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510(k) Data Aggregation

    K Number
    K232837
    Manufacturer
    Date Cleared
    2024-06-07

    (267 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Uro-G HD Flexible Cystoscope is intended for endoscopic diagnosis and infusion of irrigating fluids within the bladder and urethra.

    Generally recognized indications for cystoscopy include:
    • Symptomatic voiding dysfunction
    • Hematuria
    • Bladder tumor surveillance
    • Recurrent lower urinary tract infections
    • Pelvic pain syndromes

    Device Description

    The Uro-G HD Flexible Cystoscope System is a handheld, battery-operated portable cystoscope consisting of a disposable steerable endoscopic cannula with a 2.2 mm channel for fluid infusion and instrument advancement, and a reusable handle with a video monitor. The fully assembled Uro-G HD Cystoscope System—cannula and handle—has an overall length of 630 mm (approximately 25 inches). The disposable cannula's working length is 380.2 mm (approx. 15 inches) and a total length of 406 mm, from tip to connector. The cannula's maximum width is 5.6 mm and it has a connector for attaching and detaching to the handle.

    AI/ML Overview

    This document is a 510(k) Premarket Notification for the Uro-G HD Flexible Cystoscope, seeking to prove substantial equivalence to a predicate device (Uro-G Flexible Cystoscope, K202921). As such, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" refer to the demonstration that the modified device (Uro-G HD) is as safe and effective as the predicate device, not necessarily a performance study against a specific clinical endpoint. The primary method for proving this is through comparative testing and analysis of technological characteristics.

    Here's an analysis of the provided text in the context of acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are not explicitly stated as quantitative targets in a table format within the provided text. Instead, the document uses a comparative approach against a predicate device. The "reported device performance" is essentially the Uro-G HD's characteristics, and "meeting acceptance criteria" means demonstrating that these characteristics are equivalent to or improve upon the predicate without introducing new risks.

    Here’s a table summarizing the key characteristics and the comparison to the predicate device, highlighting what could be implicitly considered an "acceptance criterion" (i.e., equivalence or improvement):

