(92 days)
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System is indicated for the gas enhanced ablation of soft tissue using helium-based plasma.
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System produces a Helium-based cold plasma spray to deliver high frequency low energy current intended for the ablation of soft tissues.
The Canady Helios Cold Plasma™ XL-1000CP Ablation System includes the following items:
- Canady Helios Cold Plasma™ XL-1000CP SMART Electrosurgical Generator
- Canady Helios™ Cold Plasma Ablators
- Foot Pedal
- Trolley Cart
The Canady Helios Cold Plasma™ XL-1000CP™ SMART Electrosurgical Generator is a transportable nonsterile electrical device compatible for use in the operating room environment. The Canady Helios Cold Plasma™ XL-1000CP SMART Electrosurgical Generator creates high frequency, short duration energy pulses with regulated Helium gas, which is delivered to the target tissue via the Canady Helios™ Cold Plasma Ablators. The Canady Helios™ Cold Plasma Ablators are sterile monopolar electrosurgical instruments intended for single use.
This document, K240297, is a 510(k) Premarket Notification for the Canady Helios Cold Plasma™ XL-1000CP™ Ablation System. It demonstrates substantial equivalence to a predicate device, not an AI/ML powered device. Therefore, the information requested about acceptance criteria, study details, ground truth establishment, sample sizes, and expert adjudication as pertains to AI/ML device performance is not applicable to this submission.
The document focuses on the safety and effectiveness of the electrosurgical ablation system itself, comparing it to an existing predicate device based on its intended use, technological characteristics, and performance testing against recognized standards.
Here's a breakdown of what is available in the document regarding the device's performance and acceptance, interpreted in a general sense rather than specifically for AI/ML:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't provide specific numerical acceptance criteria for performance; rather, it lists various tests conducted and generally states that the device "Met criteria." This is common for non-AI medical devices where performance is typically validated against engineering specifications and applicable standards, rather than statistical thresholds for diagnostic accuracy.
| Test Category | Reported Device Performance |
|---|---|
| Electrical Safety Testing | Met criteria |
| High Frequency Testing | Met criteria |
| Electromagnetic Compatibility Testing | Met criteria |
| Electromechanical Safety Testing | Met criteria |
| Package Integrity | Met criteria |
| Shelf Life | Met criteria |
| Sterilization | Met criteria |
| Software and System Verification / Validation | Met criteria |
| Cybersecurity | Met criteria |
| Biological Safety | Met criteria |
| Ablation Effectiveness | Met criteria |
| Thermal Effect | Met criteria |
The document also notes in the Substantial Equivalence table:
- Performance: "Shown to ablate soft tissue at specified parameters." (For both subject and predicate device).
2. Sample Size Used for the Test Set and Data Provenance:
This information is not applicable as the document describes a traditional medical device (electrosurgical ablation system) and its performance validation, not an AI/ML-powered device requiring a test set for algorithmic performance evaluation. The "tests" mentioned are likely bench testing, in-vitro experiments, or potentially animal studies (though not specified), designed to verify physical and electrical properties, sterility, and basic function. Data provenance as typically understood for AI (e.g., country of origin of patient data, retrospective/prospective) is irrelevant here.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
Not applicable. There is no "ground truth" in the AI/ML sense (e.g., clinical labels for images) established by experts for this type of device. Performance is assessed against engineering specifications, safety standards, and the ability to perform its stated function (ablation).
4. Adjudication Method for the Test Set:
Not applicable. No adjudication methods are described as there is no human interpretation of data for algorithmic ground truth establishment.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
Not applicable. This type of study is relevant for AI/ML diagnostic or assistive technologies where human reader performance is a key metric. This is a therapeutic electrosurgical device.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
Not applicable. As this is not an AI/ML device, the concept of a standalone algorithm performance test is not relevant.
7. Type of Ground Truth Used:
Not applicable in the AI/ML sense. For this device, "ground truth" refers to established engineering principles, safety standards (e.g., electrical safety, electromagnetic compatibility), and the physical outcome of the ablation process (e.g., tissue ablation effectiveness, thermal effect), verified through laboratory testing against specifications.
8. Sample Size for the Training Set:
Not applicable. There is no "training set" as this is not an AI/ML device that learns from data.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. Similar to point 8, there is no training set or associated ground truth for this type of medical device submission.
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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: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square and the words "U.S. Food & Drug Administration".
May 3, 2024
US Medical Innovations, LLC % Audrey Swearingen Sr. Regulatory Consultant Emergo Global Consulting, LLC 2500 Bee Cave Road Building 1, Suite 300 Austin, Texas 78746
Re: K240297
Trade/Device Name: Canady Helios Cold Plasma™ XL-1000CP™ Ablation System (XL-1000CPSYS) Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: GEI Dated: February 1, 2024 Received: February 1, 2024
Dear Audrey Swearingen:
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 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.
