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510(k) Data Aggregation
(170 days)
The Bladeless Trocar, Bladed Trocar, and Hasson Trocar have application in a variety of laparoscopic procedures to provide a port of entry for laparoscopic instruments.
The Disposable Surgical Trocar is composed of two parts, one obturator and one guide tube (cannula). The obturator of the Bladeless Trocar is plastic allowing the surgeon to dilate between tissues. The obturator of Bladed Trocar is made of PC and a small blade made of stainless steel, which is released when the surgeon presses the trocar to help with cutting. The Disposable Surgical Trocar Kit, bladed or bladeless, has one obturator and two cannulas or two obturators and four cannulas. The device is for single use only. This device is sterilized with ethylene oxide and has a shelf life of 3 years.
This is an FDA 510(k) summary for a medical device called "Bladeless Trocar; Bladed Trocar; Hasson Trocar." The document describes the device, its intended use, and compares it to a legally marketed predicate device (K141594).
However, your request asks for "acceptance criteria and the study that proves the device meets the acceptance criteria" specifically in the context of an AI/ML medical device submission. The provided document is for a mechanical surgical instrument (trocar) and does not involve AI/ML. Therefore, the requested information categories concerning AI/ML performance (e.g., sample size for test set, data provenance, expert ground truth, MRMC studies, standalone performance, training set details) are not applicable to this submission.
The document states:
"The subject device trocar models (Bladeless Trocar, Hasson Trocar) are manufactured by the same company that manufactures those of the predicate device (Unimicro) and are identical to those cleared under K141594. As such, performance testing is not required."
This statement indicates that the regulatory acceptance is based on the substantial equivalence to a predicate device, specifically because the new device is identical and manufactured by the same company as the predicate. Therefore, no new performance studies were conducted or required to demonstrate that the device meets acceptance criteria.
To specifically address the prompts given the available information:
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A table of acceptance criteria and the reported device performance
- Acceptance Criteria: Substantial Equivalence to predicate device K141594. The key criteria are identical design, materials, manufacturing process, and intended use to a previously cleared device.
- Reported Device Performance: Not applicable, as performance testing was explicitly stated as "not required" due to the identical nature to the predicate device. The performance is assumed to be equivalent to the predicate device.
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable as no performance study was conducted.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not applicable as no performance study was conducted.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable as no performance study was conducted.
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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 non-AI device.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a non-AI device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Not applicable as no performance study was conducted. Regulatory acceptance is based on substantial equivalence to the predicate device.
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The sample size for the training set
- Not applicable. This is a non-AI device.
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How the ground truth for the training set was established
- Not applicable. This is a non-AI device.
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(145 days)
ENPOLE is a single-use medical device to have a port to insert endoscopic instruments for endoscopic procedures.
The Bladeless Trocar is a sterile single patient use instrument consisting of a sleeve in sizes from 5 mm to 12 mm diameters. The trocar sleeve for the devices contains two seal, an outer integrated self-adjusting seal that accommodates instruments ranging from 5 mm to 12.5 mm in diameter where indicated and an internal seal. Together, these seal minimize gas leakage when instruments are inserted or withdrawn through the trocar. The 5 mm trocar sleeve accommodates only 5 mm instruments. A stopcock valve is compatible with standard luer lock fittings and provides attachment for gas insufflation and desufflation. Bladeless trocar is access into the abdomen of laparoscopy that is particular to the insertion of surgical instruments through small incisions. The sleeve penetrated into the intra- abdominal by the obturator is inserted and fixed in the abdominal wall, which is a principle that allows laparoscopy to be performed at a constant abdominal pressure state by keeping it sealed to the outside of the human body.
The provided document describes the FDA 510(k) clearance for the ENPOLE® Bladeless Trocar, a single-use medical device used to create a port for inserting endoscopic instruments during endoscopic procedures. It does not contain information about acceptance criteria and a study proving device performance in the context of an AI/ML powered device. The "Performance Data" section lists several physical and functional tests, but the criteria are generically stated as "Internal standard" and the results as "Pass".
Therefore, I cannot fulfill your request for information regarding AI/ML related acceptance criteria, study design, sample sizes, ground truth establishment, or expert involvement as this document pertains to a traditional medical device (bladeless trocar) and not an AI/ML-powered one.
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(81 days)
The Artemis Lap Cannula has applications in abdominal, thoracic, and gynecologic minimally invasive procedures to establish a path of entry for minimally invasive instruments. Artemis Lap Cannula may be used for primary and secondary insertions.
Artemis Lap Cannula system is a radiolucent, reusable, bladeless laparoscopic trocar, consisting of a cannula, an obturator, a depth limiter, and a disposable standalone seal pack. The trocar is available in two diameters: Ø5mm and Ø12mm, each consists of 4 different length variants. Depth limiter component is available in two diameters and fits either the Ø5mm or Ø12mm cannula regardless of the length. Depth limiter can be used to prevent over penetration during surgical procedures. Artemis Lap Cannula may be used in abdominal, thoracic, or gynecological procedures.
