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510(k) Data Aggregation

    K Number
    K142525
    Device Name
    PK Lap Loop
    Date Cleared
    2014-11-21

    (74 days)

    Product Code
    Regulation Number
    884.4150
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Bipolar Laparoscopic Loop is a 5mm bipolar electrosurgical device. The device is intended to be used for the amputation of the mobilised uterus during Laparoscopic Supracervical (Subtotal) Hysterectomy and the resection of devascularized subserosal pedunculated myomas. It is used in conjunction with the Olympus Electrosurgical Generator ESG-400.

    Device Description

    The Bipolar Laparoscopic Loop is a single use disposable high frequency RF bipolar accessory to be used in conjunction with the Olympus Electrosurgical Generator ESG-400. It is available in an 88mm x 227mm loop size. The device is sterilized by ethylene.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the PK Lap Loop, a bipolar electrosurgical device. The submission focuses on demonstrating substantial equivalence to a predicate device (PKS BiLL) rather than presenting a standalone study with defined acceptance criteria and performance metrics in the typical sense of AI/algorithmic device evaluation.

    Here's an analysis based on the provided text, addressing your points where applicable:

    1. A table of acceptance criteria and the reported device performance

    The concept of specific "acceptance criteria" for performance metrics like sensitivity, specificity, or F1-score, as seen in AI/ML device submissions, is not directly applicable here. This document is for a traditional medical device (electrosurgical loop) and focuses on demonstrating substantial equivalence to an already cleared predicate device. The "performance" is implicitly tied to demonstrating that the new device functions equivalently and safely to the predicate.

    The closest to acceptance criteria are the characteristics compared between the PK Lap Loop and the predicate PKS BiLL. The reported device performance is that these characteristics are identical or similar to the predicate, implying they meet the predicate's established performance and safety profile.

    CharacteristicAcceptance Criteria (Implicit: Substantial Equivalence to Predicate)Reported Device Performance (PK Lap Loop vs. PKS BiLL)
    Electrosurgical GeneratorCompatibility with a cleared generatorDifferent (Olympus ESG 400 vs. Gyrus G400)
    Energy used and deliveredIdentical output waveforms and power levelsIdentical
    Compatibility with other devicesSame as predicateIdentical
    DesignFundamentally same, minor changes no impact on safety/usabilitySimilar (minor corporate branding changes)
    Performance (tissue effect, speeds, forces)Same as predicateIdentical
    Device Min and Max output powersAverage power of one cycle period is 200WIdentical
    Cutting time<15 seconds maxIdentical
    Electrode dimensions88mm x 227mmIdentical
    Loop wire diameter0.4mm single wireIdentical
    To fit trocar5mmIdentical
    Electrical safetyCompliant with IEC 60601, IEC 60601-1, IEC and 60601-2-2Identical
    Thermal safetyCompliant with relevant clauses of IEC 60601Identical
    BiocompatibilityCompliant with ISO 10993Similar (materials mostly same, specific tests for new components)
    Mechanical safetyDesigned to withstand same clinical loadsIdentical
    Sterility/MethodologyValidated sterilization methodDifferent (ETO vs. Gamma Irradiation)
    Sterility/Assurance level10^-6Identical

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document mentions "mechanical and tissue tests" were performed. However, it does not specify the sample size for these tests (e.g., number of tissue samples, number of test repetitions). The data provenance is also not explicitly stated as retrospective or prospective, nor is the country of origin of the data provided. The core of the submission relies on comparing the new device to the predicate, and leveraging prior testing and standards relevant to the predicate.

    3. 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)

    This is not applicable to this type of device submission. There is no concept of "ground truth" to be established by experts in the context of electrosurgical device performance demonstration for substantial equivalence. The tests performed are engineering and biological validations, not clinical assessments by experts for diagnostic or treatment efficacy.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This is not applicable. Adjudication methods are typically used in clinical studies or expert reviews of data (e.g., imaging) to establish ground truth or assess agreement, which is not relevant for this device's validation.

    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. This device is an electrosurgical tool, not an AI or imaging diagnostic device that would involve human readers or AI assistance.

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

    No, a standalone algorithm-only performance study was not done. This is a physical electrosurgical device, not an algorithm.

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

    The concept of "ground truth" as presented in your question (expert consensus, pathology, outcomes data) is not applicable to this premarket notification. The "truth" in this context is established through:

    • Compliance with recognized standards: IEC 60601, ISO 10993, ISO 11607, ISO 11737.
    • Engineering testing: Mechanical, electrical safety, thermal safety.
    • Pre-clinical (tissue) testing: To demonstrate equivalent tissue effects, speeds, and forces.
    • Biocompatibility testing: Compliance with ISO 10993.
    • Sterilization validation: Compliance with ISO 11607 and ISO 11737.

    8. The sample size for the training set

    This is not applicable. This is a traditional medical device, not an AI/ML device that requires a training set.

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

    This is not applicable. See point 8.

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