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510(k) Data Aggregation

    K Number
    K213814
    Manufacturer
    Date Cleared
    2022-02-02

    (57 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 Viveve 2.0 System is indicated for use in general surgical procedures for electrocoagulation and hemostasis.

    Device Description

    The Viveve 2.0 System utilizes monopolar radiofrequency (RF) energy to selectively heat a given volume of tissue beneath the surface, while cryogen is delivered to the inside of the treatment tip to cool the surface tissue. The generator delivers energy to the treatment tip to create an electric field under the treatment tip (electrode). The mechanism of action is the application of RF energy to the tissue causing coagulation and/or hemostasis.

    The Viveve® 2.0 System consists of four (4) primary components:

    • . An RF Generator to provide the heating energy. The Generator incorporates the Cooling Module to supply coolant which provides the cooling energy.
    • . A hand piece that couples the cooling and heating energy to the tissue through the treatment tip.
    • A footswitch that allows the user to turn the RF Energy on or off.
    • 5cm or 8cm Sterile Disposable Treatment Tips.

    Accessories include:

    • . Coupling Fluid
    • Cryogen ●
    • Return Cable ●
    • Return Pad ●
    • . Power Cord
    AI/ML Overview

    This document, K213814, is a 510(k) premarket notification for the Viveve 2.0 System. It describes a change in the manufacturing site from Sparton Medical to Spartronics for the Viveve 2.0 System.

    Based on the provided text, there is no detailed study information regarding acceptance criteria and device performance as typically expected for demonstrating clinical efficacy or algorithm performance. This submission is primarily about a manufacturing site change and asserts that because no other aspects of the device have changed, the performance remains the same as the predicate device. Therefore, many of the requested details about studies are not present in this document.

    However, I can extract the relevant information that is available and explain why other sections are not applicable.


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

    This document does not provide a table of acceptance criteria and reported device performance in the context of clinical efficacy or algorithm performance. The core assertion of this 510(k) is that the device (Viveve 2.0 System) is substantially equivalent to its predicate device (Viveve 2.0 System, K212678) because only the manufacturing site has changed, and no other aspects of the device, software, or indications for use have been altered.

    Therefore, the "acceptance criteria" here implicitly refer to demonstrating that the device produced by the new manufacturer maintains the same specifications and quality as the previous manufacturer, ensuring it performs identically to the predicate device.

    Implicit Acceptance Criteria (for the manufacturing change):

    Acceptance Criteria CategoryReported Device Performance (as stated in the document)
    Manufacturing Site LocationChanged from Sparton Medical (Frederick, CO) to Spartronics (Watertown, SD)
    Console/GeneratorNot changing as part of this submission.
    FootswitchNot changing as part of this submission.
    HandpieceNot changing as part of this submission.
    CryogenNot changing as part of this submission.
    Software Modifications (Console, Display, Handpiece)Not changing as part of this submission.
    Hardware Modifications (Operating System)Not changing as part of this submission.
    Labeling Modifications (Technical User Manual, Instructions for Use)No changes have been made.
    Technical/Environmental Specification ModificationsIEC60601, Electrostatic Discharge (ESD), and Voltage Dip are aligned with the Contract Manufacturing Organization's (CMO) Quality Management System (QMS) Requirements.
    Safety and Efficacy ImplicationsThe proposed contract manufacturer modifications do not raise new questions of the safety or efficacy of the device, and the intended use remains unchanged.

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

    Not applicable. This 510(k) does not describe a test set or data provenance in the context of evaluating the clinical performance or accuracy of the device itself. The "performance data" mentioned refers to "Design verification testing, including bench performance and software verification/validation" to demonstrate substantial equivalence, rather than a clinical study with a patient test set.

    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. As this 510(k) is focused on a manufacturing site change and substantial equivalence without clinical efficacy studies, there's no mention of experts establishing ground truth for a test set.

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

    Not applicable. There is no described test set or clinical study requiring an adjudication method.

    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. The Viveve 2.0 System is an electrosurgical cutting and coagulation device, not an AI-assisted diagnostic or therapeutic system. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant to this device or its submission.

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

    Not applicable. The Viveve 2.0 System is a physical medical device (RF generator, handpiece, etc.) used in general surgical procedures. It does not operate as a standalone algorithm.

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

    Not applicable. No ground truth in the context of clinical data or algorithm performance is described in this submission. The "performance data" mentioned refers to "Design verification testing" (e.g., bench testing, software validation) to ensure the device manufactured at the new site meets pre-defined engineering and safety specifications, consistent with the predicate device.

    8. The sample size for the training set

    Not applicable. As there are no clinical studies or AI algorithms being evaluated in this submission, there is no training set to report.

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

    Not applicable. As above, there is no training set mentioned in this submission.

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    K Number
    K193611
    Date Cleared
    2020-01-16

    (21 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Viveve 2.0 System is indicated for use in general surgical procedures for electrocoagulation and hemostasis.

