K110829 · Barosense, Inc. · OCW · Jun 3, 2011 · Gastroenterology, Urology
Device Facts
Record ID
K110829
Device Name
ACE STAPLER AND CARTRIDGE
Applicant
Barosense, Inc.
Product Code
OCW · Gastroenterology, Urology
Decision Date
Jun 3, 2011
Decision
SESE
Submission Type
Special
Regulation
21 CFR 876.1500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The BaroSense ACE Stapler and Cartridge are indicated for endoluminal trans-oral tissue approximation and ligation in the gastrointestinal tract.
Device Story
The ACE Stapler is a surgical device used in hospitals or surgery centers for tissue closure in the stomach or GI tract. It consists of a reusable, flexible handle and a single-patient-use, disposable stapler head fitted with a sterile, single-use staple cartridge. Operated by a physician, the device is introduced trans-orally; a flexible endoscope is passed through the stapler for visualization. The device uses a vacuum pump to create a tissue plication, which is then compressed and secured with a double, circular row of titanium staples and a non-absorbable reinforcement ring. Tissue compression and stapling are controlled via external inflation syringes. The device may be used with a guidewire or an endogastric overtube for protection during repeated insertions. By enabling endoluminal tissue approximation, the device provides a minimally invasive alternative to traditional surgical approaches for GI tract procedures.
Clinical Evidence
No clinical data provided. Safety and effectiveness were established through bench testing and animal studies. All patient-contacting components were tested for biocompatibility per ISO 10993 requirements. All testing yielded acceptable results.
Technological Characteristics
Materials: Biocompatible per ISO 10993. Sensing/Actuation: Vacuum-assisted tissue plication; mechanical compression and stapling. Energy: Manual (inflation syringes). Form factor: Flexible, endoluminal, trans-oral. Connectivity: None. Sterilization: Radiation (ISO 11137-1, ISO 11137-2). Components: Reusable handle, disposable head, single-use cartridge, titanium staples, non-absorbable reinforcement ring.
Indications for Use
Indicated for endoluminal trans-oral tissue approximation and ligation in the gastrointestinal tract for patients requiring such procedures.
Regulatory Classification
Identification
An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.
Special Controls
*Classification* —(1)*Class II (special controls).* The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.
In combination with the general controls of the FD&C Act, the integrated operating table-electromechanical surgical system is subject to the following special controls:
1. (1) Premarket clinical performance testing, or a combination of premarket clinical performance testing and postmarket surveillance (in accordance with special control (2)), must include the following:
1. (i) Objective performance measures (e.g., rate and number of conversions to other surgical modalities, rate of device related adverse events (including tissue injury, hematoma, and increased blood loss), and their severity, cause, and outcomes) must be reported with relevant descriptive comparator performance measures.
2. (ii) The data must demonstrate the performance of the device for providing accurate and precise control of attached surgical instruments in range of clinical conditions relevant to the device's intended use.
3. (iii) The test dataset must include data collected from a patient population representative of the intended patient population under anticipated conditions of use.
2. (2) Data obtained from postmarket surveillance must demonstrate, in consideration of the premarket data obtained in accordance with special control (1), that the device performs in accordance with special control (1), unless FDA determines, based on the totality of the premarket data, that data from postmarket surveillance is not required to demonstrate that the device performs as intended. Such postmarket surveillance must be conducted per a protocol determined appropriate by FDA to demonstrate that the device performs as intended (in consideration of the premarket data obtained in accordance with special control (1)), and must include initiation, enrollment, and reporting requirements to ensure timely periodic updates to FDA on post-market surveillance progress and outcomes.
3. (3) Animal performance testing must evaluate the extent of port site trauma due to repositioning of table during surgical procedures when utilizing robotic minimally invasive and laparoscopic approaches
4. (4) The device manufacturer must develop, and update as necessary, a device-specific use training program that ensures proper device setup/use/shutdown, accurate control of instruments to perform the intended surgical procedures, troubleshooting and handling during unexpected events or emergencies, and safe practices to mitigate use error.
