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510(k) Data Aggregation

    K Number
    K231400
    Date Cleared
    2023-08-04

    (81 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Bladeless Trocar – Artemis Lap Cannula

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

    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.

    Device Description

    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.

    AI/ML Overview

    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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    K Number
    K230058
    Date Cleared
    2023-04-28

    (109 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Bladeless Trocar – Artemis Lap Cannula

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

    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.

    Device Description

    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.

    AI/ML Overview

    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)
    BiocompatibilityFound biocompatible for intended use.Implied equivalent to predicate.
    Reprocessing EffectivenessValidated 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 TestingData demonstrates the proposed devices perform statistically equivalent to the predicate device.Statistically equivalent to predicate device for leak performance.
    Intended UseApplications in abdominal, thoracic, and gynecologic minimally invasive procedures to establish a path of entry.Identical to the relevant part of the predicate device.
    Basic DesignRadiolucent, 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.
    SterilizationCobalt, irradiation.Equivalent (Cobalt, irradiation).
    Seal Design (Outer & Inner)Multi-piece (Pacman), overlapping outer seal; Duckbill inner seal.Equivalent to predicate.
    Obturator Tip DesignBladeless.Equivalent to predicate.
    Sleeve DesignLow-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 DesignLow-profile design.Equivalent to predicate.
    Cannula DesignLow-profile design.Equivalent to predicate.
    Outer Seal MaterialPolycarbonate and Polyisoprene.Equivalent to predicate.
    Inner Seal MaterialPolyisoprene.Equivalent to predicate.
    Dimensions (Diameter)5 mm & 12 mm.Equivalent to predicate.
    Dimensions (Length)75 mm, 100 mm, 150 mm.Equivalent to predicate.
    Sleeve MaterialRadel.Difference: Radel vs. predicate's Polycarbonate.
    Obturator MaterialRadel.Difference: Radel vs. predicate's Polycarbonate.
    PackagingFlexible Film Composite, with lidding film top stock (FMP-521®).Difference: Flexible Film Composite vs. predicate's Copolyester rigid blister.
    Depth Limiter5 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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