K Number
K251082
Date Cleared
2025-10-10

(184 days)

Product Code
Regulation Number
876.4350
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.

Device Description

The HYDROS Robotic System has three components – the HYDROS Robotic System, HYDROS TRUS Probe, and HYDROS Handpiece.

  1. HYDROS Robotic System
    The HYDROS Robotic System, consists of the following nine components:
  • HYDROS Tower
  • Touchscreen Interfaces - Monitor that supports the Tower Monitor (Tmon) and Surgeon Monitor (Smon)
  • HYDROS Software
  • HYDROS Operating System
  • Embedded Software
  • Motorpack
  • Handpiece Arm
  • TRUS Probe Arm
  • Foot Pedal

The HYDROS Robotic System is provided non-sterile, and no sterilization is required prior to each use. The Tower, Foot Pedal, Roll Stand, Articulating Arms, and Motorpack are reprocessed per instructions provided with the device after each use. The HYDROS Robotic System does not come in contact with the patients during the procedure.

  1. HYDROS TRUS Probe
    The HYDROS TRUS Probe is a biplane transrectal ultrasound probe that is used in the conjunction with the HYDROS Robotic System and HYDROS Handpiece to provide ultrasound imaging to deliver the AQUABLATION procedure. The HYDROS TRUS Probe is re-usable and provided non-sterile. It is reprocessed prior to each use as per the instructions provided in the IFU.

  2. HYDROS Handpiece
    The HYDROS Handpiece is the single-use sterile surgical device introduced to the surgical site within the prostate through the urethra to visualize, resect and remove prostatic tissue. The HYDROS Handpiece is integrated with a digital CMOS Scope and is terminally sterilized by EtO.

AI/ML Overview

The provided document is a 510(k) Clearance Letter and 510(k) Summary for the HYDROS Robotic System. This type of FDA submission focuses on demonstrating substantial equivalence to a predicate device, rather than providing detailed clinical study results and acceptance criteria for specific AI/ML components as one might find in a De Novo or PMA submission.

Therefore, the document does not contain all the requested information for the acceptance criteria and the study proving the device meets those criteria, particularly for the AI/ML aspects. It only states that the AI/ML component "Passes" FDA guidance.

However, based on the information provided, here's what can be extracted and inferred:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state acceptance criteria in quantitative terms for the AI/ML features. Instead, it indicates that the AI/ML component passed relevant FDA guidance.

Feature AreaAcceptance Criteria (from document)Reported Device Performance (from document)
FirstAssist AI™Complies with FDA Guidance for AI/ML in Medical Device Development."Pass" (referring to compliance with FDA Guidance: Clinical Performance Assessment: Considerations for Computer-Assisted Detection Devices Applied to Radiology Images and Radiology Device Data in Premarket Notification (510(k)) Submissions; Computer-Assisted Detection Devices Applied to Radiology Images and Radiology Device Data - Premarket Notification [510(k)] Submissions; Good Machine Learning Practice for Medical Device Development: Guiding Principles)
Overall SystemMeets applicable standards and guidance documents for non-clinical tests."Pass" for all listed non-clinical bench tests (System Verification, Usability, EMC, Basic Safety, Wireless, Sterilization, Biocompatibility, Packaging, Shelf Life, Reliability, Labeling, Reprocessing, Corrosion, Cystoscope Imaging, Ultrasound Imaging, Cybersecurity, Software).

Limitations: The document does not provide specific performance metrics (e.g., accuracy, sensitivity, specificity, or localization error thresholds) as acceptance criteria for the FirstAssist AI™ feature, nor does it present quantitative results. The "Pass" indicates general compliance with regulatory expectations for a 510(k) AI/ML submission.

2. Sample Size Used for the Test Set and Data Provenance

The document does not specify the sample size used for the test set or the data provenance (e.g., country of origin, retrospective/prospective) for the AI/ML components. It only mentions "non-clinical performance data" and "simulated use testing and cadaver testing" for overall system validation, but these don't specifically refer to the AI/ML test set.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

The document does not provide information on the number of experts used to establish ground truth or their qualifications for the AI/ML test set.

4. Adjudication Method for the Test Set

The document does not specify any adjudication method used for the test set, particularly for the AI/ML component.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

The document does not mention a Multi-Reader Multi-Case (MRMC) comparative effectiveness study. It also does not provide any effect size for human readers improving with AI assistance. The AI feature ("FirstAssist AI™") is described as "optional" assistance during the PLAN step for displaying nozzle position, prostate capsule boundary, and placing landmarks, implying it's a tool for surgeons rather than a primary diagnostic AI.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) was Done

The document implicitly suggests a standalone component analysis for the AI/ML feature by stating it "provides the handpiece nozzle position and the prostate capsule boundary" and "will place the 4 landmarks." However, detailed standalone performance metrics (e.g., how accurate the AI's landmark placement is without human correction, or the performance of the AI in identifying boundaries) are not provided. The description focuses on its function as an assistive tool, implying human review and adjustment.

