K Number
K232464
Device Name
VereSee Optical Veres Needle System
Date Cleared
2024-05-02

(261 days)

Product Code
Regulation Number
884.1730
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The VereSee Optical Veres Needle System is intended for percutaneous insertion into the peritoneal cavity for the purpose of insufflation with carbon dioxide to establish pneumoperitoneum prior to the placement of trocars during laparoscopic surgery.
Device Description
The VereSee Optical Veres Needle System is comprised two components: 1) Optical Veres Needle, and 2) Camera Control Unit. The Optical Veres Needle consists of a series of three concentric, stainless steel cannulas with a handle and an umbilical cable to connect it to the VereSee Camera Control Unit. The device is provided sterile for single-patient use. The Outer Cannula provides a luer fitting for connection of insufflation tubing with an integral flow control stopcock and a set of seals to prevent leakage of insufflation gas. The Central Cannula consists of a stainless steel hypo tube with a clear, point tip for penetration and visualization during abdomen penetration. The Inner Cannula is composed of a stainless steel hypo tube with a CMOS camera surrounded by light fibers at its tip. The light fibers carry the light from an integral LED which is mounted to a heat sink to distribute heat from the LED. The VereSee Camera Control Unit connects the CMOS camera in the Optical Veres Needle to HDMI compatible monitors to provide an image for laparoscopic procedures. The VereSee Camera Control Unit (CCU) includes an LED driver to power the LED. The CCU connects to the Optical Veres Needle via an umbilical cable. The VereSee Camera Control Unit converts signals from the CMOS camera in the Optical Veres Needle to a format compatible with HDMI display input requirements.
More Information

Not Found

No
The description focuses on the optical and mechanical components of the device and the conversion of camera signals for display. There is no mention of AI/ML for image analysis, decision support, or any other function.

No.
The device is used to establish pneumoperitoneum for surgical access, which supports a procedure but does not directly treat a disease or condition.

No

The device is intended for insufflation and visualization during laparoscopic surgery, not for diagnosing a condition or disease.

No

The device description clearly outlines hardware components including an Optical Veres Needle (cannulas, handle, umbilical cable, CMOS camera, light fibers, LED) and a Camera Control Unit (LED driver, signal converter). The performance studies also include testing on physical and mechanical characteristics, electrical safety, and EMC, which are related to hardware.

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

Here's why:

  • Intended Use: The intended use is for percutaneous insertion into the peritoneal cavity for insufflation and visualization during laparoscopic surgery. This is a surgical procedure performed directly on the patient's body.
  • Device Description: The device is a surgical instrument with an optical component for visualization during the procedure. It does not analyze samples taken from the body (like blood, urine, or tissue) to provide diagnostic information.
  • Lack of IVD Characteristics: IVD devices are designed to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not perform any such analysis.

The device is a surgical tool used for visualization and insufflation during a surgical procedure, not for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The VereSee Optical Veres Needle System is intended for percutaneous insertion into the perioneal cavity for the purpose of insufflation with carbon dioxide to establish pneumoperitoneum prior to the placement of trocars copic surgery.

Product codes (comma separated list FDA assigned to the subject device)

HIF

Device Description

The VereSee Optical Veres Needle System is comprised two components:

    1. Optical Veres Needle, and
    1. Camera Control Unit.

Optical Veres Needle
The Optical Veres Needle consists of a series of three concentric, stainless steel cannulas with a handle and an umbilical cable to connect it to the VereSee Camera Control Unit. The device is provided sterile for single-patient use. Each of the three concentric, stainless steel cannulas is described below:

    1. Outer Cannula (or Insufflation Cannula) provides a luer fitting for connection of insufflation tubing with an integral flow control stopcock and a set of seals to prevent leakage of insufflation gas.
    1. Central Cannula (or Access Cannula) consists of a stainless steel hypo tube with a clear, point tip for penetration and visualization during abdomen penetration.
    1. Inner Cannula (or Camera Cannula) is composed of a stainless steel hypo tube with a CMOS camera surrounded by light fibers at its tip. The light fibers carry the light from an integral LED which is mounted to a heat sink to distribute heat from the LED.

