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510(k) Data Aggregation

    K Number
    K160602
    Manufacturer
    Date Cleared
    2016-06-23

    (113 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    JustRight Surgical

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The JustRight Surgical® Vessel Sealing System is indicated for use in open and laparoscopic general surgical procedures to seal blood vessels and vascular bundles up to and including 5 mm in diameter for use in adult and pediatric populations, wherever vessel ligation is required.

    The device is contraindicated for use in ENT procedures.

    Device Description

    The JustRight Surgical® Vessel Sealing System consists of the JustRight™ Generator and a JustRight™ Sealer. The JustRight™ Generator is designed to provide low power bipolar RF energy for vessel-sealing applications. The JustRight™ Generator is for use only with JustRight™ Sealer instruments. The JustRight™ Sealer is a hand held ring handle design with either a 10 cm or a 20 cm shaft length that is compatible with a 3mm (ID) cannula. The JustRight™ Sealer attaches to the generator via a 10' cord.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for the JustRight Surgical® Vessel Sealing System. It focuses on demonstrating substantial equivalence to predicate devices, particularly for an expanded indication to include pediatric use.

    Here's an analysis of the acceptance criteria and the study information based on the provided document.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with specific numerical targets. Instead, it relies on demonstrating equivalence through various tests and a literature review. The performance claims are comparative to predicate devices.

    Acceptance Criterion (Implied)Reported Device Performance
    Bench Testing - Device Function and DurabilityConfirmed device performance and characteristics.
    Electrical Safety (in accordance with IEC 60601-1-1)Conducted and met standards.
    Electromagnetic Compatibility (EMC) (in accordance with IEC 60601-1-2)Conducted and met standards.
    Electrosurgical Generator Safety (in accordance with IEC 60601-2-2)Conducted and met standards.
    Biocompatibility (in accordance with ISO 10993)Conducted and met standards.
    Vessel Sealing Performance (in vivo) (equivalent to predicate device in pediatric and adult populations)Animal testing confirmed device performance to be equivalent to the predicate device. Literature review and post-market feedback support safety and efficacy for pediatric indication.

    2. Sample Size for the Test Set and Data Provenance

    • Animal Testing: The document states "Animal testing... conducted," but does not specify the sample size (number of animals or number of seals) used for the in vivo evaluation.
    • Data Provenance:
      • Bench Testing: Internal JustRight Surgical LLC.
      • Animal Testing: Not explicitly stated, but typically conducted in a laboratory setting.
      • Literature Review: Publicly available medical literature, including meta-analyses, focusing on complication rates in pediatric vs. adult populations using vessel sealers.
      • Post-Market Feedback: Data collected on the existing JustRight Surgical® Vessel Sealing System.

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

    This type of information is not applicable or not provided in the context of this 510(k) submission. The document describes engineering and animal studies, not human clinical trials or diagnostic AI studies requiring expert ground truth establishment for a test set.

    4. Adjudication Method for the Test Set

    This is not applicable as the studies are technical and animal tests, not clinical or diagnostic studies requiring expert adjudication of results.

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

    No, an MRMC comparative effectiveness study was not done. The document focuses on device performance and equivalence to predicate devices, not on human reader performance with or without AI assistance.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    This question is not applicable as the device is a physical surgical instrument (vessel sealing system), not an AI algorithm.

    7. The Type of Ground Truth Used

    • Bench Testing: Engineering specifications and standardized test methods (e.g., electrical safety standards, force/pressure measurements for seals, durability cycles).
    • Animal Testing: Direct observation of vessel sealing efficacy in an in vivo model, likely based on burst pressure and histological assessment of sealed vessels, comparing outcomes to the predicate device.
    • Literature Review: Published clinical outcomes and complication rates for vessel sealing devices.
    • Post-Market Feedback: Real-world data reported by users of the device.

    8. The Sample Size for the Training Set

    This is not applicable. The device is a hardware system, not an AI algorithm that requires a "training set." The development of the device would involve engineering design and testing, not machine learning model training.

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

    This is not applicable for the same reason as point 8.

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    K Number
    K132472
    Date Cleared
    2014-02-11

    (188 days)

    Product Code
    Regulation Number
    878.4750
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    JUSTRIGHT SURGICAL, LLC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The JustRight™ 5mm Stapler is intended for use in abdominal, gynecologic, pediatric and thoracic surgery for resection, transection and creation of anastomosis.

