(135 days)
The F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit are indicated for endoscopic examination in the urinary tract and can be used to examine the interior of the kidney, and using additional accessories, to perform various diagnostic and therapeutic procedures.
The F88 URE-SD Flexible Ureteroscope, Standard Deflection and the F88 URE-RD Flexible Ureteroscope, Reverse Deflection (both also collectively referred to as the "F88 URE-SD/RD Flexible Ureteroscope") is a handheld flexible ureteroscope with a flexible insertion portion length of 670 mm and a maximum outer diameter of 3.05 mm. The device includes a working channel of 1.2 mm diameter for the insertion of various compatible flexible instruments and irrigation systems. The distal tip is equipped with a CMOS imaging sensor and an LED light source for live videos. The control body has a deflection lever to deflect the distal tip up to at least 270° in the up or down directions for navigation and access to targeted areas. The push buttons can be programmed to perform functions such as white balance, brightness, picture, record, zoom and to provide access to the setup menu.
The standard deflection (SD) and reverse deflection (RD) models are functionally identical, with one primary difference: the direction of the distal tip deflection in response to the deflection lever's movement. When the deflection lever of the standard model moves upward, the distal tip deflects upward. In the reverse model, when the deflection lever moves upward, the distal tip deflects downward. The model is selected depending on the handling preference of the user.
The F88 URE-SD/RD Flexible Ureteroscope is a reusable device.
The F88 URE-SD/RD Flexible Ureteroscope is compatible for use with the F88 Flexible Camera Control Unit (FCCU) and several accessories, listed below:
- Single Luer Stopcock
- Vent Cap with Sterilization Card
- Manual Leak Tester
- Luer Port Cleaning Brush
- Cleaning Brush
- URE Working Channel Cleaning Brush
The F88 Flexible Camera Control Unit (FCCU) or F88 flexible camera console is a device that processes and produces live video images during endoscopic procedures. It is used together with the F88 URE-SD/RD Flexible Ureteroscope and compatible surgical display monitors to form the F88 Flexible Camera System.
The provided FDA 510(k) clearance letter for the F88 URE-SD/RD Flexible Ureteroscope does not contain information about specific acceptance criteria related to accuracy metrics (like sensitivity, specificity, or AUC) or the results of a study designed to demonstrate the device meets such criteria for diagnostic performance.
The document primarily focuses on demonstrating substantial equivalence to a predicate device (Karl Storz Flexible Video-Uretero-Renoscope, K141250) based on:
- Identical Indications for Use: Both devices are indicated for endoscopic examination in the urinary tract, including the kidney, for diagnostic and therapeutic procedures.
- Similar Technological Characteristics: The differences between the devices are described as minor and not raising new questions of safety or effectiveness.
- Performance Testing to Address Safety and Effectiveness: This testing primarily covers non-clinical aspects essential for medical devices, such as biocompatibility, reprocessing validation, electrical safety, EMC, and software validation.
Therefore, many of the requested details about acceptance criteria, device performance, sample sizes, ground truth establishment, expert involvement, and comparative effectiveness studies are not present in this document. This is common for 510(k) submissions for devices like endoscopes, where the primary concern is the device's physical and functional equivalence and safety, rather than a quantifiable diagnostic accuracy claim that would necessitate extensive clinical performance studies.
Here's a breakdown of what can and cannot be answered from the provided text:
Acceptance Criteria and Device Performance (as inferable from the document):
Since the device is a flexible ureteroscope, the "acceptance criteria" discussed are largely related to functional performance, safety, and equivalence to a predicate device rather than diagnostic accuracy metrics. The document states that the device "performs as intended" and "has the same or better performance than the predicate device."
