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510(k) Data Aggregation

    K Number
    DEN230078
    Date Cleared
    2024-10-11

    (325 days)

    Product Code
    Regulation Number
    878.4964
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Versius Surgical System is a robotically assisted surgical device that is intended to assist in the precise and accurate control of Versius Surgical endoscopic instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, forceps/pick-ups, needle holders, electrosurgery, and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrosurgery and suturing.

    The Versius Surgical System is indicated for adult patients 22 years of age and older, eligible for soft tissue minimal access surgery, for cholecystectomy.

    Device Description

    The Versius Surgical System is intended to assist in the accurate control of its surgical endoscopic instruments across a range of surgical procedures.

    The system comprises (Figure 1):

    • . a surgeon console,
    • a visualization bedside unit .
    • . up to three instrument bedside units
    • . surgical attachments comprising an endoscopic camera and surgical instruments,
    • . and sterile drapes

    Each bedside unit includes a robot arm to which the endoscopic camera and instruments are attached.

    AI/ML Overview

    This application is for the Versius Surgical System, a robotic surgical device. The acceptance criteria and the study that proves the device meets the acceptance criteria are detailed below. It's important to note that the provided text describes validation and verification processes across various aspects (biocompatibility, sterility, electrical safety, software, bench testing, animal testing, human factors, and clinical studies) rather than a single unified "study" with one set of acceptance criteria. The acceptance criteria are largely defined by passing these various tests and achieving specific clinical outcomes.

    1. Table of Acceptance Criteria and Reported Device Performance

    Given the nature of the information, which includes various types of testing (non-clinical, animal, human factors, and clinical trials), I will integrate and summarize the "acceptance criteria" based on the "Results" sections for each type of study, particularly focusing on the clinical effectiveness and safety criteria.

    CategoryAcceptance Criteria (Inferred/Stated)Reported Device Performance
    Non-Clinical Testing
    BiocompatibilityPass tests for Cytotoxicity, Sensitization, Irritation, Acute Systemic Injection, Material-mediated Pyrogenicity, Hemocompatibility (ISO 10993 series, ASTM F756).PASS for all listed tests.
    Cleaning/SterilizationPass validation according to relevant AAMI, ISO, and FDA reprocessing guidelines for all components (console, instruments, endoscopes, cables).PASS for Cleaning, Disinfection, and Sterilization across all relevant components.
    Environmental/Pass tests for environmental and distribution challenges (ASTM D4169, ISTA 7D, etc.).PASS.
    Electrical/Mechanical/ Thermal Safety & EMCPass tests for Electrical Safety (IEC 60601-1, -1-6, -1-8, -2-18, -2-2, 80601-2-77), EMC Immunity (IEC 60601-1-2, IEC/EN 61000-4-39), EMC Emissions (IEC 60601-1-2, CISPR 11), Wireless co-existence (AAMI TIR69, ANSI C63.27, AIM 7351731).PASS for all listed tests.
    Software & Cybersecurity"Enhanced Documentation" for "Major" level of concern, with satisfactory V&V testing and hazard analysis. Device determined cyber device, with documentation in accordance with FDA guidance "Cybersecurity in Medical Devices".Adequate documentation provided, V&V testing with satisfactory results. Cybersecurity documentation provided demonstrated reasonable assurance the device is cybersecure.
    Bench TestingBedside Unit stability and movement (Demonstrate stability and movability). Bedside Unit brake & height adjustment (Verify operator prevented from releasing brake or adjusting height during surgery). Electromechanical arm motion accuracy (Reach entire intended workspace). Instrument motion accuracy (Accuracy of instruments, quantify unintended motion). System Latency (Within pre-defined acceptable range). Droop (End-effector does not droop/apply force under single fault conditions). System component integrity, loading, mechanical (Rigidity, yield strength, withstand loads, lift/pull force). System interfaces (Compatible and operate as expected). Electrical properties (Verify grounding, insulation, ingress protection, power controls). Electrosurgical compatibility (Performance testing). Arm simulated use testing (Maintain functionality for worst-case procedure). Thermal effects on tissue (Evaluate electrosurgical functionalities).PASS for all listed bench tests.
    Animal TestingValidate safety and effectiveness through complete robotic cholecystectomy in acute and chronic porcine models; demonstrate accurate and instinctive manipulation of tissue. No adverse effects or unexpected tissue effects.Three acute and three chronic animals underwent complete robotic cholecystectomy. Six additional animals underwent TLH (for suturing). All endpoints evaluated per protocol; no adverse effects or unexpected tissue effects, and the Versius system performed all functions as indicated.
    Human Factors TestingFacilitate safe and effective use; mitigate foreseeable use-related risks (e.g., cable tripping, arm collisions, tipping). Validation study to show all participants complete required tasks without pattern of use error or difficulties.All participants (sixteen teams) were able to complete the required tasks within the study in a way that demonstrates that no pattern of use error or difficulties was present. Study validated that the final design of the Versius Surgical System met the needs of the intended users and that all foreseeable use-related risks had been mitigated.
    Clinical Effectiveness
    Cholecystectomy: Rate of unplanned conversion to other MAS or open surgery.Poland Study: Low rate of unplanned conversion.
    India Study: No unplanned conversions.Poland Study: 1 (3.3%) conversion to open surgery due to challenging anatomy. 29 (96.6%) procedures completed as planned.
    India Study: 0 (0%) conversions reported. All 30 (100%) procedures completed as planned.
    Cholecystectomy: Rate of total intro- and post-operative serious adverse events (SAE) up to 30 days post-procedure.Low rate of SAEs, not related to the Versius Surgical System.Poland Study: 3 total adverse events, 2 of which were serious (6.6%), both postoperative and reported in the same patient who underwent open conversion, and not related to the Versius Surgical System.
    India Study: 0 (0%) intraoperative or postoperative adverse or serious adverse events reported up to 30 days.
    Suturing: No occurrences of vaginal vault dehiscence at 42-day follow-up (for TLH cases supporting general suturing indication).No occurrences of vaginal vault dehiscence.0 out of 60 occurrences of vaginal vault dehiscence for the 60 TLH cases (30 from Poland, 30 from India) where only Versius System Needle holders were used for driving the needle.

