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510(k) Data Aggregation

    K Number
    K103375
    Date Cleared
    2011-03-16

    (120 days)

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

    PLUMEPEN INTEGRATED SMOKE EVACUATION PENCIL

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

    The PLUMEPEN is designed for general electrosurgical applications, including cutting and coagulation, and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. The pencil enables the operator to remotely conduct an electrosurgical current from the output connector of an electrosurgical unit to the operative site for the desired surgical effect.

    Indications for use for PLUMEPEN® Integrated Smoke Evacuation Pencil include:

    • To remove smoke plume from the surgical site a.
    • b. To remotely conduct an electrosurgical current from the output connector of an electrosurgical unit to the target tissue for the desired surgical effect
    Device Description

    The PLUMEPEN Integrated Smoke Evacuation Pencil is a sterile, single use integrated electrosurgical pencil and smoke evacuation handpiece. The device is intended for general electrosurgical applications and when used in conjunction with an effective smoke evacuation system, for removing smoke generated by electrosurgery.

    The device is constructed using the same materials and design specifications commonly found in the predicate devices in the electrosurgical marketplace. The device is designed to integrate smoke evacuation into electrosurgery by combining both features into a single handpiece. The integrated smoke evacuation pathway is located above the electrosurgical blade to capture the smoke plume created during cauterization. The extendable channel allows for adjustment of the capture position to accommodate a variety of different style and length electrosurgical blades. There are two (2) buttons on the device, which activate monopolar cut or coagulate. The pencil is connected to tubing which will be attached to a variety of smoke evacuation systems. The smoke is then filtered by the smoke evacuation system to limit personnel exposure to the hazards associated with surgical smoke plume. The device will be packaged singly for sterile distribution.

    AI/ML Overview

    This 510(k) summary describes a medical device called the PLUMEPEN® Integrated Smoke Evacuation Pencil, which combines electrosurgery and smoke evacuation functions. The submission aims to demonstrate its substantial equivalence to previously cleared predicate devices.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly define specific quantitative acceptance criteria (e.g., minimum smoke capture efficiency, maximum temperature rise, specific electrical performance thresholds) for the PLUMEPEN. Instead, it relies on the concept of "substantial equivalence" to predicate devices.

    The reported device performance is described generally as:

    Acceptance Criterion (Implied)Reported Device Performance
    Electrosurgical Functionality (Cut & Coagulate)Performs as intended, with the same or similar results as a predicate device. The technological characteristics do not change compared to predicate devices. Utilizes the same electrosurgical pencil as K936304.
    Smoke Evacuation FunctionalityPerforms as intended. Designed to remove smoke generated by electrosurgery. Placement of the smoke capture channel above the electrosurgical blade has demonstrated "superior capture effectiveness." The nozzle is designed not to impede electrosurgical operation and provides for intake of surgical smoke. The extendable channel allows for adjustment.
    Safety"As safe and performs as well as or better than the previously identified legally marketed predicate devices." Complies with applicable sections of IEC 60601-2-2 (Standard for Electrosurgical Devices) and ISO 10993 (Biocompatibility). The predicate GOLDVAC provides alarms for conditions that could pose risk. Uses previously cleared stainless steel and non-stick blades. Uses K-resin (SBC) for the smoke tube, a "higher quality, similar material as polycarbonate."
    Operational Characteristics (Integration of functions, ease of use, clutter)Equivalent to predicate devices (GoldVac, PenEvac, PenAdapt) in that cut, coagulate, and smoke evacuations are contained in one device, limiting the need for several devices. Tubing houses the cord set to eliminate clutter. Back end of the pencil swivels for maximum range of motion with limited drag.
    MaterialsUses ABS plastic for the body (like PLUMEPEN and predicate devices except PenAdapt). Uses previously cleared stainless steel blade (K936304) and non-stick blade (K043036). Uses K-resin (SBC) for its smoke tube, which is described as a "higher quality, similar material as polycarbonate" used in predicate devices.
    Compliance with StandardsComplies with IEC 60601-2-2 and ISO 10993.

    2. Sample Size Used for the Test Set and Data Provenance

    The document explicitly states: "Bench testing on the subject device has shown the device to perform as intended with the same or similar results as a predicate device."

    • Sample Size for Test Set: Not specified. The document only mentions "the subject device" (singular), implying that perhaps one or a few units were tested to demonstrate performance. There is no information on the number of individual tests or repetitions performed.
    • Data Provenance: The testing was "bench testing," meaning in a laboratory setting. There is no information provided about the country of origin of data or whether it was retrospective or prospective. It is a non-clinical study.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    This information is not provided. The study described is a non-clinical bench test, not one that would typically involve human expert interpretation for ground truth establishment in the way, for example, an imaging diagnostic algorithm would.

    4. Adjudication Method for the Test Set

    This information is not applicable/provided. As it was a non-clinical bench test, an adjudication method for a test set based on expert consensus would not be relevant. The "ground truth" (or performance standard) appears to be derived from the expected function of electrosurgical pencils and smoke evacuation systems, and comparison to predicate devices, rather than expert adjudication of clinical outcomes or images.

    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, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is relevant for diagnostic or interpretive AI systems where human readers evaluate cases. The PLUMEPEN is an electrosurgical tool, and its evaluation focuses on its physical and functional performance, not its impact on human reader performance.

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

    The entire "Performance Testing" section describes standalone non-clinical bench testing of the device's physical and functional attributes. The device itself does not contain an "algorithm" in the sense of an AI system. The testing evaluated its capacity for electrosurgery and smoke evacuation.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical testing appears to be based on:

    • Functional expectations: The device should perform cutting, coagulation, and smoke evacuation effectively.
    • Comparison to predicate devices: The device should perform "with the same or similar results as a predicate device," and be "as safe and performs as well as or better than" them.
    • Compliance with recognized standards: Adherence to IEC 60601-2-2 and ISO 10993.

    There is no mention of pathology, clinical outcomes data, or expert consensus in the typical sense of evaluating a diagnostic or therapeutic outcome.

    8. The Sample Size for the Training Set

    This information is not applicable/provided. The PLUMEPEN is a physical medical device, not an AI/machine learning algorithm that requires a "training set."

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

    This information is not applicable/provided for the reason stated in point 8.

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