AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

IntelliBlate Microwave Ablation System:

The IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue. The IntelliBlate Microwave Ablation System is not intended for use in cardiac procedures.

IntelliBlate Ximitry Probe Assembly:

The IntelliBlate Ximitry Probe Assembly, used with the IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue.

The IntelliBlate Ximitry Probe Assembly is not intended for use in cardiac procedures.

Device Description

The IntelliBlate Microwave Ablation System is a software-controlled microwave therapy delivery system with graphical user interface and hardware to control and monitor the therapy delivered to the target tissues.

The system consists of a 2.45 GHz microwave generator (console) with an integrated peristaltic pump assembly for coolant fluid delivery, a coolant Fluid Mount and an optional mobile cart for the console. Accessories for the system include IntelliBlate Ximitry Probe Assembly - a sterile, single-use disposable microwave ablation assembly with ablation probes and a cassette for coolant fluid tubing (closed cooling circuit).

AI/ML Overview

The provided text does not contain detailed acceptance criteria for the IntelliBlate Microwave Ablation System that would typically be found in a clinical study report or a more extensive submission. The document primarily focuses on demonstrating substantial equivalence to predicate devices through technical comparisons and non-clinical testing summaries.

However, based on the information provided, we can infer some general acceptance criteria related to safety and performance, and describe the studies conducted as reported in the "Performance Data" section.

Here's an attempt to structure the information based on the provided text, acknowledging the limitations in detail for many of the requested points:

Implicit Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Inferred from Performance Data)Reported Device Performance (as stated in the document)
Functional Design and Performance: Device meets established design criteria.The subject devices successfully completed functional testing.
Ablation Performance in Ex-vivo Tissues: Ablation performance is substantially equivalent to predicate devices in various tissues.Ex-vivo testing of the devices at single, double, and track ablation settings in porcine liver, kidney, and muscle demonstrated that the differences in design and system characteristics do not affect the ablation performance of the subject device in comparison to the predicate device.
Usability and Performance (Acute Animal Model): Devices are usable and perform as expected in living tissue models.Acute GLP studies validated usability and performance of the devices on porcine soft tissue models.
Reliability: Device maintains consistent operation over time.The subject devices successfully completed reliability testing.
Electrical Safety: Device complies with relevant electrical safety standards.The IntelliBlate Microwave Ablation System and its accessories comply with applicable IEC 60601 series of standards: IEC 60601-1, IEC 60601-1-6, IEC 60601-2-6, and IEC 60601-1-2.
Electromagnetic Compatibility: Device complies with relevant electromagnetic compatibility standards.The IntelliBlate Microwave Ablation System and its accessories comply with applicable IEC 60601 series of standards: IEC 60601-1, IEC 60601-1-6, IEC 60601-2-6, and IEC 60601-1-2.
Sterility: Ximitry Probe Assembly achieves a minimum sterility assurance level of 10^-6.Ximitry Probe Assembly is sterilized utilizing 100% ethylene oxide gas to ensure a minimum sterility assurance level of 10^-6 in accordance with ISO 11135, ISO 10993-7, ISO 11138-1, ISO 11737-1, and ISO 11737-2.
Software Verification: Software functions are verified according to medical device software standards and FDA guidance.Software verification was conducted in accordance with IEC 62304 and FDA guidance "Content of Premarket Submissions for Device Software Functions."
Cybersecurity: Cybersecurity requirements are assessed and addressed per FDA guidance.Cybersecurity requirements were assessed per FDA guidance's "Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions, Postmarket Management of Cybersecurity in Medical Devices."
Thermal Effects and Temperature Monitoring: Thermal performance is substantially equivalent to predicate devices and monitoring is effective.Comparison of thermal effects between IntelliBlate Microwave Ablation System and its predicate demonstrated that the performance of the subject device is substantially equivalent to the predicate device. Thermal effects and temperature monitoring testing were completed in accordance with FDA Guidance.
Biocompatibility: Patient-contacting components are biocompatible.Biocompatibility testing of the Ximitry Probe Assembly in accordance with ISO 10993-1 demonstrated that the patient-contacting components are biocompatible.
Packaging Integrity and Shelf Life: Packaging maintains integrity and device remains viable for its intended shelf life.Packaging integrity and shelf-life testing was performed in accordance with ISO 11607-1 and ISO 11607-2.

