K Number
K231260
Device Name
HTx Disposable Hysteroscope System
Date Cleared
2024-03-05

(309 days)

Product Code
Regulation Number
884.1690
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
HTx Disposable Hysteroscope System is intended to be used for viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures. Note: Hysteroscopes are used as tools for access to the uterine cavity and are not, in and of themselves a method of surgery.
Device Description
The HTx Disposable Hysteroscope System is a single use hysteroscope endoscope intended for gynecology procedure applications. It includes a single-use, disposable hysteroscope cannula (HTx40 or HTx60), a reusable imaging system (HTx1000/Htx2000), and optional accessories (medical keyboard, barcode reader and IV pole mounting rack). The disposable hysteroscope contains a miniature CMOS camera, a light-emitting diode (LED) illumination module, and channels for fluid in/out flow as well as for instrument insertion. HTx60 has a cannula outer diameter of 6.2 mm and adapts to tools up to 3 mm (9 Fr), while HTx40 has an outer diameter of 4.5 mm and adapts to tools up to 5 Fr. The cannula connects directly to the image processor via an image cable. The image processor processes the raw image signal from the cannula and outputs the video on a display for real-time visualization. The image processor includes input/output ports for interfacing with different peripherals such as a keyboard or a USB flash disk. Fluid irrigation is achieved through a tube which is connected to an IV bag and pressured via peristaltic pump (not included in the subject device). The fluid inflow channel shares the same with the working channel.
More Information

No
The description focuses on standard imaging and fluid management components, and there is no mention of AI or ML in the device description, intended use, or performance studies.

No
The device is described as a tool for viewing and accessing the uterine cavity and cervical canal for diagnostic and operative procedures, explicitly stating it is not a method of surgery. This indicates it is a surgical accessory rather than a therapeutic device that provides treatment.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is "intended to be used for viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures."

No

The device description clearly outlines hardware components such as a disposable hysteroscope cannula with a CMOS camera and LED illumination, a reusable imaging system (image processor), and optional accessories like a medical keyboard and barcode reader. While software is mentioned as being tested, the device is fundamentally a hardware system with integrated software for image processing and control.

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

Here's why:

  • Intended Use: The intended use is for "viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures." This describes a device used for direct visualization within the body, not for examining samples taken from the body.
  • Device Description: The description details a hysteroscope system that includes a camera, light, and channels for fluid and instruments. This is consistent with an endoscopic device used for internal examination and procedures.
  • Lack of IVD Characteristics: An IVD device typically involves the examination of biological samples (blood, urine, tissue, etc.) in vitro (outside the body) to provide information about a patient's health status. This device does not perform such analysis.

The device is a medical device used for visualization and access during gynecological procedures, but it does not fit the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

HTx Disposable Hysteroscope System is intended to be used for viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures.

Note: Hysteroscopes are used as tools for access to the uterine cavity and are not, in and of themselves a method of surgery.

Product codes

HIH

Device Description

The HTx Disposable Hysteroscope System is a single use hysteroscope endoscope intended for gynecology procedure applications. It includes a single-use, disposable hysteroscope cannula (HTx40 or HTx60), a reusable imaging system (HTx1000/Htx2000), and optional accessories (medical keyboard, barcode reader and IV pole mounting rack).

The disposable hysteroscopes (HTx40 or HTx60) were cleared under K211227. The disposable hysteroscope contains a miniature CMOS camera, a light-emitting diode (LED) illumination module, and channels for fluid in/out flow as well as for instrument insertion. HTx60 has a cannula outer diameter of 6.2 mm and adapts to tools up to 3 mm (9 Fr), while HTx40 has an outer diameter of 4.5 mm and adapts to tools up to 5 Fr. The cannula connects directly to the image processor via an image cable. The image processor processes the raw image signal from the cannula and outputs the video on a display for real-time visualization. The image processor includes input/output ports for interfacing with different peripherals such as a keyboard or a USB flash disk. Fluid irrigation is achieved through a tube which is connected to an IV bag and pressured via peristaltic pump (not included in the subject device). The fluid inflow channel shares the same with the working channel.

