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510(k) Data Aggregation
(265 days)
The AB1 Instrument, when used with the Creo Medical Electrosurgical System, is intended for use in coagulation (ablation) of soft tissue.
The AB1 Instrument is not intended for use in cardiac procedures.
The Creo Electrosurgical System is intended to provide microwave energy for coagulation (ablation) of soft tissue and is for use only with compatible Creo Medical instruments and accessories.
The System is not intended for use in cardiac procedures.
The Creo Medical (Creo) AB1 soft tissue microwave ablation instrument (electrosurgical instrument, accessory or instrument, also referred to as AB1) is designed for use with the Creo electrosurgical system, previously cleared under K200298. No changes have been made to the Creo generator, footswitch, or interface cable with sterile sheaths that comprise the electrosurgical system, nor are any changes proposed to the AB1 instrument in this 510k.
AB1 is provided as a sterile, single-use instrument that is 0.95 m long with a 4.3 mm diameter shaft that terminates in a distal antenna that is 38 mm long and less than 2.00 mm in diameter (nominally, 1.9 mm) with a conical tip. The AB1 instrument is provided with a flexible, removable (distal) handle. The outer sheath of the flexible shaft may be removed.
This 510k provides instructions to the end user on how to remove the outer extrusion and distal handle to create a configuration that has an outer diameter less than 2.00 mm. The instrument may be used to access target tissue directly, e.q. in open surgical procedures, or, with the handle and outer sheath removed, through a compatible trocar in minimally invasive procedures. The antenna couples microwave energy to target tissue when AB1 is powered by the Creo Electrosurqical System. AB1 is only compatible for use with the Creo Electrosurgical System, and the Creo Electrosurgical System is only intended for use with compatible Creo instruments and accessories.
The provided text is a 510(k) summary for a medical device (Creo Electrosurgical System with AB1 Instrument). It describes a change to the Indications For Use (IFU) of an already cleared device, specifically allowing the removal of an outer sheath and distal handle to enable use with a compatible trocar in minimally invasive procedures.
This document does not describe an AI/ML-based device or a study involving human readers and AI assistance for diagnostic purposes. Therefore, most of the requested information (such as acceptance criteria for AI performance, sample size for AI test sets, expert ground truth establishment, MRMC studies, standalone AI performance, etc.) is not applicable to this submission.
The document focuses on demonstrating the safety and effectiveness of a modified configuration of an electrosurgical instrument for soft tissue ablation, predominantly through bench testing and preclinical evaluation, ensuring it is equivalent to the predicate device.
However, I can extract the information related to the device performance data based on the context of the document, even though it's not an AI/ML study.
Here's a breakdown of the available information:
1. A table of acceptance criteria and the reported device performance
The document lists performance tests conducted to address the change in labeling. It doesn't present a formal table of acceptance criteria with corresponding performance data, but rather a list of tests and a general conclusion.
| Test Conducted | Purpose/Criterion (Inferred) | Reported Performance |
|---|---|---|
| Pull (tensile) test | To ensure the mechanical integrity and strength of the instrument in the modified configuration. | "meets all design specifications" (general statement) |
| Removal of outer extrusion test (effects on underlying cable, cosmetics, electrical performance) | To verify that the process of removing the outer sheath does not damage the instrument, affect its appearance, or compromise its electrical function. | "meets all design specifications" (general statement) |
| Insertion and retraction into and from an introducer test | To ensure the instrument can be safely and effectively inserted into and retracted from an introducer, as implied by the revised IFU. | "meets all design specifications" (general statement) |
| Shaft bending test | To assess the flexibility and durability of the instrument shaft in the modified configuration under potential bending stress. | "meets all design specifications" (general statement) |
| VNA (vector network analyzer) return loss test | To evaluate the electrical performance and impedance matching of the microwave antenna in the modified configuration, ensuring efficient energy delivery. | "meets all design specifications" (general statement) |
| Thermal profile with introducer test | To assess the thermal characteristics of the device when used with an introducer, ensuring safe operating temperatures and effective energy delivery. | "meets all design specifications" (general statement) |
| Comparison of dimensions of ablations created by new and predicate device in ex-vivo tissue | To demonstrate that the modified configuration produces comparable ablation zones (size and shape) to the original predicate device, ensuring equivalent therapeutic effect. | "meets all design specifications" (general statement) |
