K213606 · EvoEndo, Inc. · FDS · Feb 14, 2022 · Gastroenterology, Urology
Device Facts
Record ID
K213606
Device Name
EvoEndo Single-Use Endoscopy System
Applicant
EvoEndo, Inc.
Product Code
FDS · Gastroenterology, Urology
Decision Date
Feb 14, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.1500
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The EvoEndo Model LE Gastroscope is intended for the visualization of the upper digestive tract in adults and pediatric patients, specifically for the observation, diagnosis, and endoscopic treatment of the esophagus, stomach, and duodenal bulb in patients over the age of five years. The gastroscope is a sterile single-use device and can be inserted orally or transnasally. The EvoEndo Controller is intended for use with an EvoEndo Endoscopic diagnosis, treatment, and video observation.
Device Story
System consists of sterile, single-use EvoEndo Model LE Gastroscope and EvoEndo Controller. Gastroscope features HD camera at distal tip, 4-way steering, and working channel for accessories; inserted orally or transnasally. Controller processes video/images from gastroscope and outputs to external medical-grade monitor via HDMI. Used in clinical settings by physicians for upper GI endoscopy. System enables visualization and diagnostic/therapeutic procedures; single-use design eliminates reprocessing requirements, reducing cross-contamination risk.
Clinical Evidence
No clinical data. Bench testing only, including visual, dimensional, functional, and transit simulation verification. Optical performance compared to predicate. Usability testing performed in simulated clinic-office setting using benchtop and animal models.
Technological Characteristics
Single-use flexible gastroscope; EO sterilized. Features 4-way steering, HD camera, air/water/suction lines. Controller provides image processing. Electrical safety/EMC per IEC 60601-1, IEC 60601-1-2, IEC 60601-2-18. Photobiological safety per IEC/TR 62471. Biocompatibility per ISO 10993-1.
Indications for Use
Indicated for visualization, observation, diagnosis, and treatment of the esophagus, stomach, and duodenal bulb in adults and pediatric patients over the age of five years.
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.
Predicate Devices
FUJINON MODEL EG-530N TRANS NASAL INSERTION (K063316)
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February 14, 2022
EvoEndo Inc % Isabella Schmitt Regulatory Affairs Consultant Proxima Clinical Research 2450 Holcombe Boulevard Houston, TX 77021
Re: K213606
> Trade/Device Name: EvoEndo Single-Use Endoscopy System Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: FDS, FET Dated: November 12, 2021 Received: November 15, 2021
Dear Isabella Schmitt:
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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 (OS) 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,
Shanil P. Haugen, Ph.D. 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
Enclosure
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## Indications for Use
510(k) Number (if known) 'K213606
Device Name EvoEndo Single-Use Endoscopy System
Indications for Use (Describe)
The EvoEndo Model LE Gastroscope is intended for the upper digestive tract in adults and pediativ patients, specifically for the observation, diagnosis treatment of the esophagus, stomach, and duodenal bulb in patients over the age of five years. The gastroscope is a sterile single-use device and can be inserted orally or transnasally.
The EvoEndo Controller is intended for use with an EvoEndo Endoscopic diagnosis, treament, and video observation.
| 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) |
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Image /page/3/Picture/0 description: The image shows the logo for Evoendo. The logo consists of a stylized letter 'e' formed by concentric circles in red and blue, followed by the word 'evoendo' in blue sans-serif font. The logo is simple and modern, with a focus on the company name.