AcuVu has designed a new image processor HTx2000 as an alternative to the existing HTx1000 cleared under K211227 and modified HTx1000 since the clearance under K211227.

Changes made to the subject device compared to the predicate device are as follows:

  • A new image processor, HTx2000, is added to the system as an alternative option to the existing HTx1000.
    • Portable
    • an external monitor is optional for display
    • I HDMI port is available for an optional external monitor (2x DVI for HTx1000)
    • A new power source (Li-ion battery) is available in addition to an AC adapter.
    • Touch screen (no keyboard is needed)
    • Input interface: to connect the hysteroscope image cable and receive raw signal input, a 38-pin gold finger design (a 14-pin aviation socket for HTx2000)
    • LAN port is disabled
    • Software is revised for HTx2000 to incorporate the changes,
    • Polycarbonate/acrylonitrile, butadiene, styrene (PC/ABS) plastic housing material
  • Design changes of HTx1000 since K211227 clearance .
    • Magnetic ring: removed
    • Cable connector: a new connector of the hysteroscope and cable has been redesigned
    • Power cord: the power cord is changed
    • Power adapter: a new power adapter has been changed
    • ISP board: the image signal processor (ISP) board layout has been redesigned
    • An optional mounting rack is added as a new accessory for attaching the HTx2000 onto a metical IV pole.
    • Package and device labels are revised
      The HTx2000 is a portable version of the HTx1000 in that it comes with a built-in touch screen, eliminating the necessity of attaching a keyboard and an external monitor as user interface for information entry and display.

The HTx2000 will not supersede the legally marketed HTx1000, but is an alternative option for users. The HTx1000 will continue to be available as a component of the HTx Disposable Hysteroscope System. The following table provides an overview of all key components of the subject device and explains which are legacy modules inherited from the predicate device and which are newly developed ones.

The subject device also offers optional accessories, as summarized in Table 3 below.

Note:

  • The display (Jusha E240A) previously available as an optional accessory of the predicate device has now been removed from the accessory list of the subject device.
  • The IV pole mounting rack is a newly developed accessory for mounting the HTx2000 on an IV pole.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cervical canal and uterine cavity

Indicated Patient Age Range

adult

Intended User / Care Setting

Trained Medical Professionals / Hospitals and physician's office

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical tests were conducted to verify that the proposed device met all design specifications. No additional testing for HTx40 or HTx60 alone were necessary. However, the hysteroscope's compatibility with the image processors was assessed. The results demonstrated compliance with all design requirement specifications or statutory standards.

  • a) Bench-top test
      1. Color performance for HTx2000 utilizing the HTx40 and HTx 60 hysteroscopes assess the following specifications:
      • Ground truth measurements using a spectrophotometer
      • Working distance
      • color contrast enhancement (CCE)
      1. Basic electric safety (electrical, thermal, mechanical, etc.)

IEC 60601-1:2005+AMD1:2012 Medical Electrical Equipment- Part 1: General requirements for basic safety and essential performance.

    1. Electromagnetic compatibility
      IEC 60601-1-2:2020, Medical electrical equipment- Part 1-2: General requirements for basic safety and essential performance- Collateral standard: Electromagnetic compatibility- Requirements and tests.
    1. Software testing
      The software of the subject device was validated as Basic Documentation Level in accordance with FDA's Guidance for Industry and FDA Staff, "Content of Premarket Submissions for Device Software Functions", issued on June 14, 2023.
    1. Battery safety
      The lithium-ion battery safety was verified in compliance with the applicable requirements of IEC 62133-2:2017/AMD1:2021 and UN38.3.

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

Not Found

Predicate Device(s)

K211227

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 884.1690 Hysteroscope and accessories.

(a)
Identification. A hysteroscope is a device used to permit direct viewing of the cervical canal and the uterine cavity by a telescopic system introduced into the uterus through the cervix. It is used to perform diagnostic and surgical procedures other than sterilization. This generic type of device may include obturators and sheaths, instruments used through an operating channel, scope preheaters, light sources and cables, and component parts.(b)
Classification. (1) Class II (performance standards).(2) Class I for hysteroscope accessories that are not part of a specialized instrument or device delivery system; do not have adapters, connectors, channels, or do not have portals for electrosurgical, laser, or other power sources. Such hysteroscope accessory instruments include: lens cleaning brush, cannula (without trocar or valves), clamp/hemostat/grasper, curette, instrument guide, forceps, dissector, mechanical (noninflatable), and scissors. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 884.9.

