The Sphincterotome is indicated for use in the cannulation of the biliary ducts and the transendoscopic sphincterotomy of the Papilla of Vater and/or the Spincter of Oddi. The device is supplied sterile and intended for single use only.
Device Story
Sterile, single-use sphincterotome for endoscopic use; compatible with endoscope working channels. Device consists of long plastic tube with internal wire; distal end features exposed wire segment. Operated by physician during ERCP; device functions as applied part of electrosurgical generator. High-frequency monopolar current delivered through wire to open papilla roof, exposing biliary or pancreatic orifices for cannulation. Some models include preloaded guidewire. Output is mechanical incision via electrosurgical energy. Benefits include facilitated ductal access and sphincterotomy.
Clinical Evidence
No clinical data included. Substantial equivalence supported by bench testing, including biocompatibility (ISO 10993-5, -10, -11), electrosurgical safety (IEC 60601), and performance testing (injection, compatibility, visibility, electrical performance, mechanical integrity).
Technological Characteristics
Materials: PTFE, Stainless Steel 304, PET, silicone oil, polyurethane, hydrophilic coating. Energy: Monopolar radio frequency current. Form factor: Long tube (1800mm) for 2.8mm accessory channels. Sterilization: Ethylene Oxide (EO), SAL 10^-6. Connectivity: None (standalone accessory).
Indications for Use
Indicated for cannulation of biliary ducts and transendoscopic sphincterotomy of the Papilla of Vater and/or Sphincter of Oddi in patients undergoing ERCP.
Regulatory Classification
Identification
An endoscopic electrosurgical unit and accessories is a device used to perform electrosurgical procedures through an endoscope. This generic type of device includes the electrosurgical generator, patient plate, electric biopsy forceps, electrode, flexible snare, electrosurgical alarm system, electrosurgical power supply unit, electrical clamp, self-opening rigid snare, flexible suction coagulator electrode, patient return wristlet, contact jelly, adaptor to the cord for transurethral surgical instruments, the electric cord for transurethral surgical instruments, and the transurethral desiccator.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
February 8, 2021
Hangzhou AGS MedTech Co., Ltd. Chunqi Han R&D Director Building 5, Building 6, No.597 Kangxin Road Yuhang District Hangzhou, Zhejiang 311106 CHINA
Re: K201121
Trade/Device Name: Sphincterotome Regulation Number: 21 CFR 876.4300 Regulation Name: Endoscopic electrosurgical unit and accessories Regulatory Class: Class II Product Code: KNS
Dear Chunqi Han:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated February 5, 2021. Specifically, FDA is updating this SE Letter with a signature as an administrative correction.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Thelma Valdes, OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices, 301-796-9621, Thelma.valdes@fda.hhs.gov.
Sincerely,
Date: 2021.02.08 Thelma I. Valdes -S 12:47:14 -05'00'
Thelma Valdes, Ph.D. Acting Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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February 5, 2021
Hangzhou AGS MedTech Co., Ltd. Chunqi Han R&D Director Building 5, Building 6, No.597 Kangxin Road Yuhang District Hangzhou, Zhejiang 311106 CHINA
Re: K201121
> Trade/Device Name: Sphincterotome Regulation Number: 21 CFR 876.4300 Regulation Name: Endoscopic electrosurgical unit and accessories Regulatory Class: Class II Product Code: KNS Dated: April 22, 2020 Received: April 27, 2020
Dear Chungi Han:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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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 adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Thelma Valdes, PhD Acting Assistant Director Obesity and Hepatobiliary Devices Team DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
#### 510(k) Number (if known)
K201121
Device Name Sphincterotome
Indications for Use (Describe)
The Sphincterotome is indicated for use in the cannulation of the biliary ducts and the transendoscopic sphincterotomy of the Papilla of Vater and/or the Spincter of Oddi. The device is supplied sterile and intended for single use only.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
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#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
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Image /page/4/Picture/0 description: The image shows a logo for AGS Medtech. The logo consists of a blue circular design with a green center, resembling a stylized medical symbol. To the right of the symbol, the text "AGS MEDTECH" is written in a simple, sans-serif font, with the Chinese characters for "Anjie Si Medical" appearing below it.