5. (5) The device manufacturer may only distribute the device to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program.
(6) Human factors assessment must demonstrate that the user can correctly use the device system across all intended use environments with the provided instructions and training materials, including patient access during normal operating conditions and emergency situations, and effects arising from the integrated nature of the operating table and robotic surgical arms.
(7) Labeling must include:
(i) A detailed summary of clinical performance testing conducted with the device, including study population, results, adverse events, and comparisons to any comparator groups identified;
(ii) A statement in the labeling that the safety and effectiveness for the representative specific procedures was based on evaluation of the device as a surgical tool and did not include evaluation of outcomes related to the treatment of the patient's underlying disease or condition, unless FDA determines that it can be removed or modified based on clinical performance data submitted to FDA;
(iii) Identification of compatible devices;
(iv) The list of surgical procedures for which the device has been determined to be safe with clinical justification;
(v) Reprocessing instructions for reusable components;
(vi) A shelf life for any sterile components;
(vii) A description of the device-specific use training program;
(viii) A statement that the device is only for distribution to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program; and
(ix) A summary of any completed postmarket surveillance data collected as required by special control (2), including updated labeling to accurately reflect outcomes observed in postmarket surveillance.
(8) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use and must include:
(i) Device motion accuracy and repeatability;
(ii) System testing;
(iii) Instrument reliability;
(iv) Crosstalk;
(v) Table motion control;
(vi) Thermal effects on tissue;
(vii) User-device interface performance;
(viii) Workspace access testing; and
(ix) Performance testing with compatible devices.
(9) Software verification, validation, and hazard analysis must be performed.
(10) Electromagnetic compatibility and electrical, thermal, and mechanical safety testing must be performed.
(11) Performance data must demonstrate the sterility of all patient-contacting device components.
(12) Performance data must support the shelf life of the device components provided sterile by demonstrating continued sterility and package integrity over the labeled shelf life.
(13) Performance data must validate the reprocessing instructions for the reusable components of the device.
(14) Performance data must demonstrate that all patient-contacting components of the device are biocompatible.
(15) Performance data must demonstrate that all patient-contacting components of the device are non-pyrogenic.
(16) The device manufacturer must submit a report to the FDA annually on the anniversary of initial marketing authorization for the device, until such time as FDA may terminate such reporting, which comprises the following information:
(i) Cumulative summary, by year, of complaints and adverse events since date of initial marketing authorization; and
(ii) Identification and rationale for changes made to the device, labeling, or device specific use training program, which did not require submission of a premarket notification during the reporting period.
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#### III. 510(k) Summary
JUN - 3 2011
# BaroSense ACE™ Stapler and Cartridge
Image /page/0/Picture/4 description: The image shows the logo for Barosense Inc. The logo features a stylized figure with arms raised inside of a circle. The text "BAROSENSE" is to the right of the figure, with "INC." below it.
# General Information
| Criteria | Information |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | ACE™ Stapler<br>(Note: the trademark name is still being finalized<br>and may change from that listed above) |
| Product Name | ACE Stapler and Cartridge |
| Catalog/Model Number | F0084 ACE Stapler Reusable Handle<br>F0085 ACE Stapler Head<br>F0087 ACE Stapler Cartridge |
| Common Name | surgical stapler and cartridge |
| Classification | 21 CFR 876.1500- Endoscope and Accessories;<br>Class II; Product code: OCW |
| 510(k) Owner | BaroSense, Inc.<br>250 Chesapeake Drive<br>Redwood City CA 94063 |
| Contact Person | Sheila Stevens, PhD<br>Director Clinical and Regulatory Affairs BaroSense, Inc.<br>sstevens@barosense.com<br>650-362-6016 (phone) 650-362-0070 (fax) |
## Summary of Substantial Equivalence
The BaroSense, Inc., ACE Stapler and Cartridge (component models F0084, F0085 and F0086) are substantially equivalent to the BaroSense ACE Stapler and Cartridge (component models F0031 and F0007).
