Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart

Q: Who is the manufacturer of Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart?

Conmed Corporation filed the 510(k) submission for Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart (K213354).

Q: What is the FDA product code for Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart?

GEI. It is classified under 21 CFR 878.4400 as a Class 2 device in the General, Plastic Surgery panel.

Q: What is the regulatory pathway for Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart?

510(k) clearance (submission type: Traditional).

Q: What are the predicate devices for Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart?

HelixAR ABC System (K172671); Valleylab FT10 Electrosurgical Platform (K170170).

Q: Who can help prepare an FDA 510(k) submission like Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart?

Innolitics — a medical-device software consultancy — provides regulatory and engineering support for FDA 510(k) submissions. See https://innolitics.com/services/510ks/ or contact https://innolitics.com/contact.

K213354 · Conmed Corporation · GEI · Mar 11, 2022 · General, Plastic Surgery

Device Facts

Record ID	K213354
Device Name	Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart
Applicant	Conmed Corporation
Product Code	GEI · General, Plastic Surgery
Decision Date	Mar 11, 2022
Decision	SESE
Submission Type	Traditional
Regulation	21 CFR 878.4400
Device Class	Class 2
Attributes	Therapeutic

Intended Use

The CONMED UNIFY is indicated for surgical procedures for the cutting and/or coagulation of tissue when hemostasis is desired. This generator can be used with compatible resectoscopes for the removal or coagulation of tissue in 0.9% NaCl solution as the irrigation medium. This generator, when used with compatible vessel sealing devices, is indicated for the ligation of tissue bundles, lymphatics, and vessels in open and laparoscopic procedures. Reference instructions for use (IFU) for applicable vessel sealing devices. The vessel sealing function has not been shown to be effective for tubal coagulation for sterilization procedures. Do not use this function for these procedures.

Device Story

Unify Multifunction Energy Platform (MEP) is an electrosurgical generator system for OR/endoscopy use. Inputs: user-selected modes (monopolar/bipolar) via touchscreen GUI; RF energy delivery via handpieces/cables. Operation: microprocessor-controlled high-frequency RF energy for tissue cutting, coagulation, and vessel sealing. Outputs: controlled electrical energy to tissue; visual/audible alerts; touchscreen status updates. Used by surgeons/clinicians to achieve hemostasis, ligate vessels (up to 7mm), or perform bipolar resection in saline. System includes generator, CleanSeal vessel sealers, bipolar resection cables, wireless footswitch, and cart. Benefits: provides controlled tissue destruction/sealing, reducing bleeding in multispecialty procedures. Safety features include Automatic Return Monitoring (ARM) for dispersive electrodes and continuous microprocessor safety monitoring.

Clinical Evidence

No human clinical trials. Evidence includes benchtop/ex-vivo performance testing, in-vivo simulated use, and a 21-day chronic porcine animal study. Animal study compared Unify ESU/CleanSeal 5mm Maryland sealer to Valleylab FT10/LigaSure Maryland sealer, confirming effective sealing of arteries, veins, and A/V bundles. Biocompatibility testing (ISO 10993) confirmed safety for patient-contact components.

Technological Characteristics

High-frequency (RF) electrosurgical generator. Features: touchscreen GUI, ARM for dual dispersive electrodes, smart accessory connection. Energy: RF. Protection: Type CF. Duty cycle: 15s ON/30s OFF. Connectivity: wired/wireless footswitch, smart accessory ports. Standards: AAMI/ANSI ES60601-1, IEC 60601-2-2, IEC 60601-1-2, IEC 62304, ISO 14971, ISO 10993-1, ISO 17664:2017.

Indications for Use

Indicated for surgical cutting/coagulation of tissue in all patient populations. Includes vessel ligation/division (up to 7mm) in open/laparoscopic gynecological, general, urologic, and vascular procedures. Compatible with resectoscopes for tissue removal/coagulation in 0.9% NaCl. Contraindicated for tubal sterilization/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.

