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510(k) Data Aggregation

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    Device Name :

    Valleylab™ SM Smoke Management Pencil with Edge™ Blade Electrode, 10’ (3m) (VSMP10); Valleylab™ SM Smoke

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

    The Valleylab™ SM Smoke Management Pencil and accessories are designed for general electrosurqical applications, including cutting and coagulation, and for removing surgical 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.

    Device Description

    The Valleylab™ SM Smoke Management Pencils are monopolar electrosurgical smoke evacuation pencils intended for cutting and coagulation of tissue while simultaneously removing surgical smoke. The pencils are designed to capture surgical smoke and improve visibility to target tissues, while reducing staff and patient exposure to the hazards of surgical plume. The Valleylab™ SM Smoke Management Extended Nozzle accessories are for use with longer electrodes for deeper access procedures. The predicate device is the Valleylab™ Smoke Evacuation Rocker Switch Pencil cleared under K182772.

    The proposed devices are compatible with Covidien electrosurgical generators at a maximum peak voltage 4500 Vpk having a 3-prong connector and smoke evacuators having a 3/8" port. Electrode compatibility includes use with standard 3/32" diameter hex and non-hex electrodes. The pencils are available in 10' and 15' tubing/cable lengths models.

    AI/ML Overview

    This document pertains to the 510(k) premarket notification for the Valleylab™ SM Smoke Management Pencil and accessories. It's important to note that this device is a physical electrosurgical tool and does not contain an AI component. Therefore, much of the requested information regarding acceptance criteria and studies for AI-driven devices (like sample sizes for test sets, ground truth establishment for AI, MRMC studies, standalone algorithm performance, and training set details) is not applicable here.

    However, I can extract and present the acceptance criteria and performance testing conducted for this device, which are relevant to its substantial equivalence determination.


    Acceptance Criteria and Reported Device Performance

    The substantial equivalence determination for the Valleylab™ SM Smoke Management Pencil and accessories is based on meeting various performance standards and demonstrating safety and efficacy comparable to its predicate device (Valleylab™ Smoke Evacuation Rocker Switch Pencil cleared under K182772).

    Here's a summary of the performance testing and their acceptance criteria, as reported in the 510(k) summary:

    CategoryAcceptance Criteria (Met Standards/Requirements)Reported Device Performance
    Sterilization & Shelf-LifeSterilization by ethylene oxide (EO) to sterility assurance level 10-6 in accordance with ISO 11135, ISO 11737-1, ISO 11737-2, and ISO 10993-7. Product packaging designed and validated per ISO 11607-1, ISO 11607-2, ASTM D4169. Shelf-life determination based on accelerated aging methods per ASTM F1980.The Valleylab™ SM Smoke Management Pencil and accessories met the acceptance criteria for sterilization by ethylene oxide (EO) to sterility assurance level 10-6 in accordance with the applicable validation standards. Product packaging was designed and validated in accordance with packaging standards. The Valleylab™ SM Smoke Management Pencils are labeled for a 4-year shelf-life, and the Valleylab™ SM Smoke Management Extended Nozzles are labeled for a 5-year shelf-life in accordance with accelerated aging methods.
    BiocompatibilityRequirements of biocompatibility standard ISO 10993-1 for the following endpoints: cytotoxicity, sensitization, intracutaneous reactivity, acute systemic toxicity, and material-mediated pyrogenicity.The Valleylab™ SM Smoke Management Pencil and accessories met the requirements of biocompatibility standard ISO 10993-1 for the specified endpoints.
    SoftwareN/A (The device is not a software-driven device).The Valleylab™ SM Smoke Management Pencil does not contain software.
    Electromagnetic Compatibility & Electrical SafetyApplicable clauses of electromagnetic compatibility standard IEC 60601-1-2 and electrical safety standards IEC 60601-1, and IEC 60601-2-2.The Valleylab™ SM Smoke Management Pencil met the applicable clauses of electromagnetic compatibility standard IEC 60601-1-2 and electrical safety standards IEC 60601-1, and IEC 60601-2-2.
    Performance Testing - BenchDevice requirements for mechanical, functional, reliability, and ex vivo thermal tissue effect testing. (Specific quantitative acceptance criteria are not detailed in this summary document but are implied to be met through internal validation.)The Valleylab™ SM Smoke Management Pencil and accessories met the device requirements for mechanical, functional, reliability, and ex vivo thermal tissue effect testing.
    Usability/Human FactorsDemonstration of safe and effective use for the intended users, intended use, and use environments according to methods in IEC 60601-1-6 and IEC 62366-1.The Valleylab™ SM Smoke Management Pencil and accessories demonstrated safe and effective use for the intended users, intended use, and use environments according to methods in IEC 60601-1-6 and IEC 62366-1.

    Study Details Regarding Acceptance Criteria (as applicable to a non-AI medical device)

    Given that this is a 510(k) submission for an electrosurgical pencil and accessories, and not an AI-driven device, the detailed questions regarding AI study methodology are largely not applicable. However, I will address what is known from the provided text for each point:

    1. A table of acceptance criteria and the reported device performance: See the table above.
    2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
      • The document does not specify exact sample sizes for each test (e.g., number of units tested for sterilization, biocompatibility, electrical safety, or bench performance).
      • The data provenance is not explicitly stated in terms of country of origin but is from Covidien LLC, a Medtronic company. The tests would be prospective in nature, as they involve testing the actual device prototypes or production samples against established standards.
    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): Not applicable for this type of device testing. Ground truth (e.g., sterility, electrical safety, mechanical integrity) is established by adherence to recognized international and national standards, not expert consensus in the diagnostic sense.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. Device performance against technical standards is typically assessed through objective measurements, not human 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: Not applicable, as this is not an AI device.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable, as this is not an AI device.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): For this device, "ground truth" refers to the objective, measurable parameters defined by recognized international and national standards (e.g., ISO for sterilization and biocompatibility, IEC for electrical safety and EMC, ASTM for packaging and shelf-life).
    8. The sample size for the training set: Not applicable, as this is not an AI device.
    9. How the ground truth for the training set was established: Not applicable, as this is not an AI device.

    In conclusion, the Valleylab™ SM Smoke Management Pencil and accessories have undergone rigorous non-clinical performance evaluations against established medical device standards to demonstrate substantial equivalence to a predicate device. The nature of this product as a physical electrosurgical tool means that many of the AI-specific questions are not relevant.

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