    Device Description

    The Viveve® 2.0 System consists of four (4) primary components:

    • . An RF Generator to provide the heating energy. The Generator incorporates the Cooling Module to supply coolant which provides the cooling energy.
    • . A hand piece that couples the cooling and heating energy to the tissue through the treatment tip.
    • A footswitch that allows the user to turn the RF Energy on or off.
    • . 5cm or 8cm Sterile Disposable Treatment Tips.

    Accessories include:

    • Coupling Fluid
    • Cryogen ●
    • Return Cable ●
    • Return Pad ●
    • . Power Cord
    AI/ML Overview

    The provided document describes the Viveve 2.0 System, an electrosurgical device that delivers radiofrequency energy. The primary change in this 510(k) submission (K193611) compared to its predicate device (K190422) is the addition of Contact Quality Monitoring (CQM) software and a modified user interface. The study focuses on demonstrating the safety and effectiveness of this added feature.

    Here's a breakdown of the requested information based on the document:

    1. Table of Acceptance Criteria and Reported Device Performance

    Feature/TestAcceptance CriteriaReported Device Performance
    CQM Contact Resistance Measurement0 to 200 Ω with ±10% (100 Ω - 200 Ω range) and ± 10 Ω accuracy (< 100 Ω)The CQM reading was as expected between 50 Ω ± 10 Ω with the RF Activated.
    CQM Circuit Response Time Constant< 20 msThe voltage on channel 1 of the oscilloscope transitioned 63% of the way from low to high in <= 20 ms.
    RF Output Disable on Loss of Patient ContactThe RF Generator hardware shall support detection and provide means to disable the RF output for the following operating condition error: Loss of patient contact.The RF Generator did fault when the CQM circuit was not complete, resulting in radiofrequency interruption to the patient.
    CONTACT MAP Graphic Illumination (GUI)Not illuminated when the Return Pad is not connected to the phantom tissue; illuminated green when the Return Pad is connected to the phantom tissue.The CONTACT MAP graphic within the Graphic User Interface was not illuminated when the Return Pad was not connected and was illuminated green when connected.
    Error Message on Inadequate Return Pad ContactWhen the Return Pad is not adequately connected to the phantom tissue, the RF Generator will fault and result in an E63 - Check Tip Contact error. Acknowledge the error by selecting OK. Place the Return Pad securely on the phantom tissue so that the CONTACT MAP is illuminated and ensure a pulse is delivered.An E63 - Check Tip Contact error was generated when the Return Pad was not adequately connected. A pulse was delivered after the Return Pad was securely placed and the CONTACT MAP illuminated.
    Overall Software Performance (CQM Updates)Meet the impacted customer requirements identified within ENG-017 Impact Analysis for CQM Updates.All tested functions performed as expected, and the CQM updates met the identified customer requirements.
    Electrical Safety / EMC TestingConformance to various IEC and EMC standards (detailed in Section 5.9).All parameters in applicable standards were met and recorded as PASS results.

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

    The document does not specify a specific "test set" in terms of patient data. The testing described for the CQM and software validation was performed on the device itself, likely using phantom tissue (pork belly) for functional tests of the return pad contact. The data provenance is internal testing performed by Viveve and by contract manufacturer Sparton Medical, as well as third-party testing by Intertek. There is no information about country of origin of data or whether it was retrospective or prospective, as it's not a clinical study on human subjects but rather device verification and validation.

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

    Not applicable. The ground truth for this device modification is based on engineering specifications and compliance with established electrical safety and software validation standards, not expert clinical interpretation of data. The "ground truth" is that the device correctly identifies and reports contact quality and disables RF output when necessary.

    4. Adjudication method for the test set

    Not applicable. This was device verification and validation against engineering specifications and international standards, not a clinical study requiring adjudication of expert interpretations.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done

    No. This document does not describe an MRMC comparative effectiveness study. The submission is for a modification to an electrosurgical device, specifically related to a safety feature (Contact Quality Monitoring). It does not involve human readers interpreting medical images or data from an AI system.

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

    Yes, in a sense. The testing described for the CQM feature and software verification is a standalone evaluation of the algorithm's performance in monitoring contact and issuing alerts or disabling RF output. There is no mention of a "human-in-the-loop performance" study described in this document for the specific change being cleared. The device's safety mechanisms (like CQM) are designed to operate automatically.

    7. The type of ground truth used

    The ground truth used for this submission is based on:

    • Engineering specifications and design requirements: The device's expected behavior and performance characteristics (e.g., resistance range, response time for CQM).
    • International standards conformance: Compliance with established electrical safety and electromagnetic compatibility standards (e.g., AAMI ES60601-1, IEC 60601-1-6, IEC 60601-2-2, IEC 60601-1-2).
    • Functional validation against known states: Demonstrating that the system responds correctly to scenarios like adequate vs. inadequate return pad contact using phantom tissue.

    8. The sample size for the training set

    Not applicable. This is not an AI/ML device that requires a training set of data. The "software" in question is for Contact Quality Monitoring, a rules-based or algorithmic safety feature, not a learning algorithm.

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

    Not applicable, as there is no training set for an AI/ML algorithm in this context.

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