| Criterion Type | Specific Criterion (Inferred/Stated) | Reported Device Performance (Inferred/Stated) |
|---|---|---|
| Indications for Use | Identical to predicate device | Met: Indicated for endoscopic examination in the urinary tract, including the kidney, for diagnostic and therapeutic procedures. |
| Biocompatibility | Successful testing per ISO 10993-1 and FDA guidance | Met: Testing (Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Material Mediated Pyrogenicity) successfully completed. |
| Reprocessing | Cleaning and sterilization validation | Met: Reprocessing validation (including cleaning, sterilization, human factors testing) successfully completed. |
| Electrical Safety | Compliance with IEC 60601-1 standard | Met: Device complies with IEC 60601-1. |
| EMC | Compliance with IEC 60601-1-2 standard | Met: Device complies with IEC 60601-1-2. |
| Software V&V | Verification and validation per FDA guidance (basic level) | Met: Software V&V completed, including system, installation, integration, unit, and user acceptance testing. |
| Cybersecurity | Vulnerability assessment, penetration testing per FDA guidance | Met: Cybersecurity testing completed, including vulnerability assessment and penetration testing. |
| Physical Dimensions | Similar to predicate device; minor differences proven safe/effective | Met: Differences in working channel length (670mm vs 675mm), distal tip outer diameter (9.15 Fr vs 8.5 Fr), and insertion tube outer diameter (2.85 mm vs 2.9 mm) deemed minor and not affecting safety or effectiveness. |
| Field of View | Comparison to predicate device | Met: Subject device (106°) has a slightly wider field of view than predicate (90°), deemed not to affect safety or effectiveness. |
| Depth of View | Comparison to predicate device; within range for cleared devices | Met: Subject device (2-50mm) differs from predicate (4-60mm), deemed minor and within acceptable range for other 510(k) cleared ureteroscopes. |
| Deflection Angles | ≥ 270° Up / ≥ 270° Down | Met: Identical to predicate device. |
| Functional Equivalence | Same or better performance than predicate device | Met: Performance testing and comparative testing demonstrated device performs as intended and is as safe and effective. |
| Transportation | Simulated Transportation Validation (ASTM D4169-23e1) | Met: Validation successfully completed for both components. |
| System Reliability | Successful testing | Met: System Reliability Testing completed for FCCU. |
| Video Performance | Successful testing | Met: Video Performance and Timing testing completed for FCCU. |
| RF Interference | Successful testing | Met: RF Interference testing completed for FCCU. |
Detailed Study Information (Based on provided text):
-
Sample size used for the test set and the data provenance:
- Not Applicable/Not Provided: The document does not describe a "test set" in the context of diagnostic accuracy data (e.g., medical images or patient cases). The performance testing conducted was primarily for engineering, safety, and functional validation (e.g., biocompatibility samples, reprocessed devices, electrical/EMC test units, software code).
- Data Provenance: Not applicable for the types of tests described.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable/Not Provided: No "ground truth" (e.g., disease presence/absence determined by an expert) for diagnostic performance was established or discussed. The device is an imaging tool, not an AI diagnostic algorithm making determinations. For human factors testing related to reprocessing, it's plausible experts were involved, but details are not provided.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not Applicable/Not Provided: There was no diagnostic "test set" requiring adjudication of ground truth.
-
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: "Clinical testing was not required to demonstrate substantial equivalence to the predicate device." MRMC studies are typically for evaluating the impact of AI on human diagnostic performance. Since this device is an endoscope and not an AI diagnostic tool, such a study would not apply in this context.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No: This is a physical medical device (an endoscope) with an accompanying camera control unit. It is not an algorithm that performs standalone diagnostic tasks. The closest equivalent would be the "Software Verification and Validation Testing" for the F88 Flexible Camera Control Unit (FCCU), but this only validates the software's functionality, not its diagnostic accuracy in a standalone capacity.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not Applicable/Not Provided: For a ureteroscope seeking 510(k) clearance based on substantial equivalence, the "ground truth" is typically the established safety and effectiveness of the predicate device and the adherence of the new device to relevant performance standards and engineering specifications. No diagnostic "ground truth" data was used for a clinical performance evaluation.
-
The sample size for the training set:
- Not Applicable/Not Provided: This device is not an AI algorithm that requires a "training set" of data.
-
How the ground truth for the training set was established:
- Not Applicable/Not Provided: No training set was used.
Summary of what the document does describe:
The study proving the device meets its "acceptance criteria" (which are more focused on safety, functional performance, and technological equivalence) consists of a comprehensive suite of non-clinical tests:
- Biocompatibility Testing: According to ISO 10993-1 and FDA guidance, including cytotoxicity, sensitization, irritation, acute systemic toxicity, and material mediated pyrogenicity.
- Reprocessing Validation: Cleaning, sterilization, and human factors testing.
- Electrical Safety and EMC Testing: Compliance with IEC 60601-1 and IEC 60601-1-2.
- Software Verification and Validation Testing: For the FCCU, following FDA guidance for basic software, including various stages of testing.
- Cybersecurity Testing: Vulnerability assessment and penetration testing following FDA guidance.
- Additional Performance Testing:
- For Ureteroscopes: Design Verification, Simulated Transportation Validation, and Comparative testing with the predicate device.