Predicate Devices

HelixAR ABC System (K172671)
Valleylab FT10 Electrosurgical Platform (K170170)

Reference Devices

LigaSure Maryland Jaw Sealer/Divider One-step Sealing, Nano-coated (K170869)

Related Devices

K051644 — VALLEYLAB FORCETRIAD ELECTROSURGICAL GENERATOR · Valleylab · Aug 11, 2005
K191601 — Valleylab FT10 Electrosurgical Platform · Covidien · Jul 12, 2019
K252412 — Voyant® Electrosurgical Generator (EA030/Electrosurgical Generator) · Applied Medical Resources Corporation · Oct 31, 2025
K170170 — Valleylab FT10 Electrosurgical Platform · Covidien, LLC · Feb 16, 2017
K110268 — FORCETRIAD ELECTROSURGICAL GENERATOR · Covidien Lp, Formerly Know AS Valleylab, A Divison · May 31, 2011

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). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue. March 11, 2022 ConMed Corporation Lisa Anderson Senior Lead Regulatory Affairs Specialist 525 French Road Utica, New York 13502 Re: K213354 Trade/Device Name: Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: February 4, 2022 Received: February 9, 2022 Dear Lisa Anderson: 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/cdrl/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. {1}------------------------------------------------ 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-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 medical devices and radiation-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}------------------------------------------------ Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below. #### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration ### Indications for Use 510(k) Number (if known) K213354 #### Device Name Unify Multifunction Energy Platform, CleanSeal Vessel Sealers, Unify Bipolar Resection Cables, Unify Cart #### Indications for Use (Describe) Unify Multifunction Energy Platform and Unify Cart The CONMED UNIFY is indicated for surgical procedures for the cutting and/or coagulation of tissue when hemostasis is desired. This generator can be used with compatible resectoscopes for the removal or coagulation of tissue in 0.9% NaCl solution as the irrigation medium. This generator, when used with compatible vessel sealing devices, is indicated for the ligation of tissue bundles, lymphatics, and vessels in open and laparoscopic procedures. Reference instructions for use (IFU) for applicable vessel sealing devices. The vessel sealing function has not been shown to be effective for tubal coagulation for sterilization procedures. Do not use this function for these procedures. #### CleanSeal Vessel Sealers CONMED CleanSeal Vessel Sealers are intended to be used in open and minimally invasive procedures for the ligation and division of tissue bundles, lymphatics, and vessels up to and including 7 mm vessels (arteries and veins). The handpiece is indicated for use in gynecological and general surgical procedures, including urologic and vascular. These procedures include, but are not limited to, hysterectomies, colectomies, Nissen fundoplication, and adhesiolysis. The CleanSeal Vessel Sealer has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the CleanSeal Vessel Sealer for these procedures. #### Unify Bipolar Resection Cables The CONMED UNIFY Bipolar Resection Cables are used to connect compatible accessories to the CONMED UNIFY ESU. UNIFY Bipolar Resection Cables are used in conjunction with the Bipolar Resection capabilities of the UNIFY ESU for the removal or coagulation of tissue in 0.9% NaCI solution as the irrigation medium. The CONMED UNIFY Bipolar Resection Cables are intended for use with only compatible resectoscopes (refer to Compatibility for details). Maximum rated voltage 750 V. #### Unify Wireless FootSwitch The Wireless Footswitch Kit is intended for use with the CONMED UNIFY™ Advanced Energy Generator for the operation of foot-controlled RF devices. 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. {3}------------------------------------------------ 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}------------------------------------------------ # Section 6 - 510(k) Summary of Safety and Effectiveness ## ConMed Unify Multifunction Energy Platform with CleanSeal Vessel Sealing Technology In accordance with the requirements of the Safe Medical Device Act of 1990 and 21CFR 807.92, ConMed Corporation is hereby submitting the 510(k) Summary of Safety and Effectiveness for 510(k) number K213354 as of Jan 12th, 2022. ## A. Submitter ConMed Corporation 525 French Road Utica, NY 13502 Establishment Registration: 1320894 ### B. Company Contact Lisa Anderson Sr. Lead Requlatory Affairs Specialist M: (941) 713-2035 ## C. Device Name | Device Name | Unify Multifunction Energy Platform