Digitally signed by Mark Mark Trumbore -S Trumbore -S Date: 2024.05.03 11:01:07 -04'00
Mark Trumbore, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices
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Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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K240297
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Submission Number (if known)
Device Name
Canady Helios Cold Plasma™ XL-1000CP™ Ablation System (XL-1000CPSYS)
Indications for Use (Describe)
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System is indicated for the gas enhanced ablation of soft tissue using helium-based plasma.
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 Canady Helios Cold Plasma™ XL-1000CP™ Ablation System
The following information is provided in accordance with 21 CFR 807.92.
Submission Sponsor:
US Medical Innovations LLC 6930 Carroll Avenue, Suite 1000 Takoma Park, MD 20912 Contact: Jerome Canady, MD., FACS Title: CEO Phone: (301) 270-0147
Submission Correspondent:
Emergo by UL 2500 Bee Cave Road, Building 1, Suite 300 Austin, TX 78746 Contact: Ms. Audrey Swearingen Senior Regulatory Consultant Title: Phone: (512) 327-9997 LST.AUS.ProjectManagement@ul.com Email:
Date: April 18, 2024
Device Identification:
| Trade or Proprietary Name: | Canady Helios Cold Plasma™ XL-1000CP™ Ablation System (XL-1000CPSYS |
|---|---|
| Common or Usual Name: | Surgical ablation system |
| Regulation Number: | 21 CFR 878.4400 |
| Regulation Name: | Electrosurgical cutting and coagulation device and accessories |
| Product Code: | GEI |
| Device Class: | II |
| Panel: | General & Plastic Surgery |
Legally Marketed Predicate Device:
| Trade Name: | Canady Plasma SMART XL-1000 Electrosurgical Generator with Accessories |
|---|---|
| 510(k) Number: | K192124 |
| Manufacturer: | US Medical Innovations LLC |
| Regulation Number: | 21 CFR 878.4400 |
| Regulation Name: | Electrosurgical cutting and coagulation device and accessories |
| Product Code: | GEI |
Intended Use/Indications for Use:
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System is indicated for the gas enhanced ablation of soft tissue using helium-based plasma.
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Device Description:
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System produces a Helium-based cold plasma spray to deliver high frequency low energy current intended for the ablation of soft tissues.
The Canady Helios Cold Plasma™ XL-1000CP Ablation System includes the following items:
- Canady Helios Cold Plasma™ XL-1000CP SMART Electrosurgical Generator
- Canady Helios™ Cold Plasma Ablators
- Foot Pedal
- Trolley Cart
The Canady Helios Cold Plasma™ XL-1000CP™ SMART Electrosurgical Generator is a transportable nonsterile electrical device compatible for use in the operating room environment. The Canady Helios Cold Plasma™ XL-1000CP SMART Electrosurgical Generator creates high frequency, short duration energy pulses with regulated Helium gas, which is delivered to the target tissue via the Canady Helios™ Cold Plasma Ablators. The Canady Helios™ Cold Plasma Ablators are sterile monopolar electrosurgical instruments intended for single use.
Substantial Equivalence:
The following table compares the proposed Canady Helios Cold Plasma™ XL-1000CP™ Ablation System to the Canady Plasma SMART XL-1000 Electrosurgical Generator with Accessories predicate device, with respect to intended use and technological characteristics.
| Trade Name | Canady Helios Cold Plasma™ XL-1000CP™ SMART AblationSystem | Canady Plasma SMART XL-1000Electrosurgical Generator withAccessories System (K192124) | Significant Difference |
|---|---|---|---|
| Manufacturer | US Medical Innovations, LLC | US Medical Innovations, LLC | N/A |
| Product code(s)/Regulation No. | GEI /878.4400 | GEI /878.4400 | Both are under thesame regulation |
| Intended Use | Gas enhanced ablation of softtissue. | Gas enhanced ablation of softtissue. | None |
| Indications for Use | The Canady Helios Cold Plasma™XL-1000CP™ SMART AblationSystem is indicated for gasenhanced ablation of soft tissueusing helium based plasma. | The Canady Plasma® SMART XL-1000™ Electrosurgical Generatorwith Accessories is intended toprovide gas-enhancedcoagulation during generalsurgery procedures. The CanadyPlasma® SMART XL-1000™Electrosurgical Generator withAccessories is designed for gasenhanced coagulation whenused only with the CanadyPlasma Electrosurgery Unit andcompatible monopolar and/orbipolar handpieces.The Canady Electrosurgery UnitGenerators are intended to cutand/or coagulate tissue whenused with compatiblemonopolar and/or bipolar RF | The XL-1000CP uses asubset of theIndications for usedefined for thepredicate device. |