- For FCCU: Design Verification, EMC, Control Unit Feature Verification, System Reliability Testing, Video Performance and Timing, RF Interference, and Simulated Transportation Validation.
The overall approach relies on demonstrating that the new device is fundamentally similar to a previously cleared device, and that any minor differences do not adversely impact safety or effectiveness, as confirmed by robust non-clinical engineering and safety testing.
FDA 510(k) Clearance Letter - F88 URE-SD/RD Flexible Ureteroscope
Page 1
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
Doc ID # 04017.07.05
May 2, 2025
SG Endoscopy Pte Ltd
℅ Samantha Eakes
Vice President, Regulatory Affairs
Eliquent Life Sciences
1055 Thomas Jefferson St.
Suite 450
Washington, District of Columbia 20007
Re: K243894
Trade/Device Name: F88 URE-SD/RD Flexible Ureteroscope
Regulation Number: 21 CFR 876.1500
Regulation Name: Endoscope and accessories
Regulatory Class: II
Product Code: FGB
Dated: December 18, 2024
Received: April 11, 2025
Dear Samantha Eakes:
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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K243894 - Samantha Eakes Page 2
(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 (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-reporting-combination-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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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
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K243894 - Samantha Eakes Page 3
the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/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,
Mark R. Kreitz -S
for Mark J. Antonino, M.S.
Assistant Director
DHT3B: Division of Reproductive,
Gynecology, and Urology Devices
OHT3: Office of Gastrorenal, ObGyn,
General Hospital, and Urology Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
Page 4
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.
Indications for Use
Submission Number (if known)
K243894
Device Name
F88 URE-SD/RD Flexible Ureteroscope
Indications for Use (Describe)
The F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit are indicated for endoscopic examination in the urinary tract and can be used to examine the interior of the kidney, and using additional accessories, to perform various diagnostic and therapeutic 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)
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."
Page 5
510(k) Summary for the F88 URE-SD/RD Flexible Ureteroscope
SG Endoscopy Pte Ltd
I. SUBMITTER
SG Endoscopy Pte Ltd.
Address: 79 Loyang Way, Singapore, 508766
Contact: John Woo Yeng Jie, Director
Phone Number: +65 8518 3338
Date Prepared: December 18, 2024
II. DEVICE
Name of Device: F88 URE-SD/RD Flexible Ureteroscope
Common or Usual Name: Flexible Ureteroscope
Classification Name: Endoscope and Accessories (21 CFR 876.1500)
Regulatory Class: Class II
Product Code: FGB – Ureteroscope and Accessories, Flexible/Rigid
III. PREDICATE DEVICE
510(k) Number: K141250
Submitter: Karl Storz Endoscopy-America, Inc.
Name of Device: Flexible Video-Uretero-Renoscope System
Common or Usual Name: Flexible Ureteroscope
Classification Name: Endoscope and Accessories (21 CFR 876.1500)
Regulatory Class: Class II
Product Code: FGB – Ureteroscope and Accessories, Flexible/Rigid
IV. DEVICE DESCRIPTION
F88 URE-SD/RD Flexible Ureteroscope
The F88 URE-SD Flexible Ureteroscope, Standard Deflection and the F88 URE-RD Flexible Ureteroscope, Reverse Deflection (both also collectively referred to as the "F88 URE-SD/RD Flexible Ureteroscope") is a handheld flexible ureteroscope with a flexible insertion portion length of 670 mm and a maximum outer diameter of 3.05 mm. The device includes a working channel of 1.2 mm diameter for the insertion of various compatible flexible instruments and irrigation systems. The distal tip is equipped with a CMOS imaging sensor and an LED light source for live videos. The control body has a deflection lever to deflect the distal tip up to at least 270° in the up or down directions for navigation and access to targeted areas. The push buttons can be programmed to perform functions such as white balance, brightness, picture, record, zoom and to provide access to the setup menu.
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The standard deflection (SD) and reverse deflection (RD) models are functionally identical, with one primary difference: the direction of the distal tip deflection in response to the deflection lever's movement. When the deflection lever of the standard model moves upward, the distal tip deflects upward. In the reverse model, when the deflection lever moves upward, the distal tip deflects downward. The model is selected depending on the handling preference of the user.
The F88 URE-SD/RD Flexible Ureteroscope is a reusable device.