| Preclinical evaluation of safety and performance in a pig model | To assess the safety and efficacy of the device in a living biological system, simulating clinical use conditions. | "meets all design specifications" (general statement), also "results... demonstrate that the potential risks associated... have been reduced to low and acceptable levels." |
| Simulated use testing of deployment through introducers | To simulate the clinical use case of deploying the device through compatible introducers, verifying ease of use and functionality. | "meets all design specifications" (general statement) |
| Electrical safety testing | To ensure the device meets applicable electrical safety standards. | "meets all design specifications and applicable medical device standard requirements" |
| Usability engineering validation | To ensure the device (with the modified IFU) can be safely and effectively used by intended users, and to identify potential use errors. This is particularly relevant for instructions on modifying the device configuration. | "meets all design specifications" (general statement), and "no new or different questions of safety or effectiveness raised by the modification to the IFU" |
Overall Conclusion on Performance: "The results of the tests conducted and leveraged demonstrate that the AB1 instrument in the proposed configuration with outer sheath and distal handle removed meets all design specifications and applicable medical device standard requirements, and that it is substantially equivalent to the predicate AB1 instrument with the handle and outer sheath in place."
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: Not specified for individual bench or preclinical tests. The document generically refers to "tests conducted". For the "Preclinical evaluation of safety and performance in a pig model", the sample size (number of pigs) is not provided.
- Data Provenance: Not explicitly stated for each test. The sponsor, Creo Medical Ltd., is based in the United Kingdom, so some testing might have occurred there. The preclinical study type would be prospective.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not applicable. This summary is for an electrosurgical instrument, not an AI/ML-based diagnostic device where expert ground truth for interpretation would be established. The "ground truth" for this device's performance would be engineering specifications, material properties, and biological effects (ablation size/shape, safety in animal models).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This refers to a process typically used in AI/ML performance evaluation where multiple human readers contribute to a consensus ground truth. The tests performed here are primarily objective engineering and preclinical evaluations.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No. An MRMC study is not relevant to an electrosurgical cutting and coagulation device. This document is not describing an AI-assisted diagnostic or therapeutic system.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is not an algorithm-based device. The "performance" being evaluated is the physical and functional characteristics of the electrosurgical instrument itself.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For the performance tests, the "ground truth" would be:
- Engineering Specifications: For mechanical tests (tensile, bending, insertion/retraction), and electrical tests (VNA, electrical safety).
- Defined Ablation Characteristics: For ex-vivo tissue comparisons (ablation dimensions).
- Physiological/Histopathological Observation: For the preclinical pig model, assessing safety (e.g., lack of unintended damage) and efficacy (e.g., successful ablation).
- Usability Standards: For usability engineering validation.
8. The sample size for the training set
- Not applicable. This device is an electrosurgical instrument, not an AI/ML model. There is no training set in the AI/ML sense.
9. How the ground truth for the training set was established
- Not applicable. As above, there is no AI/ML training set.
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(250 days)
The NP1 MicroBlate Fine Instrument, when used with the Creo Medical Electrosurgical System, is intended for use in coagulation (ablation) of soft tissue.
The NP1 MicroBlate Fine Instrument is not intended for use in cardiac procedures.
The Electrosurgical Generator provides microwave (MW) energy to the compatible Creo Medical AB1 MicroBlate Flex and NP1 MicroBlate Fine instruments, intended for coagulation (ablation) of soft tissue.
The Electrosurgical Generator provides microwave (MW) energy to the compatible Creo Medical HS1 SlypSeal Instrument, intended for coagulation (hemostasis and cauterization) of soft tissue.
The Electrosurgical Generator provides microwave (MW) and radiofrequency (RF) energy to the compatible Creo Medical RS2 Speedboat Instrument, intended for coagulation (hemostasis and cauterization) and cutting soft tissue.
The Electrosurgical System is not intended for use in cardiac procedures.
