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510(k) Data Aggregation

    K Number
    K240364
    Date Cleared
    2024-10-16

    (253 days)

    Product Code
    Regulation Number
    884.4530
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    LI Medical Corporation Ltd.

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

    Use of the RELIEEV Uterine Manipulator Injector is indicated in Diagnostic Laparoscopy, Minilaparotomy, Fertility Exams, and Salpingoplasty procedures where manipulation of the uterus is required.

    Device Description

    The "RELIEEV" Uterine Manipulator Injector is intended to be used during medical procedures where manipulation of the uterus or injection of fluids into the uterine lumen are needed. This device is a sterile, single use product consisting of a plastic (PVC) insertion tube that includes two lumens, one for inflation of a 10 mL intrauterine balloon (cuff) at the distal end of the insertion tube via the inflation valve using the provided 10 mL syringe and the other for injection of fluid through a distal end-port using a user-provided syringe via the Leur fitting. The device also includes a movable/removable rigid handle that allows alteration of the device insertion depth and includes a cervical stop, laser etched depth markings to aid in setting the insertion depth, and a pilot balloon to assess maintenance of cuff inflation. The device is curved to facilitate forward uterine manipulation. The device has an overall length of 36 cm and an outer diameter of the catheter component of 5.0 mm. When inflated with 10 mL of air, the balloon has a diameter of 23.0-24.9 mm.

    AI/ML Overview

    This document is an FDA 510(k) summary for the "RELIEEV" Uterine Manipulator Injector. It describes the device and claims substantial equivalence to a predicate device, the Panpac Uterine Manipulator Injector, Model Umi 4.5 (K092980).

    Based on the provided text, the device in question is a medical instrument, not an AI/software device. Therefore, the questions related to AI/software performance, ground truth, human readers, and training/test sets are not applicable to this document.

    The acceptance criteria and study proving the device meets them are related to the physical and biological safety and performance of the Uterine Manipulator Injector, rather than an AI algorithm.

    Here's the information extracted from the document, tailored to the type of device described:


    Acceptance Criteria and Device Performance for "RELIEEV" Uterine Manipulator Injector

    This device is a physical medical instrument, and its performance evaluation focuses on its physical characteristics, sterility, biocompatibility, and mechanical integrity, comparing it to a legally marketed predicate device.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document details various tests performed to ensure the device meets safety and performance standards for a physical medical device. The "acceptance criteria" are implied by the successful completion of these tests per the referenced standards and the statement that "all predetermined acceptance criteria were met."

    Area of PerformanceSpecific Test/EvaluationAcceptance Criteria (Implied by standard and successful outcome)Reported Device Performance
    SterilizationEO sterilization validationConformance to ISO 11135-1:2014 & ISO 10993-7:2008 for residual EtOMet (testing performed)
    PackagingVisual inspectionConformance to ASTM F1886/F1886M-16Met (testing performed)
    Seal Strength testingConformance to ASTM F88/F88M-23Met (testing performed)
    Dye Penetration testConformance to ASTM F1929-15Met (testing performed)
    TransportationTransportation Simulation testingConformance to ASTM D4169-23Met (testing performed)
    BiocompatibilityCytotoxicityNon-cytotoxic per ISO 10993-5:2009Non-cytotoxic
    SensitizationNon-sensitizing per ISO 10993-10:2021Non-sensitizing
    IrritationNon-irritating per ISO 10993-23:2021Non-irritating
    Acute Systemic ToxicityNon-systemically toxic per ISO 10993-11:2017Non-systemically toxic
    Material Mediated PyrogenicityNon-pyrogenic per USPNon-pyrogenic
    Bench Performance (after accelerated aging)Dimensional specificationsMet pre-determined criteriaAll "predetermined acceptance criteria were met"
    Bend test (Force to tip deflection)Met pre-determined criteriaAll "predetermined acceptance criteria were met"
    Cuff Burst TestMet pre-determined criteriaAll "predetermined acceptance criteria were met"
    Tensile strength testing (all joints/connections)Met pre-determined criteriaAll "predetermined acceptance criteria were met"
    Repeated cuff inflationMet pre-determined criteriaAll "predetermined acceptance criteria were met"
    Prolonged inflationMet pre-determined criteriaAll "predetermined acceptance criteria were met"
    Insertion depth marker integrity testingMet pre-determined criteriaAll "predetermined acceptance criteria were met"
    Handle locking mechanism testing (force to move from set position)Met pre-determined criteriaAll "predetermined acceptance criteria were met"

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

    The document does not explicitly state the sample sizes for the various tests. It refers to established testing standards (e.g., ISO, ASTM, USP), which would specify appropriate sample sizes for each test type. The data provenance is from bench testing and laboratory evaluations conducted by the manufacturer (LI Medical Corporation LTD.) to support regulatory submission. This is a prospective assessment of newly manufactured devices under controlled conditions.

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

    This concept is not applicable to the assessment of a physical medical device like a uterine manipulator. "Ground truth" in this context refers to the defined acceptable parameters for physical and biological performance, which are established by international standards and regulatory guidelines, not by individual experts evaluating images or clinical data.

    4. Adjudication Method for the Test Set

    Not applicable for a physical medical device. Performance is judged against specified engineering, material, and biological safety standards, not through adjudication of expert opinions.

    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, as this is not an AI/software device.