The F88 URE-SD/RD Flexible Ureteroscope is compatible for use with the F88 Flexible Camera Control Unit (FCCU) and several accessories, listed below:
- Single Luer Stopcock
- Vent Cap with Sterilization Card
- Manual Leak Tester
- Luer Port Cleaning Brush
- Cleaning Brush
- URE Working Channel Cleaning Brush
F88 Flexible Camera Control Unit (FCCU)
The F88 Flexible Camera Control Unit (FCCU) or F88 flexible camera console is a device that processes and produces live video images during endoscopic procedures. It is used together with the F88 URE-SD/RD Flexible Ureteroscope and compatible surgical display monitors to form the F88 Flexible Camera System.
V. INDICATIONS FOR USE
The F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit are indicated for endoscopic examination in the urinary tract and can be used to examine the interior of the kidney, and using additional accessories, to perform various diagnostic and therapeutic procedures.
VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The subject device, the F88 URE-SD/RD Flexible Ureteroscope, and the predicate device, the Karl Storz Flexible Video-Uretero-Renoscope, have the identical intended use and indications for use and very similar technological characteristics. The differences in technological characteristics between the two devices are minor and do not raise different questions of safety and effectiveness. Comprehensive performance testing has been conducted on the subject device to address the minor differences in technological characteristics and to demonstrate that the subject device performs as intended and has
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the same or better performance than the predicate device. This includes comparative testing with the predicate device.
| Device | Flexible video endoscope with video processor (Subject device) | Flexible Video-Uretero-Renoscope System (Predicate device) | Comparison |
|---|---|---|---|
| Trade Name | F88 URE-SD/RD Flexible Ureteroscope | FLEX-XC Flexible Video-Uretero-Renoscope System | N/A |
| 510(k) Number | TBD | K141250 | N/A |
| Device Classification | Class II | Class II | Identical |
| FDA Regulation number | 21 CFR 876.1500 | 21 CFR 876.1500 | Identical |
| Product Code | FGB | FGB | Identical |
| Indications for Use | The F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit are indicated for endoscopic examination in the urinary tract and can be used to examine the interior of the kidney and using additional accessories, to perform various diagnostic and therapeutic procedures. | The KARL STORZ Flexible Video-Uretero-Renoscope System is indicated for endoscopic examination in the urinary tract and can be used to examine the interior of the kidney, and using additional accessories, to perform various diagnostic and therapeutic procedures. | Identical (except for device names) |
| Patient contact materials | Biocompatible materials | Biocompatible materials | Similar. Biocompatibility testing was successfully conducted in accordance with ISO 10993-1 on all patient contacting materials |
| Reusable | Yes | Yes | Identical |
| Sterilization method | Vaporized Hydrogen Peroxide | Vaporized Hydrogen Peroxide | Identical |
| No. of working channel(s) | 1 | 1 | Identical |
| Working channel diameter | 1.2mm | 1.2mm | Identical |
| Working channel length | 670 mm | 675 mm | Similar. The minor difference in working length does not affect safety or effectiveness. Performance testing demonstrated that the subject device met its required specifications. |
| Outer Diameter of distal tip | 9.15 Fr | 8.5 Fr | Similar. The minor difference in outer diameter |
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| Device | Flexible video endoscope with video processor (Subject device) | Flexible Video-Uretero-Renoscope System (Predicate device) | Comparison |
|---|---|---|---|
| Outer Diameter of insertion tube | 2.85 mm | 2.9 mm | Similar. The minor difference in outer diameter of the insertion tube does not affect safety or effectiveness. Performance testing demonstrated that the subject device met its required specifications. |
| Configuration | F88 URE-SD > Standard Deflection; F88 URE-RD > Reverse Deflection | 11278 VSA > Positive Deflection; 11278 VSUA > Contrapositive Deflection | Identical. Both ureteroscopes are available in standard and reverse deflection models. |
| Deflection angles | ≥ 270° Up / ≥ 270° Down | ≥ 270° Up / ≥ 270° Down | Identical |
| Image sensor at distal tip | CMOS | CMOS | Identical |
| Light source | LED integrated in handle | LED integrated in handle | Identical |
| Direction of view | 0° | 0° | Identical |
| Field of view (diagonal) | 106° | 90° | Similar. The subject device has a slightly wider field of view. This difference does not affect safety or effectiveness. |
| Depth of view | 2 – 50 mm | 4 – 60 mm | Similar. The difference in depth of view is minor and does not affect safety or effectiveness. The depth of view of the subject device is within the range for other 510(k) cleared ureteroscopes. |