# 3 510(k) Summary
| 510(k) Owner: | EvoEndo, Inc.<br>12649 East Caley Ave, Suite 116<br>Centennial, CO 80111 |
|------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Official Contact: | Heather Underwood, PhD<br>Telephone: +1 (303) 223-7445<br>E-mail: heather@evoendo.com |
| Representative Consultant Contact: | Isabella Schmitt<br>Proxima Clinical Research, Inc.<br>2450 Holcombe Blvd, Suite J<br>Houston, TX 77021<br>Telephone: +1 (404) 205-4653<br>E-mail: Isabella@ProximaCRO.com |
| Date Summary Prepared: | 12 November 2021 |
| Trade Name: | EvoEndo Single-Use Endoscopy System |
| Common Name: | Gastroscope and accessories, flexible / rigid<br>Endoscopic video imaging system /<br>component, Gastroenterology-Urology |
| Classification: | Class II |
| Classification Number: | 21 CFR 876.1500 |
| Product Code(s): | FDS, FET |
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Image /page/4/Picture/0 description: The image shows the logo for Evoendo. The logo consists of a stylized "e" symbol made up of two concentric circles, one red and one blue. To the right of the symbol is the word "evoendo" in blue, lowercase letters. The logo is simple and modern, with a focus on the company name.
Classification Advisory Committee:
Gastroenterology / Urology
Predicate Device(s):
FUJINON MODEL EG-530N TRANS NASAL INSERTION (K063316)
Boston Scientific EXALT Controller (K193202)
### Device Description:
The EvoEndo Endoscopy System is comprised of two regulated components:
- EvoEndo Model LE Single-Use Gastroscope (hereafter referred to as the EvoEndo Endoscope)
- EvoEndo Controller (hereafter referred to as the Controller) ●
The EvoEndo Endoscope is a sterile, single use gastroscope intended to perform oral or transnasal diagnostic endoscopy in adult and pediatric patients. The EvoEndo Endoscope is ethylene oxide (EO) sterilized and is comprised of:
- o Handle
- Umbilical Bundle that includes air, water, and suction lines, as well as the video connector ●
- Endoscope shaft with HD Camera ●
The Controller of the EvoEndo Endoscopy System translates the images or video captured by the camera at the distal end of the EvoEndo Endoscope to a monitor via an HDMI cable.
### Intended Use / Indications for Use:
The EvoEndo Model LE Gastroscope is intended for the visualization of the upper digestive tract in adults and pediatric patients, specifically for the observation, diagnosis, and endoscopic treatment of the esophagus, stomach, and duodenal bulb in patients over the age of five years. The gastroscope is a sterile single-use device and can be inserted orally or transnasally.
The EvoEndo Controller is intended for use with an EvoEndo Endoscopic diagnosis, treatment, and video observation.
### Technological Characteristics:
The EvoEndo Endoscope allows for oral or transnasal insertion and visualization of the esophagus, stomach, and duodenal bulb in both pediatric and adult patients due to its small outer diameter, working channel compatible with standard accessories, and over 1 m working length. The proximal handle on the EvoEndo Endoscope allows physicians to control the distal tip of the EvoEndo Endoscope with 4-way steering as well as buttons for AWS activation and image and video capture and adjustment. The Controller is intended for video and image processing and translates the
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Image /page/5/Picture/1 description: The image shows the logo for "evoendo". The logo consists of a circular graphic to the left of the text. The graphic is made up of three concentric circles, with the innermost circle being blue, the middle circle being red, and the outermost circle being blue. The text "evoendo" is written in a sans-serif font and is blue.
images or video captured by the HD camera at the distal end of the EvoEndo Endoscope via an HDMI cable to a Medical-Grade Monitor (not included with system).
#### Biocompatibility Testing:
Cytotoxicity, sensitization, acute systemic toxicity, and material-mediated pyrogenicity testing was performed per ISO 10993-1 and the FDA Guidance for Industry and FDA Staff, "Use of International Standard ISO 10993-1, 'Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process." There were no cytotoxicity, sensitization, irritation, acute systemic toxicity, or material-mediated pyrogenicity concerns associated with the EvoEndo Endoscopy System.
#### Sterilization Validation:
The EvoEndo Endoscope is packaged individually, provided sterile, labeled for single use only, and sterilized using 100% ethylene oxide (EO) gas in a fixed chamber. Validation performed for the sterilization technique met all acceptance criteria. Functional testing confirmed that sterilization did not impact product safety or effectiveness.
#### Electrical Safety and EMC Testing:
The Electrical Safety (ES) and Electromagnetic Compatibility (EMC) testing conformed to IEC 60601-1:2005/(R)2012 and A1:2012, IEC 60601-1-2:2014, and IEC 60601-2-18:2009. All acceptance criteria were met.