The provided text describes a 510(k) premarket notification for a medical device called the "Bladeless Trocar - Artemis Lap Cannula" (K231400) and references a previous clearance (K230058) as a primary predicate. This document is a regulatory submission, not a study report, and thus focuses on demonstrating substantial equivalence to a predicate device rather than presenting a standalone clinical or analytical performance study with acceptance criteria and detailed outcomes in the same way one might describe an AI/ML device study.
Therefore, the information requested regarding acceptance criteria and a study proving the device meets those criteria, particularly aspects like sample sizes for test/training sets, data provenance, expert qualifications, adjudication methods, MRMC studies, or standalone algorithm performance, is not applicable or available in this type of regulatory document for this specific device.
This device (Bladeless Trocar - Artemis Lap Cannula) is a physical surgical instrument, not an AI/ML diagnostic or prognostic system. The performance claims for such devices typically revolve around mechanical properties, biocompatibility, and sterility, which are verified through non-clinical testing and comparison to legally marketed predicate devices.
However, I can extract information regarding the non-clinical testing performed and the conclusion drawn from it, which serves as a form of "proof" of meeting the regulatory requirements for substantial equivalence.
Non-Clinical Testing and Performance for Bladeless Trocar - Artemis Lap Cannula (K231400)
1. Table of Acceptance Criteria and Reported Device Performance (Derived from Regulatory Review)
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Leak Testing: Demonstrate performance statistically equivalent to the predicate device. | "The leak test data demonstrates the proposed devices preform statically equivalent to the predicate device." |
| ISO 80639-7 Compliance: Meet criteria of the standard. | "Nonclinical testing in accordance with ISO 80639-7 was completed. The test data demonstrates success and met the criteria of ISO 80369-7." (Note: The provided text mistakenly refers to 80639-7 in the criterion and 80369-7 in the performance. Assuming 80369-7 is the correct standard, likely relating to small-bore connectors.) |
Explanation of "Acceptance Criteria" for this type of device:
For a physical surgical instrument like a trocar, "acceptance criteria" are typically defined by recognized consensus standards (e.g., ISO standards for medical devices, biomechanical testing standards) and comparison to predicate devices. The primary goal is to demonstrate that the new device is as safe and effective as a legally marketed device.
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not specified in the provided text. Non-clinical testing typically involves a statistically relevant number of units for mechanical or material tests, but the exact count is not detailed here.
- Data Provenance: The testing was "Nonclinical Testing" conducted to support the 510(k) submission. This is laboratory-based testing, not human or patient data. The country of origin of the data is implicitly the country where the manufacturer (T.A.G. Medical Products Corporation, Ltd, Israel) conducted or commissioned the tests.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
- Not applicable. This information pertains to studies involving expert review for setting ground truth (e.g., for AI/ML algorithms). This device and its associated testing do not involve establishing ground truth from expert clinical review. The "ground truth" for non-clinical testing is typically defined by the test protocol, measurement standards, and device specifications.
4. Adjudication Method for the Test Set:
- Not applicable. This concept relates to reconciling disagreements among experts in setting ground truth for data. Non-clinical physical testing results are usually objective measurements, not subject to expert adjudication in the same manner.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- No. An MRMC study is relevant for comparing the performance of human readers, often with and without AI assistance, on diagnostic cases. This device is a surgical instrument, not a diagnostic tool requiring such a study.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not applicable. This refers to the performance of an AI algorithm in isolation. This device is a physical instrument, not an algorithm.
7. The Type of Ground Truth Used:
- For the non-clinical tests (leak testing, ISO 80369-7 compliance), the "ground truth" is defined by:
- Established Test Standards: Adherence to the specified mechanical and performance characteristics outlined in the relevant ISO standard (ISO 80369-7).
- Predicate Device Performance: Comparison to the performance characteristics of the legally marketed predicate device (K230058) for specific attributes like leak resistance.
- Device Specifications: Meeting the manufacturer's own design specifications for the device.
8. The Sample Size for the Training Set:
- Not applicable. There is no "training set" in the context of a physical medical device like a trocar. This concept applies to AI/ML algorithms that learn from data.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable. As there is no training set, this question is not relevant.
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(109 days)
The Artemis Lap Cannula has applications in abdominal, thoracic, and gynecologic minimally invasive procedures to establish a path of entry for minimally invasive instruments. Artemis Lap Cannula may be used for primary and secondary insertions.
Artemis Lap Cannula system is a radiolucent, reusable, bladeless laparoscopic trocar, consisting of a cannula, an obturator, a depth limiter, and a disposable standalone seal pack. The trocar is available in two diameters: Ø5mm and Ø12mm, each consists of 4 different length variants. Depth limiter component is available in two diameters and fits either the Ø5mm or Ø12mm cannula regardless of the length. Depth limiter can be used to prevent over penetration during surgical procedures. Artemis Lap Cannula may be used in abdominal, thoracic, or gynecological procedures.
This document describes a 510(k) premarket notification for the "Bladeless Trocar - Artemis Lap Cannula." The submission seeks to prove substantial equivalence to a legally marketed predicate device (K032676, the ENDOPATH III Trocar System).