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

    Not applicable, as this is not an AI/software device.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance is based on established industry standards and regulatory requirements for medical device safety and efficacy. This includes:

    • Physical and mechanical properties (e.g., dimensions, tensile strength, inflation capabilities).
    • Sterility assurance (e.g., EtO residuals).
    • Biocompatibility (e.g., cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity).
    • Packaging integrity.

    These are quantitative metrics or pass/fail criteria derived from validated test methods.

    8. The Sample Size for the Training Set

    Not applicable, as this is not an AI/software device. There is no "training set" in the context of a physical medical device's performance validation; rather, there are samples tested according to predefined standards.

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

    Not applicable, as this is not an AI/software device.

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    K Number
    K240434
    Date Cleared
    2024-09-25

    (224 days)

    Product Code
    Regulation Number
    884.1175
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Li Medical Corporation Ltd.

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

    The "RELIEEV" Suction Curette (Flexible 3.0/ Standard 3.6) is used to remove samples of materials from the uterus and from the mucosal lining of the uterus by scraping or vacuum suction. These devices obtain tissue samples for purposes of biopsy precancer screening or they can be used for menstrual extraction.

    Device Description

    The "RELIEEV" Suction Curette is a sterile, disposable, single-use device used to obtain a sample from the uterine mucosal lining. It is available in two models – Flexible 3.0 and Standard 3.6 with outer diameters of 3.0 mm and 3.6 mm respectively. The device consists of a tube and piston made of polypropylene (PP) with a silicone O-ring. The subject device is packaged in medical paper grade pouch (60g).

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the "RELIEEV" Suction Curette. The information provided in the document does not contain details about acceptance criteria and a study proving the device meets those criteria in the context of an AI/ML powered device, as the device is a physical medical instrument, not a software or AI-based product.

    The document discusses performance data related to physical bench testing, biocompatibility, packaging and shipping validation, sterilization validation, and shelf life to demonstrate substantial equivalence to a predicate device.

    To address your request, I will categorize the information presented in the document as it pertains to the performance and validation of this physical device.

    1. A table of acceptance criteria and the reported device performance

    Based on the provided document, specific numerical acceptance criteria values are generally not explicitly stated for each test, but rather the conclusion that the device "passed" or "performed according to product specifications" is given. The "Reported Device Performance" here reflects these summarized outcomes.

    Acceptance Criteria Category (Implied/General)Reported Device Performance (Summary from document)
    Bench Testing
    Dimensional Analysis PerformancePerformed according to product specifications (passed)
    Suction Force PerformancePerformed according to product specifications (passed)
    Marker Readability after Bending PerformancePerformed according to product specifications (passed)
    Bending Force PerformancePerformed according to product specifications (passed)
    Biocompatibility Testing
    CytotoxicityNon-cytotoxic (Passed ISO 10993-5:2009)
    SensitizationNon-sensitizer (Passed ISO 10993-10:2021)
    IrritationNon-irritant (Passed ISO 10993-23:2021)
    Packaging and Shipping Validation
    Withstand distribution environmentWithstood distribution environment (Passed ASTM D4332-22 & ASTM D4169-22)
    Seal Peel TestPassing results (per ASTM F88/F88M-23)
    Dye PenetrationPassing results (per ASTM F1929-15)
    Visual InspectionPassing results (per ASTM F1886/F1886M-16)
    Sterilization Validation
    Sterility AssuranceSterilization process validated per ISO 11135:2014; sterility testing and documentation provided.
    Shelf Life
    3-year Shelf Life ClaimSupported by accelerated aging (ASTM F1980-21) and package integrity/bench testing on aged devices.

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

    The document does not specify the exact sample sizes for the individual tests (e.g., number of devices tested for suction force, biocompatibility, etc.). It only states that "Physical bench testing was performed" and "The subject device test results were compared with the predicate device".

    Data Provenance: The manufacturing company is LI Medical Corporation LTD. in New Taipei City, Taiwan. The studies were likely conducted either internally by the manufacturer or by contract testing laboratories performing the specified ISO and ASTM standards. The data is retrospective in the sense that the tests were performed on finished devices to support the 510(k) submission.

    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 to the "RELIEEV" Suction Curette as described in the document. This is a physical medical device, not a diagnostic device involving expert interpretation of data or images to establish a "ground truth" for a test set. The validation relies on objective physical, chemical, and biological testing standards.

    4. Adjudication method for the test set

    This question is not applicable. Adjudication methods (like 2+1, 3+1) are typically used for clinical studies involving human interpretation or subjective assessments, which are not detailed in this document for the provided device. The device validation relies on standardized tests with defined pass/fail criteria.

    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

    This question is not applicable. An MRMC study is relevant for diagnostic devices that involve human readers interacting with images or data, often in the context of AI assistance. The "RELIEEV" Suction Curette is a physical instrument for tissue sampling.

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

    This question is not applicable. This device is not an algorithm or software. It is a physical suction curette.

    7. The type of ground truth used

    This question is not directly applicable in the terms usually associated with AI/ML devices. For this physical device, "ground truth" is established through:

    • Physical measurements and functional performance standards: Defined by product specifications and comparing against the predicate device.
    • Standardized testing methods: Such as ISO and ASTM standards for biocompatibility, sterility, packaging, and shelf-life, which provide objective criteria for success or failure.
    • Analytical chemistry and microbiology results: For biocompatibility and sterility.

    8. The sample size for the training set

    This question is not applicable. There is no AI/ML component described for this device, therefore no "training set" in that context. The device is validated through traditional engineering, biological, and sterility testing.

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

    This question is not applicable, as there is no training set for an AI/ML algorithm for this physical device.

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