The Smoke Evacuation Button Switch Pencil and Telescoping Smoke Evacuation Button Switch Pencil are intended for general electrosurgical applications, including cutting and coagulation, and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. The Pencil enables the operator to remotely conduct an electrosurgical current from the output connector of an electrosurgical unit to the operative site for the desired surgical effect.
Device Story
Electrosurgical accessory consisting of a handheld pencil with integrated smoke collection tube and replaceable electrode; connects to electrosurgical generator and smoke evacuation system. Operator uses button switches on pencil to remotely conduct electrosurgical current to operative site for cutting/coagulation while simultaneously evacuating surgical smoke. Used in clinical surgical settings. Single-use, sterile device. Benefits include reduced surgical smoke exposure for staff and precise delivery of electrosurgical energy.
Clinical Evidence
Bench testing only. No clinical data. Compliance demonstrated with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2, ISO 10993-1, ISO 11607-1, and ASTM D4169. Additional performance testing included mechanical integrity, activation force, switch resistance, strain relief, and pull-out force testing.
Technological Characteristics
Monopolar electrosurgical pencil with integrated smoke evacuation tube. Features button-style activation switch. Available in simplified (round/oval housing) and premium (extender mechanism) series. Single-use, sterile. Complies with IEC 60601-1, IEC 60601-1-2, and IEC 60601-2-2 standards.
Indications for Use
Indicated for general electrosurgical cutting and coagulation and smoke removal during surgery. Used by clinicians in conjunction with electrosurgical generators and smoke evacuation systems.
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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Image /page/0/Picture/0 description: The image shows 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 consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, and then the word "ADMINISTRATION" in a smaller font size below that.
November 20, 2020
New Deantronics Taiwan Ltd. % Mr. Craig Coombs President Coombs Medical Device Consulting, Inc. 1100 Pacific Marina, Suite 806 Alameda, California 94501
Re: K202962
Trade/Device Name: Smoke Evacuation Button Switch Pencil and Telescopic Smoke Evacuation Button Switch Pencil.
Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: September 29, 2020 Received: September 30, 2020
Dear Mr. Coombs:
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.
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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 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 mediation-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.
Long Chen, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K202962
#### Device Name
Smoke Evacuation Button Switch Pencil and Telescopic Smoke Evacuation Button Switch Pencil
#### Indications for Use (Describe)
The Smoke Evacuation Button Switch Pencil and Telescoping Smoke Evacuation Switch Pencil are intended for general electrosurgical applications, including cutting and coagulation, and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. The Pencil enables the operator to remotely conduct an electrosurgical current from the output connector of an electrosurgical unit to the operative site for the desired surgical effect.
| 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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Image /page/3/Picture/0 description: The image contains the logo for "NEW DEANTRONICS". The word "NEW" is in black outlined in blue. To the right of the word "NEW" is a blue circle with a red dot in the center. The word "DEANTRONICS" is in blue and to the right of the circle.
# K202962 510(k) Summary
# A. Device Information:
| Category | Comments |
|------------------------------------------|-----------------------------------------------------------------------------------------------|
| Sponsor: | New Deantronics Taiwan Ltd. |
| | 12F., No.51, Sec. 4, Zhongyang Rd., |
| | Tucheng District |
| | New Taipei City 236, |
| | Taiwan. |
| | Tel: (886) 2-2268-1726 |
| | Fax: (886) 2-2268-3800 |
| | Sponsor Contact: Ms. Jane Liu, President |
| | Email: jane@newdean.com.tw |
| | Correspondent Contact<br>Information: |
| President | |
| Coombs Medical Device Consulting | |
| 1100 Pacific Marina, Suite 806 | |
| Alameda, CA 94501 | |
| Tel: 510-995-8499 | |
| Email: CraigJCoombs@gmail.com | |
| Device Common Name: | Electrosurgical Accessory - Electrode |
| Device Classification Number: | 21 CFR 878.4400 |
| Device Classification &<br>Product Code: | Class II,<br>GEI |
| Device Proprietary Name: | Smoke Evacuation Button Switch Pencil and<br>Telescopic Smoke Evacuation Button Switch Pencil |
# Predicate Device Information:
| Predicate Device: | Smoke Evacuation Rocker Switch Pencil<br>and<br>Telescoping Smoke Evacuation Rocker<br>Switch Pencil |
|----------------------------------------------------|------------------------------------------------------------------------------------------------------|
| Predicate Device Manufacturer: | Covidien (formerly Valleylab, Inc.) |
| Predicate Device Common Name: | Electrosurgical Accessory - Electrode |
| Predicate Device Premarket Notification # | K182772 |
| Predicate Device Classification: | 21 CFR 878.4400<br>Electrosurgical, Cutting & Coagulation<br>Device and Accessories |
| Predicate Device Classification &<br>Product Code: | Class 2,<br>GEI |
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Image /page/4/Picture/0 description: The image shows the logo for New Deantronics. The word "NEW" is in blue, and the word "DEANTRONICS" is in dark blue. There is a blue circle with a red dot in the middle between the two words. The logo is simple and clean.
# B. Date Summary Prepared
16 November 2020
# C. Description of Device
The application devices, the Smoke Evacuation Button Switch Pencil and the Telescopic Smoke Evacuation Button Switch Pencil (referred to hereafter as the Smoke Evaluation Pencils), are a collection of electrosurgical electrodes with an integrated smoke collection tube. The flat blade electrode provided in each pencil can be removed and replaced with a compatible electrode.
