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510(k) Data Aggregation

    K Number
    DEN230032
    Date Cleared
    2024-04-05

    (346 days)

    Product Code
    Regulation Number
    878.4963
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Symani® Surgical System is intended for soft tissue manipulation to perform anastomosis. suturing, and ligation microsurgery techniques on small blood vessels and lymphatic ducts between 0.1 and 2.5 mm in open free-flap surgery of the breast and extremities and open lymphatic surgery of the extremities.

    The Symani® Surgical System is indicated for use during microsurgical procedures when use of a motion scaling function is deemed appropriate by the System is indicated for use in adults. It is intended to be used by trained physicians in an appropriate operating environment in accordance with the Instructions for Use.

    Device Description

    The Symani Surgical System is designed for open microsurgery procedures, featuring articulated and interchangeable instruments.

    The surgeon manipulates the Master Controllers, which in turn drive the articulated (wristed) robotic Instruments at the operating table/site, replicating and scaling down the surgeon movements using a chosen scaling factor. Symani is used in combination with conventional surgical microscopes, either optical or digital.

    Symani is composed of three main components (Figure 1):

    • The Console, which is a reusable equipment and not sterile; .
    • The Cart with Macropositioner and two Micromanipulators, which is a reusable equipment . and not sterile: and
    • . Two articulated Instruments, which are single-use and terminally sterilized via ethylene oxide
    AI/ML Overview

    Here's a detailed breakdown of the acceptance criteria and the study that proves the Symani Surgical System meets them, based on the provided text:

    Overview of Device and Intended Use:

    The Symani Surgical System is an electromechanical system for open microsurgery, specifically intended for soft tissue manipulation to perform anastomosis, suturing, and ligation microsurgery techniques on small blood vessels and lymphatic ducts (between 0.1 and 2.5 mm). Its primary indications are in open free-flap surgery of the breast and extremities and open lymphatic surgery of the extremities for adults. It's designed to provide motion scaling and tremor reduction, assisting trained physicians in an appropriate operating environment.


    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the Symani Surgical System are primarily derived from the "Special Controls" section and the "Performance Testing - Bench" table (Table 5). The reported device performance is indicated as "PASS" for all listed bench tests.