VereSee Camera Control Unit
The VereSee Camera Control Unit connects the CMOS camera in the Optical Veres Needle to HDMI compatible monitors to provide an image for laparoscopic procedures. The VereSee Camera Control Unit (CCU) includes an LED driver to power the LED. The CCU connects to the Optical Veres Needle via an umbilical cable. The VereSee Camera Control Unit converts signals from the CMOS camera in the Optical Veres Needle to a format compatible with HDMI display input requirements.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CMOS camera

Anatomical Site

peritoneal cavity

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Sterilization:
The VereSee Optical Veres Needle is sterilized by ethylene oxide (EO). Sterilization was performed as described in ISO 11135:2014, Sterilization of healthcare products -Ethylene oxide - Requirements for the development, validation, and routine control of a sterilization process for medical devices. The sterilization assurance level (SAL) is 106. Testing of EO residuals was conducted per ISO 10993-7 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals. VereSee Optical Needle devices met the requirements of the standard.

Transit Simulation and Shelf-Life:
Transit simulation and shelf-life testing was conducted for the VereSee Optical Needle to establish the suitability of the packaging to protect the device during simulated transportation, product shelf-life and ability of the packaging to maintain a sterile barrier. Transit simulation testing was conducted per ASTM D4169-22. The final packaging was tested following simulated transportation, including the following: Seal Strength Test (ASTM F88), Visual Inspection (ASTM F1886), and Bubble Leak testing (ASTM F2096). Accelerated aging was conducted per ASTM F1980-21 followed by performance testing and package integrity testing. A shelf-life of 6 months was established based upon accelerated aging testing.

Biocompatibility:
The VereSee Optical Veres Needle has been tested according to ISO 10993-1 recommendations for externally communicating devices with bone/tissue/dentin contact of limited contact duration (

§ 884.1730 Laparoscopic insufflator.

(a)
Identification. A laparoscopic insufflator is a device used to facilitate the use of the laparoscope by filling the peritoneal cavity with gas to distend it.(b)
Classification. (1) Class II (performance standards).(2) Class I for tubing and tubing/filter kits which include accessory instruments that are not used to effect intra-abdominal insufflation (pneumoperitoneum). 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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May 2, 2024

Freyja Healthcare, LLC % Christine Brauer, PhD Regulatory Affairs Consultant Brauer Device Consultants. LLC 7 Trail House Court Rockville, Maryland 20850

Re: K232464

Trade/Device Name: VereSee Optical Veres Needle System Regulation Number: 21 CFR 884.1730 Regulation Name: Laparoscopic Insufflator Regulatory Class: II Product Code: HIF Dated: April 2, 2024 Received: April 3, 2024

Dear Christine Brauer, PhD:

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"

1

(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 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

2

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,

Jason Roberts -S

Jason R. Roberts, PhD 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) K232464

Device Name

VereSee Optical Veres Needle System

Indications for Use (Describe)

The VereSee Optical Veres Needle System is intended for percutaneous insertion into the perioneal cavity for the purpose of insufflation with carbon dioxide to establish pneumoperitoneum prior to the placement of trocars copic surgery.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) SUMMARY VereSee Optical Veres Needle K232464

Applicant Information

| Applicant and
510(k) Owner: | Freyja Healthcare, LLC
488 Pleasant Street
North Andover, Massachusetts 01845 USA |
|--------------------------------|----------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Ronald Adams
Chief Technology Officer
Freyja Healthcare, LLC
Telephone: 775-800-7300
Email: ron@freyjahealthcare.com |

Date of Preparation: 30 April 2024

510(k) Number: K232464

Device and Classification Information

Trade Name:VereSee Optical Veres Needle
Common Name:Veres Needle
Regulation Name:Laparoscopic Insufflator
Regulation Number:21 CFR 884.1730
Product Code:HIF (Insufflator, Laparoscopic)
Class:II

VereSee Optical Veres Needle System is comprised two components:

    1. Optical Veres Needle, and
    1. Camera Control Unit.

Optical Veres Needle

The Optical Veres Needle consists of a series of three concentric, stainless steel cannulas with a handle and an umbilical cable to connect it to the VereSee Camera Control Unit. The device is provided sterile for single-patient use. Each of the three concentric, stainless steel cannulas is described below:

5

    1. Outer Cannula (or Insufflation Cannula) provides a luer fitting for connection of insufflation tubing with an integral flow control stopcock and a set of seals to prevent leakage of insufflation gas.
    1. Central Cannula (or Access Cannula) consists of a stainless steel hypo tube with a clear, point tip for penetration and visualization during abdomen penetration.
    1. Inner Cannula (or Camera Cannula) is composed of a stainless steel hypo tube with a CMOS camera surrounded by light fibers at its tip. The light fibers carry the light from an integral LED which is mounted to a heat sink to distribute heat from the LED.

