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510(k) Data Aggregation
(120 days)
The Flexible HD Cysto-Urethroscope System is used to provide visualization and operative access during diagnostic and therapeutic endoscopic procedures of urinary tract including the urethra, bladder, ureters, and kidneys.
The components subject of this submission are: the Flexible HD Cysto-Urethroscope (Part Number: 11272VH(U)), the LUER ports (Part Number: 11014L(U)), the Suction Valve (Part Number: 11301CE1/20), and the IMAGE1 S CCU. The CCU consists of the IMAGE1 S Connect Module (Model Number: TC200US) and IMAGE1 S X-Link (Model Number: TC301US).
The provided information is a 510(k) summary for the KARL STORZ Flexible HD Cysto-Urethroscope System. This type of submission is for demonstrating substantial equivalence to a legally marketed predicate device, not for proving a device meets specific acceptance criteria based on AI performance or clinical efficacy. The changes submitted in this 510(k) are related to adding new sterilization methods (Sterilization V PRO-60 and High Level Disinfection).
Therefore, the document does not contain the kind of information requested regarding acceptance criteria and performance studies for an AI/ML driven device, specifically:
- A table of acceptance criteria and the reported device performance: This document does not describe performance metrics for a diagnostic or AI-driven device, but rather refers to reprocessing validation and biocompatibility.
- Sample size used for the test set and the data provenance: Not applicable as there's no mention of a test set for AI performance. The studies mentioned are non-clinical (biocompatibility and reprocessing validation).
- Number of experts used to establish the ground truth...: Not applicable as there's no AI component or ground truth establishment for diagnostic performance.
- Adjudication method: Not applicable.
- If a multi-reader multi-case (MRMC) comparative effectiveness study was done: The document explicitly states "Clinical testing was not required to demonstrate the substantial equivalence to the predicate devices. Non-clinical bench testing was sufficient to establish the substantial equivalence of the modifications." This means no MRMC study was performed.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable as this is not an AI/ML device.
- The type of ground truth used: Not applicable.
- The sample size for the training set: Not applicable.
- How the ground truth for the training set was established: Not applicable.
Summary of Device Performance and Acceptance Criteria from the Provided Document:
The acceptance criteria and performance data in this 510(k) summary are related to the safety and functionality of the endoscope itself, particularly regarding its reprocessing and biocompatibility, as opposed to diagnostic performance of an AI component.
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria Category | Specific Criteria/Tests | Reported Device Performance/Conclusion |
|---|---|---|
| Biocompatibility | ISO 10993-5:2009/(R) 2014 Cytotoxicity | Performed according to ISO 10993-1 and FDA Guidance. |
| ISO 10993-10:2010 Sensitization & Irritation | Performed according to ISO 10993-1 and FDA Guidance. | |
| ISO 10993-11:2006/(R) 2010 Systemic Toxicity | Performed according to ISO 10993-1 and FDA Guidance. | |
| Overall Conclusion | The biocompatibility evaluation for patient-contacting components was performed and deemed acceptable. | |
| Reprocessing Validation | Cleaning Validation | Validation activities performed according to FDA Guidance. The device maintained functionality after reprocessing cycles. |
| Sterilization Validation (V-PRO 60 and HLD) | Validation activities performed according to FDA Guidance and relevant standards (AAMI TIR 12, ISO 15883-5, AAMI TIR 30, AAMI/ANSI/ISO 11737-1, ASTM E1837-96). Confirmed effective sterilization for specified methods. | |
| Overall Conclusion | The reprocessing data submitted is in compliance with relevant standards, demonstrating the device can be effectively cleaned, sterilized, and high-level disinfected. | |
| Functional Equivalence | Comparison to Predicate Device (K182723) | The nonclinical tests demonstrate that the subject device performs as well as or better than the legally marketed predicate device (KARL STORZ Flexible HD Cysto-Urethroscope K182723). |
2. Sample size used for the test set and the data provenance:
- The document does not specify sample sizes for the biocompatibility or reprocessing validation tests. These tests are typically performed on a limited number of device samples or representative materials.
- Data provenance is not specified beyond being "non-clinical bench testing." There's no mention of country of origin or retrospective/prospective nature as this applies to clinical study data, which was explicitly not required.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. Ground truth establishment by experts pertains to diagnostic or clinical performance evaluations, which were not part of this 510(k) submission.
4. Adjudication method for the test set:
- Not applicable.
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:
- No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical testing was not required to demonstrate the substantial equivalence to the predicate devices. Non-clinical bench testing was sufficient to establish the substantial equivalence of the modifications." This device is an endoscope system, not an AI-driven diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an algorithm or AI-driven device.
