K Number
K240495
Device Name
Flexible Fixation Device for Gynecological Applicators (GM11001960)
Date Cleared
2024-05-09

(79 days)

Product Code
Regulation Number
892.5700
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Flexible Fixation Device for gynecological applicators is intended for cancer treatment of the vagmal stump. cervix, uterus, endometrium or rectum using HDR or PDR Brachytherapy.
Device Description
The Flexible Fixation Device for Gynecological Applicators is an accessory used to hold an applicator in place, to prevent movement of the applicator during the imaging (standard radiograph, CT and/or MR technique) and treatment process for HDR and PDR brachytherapy. The key performance characteristics of the device are as follows: Fixation rings for cylinders of various diameters (20 mm - 40 mm); and fixation straps (500 mm/150 mm, 1050 mm /350 mm, 1700 mm/500 mm) - CT compatible - - -MR safe - -Fixation rings are sterilizable and released for 250 reuses - -Fixation plate rings are sterilizable and released for 50 reuses - -The fixation straps are qualified for 50 textile laundering cycles - -Suitable for patient contact—on intact skin—for a period of less than 30 day Fixation straps are fixed in slots of the fixation plate and around the waist of the fixation ring is attached onto an applicator which then is inserted into the patient. The flexible fixation plate is attached over the applicator and clamped in the fixation ring. The applicator is connected to an afterloader. This combination places the remote-controlled radioisotope treatment source (brachytherapy source) nearby the target tissue. The applicator guides the radioactive source to the correct location or locations for treatment. The fixation rings for cylinders of ø 20, 23-, 26-, 30-, 35-, and 40-mm diameter, in combination with the flexible fixation plate, provide a mount for the respective cylinder applicator. The flexible fixation plate for gynecological applicators has a smaller and a larger teardrop-shaped holes for the different fixation rings. It also provides several slots for the fixation straps. The fixation straps of different lengths (500 mm/150 mm, 1050 mm/350 mm/500 mm) can be fixed at the fixation plate through the slots of the plate using hook-and-loop fasteners. Multiple straps in suitable lengths can be combined and fixated around the patient's waist and if necessary, additionally around the shoulders.
More Information

Not Found

No
The device description focuses on mechanical fixation and material properties, with no mention of AI/ML capabilities or data processing beyond standard imaging techniques.

No.
The device is an accessory used to hold an applicator in place during cancer treatment; it does not directly treat the disease itself.

No.

The device is described as an accessory used to hold an applicator in place during cancer treatment, not for diagnosis.

No

The device description clearly outlines physical components such as fixation rings, straps, and plates, and discusses their material properties, sterilization, and mechanical testing. This indicates it is a hardware device, not software-only.

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

Here's why:

  • Intended Use: The intended use is for "cancer treatment of the vaginal stump, cervix, uterus, endometrium or rectum using HDR or PDR Brachytherapy." This describes a therapeutic intervention, not a diagnostic test performed on samples taken from the body.
  • Device Description: The device is described as an "accessory used to hold an applicator in place, to prevent movement of the applicator during the imaging... and treatment process." This is a mechanical support device used during a medical procedure.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in biological samples
    • Providing information for diagnosis, monitoring, or screening of diseases

The device's function is to physically stabilize a medical applicator during brachytherapy treatment. This falls under the category of a therapeutic or procedural medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Flexible Fixation Device for gynecological applicators is intended for cancer treatment of the vagmal stump. cervix, uterus, endometrium or rectum using HDR or PDR Brachytherapy.

Product codes

JAQ

Device Description

The Flexible Fixation Device for Gynecological Applicators is an accessory used to hold an applicator in place, to prevent movement of the applicator during the imaging (standard radiograph, CT and/or MR technique) and treatment process for HDR and PDR brachytherapy.

