K211203 · Green Or, LLC · NUJ · Apr 7, 2022 · General, Plastic Surgery
Device Facts
Record ID
K211203
Device Name
Green OR Reprocessed Aquamantys Bipolar Sealer
Applicant
Green Or, LLC
Product Code
NUJ · General, Plastic Surgery
Decision Date
Apr 7, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4400
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Green OR Reprocessed Aquamantys Bipolar Sealer is a sterile, single-use bipolar electrosurgical device intended to be used in conjunction with a qualified Pump Generator for delivery of radio-frequency (RF) energy and saline for hemostatic sealing and coagulation of soft tissue and bone at the operative site. The device is not intended for contraceptive tubal coagulation (permanent female sterilization). The Green OR Reprocessed Aquamantys 2.3 Bipolar Sealer is intended for, but not limited to orthopaedic, neurosurgical, spine, thoracic, and open abdominal surgery. The Green OR Reprocessed Aquamantys 6.0 Bipolar Sealer is intended for, but not limited to orthopaedic, spine, thoracic, and open abdominal surgery. The Green OR Reprocessed Aquamantys 9.5 XL Bipolar Sealer is intended for, but not limited to open abdominal, orthopaedic, and thoracic surgery.
Device Story
Reprocessed single-use bipolar electrosurgical device; delivers RF energy and saline to soft tissue and bone for hemostasis. Input: RF energy and saline flow from qualified Pump Generator. Output: Coagulated tissue at operative site. Operated by surgeons in OR. Device features on-off button for simultaneous RF and saline activation; includes saline delivery line, pump tubing, and drip chamber/spike. Connects to generator via three-pin electrical connector. Benefits: Provides hemostatic sealing during surgical procedures. Device is reprocessed version of original OEM equipment.
Bipolar electrosurgical device; RF energy and saline delivery. Three-pin electrical connector. Includes saline fluid delivery line, pump tubing, and drip chamber/spike. Sterilization validation performed. Electrical safety per IEC 60601-2-2. Reprocessed single-use device.
Indications for Use
Indicated for hemostatic sealing and coagulation of soft tissue and bone in orthopaedic, neurosurgical, spine, thoracic, and open abdominal surgery. Contraindicated for contraceptive tubal coagulation.
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.
{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: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.
April 7, 2022
Green OR, LLC. % Aaron Rogers Director of Regulatory and Quality Pathway LLC 8779 Cottonwood Ave. Suite 105 Santee, California 92071
Re: K211203
Trade/Device Name: Green OR Reprocessed Aquamantys Bipolar Sealer Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: NUJ Dated: March 7, 2022 Received: March 8, 2022
Dear Aaron Rogers:
We have reviewed vour 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
{1}------------------------------------------------
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-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 (QS) 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,
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}------------------------------------------------
# K211203 - Aaron Rogers
| Reprocessed Single-Use Device Models Included in Submission: | | |
|--------------------------------------------------------------|--------------|----------------------------------|
| OM | Model Number | Device Name/Description |
| OEM | Model Number | Device Name/Description |
| Medtronic | 23-113-1 | Aquamantys 2.3 Bipolar Sealer |
| Medtronic | 23-112-1 | Aquamantys 6.0 Bipolar Sealer |
| Medtronic | 23-313-1 | Aquamantys 9.5 XL Bipolar Sealer |
{3}------------------------------------------------
## Indications for Use
510(k) Number (if known) K211203
#### Device Name
Green OR Reprocessed Aquamantys 2.3 Bipolar Sealer, Green OR Reprocessed Aquamantys 6.0 Bipolar Sealer, Green OR Reprocessed Aquamantys 9.5 XL Bipolar Sealer
#### Indications for Use (Describe)
The Green OR Reprocessed Aquamantys Bipolar Sealer is a sterile, single-use bipolar electrosurgical device intended to be used in conjunction with a qualified Pump Generator for delivery of radio-frequency (RF) energy and saline for hemostatic sealing and coagulation of soft tissue and bone at the operative site. The device is not intended for contraceptive tubal coagulation (permanent female sterilization).
The Green OR Reprocessed Aquamantys 2.3 Bipolar Sealer is intended for, but not limited to orthopaedic, neurosurgical, spine, thoracic, and open abdominal surgery.
The Green OR Reprocessed Aquamantys 6.0 Bipolar Sealer is intended for, but not limited to orthopaedic, spine, thoracic, and open abdominal surgery.