The Creo Medical Electrosurgical System with NP1 Instrument includes the following:
- . NP1 Instrument
- . Electrosurgical Generator
- . Footswitch
- . Interface Cable with Sterile Sheaths
The Electrosurgical Generator is designed to deliver bipolar radiofrequency (RF) energy and microwave (MW) energy for the purpose of cutting and coagulating tissue. Only the microwave output is used to power the NP1 Instrument. The Electrosurgical Generator output is actuated via a two-pedal Footswitch. One pedal activates the bipolar RF energy output for cutting (not active for use of NP1); the other pedal activates the MW enerqy output for coaqulation. The Electrosurgical Generator incorporates proprietary software developed by Creo Medical for generating and controlling the two energies delivered. The Electrosurgical Generator and Footswitch are non-sterile and reusable.
The single-use Interface Cable provides a conductive pathway between compatible Creo electrosurgical instruments and the output of the Electrosurgical Generator and is supplied with a sterile sheath that is fitted over the cable's distal end during use to minimize the potential for contamination of the sterile field.
The sterile, single-use NP1 soft tissue ablation instrument consists of a handle, 1.6 m long x 2.7 mm diameter flexible shaft, active nitinol antenna and pointed ceramic tip. Bipolar electrodes separated by dielectric materials couple microwave energy to target tissue when NP1 is activated. NP1 is only compatible for use with the Creo Medical Electrosurgical System, and the System is only intended for use with compatible Creo instruments and accessories.
The provided document does not contain acceptance criteria or a study demonstrating device performance against such criteria in the context of typical AI/ML device evaluations. This document is a 510(k) premarket notification for a medical device (electrosurgical system) and focuses on demonstrating substantial equivalence to a predicate device, primarily through technological characteristics and the removal of a specific contraindication for transluminal use.
Therefore, I cannot provide the requested information for an AI/ML context because the document does not discuss an AI/ML device, its performance metrics, or related studies like sample sizes, expert ground truth, adjudication methods, MRMC studies, or standalone performance.
The "Performance Data" section explicitly states: "No bench or clinical data were required to demonstrate substantial equivalence with the predicate device or to justify the elimination of the contraindication for transluminal use from the NP1 instrument IFU." It does mention a preclinical study in a porcine model to demonstrate transluminal navigation and ablation, but this is not presented as meeting specific, measurable acceptance criteria in the format requested for AI/ML performance.
In summary, the information you requested is not present in the provided document as it pertains to a different type of device clearance rather than an AI/ML device performance evaluation.
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(334 days)
The Creo Electrosurgical System is intended to provide microwave energy for coagulation (ablation) of soft tissue and is for use only with compatible Creo Medical instruments and accessories.
The System is not intended for use in cardiac procedures.
The AB1 Instrument, when used with the Creo Electrosurgical System, is intended for use in coagulation (ablation) of soft tissue.
The AB1 Instrument is not intended for use in cardiac procedures.
The Creo Medical (Creo) Electrosurgical System with AB1 Accessory includes the following:
- . AB1 Instrument
- . Electrosurqical Generator
- . Footswitch
- . Interface Cable with Sterile Sheaths
The Electrosurgical Generator is designed to deliver bipolar radiofrequency (RF) energy and microwave (MW) energy for the purpose of cutting and coagulating (ablating) tissue. Only the microwave output is used to power the AB1 Instrument. The Electrosurgical Generator output is actuated via a two-pedal Footswitch. One pedal activates the bipolar RF energy output for cutting; the other pedal activates the MW energy output for coagulation. The Electrosurgical Generator incorporates proprietary software developed by Creo for generating and controlling the two energies delivered. The Electrosurgical Generator and Footswitch are non-sterile and reusable.
The single-use Interface Cable connects compatible Creo electrosurgical instruments to the Electrosurgical Generator and is supplied with a sterile sheath that is fitted over its distal end during use to minimize the potential for contamination of the sterile field.
The sterile, single-use AB1 soft tissue ablation accessory (Instrument) consists of a flexible, movable handle and a 0.95 m long x 4.3 mm diameter shaft that terminates in a 38 mm long x 1.9 mm diameter distal antenna with conical tip. Two metallic washers separated by dielectric materials couple microwave energy to target tissue when AB1 is only compatible for use with the Creo Electrosurgical System, and the Creo Electrosurgical System is only intended for use with compatible Creo instruments and accessories.
