way water valve, needle free joint. | Comprised of three components: sheath, dilator and connector. Outer surface of the sheath has a hydrophilic coating. | Different 3 (Considered not to raise different questions of safety/effectiveness, only increases operation requirements for doctors). |
| Materials | Sheath tube: Pebax6333 SA01 MED, SUS 304, PTFE, PAM. Sheath tube base: ABS, PC. Dilator: LDPE. Center base of dilator components: ABS, PC, silica gel, POM. | Sheath Tube: PTFE, Nylon (PA), stainless steel. Outer surface: Nylon (PA). Inner surface: PTFE. Dilator: Polyethylene (PE). | Different 4 (Pebax6333 has properties of nylon; both passed biological tests, hence not raising new questions of safety/effectiveness). |
2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
The document does not specify exact sample sizes for each non-clinical test conducted (e.g., number of devices tested for bending resistance, friction, etc.). The non-clinical tests were conducted to assess the intrinsic properties of the device, likely a representative sample of manufactured units.
The data provenance is from YouCare Technology Co., Ltd. (Wuhan), China. The tests are non-clinical (laboratory/bench testing) and thus not applicable to retrospective or prospective human patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not applicable as the device is a physical medical instrument, and the testing involves non-clinical performance and material safety assessments, not an AI or diagnostic algorithm requiring expert "ground truth" establishment for image interpretation or similar.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
This information is not applicable for the same reasons as point 3. Testing involves objective measurements against established technical standards (e.g., tensile strength in Newtons, friction coefficients, visual inspection for defects after bending).
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:
This information is not applicable as the device is a physical medical instrument, not an AI/software device. No MRMC study was conducted or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
This information is not applicable as the device is a physical medical instrument, not an AI/software device. No standalone algorithm performance was assessed.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for this device's performance is based on established engineering standards, material specifications, and regulatory guidelines for mechanical properties, material biocompatibility, sterility, and physical dimensions. For example, testing for "Peak tensile force" has a "ground truth" defined as "not less than 15N." Biocompatibility is assessed against ISO 10993 standards.
8. The sample size for the training set:
This information is not applicable as the device is a physical medical instrument, not an AI/software device. There is no concept of a "training set" in the context of this 510(k) submission.
9. How the ground truth for the training set was established:
This information is not applicable for the same reasons as point 8.
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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: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.
August 2, 2023
YouCare Technology Co., Ltd. (Wuhan) Bing Hu Manager Tangxunhu North Street Wuhan, Hubei 430000 China
Re: K230748
Trade/Device Name: Disposable Ureteral Access Sheath Regulation Number: 21 CFR§ 876.1500 Regulation Name: Endoscope and Accessories Regulatory Class: II Product Code: FED Dated: July 5, 2023 Received: July 5, 2023
Dear Bing Hu:
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.
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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-regulatoryinformation/postmarketing-safety-reporting-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-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,
Mark J. Antonino -S
Mark J. Antonino, M.S. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology 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) K230748
Device Name Disposable Ureteral Access Sheath
Indications for Use (Describe)
The Disposable Ureteral Access Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract
Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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Section 5 - 510(k) Summary
Date of Summary Preparation: 07/16/2023
1. Submitter's Identifications
Submitter's Name: YouCare Technology Co., Ltd.(Wuhan). Address: Great Wall Science and Technology Park, Tangxunhu North Street, East Lake Development Zone Wuhan, 430223 Hubei P.R. China. Contact Person: Bing Hu Contact Email: hb@youcaretech.com Telephone: +86-27-87926396-830
2. Correspondent's Identifications
Correspondent's Name: YouCare Technology Co., Ltd.(Wuhan). Address: Great Wall Science and Technology Park, Tangxunhu North Street, East Lake Development Zone Wuhan, 430223 Hubei P.R. China. Contact Person: Bing Hu Contact Email: hb@youcaretech.com Telephone: +86-27-87926396-830
3. Name of the Device
Product Name: Disposable Ureteral Access Sheath Trade Name: Disposable Ureteral Access Sheath Model: YC-Videoaid-sheath-A YC-Videoaid-sheath-B Classification Name: Endoscope and accessories Regulation Number: 21 CFR§ 876.1500 Product Code: FED Device Classification: Class II
4. The Predicate Devices
Well Lead Ureteral Access Sheath
This predicate has not been subject to a design-related recall. No reference devices were used in this submission
5. Device Description
The product is composed of sheath tube, sheath tube base, dilator and center base of dilator. The sheath tube base contains a backwater interface. The center base of dilator consists of upper cover of dilator base, lower cover of dilator base , fiber image channel interface F, irrigation channel interface I, equipment channel interface E, obturator, two-way water valve, needle free joint. There is no guide wire. The product is sterilized by EO, it should be sterile and only for
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single use.
