The RF instruments are used for tissue and vessel coagulation (hemostasis) by means of radio-frequency current. The products are intended for use in endoscopically performed or supported surgery intended are: - Endoscopic procedures - Orthopedic coagulation - Neurosurgical coagulation The products are exclusively intended for use by specialized medical personnel and may only be used by adequately qualified and trained medical personnel.
Device Story
TipControl RF Instruments are disposable, single-use bipolar electrosurgical devices; consist of handle, sheath tube, electrode, and connection cable. Used in endoscopic, orthopedic, and neurosurgical procedures; operated by specialized medical personnel. Device connects to external bipolar radiofrequency generators (e.g., Surgitron, Surgi-Max Plus) which supply electrical current to distal tips for tissue/vessel coagulation. Provides hemostasis during surgery; benefits patient through controlled coagulation in minimally invasive settings.
Clinical Evidence
No clinical or animal studies were conducted. Substantial equivalence is supported by bench testing, including biocompatibility (ISO 10993), electrical safety, and electromagnetic compatibility (IEC 60601-1, IEC 60601-2-2, IEC 60601-2-18).
Technological Characteristics
Disposable bipolar electrosurgical instrument; 2.5mm electrode tip; 280mm or 350mm working length. Connects to external RF generators up to 4 MHz. Manufactured per ISO 13485, ISO 9001. Sterilized via ethylene oxide (ISO 11135). Biocompatibility per ISO 10993. Electrical safety per IEC 60601 series.
Indications for Use
Indicated for tissue and vessel coagulation (hemostasis) in endoscopic, orthopedic, and neurosurgical procedures. Intended for use by specialized, qualified, and trained medical personnel.
Regulatory Classification
Identification
An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.
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Public Health Service
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 5. 2017
Richard Wolf Medical Instruments Corporation Mr. Michael Loiterman US Head of Regulatory - QA/QC 353 Corporate Woods Parkway Vernon Hills, Illinois 60061
Re: K170377
Trade/Device Name: TipControl RF Instrument bipo Ø 2.5mm WL 280mm. TipControl RF Instrument bipo Ø 2.5mm WL 350mm Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: GEI Dated: February 3, 2017 Received: February 7, 2017
Dear Mr. Loiterman:
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
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Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
# Jennifer R. Stevenson -S
For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K170377
#### Device Name
TipControl RF Instrument bipo Ø 2.5mm W1 280mm, TipControl RF Instrument bipo Ø 2.5mm W1 350mm
Indications for Use (Describe)
The RF instruments are used for tissue and vessel coagulation (hemostasis) by means of radio-frequency current. The products are intended for use in endoscopically performed or supported surgery intended are:
- * Endoscopic procedures
- * Orthopedic coagulation
- * Neurosurgical coagulation
The products are exclusively intended for use by specialized medical personnel and may only be used by adequately qualified and trained medical personnel.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 5. 510(k) Summary
| Submitter: | | Date of Preparation: | February 3, 2017<br>Revised 04-04-2017 |
|---------------------------------------------------------------------|----------------------------------------------------------------------------------|----------------------------------------|----------------------------------------------------------------------------------|
| Company / Institution name: | RICHARD WOLF MEDICAL INSTRUMENTS CORP. | FDA establishment registration number: | 14 184 79 |
| Division name (if applicable): | N.A. | Phone number (include area code): | ( 847 ) 913 1113 |
| Street address: | 353 Corporate Woods Parkway | FAX number (include area code): | ( 847 ) 913 0924 |
| City: | Vernon Hills | State/Province: | Illinois |
| Country: | USA | ZIP / Postal Code: | 60061 |
| Contact name: | Mr. Michael G. Loiterman | | |
| Contact title: | US Head of Regulatory – QA/QC | | |
| Parent Company: | | | |
| Company / Institution name: | Richard Wolf GmbH | FDA establishment registration number: | 96 111 02 |
| Street address: | Pforzheimer Str. 32 | | |
| City: | Knittlingen | State/Province: | Baden-Württemberg |
| Country: | Germany | ZIP / Postal Code: | 75438 |
| Product Information: | | | |
| Trade names: | RF INSTRUMENT BIPO Ø 2.5MM WL<br>280MM<br>RF INSTRUMENT BIPO Ø 2.5MM WL<br>350MM | Model numbers: | 49936911<br>49936921 |
| Common name: | TipControl RF Instrument, bipo | Classification name: | GEI, 878.4400 Electrosurgical cutting and<br>coagulation device and accessories. |
| Information on devices to which substantial equivalence is claimed: | | | |
| 510(k) No.: | K003126 | Trade or proprietary or model name: | Trigger Flex™ Bipolar Electrode |
| Manufacturer: | ELLMAN INTL., INC. | | |
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# 5.1 Description
The TipControl RF (Radio Frequency) Instruments, bipo are disposable single-use, sterile packaged electrosurgical devices, used for tissue and vessel coagulation (hemostasis) by means of radio-frequency current. The products are intended for use in endoscopic performed or supported surgeries. The types of surgery intended are: Endoscopic procedures, orthopedic coagulation, and neurosurgical coagulation. These products are exclusively intended for use by specialized medical personnel and may only be used by adequately qualified and trained medical personnel.
The TipControl RF Instrument, bipo consists of a handle, a sheath tube, the TipControl RF electrode and a connection cable with an US 2-PIN device connector. The just mentioned components comprise a complete unit for disposable use and cannot be dismantled. They are currently available in a working length of 280 mm or 350 mm.