Here's a breakdown of the other requested information based on the provided text. Please note that many of these details are not explicitly stated in the summary document.

2. Sample size used for the test set and the data provenance:

  • Test set sample size: Not explicitly stated for specific non-clinical tests. For the ex-vivo ablation performance study, it mentions testing in "porcine liver, kidney and muscle," but no specific numbers of samples or experimental runs are provided.
  • Data provenance:
    • Ex-vivo ablation performance: Porcine tissues. Origin of the pigs not specified.
    • Acute animal testing: Porcine soft tissue models. Conducted in accordance with GLP Regulations (21 CFR Part 58) in the United States.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

  • This information is not provided in the document. The studies mentioned (ex-vivo, animal GLP) would likely involve trained personnel or researchers, but their specific qualifications or role in establishing "ground truth" (e.g., assessing ablation zones) are not described. The document primarily focuses on engineering and animal model performance rather than human expert interpretation of results.

4. Adjudication method for the test set:

  • This information is not provided in the document. Given the nature of the non-clinical and animal studies described, a formal adjudication method (like 2+1 or 3+1 often used for diagnostic AI) is very unlikely to have been applied. The evaluation would be based on direct measurements and observations by the researchers.

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:

  • No, an MRMC comparative effectiveness study was not done. The IntelliBlate Microwave Ablation System is a hardware-based therapeutic device, not an AI diagnostic or assistance tool for human readers. Therefore, this type of study is irrelevant to this device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

  • This device is a physical system for microwave ablation. The "software" mentioned in the document is for controlling the device's functions and user interface, not for standalone diagnostic or interpretive performance. Therefore, the concept of "standalone (algorithm only)" as it applies to AI diagnostics is not applicable here. The device's performance is inherently "standalone" in its therapeutic action, but this is not an algorithm acting independently of human control.

7. The type of ground truth used:

  • For Ex-vivo Ablation Performance: The "ground truth" would be the actual measured ablation zone characteristics (e.g., volume, size, shape) in the porcine tissues, determined by direct observation or histological analysis post-ablation.
  • For Acute Animal Testing: The "ground truth" would be the observed acute effects of ablation in porcine soft tissues, assessed through direct observation, physiological measurements, and potentially necropsy/histopathology.
  • For Sterilization, Biocompatibility, Electrical Safety, etc.: The "ground truth" is adherence to specified standards and objective measurements (e.g., sterility assurance level, physical/chemical properties, electrical performance).

8. The sample size for the training set:

  • This information is not applicable in the context of the studies described. The device is a microwave ablation system, and the testing described (functional, ex-vivo, animal, electrical, etc.) are verification and validation studies against pre-defined engineering and safety criteria, not training of a machine learning model.

9. How the ground truth for the training set was established:

  • This information is not applicable for the reasons stated in point 8. There is no mention of a "training set" for a machine learning model. The "training" that occurs is in the development and refinement of the device's design and operational parameters based on engineering principles and iterative testing.

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA acronym with the full name of the agency on the right. The symbol on the left is the Department of Health & Human Services logo. The FDA acronym is in a blue square, and the full name of the agency, "U.S. Food & Drug Administration," is in blue text to the right of the square.

July 19, 2024

Varian Medical Systems, Inc. Lynn Allman Sr. Director Regulatory Affairs 3100 Hansen Way Palo Alto, California 94304

Re: K240480

Trade/Device Name: IntelliBlate Microwave Ablation System Console (IB-CON); IntelliBlate Microwave Ablation System Mobile Cart (IB-CART); IntelliBlate Ximitry Probe Assembly, 13G x 15cm (IB-XPA-1315); IntelliBlate Ximitry Probe Assembly, 13G x 20cm (IB-XPA-1320); IntelliBlate Ximitry Probe Assembly, 13G x 27cm (IB-XPA-1327) Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting And Coagulation Device And Accessories Regulatory Class: Class II Product Code: NEY Dated: June 17, 2024 Received: June 18, 2024

Dear Lynn Allman:

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.

