Ellusa Bipolar Wands

K202558 · Ellusa, LLC · GEI · Nov 2, 2020 · General, Plastic Surgery

Device Facts

• Record ID: K202558
• Device Name: Ellusa Bipolar Wands
• Applicant: Ellusa, LLC
• Product Code: GEI · General, Plastic Surgery
• Decision Date: Nov 2, 2020
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4400
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Ellusa Bipolar Wands are intended for use by a physician familiar with bipolar coagulation with electrosurgery where coagulation/contraction of soft tissue is needed.

Device Story

Ellusa Bipolar Wands are disposable, bipolar electrosurgical devices; consist of plastic handle, insulated electrode shaft, bipolar tip, and integrated cable. Designed for connection to Ellusa high-frequency RF generators. Operated by physician via footswitch during general surgery. Device delivers RF energy to target tissue; energy causes cutting or coagulation based on generator waveform and power settings. Transient patient contact. Benefits include controlled soft tissue coagulation/contraction. Bench testing confirms thermal effects on tissue and surface temperature safety.

Clinical Evidence

No clinical data. Substantial equivalence demonstrated via bench testing, including thermal effect analysis on ex vivo tissue (liver, kidney, muscle), temperature profiling of applicators/cables, and adherence to electrical safety (IEC 60601 series) and biocompatibility (ISO 10993) standards.

Technological Characteristics

Disposable bipolar electrosurgical wand; stainless steel electrode; plastic handle; 11-40cm shaft length; 1.2-6mm diameter. RF energy source (0-170W). Footswitch activation. Sterilized via ethylene oxide (ISO 11135). Biocompatible per ISO 10993. Complies with IEC 60601-1, IEC 60601-2-2, IEC 60601-1-2, IEC 60601-1-6, and IEC 62366.

Indications for Use

Indicated for use by physicians familiar with bipolar electrosurgical coagulation for soft tissue coagulation/contraction.

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.

Predicate Devices

• Soniquence Bipolar Electrodes (K190336)

Submission Summary (Full Text)

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym and name on the right. The FDA acronym is in a blue square, followed by the words "U.S. Food & Drug Administration" in blue text.

November 2, 2020

Ellusa, LLC Ms. Suzanne Lucas Sr. Regulatory Affairs Specialist 2473 Grand Avenue Baldwin, New York 11510

Re: K202558

Trade/Device Name: Ellusa Bipolar Wands Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: August 31, 2020 Received: September 4, 2020

Dear Ms. Lucas:

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

{1}------------------------------------------------

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 ([e-mail]) or phone [phone] 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

{2}------------------------------------------------

### Indications for Use

510(k) Number (if known)

#### K202558

Device Name Ellusa Bipolar Wands

Indications for Use (Describe)

The Ellusa Bipolar Wands are intended for use by a physician familiar with bipolar coagulation with electrosurgery where coagulation/contraction of soft tissue is needed.

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)

#### 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 [e-mail]

"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}------------------------------------------------

Image /page/3/Picture/1 description: The image shows the word "ellusa" in a stylized font. The word is in black and is set against a white background. A swooping black design element is on the left side of the word, adding a dynamic and modern touch to the overall logo.

# 510(k) Summary

(As required by 21 CFR 807.92(a)) (K202558)

Date Prepared October 29, 2020

### Submitter's Information (807.92(a)(1))

Company Name and Address: Ellusa, LLC 2473 Grand Avenue Baldwin, NY 11510 Phone: [phone] www.ellusa.com Establishment Registration number: 3016087306

#### Contact Information:

Ms. Suzanne Lucas Sr. Regulatory Affairs Specialist Phone: [phone] Email: [e-mail]

#### Device Information (807.92(a)(2))

Trade Name: Ellusa Bipolar Wands

#### Common/Usual Name

Electrosurgical, Cutting & Coagulation Device & Accessories

#### Classification Name and Regulation

Electrosurgical Cutting and Coagulation Device and Accessories; 21 CFR 878.4400

#### Classification Panel

Division of General, Restorative, and Neurological Devices

#### Device Class/Product Code

FDA Classification: Class 2 FDA Product Code: GEI

{4}------------------------------------------------

# Predicate Devices (807.92(a)(3))

Soniquence Bipolar Electrodes (K190336)

### Use of Guidance Documents

The content provided within this 510k follows the FDA guidance document "Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery" issued on March 9, 2020.