# 510(k) Summary
We submit this 510(k) Summary as per 21 CFR 807.92, it meets the content and format regulatory requirements.
# 5.1 Submitter
| Submitted by/Owner: | Hangzhou AGS MedTech Co., Ltd.<br>Building 5, Building 6, NO.597 Kangxin Road Yuhang<br>District, Hangzhou, Zhejiang 311106 China |
|---------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|
| Establishment<br>Registration Number: | 3010288205 |
| Registration Status: | Active |
| Contact Person: | Yanping Fu<br>Phone: 0086-15958493282<br>Fax: 0086-0571-87671225<br>Email: fuyp@bioags.com |
| Date Prepared: | Apr. 22, 2020 |
# 5.2 Proposed Device
| Trade Name: | Sphincterotome |
|-------------------------|-----------------------------------------------------------------|
| Device Name: | Sphincterotome |
| Common Name: | Sphincterotome |
| Regulation class: | Class II |
| Regulation Number: | 876.4300 |
| Regulation Description: | Endoscopic electrosurgical unit and accessories. |
| Review Panel: | Gastroenterology/Urology |
| Product Code: | KNS |
| Product Code Name: | Unit, Electrosurgical, Endoscopic (With Or Without Accessories) |
### 5.3 Predicate Device
| Trade Name: | Howell D.A.S.H.® |
|-------------------------|-----------------------------------------------------------------|
| Device Name: | Sphincterotome with DomeTip |
| Common Name: | Sphincterotome with DomeTip |
| 510(k) Number: | K172665 |
| Regulation class: | Class II |
| Regulation Number: | 876.4300 |
| Regulation Description: | Endoscopic electrosurgical unit and accessories. |
| Review Panel: | Gastroenterology/Urology |
| Product Code: | KNS |
| Product Code Name: | Unit, Electrosurgical, Endoscopic (With Or Without Accessories) |
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Image /page/5/Picture/1 description: The image contains a logo for AGS Medtech. The logo consists of a circular design with three curved shapes in blue and green. To the right of the logo, the text "AGS MEDTECH" is written in English, followed by the same name written in Chinese characters. The text is in a simple, sans-serif font.
| Trade Name: | Huibregtse® |
|-------------------------|-----------------------------------------------------------------|
| Device Name: | Needle knife |
| Common Name: | Needle knife |
| 510(k) Number: | K040981 |
| Regulation class: | Class II |
| Regulation Number: | 876.4300 |
| Regulation Description: | Endoscopic electrosurgical unit and accessories. |
| Review Panel: | Gastroenterology/Urology |
| Product Code: | KNS |
| Product Code Name: | Unit, Electrosurgical, Endoscopic (With Or Without Accessories) |
### 5.4 Device Description
The sphincterotome described in this submission are a sterile, single use devices compatible with the working channel of endoscope. The device consists of a long plastic tube with a wire running the length of its interior. A small portion of that wire is exposed at its distal end. The roof of the papilla is opened by passing high-frequency current through the wire, exposing the biliary or pancreatic orifices for selective cannulation. For 50910 series, there's preloaded guide wire.
### 5.5 Indication for use statement
The Sphincterotome is indicated for use in the cannulation of the biliary ducts and the transendoscopic sphincterotomy of the Papilla of Vater and/or the Spincter of Oddi. The device is supplied sterile and intended for single use only.
### 5.6 Comparison of Technology Characteristics
Our proposed device Sphincterotome is substantially equivalent to the predicate devices. The differences between the Sphincterotome and the predicate devices do not raise any questions regarding its safety and effectiveness. The differences are listed in the table below
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Image /page/6/Picture/1 description: The image contains a logo with the text "AGS MEDTECH" and "安杰思医学". The logo consists of a circular design with three curved shapes in blue and green. The text "AGS MEDTECH" is in a smaller font size and is positioned above the Chinese characters "安杰思医学", which are in a larger font size. The overall design is clean and professional, suggesting a company in the medical technology field.