7. The Type of Ground Truth Used

The document does not explicitly state the type of ground truth used for the AI/ML component. Given the nature of prostate anatomy and procedural planning in a surgical context, it could involve expert anatomical annotation on imaging data, but this is not specified.

8. The Sample Size for the Training Set

The document does not provide the sample size used for the training set of the AI/ML model.

9. How the Ground Truth for the Training Set was Established

The document does not describe how the ground truth for the training set was established for the AI/ML model.

Summary of AI/ML Specifics from the Document:

  • Feature Name: FirstAssist AI™ (previously Assisted Planning)
  • Functionality:
    • Transverse view: Provides handpiece nozzle position and prostate capsule boundary.
    • Sagittal view: Places 4 landmarks (treatment start (TS), bladder neck (BN), mid-prostate (MP), and treatment end (TE)).
  • User Interaction: The surgeon has the option to adjust the landmarks as needed.
  • Change from Predicate: The subject device has an "updated AI model for the same functionality of landmark identification."
  • Regulatory Status: "Passes" FDA Guidance for AI/ML.

In conclusion, while the document confirms the HYDROS Robotic System has an AI/ML component ("FirstAssist AI™") and was cleared based on non-clinical performance and equivalence to a predicate, it lacks the detailed quantitative acceptance criteria and study particulars for the AI/ML model itself that would typically be found in a more comprehensive clinical validation report. The "Pass" for AI/ML indicates compliance with the regulatory requirements pertinent to a 510(k) submission, which often rely on demonstration of similar performance to a predicate or adherence to recognized performance standards rather than extensive de novo clinical studies specifically for the AI component's accuracy.

FDA 510(k) Clearance Letter - HYDROS Robotic System

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov

Doc ID # 04017.08.00

October 10, 2025

Procept BioRobotics
Bijesh Chandran
Senior Vice President, Regulatory Affairs and Quality Assurance
150 Baytech Drive
San Jose, California 95134

Re: K251082
Trade/Device Name: HYDROS Robotic System (HY1000); HYDROS Handpiece (HH1000); HYDROS TRUS Probe (HU1000)
Regulation Number: 21 CFR 876.4350
Regulation Name: Fluid Jet System For Prostate Tissue Removal
Regulatory Class: Class II
Product Code: PZP, ITX
Dated: September 14, 2025
Received: September 15, 2025

Dear Bijesh Chandran:

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

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K251082 - Bijesh Chandran Page 2

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 (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).

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K251082 - Bijesh Chandran Page 3

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-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 J. ANTONINO -S

Mark 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

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FORM FDA 3881 (8/23) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.

510(k) Number (if known): K251082

Device Name:
HYDROS Robotic System (HY1000)
HYDROS Handpiece (HH1000)
HYDROS TRUS Probe (HU1000)

Indications for Use (Describe):
The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.

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."

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PROCEPT BioRobotics Corporation · 150 Baytech Drive · San Jose, CA 95134
office: +1.650.232.7200 · info@PROCEPT-BioRobotics.com

510(k) SUMMARY

Date Prepared: Sep 12, 2025

Owner/SponsorPROCEPT BioRobotics Corporation150 Baytech Drive,San Jose, 95134USA
SubmitterContact Name: Bijesh ChandranTitle: SVP, Regulatory Affairs and Quality AssuranceAddress: 150 Baytech Drive, San Jose, CA 95134, USATelephone: (650) 232-7203Email: b.chandran@procept-biorobotics.com
Trade Name1. HYDROS™ Robotic System2. HYDROS™ TRUS Probe3. HYDROS™ Handpiece
ClassificationClass II
Classification NameFluid jet system for prostate tissue removal
Product CodePZP
Regulation Number21 CFR 876. 4350

K251082
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Predicate Device

1. Primary Predicate¹

Trade Name - HYDROS™ Robotic System
510(k) Number - K240200 cleared on August 20, 2024.
Product Code – PZP
Regulation Number: 876. 4350
Device Classification - Class II

Device Description

The HYDROS™ Robotic System has three components – the HYDROS Robotic System, HYDROS TRUS Probe, and HYDROS Handpiece.