The key performance characteristics of the device are as follows:

Fixation rings for cylinders of various diameters (20 mm - 40 mm); and fixation straps (500 mm/150 mm, 1050 mm /350 mm, 1700 mm/500 mm)

  • CT compatible -
  • -MR safe
  • -Fixation rings are sterilizable and released for 250 reuses
  • -Fixation plate rings are sterilizable and released for 50 reuses
  • -The fixation straps are qualified for 50 textile laundering cycles
  • -Suitable for patient contact—on intact skin—for a period of less than 30 day

Fixation straps are fixed in slots of the fixation plate and around the waist of the fixation ring is attached onto an applicator which then is inserted into the patient. The flexible fixation plate is attached over the applicator and clamped in the fixation ring. The applicator is connected to an afterloader. This combination places the remote-controlled radioisotope treatment source (brachytherapy source) nearby the target tissue. The applicator guides the radioactive source to the correct location or locations for treatment.

The fixation rings for cylinders of ø 20, 23-, 26-, 30-, 35-, and 40-mm diameter, in combination with the flexible fixation plate, provide a mount for the respective cylinder applicator. The flexible fixation plate for gynecological applicators has a smaller and a larger teardrop-shaped holes for the different fixation rings. It also provides several slots for the fixation straps. The fixation straps of different lengths (500 mm/150 mm, 1050 mm/350 mm/500 mm) can be fixed at the fixation plate through the slots of the plate using hook-and-loop fasteners. Multiple straps in suitable lengths can be combined and fixated around the patient's waist and if necessary, additionally around the shoulders.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

standard radiograph, CT and/or MR technique

Anatomical Site

vagina, vaginal stump, cervix, uterus, endometrium or rectum

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

The following performance data was provided in support of the substantial equivalence determination.

Biocompatibility Testing:

The compatibility of the skin-contact component material in the finished product meets the biocompatibility requirements. The Biological Evaluation Tests are in compliance with the standards of ISO 10993-1 and its applicable parts, "Biological Evaluation of Medical Device – Part 1: Evaluation and Testing Within a Risk Management Process".

Cleaning, Disinfection and Sterilization Testing:

Cleaning, disinfection and sterilization testing was conducted to demonstrate the device components may be sterilized effectively (as appropriate) and the device can be used and sterilized for the specified number of times.

Human factors validation study was conducted according to the standard IEC 62366 to verify that the device performs well as intended for the intended users, uses, and use environments.

Mechanical and Acoustic Testing:

The Flexible Fixation Device for Gynecological Applicators has undergone formal design verification and design validation testing. Design verification and design validation testing demonstrates that the device performs as intended.

Design verification and design validation testing was performed according to the FDA Quality System Regulation (21 CFR §820), ISO 13485 Quality Management System Standard, and ISO 14971 Risk Management Standard.

Key Metrics

Not Found

Predicate Device(s)

K151657

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.5700 Remote controlled radionuclide applicator system.

(a)
Identification. A remote controlled radionuclide applicator system is an electromechanical or pneumatic device intended to enable an operator to apply, by remote control, a radionuclide source into the body or to the surface of the body for radiation therapy. This generic type of device may include patient and equipment supports, component parts, treatment planning computer programs, and accessories.(b)
Classification. Class II.

0

May 9, 2024

Image /page/0/Picture/1 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, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".

Varian Medical Systems, Inc % Dr. Lynn Allman Sr. Director, Regulatory Affairs 3100 Hansen Way PALO ALTO, CA 94304

Re: K240495

Trade/Device Name: Flexible Fixation Device for Gynecological Applicators Regulation Number: 21 CFR 892.5700 Regulation Name: Remote Controlled Radionuclide Applicator System Regulatory Class: Class II Product Code: JAQ Dated: February 20, 2024 Received: February 20, 2024

Dear Dr. 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.

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

1

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 medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the 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,

Locon Weidner

Lora D. Weidner, Ph.D. Assistant Director Radiation Therapy Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K240495

Device Name

Flexible Fixation Device for Gynecological Applicators

Indications for Use (Describe)

The Flexible Fixation Device for gynecological applicators is intended for cancer treatment of the vagmal stump. cervix, uterus, endometrium or rectum using HDR or PDR Brachytherapy.

