(90 days)
The hekaDrill system is intended for use in surgical procedures involving incision / cutting, removal, drilling and sawing of soft and hard tissue, bone and biomaterials. The system is specifically intended for use in Neurosurgical (Cranial including craniotomy); Ear, Nose and Throat (ENT), Maxillofacial, Orthopedic, Arthroscopic, Spinal, Stemotomy, and General Surgical Procedures.
The hekaDrill System consists of electric and pneumatic drill handpieces, a power console, footswitches, attachments, connection cables, irrigation tube kits, cutting tools, and system accessories. The handpieces, attachments, and system accessories are provided non-sterile and are reusable. The console and footswitches are reusable and are not intended to be sterilised. The cutting tools and irrigation tube kits are provided sterile and are single use.
The hekaDrill device primarily consists of various components for surgical procedures involving cutting, drilling, and sawing of soft and hard tissues. The performance assessment focused on comparing the device's cutting performance, electrical safety, electromagnetic compatibility, and biocompatibility with predicate devices and relevant standards.
Here's a breakdown of the acceptance criteria and study information:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria Category | Specific Acceptance Criteria / Standard Met | Reported Device Performance |
|---|---|---|
| General Performance | Equivalent or better cutting performance compared to predicate drill system (vibration, noise, control, and performance) | Cutting performance was equivalent or better to that of the predicate device. |
| Electrical Performance | Electrical safety according to IEC 60601-1:2005 | Instruments conform to IEC 60601-1:2005 for electrical safety. |
| Electromagnetic compatibility according to IEC 60601-1-2:2014 | Instruments conform to IEC 60601-1-2:2014 for electromagnetic compatibility. | |
| Biocompatibility | Non-cytotoxic (L929 MEM Elution) | No biological reactivity (Grade 0) of cells exposed to test article extract. |
| Non-sensitizer (Kligman Maximization) | Test article extracts elicited no reaction at challenge (0% sensitization). | |
| Non-irritant (Intracutaneous Injection) | Test article sites did not show a significantly greater biological reaction than the control article. | |
| Non-toxic (Systemic Toxicity) | Test article did not induce a significantly greater biological reaction than the control extracts. | |
| Non-pyrogenic (Pyrogenicity) | Test article did not induce a pyrogenic response. | |
| Non-hemolytic (Indirect Hemolysis) | Test article led to a hemolysis index above the negative control of 0.14%. |
2. Sample Size Used for the Test Set and Data Provenance:
The document does not explicitly state the specific sample sizes for each performance test (e.g., number of cutting trials, number of biological samples). It also does not specify the country of origin for the data or whether the studies were retrospective or prospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
The document does not mention the use of experts to establish a "ground truth" in the traditional sense for the performance tests described. The assessment relied on objective measurements and comparisons against established standards and predicate device performance. For the biocompatibility tests, the "ground truth" is determined by the specific reaction observed (e.g., cytotoxicity, sensitization), not expert consensus on an image or diagnosis.
4. Adjudication Method for the Test Set:
Not applicable in this context. The performance tests involve objective measurements and comparisons to standards, not subjective interpretations requiring adjudication among experts.
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:
Not applicable. The hekaDrill is a surgical drill system, not an AI-powered diagnostic or assistive device that would involve human readers or image interpretation.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable, as this is a physical medical device, not a software algorithm.
7. The Type of Ground Truth Used:
For the performance tests:
- General Performance: The "ground truth" was established by comparing direct measurements of performance characteristics (vibration, noise, control, cutting effectiveness) against those same characteristics of a predicate device.
- Electrical Performance: The "ground truth" was the adherence to established international safety standards (IEC 60601-1:2005 and IEC 60601-1-2:2014).
- Biocompatibility: The "ground truth" was dictated by the specific biological responses observed in standardized tests, such as the absence of biological reactivity in cytotoxicity assays or no significant reaction in sensitization tests.
8. The Sample Size for the Training Set:
Not applicable. This is a physical medical device. The concept of a "training set" is typically associated with machine learning or artificial intelligence models.
9. How the Ground Truth for the Training Set Was Established:
Not applicable, as there is no training set for this type of device.
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March 14, 2024
Zethon Ltd Faith Robertson Senior Quality and Regulatory Officer 2 Halton Brook Business Park Aston Clinton, Buckinghamshire HP22 5WF United Kingdom
Re: K233958
Trade/Device Name: hekaDrill Regulation Number: 21 CFR 874.4250 Regulation Name: Ear, Nose, And Throat Electric Or Pneumatic Surgical Drill Regulatory Class: Class II Product Code: ERL, HBC, HBB, HBE, HSZ, GEY Dated: November 8, 2023 Received: December 15, 2023
Dear Faith Robertson:
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" (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).