The provided text describes the Creo Electrosurgical System with AB1 Accessory, which is intended for soft tissue coagulation (ablation) using microwave energy. The 510(k) summary (K200298) primarily focuses on demonstrating substantial equivalence to a predicate device (K163105 Emprint Ablation System) through various performance data, rather than outlining specific clinical acceptance criteria for diagnostic performance.
Therefore, the requested information categories related to diagnostic performance (e.g., effect size of human readers with AI, standalone performance, MRMC study, expert qualifications for ground truth) are not applicable to this submission, as it is for an electrosurgical device and not an AI/diagnostic software.
However, the document does contain information about performance testing and acceptance criteria related to its operational safety and effectiveness as a medical device.
Here's a breakdown of the available information:
1. Table of Acceptance Criteria (as implied by testing) and Reported Device Performance:
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Sterilization Assurance Level: Maintain required sterility for single-use instruments. (Implied: SAL of 10^-6) | The AB1 Sterility Assurance Level is 10^-6, per ISO 11135 and AAMI TIR28 standard evaluation. |
| Shelf-life: Maintain device integrity and functionality over time. | The shelf-life for the AB1 Instrument is 6 months. The shelf life for the Interface Sheath is 3 years. |
| Biocompatibility: Acceptable biological risk for patient-contacting materials. (Implied compliance with ISO 10993-1 and FDA guidance) | Biocompatibility evaluation conducted in accordance with ISO 10993-1:2009 and FDA guidance. The antenna assembly of AB1 and distal portion of its shaft are categorized as externally communicating with limited (< 24h) contact with tissue. Tests included Cytotoxicity, Sensitization, Irritation, Systemic toxicity, Pyrogen Testing, and Hemolysis. Results "support a finding of a low and acceptable biological and toxicological risk." |
| Electrical Safety: Compliance with relevant medical electrical equipment standards. (Implied: IEC 60601-1, IEC 60601-2-2, IEC 60601-2-6) | The system complies with FDA-recognized versions of IEC 60601-1, IEC 60601-2-2, and IEC 60601-2-6 standards for safety. |
| Microwave Safety: Safe operation regarding microwave energy. | Included in Electrical Safety and EMC testing. The Electrosurgical Generator maintains energy delivery within specifications. |
| Electromagnetic Compatibility (EMC): Compliance with EMC standards. (Implied: IEC 60601-1-2) | The system complies with IEC 60601-1-2 standard for EMC. EMC test results "demonstrate acceptable safety and performance of the new system." |
| Software Verification and Validation: Safe and effective software operation. (Implied: "major" level of concern addressed as per FDA guidance) | Software verification and validation testing were conducted, and documentation was provided as recommended by FDA's Guidance for Industry. The software was considered a "major" level of concern, meaning a failure could directly result in serious injury or death. |
| Mechanical Performance: Meets design specifications for physical device characteristics (e.g., diameter, insertion force, durability). | Tests included: Diameter/weight, Insertion and retraction force, Shaft bending, VNA, Connector compatibility, Thermal profile, Pull, Durability, Heat shrink pull, and Standing wave ratio / reflected power threshold testing. Results "demonstrate that the AB1 Electrosurgical System meets design specifications and performs as intended." |
| Ablation Performance (Repeatability & Equivalence): Ability to produce consistent ablation zones and equivalence to predicate device. | Simulated use studies in ex-vivo tissue were conducted for ablation zone repeatability and comparison to the predicate. Results "characterize the ablation volumes created by the new and predicate systems, which have been determined to be equivalent." Tests also "demonstrate that the AB1 Electrosurgical System... performs as intended, and support Creo's assertion of substantial equivalence to the predicate device." Evaluations in ex vivo bovine tissue "demonstrate that the temperature of applied parts does not exceed permissible limits and that no non-target tissue is thermally injured as a result of AB1 treatments at its maximum power setting." |
| Energy Delivery Specifications: Generator output voltage, power, current, duty cycle, and duration are within specifications. (Implied for microwave output) | The Electrosurgical Generator output "are under the control of software and hardware circuits to assure the energy delivered to the AB1 instrument via the Interface Cable is within specifications." |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not explicitly stated for each test type (e.g., "simulated use studies in ex-vivo tissue"). However, the text refers to "simulated use studies conducted in ex-vivo muscle, liver, lung and kidney tissue" and "ex vivo bovine tissue."
