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510(k) Data Aggregation
(266 days)
The PhotonBlade® with Adaptive Smoke Evacuation is a monopolar RF device coupled with illumination that is indicated for cutting and coagulation of tissue during general surgical procedures and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system.
The PhotonBlade® with Adaptive Smoke Evacuation (PB2SE) is a single use, sterile, electrosurgical device with a light and adaptive smoke evacuation attachment. The device has a monopolar electrode at the distal tip, which delivers Radiofrequency (RF) energy for cutting and coagulation of tissue. The electrode tip is located at the distal end of a rotatable and extendable shaft. The adaptive smoke evacuation attachment connects to the telescoping shaft and the cable of the PhotonBlade. It incorporates a barb connector at the end of the tubing to allow connection to a secondary suction hose connected to a smoke evacuation system. The device handle is integrated with controls for cut, coagulation, and illumination (light). A universal cable attaches the device to a 510(k) cleared electrosurgical unit.
The provided text describes a 510(k) submission for the "PhotonBlade® with Adaptive Smoke Evacuation" device. This is a premarket notification for a medical device seeking substantial equivalence to a legally marketed predicate device, rather than a novel AI/software as a medical device (SaMD) cleared through a de novo or PMA pathway.
Therefore, the document does not contain the information typically sought for a study proving device performance against acceptance criteria for an AI/SaMD. Specifically:
- No acceptance criteria table for AI performance: The document focuses on performance testing for an electrosurgical device (e.g., electrical safety, mechanical/functional testing, biocompatibility, smoke evacuation flow rate).
- No mention of AI/algorithm: The device is described as a monopolar RF device with illumination and adaptive smoke evacuation. There is no indication of an AI component.
- No data provenance, expert ground truth, adjudication, MRMC studies: These elements are characteristic of studies evaluating AI performance in interpreting medical images or other data, which is not applicable here.
- No standalone algorithm performance or training set information: Again, these are specific to AI/machine learning models.
Based on the provided text, the device is an electrosurgical tool, and the "study" described is a set of engineering and bench tests, not a clinical study to prove AI performance.
Therefore, it is not possible to describe the acceptance criteria and study as requested, because the provided input does not pertain to an AI/SaMD.
However, I can extract the acceptance criteria and performance data for the electrosurgical device itself as described in the 510(k) summary:
Acceptance Criteria and Device Performance (for the electrosurgical device, not AI/SaMD)
The document frames the "acceptance criteria" and "performance" in terms of confirming the device meets design specifications, safety, and effectiveness compared to predicates, rather than statistical performance metrics for an AI system.
1. Table of Acceptance Criteria and Reported Device Performance (as inferred from the text):
Acceptance Criteria / Performance Aspect | Reported Device Performance |
---|---|
Biocompatibility | Tested per ISO 10993-1:2009/(R)2013 and FDA guidance (June 2016). The only new contacting material (smoke evacuation tubing) was tested and confirmed to be biocompatible for its intended use. Classification: external communicating device, tissue contact, less than 24-hour duration. |
Electrical Safety & EMC | Tested per IEC 60601-1:2005 + A1:2012 (US deviation), IEC 60601-2-2:2017 (6th Ed), IEC 60601-1-2:2014 (4th Ed), and AIM 7351731 Rev 2.00 standards. The device complies with relevant sections of the standards. |
Mechanical & Functional Testing | Performed on conditioned samples (EtO sterilization, distribution simulation, 24 months accelerated aging). Results confirm the product meets the specifications and acceptance criteria. (Specific metrics not provided, but general compliance stated). |
Illumination Function | Nominal Light Output: 29 Lumens (compared to 28 Lumens for predicate). Light Color: White. Updates to PCBA LED driver circuit component to reduce susceptibility to RF interference, resulting in a more consistent illumination function. |
Smoke Evacuation | No specific standards exist, but tests were conducted to verify design requirements, performance specs, and intended use. The design does not affect or change electrosurgical function. Smoke evacuation flow rate was evaluated and compared to reference device (PEAK PlasmaBlade 3.0S), demonstrating equivalent or better flow rate. The intake portion did not obstruct electrosurgical function while removing smoke. Results demonstrate the product is safe, effective, and meets requirements for technology, performance, and intended use. |
Sterility Assurance Level (SAL) | 1 x 10^-6 (consistent with predicate and reference devices). |
Electrical Insulation Improvement | Changes to internal and external components of telescoping shaft and electrode were made to improve electrical insulation. This indicates an improved safety feature compared to the predicate, implicitly meeting an internal acceptance criteria for improved insulation. (No specific numerical acceptance criteria provided, but the improvement is noted as a device modification). |
Substantial Equivalence | The overall conclusion is that the data demonstrates the device is "at least as safe and effective as the predicates," and any differences do not raise new safety/effectiveness issues, thus supporting a determination of substantial equivalence. This is the overarching "acceptance criterion" for a 510(k) submission. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not explicitly stated in numerical terms for each test. The text mentions "conditioned samples" for mechanical and functional testing, and "the material" for biocompatibility. This suggests standard engineering test samples, not patient cohorts.