7. The type of ground truth used:
- Not applicable in the context of diagnostic performance. For biocompatibility and reprocessing, the "ground truth" is adherence to established international standards and FDA guidance for these types of non-clinical tests.
8. The sample size for the training set:
- Not applicable. No training set is mentioned as this is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not applicable.
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(207 days)
The Flexible HD Cysto-Urethroscope System is used to provide visualization and operative access during diagnostic and therapeutic endoscopic procedures of urinary tract including the urethra, bladder, ureters, and kidneys.
The components subject of this submission are: the Flexible HD Cysto-Urethroscope (Part Number: 11272VH(U)), the LUER ports (Part Number: 11014L(U)), the Suction Valve (Part Number: 091011-20), and the IMAGE1 S CCU. The CCU consists of the IMAGE1 S Connect Module (Model Number: TC200US) and IMAGE1 S X-Link (Model Number: TC301US). The Flexible HD Cysto-Urethroscope (Part Number: 11272VH(U)) is a reusable, flexible video scope with an insertion shaft OD of 5.5 mm and length of 37 cm, a working channel OD of 2.3 mm, and a suction channel. Users can choose to attach either a LUER port with stopcocks (Part Number: 11014L) or a double LUER port (Part Number: 11014LU) to the working channel port. In terms of optics, it has direction of view of 0 degrees and field of view of 100 degrees.
The provided document does not describe the acceptance criteria or a study that proves the device meets those criteria in the context of diagnostic performance (e.g., sensitivity, specificity, accuracy). Instead, it focuses on the substantial equivalence of the Flexible HD Cysto-Urethroscope System to predicate devices based on non-clinical performance data, primarily concerning electrical safety, EMC, biocompatibility, and reprocessing validation.
Here's an analysis of the available information:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not provide a table with specific performance metrics like sensitivity, specificity, or image quality scores that would typically be associated with acceptance criteria for diagnostic devices. Instead, the "performance" is demonstrated through compliance with various safety and technical standards for medical devices.
| Acceptance Criteria Category | Reported Device Performance (Compliance) |
|---|---|
| Electrical Safety | Compliant with ANSI/AAMI ES:60601-1:2005 |
| Electromagnetic Compatibility | Compliant with IEC 60601-1-2:2007 |
| Biocompatibility | Compliant with ISO 10993-1, ISO 10993-5:2009/(R) 2014, ISO 10993-10:2010, ISO 10993-11:2006/(R) 2010, and FDA Guidance |
| Photobiological Safety | Compliant with IEC 62471:2006 |
| Reprocessing Validation (Cleaning & Sterilization) | Compliant with AAMI TIR 12:2010, ISO 15883-5:2005, AAMI TIR 30:2011, AAMI/ANSI/ISO 11737-1:2006/(R)2011, ASTM E1837-96:2014, and FDA Guidance |
2. Sample Size Used for the Test Set and Data Provenance:
No sample size for a "test set" in the context of diagnostic performance (e.g., patient data, image dataset) is mentioned. The studies performed were non-clinical bench testing to evaluate electrical safety, EMC, biocompatibility, and reprocessing. These tests involve laboratory procedures on device components or the entire device, not on human subjects or patient data. Therefore, data provenance (country of origin, retrospective/prospective) is not applicable in this context.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
Not applicable. Since the studies were non-clinical bench tests (e.g., electrical measurements, material testing, sterilization efficacy), there was no "ground truth" to be established by experts in the diagnostic sense. The results of these tests are typically evaluated against established engineering specifications and regulatory standards.
4. Adjudication Method for the Test Set:
Not applicable for the same reasons as above. There was no need for expert adjudication for non-clinical bench testing.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical testing was not required to demonstrate the substantial equivalence to the predicate devices. Non-clinical bench testing was sufficient to establish the substantial equivalence of the modifications." This indicates that there was no human reader study, and therefore, no effect size of AI assistance could be determined.
6. If a Standalone (algorithm only without human-in-the-loop performance) was done:
No, a standalone algorithm performance study was not done. This device is a physical endoscope system, not an AI algorithm.
7. The Type of Ground Truth Used:
As noted, there was no "ground truth" in the diagnostic context. For the non-clinical tests, the "ground truth" implicitly refers to the established scientific and regulatory standards (e.g., specific voltage limits for electrical safety, acceptable cytotoxicity levels for biocompatibility, sterility assurance levels for reprocessing).
8. The Sample Size for the Training Set:
Not applicable. This device is not an AI/ML algorithm that requires a training set.
9. How the Ground Truth for the Training Set was Established:
Not applicable for the same reason as above.
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