6. Indications for use
The Disposable Ureteral Access Sheath is used to establish a conduit during endoscopic urological procedures facilitating the passage of endoscopes and other instruments into the urinary tract.
7. Operating instructions
-
Substantial Equivalence
-
Check the package, it is forbidden to use when sterile barrier is damaged.
-
Open the package, and make sure that the product structure is complete without missing of product structure, and it is firmly connected between two-way water valve and irrigation channel, obturator and fiber image channel, needle free joint and equipment channel
-
Insert the guide wire (diameter no more than 0.035 inch or 0.89mm) into ureter to the predetermined length, and then build the channel.
-
The endoscope is inserted through the obturator into the fiber image channel until the objective lens of endoscope reaches the end of the dilator. Connect the negative pressure aspirator to irrigation channel.
-
After flushing and lubricating the sheath tube with normal saline, take away the needle free joint, insert the guide wire into the channel (marked with a notch) on the top of dilator which until it extends out of the equipment channel interface E, then reinstall the needle free joint after threading guide wire out of the needle free joint ..
-
Push the dilator/sheath along guide wire, open the two-way water valve and water irrigation system to ensure the view of the endoscope is clear. Confirm the position of dilator/sheath through the endoscope.
-
Fix the sheath in place, at the same time, loosen the joint and remove the dilator.
-
Import the required endoscope or other surgical instruments.
| New device | Predicate device | Comparison | |
|---|---|---|---|
| "K"NUMBERS | / | K151084 | / |
| Manufacturer | YouCare Technology Co.,Ltd.(Wuhan). | Well Lead Medical Co. Ltd | / |
| Regulation # | 876.1500 | 876.1500 | Same |
| Product Code | FED | FED | Same |
| Classificationname | Endoscope and accessories | Endoscope and accessories | Same |
| Intended use | It is intended to establish achannel during urologic surgicalprocedures, facilitating thepassage of endoscopes and otherinstruments into the urinarytract. | The Well Lead ureteral accesssheath is used to establish aconduit during endoscopicurological procedures facilitatingthe passage of endoscopes andother instruments into the urinarytract. | Same |
| Regulatory Class | Class II | Class II | Same |
| Sterility | Yes | Yes | Same |
| SterilizationMethod | EO | EO | Same |
| Single Use | Yes | Yes | Same |
| Sheath ID | 12Fr | 10Fr, 12Fr, 14Fr | Different 1 |
| Sheath length | 45cm, 35cm | 13cm, 20cm, 28cm, 35cm, 45cm,55cm | Different 2 |
| Primarystructure | The product is composed of sheathtube, sheath tube base, dilator andcenter base of dilator. The sheathtube base contains a backwaterinterface. The center base of dilatorconsists of upper cover of dilatorbase, lower cover of dilator base ,fiber image channel interface F,irrigation channel interface I,equipment channel interface E,obturator, two-way water valve,needle free joint. | The Well Lead Ureteral AccessSheath is comprised of threecomponents: sheath, dilator andconnector. The outer surface ofthe sheath has a hydrophiliccoating. | Different 3 |
| Materials | sheath tube: Pebax6333 SA01MED, SUS 304, PTFE, PAMsheath tube base: ABS, PC(backwater interface: PC)dilator: LDPE | Sheath Tube: PTFE, Nylon (PA),stainless steelOuter surface: Nylon (PA)Inner surface: PTFEDilator: Polyethylene (PE) | Different 4 |
| center base of dilator | |||
| upper cover of the dilator base:ABS | |||
| lower cover of the dilator base:ABS | |||
| fiber image channel interface F:PC | |||
| irrigation channel interface I: PCequipment channel interface E:PC | |||
| obturator: PC, silica gel | |||
| two-way water valve: PC, POM | |||
| needle-free joint: PC, silica gel | |||
| Package | Single-use EO sterilized pouch withone device per pouch | Single-use EO sterilized pouch withone device per pouch | Same |
| Biocompatible | Yes | Yes | Same |
| Shelf Life | 3 years | 3 years | Same |
| BendingResistance | Bending any section of thedilator, sheath tube or theassembly of sheath tube anddilator into a ring with a radiusof 5cm for 1min, there should beno crease, crack or otherundesirable phenomena. | Bending any section of thedilator, sheath tube or theassembly of sheath tube anddilator into a ring with a radiusof 5cm for 1min, there shouldbe no crease, crack or otherundesirable phenomena. | Same |