- Data Provenance: Not applicable in the context of clinical data for AI/SaMD. The studies are bench/engineering tests conducted by the manufacturer. No country of origin for "data" in the sense of patient data is relevant here. The studies are retrospective in the sense that they are performed on manufactured devices to support the submission.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- Not Applicable. This is an electrosurgical device, not an AI system that interprets medical data. Ground truth in this context refers to engineering specifications and performance standards established through generally accepted methods in medical device testing. There are no human "experts" establishing a clinical ground truth for image interpretation or disease diagnosis.
4. Adjudication Method for the Test Set:
- Not Applicable. As there are no human experts classifying or interpreting data for decision-making (as in AI/SaMD evaluations), there is no adjudication process.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done:
- No. MRMC studies are specific to evaluating the clinical performance of diagnostic or screening devices, often involving human readers with and without AI assistance. This device is an electrosurgical tool, and such a study is not relevant to its function.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This device does not have a standalone algorithm for diagnostic or interpretative purposes. "Standalone performance" in this context would refer to the device's electrosurgical and smoke evacuation functions on their own, which are indeed what the performance tests cover (e.g., flow rate, electrical safety).
7. The Type of Ground Truth Used:
- For this device, the "ground truth" is defined by:
- Engineering Specifications: Defined by the manufacturer's design inputs.
- International Standards: e.g., IEC 60601 series for electrical safety, ISO 10993 for biocompatibility.
- Predicate Device Performance: Benchmarking against the previously cleared PhotonBlade® and reference devices for function (e.g., smoke evacuation flow rate).
- Intended Use/Design Requirements: Verification that the device performs as intended (cutting, coagulation, smoke removal) without affecting electrosurgical function.
8. The Sample Size for the Training Set:
- Not Applicable. This is not an AI/machine learning device; therefore, there is no "training set."
9. How the Ground Truth for the Training Set was Established:
- Not Applicable. As there is no training set for an AI model, there is no ground truth establishment process for it.
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(43 days)
The PlasmaBlade T is a monopolar, single use, sterile, disposable device intended for use with the AEX Generator. The device delivers RF energy concurrent with saling and coagulation of soft tissue and bone and RF energy for cutting and coagulation of soft tissue. It is intended for, but not limited to. General, Plastic and Reconstructive (including but not limited to skin incisions and development of skin flaps), ENT, Gynecologic, Orthopaedic, Arthroscopic, Spinal, Thoracic, and Open abdominal surgery procedures.
The PlasmaBlade T should not be used on small appendages or body parts, as in circumcision. The device is not intended for contraceptive tubal coagulation (permanent female sterilization).
The proposed single-use disposable accessory device, the PlasmaBlade T monopolar handpiece, provides the hemostatic capabilities of the Aquamantys SBS 5.0 Handpiece (Cleared under K111732, K132974) and the cutting and coagulative capabilities of the PEAK PlasmaBlade 3.0S (Previously cleared under K093695).
The proposed PlasmaBlade T Handpiece device is a monopolar, single use, disposable device and is provided sterile. The devices are not intended for reuse or resterilization. The PlasmaBlade T handpiece consists of an enamel coated insulated blade electrode with an uncoated circular electrode, an insulated telescoping shaft, handle with three integrated controls, and a co-extruded cable assembly to provide both power and saline. The seven-pin electrical connector is designed to be plugged into the AEx Generator (Cleared under K143175).