{1}------------------------------------------------

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).

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,

Digitally signed by Colin K. Colin K. Chen -S Date: 2024.07.19 Chen -S 13:35:14 -04'00'

Long Chen, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices

for

{2}------------------------------------------------

OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

{3}------------------------------------------------

Indications for Use

510(k) Number (if known) K240480

Device Name

IntelliBlate Microwave Ablation System Console (IB-CON); IntelliBlate Microwave Ablation System Mobile Cart (IB-CART); IntelliBlate Ximitry Probe Assembly, 13G x 15cm (1B-XPA-1315); IntelliBlate Ximitry Probe Assembly, 13G x 20cm (1B-XPA-1320); IntelliBlate Ximitry Probe Assembly, 13G x 27cm (IB-XPA-1327).

Indications for Use (Describe) IntelliBlate Microwave Ablation System:

The IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue. The IntelliBlate Microwave Ablation System is not intended for use in cardiac procedures.

IntelliBlate Ximitry Probe Assembly:

The IntelliBlate Ximitry Probe Assembly, used with the IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue.

The IntelliBlate Ximitry Probe Assembly is not intended for use in cardiac procedures.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{4}------------------------------------------------

Image /page/4/Picture/0 description: The image shows three blue circles in a row. The circles are evenly spaced and are all the same size. The background is white. The circles are a bright, vibrant blue.

Varian Medical Systems, Inc 3100 Hansen Way Palo Alto, CA 94304-1038

Telephone: 1.650.493.4000 Toll Free: 800.544.4636 www.varian.com

PREMARKET NOTIFICATION

K240480 510(k) Summary IntelliBlate Microwave Ablation System and Accessories The following information is provided as required by 21 CFR 807.92

Submitter's Information: l.

Name and Address:Varian Medical Systems Inc.9825 Spectrum Drive, Building 2 Austin, TX 78717
Contact Name:Lynn Allman, Senior Director Regulatory Affairs
E-mail:submissions.support@varian.com
Date Prepared:July 17, 2024

ll. Device Information:

Proprietary Name:IntelliBlate Microwave Ablation System and Accessories
Common/ Usual Name:System, Ablation, Microwave and Accessories
Classification Name:Electrosurgical cutting and coagulation device and accessories
Classification Panel:General & Plastic Surgery
Regulation Number:21 CFR 878.4400
Product CodeNEY

III. Predicate Devices:

Emprint Ablation System with Thermosphere Technology (K200796) Neuwave Certus 140 2.45 GHz Ablation System and Accessories (K100744)

IV. Subject Device Description:

The IntelliBlate Microwave Ablation System is a software-controlled microwave therapy delivery system with graphical user interface and hardware to control and monitor the therapy delivered to the target tissues.

The system consists of a 2.45 GHz microwave generator (console) with an integrated peristaltic pump assembly for coolant fluid delivery, a coolant Fluid Mount and an optional mobile cart for the console. Accessories for the system include IntelliBlate Ximitry Probe Assembly - a sterile, single-use disposable microwave ablation assembly with ablation probes and a cassette for coolant fluid tubing (closed cooling circuit).

{5}------------------------------------------------

V. Intended Use/ Indications of Use Statement:

IntelliBlate Microwave Ablation System

The IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue.

The IntelliBlate Microwave Ablation System is not intended for use in cardiac procedures.

IntelliBlate Ximitry Probe Assembly

The IntelliBlate Ximitry Probe Assembly, used with the IntelliBlate Microwave Ablation System is intended for coagulation (ablation) of soft tissue.

The IntelliBlate Ximitry Probe Assembly is not intended for use in cardiac procedures.

VI. Substantial Equivalence Discussion:

The following table compares the subject device to the predicate devices with respect to indications for use, principles of operation, technological characteristics, materials, and performance, and forms the basis for the determination of substantial equivalence.

