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510(k) Data Aggregation

    K Number
    K223064
    Date Cleared
    2022-10-28

    (28 days)

    Product Code
    Regulation Number
    884.4530
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ALLY II Uterine Positioning System™ (UPS)

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

    The ALLY II UPS™ (Uterine Positioning System) is intended to assist the surgical staff in mounting, positioning and holding uterine manipulators during gynecological laparoscopic surgical procedures. It is intended for use by trained operating room personnel in an operating room environment.

    Device Description

    The ALLY II UPS™ (Uterine Positioning System) attaches to the operating room table and enables the bed-side assistant to readily mount, hold, and position the manipulator during laparoscopic surgical procedures. The ALLY II UPS enables access and provides the ability to maneuver and maintain the manipulator in a desired position. The ALLY II UPS consists of the ALLY II UPS and a manipulator adapter with built-in sterile drape, known as the adapter drape.

    The CooperSurgical ALLY II UPS is a non-patient contacting, electromechanical device that consists of a single, multi-segmented, articulated arm. The ALLY II UPS can be attached to the standard operating room bed rail, and a separate, sterile, disposable Adapter Drape that is used to attach a uterine manipulator to the ALLY II UPS. When unlocked, the flexible arm allows the attached manipulator to be positioned by the user. The arm can then be locked in the desired position by releasing a foot pedal, activating a linear actuator that applies tension to an internal cable, drawing the segments together and thus locking the arm. The segmented design of the arm allows lateral/medial movement from a single point to position the uterine manipulator.

    The purpose of this submission is to gain clearance for minor modifications made to the ALL Y Uterine Positioning System to meet user needs and allow for user convenience. The overall functionality and interface of the ALLY II UPS for the user remains the same.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification from the FDA for a medical device called the ALLY II UPS™ (Uterine Positioning System). This type of document is for medical devices, not AI/ML algorithms. Therefore, the questions related to AI/ML specific aspects like training data, ground truth establishment, MRMC studies, and standalone algorithm performance are not applicable to this submission.

    The acceptance criteria and performance data described in this document relate to the physical and mechanical performance of the revamped medical device compared to its predicate.

    Here's an analysis based on the provided text, focusing on the device's acceptance criteria and proven performance:

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

    The document doesn't provide a direct table of acceptance criteria with corresponding performance values for the ALLY II UPS™. Instead, it broadly states that "The ALLY II UPS met the pre-determined acceptance criteria for each intended output." It lists the types of tests performed.

    Implied Acceptance Criteria and Performance (based on Section VII. Performance Data):

    Performance MetricAcceptance Criteria (Implied)Reported Device Performance (Summary)
    Durability (Useful Life)Device sustains intended function, material integrity, and performance over its expected lifespan."was performed" (details not provided, but implies met criteria given substantial equivalence conclusion)
    Holding ForceDevice can consistently and securely hold uterine manipulators in desired positions without slippage or movement beyond acceptable tolerances."was performed" (details not provided, but implies met criteria given substantial equivalence conclusion)
    Range of MotionDevice can manipulate to designated 6 points of extension in anteverted hand position and designated 5 points of extension in retroverted hand position.Subject device has "greater Range of Motion than the predicate" and met the specified extension points.
    Link SoakMaterials of the flexible arm (17-4 stainless steel, PEEK inserts) maintain integrity and function after exposure to relevant cleaning/sterilization protocols."was performed" (details not provided, but implies met criteria given substantial equivalence conclusion)
    Foot Pedal Cable RetentionThe detachable foot pedal cable remains securely connected during use and does not pose a safety risk."Justification" submitted (details not provided, but implies met criteria given substantial equivalence conclusion)
    Electrical Safety (IEC 60601-1)Compliance with general requirements for basic safety and essential performance of medical electrical equipment.Device is "compliant with the following standards: IEC 60601-1: 2005+AMD1:2012+AMD2:2020 CSV"
    EMC (IEC 60601-1-2)Compliance with requirements for electromagnetic compatibility for medical electrical equipment.Device is "compliant with the following standards: IEC 60601-1-2: 2014"

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

    • Sample Size: The document does not specify the sample size for any of the tests (Durability, Holding force, Range of motion, Link Soak, Foot Pedal Cable Retention).
    • Data Provenance: The data provenance is internal testing performed by CooperSurgical, Inc. It is a prospective test in the sense that newly designed units of the ALLY II UPS™ were manufactured and then tested to demonstrate their performance. The country of origin for the testing is not explicitly stated but is implied to be within the company's operational context (likely US, given the FDA 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 as this is a mechanical device, not an AI/ML system that requires expert interpretation for ground truth. The "ground truth" for this device would be defined by engineering specifications and objective measurements (e.g., force in Newtons, angles in degrees, material integrity).

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

    Not applicable for this type of device. Adjudication methods are typically used in clinical studies or for establishing ground truth from human interpretations (e.g., radiology reads). The performance of this device is assessed through engineering and mechanical testing against predefined specifications.

    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 a mechanical uterine positioning system, not an AI-assisted diagnostic or therapeutic tool with human readers.

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

    Not applicable. This is a purely mechanical device; there is no AI algorithm to test for "standalone" performance.

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

    The "ground truth" in this context is defined by engineering specifications, mechanical measurements, and compliance with recognized standards. For example:

    • Holding Force: Measured in units of force (e.g., Newtons or pounds) against a specified minimum.
    • Range of Motion: Measured in degrees or specific positions achievable, defined by design.
    • Durability: Performance over a specified number of cycles or operating hours.
    • Material Integrity: Assessed through material science tests and visual inspection post-soak/cycle.
    • Electrical Safety/EMC: Compliance verified against the specified IEC standards (60601-1 and 60601-1-2).

    8. The sample size for the training set

    Not applicable. This is a physical medical device, not a machine learning model that requires a training set.

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

    Not applicable. As stated above, this is not an AI/ML device.

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