Date: March 22, 2011
{1}------------------------------------------------
# Predicate Devices
| Manufacturer | Predicate device | 510(k) |
|-------------------------------------|----------------------------------------------------------------|---------|
| BaroSense, Inc.<br>Redwood City, CA | ACE Stapler, model F0031<br>ACE Stapler Cartridge, model F0007 | K082044 |
## Device Description
The ACE™ Stapler is a surgical stapler used in hospitals or surgery centers for staple closure on the wall of the stomach or gastrointestinal tract.
The single-patient-use, disposable stapler head is supplied non-sterile and is fitted with a sterile, single-use staple cartridge. The stapler head is attached to a reusable, flexible stapler handle that controls the position and articulation of the stapler head. In use, the stapler is introduced into the patient through the mouth. A flexible endoscope passes through the stapler for gastric tissue visualization. The stapler works in conjunction with a vacuum pump to create a plication [tissue fold] in the GI tract, which is then compressed. The stapler then places a double, circular row of titanium staples. A non-absorbable ring helps reinforce the staple placement in the tissue. The tissue compression and stapling functions are controlled by commercially available inflation syringes.
The stapler may be introduced over a guidewire. If multiple plications are required, an endogastric overtube may be used to protect the esophageal tissues during repeated insertions of the device. The guidewire, overtube, flexible endoscope, vacuum pump and inflation syringes used with the stapler are all commercially available medical devices, not the subject of this 510(k), and are not supplied with the stapler.
The predicate device has identical technological characteristics. However, the predicate stapler device is provided as a single-patient-use, non-sterile, disposable unit. The predicate device is introduced through an overtube, as it does not include a membrane designed for guidewire introduction.
### Indications for Use
The BaroSense ACE Stapler is indicated for endoluminal trans-oral tissue approximation and ligation in the gastrointestinal tract.
### Bench/Animal Testing
All patient contacting components of the ACE Stapler are composed of materials of known biocompatibility tested to the requirements of ISO 10993. The safety and effectiveness of the device was further established through a series of bench and animal tests. All testing yielded acceptable results.
{2}------------------------------------------------
| Form Approved: OMB No. 0910-0120; Expiration Date: 8/31/10 | | |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-------------------------------------------------------|
| Department of Health and Human Services<br>Food and Drug Administration | | |
| STANDARDS DATA REPORT FOR 510(k)s<br>( <i>To be filled in by applicant</i> ) | | |
| This report and the Summary Report Table are to be completed by the applicant when submitting a 510(k) that refer-<br>ences a national or international standard. A separate report is required for each standard referenced in the 510(k). | | |
| <b>TYPE OF 510(K) SUBMISSION</b> | | |
| <label><input type="checkbox"/> Traditional</label> | <label><input checked="" type="checkbox"/> Special</label> | <label><input type="checkbox"/> Abbreviated</label> |
| <b>STANDARD TITLE</b> <sup>1</sup> | | |
| ISO 11137-1:2006 Sterilization of Health Care Products - Radiation- Part 1: | | |
| <b>Please answer the following questions</b> | | |
| Is this standard recognized by FDA <sup>2</sup> ? | <label><input checked="" type="checkbox"/> Yes</label> | <label><input type="checkbox"/> No</label> |
| FDA Recognition number <sup>3</sup> | # 14-297 | |
