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510(k) Data Aggregation

    K Number
    K223272
    Date Cleared
    2023-02-28

    (127 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 SurBlate™ Ablation System is intended for coagulation (thermoablation) of soft tissues. Not for use in cardiac procedures.

    Device Description

    The SurBlate™ Ablation System is an integrated system for interstitial thermoablation of soft tissues through controlled emission of microwaves. The system is composed by four interactive devices (and one optional device), namely: a) SurBlate™-GEN: a digitally controlled microwave power source, operating at 2450 MHz, and delivering up to 100 Watts CW (continuous wave). SurBlate™-GEN features a single output channel. b) SurBlate™-APPLICATOR: an interstitial single-use coaxial microwave applicator, activated by the SurBlate™-GEN and connected to SurBlate™-GEN via the SurBlate™-COAX. c) SurBlate™-PUMP: a peristaltic pump for convective applicator cooling through continuous circulation of liquid coolant, fully controlled by and attached to SurBlate™-GEN. d) SurBlate™-COAX: a microwave coaxial cable serving as a medical grade microwave transmission line used for transmitting microwave energy. Its characteristic impedance is 50 ohm. In the system, it is used to transmit microwave energy from SurBlate™-GEN to the SurBlate™ APPLICATOR. e) SurBlate™-FOOT (Optional): a foot pedal supplied with SurBlate™-GEN for remote control of energy delivery activation.

    AI/ML Overview

    The provided text is a 510(k) summary for the SurBlate™ Ablation System. It details the device, its intended use, comparison to a predicate device, and various performance and safety tests conducted to demonstrate substantial equivalence. However, it does not explicitly describe a study where the device "meets acceptance criteria" in terms of clinical performance metrics like sensitivity, specificity, or improvement over human readers.

    Instead, the submission focuses on engineering and bench performance tests to demonstrate that the SurBlate™ Ablation System is as safe and effective as its predicate device (HS AMICA). The "acceptance criteria" here relate to compliance with international standards and successful operation within predefined technical specifications, rather than clinical efficacy metrics.

    Therefore, many of the requested points regarding clinical testing, expert adjudication, MRMC studies, and ground truth for clinical outcomes cannot be extracted from this document, as those types of studies were not required for this 510(k) clearance for this type of device (an electrosurgical cutting and coagulation device). The document explicitly states: "Animal Study and Human Clinical performance testing were not required to demonstrate safety and effectiveness of SurBlate™ Ablation System."

    However, I can extract information related to the technical performance tests that were conducted.

    Here's a breakdown of the available information based on your request:

    1. Table of acceptance criteria and reported device performance:

    The document describes several performance tests with implied acceptance criteria being successful compliance with the stated ranges and conditions. It doesn't present these in a formal "acceptance criteria vs. reported performance" table for each specific parameter, but rather states successful completion of tests.