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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Premarket Notification - 510(k) Summary

Traditional 510(k) Submission for Flexible Fixation Device for Gynecological Applicators

l. Submitter's Name

Varian Medical Systems 3100 Hansen Way Palo Alto, CA 94304

Contact Name: Lynn, Allman, PhD., Senior Director Regulatory Affairs Phone: (650) 424-5369 E-mail: submissions.support@varian.com Date Prepared: April 23, 2024

II. Device Information

Proprietary Name: The Flexible Fixation Device for Gynecological Applicators Classification Name: Remote Controlled Radionucleotide Applicator System Regulation Number: §892.5700 Product Code: JAQ

III. Predicate Device

Shielded Applicator Set, Cervical Stop (K151657)

IV. Device Description

The Flexible Fixation Device for Gynecological Applicators is an accessory used to hold an applicator in place, to prevent movement of the applicator during the imaging (standard radiograph, CT and/or MR technique) and treatment process for HDR and PDR brachytherapy.

The key performance characteristics of the device are as follows:

Fixation rings for cylinders of various diameters (20 mm - 40 mm); and fixation straps (500 mm/150 mm, 1050 mm /350 mm, 1700 mm/500 mm)

  • CT compatible -
  • -MR safe
  • -Fixation rings are sterilizable and released for 250 reuses
  • -Fixation plate rings are sterilizable and released for 50 reuses
  • -The fixation straps are qualified for 50 textile laundering cycles
  • -Suitable for patient contact—on intact skin—for a period of less than 30 day

Fixation straps are fixed in slots of the fixation plate and around the waist of the fixation ring is attached onto an applicator which then is inserted into the patient. The flexible fixation plate is attached over the applicator and clamped in the fixation ring. The applicator is connected to an afterloader. This combination places the remote-controlled radioisotope treatment source (brachytherapy source) nearby the target tissue. The applicator guides the radioactive source to the correct location or locations for treatment.

4

Image /page/4/Picture/0 description: The image shows the logo for Varian, a Siemens Healthineers Company. The word "varian" is written in a bold, sans-serif font. Below the word "varian" is the text "A Siemens Healthineers Company" in a smaller font.

The fixation rings for cylinders of ø 20, 23-, 26-, 30-, 35-, and 40-mm diameter, in combination with the flexible fixation plate, provide a mount for the respective cylinder applicator. The flexible fixation plate for gynecological applicators has a smaller and a larger teardrop-shaped holes for the different fixation rings. It also provides several slots for the fixation straps. The fixation straps of different lengths (500 mm/150 mm, 1050 mm/350 mm/500 mm) can be fixed at the fixation plate through the slots of the plate using hook-and-loop fasteners. Multiple straps in suitable lengths can be combined and fixated around the patient's waist and if necessary, additionally around the shoulders.

V. Intended Use

The Flexible Fixation Device for gynecological applicators is intended for cancer treatment of the vagina, vaginal stump, cervix, uterus, endometrium or rectum using HDR or PDR Brachytherapy.

VI. Comparison of Technological Characteristics with the Predicate Device

| Feature
and/or
Specification | Predicate Device: Shielded
Applicator Set, Cervical Stop
K151657
(GM11001960 Flexible Fixation
device for Gynecological
Applicators is listed as an
optional accessory of the
Shielded Applicator Set) | Subject Device: Flexible
Fixation Device for
Gynecological Applicators | Comparison |
|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | The Shielded Applicator Set is
intended for cancer treatment of
the vagina, vaginal stump or
rectum where partial shielding is
required using HDR or PDR
Brachytherapy. | The Flexible Fixation Device
for gynecological applicators is
intended for cancer treatment
of the vagina, vaginal stump,
cervix, uterus, endometrium
or rectum using HDR or PDR
Brachytherapy. | A separate
intended use
statement is now
defined for the
Flexible Fixation
Device for
Gynecological
Applicators. |
| Indications
for Use | The Shielded Applicator Set is
intended for cancer treatment of
the vagina, vaginal stump or
rectum where partial shielding is
required using HDR or PDR
Brachytherapy. The Flexible
Fixation Device is a clinical use
accessory for the fixation of
gynecological applicators. | The Flexible Fixation Device
for gynecological applicators is
indicated for cancer treatment
of the vagina, vaginal stump,
cervix, uterus, endometrium
or rectum using HDR or PDR
Brachytherapy. | A separate
intended use
statement is now
defined for the
Flexible Fixation
Device for
Gynecological
Applicators. |
| Compatible
Afterloader | VariSource iX™
VariSource 200™
GammaMedplus iX™
GammaMedplus 3/24 iX™
BRAVOS Afterloader System | VariSource iX™
VariSource 200™
GammaMedplus iX™
GammaMedplus 3/24 iX™
BRAVOS Afterloader System | No Change |
| | | | |
| Compatible
Applicators | Shielded Applicator Set
Stump Applicator Set with CT
Cylinders
Vaginal Applicator Set with CT
Cylinders
Segmented Cylinder Applicator Set
Cervix Applicator Set
Segmented Cervix Applicator Set

