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510(k) Data Aggregation
(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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