K170667 · Carl Zeiss Meditec, AG · GWG · Aug 18, 2017 · Neurology
Device Facts
Record ID
K170667
Device Name
QEVO System with KINEVO 900
Applicant
Carl Zeiss Meditec, AG
Product Code
GWG · Neurology
Decision Date
Aug 18, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1480
Device Class
Class 2
Indications for Use
The QEVO System with KINEVO 900 is intended for viewing internal surgical sites during general surgical procedures and for use in visualization of ventricles and structures within the brain during neurological surgical procedures as well as for viewing internal surgical sites during anterior and posterior spinal procedures, such as nucleotomy, discectomy, and foraminotomy.
Device Story
QEVO System with KINEVO 900 is a reusable neurological endoscope system. Input: optical images of internal surgical sites captured via rigid rod lenses and CMOS sensor in the endoscope main body. Transformation: light transmitted through insertion tube via fiber optics; images processed by QEVO Endoscope Control Unit (ECU) and displayed on an external monitor. Used in OR by surgeons/assistants during neurological and spinal procedures (e.g., nucleotomy, discectomy, foraminotomy). KINEVO 900 microscope provides standard optical visualization; QEVO endoscope provides additional endoscopic views. Output: 2D video feed on external monitor. Benefit: enhanced visualization of surgical anatomy to assist clinical decision-making during surgery.
Clinical Evidence
No clinical data. Substantial equivalence established via bench testing, including design verification, optical safety (IEC 62471), thermal safety (IEC 60601-1), electrical safety (IEC 60601-1, IEC 60601-2-18), and electromagnetic compatibility (IEC 60601-1-2).
Technological Characteristics
Reusable rigid endoscope with 3.6mm diameter insertion tube. Sensing: CMOS imaging sensor. Light source: Integrated adjustable LED. Connectivity: HDMI/DVI and Ethernet to ECU. Sterilization: Steam sterilization (SAL 10^-6). Compliance: IEC 60601-1, IEC 60601-2-18, IEC 60601-1-2, IEC 62471. Biocompatibility: ISO 10993.
Indications for Use
Indicated for patients undergoing general, neurological, or spinal surgical procedures requiring visualization of internal surgical sites, ventricles, or brain structures.
Regulatory Classification
Identification
A neurological endoscope is an instrument with a light source used to view the inside of the ventricles of the brain.
Predicate Devices
VSII Visionsense Stereoscopic Vision System (K082355)
Submission Summary (Full Text)
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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
Carl Zeiss Meditec Ag % Calley Herzog Senior Consultant Biologics Consulting 400 N. Washington St. Suite 100 Alexandria, Virginia 22314
Re: K170667
Trade/Device Name: QEVO System with KINEVO 900 Regulation Number: 21 CFR 882.1480 Regulation Name: Neurological Endoscope Regulatory Class: Class II Product Code: GWG Dated: July 18, 2017 Received: July 19, 2017
Dear Calley Herzog:
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. Iisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device
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related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 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,
Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## 510(K) SUMMARY
In accordance with 21 CFR 807.87(h) and (21 CFR 807.92) the 510(k) Summary for the QEVO System with KINEVO 900 is provided below.
| Device Common Name: | Neurological endoscope |
|----------------------------|-----------------------------------------------------------------------------------------------------------------------|
| Device Trade Name: | QEVO System with KINEVO 900 |
| Applicant: | Carl Zeiss Meditec AG<br>Goeschwizer Strasse 51-52<br>D-07745 Jena<br>Germany |
| Contact: | Dr. Christian Muenster<br>Director Regulatory and Clinical Affairs<br>+49 7364 206985<br>christian.muenster@zeiss.com |
| Prepared by: | Calley Herzog<br>Biologics Consulting Group, Inc.<br>(720) 883-3633<br>cherzog@biologicsconsulting.com |
| Date Prepared: | August 11, 2017 |
| Classification Regulation: | 882.1480, Class II |
| Classification Name: | Neurological endoscope |
| Panel: | Neurology |
| Primary Product Code: | GWG |
| Predicate Device: | VSII Visionsense Stereoscopic Vision System (K082355 |
#### Indication for Use:
The QEVO System with KINEVO 900 is intended for viewing internal surgical sites during general surgical procedures and for use in visualization of ventricles and structures within the brain during neurological surgical procedures as well as for viewing internal surgical sites during anterior and posterior spinal procedures, such as nucleotomy, discectomy, and foraminotomy.
