FluidSmart

K172048 · Thermedx, LLC · HIG · Sep 5, 2017 · Obstetrics/Gynecology

Device Facts

Record IDK172048
Device NameFluidSmart
ApplicantThermedx, LLC
Product CodeHIG · Obstetrics/Gynecology
Decision DateSep 5, 2017
DecisionSESE
Submission TypeSpecial
Regulation21 CFR 884.1700
Device ClassClass 2

Intended Use

Intended for irrigation and fluid warming in laparoscopic procedures, and distention, fluid warming, and volume/deficit measurements in endoscopic procedures within gynecology, and orthopedic disciplines.

Device Story

FluidSmart is a rolling, electro-mechanical unit for endoscopic/laparoscopic procedures. It uses a peristaltic pump to pressurize irrigation fluids (saline, lactated ringer's, glycine, sterile water) and infrared heating for fluid warming. Input data includes temperature and pressure sensor readings, plus weight data from load cells on fluid bag hooks and suction canisters. A touch-screen processor provides closed-loop control, adjusting pump speed and warming power. Output includes warmed, pressurized fluid delivered to the surgical site and real-time fluid volume/deficit measurements. Used in OR settings by clinicians to maintain distention and irrigation; pressure relief valves in disposable tubing sets ensure safety. Benefits include precise fluid management and thermal regulation, aiding visualization and surgical outcomes.

Clinical Evidence

No clinical testing was conducted. Substantial equivalence is supported by non-clinical design verification testing, including software verification and tubing set verification.

Technological Characteristics

Electro-mechanical device; infrared fluid heating; peristaltic pump for pressure generation; touch-screen interface; closed-loop control system. Disposable tubing sets include spikes, clamps, warming cartridges, and luer locks with integrated pressure relief valves. Operates at pressures up to 300 mmHg.

Indications for Use

Indicated for irrigation, fluid warming, distention, and volume/deficit measurement during laparoscopic and endoscopic procedures in gynecology, urology, and orthopedic disciplines.

Regulatory Classification

Identification

A hysteroscopic insufflator is a device designed to distend the uterus by filling the uterine cavity with a liquid or gas to facilitate viewing with a hysteroscope.

Predicate Devices

Reference Devices

Related Devices

Submission Summary (Full Text)