- Data Provenance: Ex-vivo tissue (not specified if animal or human for all tests, but bovine tissue is explicitly mentioned). Given the nature of these tests, it's lab-based simulated use. No country of origin for the ex-vivo tissue is provided. These are prospective tests performed by the manufacturer to demonstrate device performance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This question is not applicable as the ground truth for an electrosurgical device's performance relates to its physical, electrical, and ablative characteristics, not diagnostic interpretations requiring expert consensus. The "ground truth" here is the measured physical and biological effects of the device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication methods are relevant for subjective interpretations of data, typically in diagnostic studies. For engineering and performance testing, objective measurements and established standards are used.
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 device is an electrosurgical tool, not an AI-assisted diagnostic imaging or interpretation system.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical instrument for surgery, not an algorithm.
7. The type of ground truth used:
- For sterilization: Conformance to ISO 11135 and AAMI TIR28 standards.
- For biocompatibility: Conformance to ISO 10993-1 and FDA guidance, with specific toxicological and biological tests.
- For electrical/microwave safety and EMC: Conformance to IEC 60601 series standards.
- For mechanical/ablation performance: Direct physical measurements (e.g., diameter, force, thermal profiles, ablation zone size/shape) and comparison against design specifications and equivalence to the predicate device's measured performance in ex-vivo tissue models. This is effectively physical measurement and comparison to established engineering specifications and predicate device performance.
8. The sample size for the training set:
- Not applicable. This is not an AI/machine learning device that requires a training set.
9. How the ground truth for the training set was established:
- Not applicable. As above, no training set for an algorithm is involved.
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(300 days)
The Creo Electrosurgical System is intended to provide microwave energy for coagulation (ablation) of soft tissue and is for use only with compatible Creo Medical instruments and accessories.
The System is not intended for use in cardiac procedures.
The NP1 instrument, when used with the Creo Medical Electrosurgical System, is intended for use in coagulation (ablation) of soft tissue.
The NP1 Instrument is not intended for use in cardiac procedures.
The Creo Medical Electrosurgical System with NP1 Accessory includes the following:
- . NP1 Instrument
- . Electrosurgical Generator
- . Footswitch
- Interface Cable with Sterile Sheaths
The Electrosurgical Generator is designed to deliver bipolar radiofrequency (RF) energy and microwave (MW) energy for the purpose of cutting and coagulating tissue. Only the microwave output is used to power the NP1 Instrument. The Electrosurgical Generator output is actuated via a two-pedal Footswitch. One pedal activates the bipolar RF energy output for cutting; the other pedal activates the MW energy output for coagulation. The Electrosurgical Generator incorporates proprietary software developed by Creo Medical for generating and controlling the two energies delivered. The Electrosurgical Generator and Footswitch are non-sterile and reusable.
The single-use Interface Cable connects compatible Creo electrosurgical instruments to the Electrosurgical Generator and is supplied with a sterile sheath that is fitted over its distal end during use to minimize the potential for contamination of the sterile field.
The sterile, single-use NP1 soft tissue ablation accessory (Instrument) consists of a handle, 1.4 m long x 2.7 mm diameter shaft, active nitinol antenna and pointed ceramic tip. Stainless-steel bipolar electrodes separated by dielectric materials couple microwave energy to target tissue when NP1 is in use. NP1 is only compatible for use with the Creo Medical Electrosurgical System, and the System is only intended for use with compatible Creo instruments and accessories.
I am sorry, but the provided text from the FDA 510(k) Pre-Market Notification for the Creo Medical Electrosurgical System with NP1 Accessory does not contain the specific information required to answer your request.
The document is a notification of substantial equivalence for a medical device, and while it mentions performance testing, it does not include:
- A table of acceptance criteria and reported device performance related to a specific study. It broadly states, "The system meets all design specifications, risk mitigation requirements, and applicable medical device standard requirements." and references "Results of mechanical and ablation performance tests, including bench tests and simulated use studies conducted in ex-vivo tissue, demonstrate that the NP1 Electrosurgical System meets design specifications and performs as intended." but no specifics.