Table 1: Comparison of Technological Characteristics between subject and predicate devices

{6}------------------------------------------------

Features/ CharacteristicsSubject DeviceIntelliBlate Microwave Ablation Systemand AccessoriesPredicate DeviceEmprint Ablation System withThermosphere Technology (K200796)Predicate DeviceNeuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)Comparison
Product code, FDAregulation and deviceclassNEY, 21 CFR 878.4400 and Class IINEY, 21 CFR 878.4400 and Class IINEY, 21 CFR 878.4400 and Class IISame
510(k) clearance(s)No prior 510(k) clearancesK200796K100744Subject device is a new devicewith no prior regulatoryclearances.
ManufacturerVarian Medical SystemsCovidienNeuwave Medical Inc.Different manufacturer
Prescription (Rx only)YesYesYesSame
Intended UseIntended for coagulation (ablation) ofsoft tissue in laparoscopic,intraoperative, and percutaneousablation proceduresIntended for coagulation (ablation) ofsoft tissue in laparoscopic,intraoperative, and percutaneousablation procedures.The Neuwave Medical Certus 1402.45 GHz Ablation System andAccessories are intended for theablation (coagulation) of soft tissue.The Certus 140™ 2.45 GHz AblationSystem is not intended for use incardiac procedures.NeuWave recommends against theuse of the Certus 140 2.45 GHzAblation System in the followingsituations:* Pregnant patients - potential risksto patient and/or fetus have notbeen established* Patients with implantablepacemakers or other electronicimplants. Implanted electronicdevices may be adversely affected bymicrowave powerThe system is designed for facility useand should only be used under theorders of a clinician.Same indication of use -subjectand predicate devices areindicated for coagulation(ablation) of soft tissue.Subject device does not includepercutaneous, laparoscopic,endoscopic, and intraoperativecoagulation (ablation) of softtissue, including partial orcomplete ablation ofnonresectable liver tumors.
Features/ CharacteristicsSubject DeviceIntelliBlate Microwave Ablation Systemand AccessoriesPredicate DeviceEmprint Ablation System withThermosphere Technology (K200796)Predicate DeviceNeuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)Comparison
Indications for UseStatement for IntelliBlateMicrowave AblationSystemThe IntelliBlate Microwave AblationSystem is intended for coagulation(ablation) of soft tissue.The IntelliBlate Microwave AblationSystem is not intended for use incardiac procedures.The Emprint™ Ablation System isintended for use in percutaneous,laparoscopic, endoscopic, andintraoperative coagulation (ablation) ofsoft tissue, including partial orcomplete ablation of nonresectableliver tumors.The Emprint™ Ablation System is notintended for use in cardiac procedures.The Neuwave Medical Certus 1402.45 GHz Ablation System andAccessories are intended for theablation (coagulation) of soft tissue.The Certus 140™ 2.45 GHz AblationSystem is not intended for use incardiac procedures.NeuWave recommends against theuse of the Certus 140 2.45 GHzAblation System in the followingsituations:* Pregnant patients - potential risksto patient and/or fetus have notbeen established* Patients with implantablepacemakers or other electronicimplants. Implanted electronicdevices may be adversely affected bymicrowave powerThe system is designed for facility useand should only be used under theorders of a clinician.Same indication of use –subjectand predicate devices areindicated for coagulation(ablation) of soft tissue.Subject device does not includepercutaneous, laparoscopic,endoscopic, and intraoperativecoagulation (ablation) of softtissue, including partial orcomplete ablation ofnonresectable liver tumors.
Indications for UseStatement for IntelliBlateXimitry Probe AssemblyThe IntelliBlate Ximitry Probe Assembly,used with the IntelliBlate MicrowaveAblation System is intended forcoagulation (ablation) of soft tissue.The IntelliBlate Ximitry Probe Assemblyis not intended for use in cardiacprocedures.The Covidien Emprint™ Ablation Systemis intended for use in percutaneous,laparoscopic, endoscopic, andintraoperative coagulation (ablation) ofsoft tissue, including partial orcomplete ablation of nonresectableliver tumors.The Covidien Emprint™ AblationSystem is not intended for use incardiac procedures.The Neuwave Medical Certus 1402.45 GHz Ablation System andAccessories are intended for theablation (coagulation) of soft tissue.The Certus 140™ 2.45 GHz AblationSystem is not intended for use incardiac procedures.NeuWave recommends against theuse of the Certus 140 2.45 GHzAblation System in the followingsituations.Same indication of use -subjectand predicate devices areindicated for coagulation(ablation) of soft tissue.Subject device does not includepercutaneous, laparoscopic,endoscopic, and intraoperativecoagulation (ablation) of softtissue, including partial orcomplete ablation ofnonresectable liver tumors.