New Deantronics is requesting clearance two series Smoke Evacuation Pencils.
The simplified series includes two different housing styles (round and oval) of pencil body design. Each housing style has two different lengths of attached tubing at the proximal end of the pencil body, 10ft and 15ft; thus, there are 4 models in this and the premium series. These 4 simplified series models share the same design elements (functional design, technology design, packaging, sterilization method and process, etc.)
The premium series embodies one of two extender mechanisms. There are 2 smoke nozzle extender/fixation mechanism designs in this series; with and without lock mechanism. Each design includes two lengths of spiral tube and cable, while all the other design elements, such as cosmetic appearance, grip characteristics, construction materials, packaging, sterilization method, etc., are identical in this premium series to the simplified series.
The Smoke Evacuation Pencils are designed to be used with a compatible electrosurgical generator and smoke evacuation system.
These devices are single use and are sold sterile.
# D. Indications for Use
The Smoke Evacuation Button Switch Pencil and Telescoping Smoke Evacuation Button Switch Pencil are intended for general electrosurgical applications, including cutting and coagulation, and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. The Pencil enables the operator to remotely conduct an electrosurgical current from the output connector of an electrosurgical unit to the operative site for the desired surgical effect.
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Image /page/5/Picture/1 description: The image shows the logo for New Deantronics. The word "NEW" is in black font on the left side of the logo. To the right of the word "NEW" is a blue circle with a red dot in the center. The word "DEANTRONICS" is in blue font on the right side of the logo.
# E. Comparison to Predicate Device
The application Smoke Evacuation Pencils and the predicate devices
| Same | Indications for Use FDA Product Code Electrosurgical Monopolar Energy Operation Principle Compatible Device Maximum Allowable Voltage Replaceable Coated Electrode Ex-vivo Monopolar Thermal Effect Sterilization Method Single Use |
|-----------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Different | Physical Dimensions Construction Materials Activation Switch Type Electrode Coating Extendable Smoke Nozzle Fixation Mechanism |
None of the differences raised new questions of safety or effectiveness. New Deantronics concludes the devices are substantially equivalent.
# F. Summary of Supporting Data
The application Smoke Evacuation Pencils were tested and found to be in compliance with the pertinent portions of the following standards:
| Standards<br>Body & # | Standard Name | Standard<br>Version |
|-----------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|
| IEC 60601-1 | Medical electrical equipment - Part 1: General requirements for basic<br>safety and essential performance | 2005 + AMD1:2012 |
| IEC 60601-1-2 | Medical electrical equipment – Part 1-2: General requirements for basic<br>safety and essential performance – Collateral Standard:<br>Electromagnetic disturbances – Requirements and tests | 2014 |
| IEC 60601-2-2 | Medical electrical equipment –Part 2-2: Particular requirements for the<br>safety of high frequency surgical equipment | 2017 |
| ISO 10993-1 | Biological Evaluation of Medical Devices – Part 1: Evaluation and testing<br>within a risk management process. | 2018 |
| ISO 11607-1 | Packaging for terminally sterilized medical devices – Part 1:<br>Requirements for materials, sterile barrier systems and packaging<br>systems; | 2019 |
| ASTM D4169 | Standard Practice for Performance Testing of Shipping Containers and<br>Systems | 2016 |
The Smoke Evacuation Pencil was fully tested and in compliance with the FDA guideline Premarket Notification (510(k)) Submissions for Electrosurqical Devices for General Surgery: Guidance for Industry and Food and Drug Administration Staff (9 March 2020).
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Image /page/6/Picture/1 description: The image shows the logo for New Deantronics. The word "NEW" is in a sans-serif font and is in a light blue color. To the right of the word "NEW" is a blue circle with a red dot in the center. To the right of the circle is the word "DEANTRONICS" in a bold, sans-serif font and is in a dark blue color.
Additional performance testing, outside of that described in the standards and guidelines described above, included:
| Additional Performance Test Item |
|---------------------------------------------------------------------------|
| Button Activation Force |
| Continuity & Activation switch resistance |
| Button activation over time |
| Continuity & Activation switch resistance |
| Activation over time |
| Electrode insertion/extraction force and electrode heat shrink inspection |
| Plug insertion/extraction force |
| Dynamic strain relief |
| Static strain relief |
| Adapter insertion/extraction force |
| Smoke tube-cable exit separation force |
| Smoke tube separation force |
| Nozzle extension/retraction force |
| Snap fit strength |
| Weld integrity test |
| Button retention force |
| Smoke tube linear force rupture |
| Smoke nozzle pull-out force |
| Electrode Wobble |
# G. Conclusion
After comparing the Indications for Use, technology and design of the Smoke Evacuation Pencils, along with all electrical safety (including IEC 60601-1: 2005 + AM1:2012; IEC 60601-1-2: 2014; IEC 60601-2-2: 2017) and performance testing, in accordance with the FDA's guidelines and FDA-recognized consensus standards for electrical safety, New Deantronics concludes that the Smoke Evacuation Button Switch Pencil and Telescoping Smoke Evacuation Button Switch Pencil are substantially equivalent to the predicate Covidien (ValleyLab) Smoke Evacuation Rocker Switch Pencil and the Telescoping Smoke Evacuation Rocker Switch Pencil (K182772).
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1. Search: exact and fuzzy
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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.
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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.
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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.
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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.