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510(k) Data Aggregation

    K Number
    K143420
    Manufacturer
    Date Cleared
    2015-10-30

    (336 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K133444, K971247

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

    The SYMBIS Surgical System is a computer-controlled electromechanical arm. The arm is performed by the neurosurgeon. It is intended to be used in the spatial positioning and orientation of a biopsy instrument guide.

    Guidance is based on a pre-operative plan developed using the Medtronic StealthStation® along with fiducial marker or optical registration. The system is intended for use by neurosurgeons to guide a biopsy needle.

    It is intended for use by trained physicians for needle based biopsy.

    Device Description

    The SYMBIS Surgical System is a computer-controlled electromechanical arm. It is intended to be used in the operating room for the spatial positioning and orientation of an instrument guide. The system is intended for use by trained physicians for needle based biopsy.

    The SYMBIS Surgical System consists of the a Surgeon Console, Surgical Cart, Manipulator, Robot Control Cabinet (RCC), Vision System, Platform Room Integration Kit and System Software.

    The Manipulator is a master/slave robot configured with either a left arm or a right arm is mounted to the Surgical Cart. The Surgical Cart is used to transport the Manipulator to and from the operating room, as well as serve as a stationary platform for robotic surgery. The Surgical Cart has an onboard immobilization system to prevent horizontal movement when positioned for surgery. The Instrument Guide is attached to the draped Manipulator and is used by the surgeon to guide the trajectory of a stereotactic instrument (e.g. Biopsy Needle). The Manipulator has six (6) degrees of freedom (DOF). The SYMBIS System provides tremor filtering and motion scaling while the surgeon positions the Manipulator and Instrument Guide to the target position. A Vision System mounted to the Surgical Cart provides the surgeon with a high definition, three-dimensional view of the patient, surgical site, and Manipulator.

    The Surgeon Console provides the surgeon with workstation console from which the surgeon controls the Manipulator. The Surgeon Console is located in the operating room. The surgeon, seated at the Surgeon Console, controls all movements of the Manipulator with a hand controller and foot pedal. The upper and middle displays on the Surgeon Console are medical grade, high definition monitors, and the middle monitor is capable of displaying 3 dimensional (3D) images The upper display provides the video output from a third-party navigation system (i.e. Medtronic Stealth station s7/i7). The middle display provides the 3D video output from the field camera, to provide situational awareness to the surgeon when moving the robot near the patient, surgical site, and OR staff. The video from the Vision System, along with the video from the third-party navigation system, is used by the surgeon to manipulate the Instrument Guide to the entry position.

    The Robot Control Cabinet (RCC) is an electronics rack and contains to operate the Surgical Cart, Manipulator and Surgeon Console. It is situated in the hospital's equipment room, adjacent to the surgical suite. The RCC includes the supporting electronic, power supply, and computers for the system.

    The platform room integration kit includes motor drivers to run the Manipulator, an OR Pendant with an E-Stop, cable interface mounting plates and system integration cables.