The proposed PlasmaBlade T Handpiece is a disposable device, that when connected to the AEX Generator (K143175), uses monopolar RF energy for the resection and coagulation of soft tissue and bone. The proposed PlasmaBlade T Handpiece device provides similar resection and coagulative effect to the predicate device, the PlasmaBlade 3.0S Monopolar Handpiece (Cleared under K093695).
In addition to the monopolar cutting and coagulation capabilities the proposed PlasmaBlade T Handpiece device also uses monopolar RF energy concurrent with saline delivery to provide a broader coagulative effect; similar to the predicate Aquamantys SBS 5.0 Handpiece (Cleared under K111732, K132974), this result is trademarked as Transcollation® Technology by Medtronic. The proposed PlasmaBlade T Handpiece device also has a pump header tubing segment and saline bag spike tubing allowing the user to manually connect the device to saline source in the OR as well as the AEX Generator's peristaltic pump. This ensures the device is connected for saline delivery at the same time as the device is connected electrically to the proposed AEX Generator.
This document describes a 510(k) premarket notification for the PlasmaBlade T device, an electrosurgical cutting and coagulation device. The information provided focuses on demonstrating substantial equivalence to predicate devices through non-clinical testing.
Here's an analysis of the provided text regarding acceptance criteria and the study that proves the device meets them:
Key Takeaway: The provided document is a 510(k) submission, which aims to demonstrate "substantial equivalence" to a legally marketed predicate device, rather than proving a novel device meets specific (and often more stringent) acceptance criteria through exhaustive clinical trials typically associated with a "new" device. For 510(k)s, "acceptance criteria" are generally tied to showing that the new device performs as safely and effectively as the predicate, often through a combination of bench testing and, sometimes, animal studies. Clinical trials (human studies) are usually not required for 510(k)s unless there are significant differences in technology or indications from the predicate that raise new questions of safety or effectiveness.
Based on the information, here's a breakdown:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't provide a formal table of quantitative acceptance criteria with corresponding performance metrics like one might see for an AI-driven diagnostic device (e.g., sensitivity, specificity thresholds). Instead, the "acceptance criteria" are implicitly met by demonstrating substantial equivalence to the predicate devices through various non-clinical tests.
Acceptance Criterion (Implicitly Met) | Reported Device Performance (Summary of Evidence) |
---|---|
Functional Equivalence: Device performs as intended for cutting and coagulation of soft tissue/bone and hemostatic sealing with saline. | The PlasmaBlade T monopolar handpiece provides: |
- "hemostatic capabilities of the Aquamantys SBS 5.0 Handpiece" (Predicate K111732, K132974)
- "cutting and coagulative capabilities of the PEAK PlasmaBlade 3.0S" (Predicate K093695).
"The proposed PlasmaBlade T Handpiece device provides similar resection and coagulative effect to the predicate device, the PlasmaBlade 3.0S Monopolar Handpiece."
"The proposed PlasmaBlade T Handpiece device also uses monopolar RF energy concurrent with saline delivery to provide a broader coagulative effect; similar to the predicate Aquamantys SBS 5.0 Handpiece." |
| Similar Tissue Effect (Safety): The thermal damage profile imparted on tissue is comparable to predicate devices. | "The in-vivo testing determined the zone of thermal damage imparted on the tissue by the proposed devices was comparable to the predicates." |
| Biocompatibility: Device materials are suitable for contact with tissue. | "Biocompatibility" testing was conducted and passed. (No specific performance data given, but implied acceptance by passing this test). |
| Sterilization Efficacy: The device can be effectively sterilized. | "Sterilization" testing was conducted and passed. |
| Electrical Safety/Electromagnetic Compatibility (EMC): The device meets electrical safety and EMC standards. | "Electrical Safety/EMC" testing was conducted and passed. |
| Mechanical Integrity/Durability: The device maintains its mechanical integrity through transit, shelf life, and during use. | "Transit," "Shelf Life," "Mechanical Testing," and "Activation Testing" were conducted and passed. |
Study Type: Non-Clinical Performance Testing (Bench and Animal) to demonstrate substantial equivalence.
2. Sample Size and Data Provenance for the Test Set:
- Sample Size: The document does not specify exact sample sizes for each type of bench testing (e.g., number of devices tested for sterilization, number of cycles for activation testing). For the in-vivo animal model, it states that testing was "completed" but does not give the number of animals or trials.