### Device Description (807.92(a)(4))

The Ellusa Bipolar Wand family is a line of disposable bipolar electrosurgical devices which is intended for use by a physician familiar with electrosurgery in bipolar coagulation for general surgery where coagulation of soft tissue is needed. The basic design of the Ellusa Bipolar Wands is a plastic handle, an elongated, insulated electrode shaft, a bipolar electrode tip, and an integrated cable and plug which is designed to connect exclusively to the Ellusa line of highfrequency RF energy sources.

The operational principle of the device is common to all active bipolar electrosurgical devices; the active tip of the Ellusa Bipolar Wand emits RF energy generated according to settings established on the Ellusa Generator which emits high frequency, low temperature radiowaves directed to the electrode tip. The electrical power operating at radio frequency (RF) is transferred to tissue at the surgical site. This energy is capable of cutting or coagulating target tissue depending on the waveform associated with the mode and power setting of the generator. The devices are disposable and intended for single use only. The devices are intended for transient contact with the patient and are provided sterilized by ethylene oxide and has a shelf life of three years from the date of sterilization.

#### Intended Use:

The Ellusa Bipolar Wands are intended for use by a physician familiar with bipolar coagulation with electrosurgery where coagulation/contraction of soft tissue is needed.

# Comparison of Technological Characteristics (807.92(a)(6))

The Ellusa Bipolar Wands are identical in technological characteristics to the Soniquence Bipolar Electrodes (K190336) based on a comparison of physical and performance characteristics. There are no technological differences between the subject device as compared to the predicate devices, and the indications for use are identical.

{5}------------------------------------------------

| Technological Characteristic | Soniquence Bipolar Electrodes | Ellusa Bipolar Wand |
|------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | PREDICATE DEVICE (K190336) | SUBJECT DEVICE |
| Intended Use | The Soniquence Bipolar Electrode is intended<br>for use by a physician familiar with bipolar<br>coagulation with electrosurgery where<br>coagulation/contraction of soft tissue is<br>needed. | The Ellusa Bipolar Wands are intended for<br>use by a physician familiar with bipolar<br>coagulation with electrosurgery where<br>coagulation/contraction of soft tissue is<br>needed. |
| Product Code | GEI | Identical to predicate |
| Device Classification | Class II | Identical to predicate |
| Functions | Cutting/coagulation | Identical to predicate |
| Operating principle | Bipolar | Identical to predicate |
| Energy Source | RF Energy | Identical to predicate |
| Electrode Materials | Stainless steel | Identical to predicate |
| Tip Configurations | Ball Tip, Standard, Hex blade | Identical to predicate |
| Tip dimensions | 0.5 - 8mm | Identical to predicate |
| Shaft lengths | 11 - 40cm | Identical to predicate |
| Shaft diameter | 1.2 - 6mm | Identical to predicate |
| Stability and Shelf Life | 3 years | Identical to predicate |
| Coating | None | Identical to predicate |
| Cable Length (m) | 3m | Identical to predicate |
| Activation Method | Footswitch | Identical to predicate |
| Testing standards used | IEC 60601-1 and IEC 60601-2-2 | Identical to predicate |
| Biocompatibility | ISO 10993 | Identical to predicate |
| Sterilization Methods | Ethylene Oxide | Identical to predicate |
| Packaging | Sterile, Blister Tray | Identical to predicate |
| Min., Max., Default output<br>Values (Wattage) | 0-170 | Identical to predicate |

{6}------------------------------------------------

# Non-Clinical Testing (807.92(b)(1))

The Ellusa Bipolar Wands will be manufactured in accordance with the design control requirements of 21 CFR 820.30. Appropriate non-clinical verification and validation activities were planned and conducted to address identified risks and ensure the safety and effectiveness of the device. The following standards have been applied to the devices and passed all applicable tests requirements.