1. HYDROS Robotic System

The HYDROS Robotic System, consists of the following nine components:

  • HYDROS Tower
  • Touchscreen Interfaces - Monitor that supports the Tower Monitor (Tmon) and Surgeon Monitor (Smon)
  • HYDROS Software
  • HYDROS Operating System
  • Embedded Software
  • Motorpack
  • Handpiece Arm
  • TRUS Probe Arm
  • Foot Pedal

The HYDROS Robotic System is provided non-sterile, and no sterilization is required prior to each use. The Tower, Foot Pedal, Roll Stand, Articulating Arms, and Motorpack are reprocessed per instructions provided with the device after each use. The HYDROS Robotic System does not come in contact with the patients during the procedure.

2. HYDROS TRUS Probe

The HYDROS TRUS Probe is a biplane transrectal ultrasound probe that is used in the conjunction with the HYDROS Robotic System and HYDROS Handpiece to provide ultrasound imaging to deliver the AQUABLATION procedure. The HYDROS TRUS Probe is re-usable and provided non-sterile. It is reprocessed prior to each use as per the instructions provided in the IFU.

3. HYDROS Handpiece

The HYDROS Handpiece is the single-use sterile surgical device introduced to the surgical site within the prostate through the urethra to visualize, resect and remove prostatic tissue. The HYDROS Handpiece is integrated with a digital CMOS Scope and is terminally sterilized by EtO.

¹ The predicate device has not been subject to any design related recall.

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Intended Use/Indications for Use

The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.

Intended Patient Population

The intended patient population is males suffering from LUTS resulting from benign prostatic hyperplasia (BPH).

Intended Users

The intended user shall be a urologist, supported by OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.

Technological Comparison as compared to the Predicate Device

HYDROS ROBOTIC SYSTEM

COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Device Trade NameHYDROS® Robotic SystemHYDROS® Robotic System
ManufacturerPROCEPT BioRobotics CorporationPROCEPT BioRobotics Corporation
REF/Model NumberHY1000HY1000
Pre-Market Notification TypeTraditional 510(k)Traditional 510(k)
510(k) numberK251082K240200
Regulation Number21 CFR 876.435021 CFR 876.4350
Regulation NameFluid jet system for prostate tissue removalFluid jet system for prostate tissue removal
Product ClassificationClass IIClass II
Product CodePZPPZP
Intended Use/Indications for UseThe HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.
Intended UserThe intended user shall be a urologist, supported byThe intended user shall be a urologist, supported by OR

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.
Patient PopulationMales suffering from LUTS resulting from benign prostatic hyperplasia (BPH).Males suffering from LUTS resulting from benign prostatic hyperplasia (BPH).
Intended Body/Tissue InteractionThe HYDROS Robotic System is not patient contacting.The HYDROS Robotic System is not patient contacting.
Operating EnvironmentTemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPATemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPA
Storage EnvironmentTemperature: 10° to 30°Humidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPATemperature: 10° to 30°Humidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPA
Transportation EnvironmentTemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60 kPA to 106 kPATemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60 kPA to 106 kPA
Cleaning and Disinfection MethodClean using quaternary ammonium –based cleaner and disinfect using intermediate level disinfectant.Clean using quaternary ammonium –based cleaner and disinfect using intermediate level disinfectant.
Use Life1 year1 year

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Surgeon Interface- Two monitors for display – one surgeon monitor (Smon) for use in the sterile environment and the tower monitor (Tmon) which can be used by support staff.- Portrait view- Interaction is through touchscreen.- Physician authorization is enabled on the surgeon monitor or by pressing the + button on the motorpack.- Two monitors for display – one surgeon monitor (Smon) for use in the sterile environment and the tower monitor (Tmon) which can be used by support staff.- Portrait view- Interaction is through touchscreen.- Physician authorization is enabled only on the surgeon monitor.
UltrasoundIntegrated ultrasound and a compatible TRUS probe is provided with the HYDROS Robotic System.Integrated ultrasound and a compatible TRUS probe is provided with the HYDROS Robotic System.
Cystoscope ImagingThe CMOS scope connects to the HYDROS Robotic System and specifically the camera control unit (CCU) located within the tower infrastructure of the device for cystoscope image processing.The CMOS scope connects to the HYDROS Robotic System and specifically the camera control unit (CCU) located within the tower infrastructure of the device for cystoscope image processing.
Maximum angle rotation225 degrees225 degrees
Maximum depth of penetration24.3 mm24.3 mm
Network Connection CapabilityThe HYDROS Robotic System component (PC) includes a Wi-Fi card that creates network connection capability.The HYDROS Robotic System component (PC) includes a Wi-Fi card that creates network connection capability.
Cloud Connection + Wi-Fi connectionThe software allows enabling and disabling the cloud connection on the Wi-Fi connected systems.The software allows enabling and disabling the cloud connection on the Wi-Fi connected systems.

