(62 days)
The ProCam Medical Pediatric Dispersive Electrode is indicated for use in monopolar electrosurgical applications as a non-sterile, disposable device, for single patient use, only. It is intended to disperse the current as it is removed from the patient during the electrosurgical process. By connecting to the electrosurgical generator, via the pre-attached cable or re-useable cable, the circuit is completed causing successful cutting or coagulation in the patient. This electrode is intended for use in electrosurgery on pediatric patients weighing 25 lbs. or less and with the generator power settings less than 150 watts. The Pediatric Dispersive Electrode is not indicated for use for high-powered procedures such as transurethral resection (TUR). The device will work with any standard generator.
The function of the Ludlow Technical Products pediatric ESD electrodes is to complete the electrosurgical circuit between the patient, the active electrode, and the generator. The products are the same in their construction using conductive adhesive hydrogel along with a foil/polyester conductor plate and a foam insulation backing.
This document is a 510(k) premarket notification for a medical device submitted to the FDA, not a study report for an AI/ML device. Therefore, it does not contain the information requested in your prompt regarding acceptance criteria, sample sizes, ground truth establishment, or human-in-the-loop studies for an AI/ML device.
This submission is for an Electrosurgical Dispersive Electrode, a physical medical device. The "acceptance criteria" and "device performance" in this context refer to engineering and safety standards for this hardware, not algorithmic performance.
Here's what can be extracted from the document based on the device type:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria (ANSI/AAMI HF 18-1993 Section 4.2.3 and 4.2.5) | Reported Device Performance (Ludlow Technical Products Pediatric ESD Electrodes) |
|---|---|
| Section 4.2.3: Dispersive Electrodes | |
| - Maximum Safe Temperature Rise | Met the requirements of the standard |
| - Electrode Contact Impedance | Met the requirements of the standard |
| - Electrode Adherence | Met the requirements of the standard |
| - Packaging/Shelf life | Met the requirements of the standard |
| Section 4.2.5: Operating Conditions | Met the requirements of the standard |
| Biological Evaluation (ISO 10993 Part 1) | Tested successfully |
2. Sample size used for the test set and the data provenance: Not applicable. This is for a physical device, not an AI/ML model. Testing involved compliance with engineering standards on a physical product.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI/ML model doesn't apply here. Compliance was assessed against established engineering and safety standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. This is not a diagnostic or prognostic AI/ML device requiring human adjudication of results. Compliance was determined by meeting predefined technical specifications in standards.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. This is a physical electrosurgical dispersive electrode, not an AI/ML diagnostic or assistive device for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This section pertains to AI/ML algorithm performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable for an AI/ML model. For this device, the "ground truth" or standard for safety and effectiveness was adherence to published industry standards such as ANSI/AAMI HF 18-1993 and ISO 10993.
8. The sample size for the training set: Not applicable. This section pertains to AI/ML models.
9. How the ground truth for the training set was established: Not applicable. This section pertains to AI/ML models.
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OCT 21 1997
Two Ludlow Park Drive P.O. Box 297 Chicopee, MA 01021-0297 413-593-6400
Ludlow Technical Products
510 (k) SUMMARY
Electrosurgical Dispersive Electrodes Pediatric Dual and Single Element Pads Ludlow Technical Products Two Ludlow Park Drive Chicopee, MA 01022
Ludlow Technical Products considers their pediatric dual and single element ESD electrodes to be safe and effective for use in monopolar electro-surgery when used according to the intended procedures as related in the instructions accompanying the product. The function of the Ludlow Technical Products pediatric ESD electrodes is to complete the electrosurgical circuit between the patient, the active electrode, and the generator. The instruction for use insert as well as the pouch labeling contain the necessary warnings per the AAMI standard section 4.1.4.2 "Electrodes intended for use on Infants".
The safety issues of the device were evaluated to the ANSI/AAMI specification HF 18-1993 whereby this standard was issued to "help insure safe and effective use of electrosurgical devices". The ANSI/AAMI standard HF 18-1993 covers all facets of electrosurgical devices. The Ludlow Technical Products Pediatric ESD electrodes were tested according to section 4.2.3 "Dispersive Electrodes", which covers Maximum Safe Temperature Rise, Electrode Contact Impedance, Electrode Adherence, and Packaging/Shelf life; also, section 4.2.5 which covers "Operating Conditions". In each of the test areas listed, the Ludlow Technical Products Pediatric dispersive electrode met the requirements of the ANSI/AAMI HF 18-1993 standard. These results are on file at Ludlow Technical Products.
The Ludlow Technical Products Pediatric electrode was also tested successfully to the ISO - 10993, Biological Evaluation of Medical Devices Part I : Evaluation & Testing.
The Ludlow Technical Products Pediatric ESD electrode is substantially equivalent to products existing the marketplace. The Valleylab E7510 Infant REM Polyhesive II is a Disposable Patient Return Electrode to which we have drawn the comparison. The Ludlow Technical Products pediatric electrode functions the same as the Valleylab E7510 Infant pad. The products are the same in their construction using conductive adhesive hydrogel along with a foil/polyester conductor plate and a foam insulation backing.
This summary of 510 (k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
M. Bean Rice
M. Beth Rice A CLICO INTERNATIONAL LTD. COMPANY
8/5/97
Date
Date
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Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter. Inside the circle is a stylized image of an eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20856
1997
OCT 2 1 1997
Mr. Patrick A. Malia Manager of Quality Assurance Ludlow Technical Products Two Ludlow Park Drive, PO Box 297 Chicopee, Massachusetts 01021-0297
Re: K973110
Trade Name: Disposable Dispersive Electrode, Pediatric, Dual and Single Element, Corded and Non-Corded Regulatory Class: II Product Code: GEI Dated: August 5, 1997 Received: August 20, 1997
Dear Mr. Malia:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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 (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirements , as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for
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Page 1 - Mr. Patrick A. Malia
devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits vour device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4595. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours.
Celia M. Witten, Ph.D., M.D. Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Image /page/3/Picture/0 description: The image shows the logo for ProCam Medical. The logo consists of a black square with a design inside, followed by the word "ProCam" in large, bold letters. Below "ProCam" is the word "MEDICAL" in smaller, bold letters. The logo appears to be printed in black ink on a white background.
INDICATIONS FOR USE STATEMENT
510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________
Device Name:
Indications For Use:
The ProCam Medical Pediatric Dispersive Electrode is indicated for use in monopolar electrosurgical applications as a non-sterile, disposable device, for single patient use, only. It is intended to disperse the current as it is removed from the patient during the electrosurgical process. By connecting to the electrosurgical generator, via the pre-attached cable or re-useable cable, the circuit is completed causing successful cutting or coagulation in the patient. This electrode is intended for use in electrosurgery on pediatric patients weighing 25 lbs. or less and with the generator power settings less than 150 watts. The Pediatric Dispersive Electrode is not indicated for use for high-powered procedures such as transurethral resection (TUR). The device will work with any standard generator.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
| (Division Sign-Off) | |
|---|---|
| Division of General Restorative Devices | |
| 510(k) Number | K973110 |
| Prescription Use | X | OR | Over-The-Counter Use |
|---|---|---|---|
| ------------------ | --------------------------------------------------- | ---- | ---------------------- |
(Per 21 CFR 801.109)
Two Ludlow Park Drive • Chicopee, MA 01022 • 413-593-6100 • 113-593-8391 FAX
A tyco INTERNATIONAL LTD COMPANY
§ 878.4400 Electrosurgical cutting and coagulation device and accessories.
(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.