#### Device Description:
The subject device is a system used for viewing internal surgical sites during surgical procedures. The system consists of the following components:
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- . QEVO System - QEVO Endoscope Control Unit (ECU) + QEVO endoscope
- KINEVO 900 surgical microscope .
The KINEVO 900 can be operated by the surgeon and surgical assistant as a standard optical surgical microscope, using tubes and evepieces to view the surgical anatomy. When used with the QEVO System, the KINEVO 900 provides the additional capability to view images from the hand-held QEVO endoscope during neurological and spinal procedures.
The KINEVO 900 is physically connected (via power cable, HDMI/DVI cable, and Ethernet cable) to the QEVO Endoscope Control Unit (ECU). The QEVO endoscope plugs into the QEVO ECU outlet provided on the KINEVO 900.
#### Non-Clinical Testing
#### Sterilization:
The steam sterilization process was validated to achieve a sterility assurance level (SAL) of 10°.
#### Biocompatibility:
The only patient contacting component of the subject device is the Insertion tube. The contact category for this component is Tissue/Bone/Dentin Communicating, < 24 hours. The materials were testing in accordance with ISO 10993.
#### Performance Data:
The following performance testing is provided to support the substantial equivalence of the subject device:
- Design Verification Testing The purpose of the design verification is to demonstrate . that the system complies with the established system requirements.
- Optical Safety The OEVO Endoscope and ECU were assessed for conformity with the . relevant requirements of IEC 62471:2006: Photobiological safety of lamps and lamp systems and were found to comply.
- Thermal Safety When operated in intermittent mode, the maximum temperature of the . QEVO endoscope did not exceed the limits established in IEC 60601-1.
#### Software Documentation:
Software documentation for a MODERATE Level of Concern device is provided in support of the subject device.
### Electrical Safety Testing:
The QEVO endoscope, ECU, and cables were assessed for conformity with the relevant requirements of IEC 60601-1: 2005 + CORR. 1:2006 + CORR. 2:2007 + AM1:2012 (Edition 3.1, including the US deviations) and were found to comply.
The QEVO endoscope and ECU were assessed for conformity with the relevant requirements of IEC 60601-2-18:2009 (3rd edition): Particular requirements for the basic safety and essential performance of endoscopic equipment and were found to comply.
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## Electromagnetic Compatibility Testing:
The QEVO endoscope, ECU, and cables were assessed for conformity with the relevant requirements of IEC 60601-1-2 (4th Edition) and was found to comply.
#### Standards:
The table below provides the complete list of standards that are used in the 510(k) to establish device performance and support substantial equivalence:
| Standards<br>Organization | Standards<br>Number | Standard Title | Standard<br>Version/Date |
|---------------------------|---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------|
| AAMI ANSI | 60601-1 | Medical electrical equipment - Part 1: General<br>requirements for basic safety and essential<br>performance | 2005 |
| IEC | 60601-2-18 | Medical electrical equipment<br>Part 2: Particular requirements for the basic safety<br>and essential performance of endoscopic equipment | Ed. 3 / 2009 |
| IEC | 60601-1-2 | Medical electrical equipment - Part 1-2: General<br>requirements for basic safety and essential<br>performance - Collateral standard: Electromagnetic<br>compatibility - Requirements and tests | Ed. 4 / 2014 |
| IEC | 62471 | Photobiological safety of lamps and lamp systems | Ed. 1 /2006 |
| AAMI / ANSI /<br>ISO | 17665-1 | Sterilization of health care products -- moist heat --<br>part 1: requirements for the development, validation,<br>and routine control of a sterilization process for<br>medical devices | 2006 / (R)2013 |
| ANSI/AAMI | ST81 | sterilization of medical devices - information to be<br>provided by the manufacturer for the processing of<br>resterilizable medical devices | 2004/(R)2010 |
| ANSI/AAMI | ST79 | Comprehensive guide to steam sterilization and<br>sterility assurance in health care facilities | 2010/A1:2010/A2:2011<br>/A3:2012/A4:2013/(R)2<br>014 |
| AAMI ANSI<br>ISO | 10993-1 | Biological evaluation of medical devices -- Part 1:<br>Evaluation and testing within a risk management<br>process | 2009 |
| AAMI ANSI<br>ISO | 10993-5 | Biological evaluation of<br>medical devices - Part 5: Tests for in vitro<br>cytotoxicity | 2009 |
| AAMI ANSI<br>ISO | 10993-10 | Biological evaluation of medical devices - Part 10:<br>Tests for irritation and skin sensitization | 2010 |
| AAMI ANSI<br>ISO | 10993-11 | Biological evaluation of medical devices - Part 11:<br>Tests for systemic toxicity | 2006 |
## Clinical Testing
Not applicable. Clinical studies are not necessary to establish the substantial equivalence of this device.