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

    • Clinical Studies (Cholecystectomy):
      • Poland Study: 30 subjects.
        • Data Provenance: Prospective, single-center, conducted in Poland.
      • India Study: 30 subjects.
        • Data Provenance: Prospective, single-center, conducted in India.
      • Combined for Suturing: 60 subjects (30 from Poland, 30 from India; total laparoscopic hysterectomy cases).
        • Data Provenance: Prospective, from Poland and India.
    • Animal Testing:
      • Cholecystectomy: 3 acute, 3 chronic porcine models (6 animals total).
      • TLH (for suturing indication): 3 chronic, 3 acute porcine models (6 animals total).
      • Data Provenance: Not explicitly stated, but implies laboratory/research setting where GLP requirements were followed.
    • Human Factors Testing:
      • US Validation Study: Sixteen surgical teams (number of individuals not specified, but typically includes surgeon + surgical staff).
      • Data Provenance: US-based activity, simulated operating room setting.

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

    • Clinical Studies (Cholecystectomy):
      • Poland Study: 3 surgeons.
        • Qualifications: All generalists. Principal investigator: 15 years open surgery experience, no previous robotic surgery experience. Other two surgeons: ~10 years laparoscopic surgery experience, no previous robotic surgery experience.
      • India Study: 1 surgeon.
        • Qualifications: Generalist with >35 years open and laparoscopic surgery experience. Completed >500 cholecystectomy cases using OUS commercially available Versius System.
    • Animal Testing: Ground truth was established by evaluation per protocol for overall animal health, test article performance, and local tissue response, likely by veterinary pathologists and study investigators. Specific numbers and qualifications of these experts are not provided.
    • Human Factors Testing: "Intended users" were involved, including surgical teams. Specific qualifications beyond "surgeon" and "remainder of the surgical team" are not provided. The evaluation for "no pattern of use error" would implicitly involve human factors experts or trained evaluators.

    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    The document does not explicitly describe an adjudication method like 2+1 or 3+1 for the clinical outcomes or other testing results. The clinical studies describe outcomes based on the study protocol, and any "conversions" or "adverse events" are reported as observed by the investigators. For bench and animal testing, the results are simply stated as "PASS" based on expert evaluation or predefined criteria.

    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 MRMC comparative effectiveness study was done regarding human reader improvement with AI assistance. The Versius Surgical System is a robotic surgical device for performing procedures, not an AI-assisted diagnostic or imaging interpretation tool that would typically involve human "readers." The focus is on the device's performance in surgical execution.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    The device itself (the robotic system) operates under the control of a human surgeon. Therefore, a "standalone" performance without "human-in-the-loop performance" is not applicable in the context of the device's primary function in assisting surgery. The "standalone" bench tests demonstrate the system's inherent functional capabilities (e.g., motion accuracy, latency, component integrity) independent of surgeon interaction for some tests, but for surgical task performance (the indications for use), human interaction is fundamental.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    • Clinical Studies (Cholecystectomy & Suturing): Ground truth was primarily clinical outcomes data, including:
      • Rate of unplanned conversion (primary effectiveness).
      • Rate of intraoperative and postoperative serious adverse events (primary safety).
      • Operative time, estimated blood loss, complications, hospital stay, readmission, reoperation, mortality, histopathology of removed specimen, device deficiencies, etc. (secondary endpoints).
      • For suturing, vaginal vault dehiscence at 42 days was the key outcome.
      • These are based on standard medical practice and follow-up.
    • Animal Testing: Ground truth was based on animal health endpoints, test article performance, and local tissue response, likely determined through direct observation, physiological monitoring, and histopathology/gross examination of affected organs and surrounding tissue.
    • Non-Clinical Bench Testing: Ground truth was established by adherence to pre-defined acceptance criteria against established engineering and safety standards (e.g., specific thresholds for motion accuracy, latency within acceptable range, stability criteria, pass/fail for biocompatibility and sterility tests).
    • Human Factors Testing: Ground truth was the observation of tasks completion by surgical teams without a "pattern of use error or difficulties," judged by human factors experts and study evaluators against criteria for safe and effective interaction.

    8. The Sample Size for the Training Set

    The document does not explicitly provide information on a "training set" for an algorithm or AI model in the typical sense. The provided context describes verification and validation of a physical surgical system. "Training" refers to:

    • Surgical Training: The sponsor developed a "Versius-specific use training program" for human users (surgeons and surgical teams). This is training for the human operators, not a data set to train an algorithm. There's no specific sample size for this human training program mentioned as a statistical "training set."
    • Software Development: While software verification and validation (V&V) occurred, details about specific data sets used for training any internal algorithms (e.g., control algorithms) are not provided. The phrase "training set" is usually reserved for machine learning contexts, which isn't the primary focus here.

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

    As there is no explicit "training set" for an AI algorithm mentioned, this question is not fully applicable. However, for the human training, the "ground truth" for proper device use is established by adherence to documented procedures, instructions for use, and safe practices defined by the manufacturer and medical standards, which are then reinforced and assessed through the training program and human factors validation.

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