CleanSeal Vessel Sealers, Unify | |----------------------|---------------------------------------------------------------------| | Proprietary Name: | Bipolar Resection Cables, Unify Wireless FootSwitch, Unify Cart | | Common Name: | Electrosurgical Generator | | Classification Name: | Electrosurgical, Cutting & Coagulation & Accessories 878.4400 | | Regulation Number: | GEI | | Product Code: | II | | Regulatory Class: | General and Plastic Surgery | | Panel: | | ## D. Predicate Device | Primary Device Name: | HelixAR ABC System | |------------------------|--------------------------------------------------------------------| | Company Name: | ConMed Corporation | | 510(k): | K172671 | | Secondary Device Name: | Valleylab FT10 Electrosurgical Platform | | Company Name: | Covidien LLC | | 510(k): | K170170 | | Reference Device Name: | LigaSure Maryland Jaw Sealer/Divider One-step Sealing, Nano-coated | | Company Name: | Covidien LLC | | 510(k): | K170869 | ## E. Device Description The Unify Multifunction Energy Platform (Unify MEP) is composed of an electrosurgical generator (Unify ESU) with CleanSeal Technology and CleanSeal Vessel Sealing handpieces. The Unify generator is designed with a touchscreen graphic user interface (GUI) display which allows the user to select monopolar and bipolar modes of operation, choose power settings, adjust user settings options, and create, edit, or delete user programs. The Unify ESU is designed for enhanced control of bleeding {5}------------------------------------------------ #### K213354 and for the electrosurgical destruction of the tissue in multispecialty procedures in the operating room or endoscopy suite. This equipment, in conjunction with connected accessories, is intended to produce high-frequency electrical energy for the controlled destruction of tissue. The CleanSeal Vessel Sealers are designed to seal vessels up to and including 7mm vessels, tissue bundles, and lymphatics. Unify Bipolar Resection Cables are provided to connect between Unify ESU and compatible resectoscopes. ### F. Intended Use / Indications for Use ### Unify Multifunction Energy Platform and Unify Cart The CONMED UNIFY is indicated for surgical procedures for the cutting and/or coagulation of tissue when hemostasis is desired. This generator can be used with compatible resectoscopes for the removal or coagulation of tissue in 0.9% NaCl solution as the irrigation medium. This generator, when used with compatible vessel sealing devices, is indicated for the ligation and division of tissue bundles, lymphatics, and vessels in open and laparoscopic procedures. Reference instructions for use (IFU) for applicable vessel sealing devices. The vessel sealing function has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use this function for these procedures. #### CleanSeal Vessel Sealers CONMED CleanSeal Vessel Sealers are intended to be used in open and minimally invasive procedures for the ligation and division of tissue bundles, lymphatics, and vessels up to and including 7 mm vessels (arteries and veins). The handpiece is indicated for use in gynecological and general surgical procedures, including urologic, and vascular. These procedures include, but are not limited to, hysterectomies, oophorectomies, colectomies, Nissen fundoplication, and adhesiolysis. The CleanSeal Vessel Sealer has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the CleanSeal Vessel Sealer for these procedures. ### Unify Bipolar Resection Cables The ConMed UNIFY Bipolar Resection Cables are used to connect compatible accessories to the ConMed UNIFY ESU. UNIFY Bipolar Resection Cables are used in conjunction with the Bipolar Resection capabilities of the UNIFY ESU for the removal or coagulation of tissue in 0.9% NaCl solution as the irrigation medium. The ConMed UNFY Bipolar Resection Cables are intended for use with only compatible resectoscopes (refer to Compatibility for details). Maximum rated voltage 750 V. #### Unify Wireless Footswitch The Wireless Footswitch Kit is intended for use with the ConMed UNIFY™ Advanced Energy Generator for the operation of foot-controlled RF devices. ### G. Technological Characteristics The Unify MEP is similar to the predicate devices in that the system includes an electrosurgical generator with vessel sealing capabilities used in conjunction with monopolar and bipolar handpieces, footswitches, and an accessory cart. The Unify MEP design includes the non-ABC monopolar and bipolar modes present in the HelixAR Electrosurgical Generator. The design also includes Vessel {6}------------------------------------------------ #### K213354 Sealing, Soft Coag, and Bipolar Resection modes similar to those in the Valleylab FT10. The output panel