| Was a third party laboratory responsible for testing conformity of the device to this standard identified in the 510(k)? | <label><input checked="" type="checkbox"/> Yes</label> | <label><input type="checkbox"/> No</label> |
| Is a summary report <sup>4</sup> describing the extent of conformance of the standard used included in the 510(k)?<br>If no, complete a summary report table. | <label><input checked="" type="checkbox"/> Yes</label> | <label><input type="checkbox"/> No</label> |
| Does the test data for this device demonstrate conformity to the requirements of this standard as it pertains to this device? | <label><input checked="" type="checkbox"/> Yes</label> | <label><input type="checkbox"/> No</label> |
| Does this standard include acceptance criteria?<br>If no, include the results of testing in the 510(k). | <label><input checked="" type="checkbox"/> Yes</label> | <label><input type="checkbox"/> No</label> |
| Does this standard include more than one option or selection of tests?<br>If yes, report options selected in the summary report table. | <label><input type="checkbox"/> Yes</label> | <label><input checked="" type="checkbox"/> No</label> |
| Were there any deviations or adaptations made in the use of the standard?<br>If yes, were deviations in accordance with the FDA supplemental information sheet (SIS) <sup>5</sup> ? | <label><input type="checkbox"/> Yes</label> | <label><input checked="" type="checkbox"/> No</label> |
| Were deviations or adaptations made beyond what is specified in the FDA SIS?<br>If yes, report these deviations or adaptations in the summary report table. | <label><input type="checkbox"/> Yes</label> | <label><input checked="" type="checkbox"/> No</label> |
| Were there any exclusions from the standard?<br>If yes, report these exclusions in the summary report table. | <label><input type="checkbox"/> Yes</label> | <label><input checked="" type="checkbox"/> No</label> |
| Is there an FDA guidance <sup>6</sup> that is associated with this standard?<br>If yes, was the guidance document followed in preparation of this 510k? | <label><input type="checkbox"/> Yes</label> | <label><input checked="" type="checkbox"/> No</label> |
| Title of guidance: | | |
| <sup>1</sup> The formatting convention for the title is: [SDO] [numeric identifier]<br>[title of standard] [date of publication]<br><sup>2</sup> Authority [21 U.S.C.,360d], www.fda.gov/cdrh/stdsprog.html<br><sup>3</sup> http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/search.cfm<br><sup>4</sup> The summary report should include: any adaptations used to adapt to the device under review (for example, alternative test methods); choices made when options or a selection of methods are described; deviations from the standard; requirements not applicable to the device; and the name and address of the test laboratory or certification body involved in conformance assessment to this standard. The summary report Includes information on all standards utilized during the development of the device.<br><sup>5</sup> The supplemental Information sheet (SIS) is additional information which is necessary before FDA recognizes the standard. Found at http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/search.cfm<br><sup>6</sup> The online search for CDRH Guidance Documents can be found at www.fda.gov/cdrh/guidance.html | | |
{3}------------------------------------------------
Form Approved: OMB No. 0910-0120; Expiration Date: 8/31/10
Department of Health and Human Services
Food and Drug Administration
**STANDARDS DATA REPORT FOR 510(k)s**
(*To be filled in by applicant*)
This report and the Summary Report Table are to be completed by the applicant when submitting a 510(k) that refer- ences a national or international standard. A separate report is required for each standard referenced in the 510(k).