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
FirstAssist AI™ (previously Assisted Planning) FeatureOptional FirstAssist AI feature available during the PLAN step.FirstAssist AI, Transverse: When the FirstAssist AI toggle button is enabled in the transverse view at the angle and depth step, the software provides the handpiece nozzle position and the prostate capsule boundary.FirstAssist AI, Sagittal: When the FirstAssist AI toggle button is enabled at the profile landmark step the software will place the 4 landmarks – treatment start (TS), blader neck (BN), mid-prostate (MP) and treatment end (TE). The surgeon has the option to adjust the landmarks as needed. The subject device has an updated AI model for the same functionality of landmark identification.Optional FirstAssist AI feature available during the PLAN step.FirstAssist AI, Transverse: When the FirstAssist AI toggle button is enabled in the transverse view at the angle and depth step, the software provides the handpiece nozzle position and the prostate capsule boundary.FirstAssist AI, Sagittal: When the FirstAssist AI toggle button is enabled at the profile landmark step the software will place the 4 landmarks – treatment start (TS), blader neck (BN), mid-prostate (MP) and treatment end (TE). The surgeon has the option to adjust the landmarks as needed.
Workflow OptimizationGUI Steps:• Setup – includes TRUS, Handpiece and Align• Plan -includes Manual and optional FirstAssist AI TransverseGUI Steps:• Setup – includes TRUS, Handpiece and Align• Plan -includes Manual and optional FirstAssist AI Transverse Angle and Depth planning options, registration,

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Angle and Depth planning options, registration, Manual and Optional FirstAssist AI profile options for Sagittal Plane and Contour.• Treat – includes treatment with the options for starting an additional pass or completing the procedure.Manual and Optional FirstAssist AI profile options for Sagittal Plane and Contour.• Treat – includes treatment with the options for starting an additional pass or completing the procedure.
Manual Aspiration Flow RateDuring Resection: Nominal Waterjet Flow + 10ml/minManual: 360±75ml/min = [285, 435]During Resection: Nominal Waterjet Flow + 10ml/minManual: 360±75ml/min = [285, 435]
Verumontanum protection orientation• Transverse Plane - The user cannot modify the default orientation of the verumontanum protection zone.• Sagittal Plane - The user has the ability to modify the length of the verumontanum protection zone.• Transverse Plane - The user cannot modify the default orientation of the verumontanum protection zone.• Sagittal Plane - The user has the ability to modify the length of the verumontanum protection zone.

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HYDROS TRUS PROBE

COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Device Trade NameHYDROS TRUS ProbeHYDROS TRUS Probe
ManufacturerPROCEPT BioRobotics CorporationPROCEPT BioRobotics Corporation
REF/Model NumberHU1000HU1000
Pre-Market Notification InformationTraditional 510(k)Traditional 510(k)
510(k) numberK251082K240200
Regulation Number21 CFR 876.435021 CFR 876.4350
Regulation NameFluid jet system for prostate tissue removalFluid jet system for prostate tissue removal
Product ClassificationClass IIClass II
Product CodePZP, ITXPZP. ITX
Intended Use/Indications for UseThe HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.
Intended UserThe intended user shall be a urologist, supported by OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.The intended user shall be a urologist, supported by OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.
Patient PopulationMales suffering from LUTS resulting from benign prostatic hyperplasia (BPH).Males suffering from LUTS resulting from benign prostatic hyperplasia (BPH).
Intended Body/Tissue interactionThe HYDROS TRUS probe may come in contact with the rectal tissue.Tissue/Bone/Dentin per ISO 10993-1:2018, Table A.1The HYDROS TRUS probe may come in contact with the rectal tissue.Tissue/Bone/Dentin per ISO 10993-1:2018, Table A.1