The TipControl RF Instruments, bipo are designed to be used in conjunction with the electrosurgical bipolar radiofrequency generators Surgitron and Surgi-Max Plus up to 4 MHz and endoscopic accessories. The RF generator provides power and delivers electrical current to the distal tips of the RF instruments.
The TipControl RF Instruments, bipo are manufactured in accordance with standards for quality management (ISO 13485, ISO 9001), for electrical medical devices (IEC 60601), for sterilization (ISO 11135), and for biological safety (ISO 10993).
# 5.2 Indications for Use
The RF instruments are used for tissue and vessel coagulation (hemostasis) by means of radiofrequency current.
The products are intended for use in endoscopically performed or supported surgeries. The types of surgery intended are:
- * Endoscopic procedures
- * Orthopedic coagulation
- * Neurosurgical coagulation
The products are exclusively intended for use by specialized medical personnel and may only be used by adequately qualified and trained medical personnel.
# 5.3 Substantial Equivalence
The following information summarizes the technological characteristics' comparison of the submitted TipControl RF Instruments, bipo versus the predicate device Trigger-Flex™ Bipolar Electrode (K003126).
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# 5.3.1 Similarities
The submitted instruments and the predicate devices share equivalent indications for use. They have an equivalent basic operational design and use equivalent materials. Both are used in conjunction with bipolar electrosurgical radiofrequency generators, sharing equivalent technical specifications. Both the instruments and the predicate are single-use and sterile provided. And both comply with the relevant safety standards of IEC 60601.
# 5.3.2 Main Differences
### Working Lengths
The shortest working length of the submitted instrument is 280mm vs. 240mm of the predicate instruments. The longest working length of the submitted instruments is 350mm vs. 320mm for the predicate instruments.
### Diameter of the Electrode Tip
The diameter of the electrode tip (2.5mm) is 0.5mm thinner than in the predicate instrument (3.0mm).
### Sterilization Method
The submitted instruments are sterilized via ethylene oxide (EO) sterilization, predicate instruments former via gamma radiation and actual with EO.
### Product Packaging
While predicate instruments are packaged into sealed Tyvek pouches, the herein submitted instruments additionally utilize a PETG blister.
# 5.4 Performance Data
## 5.4.1 Sterilization
The TipControl RF Instruments, bipo comply with the applicable requirements of the FDArecognized standards listed below:
- Recognition Number 14-452: ISO 11135 Second edition 2014, sterilization of health-care . products - ethylene oxide - requirements for the development, validation and routine control of a sterilization process for medical devices. (Sterility)
- Recognition Number 14-408: ISO 10993-7 Second edition 2008-10-15, biological ● evaluation of medical devices - part 7: ethylene oxide sterilization residuals [including: technical corrigendum 1 (2009)]. (Sterility)
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# 5.4.2 Bench Testing
The TipControl RF Instruments, bipo perform successfully in bench testing, conducted in alignment with the following FDA guidances:
- "Evaluation of Medical Devices - Part 1: Evaluation and testing within a risk management process" issued June 16, 2016
- "Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery" issued August 15, 2016
- "Premarket Notification (510(k)) Submissions for Bipolar Electrosurgical Vessel Sealers ● for General Surgery" issued August 15, 2016
#### Biocompatibility Testing 5.4.3
Biocompatibility Test Results:
| Test | Conclusion |
|-----------------------------------------------------------------------------------------------------------------------------------|-----------------|
| ISO 10993-5: Cytotoxicity Study (XTT Assay) | non-cytotoxic |
| ISO 10993-4, -12: Hemolysis Study (Extract Only) | non-hemolytic |
| ISO 10993-10, -12: Intracutaneous Reactivity Study in Rabbit | non-irritating |
| ISO 10993-10, -12 and OECD Guideline 429 and Commission Regulation EC No. 440/2008, B.42: Skin Sensitization Study in Mice (LLNA) | non-sensitizing |
| ISO 10993-11, -12: Systemic Toxicity Study in Mice | non-toxic |
# 5.4.4 Electrical Safety and Electromagnetic Compatibility
The TipControl RF Instruments, bipo fully comply with the applicable requirements of the FDArecognized standards listed below:
- Recognition No. 19-4, IEC 60601-1:2005/(R)2012 and A1:2012., c1:2009/(r)2012 and ● a2:2010/(r)2012 (consolidated text) medical electrical equipment - part 1: general requirements for basic safety and essential performance (IEC 60601-1:2005, mod). (ES/EMC)
- Recognition No. 6-336, IEC 60601-2-2 Edition 5.0 2009-02, medical electrical equipment ● - part 2-2: particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories [including: technical corrigendum 1 (2014)]. (General Plastic Surgery/General Hospital)
- Recognition No. 9-91, IEC 60601-2-18: Edition 3.0 2009-08, medical electrical . equipment - part 2-18: particular requirements for the basic safety and essential performance of endoscopic equipment. (ObGyn/Gastroenterology/Urology)
# 5.4.5 Software Verification and Validation Testing
The products do not contain software.
# 5.4.6 Animal Studies and Clinical Studies
Neither animal studies nor clinical studies were conducted in order to demonstrate substantial equivalence.
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# 5.5 Conclusions
The submitted TipControl RF Instruments, bipo and the Trigger-Flex™ Bipolar Electrode (K003126) share equivalent indications for use.
The technological differences do not raise new types of questions with regard to safety and efficacy. Validation testing has shown that the TipControl RF Instruments, bipo perform in accordance with their technological specifications and operate as intended. Devices are as safe and effective as predicate devices.
Thus, substantial equivalency to the aforementioned 510(k)-cleared predicate devices has been demonstrated.
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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.
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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.
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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.
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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?
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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.
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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.