Features/ CharacteristicsSubject DevicePredicate DevicePredicate DeviceComparison
IntelliBlate Microwave Ablation Systemand AccessoriesEmprint Ablation System withThermosphere Technology (K200796)Neuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)
* Pregnant patients - potential risksto patient and/or fetus have notbeen established* Patients with implantablepacemakers or other electronicimplants. Implanted electronicdevices may be adversely affected bymicrowave powerThe system is designed for facility useand should only be used under theorders of a clinician.
Operating Principle formicrowave ablationMicrowave ablation is heating of thetarget tissue based on agitation ofwater molecules inducing cellular deathvia coagulation (ablation) necrosisMicrowave ablation is heating of thetarget tissue based on agitation ofwater molecules inducing cellular deathvia coagulation (ablation) necrosisMicrowave ablation is heating of thetarget tissue based on agitation ofwater molecules inducing cellulardeath via coagulation (ablation)necrosisSame
System Configuration
GeneratorTabletop Generator (console)Cart mounted GeneratorCart mounted GeneratorSame
No of independentablation channels213Subject device supports 2independent ablation channels
Cooling SystemPeristaltic Pump Assembly integratedinto the generator for each ablationchannelPeristaltic Pump Assembly separate andexternal to the generatorCO2 based cooling systemSubject and predicate device(K200796) has peristaltic pumpassembly for cooling of theablation probes.
Touch Screen/ GraphicalUser InterfaceYesNo (Physical Buttons and digital display)YesGUI/ Touch Screen
Accessories
Ablation Probe AssemblyIncludes ablation probe, coolant tubing,coolant spike, integrated cassette forcoolant delivery and power cable.Includes ablation probe, coolant tubing,coolant spike and power cable. Coolantdelivery is external via manualconnection to the external pump.Includes a probe handle, a 1.4Mcable, CO2 gas coolant tubing and aconnector assembly. An intermediatejunction box or Power DistributionSubject device does not need anadditional reusable cable toconnect probe to the generator.
Features/ CharacteristicsSubject DeviceIntelliBlate Microwave Ablation Systemand AccessoriesPredicate DeviceEmprint Ablation System withThermosphere Technology (K200796)Predicate DeviceNeuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)Comparison
Optional accessories – laser alignment disc and depth guides for ablation probesModule (PDM) is used between the probe and console.
Optional AccessoriesTemperature sensor probe, mobile cartRemote Temperature Probe, mobile cart, footswitchFootswitchSimilar optional accessories
Ablation
Ablation featuresAblation, Track Ablation and Needle LockAblation.Device can be used for track ablation as a use workflow.Ablation, Cauterize (track ablation), Tissue Loc, Planar CoagulationAdditional pre-configured ablation features in subject device
Target Ablation timeUp to 10 minutes.Up to 10 minutesUp to 10 minutesSame
Generator
Device UsageMulti-useMulti-useMulti-useSame
Compatible Disposable/Single Use DevicesMicrowave ablation probe (up to 2)Optional Temperature Sensor Probe (up to 2)Microwave ablation probe (1)Optional Remote Temperature Probe (1)Microwave ablation probe (up to 3)Subject device can connect up to 2 probes
Generator OutputFrequency2.45GHz ± 50MHz2.45GHz ± 50MHz2.45GHz ± 25MHzSame
Maximum RF power forablation (measured atoutput port):170W (single needle ablation)2x 150W (double needle ablation)150W (single needle ablation)140W (single needle ablation)2x 95W (double needle ablation)3x 65W (triple needle ablation)Increased output power to compensate for cable losses.
Power SettingsAdjusts microwave power setpoint in 5-watt incrementsAdjusts microwave power setpoint in 5-watt increments.Adjusts microwave power setpoint in 5-watt incrementsSame
Temperature MonitoringYesYesYesSame
Safety Feature -Automatic systemShutdown when ablationprobe temperatureYesYesYesSame
Features/ CharacteristicsSubject DevicePredicate DevicePredicate DeviceComparison
IntelliBlate Microwave Ablation Systemand AccessoriesEmprint Ablation System withThermosphere Technology (K200796)Neuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)
exceed limits and due tohigh reflected power
Safety StandardComplianceIEC 60601-1, 60601-1-6, 60601-2-6,60601-1-2IEC 60601-1, 60601-1-6, 60601-2-6,60601-1-2IEC 60601-1, 60601-2-2, 60601-2-6,60601-1-2Same
Potential EqualizationEqualization terminalEqualization terminalEqualization terminalSame
Electronic Interfaces forInteroperabilityUSBUSBUSBSame
Operating ConditionsTemperature: 10 to 25 °CTemperature: 10 to 30°CTemperature: 18 to 28°CSimilar
Relative Humidity: 30% to 75% (non-condensing)Relative Humidity: 20% to 80% (non-condensing)Relative Humidity: 10% to 90% (non-condensing)Similar
Atmospheric pressure range: 60kPa to106 kPaAtmospheric pressure range: 66kPa to106 kPaAtmospheric pressure range: 70kPAto 106kPaSimilar