    Acceptance Criteria CategorySpecific Criterion (from "Special Controls" or "Performance Testing - Bench")Reported Device Performance (Table 5)
    Bench/Performance Testing
    Accuracy (Translational & Orientational)(b)(4)* for each translational axis, Roll accuracy (b)(4), Pitch and Yaw accuracy (b)(4)PASS
    System ResolutionXXY axes (b)(4), RPY axes (b)(4)PASS
    Latency(b)(4)*PASS
    Repeatability(b)(4)*PASS
    Scaling Testing(b)(4)* scaling down factors with a (b)(4)* tolerance rangePASS
    Hold Testing(b)(4)*PASS
    Workspace Testing (Translational)Each axis shall report a workspace value between (b)(4)*PASS
    Workspace Testing (Angular)(b)(4)*PASS
    System Use-LifeNo structural failure or malfunctions shall be observed. No component shall be repaired or replaced.PASS
    Drop Testing (Master Controller)No impact on performances by Master Controller drops.PASS
    Emergency Stop TestingMotors stops at (b)(4)*PASS
    Cutting PerformanceThe Needle Holder Suture Cut instrument shall allow to perform at least (b)(4)* consecutive micro suture cuts.PASS
    Stitching Performance (Dilator)The Dilator instrument shall allow to perform at least (b) consecutive stitches with microsutures.PASS
    Stitching Performance (Needle Holder)The Needle Holder and Needle Suture Cut Instruments shall allow to perform at least (b)(4)* consecutive stitches with microsutures.PASS
    Grip Force (Micro/Supermicro NH)The Micro and Supermicro Needle Holder Instrument shall perform a minimum gripping force of (b)*.PASS
    Grip Force (NH with Cutter)The Needle Holder with Cutter Instrument shall have gripping force reduced of max (b)(4)* compared with Needle Holder Instrument.PASS
    Grip and Cutting ReliabilityReliability of 95% and confidence level of 85% with grip force (b)(4)*PASS
    Needle Compatibility (Micro NH)Micro Needle Holder shall firmly grasp needles with diameters between 150-70 μm.PASS
    Needle Compatibility (Supermicro NH)Supermicro Needle Holder shall firmly grasp needles with diameters below 100 μm.PASS
    Knot Tying (Micro NH/NHSC)The Micro Needle Holder and Micro Needle Holder Suture Cut shall allow to tie knots with microsurgical suture in the range of 8-0 and 10-0.PASS
    Knot Tying (Supermicro NH/NHSC)The Supermicro Needle Holder and Supermicro Needle Holder Suture Cut shall allow to tie knots with microsurgical suture in the range of 10-0 and 12-0.PASS
    Knot Tying (Micro Dilator)The Micro Dilator instrument shall allow to tie knots with microsurgical suture in the range of 8-0 and 10-0.PASS
    Knot Tying (Supermicro Dilator)The Supermicro Dilator instrument shall allow to tie knots with microsurgical suture in the range of 10/0 and 12/0.PASS
    Structural Integrity (Shaft Bending)The Instruments shaft shall not break.PASS
    Structural Integrity (Shaft Co-manipulation/Collision)The Instruments shaft shall not break.PASS
    Structural Integrity (Needle Holder Repetitive Gripping)The Needle Holder shall withstand repetitive gripping actions without functional (grip force (b)(4)*) or structural failures.PASS
    Structural Integrity (Instruments Jaws Resistance)Instruments tips shall withstand worst-case load conditions without breaking.PASS
    Microscope Compatibility (Head and Arm Fit)The microscope's head and arm shall fit between Micromanipulators avoiding collision with the Micromanipulators and Instruments.PASS
    Microscope Compatibility (Working Distance)The working distance range shall be adequate to have an appropriate vision of the surgical site, whilst avoiding any collision with Symani Instruments and Micromanipulators.PASS
    Microscope Compatibility (Setup/Vision)The user shall be able to setup the Symani and the Vision System to reach the area to be treated independently to the body districts. Each user involved in the surgery shall have a clear vision of the operating field image. The user shall be able to manage the microscope while seated at the surgical console.PASS
    Clinical Performance (Effectiveness)
    Intraoperative patency (Free-Flap)Extremities: 90.9% (95% CI: [78.3%, 97.5%])Achieved (90.9% - 100%)
    Breast: 100% (95% CI: [85.8%, 100.0%])
    Intraoperative patency (Lymphatic)Upper Extremity: 96.7% (95% CI: [88.5%, 99.6%])Achieved (94.3% - 96.7%)
    Lower Extremity: 94.3% (95% CI: [86.0%, 98.4%])
    Rate of intra-operative approach changes from robotic to manualUpper/lower limbs (Free-Flap): 11.1% (4/36)Achieved (7.7% - 11.1%)
    Breast (Free-Flap): 7.7% (1/13)
    Upper Extremity (Lymphatic): 6.7% (4/60)
    Lower Extremity (Lymphatic): 5.6% (4/71)
    Clinical Performance (Safety)
    Freedom from device related serious adverse events prior to dischargeExtremities (Free-Flap): 0% (0/31)Achieved (0%)
    Breast (Free-Flap): 0% (0/24)
    Upper Extremities (Lymphatic): 0% (0/33)
    Lower Extremities (Lymphatic): 0% (0/37)
    3-day anastomosis specific reoperation rateExtremities (Free-Flap): 3.23% (95% CI: [0.1%, 16.7%]) - Lower than literature [3]Achieved (0% - 3.23%)
    Breast (Free-Flap): 0% (95% CI: [0.00%, 14.8%])
    Lymphatic (30-day reoperation rate): 0.00% (95% CI: [0.00%,0.00%])

    *Note: "(b)(4)" indicates redacted proprietary information, implying the specific numerical criteria were defined and met but are not publicly disclosed in this document.


    2. Sample Sizes and Data Provenance

    The primary clinical evidence for this device comes from a multicenter clinical study and a cadaver/simulated use study.

    • Clinical Study:

      • Sample Size:
        • Free-Flap Procedures: 93 evaluable patients.
        • Lymphatic Surgery: 70 evaluable patients.
        • Total: 163 evaluable patients.
      • Data Provenance: The Symani study is an OUS (Outside US), prospective, single-arm, multicenter, post-market clinical follow-up (PMCF) study. It also allowed for retrospective data collection. This indicates data from European centers ("6 European centers" mentioned in Commercial Data and Literature section). Therefore, the data provenance is European (OUS) and a mix of retrospective and prospective collection.
    • Cadaver Testing: Not specified in terms of sample size for cadavers, but "several standard procedures" were simulated.

    • Simulated Use Testing: 20 experienced surgeons (>5 years of microsurgery practice) and 16 users with no microsurgery experience participated.


    3. Number of Experts and Qualifications for Ground Truth

    • Cadaver Testing: "a team composed of two expert surgeons and six residents" participated. Their specific qualifications (e.g., years of experience) are not detailed beyond "expert surgeons."
    • Simulated Use Testing: "20 experienced surgeons (>5 years of microsurgery practice)" and "16 users with no microsurgery experience." Their input was used to assess precision in stitch placement by measuring distances and angles. This serves as a form of ground truth for performance comparison.
    • Clinical Studies: The "ground truth" for clinical effectiveness and safety endpoints (e.g., anastomosis patency, adverse events, reoperation rates) was based on direct observation and clinical assessment by the participating trained physicians (surgeons) and potentially study staff at the multicenter sites. The study design does not specify adjudication by independent experts for these clinical outcomes, but rather the direct clinical results.