The Green OR Reprocessed Aquamantys 9.5 XL Bipolar Sealer is intended for, but not limited to open abdominal, orthopaedic, and thoracic surgery.
| Type of Use (Select one or both, as applicable) |
|----------------------------------------------------------------------------------|
| <input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) |
| <input type="checkbox"/> 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 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."
{4}------------------------------------------------
K211203
Image /page/4/Picture/2 description: The image shows the logo for GreenOR. The word "Green" is written in green font, and the letters "OR" are written in blue font. A green and blue circular arrow surrounds the word "Green" and connects to the letters "OR".
Reprocessed Aquamantys Bipolar Sealers
# K211203 Summary
| SUBMITTER | Green OR, LLC.<br>John Zehren<br>4200 Dahlberg Drive #300<br>Golden Valley, MN 55422 | | |
|----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|---------|
| CONTACT | Aaron Rogers<br>Pathway, LLC.<br>8779 Cottonwood Ave. #105<br>Santee, CA 92071<br>619-415-0103 x704<br>arogers@pathwaynpi.com | | |
| DATE PREPARED | April 6, 2022 | | |
| DEVICE NAME | Green OR Reprocessed Aquamantys Bipolar Sealer | | |
| CLASSIFICATION | Electrosurgical cutting and coagulation device and accessories<br>Regulation: 21 CFR 878.4400<br>Device Class: Class II<br>Product Code: NUJ | | |
| | Predicate<br>Manufacturer | Device Name | 510(k) |
| PREDICATE<br>DEVICE | Medtronic | Aquamantys 2.3 Bipolar Sealer | K132974 |
| | Medtronic | Aquamantys 9.5 XL Bipolar Sealer | K120537 |
| | Medtronic | Aquamantys 6.0 Bipolar Sealer | K111285 |
| REFERENCE<br>DEVICE | No reference devices were used in this submission. | | |
| | with an on-off button that simultaneously activates both RF and saline<br>flow. A saline fluid delivery line is provided with the device, and<br>includes a section of pump tubing and a drip chamber or spike. The<br>three-pin electrical connector is designed to be plugged into a<br>qualified Pump Generator. The generator is not included in the scope<br>of the study and will not be reprocessed. | | |
| | The Green OR Reprocessed Aquamantys Bipolar Sealer is a sterile,<br>single-use bipolar electrosurgical device intended to be used in<br>conjunction with a qualified Pump Generator for delivery of RF energy<br>and saline for hemostatic sealing and coagulation of soft tissue and<br>bone at the operative site. The device is not intended for<br>contraceptive tubal coagulation (permanent female sterilization). | | |
| INTENDED USE | The Green OR Reprocessed Aquamantys 2.3 Bipolar Sealer is<br>intended for, but not limited to orthopaedic, neurosurgical, spine,<br>thoracic, and open abdominal surgery. | | |
| | The Green OR Reprocessed Aquamantys 6.0 Bipolar Sealer is<br>intended for, but not limited to orthopaedic, spine, thoracic, and open<br>abdominal surgery. | | |
| | The Green OR Reprocessed Aquamantys 9.5 XL Bipolar Sealer is<br>intended for, but not limited to, open abdominal, orthopaedic, and<br>thoracic surgery. | | |
| TECHNOLOGICAL<br>CHARACTERISTICS | The technological characteristics and the fundamental scientific<br>technology of the subject devices are identical to the predicate<br>device. The subject devices are a reprocessed version of the<br>predicate. The predicate devices were used to support intended use,<br>technological characteristics, and functional performance<br>specifications. | | |
| | The functional characteristics of the subject devices have been<br>evaluated and found to be equivalent to the predicate devices based<br>on the following tests: | | |
| PERFORMANCE<br>TESTING | Sterilization Validation Biocompatibility Cytotoxicity Sensitization Irritation: Intracutaneous Reactivity Acute systemic toxicity Material mediated pyrogenicity Bacterial Endotoxin / LAL EMC and Electrical Safety IEC 60601-2-2 Functional Performance RF Power Output Saline Flow Rate | | |
{5}------------------------------------------------
{6}------------------------------------------------
| | • Cleaning |
|------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | • Residual Protein |
| | • Residual Total Organic Carbon |
| CONCLUSION | Based on comparisons of the indications for use, intended use, technological characteristics, and performance data to the predicate devices, the Green OR Reprocessed Aquamantys Bipolar Sealer is substantially equivalent to the predicate devices. |
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.