K171625 · Willian A. Cook Australia Pty, Ltd. · MQE · Jan 12, 2018 · Obstetrics/Gynecology
Device Facts
Record ID
K171625
Device Name
Single Lumen Ovum Aspiration Needles
Applicant
Willian A. Cook Australia Pty, Ltd.
Product Code
MQE · Obstetrics/Gynecology
Decision Date
Jan 12, 2018
Decision
SESE
Submission Type
Special
Regulation
21 CFR 884.6100
Device Class
Class 2
Indications for Use
The Single Lumen Ovum Aspiration Needles are used for laparoscopic or ultrasound guided transvaginal aspiration and flushing of oocytes from ovarian follicles for patients undergoing Assisted Reproductive procedures.
Device Story
Single Lumen Ovum Aspiration Needles are sterile, single-use devices used for oocyte retrieval. The device consists of a stainless-steel needle with an echogenic tip for ultrasound visualization, a manipulating handle, and FEP or PTFE tubing connected to a silicone stopper. The stopper fits into a 14mL test tube, which serves as a collection reservoir. The device is connected to an external vacuum pump to provide aspiration suction. Used in clinical settings by physicians during assisted reproductive procedures, the needle is guided transvaginally or laparoscopically into ovarian follicles. The aspiration process allows for the collection of oocytes for further laboratory processing. The device facilitates oocyte retrieval, which is a critical step in assisted reproduction, potentially benefiting patients by enabling fertilization procedures.
Clinical Evidence
Bench testing only. Testing included biocompatibility (ISO 10993-5, -10), Mouse Embryo Assay (≥80% development to blastocyst at 72 hours), endotoxin testing (USP <85>, <20 EU/Device), and mechanical performance testing (leak, tensile strength, needle stiffness). Stability testing confirmed performance after three years of aging.
Technological Characteristics
Stainless-steel needle (16-21 gauge, 25-35 cm length) with echogenic tip. Tubing materials: FEP and PTFE. Stopper: Silicone. Connectivity: Luer lock to vacuum pump. Sterile, single-use. Mechanical operation via external vacuum source. No software or electronic components.
Indications for Use
Indicated for patients undergoing Assisted Reproductive procedures requiring laparoscopic or ultrasound-guided transvaginal aspiration and flushing of oocytes from ovarian follicles.
Regulatory Classification
Identification
Assisted reproduction needles are devices used in in vitro fertilization (IVF), gamete intrafallopian transfer (GIFT), or other assisted reproduction procedures to obtain gametes from the body or introduce gametes, zygote(s), preembryo(s) and/or embryo(s) into the body. This generic type of device may include a single or double lumen needle and component parts, including needle guides, such as those used with ultrasound.
Special Controls
*Classification.* Class II (special controls) (mouse embryo assay information, endotoxin testing, sterilization validation, design specifications, labeling requirements, biocompatibility testing, and clinical testing).
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January 12, 2018
Willian A. Cook Australia Pty. Ltd. Gordana Pozvek, Ph.D. Senior Regulatory Affairs Specialist 95 Brandl Street Eight Mile Plains, Queensland 4113 Australia
Re: K171625
Trade/Device Name: Single Lumen Ovum Aspiration Needles Regulation Number: 21 CFR§ 884.6100 Regulation Name: Assisted Reproduction Needles Regulatory Class: II Product Code: MOE Dated: December 12, 2017 Received: December 15, 2017
Dear Gordana Pozvek:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies.
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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); 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.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Charles Viviano -S
For Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known)
K171625
#### Device Name Single Lumen Ovum Aspiration Needles
Indications for Use (Describe)
The Single Lumen Ovum Aspiration Needles are used for laparoscopic or ultrasound guided transvaginal aspiration and flushing of oocytes from ovarian follicles for patients undergoing Assisted Reproductive procedures.
| 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)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
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K171625 Page 1 of 4
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WILLIAM A. COOK AUSTRALIA PTY. LTD. BRISBANE TECHNOLOGY PARK, EIGHT MILE PLAINS BRISBANE, QLD 4113, AUSTRALIA HONE: 1800.777.222 FAX: +61.7.3841 WWW.COOKMEDICA
# 510(k) Summary - K171625
#### SUBMITTED BY:
William A. Cook Australia Pty Ltd 95 Brandl Street Eight Mile Plains OLD 4113 Australia
| Contact Person: | Gordana Pozvek Ph.D. |
|-----------------|--------------------------------|
| Tel: | +61 (7) 3841 1188 |
| Fax: | +61 (7) 3841 3905 |
| E-mail: | Gordana.Pozvek@CookMedical.com |
#### Date Prepared: January 11, 2018
#### DEVICE IDENTIFICATION:
| Trade Name: | Single Lumen Ovum Aspiration Needles |
|-------------------|-----------------------------------------------|
| Common Name: | Oocyte Retrieval Needles |
| Regulation No: | 21 CFR 884.6100, Assisted Reproduction Needle |
| Regulatory Class: | II |
| Product Code: | MQE - Needle, Assisted Reproduction |
#### PREDICATE DEVICE:
Ovum Pick-Up Aspiration Needles (K983593)
The predicate device has not been subject to a design-related recall.