    4. Adjudication Method for the Test Set

    • Clinical Study (Test Set/Clinical Data): The document does not explicitly describe an independent adjudication method (e.g., 2+1, 3+1 consensus) for the clinical outcomes in the human clinical study. The intraoperative patency and adverse events are reported as direct outcomes from the clinical settings. Anastomosis revisions, for example, were performed by the operating surgeon if patency was not achieved on the first attempt.
    • Simulated Use Testing: Data analysis of needle passage parameters (distance and angle) was conducted through a paired T-test. The measurements were taken through a digital microscope, implying a quantitative, objective assessment rather than subjective expert consensus requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No formal Multi-Reader Multi-Case (MRMC) comparative effectiveness study comparing human readers with AI vs. without AI assistance was reported. The device is a surgical system, not an AI-assisted diagnostic or imaging interpretation tool.

    However, a simulated use study did compare the precision of stitch placement with the system (robotic) versus manual instruments.

    • Comparison: Use of Symani vs. manual execution.
    • Effect Size/Performance Improvement:
      • Precision (stitch placement): Use of Symani was associated with greater precision (smaller difference between right and left distances from the cut on latex tissue) compared to manual execution.
        • Experienced microsurgeons: p = 0.02 (statistically significant improvement).
        • Users with no microsurgery experience: p = 0.36 (no statistically significant difference, but trend suggests improvement).
      • Angular Precision: Higher precision using Symani for angular precision (entry/exit angles relative to the vertical cut).
        • Users with no microsurgery experience: p < 0.01 (statistically significant improvement).
        • Experienced microsurgeons: p = 0.19 (no statistically significant difference).
      • Conclusion: The Symani system enabled greater precision in needle placement, with novice users benefiting significantly in needle angulation.
    • Trade-off: Both experienced and novice users had longer suture and anastomosis times when using Symani compared to the manual technique.

    6. Standalone (Algorithm Only) Performance

    The concept of "standalone" performance typically applies to algorithms that autonomously make a decision. The Symani Surgical System is an electromechanical device operated by a human surgeon. Therefore, a "standalone (i.e. algorithm only without human-in-the-loop performance)" study would not be applicable, as the system always requires a human operator for its intended use. Performance is inherently coupled with the human operator.


    7. Type of Ground Truth Used

    • Bench Testing: Engineering specifications and direct physical measurements (e.g., accuracy, resolution, latency, force, structural integrity).
    • Cadaver Testing: Expert judgment and qualitative assessment of system ergonomics and usability in a simulated OR environment.
    • Simulated Use Testing: Quantitative measurements of needle passage parameters (distance and angle) using a digital microscope on synthetic models, serving as objective ground truth for precision comparisons.
    • Animal Testing: Patency evaluated by "Acland milking" test, and stricture/thrombi formation evaluated by light microscopy, micro-CT, and histology – these pathology-based methods serve as objective ground truth.
    • Clinical Studies: Intraoperative patency (clinical observation by the surgeon), adverse events (reported clinical occurrences), reoperation rates (clinical outcomes), and other clinically observed parameters. This is effectively clinical outcomes data and direct surgeon observation as ground truth.

    8. Sample Size for the Training Set

    The document does not explicitly describe a "training set" in the context of an AI/ML algorithm that is trained on data. This device is an electromechanical system, not an AI diagnostic tool that learns from a dataset.

    However, if "training set" refers to the data used for non-clinical performance characterization or design verification, the samples used were:

    • Bench Tests: Not explicitly stated as "sample sizes" but rather as tests performed on the system.
    • Cadaver Testing: Number of cadavers not specified, but multiple simulations were performed.
    • Simulated Use Testing: 20 experienced surgeons and 16 novice users.
    • Animal Testing: 24 animals (rats).

    9. How Ground Truth for the Training Set Was Established

    As noted above, there isn't a traditional "training set" for an AI/ML algorithm in this context. The "ground truth" for the various performance evaluations supporting the device's design and validation were established through:

    • Bench Testing: Established engineering standards and predefined mechanical/electrical parameters.
    • Cadaver/Animal Testing: Direct observation by expert surgeons, pathologist analysis (histology, micro-CT), and established medical tests (Acland milking test).
    • Simulated Use Testing: Objective measurements using a digital microscope, comparing robotic assistance to manual techniques.

    These methods collectively served to validate the device's intended performance and safety, forming the "ground truth" for its development and regulatory acceptance.

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