- Sample sizes used for a test set or data provenance for specific performance studies. It mentions "simulated use studies conducted in ex-vivo muscle, liver, and kidney tissue" but does not give sample sizes or specific data provenance beyond being ex-vivo tissue.
- Number of experts used or their qualifications for establishing ground truth. This information is entirely absent for any performance claims.
- Adjudication method for a test set. Not mentioned.
- Details about a multi-reader multi-case (MRMC) comparative effectiveness study, including effect size. This type of study is not described or referenced.
- Details about a standalone (algorithm only) performance study. The device is an electrosurgical system, not an AI algorithm, so this concept does not apply in the typical sense of AI/ML software. Its performance is tied to its physical operation and effect on tissue.
- The type of ground truth used (e.g., pathology, outcomes data). For the ablation studies, it implies the "ablation volumes created" as a measure of performance, but it doesn't describe who established this ground truth or how precisely it was measured in terms of a clinical "ground truth."
- The sample size for a training set. As this is a hardware device with embedded software for control, not a machine learning model, the concept of a "training set" for an AI algorithm is not applicable here. The software verification and validation are mentioned but not in the context of a machine learning training set.
- How the ground truth for the training set was established. Not applicable for the reasons above.
The document primarily focuses on demonstrating substantial equivalence to a predicate device through:
- Comparison of technological characteristics.
- Compliance with electrical safety, EMC, and biocompatibility standards.
- Software verification and validation (for control software, not AI/ML).
- Bench testing and simulated use testing to show the system meets design specifications and performs as intended.
Therefore, I cannot extract the requested information from the provided text.
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(156 days)
The Creo Electrosurgical Generator is intended to provide radiofrequency (RF) electrosurgical energy for cutting and microwave energy (MW) for coagulation (hemostasis, cauterization) of soft tissue, and is for use only with compatible Creo Medical instruments and accessories.
The HS1 Hemostasis Accessory is indicated for use in endoscopic injection therapy (to deliver pharmacological injection agents, such as vasoconstrictors) and endoscopic electrohemostasis (cauterization of tissue and coagulation of blood) of actual or potential bleeding sites in the gastrointestinal tract. These sites include the following:
- · Peptic Ulcers
- · Dieulafoy Lesions
- · Mallory-Weiss Tears
- · Bleeding Polyp Stalks
- · Arteriovenous Malformations (AVMs)
- · Angiomata
The HS1 also has irrigation capability. Any other use is not recommended.
The Creo Medical Electrosurgical System with HS1 hemostasis accessory comprises of the following:
- . HS1 hemostasis surgical accessory
- . Electrosurgical Generator
- Footswitch
- Interface Cable
The Electrosurgical Generator is designed to deliver bipolar radiofrequency (RF) energy and microwave (MW) energy for the purpose of cutting and coagulating tissue. The Electrosurgical Generator output is actuated via a two-pedal Footswitch. One pedal activates the bipolar RF energy output for cut: the other pedal activates the MW energy output for coagulation. The Electrosurgical Generator incorporates proprietary software developed by Creo Medical for generating and controlling the two energies delivered. The Electrosurgical Generator and Footswitch are non-sterile and reusable.
The Interface Cable connects electrosurgical instruments to the Electrosurgical Generator and is for single-use and is supplied with a sterile sheath that is fitted over its distal end during connection to the surgical accessory.
HS1 is an electrosurgical hemostasis accessory for use with the Creo Medical Electrosurgical Generator only. HS1 is for endoscopic use and provides coagulation and injection of fluids incorporated in a single device. HS1 is for single-use only and provided sterile.
This submission describes the Creo Electrosurgical System with HS1 Hemostasis Accessory. The device is intended to provide radiofrequency (RF) electrosurgical energy for cutting and microwave energy (MW) for coagulation (hemostasis, cauterization) of soft tissue, primarily for endoscopic electrohemostasis in the gastrointestinal tract.