## DEVICE DESCRIPTION:
Single Lumen Ovum Aspiration Needles consist of a stainless-steel needle with a manipulating handle which may be connected to a fluorinated ethylene-propylene (FEP) or polytetrafluorethylene (PTFE) tube, which in turn is connected to a Silicone stopper (bung). The stopper has a Luer lock fitting directly to the stopper or connected to a length of tube to allow connection to a vacuum pump which provides aspiration suction. The stopper is placed in a 14mL test tube which acts as a collection reservoir. Needles are available in 16 to 21 gauge sizes and lengths from 25 to 35 cm. Needles have an echogenic tip that enhances the visualization of the needle tip under ultrasound.
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The Single Lumen Ovum Aspiration Needles are sterile and single-use devices.
| Product<br>codes | Needle<br>gauge | Needle<br>length<br>(cm) | Aspiration<br>Line (cm) | Vacuum<br>Line (cm) | Flushing<br>Line<br>(cm) | Bevel<br>Type |
|-------------------|--------------------------|--------------------------|-------------------------|---------------------|--------------------------|---------------|
| K-OPAA-<br>series | 17, 18, 20 | 35 | n/a | n/a | n/a | B |
| K-DOPU-<br>series | 17 | 28 or 35 | 60 or 90 | n/a | n/a | B |
| K-OPS-<br>series | 16, 17, 19,<br>20, or 21 | 28, 30, 33,<br>or 35 | 60 or 90 | n/a | n/a | A or B |
| K-OSN-<br>series | 16 or 17 | 25, 30, 33,<br>or 35 | 60 or 90 | 50 | n/a | A or B |
| K-IOPS-<br>series | 20 | 35 | 60 | 50 | n/a | A |
| K-UCI-<br>series | 16 or 17 | 30 or 35 | 60 | n/a | 60 | A |
The following needle series are included in this 510(k):
### INDICATIONS FOR USE:
The Single Lumen Ovum Aspiration Needles are used for laparoscopic or ultrasound guided transvaginal aspiration and flushing of oocytes from ovarian follicles for patients undergoing Assisted Reproductive procedures.
#### COMPARISON OF INTENDED USE AND TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE:
Single Lumen Ovum Aspiration Needles have similar Indications for Use as the predicate device (K983593). The intended use of the subject device is the same as the predicate device.
The Single Lumen Ovum Aspiration Needles are a modification of the Ovum Pick-up Aspiration Needles (K983593). The modifications are:
- The indications for use statement has been modified from the predicate device to include transvaginal ultrasound and laparoscopic approaches, both of which were specifically stated within cleared labeling for the legally marketed device. This modification to the Indication for Use statement does not impact safety and effectiveness of the device.
- Addition of a 21-gauge variant to the K-OPS Series needles. This modification provides a smaller gauge needle option. The 21-gauge variant has a 4 Fr aspiration tubing.
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- Addition of a 17 gauge, 30 cm guide needle. This modification provides a guide needle size suitable for the 20-gauge K-IOPS variant.
- The aspiration and flushing tubing has changed from Tetrafluoroethylene (NRT [TFE]) to Fluorinated Ethylene Propylene (NRT-FEP) and Polytetrafluoroethylene (NRT-PTFE).
The modifications listed above do not raise different questions of safety and effectiveness as compared to the predicate device.
### PERFORMANCE DATA:
To support the modifications to the subject device, the following design verification and validation activities were performed and summarized:
- Biocompatibility per ISO 10993-1:2009 ●
- o Cytotoxicity (ISO 10993-5:2009)
- Sensitization (ISO 10993-10:2010) o
- o Irritation (ISO 10993-10:2010)
- Mouse Embryo Assay Two cell mouse embryos were exposed to device extracts ● and cultured at 37°C in an atmosphere containing 5% CO2. The percent of embryos developed to the expanded blastocysts stage within 72 hours were assessed in comparison with the control group. The acceptance criteria for this test is ≥80% development to blastocyst at 72 hours.
- Endotoxin testing per USP <85> (< 20 EU/Device)
- Mechanical performance testing
- Negative pressure leak test o
- Tensile strength of the tubing to cannula O
- Tensile strength of the tubing to bung O
- Tensile strength of joint between cannula and handle O
- Tensile strength of 4 Fr tubing O
- Tensile strength of the joint between guide needle cannula and hub o
- o Needle stiffness
- Stability testing ●
- Negative pressure leak test after three years of aging O
- Tensile testing of joint between handle and needle cannula after three years of O aging
- Torque testing of joint between guide needle cannula and hub after three o vears of aging
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# CONCLUSION:
The results of the testing provided demonstrated that the Single Lumen Ovum Aspiration Needle is as safe and effective as the predicate device and supports a determination of substantial equivalence.
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.