| Item | Proposed device | Predicate device | Comparison | |
|----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|
| Common name | Sphincterotome | Sphincterotome with DomeTip | Similar | |
| Trade name | Sphincterotome | D.A.S.H | / | |
| Model number | 5096, 5098, 50910 | DASH-21, DASH-21-480,<br>DASH-1, DASH-260,<br>DASH-480, DASH-ACRO-<br>25-450, DASH-35, DASH-<br>ACRO-35-260, DASH-35-<br>480, DASHACRO-35-450 | / | |
| 510(k) submitter | Hangzhou AGS<br>MedTech Co., Ltd. | Wilson-Cook Medical, Inc. | / | |
| 510(k) number | / | K172665 | / | |
| Clinical Intended use | The Sphincterotome is<br>indicated for use in the<br>cannulation of the<br>biliary ducts and the<br>transendoscopic<br>sphincterotomy of the<br>Papilla of Vater and/or<br>the Spincter of Oddi.<br>The device is supplied<br>sterile and intended for<br>single use only. | Howell D.A.S.H.®<br>Sphincterotome with<br>DomeTip® (Cook<br>Reference Part Numbers<br>DASH-21, DASH-21-480,<br>DASH-1, DASH-260,<br>DASH-480, DASH-ACRO-<br>25-450, DASH-35, DASH-<br>ACRO-35-260, DASH-35-<br>480, DASHACRO-35-450):<br>This device is used for<br>cannulation of the ductal<br>system and for<br>sphincterotomy. If<br>preloaded, also aids in<br>bridging difficult strictures<br>during ERCP. | Same | |
| Technical Principles of<br>operation | Monopolar<br>Sphincterotome<br>manufactured is an<br>applied part of<br>electrosurgical<br>generator, using<br>monopolar high-<br>frequency current<br>delivered by the | Monopolar Sphincterotome<br>manufactured is an applied<br>part of electrosurgical<br>generator, using monopolar<br>high-frequency current<br>delivered by the<br>electrosurgical generator for<br>sphincterotomy with the<br>electrode. The high- | Same | |
| | Item | Proposed device | Predicate device | Comparison |
| | | electrosurgical<br>generator for<br>sphincterotomy with<br>the electrode. The<br>high-frequency<br>electricity flows from<br>the active electrode to<br>the neutral electrode<br>placed on patient skin. | frequency electricity flows<br>from the active electrode to<br>the neutral electrode placed<br>on patient skin. | |
| | Energy Use | Monopolar Radio<br>Frequency Current | Monopolar Radio<br>Frequency Current | Same |
| | Preloaded<br>Wire Guide<br>or not | Preloaded Wire Guide:<br>50910<br>Not preloaded Wire<br>Guide: 5096, 5098; | Preloaded Wire Guide:<br>DASH-21-480, DASH-<br>ACRO-25-450, DASH-480,<br>DASH-260, DASH-ACRO-<br>35-260, DASH-35-480,<br>DASHACRO-35-450;<br>Not preloaded Wire Guide:<br>DASH-21, DASH-1,<br>DASH-35; | / |
| | Sheath tube | 2.4mm | Catheter Size: 5.5Fr<br>(≈1.8mm), 6Fr (≈2mm),<br>6.5Fr (≈2.1mm) | Similar |
| | Wire Guide<br>Diameter | 0.63mm, 0.89mm | Wire Guide Diameter inch:<br>0.021 (≈0.53mm), 0.025<br>(≈0.58mm), 0.035<br>(≈0.89mm); | Similar |
| | Minimum<br>Accessory<br>Channel: | 2.8mm | 2.8mm | Same |
| | Working<br>length | 1800mm | 1960mm; | Similar |
| | Performance | (1)Injection<br>performance;<br>(2)Compatibility with<br>traction guide wire;<br>(3)Compatibility with<br>Endoscope;<br>(4)X-ray detectability, | No information | Substantial<br>equivalence.<br>We conducted all<br>the performance<br>testing on our<br>proposed device in<br>comparison with<br>our chosen |
| Item | Proposed device | Predicate device | Comparison | |
| | ⑤Visibility under<br>endoscopy,<br>⑥Electric<br>performance,<br>⑦Operation<br>flexibility,<br>⑧Rotation<br>performance; | | predicate. All the<br>test results show<br>that the proposed<br>device is<br>substantial<br>equivalence with<br>the predicate. For<br>bench tests<br>reports, please<br>refer to Section 18<br>of this submission. | |
| | Connected firmly:<br>ensure the device does<br>not cause device<br>breakage or<br>detachment between<br>joints. | Connected firmly: ensure<br>the device does not cause<br>device breakage or<br>detachment between joints. | Substantial<br>equivalence.<br>We conducted<br>Connected firmly<br>on our proposed<br>device in<br>comparison with<br>our chosen<br>predicate. All the<br>test results show<br>that the proposed<br>device is safer<br>than our predicate<br>device. For bench<br>tests reports,<br>please refer to<br>Section 18 of this<br>submission. | |