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

March 5, 2024

Suzhou AcuVu Medical Technology Co., Ltd. Sam Mostafavi Regulatory Affairs B1-212, Bio-Nano Park, 218 Xinghu Street, Suzhou Industrial Park Suzhou, Jiangsu 215125 CHINA

Re: K231260

Trade/Device Name: HTx Disposable Hysteroscope System Regulation Number: 21 CFR 884.1690 Regulation Name: Hysteroscope and accessories Regulatory Class: II Product Code: HIH Received: January 30, 2024

Dear Sam Mostafavi:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"

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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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

2

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,

Reginald K. Avery -S

for Jason Roberts, Ph.D. 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) K231260

Device Name

HTx Disposable Hysteroscope System

Indications for Use (Describe)

HTx Disposable Hysteroscope System is intended to be used for viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures.

Note: Hysteroscopes are used as tools for access to the uterine cavity and are not, in and of themselves a method of surgery.

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

This summary of 510(k) is submitted in accordance with the requirements of 21 CFR 807.92.

1. Submitter Information:

Manufacturer:Suzhou AcuVu Medical Technology Co., Ltd.
B1-212, Bio-Nano Park, 218 Xinghu Street, Suzhou Industrial Park, Suzhou,
Jiangsu, China 215125
Contact Person:Sam Mostafavi
Email: ipcs11@ymail.com
Office Number: 650-670-6972
Facsimile Number: 650-578-9653
Date Prepared:March 1, 2024

2. Device Information:

Trade/Device Name:HTx Disposable Hysteroscope System
Common Name:Hysteroscope
Model:HTx1000 and HTx2000
Regulation Number:21 CFR § 884.1690
Regulation Name:Hysteroscope and accessories
Regulatory Class:Class II
Product Code:HIH (Hysteroscope (And Accessories))
Panel:Obstetrics/Gynecology

3. Predicate Device:

HTx Disposable Hysteroscope System (K211227). This predicate device has not been subject to a designrelated or safety recall.

4. Device Description

The HTx Disposable Hysteroscope System is a single use hysteroscope endoscope intended for gynecology procedure applications. It includes a single-use, disposable hysteroscope cannula (HTx40 or HTx60), a reusable imaging system (HTx1000/Htx2000), and optional accessories (medical keyboard, barcode reader and IV pole mounting rack).

5

Image /page/5/Picture/1 description: This image shows a white medical device with a long, thin probe extending from the top. The device has a handle with a button on it, and a blue, flower-shaped attachment at the top. The device is likely used for medical procedures, such as biopsies or tissue sampling. The background is a plain gray color.

(a) HTx40/HTx60 hysteroscope

Image /page/5/Picture/3 description: The image shows an HTx1000 image processor. The processor is white and light blue. The image processor has a variety of buttons and knobs on the front.

Image /page/5/Picture/4 description: The image shows a tablet device with a stand. The tablet has a gray screen and a white frame. The stand is attached to the back of the tablet and allows it to be propped up on a flat surface. There are also ports on the side of the tablet.

(c) HTx2000 image processor

Figure 1: HTx Disposable Hysteroscope System

The disposable hysteroscopes (HTx40 or HTx60) were cleared under K211227. The disposable hysteroscope contains a miniature CMOS camera, a light-emitting diode (LED) illumination module, and channels for fluid in/out flow as well as for instrument insertion. HTx60 has a cannula outer diameter of 6.2 mm and adapts to tools up to 3 mm (9 Fr), while HTx40 has an outer diameter of 4.5 mm and adapts to tools up to 5 Fr. The cannula connects directly to the image processor via an image cable. The image processor processes the raw image signal from the cannula and outputs the video on a display for real-time visualization. The image processor includes input/output ports for interfacing with different peripherals such as a keyboard or a USB flash disk. Fluid irrigation is achieved through a tube which is connected to an IV bag and pressured via peristaltic pump (not included in the subject device). The fluid inflow channel shares the same with the working channel.