{0}------------------------------------------------ Image /page/0/Picture/2 description: The image shows the address for the Food and Drug Administration. The address is 10903 New Hampshire Avenue, Document Control Center - WO66-G609, Silver Spring, MD 20993-0002. The text is left-aligned and in a simple font. September 5, 2017 Thermedx, LLC. Homer Gregory Director. OA/RA 31200 Solon Road, Unit #1 Solon, OH 44139 K172048 Re: > Trade/Device Name: FluidSmart Regulation Number: 21 CFR§ 884.1700 Regulation Name: Hysteroscopic Insufflator Regulatory Class: II Product Code: HIG, LGZ, HRX Dated: August 29, 2017 Received: August 31, 2017 Dear Homer Gregory: 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. Image /page/0/Picture/11 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of a human figure with three faces in profile, resembling an eagle or bird-like shape. {1}------------------------------------------------ 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 (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. 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 (DICE) 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 (DICE) 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. Image /page/1/Picture/9 description: The image shows the name "Benjamin R. Fisher -S" in a clear, sans-serif font. The text is horizontally aligned and appears to be part of a document or presentation. The letters are uniformly sized and spaced, contributing to the legibility of the name. 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 {2}------------------------------------------------ ### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration # Indications for Use 510(k) Number (if known) K172048 Device Name FluidSmart Indications for Use (Describe) Intended for irrigation and fluid warming in laparoscopic procedures, and distention, fluid warming, and volume/deficit measurements in endoscopic procedures within gynecology, and orthopedic disciplines. | Type of Use (Select one or both, as applicable) | | |----------------------------------------------------------------------------------|--------------------------------------------------------------------------------| | <div> <span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> | ### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. ### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW * The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ K172048 Page 1 of 4 Section 024 Image /page/3/Picture/2 description: The image shows the logo for Thermedx. The logo consists of the word "Thermedx" in a gray, sans-serif font. Above the word is a circular graphic with curved lines in different colors, including red, orange, yellow, light blue, and dark blue. The graphic is positioned above and slightly behind the word "Thermedx." ### Attachment 4 ## Special 510(k) Summary #### l. SUBMITTER, OWNER/OPERATOR Thermedx, LLC 31200 Solon Rd., Unit #1 Solon, OH 44139 Phone: 440.542.0883, Fax: 440.542.0920 Registration Number: 3007495879 Contact Person: Homer Gregory Date Prepared: 30 June 2017 #### II. DEVICE Trade Name of Device: FluidSmart® Common or Usual Name: Thermal infusion fluid warmer Classification Name: Insufflator, Hysteroscopic Subsequent Classification Names: Arthroscope and Warmer, Thermal, Infusion Fluid Regulatory Class: II Regulation Number: 21 CFR 884.1700 Subsequent Regulation Numbers: 21 CFR 888.1100 and 21 CFR 880.5725 Product Code: HIG Subsequent Product Codes: HRX and LGZ {4}------------------------------------------------ #### PREDICATE (LEGALLY MARKETED) DEVICE SUBSTANTIAL EQUIVALENCE Thermedx believes FluidSmart® is substantially equivalent in terms of safety and effectiveness to the following predicate (legally marketed) devices: - 1. Primary: Thermedx Fluid Management System (K133799) - 2. Secondary: Smiths Medical's NormoFlo® Irrigation Warmer Model H-1129 (K072080) #### IV. REFERENCE DEVICE Kosin Technologies' Piggyback Irrigating System (K040094) used as a reference as to clinicians' current utilization of 300 mmHg pressure in urology procedures. #### V. DEVICE DESCRIPTION FluidSmart® is intended for irrigation, distention, fluid warming, and fluid volume/deficit measurements in endoscopic procedures within gynecology, urology, and orthopedic disciplines. Fluids commonly used include 0.9% saline, lactated ringer's solution, 5% mannitol, 1.5% glycine, and sterile water. The main unit is mounted on a rolling stand which houses the technology used to warm the fluids and the peristaltic pump used to pressurize the fluids. A touch-screen operated processor provides closed loop controls for fluid warming and pumping. The processor monitors temperature and pressure sensors to adjust warming power and pump speed as required. Load cells attached to the fluid bag hooks and suction canister ring allow the processor to monitor fluid levels pumped to and suctioned from the surgical site. ## Disposable Tubing Sets Several versions of the disposable tubing sets are available. The LL0002 is an inflow tubing set used for endoscopic procedures with maximum fluid pressures up to 150 mmHg. The LL0004 is an inflow and outflow tubing set used for endoscopic procedures with maximum pressures up to 150 mmHq. The LL0006 is an inflow tubing set used for endoscopic procedures with maximum fluid pressures up to 300 mmHg. The tubing sets terminate in a luer lock fitting for use with existing hospital equipment, typically an endoscope. Each tubing set includes spikes for the fluid bags, tubing clamps, a cartridge for fluid warming, and a luer lock for connection to the surgical instrument or to a tube that connects {5}------------------------------------------------ to the surgical instrument. The luer lock features a pressure relief valve operating in a range specific to that model of tubing set. #### VI. INDICATIONS FOR USE FluidSmart® is intended for irrigation and fluid warming in laparoscopic procedures, and distention, fluid warming, and volume/ deficit measurements in endoscopic procedures within gynecology, urology, and orthopedic disciplines. #### VII. TECHNOLOGICAL CHARACTERISTICS ## Technological Comparison: The modified device, FluidSmart®, is essentially identical to the primary predicate device, Thermedx Fluid Management System, and substantially equivalent to the secondary predicate device with no fundamental technological differences. Essential design, the material, the chemical composition, the energy source, basic safety/essential performance, etc., are unchanged between the modified device and the primary predicate device. Other than the change to maximum fluid pressure for ureteroscopy going from 200 mmHg to 300 mmHg, there are no changes between the modified device and the primary predicate. Packaging of the modified device and disposable tubing sets, sterilization means for the disposable tubing sets, expiration dating for the disposable tubing sets, and biocompatibility acceptability for the disposable tubing sets remain unchanged from the primary predicate as well. Changes between the modified device and the primary predicate device relate to the ureteroscopy procedure pressure being increased from the currently cleared 200 mmHg to 300 mmHg utilized by the secondary predicate device. {6}------------------------------------------------ ### Table 6 | Technological<br>Characteristic | Modified Device | Primary<br>Predicate Device | Secondary Predicate<br>Device | |--------------------------------------------------|------------------------------|----------------------------------------------|------------------------------------------------------------| | | Name:<br>FluidSmart® | Name: Thermedx<br>Fluid Management<br>System | Name: NormoFlo®<br>Irrigation Fluid Warmer<br>Model H-1129 | | Fluid Warming<br>Method | Infrared heating<br>of fluid | Same | Heat exchanger | | Pressure<br>Generation Method | Peristaltic pump | Same | On-board compressor and<br>two pressure chambers | | User Interface | Touch Screen | Same | Controls<br>+ adjustable gauge | | Device Type | Electro-<br>Mechanical | Same | Same | | Maximum Pressure<br>(ureteroscopy<br>procedures) | 300 mmHg | 200 mmHg | Same<br>(300 mmHg - 500<br>mmHg) | #### NON-CLINICAL TESTS VIII. Non-clinical testing performed including the following design verification testing: 1. Software verification testing. 2. Tubing set verification testing. #### IX. CLINICAL INFORMATION No clinical testing was conducted by or on behalf of Thermedx. #### X. CONCLUSION The proposed device is safe and effective and is substantially equivalent to the predicate devices. Any differences are minor and we believe they raise no new questions of safety and effectiveness. All statements and representations set forth above regarding or related to "substantially equivalent" or "substantial equivalence" are in the limited context of the definition and purpose of substantial equivalence in the Federal Food, Drug, and Cosmetic Act, as amended, and applicable regulations of the Food and Drug Administration, and are not made in the context of, for any purpose related to, or as an admission against interest under, any other laws or regulations, including patent laws (whether in the context of patent infringement or otherwise).
Innolitics
510(k) Summary
Decision Summary
Classification Order
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