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HYDROS TRUS PROBE

COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Duration of ContactThe HYDROS TRUS probe is considered an Externally communicating medical device. The HYDROS TRUS probe is used as part of the Aquablation procedure which lasts about 30 minutes, so the TRUS probe has Limited Exposure (≤24hr).The HYDROS TRUS probe is considered an Externally communicating medical device. The HYDROS TRUS probe is used as part of the Aquablation procedure which lasts about 30 minutes, so the TRUS probe has Limited Exposure (≤24hr).
Mode of ActionB modeB mode
Surface Area (patient contacting portion of the probe only)~276 Sq.cm~276 Sq.cm
Plane SwitchingThe handle interface of the HYDROS TRUS probe provides a button to switch ultrasound visualization planes between transverse and sagittal planesThe handle interface of the HYDROS TRUS probe provides a button to switch ultrasound visualization planes between transverse and sagittal planes
ConnectionProbe is plugged into the HYDROS Robotic System with one connectorProbe is plugged into the HYDROS Robotic System with one connector
Length of the connector cable~220 cm~220 cm
MaterialsHYDROS TRUS probe material information:- Hard Shell: ABS Plastic- Transducer portion of the probe: Silicone- Plane Switching Button: SiliconeHYDROS TRUS probe material information:- Hard Shell: ABS Plastic- Transducer portion of the probe: Silicone- Plane Switching Button: Silicone
ReprocessingReprocessing is required prior to each use and instructions are provided in the instructions for use (IFU) shipped with device.Addition of two reprocessing methods to the TRUS Probe IFU:1. Disinfection using CIDEX™ OPA (ASP™).Reprocessing is required prior to each use and instructions are provided in the instructions for use (IFU) shipped with device.

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
2. Sterilization using STERIS V-Pro maX Non-Lumen cycle.
Operating EnvironmentTemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70kPA to 101kPATemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70kPA to 101kPA
Storage EnvironmentTemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70kPA to 101kPATemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70kPA to 101kPA
Transportation EnvironmentTemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60kPA to 106kPATemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60kPA to 106kPA
Use LifeThe users are instructed to perform visual and functional inspection post reprocessing and prior to each use however, the device is validated for 71 cycles of reprocessing.The users are instructed to perform visual and functional inspection post reprocessing and prior to each use however, the device is validated for 25 cycles of reprocessing.

HYDROS HANDPIECE

COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Device Trade NameHYDROS HandpieceHYDROS Handpiece
ManufacturerPROCEPT BioRobotics CorporationPROCEPT BioRobotics Corporation
REF/Model NumberHH1000HH1000
Pre-Market Notification InformationTraditional 510(k)Traditional 510(k)
510(k) numberK251082K240200
Regulation Number21 CFR 876.435021 CFR 876.4350

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Regulation NameFluid jet system for prostate tissue removalFluid jet system for prostate tissue removal
Product ClassificationClass IIClass II
Product CodePZPPZP
Intended Use/Indications for UseThe HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.The HYDROS Robotic System is indicated for the resection and removal of prostate tissue in males suffering from lower urinary tract symptoms (LUTS) due to benign prostatic hyperplasia.
Intended UserThe intended user shall be a urologist, supported by OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.The intended user shall be a urologist, supported by OR staff, trained and familiar with performing endoscopic surgical procedures for BPH, such as TURP, and in recognizing and managing their complications. The intended user shall also be trained and familiar with TRUS imaging.
Patient PopulationMales suffering from LUTS resulting from benign prostatic hyperplasia (BPH)Males suffering from LUTS resulting from benign prostatic hyperplasia (BPH)
Intended Body/Tissue InteractionThe HYDROS Handpiece shall be used endoscopically accessing the prostate via the urethra (external communicating device, tissue/bone/dentin, with limited exposure (<24 hours).The HYDROS Handpiece shall be used endoscopically accessing the prostate via the urethra (external communicating device, tissue/bone/dentin, with limited exposure (<24 hours).
BiocompatibilityThe device was tested for biocompatibility as per the ISO 10993-1 standard and it was reported to be biocompatible.The device was tested for biocompatibility as per the ISO 10993-1 standard and it was reported to be biocompatible.
Sterilization methodEthylene Oxide Sterilization (ETO)SAL 10-6Ethylene Oxide Sterilization (ETO)SAL 10-6
Operating EnvironmentTemperature: 10° to 30° CTemperature: 10° to 30° C

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
Humidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPAHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPA
Storage EnvironmentTemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPATemperature: 10° to 30° CHumidity: 20% to 80%, non-condensingAtmospheric Pressure: 70 kPA to 101 kPA
Transportation EnvironmentTemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60 kPA to 106 kPATemperature: -18° to 60° CHumidity: 15% to 90%, non-condensingAtmospheric Pressure: 60 kPA to 106 kPA
Shelf Life of the Handpiece24 months6 months
Use Life of the scopeSingle useSingle use
ScopeThe CMOS Scope is a digital scope and comes pre-loaded in the HYDROS Handpiece. This CMOS Scope is a single-use device and provided sterile.The CMOS Scope is a digital scope and comes pre-loaded in the HYDROS Handpiece. This CMOS Scope is a single-use device and provided sterile.
Maximum angle rotation225 degrees225 degrees
Maximum depth of penetration24.3 mm24.3 mm
Resolving Power(MTF)• >80% contrast at 80 lp/ph (8 lp/mm object space) @5mm• >80% contrast at 80 lp/ph (5.3 lp/mm object space) @8mm(MTF)• >80% contrast at 80 lp/ph (8 lp/mm object space) @5mm• >80% contrast at 80 lp/ph (5.3 lp/mm object space) @8mm
Field of ViewMinimum of 60° FoVMinimum of 60° FoV
Working Length24.5cm ≥ working length ≤ 27.0cmMaximum = 24 Fr24.5cm ≥ working length ≤ 27.0cmMaximum = 24 Fr
PackagingHYDROS Handpiece will be packaged in a thermoformed Tray and Retainer manufactured using PETG.HYDROS Handpiece will be packaged in a thermoformed Tray and Retainer manufactured using PETG.