| System Components | • Canady Helios Cold Plasma™XL-1000CP™ SMARTElectrosurgical Generator• Canady Helios™ Cold PlasmaAblators• Footswitch• Power Supply Cord• XL-1000/XL-1000CP TrolleyCart | handpieces. The CanadyElectrosurgery Unit Generatorsare capable of monopolarargon gas enhancedcoagulation when used withCanady Plasma Coagulator andprobes.• Canady Plasma® SMART XL-1000™ ElectrosurgicalGenerator• Canady Plasma Hybrid Scalpel(K113500)• Canady Plasma Probes forFlexible Endoscopy(K100669)• Footswitch• Power Supply Cord• XL-1000/XL-1000CP TrolleyCart | Same. The subjectAblators are identicalto the predicate'shandpieces. |
| Generator Type | High Frequency | High Frequency | None |
| Inert Gas Type | Helium | Argon | The XL-1000CP usesthe inert gas Heliuminstead of Argon. |
| Frequency | 390 kHz | 390 kHz | None |
| Peak to Peak Voltage | 4kV (1000 Ω) | 4kV (1000 Ω) | None |
| Main CPU Type | FPGA | FPGA | None |
| Display Type | LED with backlight | LED with backlight | None |
| Monopolar | Yes, insulated | Yes, insulated | None |
| Bipolar | No | Yes | The XL-1000CPgenerator onlysupports monopolarablation. |
| Monopolar Modes | Canady Helios Cold PlasmaAblation Mode (equivalent toFulgurate High on the XL-1000) | Argon Plasma - Cut (Pure, BlendI,II,III, Pure High Cut, Blend HighCut I,II), E-Cut, Argon Plasma(Spray, Fulgurate High,Fulgurate Low, Desiccate I,II,III) | Cold Plasma ablationmode is the same asthe Argon PlasmaFulgurate High modeof the XL-1000. |
| Gas Flow Rate | 0.0 - 5.0 L/min | 0.0 - 5.0 L/min | None |
| Power Setting Shown | Yes | Yes | None |
| Cooling Type | Convection | Convection | None |
| Input Voltage, VAC | 100 – 240 | 100 - 240 | None |
| Performance | Shown to ablate soft tissue atspecified parameters. | Shown to ablate soft tissue atspecified parameters. | Both perform asintended to ablatesoft tissue. |
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Performance Testing:
The following tests were conducted to confirm that the Canady Helios Cold Plasma™ XL-1000CP™ Ablation System meets specifications and that it performs equivalently to the predicate Canady Plasma SMART XL-1000 Electrosurgical Generator with Accessories.
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| Electrical Safety Testing | Met criteria |
|---|---|
| High Frequency Testing | Met criteria |
| Electromagnetic Compatibility Testing | Met criteria |
| Electromechanical Safety Testing | Met criteria |
| Package Integrity | Met criteria |
| Shelf Life | Met criteria |
| Sterilization | Met criteria |
| Software and System Verification / Validation | Met criteria |
| Cybersecurity | Met criteria |
| Biological Safety | Met criteria |
| Ablation Effectiveness | Met criteria |
| Thermal Effect | Met criteria |
The device complies with the following applicable test standards:
| ANSI/AAMI/ISO 11135:2014/AMD 2018 | Sterilization of health-care products — Ethylene oxide — Requirements for thedevelopment, validation and routine control of a sterilization process for medicaldevices |
|---|---|
| ANSI/AAMI/ISO 11737-1:2018 | Sterilization of health care products — Microbiological methods — Part 1:Determination of a population of microorganisms on products |
| ANSI/AAMI/ISO 11737-22019 | Sterilization of medical devices — Microbiological methods — Part 2: Tests ofsterility performed in the definition, validation and maintenance of a sterilizationprocess |
| AAMI/ANSI ES 60601-1:2005/2012 | Medical Electrical Equipment - Part 1 General Requirements for Basic Safety andEssential Performance |
| IEC 60601-1-2:2020 | Medical Electrical Equipment - Part 1-2: General Requirements for Basic Satety andEssential Performance - Collateral Standard: Electromagnetic Compatibility -Requirements and Tests |
| IEC 60601-2-2:2017Edition 6.0 | Medical electrical equipment - Part 2-2: Particular requirements for the basic safetyand essential performance of high frequency surgical equipment and high frequencysurgical accessories |
| IEC 60601-1-6:2010+AMD1:2013 | Medical electrical equipment - Part 1-6: General requirements for basic safety andessential performance - Collateral standard: Usability |
| IEC 62304 Ed 1.1 2015-06,Consol. version | Medical device software - Software life cycle processes |
Conclusion:
The Canady Helios Cold Plasma™ XL-1000CP™ Ablation System has the same intended use and the same or similar technological characteristics as the predicate device. Testing to recognized consensus standards and internal performance testing has demonstrated the device is as safe and effective for requested intended use, as the predicate device. The minor technological differences compared to the predicate do not raise different types of questions of safety and effectiveness. Therefore, the Canady Helios Cold Plasma™ XL-1000CP™ Ablation System is substantially equivalent to the predicate device.
§ 878.4400 Electrosurgical cutting and coagulation device and accessories.
(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.