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510(k) Data Aggregation

    K Number
    K232240
    Date Cleared
    2023-11-13

    (108 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Microwave Ablation System is indicated for the coagulation (ablation) of soft tissue. The Microwave Ablation System is not intended for cardiac use.

    Device Description

    The Microwave Ablation System is a microwave power (energy) source that can meet the needs of clinical soft tissue microwave thermal ablation therapy. The microwave energy is transmitted to the disposable microwave ablation needle through coaxial transmission cable, and the disposable microwave ablation needle is directly inserted into the targeted soft tissue, and the electromagnetic wave (microwave) is radiated from the front end of the disposable microwave ablation needle to cause the soft tissue to produce heat and rise. When it reaches the temperature of tissue coagulation and necrosis, in-situ inactivation is formed, that is, the purpose of microwave ablation therapy is achieved.

    The Disposable Thermometer Needle and Foot Switch are accessories for the proposed device. And the proposed device is used in conjunction with the Disposable Microwave Ablation Needle made by our company.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a Microwave Ablation System. It focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study to prove the device meets specific acceptance criteria in the way a clinical trial or performance study for a diagnostic device would.

    Therefore, much of the requested information regarding acceptance criteria, reported performance, sample sizes, expert ground truth, adjudication, MRMC studies, standalone performance, and training set details are not applicable or available from this 510(k) summary. This document primarily focuses on engineering and regulatory compliance rather than clinical performance metrics as might be found in a diagnostic AI device submission.

    Here's an attempt to answer the questions based on the provided text, indicating where information is not available:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present specific quantitative performance acceptance criteria (e.g., accuracy, sensitivity, specificity) for a clinical outcome in the way an AI diagnostic device might. Instead, the "acceptance criteria" are implied by the conformance to various safety, performance, and software standards. The reported "performance" focuses on meeting these standards and demonstrating equivalence to a predicate device.

    Acceptance Criteria CategorySpecific Criteria (Implied from standards)Reported Device Performance/Compliance
    Electrical SafetyConformance to IEC 60601-1:2005, IEC 60601-1:2005/AMD1:2012, IEC 60601-1:2005/AMD2:2020Designed and tested in accordance with the specified IEC 60601-1 standards.
    EMCConformance to EN 60601-1-2: 2015+A1: 2021/ IEC 60601-1-2: 2014+AMD1:2020Designed and tested in accordance with the specified EN/IEC 60601-1-2 standards.
    Device PerformanceConformance to IEC 60601-2-6: 2012, AMD1:2016 (Particular requirements for microwave therapy equipment)Designed and tested in accordance with IEC 60601-2-6. The overall performance test of the proposed device was conducted "as same as the predicate device," addressing main functions (power module, control feedback, microwave transmitting, water circulation).
    Software Life-cycleConformance to ANSI AAMI IEC 62304:2006/A1:2016 and FDA Guidance: Content of Premarket Submissions for Device Software Functions.Software verification was conducted on the proposed device according to FDA software guidance, and the test result proves the functions in each operational mode can be achieved, and the differences in operational modes do not raise new risks.
    Thermal EffectsConformance to FDA Guidance: Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery (Thermal Effects test and Temperature monitoring test).Thermal Effects test and Temperature monitoring test were conducted in accordance with the FDA Guidance. The device includes temperature monitoring features to ensure system safety and utilizes a pumped cooling system (distilled water or saline) for the ablation needle (consistent with predicate).
    Intended UseIndicated for coagulation (ablation) of soft tissue, not intended for cardiac use.The stated indication for use is identical to the predicate device.
    Safety and EffectivenessNo new questions of safety or effectiveness are raised compared to the predicate device.Differences from the predicate device (e.g., operational modes, specific design of components) were analyzed and determined to not raise new risks or affect substantial equivalence.