| Powered by | FCU-200 | IMAGE 1 S X-LINK (TC301); IMAGE 1 S CONNECT (TC 200) | Similar. Each device is powered by its own method specific to the device. The difference in power source does not impact safety and effectiveness. |
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| Power source | 100 – 240VAC 50 – 60Hz | 100 – 240VAC 50 – 60Hz | Identical |
|---|---|---|---|
| White balance | Manual | Manual | Identical |
| Brightness control | Yes | Yes | Identical |
| Image enhancement | Yes | Yes | Identical |
| Image/Video capture | No | Yes | Different. Unlike the predicate device, the subject device is designed to not store any images or video recordings. This difference does not impact safety and effectiveness. |
| Record to memory card | No | USB Flash Drive 32 GB | Different. Unlike the predicate device, the subject device does not have a feature to record data to a memory card. This difference does not impact safety and effectiveness. |
| Water ingress protection | IPX0 | IPX0 | Identical |
VII. PERFORMANCE DATA
The following performance testing was successfully completed for the F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit (FCCU) to establish the safe and effective use of the device and to demonstrate substantial equivalence to the predicate device:
Biocompatibility Testing:
The biocompatibility evaluation for the F88 URE-SD/RD Flexible Ureteroscope was conducted in accordance with ISO 10993-1 and FDA's guidance, Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process." The device is considered an external communicating device, tissue/bone/dentin contacting with a limited contact duration < 24 hours. Testing was conducted on both non-sterile and cleaned/sterilized devices reprocessed after the recommended number of reprocessing cycles. Testing included the following:
- Cytotoxicity
- Sensitization
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- Irritation
- Acute Systemic Toxicity
- Material Mediated Pyrogenicity
Cytotoxicity testing was also conducted for the Single Luer Stopcock.
Reprocessing Validation:
Reprocessing validation including cleaning and sterilization validation and human factors testing was completed for the F88 URE-SD/RD Flexible Ureteroscope. Cleaning validation was completed for the F88 Flexible Camera Control Unit (FCCU). Steam Sterilization Validation was also completed for the Single Luer Stopcock.
Electrical Safety and Electromagnetic Compatibility (EMC):
Electrical Safety and EMC testing was completed for the F88 Flexible Camera Control Unit (FCCU). The device complies with the IEC 60601-1 standard for electrical safety and the IEC 60601-1-2 standard for EMC.
Software Verification and Validation Testing:
Software verification and validation testing was completed for the F88 Flexible Camera Control Unit (FCCU), and documentation was provided in accordance with FDA's guidance, Content of Premarket Submissions for Device Software Functions. The software documentation level was basic. Software testing included system verification, installation testing, integration testing, unit testing and user acceptance testing.
Cybersecurity Testing:
Cybersecurity testing was completed for the F88 Flexible Camera Control Unit (FCCU), and documentation was provided in accordance with FDA's guidance, Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions. A vulnerability assessment was conducted, and penetration testing was completed.
Additional Performance Testing:
Additional performance testing was completed for the F88 URE-SD/RD Flexible Ureteroscope and the F88 Flexible Camera Control Unit (FCCU) as outlined below:
F88 URE-SD/RD Flexible Ureteroscope
- Design Verification
- Simulated Transportation Validation in accordance with ASTM D4169-23e1
- Comparative testing with the predicate device
F88 Flexible Camera Control Unit (FCCU)
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- Design Verification
- Electromagnetic Compatibility in accordance with IEC 60601-1-2:2014+A1:2020 (Ed4.1) and IEC TR 60601-4-2
- Control Unit Feature Verification
- System Reliability Testing
- Video Performance and Timing
- RF Interference
- Simulated Transportation Validation in accordance with ASTM D4169-23e1
Animal Testing:
Animal testing was not required to demonstrate substantial equivalence to the predicate device.
Clinical Testing:
Clinical testing was not required to demonstrate substantial equivalence to the predicate device.
VIII. CONCLUSIONS
The information provided in this 510(k) submission demonstrates that the F88 URE-SD/RD Flexible Ureteroscope has the identical indications for use and the same overall technological characteristics as the predicate device. The performance testing demonstrates that the device is as safe, as effective, and performs as well or better than the predicate device. In conclusion, the subject device is substantially equivalent to the predicate device, the Karl Storz Flexible Video-Uretero-Renoscope (K141250).
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§ 876.1500 Endoscope and accessories.
(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.