Here's an analysis of the acceptance criteria and supporting study information:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document doesn't explicitly list "acceptance criteria" in a quantitative, pass/fail format typical for AI/ML device submissions. Instead, it details performance testing to demonstrate substantial equivalence to predicate devices. The performance aspects tested are related to the device's functional characteristics.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Coagulation Energy Equivalence (penetration and spread of thermal effects) | Bench testing showed substantial equivalence with the predicate device (Boston Scientific Injection Gold Probe) regarding the penetration and spread of thermal effects in gastrointestinal tissue, despite using different energy types (MW vs. bipolar RF). |
| Distal Tip Design Equivalence (penetration and spread of thermal effects) | Bench testing showed substantial equivalence with the predicate device concerning the penetration and spread of thermal effects in gastrointestinal tissue, despite differences in distal tip design (blade vs. dome-shaped). |
| Shaft and Distal Tip Materials Biocompatibility | Meets all relevant requirements of FDA guidance and ISO 10993 (biocompatibility). Bench testing showed substantial equivalence with the predicate devices regarding penetration and spread of thermal effects. |
| Needle and Injection Performance (flowrate, durability, sharpness, tensile strength) | Bench testing showed acceptable levels of performance for injection flowrate, insertion and retraction durability (throughout lifetime use and in worst-case endoscope positions), needle point sharpness (throughout lifetime use), and needle to hypotube and ferrule tensile strength. |
| Needle and Injection Materials Biocompatibility | Meets all relevant requirements of FDA guidance and ISO 10993 (biocompatibility). |
| General Design Specifications & Standards Compliance | The system meets all design specifications, design-risk analysis, and medical device standards for electrical safety and FDA recognized versions of EMC (IEC 60601), electrical safety (IEC 60601), biocompatibility (ISO 10993), and sterility (ISO 11135). |
| Mechanical, Coagulation, and Injection Performance (in ex-vivo/in-vivo) | Meets the design specification and shows substantial equivalence to the predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the exact sample sizes for each type of bench, ex-vivo, or in-vivo test.
- Data Provenance: The studies include "bench testing," "ex-vivo," and "in-vivo" tests. The document does not specify the country of origin of the data or whether the studies were retrospective or prospective, though in-vivo studies are typically prospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not provided in the document. For a electrosurgical device, "ground truth" might refer to histological analysis of tissue effects or clinical outcomes. The document does not mention the use of experts for establishing ground truth or their qualifications.
4. Adjudication Method for the Test Set
The document does not describe any adjudication method, such as 2+1 or 3+1, which is typically relevant for studies involving human interpretation or subjective assessments. For objective performance metrics like thermal spread or mechanical durability, such methods are not usually applicable.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The device in question is an electrosurgical system, not an AI-assisted diagnostic or interpretive tool that would typically involve human readers. Therefore, an effect size of how much human readers improve with AI vs. without AI assistance is not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
While the device incorporates "proprietary software developed by Creo Medical for generating and controlling the two energies delivered," the submission focuses on the performance of the integrated electrosurgical system (hardware + software). There is no mention of a standalone algorithm performance study independent of the physical device or a human operator. The system itself is the "standalone" entity whose performance is being evaluated.
7. The Type of Ground Truth Used
The "ground truth" implicitly used for evaluation involved:
- Physical Measurements/Observations: For bench testing of coagulation (penetration and spread of thermal effects), injection flowrate, durability, sharpness, and tensile strength.
- Standard Compliance: Adherence to electrical safety (IEC 60601), EMC (IEC 60601), biocompatibility (ISO 10993), and sterility (ISO 11135) standards.
- Clinical/Biological Equivalence: Demonstrated through ex-vivo and in-vivo tests (though specific metrics for "ground truth" here are not detailed, they would likely involve histological analysis or observable clinical effects in tissue).
8. The Sample Size for the Training Set
This information is not applicable/not provided in the context of this device submission. This is a medical device (electrosurgical system), not an AI/ML diagnostic or predictive algorithm that typically undergoes a training phase with a distinct training set of data. The "proprietary software" controls energy delivery but isn't described as a machine learning model trained on a dataset.
9. How the Ground Truth for the Training Set Was Established
As there is no mention of a specific "training set" for an AI/ML algorithm in this submission, this information is not applicable. The "ground truth" for the device's design and engineering would have been established through established physics, electrical engineering principles, surgical practice, and regulatory standards.
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