| | Force to Bow | Force to Bow | Substantial<br>equivalence.<br>We conducted<br>Force to Bow on<br>our proposed<br>device in<br>comparison with<br>our chosen<br>predicate. All the<br>test results show<br>that the proposed<br>device is as safe | |
| Item | Proposed device | Predicate device | Comparison | |
| | | | and effective as<br>our predicate<br>device. For bench<br>tests reports,<br>please refer to<br>Section 18 of this<br>submission. | |
| | Orientation of Cutting<br>Wire and Visualization<br>of Cutting Wire<br>testing: ensure for<br>orientation and<br>visualization of the<br>cutting wire when<br>endoscopically<br>viewed. | Orientation of Cutting Wire<br>and Visualization of Cutting<br>Wire: ensure for orientation<br>and visualization of the<br>cutting wire when<br>endoscopically viewed. | Substantial<br>equivalence.<br>We conducted<br>Orientation of<br>Cutting Wire and<br>Visualization of<br>Cutting Wire on<br>our proposed<br>device in<br>comparison with<br>our chosen<br>predicate. All the<br>test results show<br>that the proposed<br>device is as safe<br>and effective as<br>our predicate<br>device. For bench<br>tests reports,<br>please refer to<br>Section 18 of this<br>submission. | |
| | Ink Validation testing:<br>ensure for ink marking<br>visualization when<br>endoscopically<br>viewed. | Ink visualization: ensure for<br>ink marking visualization<br>when endoscopically<br>viewed. | Substantial<br>equivalence.<br>We conducted Ink<br>visualization on<br>our proposed<br>device in<br>comparison with<br>our chosen<br>predicate. All the<br>test results show<br>that the proposed<br>device is as safe | |
| Item | Proposed device | Predicate device | Comparison | |
| | | | and effective as<br>our predicate<br>device. For bench<br>tests reports,<br>please refer to<br>Section 18 of this<br>submission. | |
| | Fluoroscopic Visibility<br>testing: ensure the end<br>user is able to<br>fluoroscopically<br>visualize the location<br>of the<br>sphincterotome. | Fluoroscopic Visibility:<br>ensure the end user is able<br>to fluoroscopically<br>visualize the location of<br>the sphincterotome. | Substantial<br>equivalence.<br>We conducted<br>Fluoroscopic<br>Visibility on our<br>proposed device in<br>comparison with<br>our chosen<br>predicate. All the<br>test results show<br>that the proposed<br>device is as safe<br>and effective as<br>our predicate<br>device. For bench<br>tests reports,<br>please refer to<br>Section 18 of this<br>submission. | |
| Biolo-<br>gical | Materials or<br>substances in<br>contact with<br>the same<br>human tissue<br>or body<br>fluids | Plastic PTFE,<br>Stainless Steel 304,<br>PET;<br>Silicone oil, PTFE,<br>Polyurethane, Medical<br>grade hydrophilic<br>coating; | No exact information. | Different.<br>Biocompatibility<br>tests have been<br>done for the<br>difference.<br>Biological risks<br>are acceptable. |
| | Biocompatibility | In Vitro Cytotoxicity<br>Test: ISO 10993-5:<br>2009;<br>Skin sensitization<br>Test: ISO 10993-10:<br>2010;<br>Intracutaneous<br>Reactivity Test: ISO | No exact information. | |
| Item | Proposed device | Predicate device | Comparison | |
| | 10993-10: 2010;<br>Acute Systemic<br>Toxicity Test: ISO<br>10993-11:2017;<br>Pyrogenicity: ISO<br>10993-11:2017; | | | |
| Single /<br>Use | Yes | Yes | Same | |
| Shelf /<br>life<br>and<br>sterili-<br>zation | Shelf life: 3 years<br>Sterilization: EO<br>Sterilization, SAL OF<br>10-6 | Shelf life: 3 years<br>Sterilization: EO<br>Sterilization | Same | |
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Image /page/7/Picture/1 description: The image shows a logo for AGS Medtech. The logo consists of a circular design with three curved shapes in blue and green. To the right of the circular design, the text "AGS MEDTECH" is written in a sans-serif font, followed by Chinese characters below it.