{7}------------------------------------------------

{8}------------------------------------------------

{9}------------------------------------------------

{10}------------------------------------------------

Microwave Ablation Probe
Features/ CharacteristicsSubject DeviceIntelliBlate Microwave Ablation Systemand AccessoriesPredicate DeviceEmprint Ablation System withThermosphere Technology (K200796)Predicate DeviceNeuwave Certus 140 2.45 GHzAblation System and Accessories(K100744)Comparison
Compatible MicrowaveAblation ProbeXimitry Probe AssemblyMicrowave ablation antenna withThermosphere™ TechnologyAblation probes include ModelsCertusLN, CertusLK, CertusSR andCertusPRSee below comparison of thefeatures
Antenna ConnectionsSingle cable bundles integrating powercable and coolant tubing (supply andreturn lines)Separate power cable and coolanttubing (supply and return lines)Single cable bundles integratingpower cable and coolant tubing(supply and return lines)Single cable bundle
Power ConnectionPower cable connects directly to theconsolePower Cable connects to a reusablecable that connects to the consolePower cable connects to a reusablePower Distribution Module (PDM)is used between the probe andconsoleDifferent set for connection
Antenna Coolant DeliveryCoolant delivery connection via anintegrated CassetteCoolant delivery connection via manualconnection to external peristaltic pumpCoolant delivery connection via anintegrated connectorIntegrated coolant deliverycircuit
Coolant ConnectionVia spike to the coolant bagVia spike to the coolant bagVia gas fitting connection to 2 CO2gas cylindersSubject and predicate device(K200796) have the samecoolant connection.
Cooling mediumSterile water/ salineSterile salineCO2 gasAdditional coolant option
Distal Tip configurationCeramic Trocar TipCeramic Trocar tipCeramic Trocar tipSame
Antenna shaft length(s)15 cm, 20 cm, 27 cm15 cm, 20 cm, 30 cm6cm, 15cm, 20cm, 25cmVariable lengths to supportsofttissue ablations
Antenna Shaft Diameter13.5 G (2.3mm)13 G (2.4mm)13G, 15G, 17GSubject device has a thinnershaft profile
Right Angle ProbeYesYesYesSame
Antenna ShaftConstructionFiberglassFiberglassStainless steelSame
Probe Thermocouple3 integrated thermocouples at pre-defined locations on the shaft and 2internal temperature sensors within theprobe handle1 internal temperature sensor with nothermocouples on the shaft3 integrated thermocouples at pre-defined locations on the shaftMultiple temperature sensors
Patient ContactingComponentsAntenna shaft, tip, adhesive and depthguide are biocompatibleAntenna shaft, tip, adhesive and depthguide are biocompatible.Antenna shaft & tip arebiocompatible.Same
SoftwareNoNoNoSame
Device UsageSingle-use, disposableSingle-use, disposableSingle-use, disposableSame
SterilizationETOETOETOSame
Packaging Configurationand MaterialsThermoform tray and retainer lid with asingle Tyvek sterile barrier lid within aSBS (solid bleached sulfate) shelf cartonbox sealed with a tamper paper tape.Thermoform tray and single Tyveksterile barrier lid within a SBS (solidbleached sulfate) shelf carton boxsealed with a tamper paper tape.Thermoform tray and single Tyveksterile barrier lid within a SBS (solidbleached sulfate) shelf carton boxsealed with a tamper paper tape.Same
Optional AccessoriesLaser alignment disc and depth guideDepth guideNo optional accessoriesAdditional optional accessories