of Unify Multifunction Energy Platform provides receptacles for monopolar and bipolar hand- and foot-controlled devices and footswitches. The accessory cart also accommodates the use of additional Unify MEP devices, smoke evacuation units, and accessory storage. The Unify MEP provides Automatic Return Monitoring (ARM) for dual dispersive electrodes as well as visual and audible alerts similar to those used in the predicate designs. The Unify MEP is safe and effective and substantially equivalent to the predicate as demonstrated by non-clinical performance testing. | Features | Unify Multifunction Energy Platform | HelixAR ABC System | ValleyLab FT10/ LigaSure Maryland Jaw Sealer/Divider | |-------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Indications for Use | The Unify ESU is indicated for surgical procedures for the cutting and/or coagulation of tissue when hemostasis is desired. The Unify ESU can be used with compatible resectoscopes for the removal or coagulation of tissue in 0.9% NaCI solution as the irrigation medium. The Unify ESU can be used in conjunction with ConMed compatible vessel sealing hand pieces, which are intended to be used in open and laparoscopic procedures for the ligation and division of tissue bundles, lymphatics, and vessels. ConMed CleanSeal Vessel Sealers are intended to be used in open and minimally invasive procedures for the liqation and division of tissue bundles, lymphatics, and vessels up to and including 7 mm vessels (arteries and veins). The handpiece is indicated for use in gynecological and general surgical procedures, including urologic, thoracic, and vascular. These procedures include, but are not limited to, hysterectomies, oophorectomies, colectomies, Nissen fundoplication, and adhesiolysis. | The HelixAR ESU is intended to deliver argon gas, as well as a high- frequency electrical current for the cutting and/or coagulation of tissue. | The FT10 is a high frequency electrosurgical generator intended for use with monopolar and bipolar accessories for cutting and coagulating tissue. When used with compatible sealing devices, it is indicated for sealing vessels up to and including 7 mm, tissue bundles, and lymphatics. The generator can also be used with compatible resectoscopes for endoscopically controlled removal or coagulation of tissue using 0.9% NaCI solution as the irrigation medium. The tissue fusion function has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use this function for these procedures. The LigaSure Sealer/Divider is a bipolar electrosurgical instrument intended for use in minimally invasive or open surgical procedures where ligation and division of vessels, tissue bundles, and lymphatics is desired. The LigaSure Sealer/ Divider can be used on vessels (arteries and veins) up to and including 7 mm. It is indicated for use in general surgery and such surgical specialties as urologic, vascular, thoracic, and gynecologic. Procedures may include, but are not limited to, Nissen fundoplication, colectomy, cholecystectomy, adhesiolysis, hysterectomy, oophorectomy, etc. The LigaSure system has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the LigaSure system for these procedures. | | Target Population | All patient populations | All patient populations | All patient populations | | Duty Cycle | 15s ON / 30s OFF | 15s ON / 30s OFF | 10s ON / 30s OFF for any mode for 4 hours | | Features | Unify Multifunction Energy Platform | HelixAR ABC System | ValleyLab FT10/ LigaSure Maryland Jaw Sealer/Divider | | Energy Type | High Frequency (RF) | High Frequency (RF) with integrated Argon Beam Coagulation | High Frequency (RF) ~434kHz Optional Argon Module | | Degree of Protection | Type CF | Type CF | Type CF | | Design | - Patient Contact Monitoring System - Continuous microprocessor safety monitoring - LCD with touchscreen - Smart Accessory Connection - Monopolar Remote Power Control | - Patient Contact Monitoring System - Continuous microprocessor safety monitoring - LCD - Monopolar Remote Power Control | - Patient Contact Monitoring System - Continuous microprocessor safety monitoring - LCD with touchscreen - Smart Accessory Connection | | Connections | - Monopolar - Bipolar - Bipolar Vessel Sealing - Bipolar Resection - Dispersive Electrode | - Monopolar - Bipolar - ABC - Dispersive Electrode | - Monopolar - Bipolar - Bipolar Vessel Sealing - Bipolar Resection - Dispersive Electrode | | Accessories | Cart Corded and Wireless Footswitch Bipolar Resection Cable | Cart Corded and Wireless Footswitch | Cart Corded Footswitch Bipolar Resection Cable | {7}------------------------------------------------ ## H. Performance Testing The Unify MEP has been tested according to the applicable requirements