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# Substantial Equivalence Discussion
The predicate device is the previously cleared VSII Visionsense Stereoscopic Vision System (K082355). A detailed comparison of the subject device to the predicate device can be found in the table below.
| Attribute | Subject Device | Predicate Device |
|----------------------------------------------|-------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------|
| Manufacturer | Carl Zeiss Meditec AG | VISIONSENSE, LTD. |
| 510(k) Number | TBD | K082355 |
| Device Name | KINEVO 900 with QEVO System | VisionSense VSII |
| Classification<br>Regulation<br>Product Code | 882.1480, Class II<br>Neurological endoscope<br>GWG | 888.1100, Class II<br>Arthroscope<br>HRX<br>882.1480, Class II<br>Neurological endoscope<br>GWG |
| System<br>Components | Rigid endoscope, ECU | Rigid endoscope, ECU |
| Light<br>Transmission | Light source in endoscope main<br>body, light transmission through<br>insertion tube via fiber optics | Light source in endoscope main body, light<br>transmission through insertion tube via<br>fiber optics |
| Light Source | Integrated LED (intensity<br>adjustable) | Integrated LED (intensity adjustable) |
| Image<br>Transmission | Rigid rod lenses + CMOS imaging<br>sensor in endoscope main body | CCD imaging sensor at distal tip |
| Direction of<br>View | 45° | 0-70° |
| Field of View | 100° | 70° |
| Depth of Field | 5-30mm | 7-30mm |
| Image<br>Resolution | 2 Mega Pixel (Full HD imager) | 2 Mega Pixel (Full HD imager) |
| | 642 TV lines (optical resolution at<br>15% MTF) | N/A (optical resolution) |
| Image Display | External monitor | External monitor |
| 2D / 3D<br>Imaging | 2D Only | 2D & 3D |
| Recording | Via USB-port | Via USB-port |
| Attribute | Subject Device | Predicate Device |
| Insertion Tube<br>Working<br>Length | 120mm | 175mm |
| Insertion Tube<br>Outer<br>Diameter | 3.6mm | 4mm |
| Single Use/<br>Reusable | Reusable | Reusable |
| Reprocessing | Manual and automated cleaning,<br>steam sterilization | Manual cleaning, sterilization |
| Electrical<br>Safety | IEC60601-1, IEC60601-1-2 and<br>IEC60601-2-18 compliant | IEC60601-1, IEC60601-1-2 and<br>IEC60601-2-18 compliant |
#### Device Comparison Table
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#### Substantial Equivalence Conclusion
The subject device and predicate device have the same intended use, for viewing internal surgical sites during general surgical procedures.
The specifications and functionality of the subject device is similar to the predicate devices. Any differences between the devices do not raise new questions of safety and effectiveness. Performance testing demonstrated that the device meets its specifications and intended uses. Therefore, the subject device can be found substantially equivalent to the Visionsense VSII as cleared in K082355.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.