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COMPARISON ELEMENTSUBJECT DEVICEPREDICATE DEVICE
The tray and the retainer are heat sealed using a Tyvek lid.The tray and the retainer are heat sealed using a Tyvek lid.

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Non-Clinical Performance Data

Design validation included simulated use testing and cadaver testing.

Please see table below for testing conducted in accordance with applicable standards and guidance documents on the HYDROS Robotic System and its components.

Summary of non-clinical testing in accordance with applicable standards and guidance documents

Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
System VerificationFDA GuidanceGuidance for the Non‐Clinical and Clinical Investigation of Devices Used for the Treatment of Benign Prostatic Hyperplasia (BPH)Pass
UsabilityIEC 62366-1:2015/COR1:2016Medical devices – Part 1: Application of usability engineering to medical devicesPass
ANSI/AAMI HE75:2009 (R2018)Human Factors Engineering - Design Of Medical Devices
Electromagnetic CompatibilityIEC60601-1-2:2020Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic disturbances - Requirements and testsPass
IEC TR 60601-4-2Medical electrical equipment - Part 4-2: Guidance and interpretation - Electromagnetic immunity: performance of medical electrical equipment and medical electrical systems
Basic SafetyIEC 60601-1:2020Medical electrical equipment - Part 1: General requirements for basic safety and essential performancePass
IEC 60601-2-37 Edition 2.1 2015Medical electrical equipment - Part 1: General requirements for basic safety and essential performance

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Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
IEC 60601-1-6:2020Medical electrical equipment Part 1-6: General requirements for basic safety and essential performance – Collateral standard:Usability
IEC 60601-2-18: 2009Medical electrical equipment - Part 2-18: Particular requirements for the basic safety and essential performance of endoscopic equipment
IEC 80601-2-77: 2019Medical electrical equipment - Part 2-77: Particular requirements for the Basic Safety and essential performance of Robotically Assisted Surgical Equipment (RASE)
WirelessAAMI TIR69:2017/(R2020)Technical Information Report Risk Management of radio-frequency wireless coexistence for medical devices and systemsPass
FDA GuidanceRadio Frequency Wireless Technology in Medical Devices
SterilizationEN ISO 11135:2014 + AMD 1: 2019Sterilization of health-care products — Ethylene oxide — Requirements for the development, validation and routine control of a sterilization process for medical devicesPass
ISO 10993-7:2008 + AMD 1:2019Biological evaluation of medical devices — Part 7: Ethylene oxide sterilization residuals
ISO 11138-1: 2017Sterilization of health care products — Biological indicators — Part 1: General requirements
ISO 11138-2: 2017Sterilization of health care products — Biological

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Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
indicators — Part 2: Biological indicators for ethylene oxide sterilization processes
BS EN 556-1: 2001Sterilization of medical devices – Requirements for medical devices to be designated "STERILE" – Part 1: Requirements for terminally sterilized medical devices
ISO11737-1: 2018+AMD1:2021Sterilization of health care products — Microbiological methods — Part 1: Determination of a population of microorganisms on products
ISO 11737-2: 2019Sterilization of health care products — Microbiological methods — Part 2: Tests of sterility performed in the definition, validation, and maintenance of a sterilization process
ISO 11139: 2018Sterilization of health care products — Vocabulary of terms used in sterilization and related equipment and process standards
ISO 14937:2009Sterilization of health care products – General requirements for characterization of a sterilizing agent and the development, validation, and routine control of a sterilization process for medical devices
AAMI TIR 14: 2016Contract sterilization using ethylene oxide
AAMI TIR 15: 2016Physical aspects of ethylene oxide sterilization
AAMI TIR 16: 2017Microbiological aspects of ethylene oxide sterilization
ISO 14937:2009Sterilization of health care products - General requirements for characterization of a sterilizing agent and the development, validation and routine control of a sterilization process for medical devices
AAMI TIR 28: 2016/(R)2020Product adoption and process equivalence for ethylene oxide sterilization
ISO 11135 Second edition 2014-07-15Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices [Including: Amendment 1 (2018)]
ISO 11737-2 Third edition 2019-12Sterilization of medical devices - Microbiological methods - Part 2: Tests of sterility performed in the definition, validation and maintenance of a sterilization process
BiocompatibilityISO 10993-1:2018Biological evaluation of medical devices - Part1: Evaluation and testing within a risk management processPass
ISO 10993-4:2017Biological evaluation of medical devices – Part 4: Selection of tests for interactions with blood
ISO 10993-5:2009Biological evaluation of medical devices - Part5: Tests for in vitro cytotoxicity
ISO 10993-9: 2019Biological evaluation of medical devices — Part 9: Framework for identification