TYPE OF 510(K) SUBMISSION
| | Traditional | <input type="checkbox"/> | Special | <input checked="" type="checkbox"/> | Abbreviated | <input type="checkbox"/> |
|--|-------------|--------------------------|---------|-------------------------------------|-------------|--------------------------|
|--|-------------|--------------------------|---------|-------------------------------------|-------------|--------------------------|
| STANDARD TITLE¹ | ISO 11137-2:2006 Sterilization of Health Care Products - Radiation- Part 2: |
|-----------------|-----------------------------------------------------------------------------|
|-----------------|-----------------------------------------------------------------------------|
Please answer the following questions
| | Yes | No |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|-------------------------------------|
| Is this standard recognized by FDA²? | <input checked="" type="checkbox"/> | <input type="checkbox"/> |
| FDA Recognition number³ | # 14-225 | |
| Was a third party laboratory responsible for testing conformity of the device to this standard identified in the 510(k)? | <input checked="" type="checkbox"/> | <input type="checkbox"/> |
| Is a summary report⁴ describing the extent of conformance of the standard used included in the 510(k)? If no, complete a summary report table. | <input checked="" type="checkbox"/> | <input type="checkbox"/> |
| Does the test data for this device demonstrate conformity to the requirements of this standard as it pertains to this device? | <input checked="" type="checkbox"/> | <input type="checkbox"/> |
| Does this standard include acceptance criteria? If no, include the results of testing in the 510(k). | <input checked="" type="checkbox"/> | <input type="checkbox"/> |
| Does this standard include more than one option or selection of tests? If yes, report options selected in the summary report table. | <input type="checkbox"/> | <input checked="" type="checkbox"/> |
| Were there any deviations or adaptations made In the use of the standard? If yes, were deviations in accordance with the FDA supplemental information sheet (SIS)⁵? | <input type="checkbox"/> | <input checked="" type="checkbox"/> |
| Were deviations or adaptations made beyond what is specified in the FDA SIS? If yes, report these deviations or adaptations in the summary report table. | <input type="checkbox"/> | <input checked="" type="checkbox"/> |
| Were there any exclusions from the standard? If yes, report these exclusions in the summary report table. | <input type="checkbox"/> | <input checked="" type="checkbox"/> |
| Is there an FDA guidance⁶ that is associated with this standard? If yes, was the guidance document followed in preparation of this 510k? Title of guidance: | <input type="checkbox"/> | <input checked="" type="checkbox"/> |
¹ The formatting convention for the title is: [SDO] [numeric Identifier] [title of standard] [date of publication]
² Authority [21 U.S.C. 360d], www.fda.gov/cdrh/stdsprog.html
³ http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/ search.cfm
⁴ The summary report should include: any adaptations used to adapt to the device under review (for example, alternative test methods); choices made when options or a selection of methods are described; deviations from the standard; requirements not applicable to the device; and the name and address of the test laboratory or certification body involved in conformance assessment to this standard. The summary report includes information on all standards utilized during the development of the device.
⁵ The supplemental information sheet (SIS) Is additional information which la necessary before FDA recognizes the standard. Found at http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/ search cfm
⁶ The online search for CDRH Guidance Documents can be found at www.fda.gov/cdrh/guidance.html
FORM FDA 3654 (9/07)
Page 1
PSC Graphics (301) 443-1020
:
・
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| Form Approved: OMB No. 0910-0120; Expiration Date: 8/31/10 | |
|------------------------------------------------------------------------------|--|
| Department of Health and Human Services<br>Food and Drug Administration | |
| STANDARDS DATA REPORT FOR 510(k)s<br>( <i>To be filled in by applicant</i> ) | |
This report and the Summary Report Table are to be completed by the applicant when submitting a 510(k) that references a national or international standard. A separate report is required for each standard referenced in the 510(k).