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

    The document explicitly states: "No clinical study is included in this submission." This means there isn't a "test set" of patient data in the context of evaluating a diagnostic or AI-driven device's clinical performance. The testing mentioned (electrical safety, EMC, thermal effects) would involve laboratory setups and devices, not patient data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable, as no clinical study or test set using patient data for ground truth establishment was conducted or reported.

    4. Adjudication method for the test set

    Not applicable, as no clinical study or test set requiring expert adjudication was conducted or reported.

    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 Microwave Ablation System, which is a therapeutic device, not a diagnostic device that would typically involve human readers or AI assistance for interpretation.

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

    Not applicable. This device is a therapeutic system, not an algorithm or AI product. Its performance is related to its physical functions and safety, not an AI's standalone interpretation capability.

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

    For the engineering and safety tests, the "ground truth" would be the specifications and requirements defined by the relevant international standards (e.g., IEC 60601 series) and FDA guidance documents. For instance, an electrical safety test's ground truth is whether the device does or does not meet the leakage current limits. This is based on objective measurements against engineering standards, not clinical ground truth like pathology.

    8. The sample size for the training set

    Not applicable. There is no mention of a training set as this is not an AI/machine learning device.

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

    Not applicable. There is no mention of a training set.

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    K Number
    K183153
    Date Cleared
    2019-07-08

    (236 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Microwave Ablation System is intended for coagulation (ablation) of soft tissue. It is not intended for use in cardiac procedures.

    Device Description

    The Microwave Ablation System M150E is microwave-based system intended to deliver energy through an antenna inserted into soft tissue for the purpose of coagulating (ablation) of a defined volume of that tissue. The Microwave Ablation System utilizes a 2450MHz generator to deliver power to single microwave ablation antenna or double microwave ablation antennas. The Microwave Ablation Generator provides for user setting of ablation time and ablation power. The proposed device consists of Microwave Ablation Generator, Microwave Ablation Electrode Kits, Temperature Probe and Foot Switch.

    AI/ML Overview
    1. Table of Acceptance Criteria and Reported Device Performance:

    The document describes the device as a Microwave Ablation System. Rather than specific performance metrics like sensitivity/specificity for a diagnostic device, the acceptance criteria for this therapeutic device are based on demonstrating equivalent technical characteristics, safety, and performance to a predicate device.