#### Software Testing:
The firmware used in the EvoEndo Controller has been determined to be a moderate level of concern. The software in the controller consisting of 6 embedded firmware items is considered off-the-shelf software and, as such, is documented in accordance with the FDA Guidance "Off-The-Shelf Software Use in Medical Devices" (Sep 27, 2019).
#### Bench Performance Testing:
Visual, dimensional, functional, and transit simulation verification testing was performed on final sterilized EvoEndo Endoscopes. The testing sample size was selected to achieve the % confidence / % reliability ratio predetermined for each specification being tested. In functional testing, devices were verified for camera and video control unit functioning; tip deflection; air, water, and suction flow rates; functionality with accessory device; functionality after 360° bend shaft orientation; functionality with simulated repeated use; and post simulated use functionality. The maximum bending angle of the device in each direction is shown in the table below. The deflection achieved with the EvoEndo Endoscope is consistent with that of the identified predicate device in all directions, indicating substantial equivalence.
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Image /page/6/Picture/1 description: The image shows the logo for "evoendo". The logo consists of a circular graphic on the left and the word "evoendo" on the right. The circular graphic is made up of two concentric circles, one red and one blue, with a stylized "e" in the center. The word "evoendo" is written in a sans-serif font, with the letters in blue.
| Table 1: Deflection of EvoEndo Endoscope | |
|------------------------------------------|-----------------------|
| Deflection Direction | Maximum Bending Angle |
| Up | 210° |
| Down | 90° |
| Left | 100° |
| Right | 100° |
| | Table 1: Deflection of EvoEndo Endoscope | | |
|--|------------------------------------------|--|--|
|--|------------------------------------------|--|--|
In transit simulation test units underwent environmental conditioning, distribution simulation, and packaging testing to confirm the integrity of the sterile barrier and functionality of the device under expected transportation conditions. The EvoEndo Endoscopy System met acceptance criteria set for all verification testing procedures.
Optical performance testing was performed on the EvoEndo Endoscope and compared to the predicate device. The testing evaluated the resolution, depth of field, geometric distortion, image intensity uniformity, and color performance of the endoscope. The test results suggest equivalent performance across all metrics assessed, demonstrating substantial equivalence between the EvoEndo Endoscope and the predicate device.
Photobiological safety testing was performed per FDA recognized consensus standard IEC/TR 62471 First Edition 2006-07: Photobiological safety of lamps and lamp systems. Based on the measured output of the EvoEndo's light source, it was deemed to be below the limits of the exempt risk group.
### Human Factors / Usability Engineering Testing:
EvoEndo conducted a two-stage usability study of representative intended users. The study assessed the overall usability of the EvoEndo Endoscopy System and the ability for users to perform critical tasks. Participants were asked to perform the entire workflow of the device across a benchtop model session and a representative animal model session with prior training provided. Tests were performed in a simulated clinic-office setting. Throughout the procedure, there were no significant device or user malfunctions or errors that would result in patient harm during an actual procedure.
#### Animal Testing:
Animal testing was not required for this device.
#### Clinical Testing:
Clinical testing was not required for this device.
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Image /page/7/Picture/1 description: The image shows the logo for "evoendo". The logo consists of a circular design on the left, made up of two intertwined circles in red and blue. To the right of the circular design is the word "evoendo" in blue, with a sans-serif font.
#### Conclusion:
In conclusion, the EvoEndo Single-Use Endoscopy System is demonstrated to be as safe and effective and perform as well as the identified predicate devices. The EvoEndo Endoscope and Controller have the same intended use, indication, technological characteristics, and principles of operation as the respective predicates. Any differences between the EvoEndo Endoscopy System and the predicate devices do not alter the intended use of the device and do not raise new or different questions regarding its safety and effectiveness when use as labelled. Verification and usability testing demonstrate that the device performs as intended. Thus, the EvoEndo Endoscopy System is substantially equivalent to the identified predicate devices.
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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.