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K201121
Page 5 of 11
Image /page/8/Picture/1 description: The image shows the logo for AGS Medtech. The logo consists of a circular design with three curved shapes in blue and green. To the right of the circular design, the text "AGS MEDTECH" is written in English, followed by Chinese characters below it. The logo appears to be for a medical technology company.
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Image /page/9/Picture/0 description: The image shows the text 'K201121' on the first line and 'Page 6 of 11' on the second line. The text is in a simple, sans-serif font and is horizontally aligned. The text likely indicates a document identifier and page number within a larger document.
Image /page/9/Picture/1 description: The image contains a logo for AGS Medtech. The logo consists of a circular design with three curved shapes in blue and green. To the right of the circular design, the text "AGS MEDTECH" is written in English, followed by Chinese characters below it. The Chinese characters are likely the Chinese translation of "AGS MEDTECH".
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Image /page/10/Picture/0 description: The image shows a logo for AGS Medtech. The logo consists of a circular design with three blue teardrop shapes arranged in a triangle, with a green triangle in the center. To the right of the logo, the text "AGS MEDTECH" is written in English, followed by the Chinese characters "安杰思医学".
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Image /page/11/Picture/0 description: The image shows the logo for AGS Medtech. The logo consists of a blue circular design with three curved shapes inside, one of which is green. To the right of the circular design, the text "AGS MEDTECH" is written in English, followed by Chinese characters below it.
# Table 5.6-2 Comparison of technical characteristics
| Item | Proposed device | Predicate device | Comparison | |
|-------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common name | Sphincterotome | Needle knife | Similar | |
| Trade name | Sphincterotome | Huibregtse® | / | |
| Model number | 5099 | G24885/HPC-3 | / | |
| 510(k) submitter | Hangzhou AGS<br>MedTech Co., Ltd. | Wilson-Cook Medical, Inc. | Same | |
| 510(k) number | K201121 | K040981 | / | |
| Clinical Intended use | The Sphincterotome is<br>indicated for use in the<br>cannulation of the biliary<br>ducts and the<br>transendoscopic<br>sphincterotomy of the<br>Papilla of Vater and/or<br>the Spincter of Oddi. The<br>device is supplied sterile<br>and intended for single<br>use only. | The Wilson-Cook USW<br>Needleknife Papillotome is<br>intended for accessing the<br>common bile duct when<br>standard cannulation methods<br>have been exhausted. The<br>USW Needleknife Papillotome<br>is supplied sterile and intended<br>for single use only. | Same | |
| Item | Proposed device | Predicate device | Comparison | |
| Technical | Principles of<br>operation | Monopolar<br>Sphincterotome<br>manufactured is an<br>applied part of<br>electrosurgical generator,<br>using monopolar high-<br>frequency current<br>delivered by the<br>electrosurgical generator<br>for sphincterotomy with<br>the electrode. The high-<br>frequency electricity<br>flows from the active<br>electrode to the neutral<br>electrode placed on<br>patient skin. | Monopolar Sphincterotome<br>manufactured is an applied part<br>of electrosurgical generator,<br>using monopolar high-<br>frequency current delivered by<br>the electrosurgical generator<br>for sphincterotomy with the<br>electrode. The high-frequency<br>electricity flows from the<br>active electrode to the neutral<br>electrode placed on patient<br>skin. | Same |
| | Energy Use | Monopolar Radio<br>Frequency Current | Monopolar Radio Frequency<br>Current | Same |
| | Catheter Size | 2.4mm-1.8mm | 7Fr(2.33mm)-5Fr(1.67mm) | Same |
| | Wire Guide<br>Diameter | 0.63mm, 0.89mm | 0.035 (~0.89mm); | Similar |
| | Minimum<br>Accessory<br>Channel | 2.8mm | 2.8mm | Same |
| | Working<br>length | 1800mm | 2000mm | Similar |
| | Perform…
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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.