- . IEC 60601-1:2005/(R)2012 and A1:2012 - Medical Electrical Equipment, Part I: General requirements for basic safety and essential performance
- IEC 60601-1-6:2010 (Third Edition) + A1 2013: General requirements for basic safety and . essential performance - Collateral standard: Usability
- . IEC 62366:2007 (First Edition) + A1:2014: Medical devices – Application of usability engineering to medical devices
- . IEC 60601-1-2:2014 - Medical Electrical Equipment, Part l-2: General requirements for basic safety and essential performance. Collateral Standard: Electromagnetic Compatibility
- . IEC 60601-2-2: 2017 6th edition- Medical electrical equipment – Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories

# Sterilization:

- . ISO 11135:2014 - Sterilization of health-care products — Ethylene oxide —Requirements for the development, validation and routine control of a sterilization process for medical devices
- . ISO 11737-1: 2018 Sterilization of medical products--Microbiological methods--Part 1: Determination of population of microorganisms on product
- . ISO 11737-2: 2019 Sterilization of medical devices--Microbiological methods--Part 2: Tests of sterility performed in the validation of a sterilization process
- . ISO 11138-1:2017 Sterilization of health care products--Biological indicators--Part1: General Requirements
- . ISO 11138-2:2017 Sterilization of health care products--Biological indicators--Part2: Biological indicators for ethylene oxide sterilization processes

# Biocompatibility Testing:

- . ISO 10993-1:2018 Biological evaluation of medical devices -- Part 1: Evaluation and testing within a risk management process

{7}------------------------------------------------

- . ISO 10993-4:2017: 2017 Biological Evaluation of Medical Devices, Part 4: Selection of test for interactions with blood.
- . ISO 10993-5:2009 - Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
- . ISO 10993-7:2008 Biological evaluation of medical device--Part: 7: Ethylene Oxide sterilization residual.
- . ISO 10993-10:2010 - Biological evaluation of medical devices — Part 10: Tests for irritation and skin sensitization
- . ISO 10993-11:2017 - Biological evaluation of medical devices - Part 11: Tests for systemic toxicity

# Shelf Life Testing:

- . ASTM F1886/F1886M -Standard Test Method for Determining Integrity of Seals for Flexible Packaging by Visual Inspection
- . ASTM F1929 - Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration
- . ASTM F1980 - Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices

### Performance Testing

The subject device is composed of biocompatible materials, has passed dielectric testing, and performs identical to the predicate devices. Bench tests used ex vivo tissue that included liver, kidney, and muscle tissue. The subject devices were tested to demonstrate the thermal effect on tissue by measuring the width and depth of the thermally damaged zones in relation to tissue type, intensity setting, and duration of activation. The temperature profile of the subject device applicator and cable was recorded during simulation use for the maximum energy delivery duration at the maximum power to demonstrate the maximum applicator surface area and maximum cable surface temperature will be safe to the user and/or to the patient. The peak temperatures of the electrode tips and target tissue/vessels when the device is used for the maximum recommended duration and generator output settings was compared. Based on the results of the various bench tests, it was determined that the subject device is safe and effective.

#### Clinical Testing (807.92(b)(2))

This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence.

{8}------------------------------------------------

# Conclusion (807.92(b)(3))

In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the similarity to the predicate devices in terms of technology, performance, and indications for use, Ellusa, LLC concludes that the subject device, Ellusa Bipolar Wands do not raise any issues of safety or effectiveness and are substantially equivalent to the predicate devices as described above.