- Data Provenance: Not explicitly stated, but typically, these tests are conducted in a laboratory setting (e.g., Medtronic's R&D facilities or contracted labs) within the country of manufacture or testing. The document implies these were conducted specifically for this submission, making them prospective data for the purpose of this regulatory filing. There is no mention of country of origin for the data specifically.
3. Number of Experts and Qualifications for Ground Truth Establishment:
This question is largely not applicable to this type of device and study.
- This is not an AI/diagnostic device where human expert labels establish ground truth on patient data.
- Ground truth for functional performance (e.g., cutting, coagulation, thermal spread) in bench and animal studies is established through direct physical/physiological measurement and observation, not through expert consensus on interpretation. For instance, the "zone of thermal damage" is a measurable characteristic of tissue effect.
- The FDA guidance document mentioned ("Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery Guidance for Industry and Food and Drug Administration Staff") served as the standard against which the tests were designed and evaluated by the manufacturer's engineers and scientists.
4. Adjudication Method for the Test Set:
Not applicable in the context of expert adjudication for diagnostic labeling. Performance testing involves direct measurement and comparison to predefined criteria or predicate device performance. Engineer/scientist review of test results would be the "adjudication" (verification) method for non-clinical studies.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC study was NOT done.
- The device is an electrosurgical instrument, not an imaging or diagnostic AI device where human readers interpret cases. The human "user" is a surgeon performing a procedure, not "reading" data.
- The study focuses on the device's physical and functional performance, not on improving human reader interpretation.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
- Technically, all the studies described (bench and animal) are "standalone" in the sense that they are evaluating the device's intrinsic performance characteristics without a human user's interpretive decision-making being part of the primary endpoint.
- The "human-in-the-loop" for this device is the surgeon using it during a procedure for its intended purpose (cutting, coagulating, sealing), not interpreting data generated by the device. The non-clinical studies assess the device's ability to perform these actions comparably to predicates.
7. Type of Ground Truth Used:
The ground truth for the performance claims in this submission is established through:
- Physical/Chemical Measurements: For sterilization, electrical safety, mechanical integrity, shelf-life.
- Direct Observation/Measurement on Animal Tissue: For functional performance related to cutting, coagulation, and critically, the "zone of thermal damage imparted on the tissue." This is akin to a pathological/physiological ground truth as it directly measures the device's effect on biological tissue.
- Comparison to Predicate Device Performance: The primary "ground truth" for substantial equivalence is the established safe and effective performance of the predicate devices. The new device must demonstrate comparable performance across the relevant tests.
8. Sample Size for the Training Set:
Not applicable. This device is hardware (an electrosurgical instrument), not an algorithm that requires a "training set" of data in the machine learning sense.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. (See point 8).
In summary, the 510(k) submission for the PlasmaBlade T device relies on comprehensive non-clinical testing (bench and animal studies) to demonstrate substantial equivalence to its predicate devices. The "acceptance criteria" are implicitly met by showing that the new device performs comparably to the predicates in terms of safety and effectiveness across various functional and physical tests, including the critical aspect of tissue effect (thermal damage). Clinical human studies were not required for this type of device and submission pathway.
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(57 days)
AEx Generator:
The AEx Generator is a radio frequency (RF) electrosurgical generator capable of simultaneously powering specified monopolar and bipolar electrosurgical instruments. It is intended to be used for delivery of RF energy to instruments indicated for cutting and coagulation of soft tissue and for delivery of RF encrgy concurrent with saline to instruments indicated for hemostatic sealing and coagulation of soft tissue and bone. It is intended for, but not limited to. General. Plastic and Reconstructive (including but not limited to skin incisions and development of skin flaps), ENT, Gyneologic, Orthopaedic. Arthroscopic, Spinal and Neurological, Thoracic, and Open Abdominal Surgery procedures. The device is not intended for contraceptive tubal coagulation (Permanent Female Sterilization).
PlasmaBlade T:
The PlasmaBlade T is a monopolar, single use, sterile, disposable device intended for use with the AEX Generator. The device delivers RF energy concurrent with saling and coagulation of soft tissue and bone and RF energy for cutting and coagulation of soft tissue. It is intended for, but not limited to, General, Plastic and Reconstructive (including but not limited to skin incisions and development of skin flaps), ENT, Gynecologic, Orthopaedic, Arthroscopic, Spinal, Thoracic, and Open abdominal surgery procedures. The device is not intended for contraceptive tubal coagulation (permanent female sterilization).