{11}------------------------------------------------

{12}------------------------------------------------

Performance Data: VII.

1. Non-clinical Testing:

IntelliBlate Microwave Ablation System and its accessories underwent non-clinical testing to demonstrate the design and performance of the devices meet the established design criteria and are substantial equivalent to the predicate devices. The subject devices successfully completed functional, ablation performance ex-vivo tissues, reliability, and electrical testing.

Substantial equivalence in performance between the subject and predicate device cleared via K200796 was demonstrated by side-by-side testing of the subject and predicate devices for ablation. The ex-vivo testing of the devices at single, double and track ablation settings in porcine liver, kidney and muscle demonstrate that the differences in design and system characteristics do not affect the ablation performance of the subject device in comparison to the predicate device.

2. Non-clinical Animal Testing:

Animal testing with IntelliBlate Microwave Ablation System and its accessories were completed in accordance with the United States Food and Drug Administration Good Laboratory Practice (GLP) Regulations, 21 CFR Part 58 and included:

  • Acute GLP studies to validate usability and performance of the devices on porcine soft tissue models.

3. Literature Review:

Systematic literature review conducted in support of indications of use with the predicate device identified a total of 1,628 patients and 2,438 tumors included in the 23 publications. The outcome and complication rates summarized from the predicate device published literature is comparable to the meta-analyses reviewed. The meta-analyses contain published literature comparing various microwave ablation systems to radio-frequency ablation, cryoablation or surgical resection. The literature search strategy was based on an SLR approach; both SLR sections, per unique studies and published SLRs/ meta-analyses, suggested the safe and effective use of microwave ablation for the soft tissue coagulation (ablation) of tumors.

4. Sterilization:

Ximitry Probe Assembly is sterilized utilizing 100% ethylene oxide gas to ensure a minimum sterility assurance level of 10 ° in accordance with ISO 11135, ISO 10993-7, ISO 11138-1, ISO 11737-1 and ISO 11737-2.

5. Software, Cybersecurity, and Interoperability

Software verification was conducted in accordance with IEC 62304 – "Medical device software - Software life cycle processes" and FDA guidance "Content of Premarket Submissions for Device Software Functions.

Cybersecurity requirements were assessed per FDA guidance's Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions, Postmarket Management of Cybersecurity in Medical Devices.

{13}------------------------------------------------

6. Thermal Effects and Temperature Monitoring:

Thermal effects and temperature monitoring testing were completed in accordance with FDA Guidance - Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery.

Comparison of thermal effects between IntelliBlate Microwave Ablation System and its predicate demonstrated that the performance of the subject device is substantially equivalent to the predicate device.

7. Biocompatibility:

Biocompatibility testing of the Ximitry Probe Assembly in accordance with ISO 10993-1 demonstrated that the patient-contacting components are biocompatible.

8. Electrical Safety and Electromagnetic Compatibility:

The IntelliBlate Microwave Ablation System and its accessories comply with applicable IEC 60601 series of standards: IEC 60601-1, IEC 60601-1-6, IEC 60601-2-6, and IEC 60601-1-2.

9. Packaging Integrity and Shelf Life:

Packaging integrity and shelf-life testing was performed in accordance with ISO 11607-1 and ISO 11607-2.

VIII. Conclusion:

The subject device and predicate device(s) technological characteristics are equivalent. The nonclinical verification and validation performance data supports the safety and effectiveness of the subject device as indicated for use. Varian considers the IntelliBlate Microwave Ablation System and its accessories technological characteristics to be as safe and effective as the predicate device(s) and therefore, substantially equivalent to the predicate device(s).

§ 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.