    Acceptance Criteria (Implied from stated requirements/tests)Reported Device Performance
    Output power of microwave source: Within 0-100 Watts, adjusted in 5 Watt steps, with ±20% deviation.Passed. "Under rated grid voltage, microwave output power of microwave source machine is within the range of 0 Watts to 100 Watts, gradually adjusted in steps of 5 Watts with a deviation from set power of ±20%."
    Operating time of microwave source: 0-1 min (1 sec steps); 1-15 min (1 min steps), with ±1% deviation.Passed. "From 0 minutes to 1 minute the operating time of the microwave output power of the microwave source can be adjusted in steps of 1 second. From 1 minute to 15 minutes the operating time of microwave output power of the microwave source can be gradually adjusted in steps of 1 minute with a deviation of set time of ±1%."
    VSWR (Voltage Standing Wave Ratio): Maximum ≤3 under service conditions.Passed. "The maximum VSWR for SurBlate™ under service conditions is ≤3."
    Temperature range in service area: 40°C - 112°C, error +3°C.Passed. "Temperature range: 40°C - 112°C, error +3°C."
    Microwave output mode: Continuous wave mode.Passed. "Microwave output is continuous wave mode."
    Applicator Appearance & Structure: Color even, smooth, clean, no burrs, coating intact, words/symbols clear, switches secure.Passed. "Surface of machine and accessories shall be color even, smooth, clean, no burrs, and coating without dropping off and scratch etc. Words, symbols and markings shall be accurate and clear. Switches and push buttons of machine shall be reliably secure to prevent operational failure."
    Electrical Safety & EMC Testing: Compliance with IEC 60601-1, IEC 60601-2-6, IEC 60601-1-2.Passed. "Electrical safety and electromagnetic compatibility (EMC) testing" was conducted. "The system passed all pre-determined acceptance criteria identified in the test plan."
    Software Verification & Validation: Compliance with 21 CFR Part 820.30 & FDA Guidance.Passed. "Software verification and validation testing" was conducted. "Verification and validation testing were completed in accordance with the company's Design Control process in compliance with 21 CFR Part 820.30, which included testing that fulfills the requirements of FDA "Guidance on Software Contained in Medical Devices".
    Biocompatibility: Compliance with ISO 10993 series.Passed. "The biocompatibility evaluation for this device was conducted in accordance with" the listed ISO 10993 standards.
    Sterilization & Shelf-Life: Compliance with ISO 11135-1.Passed. "The sterilization and shelf-life for this device was conducted in accordance with ISO 11135-1:2014."
    Ex-vivo Ablation Performance (Coagulative Performance): Demonstrated safe and effective coagulation; substantially equivalent to predicate device.Passed. "Exvivo testing in liver, kidney and muscle was conducted... Ablation zones across tissue types and environments demonstrated safe and effective procedural success. In comparison to the predicate device, tissue type (porcine liver, kidney and muscle) was tested in the worst-case scenario (room temperature: 20 degrees C)... Ex-vivo ablation sizes for the SurBlate™ Ablation System were deemed to be substantially equivalent to the predicate device."

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

    • Test Set Sample Size:
      • Ex-vivo tissue ablation: Not explicitly stated as a number of samples or tissues, but mentions testing in "liver, kidney and muscle" (porcine) in "worst-case scenario" (20 degrees C). This implies multiple tissue samples were used.
      • For other tests (electrical, software, etc.), the sample size would be related to the number of devices or components tested, but this is not specified.
    • Data Provenance: Not specified for the ex-vivo testing. The manufacturer is Mima-Pro (Nan Tong) Scientific Inc., located in Nantong City, Jiangsu Province, PRC. This suggests the testing may have been conducted there or by a contract research organization.
    • Retrospective or Prospective: These were primarily bench and ex-vivo engineering performance tests, not clinical studies in humans or animals in a retrospective/prospective clinical trial context.

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

    This information is not applicable/not provided in this type of submission. The ground truth for the ex-vivo ablation study was the measurement of the non-stained (coagulated) area using the triphenyltetrazolium chloride (TTC) dye technique, a laboratory method, not expert consensus on pathology or outcomes.

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

    This is not applicable/not provided as there were no clinical image evaluations or similar assessments requiring expert human readers and adjudication.

    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:

    This is not applicable. The device is an ablation system, not an AI imaging analysis tool for diagnostic assistance. No MRMC study was mentioned or required.

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

    This is not applicable as it's a physical device (ablation system), not an AI algorithm. Its "performance" is its ability to coagulate tissue as designed, not to interpret images or classify data.

    7. The type of ground truth used:

    • For Ex-vivo Ablation: Laboratory measurement of the non-stained (coagulated) area using the triphenyltetrazolium chloride (TTC) dye technique. This acts as the "ground truth" for the extent of coagulation.
    • Not expert consensus, pathology, or outcomes data in the clinical sense, as human clinical studies were not required.

    8. The sample size for the training set:

    This is not applicable. The device is not an AI/ML model that requires a training set.

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

    This is not applicable as there is no training set for an AI/ML model.

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