VereSee Camera Control Unit

The VereSee Camera Control Unit connects the CMOS camera in the Optical Veres Needle to HDMI compatible monitors to provide an image for laparoscopic procedures. The VereSee Camera Control Unit (CCU) includes an LED driver to power the LED. The CCU connects to the Optical Veres Needle via an umbilical cable. The VereSee Camera Control Unit converts signals from the CMOS camera in the Optical Veres Needle to a format compatible with HDMI display input requirements.

Indication for Use

The indication for use for the VereSee Optical Veres Needle System is shown below.

The VereSee Optical Veres Needle System is intended for percutaneous insertion into the peritoneal cavity for the purpose of insufflation with carbon dioxide to establish pneumoperitoneum prior to the placement of trocars during laparoscopic surgerv.

Predicate Device Identification

For purposes of demonstrating substantial equivalence, the following predicate device was selected:

  • LaproLight Veress Needle (by Buffalo Filter, LLC) cleared via K171139 on May 18, ● 2017.

Comparison of the Indication for Use and Intended Use

The LaproLight Veress Needle ("LaproLight") and VereSee Optical Veres Needle System share the same intended use - each device is used to enable closed abdominal entry techniques for laparoscopy. Specifically, each device has a spring-loaded tip that is inserted into the patient's peritoneal cavity to allow for insufflation with carbon dioxide gas, creating a pneumoperitoneum for laparoscopic surgery (see Table 1). Each device has the same indication for use statement except for the tradename, demonstrating the devices have the same intended use.

Table 1. Summary Comparison of the Intended Use and Indication for Use for the Subject Device and Predicate Device

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| Characteristic | VereSee Optical Veres Needle System
(K232464) | LaproLight Veress Needle
(K171139) |
|-----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulation Number
Product Code | 21 CFR 884.1730
HIF | 21 CFR 884.1730
HIF |
| | Laparoscopic Insufflator | Laparoscopic Insufflator |
| Class | II | II |
| Indication for Use | The VereSee Optical Veres Needle
System is intended for percutaneous
insertion into the peritoneal cavity for the
purpose of insufflation with carbon
dioxide to establish pneumoperitoneum
prior to the placement of trocars during
laparoscopic surgery. | The LaproLight is intended for
percutaneous insertion into the
peritoneal cavity for the purpose of
insufflation with carbon dioxide to
establish pneumoperitoneum prior to the
placement of trocars during laparoscopic
surgery. |
| Intended Use | Facilitate entry of laparoscope using a
closed (veres needle) technique | Facilitate entry of laparoscope using a
closed (veres needle) technique |
| Conditions of Use | Rx Only; Single Use Only | Rx Only; Single Use Only |
| Purpose | To establish pneumoperitoneum prior to
placement of trocars during a
laparoscopic procedure | To establish pneumoperitoneum prior to
placement of trocars during a
laparoscopic procedure |
| Functions | To puncture peritoneum wall
To allow for the flow of liquid or gas
through the needle
To insufflate the peritoneal cavity with
carbon dioxide
To provide visualization during veres
needle entry | To puncture peritoneum wall
To allow for the flow of liquid or gas
through the needle
To insufflate the peritoneal cavity with
carbon dioxide |

As shown in the table above, the subject device includes the function of visualization using a camera during veres needle entry. This difference does not raise different questions of safety and effectiveness.

Comparison of the Technological Characteristics

The VereSee Optical Veres Needle System and the LaproLight share many similar technological characteristics. Both devices utilize a spring loaded obturator mechanism to provide the user with haptic feedback when entering the body. Both include a luer fitting connection for either a syringe to perform a saline flow test and/or insufflation tubing for gas delivery. For both devices, the stop cock is downstream of luer connection to control the flow of liquid or gas through the cannula with variable positions between ON and OFF. Both veres needles include a visualization element although for different purposes (see Table 2). The VereSee Optical Veres Needle System includes an optical obturator tip designed to enable visualization during body cavity entry whereas the LaproLight includes an LED, which turns on when the healthcare provider has punctured into the peritoneal cavity.