    Device Description

    The JustRight™ 5mm Stapler places two 25mm staggered rows of titanium staples while simultaneously dividing the tissue between the two staple rows. The unformed staple size is 2mm from staple backspan to staple leg tip. The system is provided with a stapler handle with one pre-loaded staple cartridge and reload cartridges are provided separately to allow for multiple staple line applications within one surgical procedure. The JustRight™ Stapler is compatible for introduction and use through a 5mm cannula sleeve and the stapler handle has a rotation knob to allow for 360° rotation of the staple cartridge.

    AI/ML Overview

    The provided FDA 510(k) summary for the JustRight™ 5mm Stapler System (K132472) describes performance data from non-clinical testing rather than human clinical study data. Therefore, many of the typical questions for AI/diagnostic devices regarding acceptance criteria, sample sizes, expert ground truth, and comparative effectiveness studies are not fully applicable in the context of this device and documentation.

    However, I can extract the information provided regarding the device's performance and the types of studies conducted.


    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implied by the successful completion and positive results of the listed non-clinical tests, demonstrating the device is "safe and effective and performs as intended" and "substantially equivalent to the predicate device." Specific numerical criteria are not detailed in this summary, but the types of performance evaluated are.

    Acceptance Criterion (Implied)Reported Device Performance
    In vitro Testing
    Device durability (multiple firings)Evaluated successfully (implies meeting durability expectations).
    Staple formationEvaluated successfully (implies correct and consistent staple formation).
    Device actuation and reload performanceEvaluated successfully (implies reliable operation and reloading).
    In vivo Testing
    Tissue trauma evaluationEvaluated successfully, including comparative testing to predicate (implies acceptable tissue trauma characteristics, comparable to predicate).
    Knife cutting performanceEvaluated successfully (implies effective and clean cutting).
    Device actuation and reload performanceEvaluated successfully (implies reliable operation and reloading in a live tissue environment).
    Staple formationEvaluated successfully (implies correct and consistent staple formation in a live tissue environment).
    Staple line integrityEvaluated successfully, including comparative burst testing to predicate, showing equivalence (implies the stapled line maintains structural integrity comparable to the predicate device, despite differences in staple count/line length).
    Biocompatibility
    Biocompatibility in accordance with ISO 10993Testing conducted successfully. Tissue contact materials are biocompatible per ISO 10993.
    Substantial Equivalence (Overall to Predicate device: Covidien Endo GIA™ 30mm 2.0 Size Stapler)Demonstrated (implies that despite some differences in cartridge length, staple line length, number of staples/line, number of staple lines/cartridge, cannula size, shaft length, shaft diameter, cartridge articulation, and reload limits, the device performs equivalently to the predicate and does not raise new questions of safety or effectiveness).

    2. Sample size used for the test set and the data provenance

    • Sample Size for Test Set: Not specified in the provided summary. The non-clinical studies involve in vitro and in vivo testing but do not detail the number of units tested or the number of animals (for in vivo).
    • Data Provenance: The studies are non-clinical (in vitro and in vivo) and conducted by the manufacturer, JustRight Surgical LLC. The country of origin and whether it's retrospective or prospective are not applicable in the typical sense for clinical data, as this refers to lab and animal testing.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This device is a surgical stapler, and the testing involves objective measurements of mechanical and biological performance (e.g., staple formation, burst strength, tissue trauma). Ground truth is established through standardized test methods and measurements, not expert consensus interpretation.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as the "test set" here refers to non-clinical performance evaluations rather than image or diagnostic interpretations requiring expert adjudication.

    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 medical device (surgical stapler), not an AI/diagnostic software, and no human reader studies or MRMC studies were performed or are relevant to its premarket notification.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a physical medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For this device, the "ground truth" for performance is based on objective measurements from specified test methods, engineering specifications, and established biocompatibility standards (e.g., ISO 10993). For in vivo testing, outcomes are measured directly (e.g., tissue trauma, staple line integrity/burst pressure).

    8. The sample size for the training set

    Not applicable. There is no "training set" as this is not an AI/machine learning device. The device itself is designed and validated through engineering principles and testing.

    9. How the ground truth for the training set was established

    Not applicable. There is no training set or associated ground truth in the context of this device.