TYPE OF 510(K) SUBMISSION
| <span style="display:inline-block; width: 100px;"></span> Traditional | <span style="display:inline-block; width: 100px;"></span> Special | <span style="display:inline-block; width: 100px;"></span> Abbreviated |
|-----------------------------------------------------------------------|-------------------------------------------------------------------|-----------------------------------------------------------------------|
|-----------------------------------------------------------------------|-------------------------------------------------------------------|-----------------------------------------------------------------------|
| STANDARD TITLE <sup>1</sup> |
|-----------------------------------------------------------------------------------------------------------|
| 10993-1:2009 Biological evaluation of medical devices -- Part 1:Evaluation and testing (Biocompatibility) |
**Please answer the following questions**
| Is this standard recognized by FDA <sup>2</sup> ? | Yes <img alt="Checked" src="checkbox_checked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------|--------------------------------------------------------|
| FDA Recognition number <sup>3</sup> | #2-156 | |
| Was a third party laboratory responsible for testing conformity of the device to this standard identified in the 510(k)? | Yes <img alt="Unchecked" src="checkbox_unchecked.png"/> | No <img alt="Checked" src="checkbox_checked.png"/> |
| Is a summary report <sup>4</sup> describing the extent of conformance of the standard used included in the 510(k)?<br>If no, complete a summary report table. | Yes <img alt="Checked" src="checkbox_checked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Does the test data for this device demonstrate conformity to the requirements of this standard as it pertains to this device? | Yes <img alt="Checked" src="checkbox_checked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Does this standard include acceptance criteria?<br>If no, include the results of testing in the 510(k). | Yes <img alt="Checked" src="checkbox_checked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Does this standard include more than one option or selection of tests?<br>If yes, report options selected in the summary report table. | Yes <img alt="Checked" src="checkbox_checked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Were there any deviations or adaptations made in the use of the standard?<br>If yes, were deviations in accordance with the FDA supplemental information sheet (SIS) <sup>5</sup> ? | Yes <img alt="Unchecked" src="checkbox_unchecked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Were deviations or adaptations made beyond what is specified in the FDA SIS?<br>If yes, report these deviations or adaptations in the summary report table. | Yes <img alt="Unchecked" src="checkbox_unchecked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Were there any exclusions from the standard?<br>If yes, report these exclusions in the summary report table. | Yes <img alt="Unchecked" src="checkbox_unchecked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
| Is there an FDA guidance <sup>6</sup> that is associated with this standard?<br>If yes, was the guidance document followed in preparation of this 510k?<br>Title of guidance: | Yes <img alt="Unchecked" src="checkbox_unchecked.png"/> | No <img alt="Unchecked" src="checkbox_unchecked.png"/> |
<sup>1</sup> The formatting convention for the title is: [SDO] [numeric Identifier] certification body involved in conformance assessment to this
(title of standard) [date of publication] standard. The summary report includes information on all standards
<sup>2</sup> Authority (21 U.S.C. 360d), www.fda.gov/cdrh/stdsprog.html utilized during the development of the device.
<sup>3</sup> http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/ <sup>5</sup> The supplemental information sheet (SIS) is additional information
search.cfm which is necessary before FDA recognizes the standard. Found at
<sup>4</sup> The summary report should Include: any adaptations used to adapt http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/
to the device under review (for example, alternative test methods); search.cfm
choices made when options or a selection of methods are described; <sup>6</sup> The online search for CDRH Guidance Documents can be found at
deviations from the standard: requirements not applicable to the www.fda.gov/cdrh/guidance.html
device; and the name and address of the test laboratory or
| FORM FDA 3654 (9/07)<br>Page 1 | PSC Graphics (301) 443-6500 |
|--------------------------------|-----------------------------|
|--------------------------------|-----------------------------|
·
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Image /page/5/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract image of an eagle with its wings spread.
Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring. MD 20993-0002
Sheila S. Stevens, Ph.D. Director, Clinical and Regulatory Affairs BaroSense, Inc. 250 Chesapeake Drive REDWOOD CITY CA 94063
JUN - 3 2011
Re: K110829
Trade/Device Name: ACE Stapler and Cartridge, Models F0084, -85 and -86 Regulation Number: 21 CFR 8876.1500 Regulation Name: Endoscope and accessories Regulatory Class: II Product Code: OCW Dated: April 28, 2011 Received: May 6, 2011
Dear Dr. Stevens:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related
{6}------------------------------------------------
#### Page 2
adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Hubert Lemmer MD
Herbert P. Lerner, M.D., Director (Acting) Division of Reproductive, Gastro-Renal and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{7}------------------------------------------------
K110829 page loft
#### Statement of Indications for Use II.
510(k) Number (if known): K // 0829
Device Name: ACE™ Stapler and Cartridge
Indications for Use: The BaroSense ACE Stapler and Cartridge are indicated for endoluminal trans-oral tissue approximation and ligation in the gastrointestinal tract.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Helid Reum
Page 1 of 1
uctive, Gastro-Renal, and
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.