AcuVu has designed a new image processor HTx2000 as an alternative to the existing HTx1000 cleared under K211227 and modified HTx1000 since the clearance under K211227.

Changes made to the subject device compared to the predicate device are as follows:

  • A new image processor, HTx2000, is added to the system as an alternative option to the existing ● HTx1000.
    • Portable O

O

  • an external monitor is optional for display O
    • I HDMI port is available for an optional external monitor (2x DVI for HTx1000)
    • A new power source (Li-ion battery) is available in addition to an AC adapter.
  • Touch screen (no keyboard is needed) O
  • Input interface: to connect the hysteroscope image cable and receive raw signal input, a 38-pin gold O finger design (a 14-pin aviation socket for HTx2000)
  • LAN port is disabled O
  • Software is revised for HTx2000 to incorporate the changes, O
  • Polycarbonate/acrylonitrile, butadiene, styrene (PC/ABS) plastic housing material O
  • Design changes of HTx1000 since K211227 clearance .
    • Magnetic ring: removed O
    • Cable connector: a new connector of the hysteroscope and cable has been redesigned O
    • Power cord: the power cord is changed O
    • Power adapter: a new power adapter has been changed O
    • ISP board: the image signal processor (ISP) board layout has been redesigned O
    • An optional mounting rack is added as a new accessory for attaching the HTx2000 onto a metical o IV pole.
    • Package and device labels are revised O

The HTx2000 is a portable version of the HTx1000 in that it comes with a built-in touch screen, eliminating the necessity of attaching a keyboard and an external monitor as user interface for information entry and display.

The HTx2000 will not supersede the legally marketed HTx1000, but is an alternative option for users. The HTx1000 will continue to be available as a component of the HTx Disposable Hysteroscope System. The following table provides an overview of all key components of the subject device and explains which are

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legacy modules inherited from the predicate device and which are newly developed ones.

ComponentModelManufacturerNotes
Disposable hysteroscopeHTx40AcuVu
HTx60AcuVuInherited from the predicate device
Image processorHTx1000AcuVu
HTx2000AcuVuNew item for submission
Table 1: List of major components of the subject device
---------------------------------------------------------------

Table 2 below gives a comprehensive comparison between the existing HTx1000 and the newly developed HTx2000.

HTx1000HTx2000
AppearanceImage: HTx1000Image: HTx2000
Compatible cannulaHTx40
HTx60HTx40
HTx60
Power supply100-240V AC(1) 100-240V AC
(2) Lithium battery
Peripheral interfaceUSB2.0×3
LAN×1 (disabled)
DVI×2USB2.0×2
LAN×1 (disabled)
HDMI×1
Image displayExternal monitor(1) 13.3" touch screen
(2) External monitor
Main boardModel: E611Model: E661
Operation softwareIPCUterView
Protection against
Electrical shockClass IClass I
Dimension
(L×W×H in mm)365 × 262 × 144324 × 203 × 46
Weight (Kg)5.31.9

Table 2: HTx1000 versus HTx2000 image processor

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The subject device also offers optional accessories, as summarized in Table 3 below.

AccessoryModelManufacturerNotes
KeyboardKSI-U10200GettInherited from the predicate device and works with HTx1000 only.
Patient management softwarePIMCAcuVudevice and works with HTx1000
only.
Barcode scanner14952DeliInherited from the predicate
device and works with both
HTx1000 & HTx2000.
IV pole mounting rackRD1851L20AcuVuUsed to mount the HTx2000
onto a medical IV pole
Table 3: List of accessories of the subject device
------------------------------------------------------

Note:

  • The display (Jusha E240A) previously available as an optional accessory of the predicate device has now a) been removed from the accessory list of the subject device.
  • b) The IV pole mounting rack is a newly developed accessory for mounting the HTx2000 on an IV pole (see the drawings below).

Image /page/7/Picture/7 description: The image shows two different views of a monitor mount. The mount consists of a VESA plate, an arm, and a clamp. The clamp is designed to attach to a pole or other cylindrical object and is tightened with a knob.