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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 QS 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 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,
Joyce C. Lin -S
for Shu-Chen Peng, Ph.D. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Indications for Use
| Indications for Use | See PRA Statement below. | ||
|---|---|---|---|
| Submission Number (if known) | K233958 | ||
| Device Name | hekaDrill | ||
| Indications for Use (Describe) | The hekaDrill system is intended for use in surgical procedures involving incision / cutting, removal, drilling and sawing of soft and hard tissue, bone and biomaterials. The system is specifically intended for use in Neurosurgical (Cranial including craniotomy); Ear, Nose and Throat (ENT), Maxillofacial, Orthopedic, Arthroscopic, Spinal, Stemotomy, and General Surgical Procedures. | ||
| 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) | Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
| Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
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510(k) Summary
22nd February 2024
- I. Company: Zethon Ltd 2 Halton Brook Business Park Weston Road Aston Clinton Buckinghamshire HP22 5WF United Kingdom
- Contact: Faith Robertson Senior Quality and Regulatory Officer Telephone Number: (+44) 01296634090 Email: faith.robertson@zethon.com
- II. Proprietary Trade Name: hekaDrill
- III. Common Name: High Speed System
- IV. Classification Name: Drill, Surgical, ENT (Electric or Pneumatic) including Handpiece (21 CFR 874.4250) Motor, Drill, Electric (21 CFR 882.4360) Motor, Drill, Pneumatic (21 CFR 882.4370) Motor, Surgical Instrument, AC-Powered (21 CFR 878.4820) Drills, Burs, Trephines & Accessories (21 CFR 882.4310)
- V. Classification: Class II
- VI. Product Code: ERL, HBC, HBB, HBE, HSZ, GEY
VII. Product Description:
The hekaDrill System consists of electric and pneumatic drill handpieces, a power console, footswitches, attachments, connection cables, irrigation tube kits, cutting tools, and system accessories. The handpieces, attachments, and system accessories are provided non-sterile and are reusable. The console and footswitches are reusable and are not intended to be sterilised. The cutting tools and irrigation tube kits are provided sterile and are single use.
VIII. Indications for Use:
The hekaDrill system is intended for use in surgical procedures involving incision / cutting, removal, drilling, and sawing of soft and hard tissue, bone and biomaterials. The system is specifically intended for use in Neurosurgical (Cranial including craniotomy); Ear, Nose and Throat (ENT), Maxillofacial, Orthopedic, Arthroscopic, Spinal, Sternotomy, and General Surgical Procedures.
IX. Identification of Legally Marketed Devices (Primary Predicate Device)
- Skeeter Ultra-Lite Oto-Tool Drill (Accessory of K041523) ●
- X. Identification of Legally Marketed Devices (Secondary Predicate Devices)
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XI. Comparison of the Technological Characteristics
The primary predicate (Skeeter Ultra-Lite Oto-Tool Drill system) consists of a dedicated electric handpiece, consoles, footpedals and a range of cutting accessories. The primary predicate device is similar to the system under review in that electric energy is used to supply power to the handpiece which then operates interchangeable cutting tools. Both systems have ENT specific indications for use.
In addition, the secondary predicate devices (Midas Rex Drill Systems) are currently available on the market consisting of both pneumatic and electric handpieces, consoles, footpedals, attachments, cutting tools and system accessories. The secondary predicate devices are similar to the system under review in that air or electric energy is used to supply power to the handpiece which then operates interchangeable cutting tools that are supported by interchangeable attachments. Both systems have the same indications for use and both use similar materials.
In summary, a full comparison between the predicate devices and the hekaDrill system demonstrated that any of the differences between the devices do not have an impact on safety and effectiveness or its ability to perform its intended use.
XII. Discussion of the Performance Testing
The following testing has been performed on the hekaDrill system in order to demonstrate the functionality of the device. A summary of this testing is as follows:
| Test performed | Description of testing | Conclusion |
|---|---|---|
| General Performance | ||
| PerformanceValidation | Cutting performance was compared topredicate drill system in terms ofvibration, noise, control andperformance. | Cutting performance was equivalent orbetter to that of predicate device |
| Electrical Performance | ||
| Electrical Safety | Electric powered instruments evaluatedfor electrical safety | Instruments conform to IEC 60601-1:2005 for electrical safety. |
| ElectromagneticCompatibility | Electric powered instruments evaluatedfor electromagnetic compatibility | Instruments conform to IEC 60601-1-2:2014 for electromagneticcompatibility. |
| Biocompatibility | ||
| Cytotoxicity – L929MEM Elution | There was no biological reactivity(Grade 0) of the cells exposed to the testarticle extract. | Non-cytotoxic |
| Sensitization –KligmanMaximization | The extracts of the test article, elicitedno reaction at the challenge (0%sensitization) | Non-sensitizer |
| Irritation –IntracutaneousInjection | The test article sites did not show asignificantly greater biological reactionthan the control article. | Non-irritant |
| Systemic Toxicity | The test article did not induce asignificantly greater biological reactionthan the control extracts. | Non-toxic |
| Pyrogenicity | The test article did not induce aPyrogenic response. | Non-pyrogenic |
| Indirect Hemolysis | The test article led to a hemolysis indexabove the negative control of 0.14%. | Non-hemolytic |
XIII. Conclusions
The hekaDrill system is substantially equivalent to the predicate devices, as shown through comparisons and testing.
§ 874.4250 Ear, nose, and throat electric or pneumatic surgical drill.
(a)
Identification. An ear, nose, and throat electric or pneumatic surgical drill is a rotating drilling device, including the handpiece, that is intended to drive various accessories, such as an ear, nose, and throat bur (§ 874.4140), for the controlled incision or removal of bone in the ear, nose, and throat area.(b)
Classification. Class II.