    CharacteristicPredicate Device (Uro-G, K202921) PerformanceSubject Device (Uro-G HD) PerformanceAcceptance Criteria (Implicit)Met?
    Cannula
    Working length380.2 mm380.2 mmNot Changed (Equivalent)Yes
    Total length (tip to connector)406 mm406 mmNot Changed (Equivalent)Yes
    Number of ports22Not Changed (Equivalent)Yes
    Working channel minimum width2.2 mm2.2 mmNot Changed (Equivalent)Yes
    Maximum insertion width (OD)5.5 mm5.6 mmEquivalent (Increased by 0.1mm, deemed not to introduce new risk, as human urethral diameter is larger)Yes
    Tip OD4 mm4 mmNot Changed (Equivalent)Yes
    Camera
    CMOS module pixels0.3 million pixels0.7 million pixelsEquivalent (Higher pixels for HD imaging, does not introduce new risk)Yes
    Focal length5 mm to 50 mm5 mm to 50 mmNot Changed (Equivalent)Yes
    Field of view (in air)120 ° ± 5 °100 ° ± 5 °Equivalent (Smaller FOV but sufficient for HD imaging in confined spaces, does not introduce new risk)Yes
    Direction of view from center axis0 ° (Forward Viewing)0 ° (Forward Viewing)Not Changed (Equivalent)Yes
    Image resolution3 lp/mm on 1551 USAF test chart in air3 lp/mm on 1551 USAF test chart in airNot Changed (Equivalent)Yes
    Image distortion< 15% at x and y direction< 15% at x and y directionNot Changed (Equivalent)Yes
    Sensor on CMOS camera640 x 480 pixels1280 x 720 pixelsEquivalent (Higher resolution for HD, does not introduce new risk or increase established risk)Yes
    Tip Angulation
    RangeUp 210 ° ± 5 °, Down 130 ° ± 5 °Up 210 ° ± 5 °, Down 130 ° ± 5 °Not Changed (Equivalent)Yes
    RadiusUp < 15 mm, Down < 20 mmUp < 15 mm, Down < 20 mmNot Changed (Equivalent)Yes
    Lever force for angulation< 2.2 lbs< 2.2 lbsNot Changed (Equivalent)Yes
    Rotation torque< 3.5 inch-lb< 3.5 inch-lbNot Changed (Equivalent)Yes
    Rotation angle< 90 ° (clockwise and counter-clockwise)< 90 ° (clockwise and counter-clockwise)Not Changed (Equivalent)Yes
    Fluid & Light
    Fluid lumen cross-section4.84 mm²4.84 mm²Not Changed (Equivalent)Yes
    Distension flow through channel> 120 mL/min> 120 mL/minNot Changed (Equivalent)Yes
    Light sourceLED, 520 lumens at 25 mm focal lengthLED, 520 lumens at 25 mm focal lengthNot Changed (Equivalent)Yes
    Tip temperature when LEDs are on< 41° C< 41° CNot Changed (Equivalent)Yes
    Power rating of source90 mW90 mWNot Changed (Equivalent)Yes
    Sterilization & Biocompatibility
    Provided SterileYesYesNot Changed (Equivalent)Yes
    Sterilization methodEthylene oxideEthylene oxideNot Changed (Equivalent)Yes
    Sterility Assurance Level10^-610^-6Not Changed (Equivalent)Yes
    Biocompatibility of MaterialsMeets ISO 10993 requirementsMeets ISO 10993 requirementsNot Changed (Equivalent)Yes
    Single UseYesYesNot Changed (Equivalent)Yes
    Handle
    Device Identity35004500N/A (New model but functional equivalence demonstrated)Yes
    Length135 mm176 mmEquivalent (Increased length does not affect performance)Yes
    Diameter37 mm36 mmEquivalent (1 mm reduction does not impact risk or performance)Yes
    Weight220 g264 gEquivalent (Increased weight does not introduce new risk or affect usability)Yes
    Video Monitor
    Screen size3.5 inches diagonal4.3 inches diagonalEquivalent (Larger size makes viewing easier, no new risk)Yes
    Input formatRGBRGBNot Changed (Equivalent)Yes
    Effective pixels640 x 4801280 x 720Equivalent (Higher resolution for HD, no new risk)Yes
    LCD resolution480 x 320800 x 480Equivalent (Higher resolution for HD, no new risk, sharper image)Yes
    LCD display resolution0.15 million pixels0.4 million pixelsEquivalent (Higher resolution for HD, no new risk, sharper image)Yes
    Power
    Power supply18650 Lithium Ion rechargeable18650 Lithium Ion rechargeableNot Changed (Equivalent)Yes
    Voltage of fully charged battery3.7 V3.7 VNot Changed (Equivalent)Yes
    Operating time after fully charged2 hours2 hoursNot Changed (Equivalent)Yes
    Battery capacity3100 mA3100 mANot Changed (Equivalent)Yes
    Operational Characteristics
    Electrical SafetyIEC 60601-2-18 compliantIEC 60601-2-18 compliantNot Changed (Equivalent)Yes
    EMCIEC 60601-1-2 compliantIEC 60601-1-2 compliantNot Changed (Equivalent)Yes
    Adjust brightnessBy depressing button on handleBy depressing button on handleNot Changed (Equivalent)Yes
    Image/video captureBy depressing camera button on handleBy depressing camera button on handleNot Changed (Equivalent)Yes
    Cleaning/disinfectionHandle cleaned/disinfected per IFUHandle cleaned/disinfected per IFUEquivalent (Modified instruction for air dry time, but efficacy remains)Yes
    DisposalCannula sterile, single use, disposed after procedureCannula sterile, single use, disposed after procedureNot Changed (Equivalent)Yes
    Frequency of useHandle reusable, Cannula single useHandle reusable, Cannula single useNot Changed (Equivalent)Yes
    Duration of use< 24 hours< 24 hoursNot Changed (Equivalent)Yes
    Site of UseHospitals and physician officesHospitals and physician officesNot Changed (Equivalent)Yes
    Software
    SW version2.04.1N/A (New version, but updates do not introduce new risks to operation)Yes
    Level of ConcernModerateModerateNot Changed (Equivalent)Yes
    General FunctionsInitialize/setup video, LCD, UI, recordingInitialize/setup video, LCD, UI, recording, storage, playbackNot Changed (Equivalent)Yes
    General Parameters of ActionTransfer of sensor data to LCD displayTransfer of sensor data to LCD displayNot Changed (Equivalent)Yes
    Block DiagramMain Board performs imaging functionalityMain Board performs imaging functionalityEquivalent (Same except for specific sensor model, which handles HD output)Yes
    Specific Parameters of Actionv2.0 updatesv4.1 updates (including v2.0)Equivalent (Updates do not introduce a new risk; e.g., improved logo, zoom, file saving, etc.)Yes

