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510(k) Data Aggregation

    K Number
    K170721
    Date Cleared
    2017-04-21

    (43 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Cut-Vac Lighted Smoke Evacuation Electrosurgical Pencil

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

    The Cut-Vac® Smoke Evacuation Electrosurgical is a monopolar device designed for general electrosurgical applications including cutting and coagulation and for removing smoke generated by electrosurgical current when used in conjunction with an effective smoke evacuation system. This device conducts an electrosurgical current from an electrosurgical generator and delivers it to the target tissue to achieve the desired surgical effect.

    Device Description

    The Precision Surgical Cut-Vac® Lighted Smoke Evacuation Electrosurgical Pencil is a standard monopolar electrosurgical pencil with incorporated LED light, and suction ability for cautery smoke. It is a sterile single use device. It performs all standard functions of an electrosurgical pencil with separate buttons for Cutting and Coagulation. Cut-Vac connects to all standard electrosurgical generator units with a standard 3-prong plug. The Cut and Coag buttons, and light switch are on the top of the device. The proximal button to the tip/blade is yellow and controls Cutting. The blue button distal to the tip controls Coagulation. The green slider switch turns the LED light on and off. The LED light does not interfere with the function of the pencil and is encased in clear thermoplastic and does not contact liquid. The light allows the operator to visualize areas during surgeries or overcome shadows despite surgical Operating Room lights. It has removable separate small batteries that are located in the distal plug that attaches to the ESP, and thus are disposable in an environmentally safe method. The retractable blade allows the operator to better control smoke evacuation by shortening the effective blade length. Cut-Vac does not have irrigation capability. It has an 8.5 foot suction tube to attach to any suction with an additional 5 feet of electro-surgical cable from the end of the suction tube to attach to an ESP generator. The first 8.5 feet of the suction tube incorporates the electro-surgical cable to eliminate clutter on the surgical field. The electrical-surgical cable leaves the tubing through a sealed and molded closed port and terminates in a standard 3-prong electro-surgical plug. The remaining portion of the suction tubing terminates to a flexible connector that attaches to different suction canister ports. The integrated device enables the operator to cut, coagulate, evacuate smoke and illuminate the surgical site without the need for separate tools. The Cut-Vac® device must be used in conjunction with an electrosurgical generator and grounding pads in order to power up the device.

    AI/ML Overview

    The document provided describes the Cut-Vac® Lighted Smoke Evacuation Electrosurgical Pencil (K170721) and its substantial equivalence to a predicate device, the Zip-Pen Smoke Evacuation Electrosurgical Pencil (K141587). The information focuses on non-clinical performance data to demonstrate safety and effectiveness, as no human clinical trials were deemed necessary.

    Here's an analysis of the provided information regarding acceptance criteria and the supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present a formal table detailing acceptance criteria with corresponding performance results for each test in a quantitative manner. Instead, it lists the types of tests performed and generally states that the device "passed all testing" or "performed equivalent to the predicate."

    Based on the text, here's a reconstructed table:

    Acceptance Criteria CategorySpecific Test/StandardReported Device Performance
    BiocompatibilityISO 10993-1Passed all requirements.
    Electrical SafetyAAMI ANSI EC 60601-1Passed all requirements.
    High Frequency Electrosurgical SafetyAAMI ANSI EC 60601-2-2Passed all requirements.
    Smoke EvacuationFDA Guidance document "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery" (using methane as surrogate)Performed equivalent to the predicate device at 3 vacuum levels.
    Thermal Zone EffectsFDA Guidance document "Premarket Notification [510(k)] Submissions for Electrosurgical Devices for General Surgery"Performed equivalent to the predicate device (evaluated in muscle, kidney, liver at min, default, max generator settings).
    Tubing IntegrityTubing leak test (quantitative analysis with water)No leaks detected.
    Shelf LifeAccelerated Aging (12-month) followed by performance testingAll units passed protocol acceptance criteria.
    Storage & TransportPackaging Drop Test (ASTM D5276-98)Passed per the standard.
    Transport TestingNot explicitly stated standardPassed.

    2. Sample Sizes and Data Provenance

    • Test Set Sample Size: The document does not specify exact sample sizes for each non-clinical test (e.g., number of devices tested for electrical safety, number of tubing samples for leak tests). For smoke evacuation and thermal zone testing, it states "The Cut-Vac performed equivalent to the predicate," implying a comparative test, but the number of units or test iterations isn't provided. For Shelf Life Testing, it mentions "All units passed protocol acceptance criteria," but the number of "units" is not quantified.
    • Data Provenance: The data is reported as non-clinical performance data generated by Precision Surgical, LLC. The origin (e.g., country) of the specific labs or facilities conducting these tests is not mentioned, but the sponsor is based in the USA (Las Vegas, Nevada). All data appears to be prospective in the sense that these tests were conducted specifically for this 510(k) submission to demonstrate equivalence.

    3. Number of Experts and Qualifications for Ground Truth

    This information is not applicable as the document describes non-clinical performance and equivalence testing, not a study involving human interpretation of data for medical diagnosis or treatment. Therefore, no "ground truth" established by clinical experts for a test set is mentioned. The "ground truth" for these engineering and performance tests would be the established standards and specifications themselves.

    4. Adjudication Method for the Test Set

    This is not applicable as the document describes non-clinical performance and equivalence testing. Adjudication methods typically apply to human-interpreted studies, often in the context of medical imaging or clinical outcomes where expert consensus is needed to resolve discrepancies.

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

    A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The document explicitly states: "There was no human clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. These types of devices, including the predicate devices, have been on the market for many years with proven safety and efficacy for the device. The non-clinical testing detailed in this submission supports the substantial equivalence of the device."

    6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance

    This concept is not applicable to this device. The Cut-Vac® is an electrosurgical hand tool; it does not involve algorithms or AI. Its performance is inherent to its physical design, materials, and electrical properties. The "performance" discussed is related to its physical functions (cutting, coagulation, smoke evacuation, illumination) and compliance with safety standards.

    7. Type of Ground Truth Used

    For the non-clinical tests, the "ground truth" implicitly used is:

    • Established engineering standards: e.g., ISO 10993-1, AAMI ANSI EC 60601-1, AAMI ANSI EC 60601-2-2, ASTM D5276-98.
    • FDA Guidance Document requirements: for smoke evacuation and thermal zone testing.
    • Predicate device performance: for comparative tests, demonstrating "equivalence" to a device already deemed safe and effective.

    8. Sample Size for the Training Set

    This information is not applicable. The device is an electrosurgical pencil and does not involve AI/ML requiring a training set.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable for the same reason as above.

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