| Coefficients ofFriction | When the sheath tube is testedfor friction, the frictioncoefficient shall not exceed 0.03. | When the sheath tube is testedfor friction, the frictioncoefficient shall not exceed0.03. | Same |
| Peak tensileforce | The peak tensile force of thesheath tube and dilator shouldnot be less than 15N. And thepeak tensile force of the junctionbetween sheath tube and sheathtube base, the dilator and centerbase of dilator also shall meetthe requirement | The Dilator to Hub TensileStrength>15N. | Same |
Comparison of technology characteristics
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YouCare Technology Co., Ltd.(Wuhan).
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YouCare Technology Co., Ltd.(Wuhan).
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9. Substantial equivalence discussion:
Different 1 -sheath ID
This difference is in sheath ID. Different sheath inner diameter device will be selected by physician per patient's condition. Moreover, a small diameter difference has little effect on the product safety performance
Different 2 -Sheath length
This difference is in sheath length. Different sheath length device will be selected by physician per patient's condition, the length difference did not affect the safety and efficacy of the product.
Different 3 - Primary structure
The sheath base of the new device is similar to the connector of the predict product. The New device has three instrument channels --- image channel, irrigation channel and equipment channel, it does not raise different questions of safety and effectiveness for patient, it only increases the operation requirements for doctors.
Different 4 - Materials
The materials of sheath tube and dilator are different. The new device is 304 Stainless Steel and Pebax6333 and Low-Density Polyethylene(LDPE), the materials of predicate device is Stainless Steel、Nylon(PA)and Polyethylene. Pebax6333 is a block polymer composed of nylon and polyether parts, which has the properties of nylon. Although the materials are different, the performance of the product is not affected, and both passed the biological test.
Substantial Equivalence discussion:
The proposed devices and the predicated device have classification information, similar materials, same specifications, same performance effectiveness. The Model of Proposed Device is included in the Model of Predicate device. The Indications for use of proposed device is same as the predicated device. the proposed devices are as safe, as effective and perform as well as the predicate device. So the proposed devices are Substantially Equivalent (SE) to the predicate device which is US legally market device.
10. Non-Clinical Tests Performed:
Non-clinical Testing: A series of preclinical tests were performed to assess the safety and performance of the Disposable Ureteral Access Sheath including biocompatibility physical and mechanical performance.
The following biocompatibility and safety tests were conducted in compliance with ISO standards:
Biocompatibility
- . Cytotoxicity Test: ISO10993-5
- . Sensitization: ISO 10993-10
- . Intracutaneous reactivity:1SO10993-10
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- Material mediated pyrogenicity: ISO10993-11
- Acute systemic toxicity: ISO10993-11 ●
Ethylene Oxide Sterilization Validation:
- ISO 11135:2014
- ISO 11737-1:2018
- ISO11737-2:2019
- ISO 10993-7: 2008
Shelf life and Package Validation:
- ASTM F1980-2016 .
- ASTM D3078-02-2021
- ASTMF 1929-15
- . ASTM F88/F88M-15
11. Performance testing
The following performance testing was conducted:
- . Bending resistance
- Coefficients of Friction
- Determining the Dimensions
- Flow test
- Patency
- . Connection
- Peak tensile force
- . Luer taper
12. Clinical Test Conclusion
No clinical study is included in this submission.
13. Conclusion:
Comparison to the predicate devices for Intended Use, structure and physical, it shows that our products are as safe, as effective and performs as well as the predicate devices.
--- End of this section ---
§ 876.1500 Endoscope and accessories.
(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.