Comparison of the Technological Similarities and Differences Between Table 2. the Subject Device and the Predicate Device

| Technological Characteristic | VereSee Optical Veres Needle System | LaproLight Veress Needle
(K171139) |
|------------------------------|-------------------------------------------------------------------|-------------------------------------------------------------------|
| Needle Design | Spring loaded stylet mechanism which
provides haptic feedback. | Spring loaded stylet mechanism which
provides haptic feedback. |

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| Technological Characteristic | VereSee Optical Veres Needle System | LaproLight Veress Needle
(K171139) |
|------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Outer Cannula | Beveled needle point for cutting through abdominal wall tissue | Beveled needle point for cutting through abdominal wall tissue |
| Inner Cannula | Spring loaded inner stylet | Spring loaded inner stylet |
| Needle Length | 127 mm | 120 mm
150 mm |
| Outer Diameter (tip) | 2.4 mm | 2 mm |
| Material | Stainless steel | Stainless steel |
| Sterility | Single use sterile | Single use sterile |
| Seal System | Integrated two component seal system to
maintain pneumoperitoneum. A dome
seal to seal when camera or visualization
camera are not in use and a self-
adjusting back-up seal when they are in
use. | Standard veres needle seal system |
| Stopcocks | An integral stopcock assembly with a
standard luer lock fitting which provides
for attachment of insufflation tubing or
syringe for saline flow test. | An integral stopcock assembly with a
standard luer lock fitting which provides for
attachment of insufflation tubing or syringe
for saline flow test. |
| Visualization | CMOS camera chip to provide
visualization during entry | LED to indicate peritoneal cavity entry |

As shown in the table above, there are differences between the subject and predicate devices. The subject device is available in one needle length rather than two for the predicate device. The outer diameter (tip) of the subject device is different (larger) than the predicate device. The subject device has a different seal system than the predicate device. The subject device has a different mode of visualization than the predicate device. None of these technological differences raise different questions of safety and effectiveness.

Performance Data

The following is a summary of the performance data to establish the substantial equivalence of the VereSee Optical Veres Needle System to the predicate device.

Sterilization:

The VereSee Optical Veres Needle is sterilized by ethylene oxide (EO). Sterilization was performed as described in ISO 11135:2014, Sterilization of healthcare products -Ethylene oxide - Requirements for the development, validation, and routine control of a sterilization process for medical devices. The sterilization assurance level (SAL) is 106.

Testing of EO residuals was conducted per ISO 10993-7 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals. VereSee Optical Needle devices met the requirements of the standard.

Transit Simulation and Shelf-Life:

8

Transit simulation and shelf-life testing was conducted for the VereSee Optical Needle to establish the suitability of the packaging to protect the device during simulated transportation, product shelf-life and ability of the packaging to maintain a sterile barrier.

Transit simulation testing was conducted per ASTM D4169-22. The final packaging was tested following simulated transportation, including the following: Seal Strength Test (ASTM F88), Visual Inspection (ASTM F1886), and Bubble Leak testing (ASTM F2096).

Accelerated aging was conducted per ASTM F1980-21 followed by performance testing and package integrity testing. A shelf-life of 6 months was established based upon accelerated aging testing.

Biocompatibility:

The VereSee Optical Veres Needle has been tested according to ISO 10993-1 recommendations for externally communicating devices with bone/tissue/dentin contact of limited contact duration ( Optical performance, including ISO 8600-3 through ISO 8600-5

  • Physical characteristics (such as weight and maximum handle temperature)

  • Mechanical testing (flow and leakage testing, spring obturator testing and needle penetration tip force testing) to evaluate key performance requirements

  • Mechanical testing (destructive) to evaluate the physical strength of the bonds between components

The mechanical testing included comparative testing to legally marketed veres needles for flow and leakage testing, needle spring obturator testing and needle penetration tip force testing. The Veres Optical Veres Needle System had comparable performance to the legally marketed veres needles.

Conclusion

The VereSee Optical Veres Needle Optical System is substantially equivalent to the predicate device.