Figure 2: The IV pole mounting rack for HTx2000

5. Indications for Use

HTx disposable hysteroscope system is intended to be used for viewing of the cervical canal and uterine cavity for the purpose of performing diagnostic and operative procedures.

Note: Hysteroscopes are used as tools for access to the uterine cavity and are not, in and of themselves a method of surgery.

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6. Comparison of Technological Characteristics

Table below includes functional and technological comparison between the subject device and predicate device.

Table 4: Functional and Technology substantial equivalency comparison
FeatureSubject DevicePredicate DeviceSubject Device Comparison
Suzhou AcuVu Medical Technology
Co. Ltd.
HTx Disposable Hysteroscope SystemSuzhou AcuVu Medical Technology
Co. Ltd.
HTx Disposable Hysteroscope
System (K211227)
ClassificationClass IIClass IISame as the predicate device
Regulation Name21 CFR § 884.169021 CFR § 884.1690Same as the predicate device
Classification PanelObstetrics and GynecologyObstetrics and GynecologySame as the predicate device
Product codeHIHHIHSame as the predicate device
Indications for useHTx disposable hysteroscope system is
intended to be used for viewing of the
cervical canal and uterine cavity for the
purpose of performing diagnostic and
operative procedures.
Note: Hysteroscopes are used as tools
for access to the uterine cavity and are
not, in and of themselves a method of
surgery.HTx disposable hysteroscope system is
intended to be used for viewing of the
cervical canal and uterine cavity for the
purpose of performing diagnostic and
operative procedures.Same as the predicate device
ProceduresViewing of the adult cervical canal and
uterine cavity for the purpose of
performing diagnostic or operative
proceduresViewing of the adult cervical canal and
uterine cavity for the purpose of
performing diagnostic or operative
proceduresSame as the predicate device
Environment of useHospitals and physician's officeHospitals and physician's officeSame as the predicate device
Intended usersTrained Medical ProfessionalsTrained Medical ProfessionalsSame as the predicate device
Disposable/ ReusableCannula is single use;
The image processor and other
modules are reusableCannula is single use;
The image processor and other
modules are reusableSame as the predicate device
SterilizationCannula is provided sterile;
The image processor and other
modules are provided non-sterile.Cannula is provided sterile;
The image processor and other
modules are provided non-sterile.Same as the predicate device
Clinical applicationDiagnostic and operative hysteroscopy.Diagnostic and operative hysteroscopy.Same as the predicate device
Patient contacting materials
(Biocompatibility)ISO 10993 compliantISO 10993 compliantSame as the predicate device
Components:
  • cannula | (1) HTx40 hysteroscope
    (2) HTx60 hysteroscope | (1) HTx40 hysteroscope
    (2) HTx60 hysteroscope | Same as the predicate device |
    | Components:
  • image processor | HTx1000 image processor
    HTx2000 image processor | HTx1000 image processor | Different.
    Subject device offers a second
    image processor HTx2000, but
    the difference does not raise
    different questions of safety and
    effectiveness for the device. |
    | Accessories | HTx1000: a barcode scanner or keyboard
    can be connected through USB interfaces
    HTx2000: a barcode scanner and an IV
    pole mounting rack | HTx1000: a barcode scanner or keyboard
    can be connected through USB interfaces,
    a medical-grade display (Jusha E240A) | Different. |
    | AC power supply | 100-240V AC converted to 12V DC by
    a power adapter | 100-240V AC converted to 12V DC by
    a power adapter | Same as the predicate device |
    | Battery-powered mode | Yes (HTx2000) | No | Different.
    The HTx2000 image processor of
    the subject device can also be
    powered by batteries. The
    difference does not raise different
    questions of safety and
    effectiveness for the device. |
    | Mode of operation | Continuous video | Continuous video | Same as the predicate device |
    | Cannula outer diameter | 4.5mm-6.2mm | 4.5mm-6.2mm | Same as the predicate device |
    | Cannula length | Working length: 240 mm
    Overall length: 330 mm | Working length: 240 mm
    Overall length: 330 mm | Same as the predicate device |
    | Field of view and direction of view | FOV: >115°,
    DOV: 12° (HTx60) and 8° (HTx40) | FOV: >115°,
    DOV: 12° (HTx60) and 8° (HTx40) | Same as the predicate device |
    | Light source | LEDs at cannula tip | LEDs at cannula tip | Same as the predicate device |
    | Image sensor | CMOS sensor 400 x 400 pixels | CMOS sensor 400 x 400 pixels | Same as the predicate device |
    | Image cable connection | (1) Cable with 38-pin gold-finger connector (for HTx2000)
    (2) Cable with 14-pin aviation connector (for HTx1000) | Cable with 14-pin aviation connector (for HTx1000) | Different.
    The HTx2000 image processor
    uses an image cable with 38-pin
    gold-finger connector. This
    difference does not raise different
    questions of safety or effectiveness
    for the device. |
    | Connectivity to customer computer | No (for HTx2000)
    Yes (for HTx1000) | Yes (for HTx1000) | Different.
    The LAN port on HTx2000 image
    processor is currently disabled for
    any connection to external
    computer or network, which
    mitigates cyber security risks when
    compared to HTx1000. |
    | Live video output port | (1) HDMI (for HTx2000)
    (2) DVI (for HTx1000) | DVI | Different.
    The HTx2000 image processor
    uses an HDMI rather than DVI
    port for video output. This
    difference does not raise different
    questions of safety or effectiveness
    for the device. |
    | Built-in touch screen | Yes (for HTx2000) | No | Different.
    The HTx2000 image processor
    has a touch screen for both
    displaying and user input. This
    difference does not raise different
    questions of safety or effectiveness
    for the device. |
    | Adjust brightness of LEDs
    during procedure | By pressing a LED button on the
    cannula | By pressing a LED button on the
    cannula | Same as the predicate device |
    | Capture image or video
    during procedure | By pressing a camera button on the
    cannula | By pressing a camera button on the
    cannula | Same as the predicate device |
    | Shelf life | ≥ 2 years (cannula)
    ≥ 5 years (image processor) | ≥ 2 years (cannula)
    ≥ 5 years (image processor) | Same as the predicate device |
    | Operation software | IPC (for HTx1000): accepts user input
    via panel buttons or keyboard.
    UterView (for HTx2000): accepts user
    input via the touch screen. | IPC (for HTx1000): accepts user input
    via panel buttons or keyboard. | Different.
    The HTx2000 software is more
    suited for touch screen operation
    and is renamed as UterView. This
    difference does not raise different
    questions of safety or effectiveness
    for the device. |