Applicators used with the Optional
Component:
Ring Applicator Set 45°
Ring Applicator Set 60°
Ring Applicator Set 90° | Shielded Applicator Set
Universal Stump Applicator Set
Universal Segmented Cylinder
Applicator Set
Universal Multi-channel Cylinder
Set
Universal Interstitial Cylinder
Set

Applicators used with the
Optional Components:
Ring Applicator Set 45°
Ring Applicator Set 60°
Ring Applicator Set 90°
3D Interstitial Ring Applicator
Set 60° (without needle use)
3D Interstitial Ring Applicator
Set 90° (without needle use) | The cylinder
applicators have
been updated to
the new
Universal family.
The same range
of diameters is
covered with the
addition of some
40 mm diameter
cylinders.

The Interstitial
ring applicators
have been
added. Without
needle use they
are equivalent to
the ring sets. |
| Optional
Components | Clamping screw of the fixation ring
Bracket for ring applicator for
flexible fixation GYN | Clamping screw of the fixation
ring
Bracket for ring applicator for
flexible fixation GYN | No Change |
| Design | Cylinder:

  • Ø 20, 23, 26, 30, 35mm
  • length 140mm
    Applicator probe:
  • Ø 3.0mm, straight
  • length 320mm
    Tungsten Alloy Shielding:
  • 90°, 180°
  • Length 122.5mm
    Marking Screw (shielded)
  • 0°, 90°, 2 x 90°, 180°, 270°
    Clamping Nut for marking screw
    Clamping screw for probe, 3 mm
    Plexiglass Filler Piece, 90° Blue
    Cleaning
    Fixation Ring for Cylinder:
    | Fixation Ring for Cylinder:
    Ø 20, 23, 26, 30, 35, 40 mm

Flexible Fixation Plate for
gynecological applicators

Fixation strap:

  • 500mm/150mm
  • 1050mm/350mm
  • 1700mm/500mm | No Change |
    | Materials | The Shielded Applicator Set
  • Shielding - Tungsten Alloy | - Fixation ring for cylinder -
    PPSU | Change in
    material of the |
    | | - Marking Screw, Clamping
    nut/Screw and
    applicator probe - Stainless
    Steel
  • Cylinder - PMMA
  • Cleaning cap - Silicone

The Flexible Fixation Device

  • Fixation ring for cylinder -
    PPSU
  • Flexible fixation plate - PVC
  • Fixation strap - Cotton/PA | - Flexible fixation plate -
    Silicone
  • Fixation strap - Cotton/PA | flexible fixation
    plate from PVC to
    silicone. |
    | Environment | The Shielded Applicator Set is a
    clinical use accessory for the
    fixation of gynecological
    applicators.

CT image compatible and MR-
Safe. | The Flexible Fixation Device is
a clinical use accessory for the
fixation of gynecological
applicators.

CT image compatible and MR-
Safe. | No Change |

Table 1: Comparison of Subiect Device to Predicate Device

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VII. Summary of Performance Testing (Non-Clinical Testing)

The following performance data was provided in support of the substantial equivalence determination.

Biocompatibility Testing:

The compatibility of the skin-contact component material in the finished product meets the biocompatibility requirements. The Biological Evaluation Tests are in compliance with the standards of ISO 10993-1 and its applicable parts, "Biological Evaluation of Medical Device – Part 1: Evaluation and Testing Within a Risk Management Process".

Cleaning, Disinfection and Sterilization Testing:

Cleaning, disinfection and sterilization testing was conducted to demonstrate the device components may be sterilized effectively (as appropriate) and the device can be used and sterilized for the specified number of times.