Currently included as part of the system in this 510(k) submission are the AEX Generator, and the PlasmaBlade T Handpiece which is a one hand-held disposable, sterile, single use disposable electrosurgical device that is compatible only with the AEX Generator.
The AEX Generator is a line powered, electrosurgical generator with monopolar and bipolar RF that is intended for use only with specific compatible Medtronic electrosurgical Handpieces. The AEX Generator is a shelf-top unit consisting of a plastic, metal housing and a front LCD control panel. The Generator has a peristaltic pump outside the generator's housing, which is capable of transferring saline through the disposable accessory device concurrent with the generator's provision of RF energy. The LCD control panel is a touchscreen and serves as the user interface for power and saline settings. The AEX Generator has three-pin and seven-pin receptacles in its front panel that provides for the monopolar PlasmaBlade and bipolar Aquamantys disposable Handpieces connection to the Generator's RF power.
The proposed PlasmaBlade T Handpiece connection to the AEX Generator pump is configured to interface with the AEX Generator peristaltic pump. The AEX Generator accepts designated, commercially available, split-pad and single foil patient return electrode pads (neutral electrodes), non-REM neutral electrodes for monopolar applications
Here's an analysis of the acceptance criteria and study information based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present acceptance criteria in a structured table or numerical values for performance metrics. Instead, it relies on a comparison of the proposed device's performance to that of predicate devices, stating it is "comparable" or shows "no clinically significant difference."
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Thermal Effects on Tissue | |
Zone of thermal damage (AEx Generator vs. Predicates) | Comparable zone of thermal damage to predicate Aquamantys and Pulsar Generators. |
Zone of thermal damage (PlasmaBlade T vs. Predicates) | Comparable zone of thermal damage to predicate Aquamantys SBS 5.0 and PlasmaBlade 4.0 Handpieces. |
Software Verification | |
Compliance with IEC 62304 Edition 1: 2006 | Software development and testing executed in compliance. |
Electromagnetic Compatibility (EMC) | |
Compliance with IEC 60601-1-2 Edition 3: 2007-03 | Tested in compliance. |
Compliance with IEC 60601-2-2 Edition 5.0 2009-02 | Tested in compliance. |
Electrical Safety | |
Compliance with IEC 60601-1:2005 3rd Edition And A1:2012 | Tested in compliance. |
Compliance with IEC 60601-2-2 Edition 5.0 2009-02 | Tested in compliance. |
General Performance Characteristics | |
Output characteristics | Verified. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document mentions "in-vivo, ex-vivo animal (porcine) studies" for thermal effects on tissue. However, it does not specify the number of animals or specific samples used in these studies.
- Data Provenance: The studies were animal (porcine) studies and were conducted as non-clinical testing. The document does not specify the country of origin.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
The document does not mention the use of experts to establish ground truth for the animal studies in the context of human diagnosis or interpretation. The "ground truth" for the thermal effects appears to be directly measured or observed in the porcine tissue. For compliance with standards, the "ground truth" is adherence to the standard's requirements, which would typically be assessed by qualified engineers/testers, but no specific number or qualifications are provided.
4. Adjudication Method for the Test Set
Not applicable. The non-clinical testing and comparison against predicate devices do not involve an adjudication method in the context of human interpretation or diagnosis.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. The document describes non-clinical testing (animal studies, software verification, EMC, electrical safety, bench-top performance) that compares the proposed device to predicate devices. It does not mention any clinical studies involving human readers or cases, nor a multi-reader multi-case (MRMC) comparative effectiveness study to assess human reader improvement with or without AI assistance. The device in question is an electrosurgical generator and handpiece, not an AI diagnostic tool.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
Not applicable. The device is a physical electrosurgical system, not an algorithm or AI. The performance studies focus on the hardware's functional capabilities.
7. Type of Ground Truth Used
For the "Thermal Effects on Tissue" studies, the ground truth appears to be direct measurement or observation of thermal damage in porcine tissue. For the other tests (Software, EMC, Electrical Safety, Bench-top), the ground truth is compliance with recognized consensus standards and verification of output characteristics.
8. Sample Size for the Training Set
Not applicable. The device is an electrosurgical generator and handpiece, not a machine learning model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as no training set is used for this type of device.
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