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The provided text does not explicitly state numerical acceptance criteria for performance metrics in a table format, nor does it provide detailed quantitative performance data for the Artemis Lap Cannula. Instead, the document focuses on demonstrating substantial equivalence through a comparison of technological characteristics and nonclinical testing.
Here's a summary of the stated performance and comparisons:
| Acceptance Criteria (Implied) | Reported Device Performance (Artemis Lap Cannula) | Comparison to Predicate (ENDOPATH III Trocar System) |
|---|---|---|
| Biocompatibility | Found biocompatible for intended use. | Implied equivalent to predicate. |
| Reprocessing Effectiveness | Validated reprocessing instructions are sufficient to clean and sterilize it in healthcare settings. | Implied equivalent to predicate. |
| Small-Bore Connectors (ISO 80369-7) | Completed testing; data demonstrates success and met the criteria of ISO 80369-7. | Implied equivalent/compliant to standard. |
| Leak Testing | Data demonstrates the proposed devices perform statistically equivalent to the predicate device. | Statistically equivalent to predicate device for leak performance. |
| Intended Use | Applications in abdominal, thoracic, and gynecologic minimally invasive procedures to establish a path of entry. | Identical to the relevant part of the predicate device. |
| Basic Design | Radiolucent, reusable, bladeless laparoscopic trocar, consisting of cannula, obturator, depth limiter, and disposable standalone seal pack. Two diameters (5mm, 12mm), 4 length variants, depth limiter. | Same basic design, but with differences in sleeve/obturator material, packaging, sleeve design, and inclusion of a depth limiter. These differences do not raise new questions of safety or effectiveness. |
| Sterilization | Cobalt, irradiation. | Equivalent (Cobalt, irradiation). |
| Seal Design (Outer & Inner) | Multi-piece (Pacman), overlapping outer seal; Duckbill inner seal. | Equivalent to predicate. |
| Obturator Tip Design | Bladeless. | Equivalent to predicate. |
| Sleeve Design | Low-profile design; release button for removal and locking of seal pack. | Equivalent to predicate for low-profile design; Difference: release button for seal pack vs. predicate's outer seal only. |
| Obturator Design | Low-profile design. | Equivalent to predicate. |
| Cannula Design | Low-profile design. | Equivalent to predicate. |
| Outer Seal Material | Polycarbonate and Polyisoprene. | Equivalent to predicate. |
| Inner Seal Material | Polyisoprene. | Equivalent to predicate. |
| Dimensions (Diameter) | 5 mm & 12 mm. | Equivalent to predicate. |
| Dimensions (Length) | 75 mm, 100 mm, 150 mm. | Equivalent to predicate. |
| Sleeve Material | Radel. | Difference: Radel vs. predicate's Polycarbonate. |
| Obturator Material | Radel. | Difference: Radel vs. predicate's Polycarbonate. |
| Packaging | Flexible Film Composite, with lidding film top stock (FMP-521®). | Difference: Flexible Film Composite vs. predicate's Copolyester rigid blister. |
| Depth Limiter | 5 or 12 mm in diameter. | Difference: Included vs. predicate's "Not included with system." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state sample sizes for specific tests (e.g., biocompatibility testing might involve various samples for different analyses, and leak testing would have its own sample size).
- Test Set Sample Size: Not explicitly stated for each test.
- Data Provenance: Not explicitly stated whether retrospective or prospective. Given the nature of pre-market testing for medical devices (biocompatibility, reprocessing, performance testing), it is typically prospective testing conducted specifically for the submission. The country of origin of the data is not specified beyond the applicant's location (Israel).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. The tests described (biocompatibility, reprocessing, ISO standard testing, leak testing) are primarily objective engineering/scientific tests, not typically reliant on expert interpretation for "ground truth" in the same way clinical imaging or diagnostic studies might be.
4. Adjudication Method for the Test Set
Not applicable for the types of nonclinical tests described. Adjudication methods are typically relevant for studies involving human interpretation or clinical outcomes.
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
A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is relevant for AI-powered diagnostic or assistive devices, which the "Bladeless Trocar - Artemis Lap Cannula" is not. It is a surgical instrument.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
A standalone performance study (algorithm only) was not done. This is not an AI/algorithm-based device.
7. The Type of Ground Truth Used
The "ground truth" for the nonclinical tests (biocompatibility, reprocessing, ISO standards, leak testing) typically refers to established scientific methodologies, validated test methods, and pre-defined acceptance criteria based on industry standards and regulatory requirements. For example:
- Biocompatibility: Established ISO standards (e.g., ISO 10993 series) define the ground truth for evaluating biological response.
- Reprocessing: Ground truth is established by validated protocols demonstrating the device can be consistently cleaned and sterilized to meet sterility assurance levels.
- ISO 80369-7: Ground truth is the successful meeting of the dimensional and performance requirements defined in the standard.
- Leak Testing: Ground truth is the quantitative measurement of leakage and its statistical equivalence to the predicate, demonstrating it meets performance expectations for sealing.
8. The Sample Size for the Training Set
Not applicable. This is not an AI/machine learning device that uses a "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable. This is not an AI/machine learning device.
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