    AI/ML Overview

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

    Acceptance Criteria and Device Performance for SYMBIS Surgical System

    1. Table of Acceptance Criteria and Reported Device Performance

    Criterion/CharacteristicAcceptance Criteria (Predicate Device K101791)Reported Device Performance (SYMBIS Surgical System)Comparison / Notes
    Indications for UseFor spatial positioning and orientation of a tool guide in neurosurgery. Applicable to any neurosurgical condition in which stereotactic surgery is appropriate.For spatial positioning and orientation of a biopsy instrument guide in neurosurgery. Intended for use by trained physicians for needle-based biopsy.Identical meaning (with added emphasis on "trained physicians" and specific to "biopsy needle").
    Where UsedHospitalHospitalIdentical
    UsersSurgeonSurgeonIdentical
    General DeviceComputer controlled electromechanical multi-jointed arm.Computer controlled electromechanical multi-jointed arm.Identical
    Localization meansRobot arm absolute encodersRobot arm absolute encodersIdentical
    Image-guidedSurgeon positions ROSA to desired biopsy trajectory using path planning software.Surgeon positions SYMBIS to desired biopsy trajectory using path planning software.Identical
    Registration MethodFiducial Markers, Optical Registration deviceFiducial Markers, Optical Registration deviceIdentical
    Instrument FixationInstruments are mounted onto robot arm's end effector.Instruments are mounted onto robot arm's end effector.Identical
    Instrument CalibrationCalibrated at the factoryCalibrated at the factoryIdentical
    System ImmobilizationCoupled to patient HFD via rigid, adjustable linkage.Coupled to patient HFD via rigid, adjustable linkage.Identical
    Patient ImmobilizationHFD Employed for Head FixationHFD Employed for Head FixationIdentical
    ModalitiesCT & MRI modalitiesCT and MRI modalities used for pre-operative planning and navigation.Identical
    Merge imagesNo support for Biopsy procedures for merging of multi-modal images in the path planning software.No support for Biopsy procedures for merging of multi-modal images in the path planning software.Identical
    Save/load path planningPath planning can be saved and loaded using the path planning software.Path planning can be saved and loaded using the path planning software.Identical
    Fiducial markers registration and pointer probeOptical registration accomplished with fiducial markers and registration probe using the path planning software.Optical registration accomplished with fiducial markers and registration probe using the path planning software.Identical
    Registration based on ultrasound measuresUltrasound based registration with patient is not supported with the path planning software.Ultrasound based registration with patient is not supported with the path planning software.Identical
    Deadman switch for cooperative movementDeadman switch employed for robotic arm movement.Deadman switch employed for robotic arm movement.Identical
    Accuracy verification on anatomical landmarksAccuracy verification performed on anatomical landmarks via a navigation probe.Accuracy verification performed on anatomical landmarks via a navigation probe.Identical
    Application Accuracy<2 mm<2 mmIdentical
    Display real-time instrument position on preoperative imagesReal-time instrument position displayed on pre-operative images in the path planning software.Real-time instrument position displayed on pre-operative images in the path planning software.Identical
    Provide mechanical guidance for surgical instrumentsSurgeon manually inserts the biopsy needle through the instrument guide.Surgeon manually inserts the biopsy needle through the instrument guide.Identical
    Surgeon carries out final gesture through the instrument guideSurgeon manually advances biopsy needle through instrument guide.Surgeon manually advances biopsy needle through instrument guide.Identical
    Electrical, Mechanical, Thermal SafetyIndustry recognized standards (IEC series).Industry recognized standards (IEC series).Identical
    EMC/EMI compatibilityIndustry recognized standards (IEC series).Industry recognized standards (IEC series).Identical
    BiocompatibilityIndustry recognized standards (IEC series).Industry recognized standards (ISO series).Identical (just different standard designation)
    Human FactorsUnknownIndustry recognized standards (IEC 62366:2007) and human factors study.Different (SYMBIS performed HF study concluding no significant risks).
    Cleaning, Disinfection, and Sterilization applicabilityManipulator arm draped (sterile drape) and disposed. Biopsy instrument guide reprocessed (sterilized).Manipulator arm draped (sterile drape) and disposed. Biopsy instrument guide sterile and disposed after use.Different (SYMBIS uses single-use/disposable guide to reduce contamination/degradation).
    Path Planning and Control SoftwareROSANNA from MedtechMedtronic StealthStation® (K133444) for path planning; SYMBIS control software for control.Different (different third-party navigation systems, but similar control software functionality).
    InstrumentationNavigation probe, Tool holder, Laser PointerNavigation probe, Tool holderDifferent (SYMBIS uses StealthStation's registration method which doesn't require a laser pointer).
    Optical registration with laser telemeterSupported on ROSA systemNot SupportedDifferent (SYMBIS uses StealthStation's registration method).
    Cooperative movementCooperative movement supported by manually guiding the instrument to the entry point.Cooperative movement supported through teleoperation at the surgeon console. Surgeon uses hand controller to manually guide the instrument.Different (ROSA implies direct manual guidance, SYMBIS specifies teleoperation via console/controller, but both involve user-guided manual positioning).
    3D Stereoscopic Camera for Situational AwarenessNot SupportedSupported by SYMBISDifferent (SYMBIS has this feature).
    Support for drilling through robot-held instrument guideSupported with ROSA systemNot supportedDifferent (SYMBIS used after burr hole is created, so not required).
    Associated equipmentSterile drapes, Fiducial markers, Neurosurgical head holder.Sterile drapes, Fiducial markers, Neurosurgical head holder, Stealth Station.Different (SYMBIS integrates with Medtronic StealthStation).

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

    The document primarily describes bench testing for design verification and validation, as well as a summative human factors validation study.

    • Design Verification and Validation (Bench Testing): No specific "test set" sample size in terms of patient data is mentioned for these tests. The testing focuses on compliance with standards (e.g., electrical safety, software, biocompatibility, sterilization) and functional performance of the device components. This is not patient data; it's device performance testing.
    • Human Factors Evaluation: Fifteen neurosurgeons participated in this study.
    • Data Provenance: The document does not specify the country of origin for any data beyond listing the submitter (IMRIS Inc.) as being from Minnetonka, MN, USA. There is no mention of retrospective or prospective data in the context of patient studies. The studies described are bench tests and a simulated human factors study, not clinical trials with patient data.

    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)

    • For the Human Factors Evaluation, 15 neurosurgeons participated. Their qualifications are stated as "neurosurgeons," but no further details (e.g., years of experience) are provided. Their role was to participate in a simulated surgical procedure to assess use-safety, effectiveness, and ease of use, not to establish ground truth for a test set in the traditional sense of medical image interpretation.

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

    • No adjudication method is mentioned. The human factors study involved neurosurgeons operating the system, and their feedback/performance was assessed, not a consensus interpretation of medical data.
    • For the bench testing, conformity to engineering specifications and standards served as the "ground truth," not expert 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

    • No MRMC comparative effectiveness study was done or mentioned in the document. The device is a computer-controlled electromechanical arm for surgical guidance, not an AI-assisted diagnostic or interpretive tool that would involve "human readers" in the typical sense of MRMC studies. It's a robotic assistance system, not an AI interpretation system.

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

    • This question is not directly applicable to the SYMBIS Surgical System as described. The system is explicitly designed for "human-in-the-loop" performance, where the "arm is performed by the neurosurgeon" and "the surgeon controls all movements of the Manipulator." There is no mention of a standalone algorithm-only mode or performance evaluation.

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

    • For design verification and validation, the ground truth was established by adherence to product specifications and recognized industry standards (e.g., IEC, ISO, AAMI). For example, a specified application accuracy of "<2 mm" is a measurable metric against which the device's performance is compared.
    • For the human factors evaluation, the "ground truth" was the assessment of "use-safety and effectiveness of the system, identify and assess any hazards resulting from implemented mitigations and evaluate ease of use" by the participating neurosurgeons in a simulated environment. This is less about a single patient-specific ground truth (like a pathology report) and more about overall system usability and safety performance.

    8. The sample size for the training set

    • No training set is mentioned as this device is not a machine learning or AI-based diagnostic tool that typically requires a training set of data. It is a robotic surgical assistance device whose control software's "training" would be part of its engineering design and development, rather than data-driven machine learning.

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

    • Not applicable, as no training set (in the context of machine learning) is referenced for this device.
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