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

    The document primarily describes bench testing and comparative analysis of the device's technological characteristics. It does not refer to a "test set" in the sense of a dataset of clinical cases for an AI algorithm. The performance data listed (e.g., measurement of outer diameter, image quality, image distortion) are conducted on the device hardware itself.

    • Sample Size for Test Set: Not applicable in the context of an AI/algorithm-based "test set." The testing involved physical devices and their components. The number of physical units tested is not specified but is typically determined by manufacturing quality control and regulatory submission requirements for non-AI devices.
    • Data Provenance (Country of Origin, Retrospective/Prospective): Not applicable for the type of testing described (bench testing of a medical device). This is a hardware device submission, not an AI/software submission that relies on clinical image data.

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

    • Number of Experts: Not applicable. Ground truth, in the context of diagnostic performance typically associated with AI/algorithm submissions, is not directly established through expert consensus on clinical cases for this device. The "ground truth" for this device's performance data relates to engineering specifications and physical measurements (e.g., true dimensions, known test chart patterns).
    • Qualifications of Experts: Not applicable beyond the implicit expertise of engineers and technicians performing the stated bench tests, and the FDA's regulatory reviewers.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. There is no clinical "test set" requiring adjudication by multiple readers.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and its Effect Size.

    • MRMC Study: No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed. This device is a hardware cystoscope, not an AI-assisted diagnostic tool for which such studies are typically conducted to evaluate reader performance with and without AI assistance.
    • Effect Size of Human Readers Improvement: Not applicable, as no MRMC study was conducted.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) was done

    • Standalone Performance: Not applicable. This is a hardware device. While it contains software, the "software verification testing" mentioned is to ensure the software properly controls the device's functions (e.g., displaying HD images, recording). There is no standalone algorithm whose diagnostic performance is being evaluated independent of human use.

    7. The Type of Ground Truth Used

    The "ground truth" for this submission is based on:

    • Engineering Specifications: The design parameters and expected performance of the device (e.g., specified focal length, field of view, angulation range, lumen cross-section, electrical safety standards).
    • Physical Measurements: Direct measurements of the device's components against design specifications (e.g., outer diameter, image quality against a known test chart, image distortion against a known pattern).
    • Biocompatibility Standards: Compliance with ISO 10993 requirements, verified through specific biocompatibility tests (Cytotoxicity, Irritation, Sensitization, Systemic Toxicity).
    • Predicate Device Performance: The established performance and safety characteristics of the legally marketed predicate device (Uro-G Flexible Cystoscope, K202921) serve as the primary reference for demonstrating equivalence.

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. This submission is for a hardware medical device with embedded software controlling its functions, not an AI/machine learning algorithm trained on a "training set" of data.

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

    • Ground Truth for Training Set: Not applicable, as there is no training set for an AI/ML model for this hardware device.
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