9

10

11

The differences in technological characteristics do not raise different questions of safety and effectiveness.

12

7. Summary of Non-clinical Performance Testing

Non-clinical tests were conducted to verify that the proposed device met all design specifications. No additional testing for HTx40 or HTx60 alone were necessary. However, the hysteroscope's compatibility with the image processors was assessed. The results demonstrated compliance with all design requirement specifications or statutory standards.

  • a) Bench-top test
      1. Color performance for HTx2000 utilizing the HTx40 and HTx 60 hysteroscopes assess the following specifications:
      • Ground truth measurements using a spectrophotometer a)
      • b) Working distance
      • c) color contrast enhancement (CCE)
      1. Basic electric safety (electrical, thermal, mechanical, etc.)

IEC 60601-1:2005+AMD1:2012 Medical Electrical Equipment- Part 1: General requirements for basic safety and essential performance.

    1. Electromagnetic compatibility
      IEC 60601-1-2:2020, Medical electrical equipment- Part 1-2: General requirements for basic safety and essential performance- Collateral standard: Electromagnetic compatibility- Requirements and tests.
    1. Software testing
      The software of the subject device was validated as Basic Documentation Level in accordance with FDA's Guidance for Industry and FDA Staff, "Content of Premarket Submissions for Device Software Functions", issued on June 14, 2023.
    1. Battery safety
      The lithium-ion battery safety was verified in compliance with the applicable requirements of IEC 62133-2:2017/AMD1:2021 and UN38.3.

8. Conclusions

The performance testing summarized above support that the subject device is as safe and effective as the predicate device. Therefore, the subject device is substantially equivalent to the predicate device.