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    K Number
    K123662
    Date Cleared
    2013-05-22

    (175 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    JUSTRIGHT SURGICAL, LLC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The JustRight Surgical™ Vessel Sealing System is intended for use in open and laparoscopic general surgical procedures to seal blood vessels and vascular bundles up to and including 5 mm in diameter wherever vessel ligation is required.

    Device Description

    The JustRight Surgical™ Vessel Sealing System consists of the JustRight™ Generator and a JustRight™ Sealer. The JustRight™ Generator is designed to provide low power bipolar RF energy for vessel-sealing applications. The JustRight™ Generator is for use only with JustRight Sealer instruments. The Sealer is a hand held ring handle design with either a 10 cm or a 20 cm Shaft length that is compatible with a 3mm (ID) cannula. The JustRight™ Sealer attaches to the generator via a 10' cord.

    AI/ML Overview

    The JustRight Surgical™ Vessel Sealing System demonstrated its performance through a series of bench and animal studies to support its substantial equivalence to predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not explicitly state quantitative acceptance criteria or specific numerical performance targets for the device. Instead, it relies on demonstrating equivalence to predicate devices through various tests.

    Test CategoryAcceptance CriteriaReported Device Performance
    Device Function & DurabilityNot explicitly defined as quantitative criteria, but implicitly means meeting expected operational standards.Bench testing of the JustRight Surgical™ Vessel Sealing System was performed to evaluate device function and durability. The document states that the testing was performed "to evaluate device function and durability," implying successful operation within expected parameters. Specific results or metrics are not provided.
    Electrical SafetyCompliance with IEC 60601-1-1Testing was conducted and found to be in accordance with IEC 60601-1-1.
    Electromagnetic CompatibilityCompliance with IEC 60601-1-2Testing was conducted and found to be in accordance with IEC 60601-1-2.
    BiocompatibilityCompliance with ISO 10993Testing was conducted and found to be in accordance with ISO 10993.
    Vessel Sealing PerformanceEquivalence to predicate device (Valleylab Ligasure™ Vessel Sealing System) in ability to seal blood vessels and vascular bundles up to 5 mm.Animal testing of the JustRight Surgical™ Vessel Sealing System was conducted, which "confirmed device performance to be equivalent to the predicate device." No specific quantitative metrics (e.g., burst pressure, thermal spread) are provided, but the equivalence implies meeting the performance standards of the predicate.

    2. Sample size used for the test set and the data provenance:

    • Test Set Sample Size: The document does not specify the exact sample size for the animal testing. It only mentions "Animal testing."
    • Data Provenance: The document does not specify the country of origin of the data. The studies were conducted by JustRight Surgical LLC. The information provided is retrospective, as it's part of a premarket notification submitted to the FDA after the tests were performed.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This information is not provided in the document. The studies described are technical performance tests (bench and animal), not diagnostic or interpretative studies requiring expert ground truth in the typical sense (e.g., radiologists interpreting images). The "ground truth" for the animal study would be the physiological outcomes observed by the researchers/veterinarians involved.

    4. Adjudication method for the test set:

    This information is not provided. Given the nature of the bench and animal testing, a formal adjudication method as understood in clinical trials or diagnostic studies (e.g., 2+1, 3+1) is not typically applicable. The results would be objectively measured or observed by the testing personnel.

    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 comparative effectiveness study was not done. The device is a surgical instrument (vessel sealing system), not an AI-powered diagnostic tool, and therefore human reader performance/improvement with AI assistance is not relevant to this submission.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

    The device is a medical instrument that delivers energy for vessel sealing; it is not an algorithm or AI system. Therefore, a "standalone algorithm performance" assessment is not applicable. The performance evaluated was the direct function of the device itself.

    7. The type of ground truth used:

    • Bench Testing: The ground truth for bench testing (electrical safety, EMC, biocompatibility, function, durability) would be objective measurements against established engineering standards (IEC, ISO) and internal design specifications.
    • Animal Testing: The "ground truth" for the animal testing would be the observed physiological outcomes and performance metrics (e.g., effectiveness of vessel sealing) measured directly in the animal models, compared against the performance of the predicate device. This is essentially outcomes data within a controlled animal study.

    8. The sample size for the training set:

    The device is a hardware system, not a machine learning algorithm. Therefore, there is no "training set" in the context of AI/ML.

    9. How the ground truth for the training set was established:

    As there is no training set for an AI/ML algorithm, this question is not applicable.

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