Human factors validation study was conducted according to the standard IEC 62366 to verify that the device performs well as intended for the intended users, uses, and use environments.

Mechanical and Acoustic Testing:

The Flexible Fixation Device for Gynecological Applicators has undergone formal design verification and design validation testing. Design verification and design validation testing demonstrates that the device performs as intended.

Design verification and design validation testing was performed according to the FDA Quality System Regulation (21 CFR §820), ISO 13485 Quality Management System Standard, and ISO 14971 Risk Management Standard.

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Image /page/7/Picture/0 description: The image shows the logo for Varian, a Siemens Healthineers Company. The word "Varian" is written in a bold, sans-serif font. Below the word "Varian" is the text "A Siemens Healthineers Company" in a smaller font. The logo is simple and modern.

Use of Consensus Standards:

The following list of FDA-recognized, voluntary consensus standards were utilized in the design and evaluation of the subject device's safety and efficacy.

| IEC 62366-

1:2015+A1:2020Application of Usability Engineering to Medical Devices
ANSI/AAMI ST98:2022Cleaning Validation of health care products –cleaning process for medical devices
ANSI / AAMI
ST79:2017(R)2022Comprehensive guide to steam sterilization and sterility assurance in health care
facilities
ISO 17664-2:2021Processing of health care products - Information to be provided by the medical device
manufacturer for the processing of medical devices –Part 2: Non-critical medical
devices
EN ISO 11138-1:2017Sterilization of health care products –Biological indicators – Part 1: General
requirements
EN ISO 11138-3:2017Sterilization of health care products –Biological indicators – Part 3: Biological indicators
for moist heat sterilization processes
EN ISO 11138-7:2019Sterilization of health care products –Biological indicators – Part 7: Guidance for the
selection, use and interpretation of results
EN ISO 11607-1:2019Packaging for terminally sterilized medical devices –Part 1: Requirements for materials,
sterile barrier systems and packaging systems
EN ISO 11737-
1:2018+A1:2021Sterilization of medical devices – Microbiological methods – Part 1: Determination of a
population of microorganisms on products
EN ISO 11737-2:2019Sterilization of medical devices - Microbiological methods - Part 2: Tests of sterility
performed in the definition, validation and maintenance of a sterilization process
EN ISO 17665-1:2006Sterilization of health care products - Moist heat - Part 1: Requirements for the
development, validation and routine control of a sterilization process for medical
devices
ISO/TS 17665-2:2009Sterilization of health care products –Moist heat –Part 2: Guidance on the application
of ISO 17665-1
ISTA 3A (2018)General Simulation Performance Tests for packaged-products weighing 150 lb. (70 kg)
or less (standard, small, flat or elongated)
EN ISO 10993-1:2018Biological evaluation of medical devices -- Part 1: Evaluation and testing within a risk
management process.
EN ISO 10993-5:2009Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
ISO 10993-18:2020/
AMD 1:2022Biological evaluation of medical devices -- Part 18: Chemical characterization of
medical device materials within a risk management process
EN ISO 10993-12:2021Biological evaluation of medical devices –Part 12: Sample preparation and reference
materials
ASTM F2503-23Standard Practice for Marking Medical Devices and Other Items for Safety in the
Magnetic Resonance Environment
ASTM D4332-22Standard Practice for Conditioning Containers, Packages, or Packaging Components for
Testing

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EN ISO 10993-2:2022 Biological evaluation of medical devices. —Part 2: Animal welfare requirements

VIII. Determination of Substantial Equivalence to the Predicate

The Flexible Fixation Device for Gynecological Applicators was previously sold as an optional accessory for the Shielded Applicator set in K151657. There are no changes in the design or principle of operation of the devices. Varian believes the major technological characteristics are substantially equivalent to the predicate device and the differences do not raise new questions of safety and effectiveness compared to the predicate. The results of verification and validation as well as conformance to relevant safety standards demonstrate that the device meets the safety and performance criteria. Varian considers the Flexible Fixation Device for Gynecological Applicators to be as safe and effective as the predicate and therefore substantially equivalent to the predicate device.