listed in FDA guidance "Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery" and "Premarket Notification (510(k)) Submissions for Bipolar Electrosurgical Vessel Sealers for General Surgery". Benchtop and ex-vivo comparison testing, in-vivo simulated use testing, and chronic animal studies support that the ConMed Unify MEP is substantially equivalent to the ConMed HelixAR and Valleylab FT10 Electrosurgical Generators in intended use, technology, and system performance. Mechanical and electrical verification activities and software validation demonstrate the Unify Multifunction Energy Platform complies with the applicable sections of AAMI/ANSI ES60601-1, IEC 60601-2-2, IEC 60601-1-2, and IEC 62304. Risk management activities in accordance with ISO 14971 demonstrate the risks associated with the use of the Unify Multifunction Energy Platform are mitigated to an acceptable level. Analyses of these activities conclude the benefits associated with the use of the Unify MEP outweigh the residual risks. #### l. Biocompatibility Test The CleanSeal 5mm Vessel Sealer (CleanSeal 5mm VS) used with Unify ESU is in compliance with 2020 FDA Guidance of Use of International Standard ISO 10993-1, "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process". The biological test results support that the CleanSeal 5mm VS met the acceptance criteria for the following biocompatibility test endpoints. | Test Endpoint | Test Method | |---------------------------|---------------------------------------------------------------------------------------------------------------------------------| | Cytotoxicity | ISO 10993-5:2009 Biological Evaluation of Medical Devices, Part 5: Tests for In Vitro Cytotoxicity | | Intracutaneous Irritation | ISO 10993-10: 2010 Standard, Biological Evaluation of Medical Devices, Part 10: Tests for Irritation and Skin Sensitization. | | Sensitization | ISO 10993-10:2010. Biological Evaluation of Medical Devices, Part 10: Tests for | {8}------------------------------------------------ | Test Endpoint | Test Method | |---------------------------------------------------------|------------------------------------------------------------------------------------------------------| | | Irritation and Skin Sensitization. | | Acute Systemic and Material Mediated Pyrogenicity | ISO 10993-11: 2017 Biological Evaluation of Medical Devices Part 11: Tests for Systemic Toxicity. | ### J. Chronic Animal Study A chronic animal study was conducted according to FDA quidance, "Premarket Notification (510(k)) Submissions for Bipolar Electrosurgical Vessel Sealers for General Surgery" Guidance for Industry and Food and Drug Administration Staff, issued on August 15, 2016; and "Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery" Guidance for Industry and Food and Drug Administration Staff, issued on March 9, 2020. The study evaluated the performance of the ConMed Unify ESU with the CleanSeal 5mm Maryland vessel sealing handpiece (Test system) in comparison to the Valleylab FT10 ESU with the LigaSure Maryland with Nanocoating, 37 cm (Predicate system). After 21 days in the porcine model, the treatment of vascular structures (i.e., arteries, veins, and arterio-venous [A/V] bundles) with the ConMed Unify ESU with the CleanSeal 5mm Maryland vessel sealing hand piece was determined to result in the effective sealing of treated vessels. ### K. Reprocess The Unify Reusable Bipolar Resection Cable (BPR Cable) was tested to be compatible with ConMed Unify ESU and Karl Storz or Richard Wolf resectoscopes. The BPR Cable may be cleaned and sterilized up to 50 use cycles. The BPR Cable is designed and manufactured as a reusable device in accordance with FDA Guidance "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling" and FDA recognized consensus standard ISO 17664:2017 Processing of health care products - Information to be provided by the medical device manufacturer for the processing of medical devices. ### L. Substantial Equivalence The differences between the predicate devices and the proposed device do not raise any new risks of safety or efficacy. Supporting information per this premarket submission, including but not limited to the bench tests, tissue validation, chronical animal study and the benefit-risk analysis, confirms that the Unify MEP is safe and effective for its intended use and is substantially equivalent in design, intended use, principals of operation, and technical characteristics to the ConMed HelixAR and Valleylab FT10 Electrosurgical Generators. The CleanSeal Vessel Sealer, in conjunction with Unify MEP, is also substantially equivalent to the reference device LigaSure Maryland Jaw Sealer/Divider (K170869) used with the predicate ValleyLab FT10.