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Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
and quantification of potential degradation products
ISO 10993-10:2021Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization
ISO 10993-11: 2017Biological evaluation of medical devices – Part 11: Tests for Systemic Toxicity
ISO 10993-12:2021Biological evaluation of medical devices – Part 12: Sample preparation and reference materials
ISO 10993-13:2010Biological evaluation of medical devices — Part 13: Identification and quantification of degradation products from polymeric medical devices
ISO 10993-14:2001Biological evaluation of medical devices — Part 14: Identification and quantification of degradation products from ceramics
ISO 10993-15:2019Biological evaluation of medical devices — Part 15: Identification and quantification of degradation products from metals and alloys
ISO 10993-18:2020Biological evaluation of medical devices – Part 18: Chemical characterization of medical device materials within a risk management process
ISO 10993-23:2021Biological evaluation of medical devices – Part 23: Tests for Irritation
Packaging and TransitISTA 3B: 2017Packaged-Products for Less-Than-Truckload (LTL) ShipmentPass
ASTM D4332-22Standard Practice for Conditioning Containers, Packages, or Packaging Components for Testing
ASTM D4169-22Standard Practice for Performance Testing of Shipping Containers and Systems
ASTM F1886/F1886M-16Standard test method for determining integrity of seals for flexible packaging visual inspection
ASTM F2096-11 (2019)Standard test method for detecting gross leaks in packaging by internal pressurization (bubble test)
ISO 11607-1: 2019Packaging for terminally sterilized medical devices — Part 1: Requirements for materials, sterile barrier systems and packaging systems
ISO 11607-2: 2019Packaging for terminally sterilized medical devices — Part 2: Validation requirements for forming, sealing and assembly processes
Shelf LifeASTM F88/F88- 2023Standard test method for seal strength of flexible barrier materialsPass
ASTM F1980-21Standard guide for Accelerated Aging of Sterile Barrier Systems and Medical Devices
ReliabilityMIL-STD-721CMilitary Standards Definitions of Terms for Reliability and MaintainabilityPass
LabelingISO 15223-1:2021Medical devices - Symbols to be used with medical device labels, labelling andPass

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Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
information to be supplied - Part 1: General requirements
ISO 20417:2021Medical devices — Information to be provided by the manufacturer
ISO 7000:2019Graphical symbols for use on equipment - Registered symbols
ISO 7010 Third edition 2019-07Graphical symbols - Safety colours and safety signs - Registered safety signs
ISO 17664-2 First edition 2021-02Processing 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.
IEC/TR 60878 Ed. 4.0 2022-11Graphical symbols for electrical equipment in medical practice
ISO 17664-1:2021Processing of health care products - Information to be provided by the medical device manufacturer for the processing of medical devicesPart 1: Critical and semi-critical medical devices
FDA GuidanceDevice Labeling Guidance #G91-1 (Blue Book Memo)
FDA GuidanceLabeling - Regulatory Requirements for Medical Devices (FDA 89-4203)
ReprocessingANSI AAMI ST98:2022Cleaning validation of health care products - Requirements for development and validation of a cleaning process for medical devicesPass
AAMI TIR 12:2020Designing, Testing, And Labeling Medical Devices Intended For Processing By Health Care Facilities: A Guide For Device Manufacturers
ASTM F3208-20Standard Guide for Selecting Test Soils for Validation of Cleaning Methods for Reusable Medical Devices
AAMI TIR 99:2024Processing of dilators, transesophageal and ultrasound probes in health care facilities
CorrosionASTM F1089-18Standard Test Method for Corrosion of Surgical InstrumentsPass
Cystoscope ImagingISO 8600-5:2020Optics and photonics - Medical endoscopes and endotherapy devices - Part 5: Determination of optical resolution of rigid endoscopes with opticsPass
ISO 8600-3:2019Endoscopes – Medical endoscopes and endotherapy devices – Part 3: Determination of field of view and direction of view of endoscopes with optics
ISO 8600-1: 2015Endoscopes – medical and endotherapy devices – Part 1: General Requirements
ISO 80369-7:2021Small-bore connectors for liquids and gases in healthcare applications – Part 7: Connectors for intravascular or hypodermic applications
ISO CIE 11664-4, First Edition 2019-06Colorimetry - Part 4: CIE 1976 Lab colour space
ISO CIE 11664-6, First Edition 2014-02-01Colorimetry - Part 6: CIEDE2000 colour difference formula
IEC 61966-2-1:1999-10Multimedia systems and equipment - Colour measurement and management - Part 2-1:

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Non-Clinical Bench TestsGuidance/Standard IDGuidance/Standard NameResults
Colour management - Default RGB colour space - sRGB
Ultrasound ImagingIEC 62127-1:2022Ultrasonics - Hydrophones - Part 1: Measurement and characterization of medical ultrasonic fieldsPass
IEC 61391-1:2006+AMD1:2017 CSV Consolidated versionUltrasonics - Pulse-echo scanners - Part 1: Techniques for calibrating spatial measurement systems and measurement of point-spread function response
FDA GuidanceMarketing Clearance of Diagnostic Ultrasound Systems and Transducers
CybersecurityISO IEC 29147 First edition 2014-02-15Information technology - Security techniques - Vulnerability disclosurePass
IEC 80001-1 Edition 1.0 2010-10Application of risk management for IT-networks incorporating medical devices - Part 1: Roles, responsibilities and activities
AAMI TIR57:2016Principles for medical device security - Risk management.
ANSI NEMA HN 1-2019American National Standard Manufacturer Disclosure Statement for Medical Device Security
FDA GuidanceCybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions
FDA GuidanceCybersecurity for Networked Medical Devices Containing Off-the-Shelf (OTS) Software
SoftwareFDA GuidanceGuidance for the Content of Premarket Submissions for Software Contained in Medical DevicesPass
Draft FDA GuidanceDraft Guidance - Content of Premarket Submissions for Device Software Functions
FDA GuidanceGeneral Principles of Software Validation
AI/MLFDA GuidanceClinical Performance Assessment: Considerations for Computer-Assisted Detection Devices Applied to Radiology Images and Radiology Device Data in Premarket Notification (510(k)) SubmissionsPass
FDA GuidanceComputer-Assisted Detection Devices Applied to Radiology Images and Radiology Device Data - Premarket Notification [510(k)] Submissions
FDA GuidanceGood Machine Learning Practice for Medical Device Development: Guiding Principles

Conclusion:

The overall performance data in this submission supports that the HYDROS Robotic System and its components are substantially equivalent to the predicate device when utilized for its intended use.

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§ 876.4350 Fluid jet system for prostate tissue removal.

(a)
Identification. A fluid jet system for prostate tissue removal is a prescription device intended for the resection and removal of prostatic tissue for the treatment of benign prostatic hyperplasia. The device cuts tissue by using a pressurized jet of fluid delivered to the prostatic urethra. The device is able to image the treatment area, or pairs with an imaging modality, to monitor treatment progress.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Clinical performance testing must evaluate the following:
(i) All adverse events associated with the device, and
(ii) Improvement in lower urinary tract symptoms (LUTS).
(2) Physician training must be provided that includes:
(i) Information on key aspects and use of the device, and
(ii) Information on how to override or stop resection.
(3) Animal testing must demonstrate that the device resects targeted tissue in a controlled manner without injury to adjacent non-target tissues.
(4) Non-clinical performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(i) Measurement of targeting accuracy and reproducibility of high velocity fluid jet, and
(ii) High pressure fluid jet verification testing at target and non-target tissues.
(5) Software verification, validation, and hazard analysis must be performed.
(6) The patient-contacting elements of the device must be demonstrated to be biocompatible.
(7) Performance data must demonstrate the electrical safety and electromagnetic compatibility of the device.
(8) Performance data must demonstrate the sterility of the patient-contacting components of the device.
(9) Performance data must support the shelf life of the device by demonstrating continued sterility, package integrity, and device functionality over the identified shelf life.
(10) Performance data must validate the instructions for reprocessing and reliability of reusable components.
(11) Labeling must include the following:
(i) A section that summarizes the clinical testing results, including the adverse event profile and improvement in LUTS;
(ii) A shelf life for single use components;
(iii) A use life for reusable components; and
(iv) Reprocessing instructions for reusable components.