    Acceptance Criteria / Performance ElementPredicate Device (Emprint™ Ablation System K133821)Proposed Device (Microwave Ablation System M150E)Result / Comparison
    Indications for UseIntended for use in percutaneous, laparoscopic, and intraoperative coagulation (ablation) of soft tissue, including partial or complete ablation of non-resectable liver tumors. Not intended for use in cardiac procedures.Intended for the coagulation (ablation) of soft tissues. Not intended for use in cardiac procedures.Equivalent
    Intended Purposecoagulation and ablation of tissuecoagulation and ablation of tissueEquivalent
    DesignSingle channel; cooling-water cycle, thermal ablation, TEMP probe, foot switch.Double channels; cooling-water cycle, thermal ablation, TEMP probe, foot switch. (Note: Double channel is a difference, but determined not to affect safety/performance.)Similar/Different
    Operating Temperature10°C-30°C5°C-40°CSimilar
    Operating Humidity20%~80% non condensation20%~80% non condensationEquivalent
    Output Parameters2450MHz±50MHz, 0-100W2450MHz±10MHz, 0-100WEquivalent
    Output Impedance50Ω nominal50Ω nominalEquivalent
    Voltage Supply100-240VAC 50-60 Hz100-240VAC 50-60 HzEquivalent
    Fuse Rating6.3 A, 250V6.3 A, 250VEquivalent
    Physicochemical PropertiesNot contain any medications, animal tissues or blood components, especially in contact with human tissue does not contain the above substances.Not contain any medications, animal tissues or blood components, especially in contact with human tissue does not contain the above substances.Equivalent
    Working PrincipleMicrowave energy delivered via antenna to coagulate tissue; transforms into heat, raising temperature to lose bioactivity.Same working principle.Equivalent
    Antenna Length (mm)CA15L1: 150; CA20L1: 200; CA30L1: 300SS-MWA-1526C: 150; SS-MWA-1531C: 150; SS-MWA-2026C: 200; SS-MWA-2031C: 200; SS-MWA-2526C: 250; SS-MWA-2531C: 250 (Note: Different lengths, but stated not to affect safety/performance in terms of depth of tumor position.)Different
    Emission Area Length (mm)CA15L1: 28; CA20L1: 28; CA30L1: 28SS-MWA-1526C: 26; SS-MWA-1531C: 31; SS-MWA-2026C: 26; SS-MWA-2031C: 31; SS-MWA-2526C: 26; SS-MWA-2531C: 31 (Note: Wider range, but stated not to affect safety/performance.)Different
    OD (mm)CA15L1: 2.40; CA20L1: 2.40; CA30L1: 2.40SS-MWA-1526C: 2.08; SS-MWA-1531C: 2.08; SS-MWA-2026C: 2.08; SS-MWA-2031C: 2.08; SS-MWA-2526C: 2.08; SS-MWA-2531C: 2.08 (Note: Thinner diameter to reduce trauma, determined not to affect ablation area or safety/performance.)Different
    Antenna MaterialNot explicitly stated for predicate in comparison table, but implied to be similar biocompatible material.304 stainless steel, biocompatible per ISO 10993-1.Similar
    Disposable/Single-useAntennas are disposable and single-use.Antennas are disposable and single-use.Equivalent
    SterilityAccessories sterilized with EO (SAL: 10-6).Accessories sterilized with EO (SAL: 10-6).Equivalent
    BiocompatibilityPatient-contacting materials are biocompatible.Patient-contacting materials are biocompatible.Equivalent
    Device Temperature MonitoringTemperature monitoring features used to ensure system safety.Temperature monitoring features used to ensure system safety.Equivalent
    Device CoolingPumped normal saline is used to cool the Emprint™ Antenna.Pumped normal saline is used to cool the antenna.Equivalent
    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: Not applicable. The submission states, "Clinical studies were not required to demonstrate the substantial equivalence of the microwave ablation system and the predicated device." The testing primarily involved non-clinical bench and lab testing (e.g., electrical safety, EMC, performance, thermal effects, temperature monitoring, shelf life, package verification, sterilization validation, biocompatibility).
      • Data Provenance: Not applicable, as no clinical test set was used. The non-clinical testing data provenance is implied to be from the manufacturer's internal testing.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable, as no clinical test set was used that required expert ground truth establishment in this type of 510(k) submission.
    3. Adjudication method for the test set:

      • Not applicable, as no clinical test set was used for adjudication.
    4. 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 therapeutic microwave ablation system, not a diagnostic imaging AI device that would involve human readers or AI assistance for interpretation.
    5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

      • Not applicable in the context of diagnostic AI performance. The device is a physically operated medical system. However, software validation was performed, indicating the internal algorithms and software governing the device's operation were tested in a standalone manner (without human intervention in the algorithm's execution during ablation).
    6. The type of ground truth used:

      • For the non-clinical tests, the "ground truth" was established by adherence to recognized national and international standards (e.g., IEC 60601-1, IEC 60601-2-6, IEC 60601-1-2, ISO 11607-1, ISO 11135, ISO 10993), and engineering specifications for system performance, thermal effects, and temperature monitoring. These standards and specifications themselves represent a form of "ground truth" for acceptable device characteristics and safety.
    7. The sample size for the training set:

      • Not applicable, as this device does not involve machine learning or AI models that require a training set in the conventional sense. The "training" here refers to the device's design, development, and adherence to established engineering principles and standards.
    8. How the ground truth for the training set was established:

      • Not applicable, as no machine learning training set was used. The "ground truth" for the device's design and operational parameters was derived from existing medical device standards, predicate device characteristics, and established engineering and physiological principles related to microwave ablation.
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