K232159 · Carl Zeiss Meditec, AG · GWG · Sep 21, 2023 · Neurology
Device Facts
Record ID
K232159
Device Name
QEVO System
Applicant
Carl Zeiss Meditec, AG
Product Code
GWG · Neurology
Decision Date
Sep 21, 2023
Decision
SESE
Submission Type
Special
Regulation
21 CFR 882.1480
Device Class
Class 2
Indications for Use
The QEVO System is intended for viewing internal surgical sites during general surgical procedures and for use in visualization of ventricles and structures within the brain during neurological surgical procedures as well as for viewing internal surgical sites during anterior and posterior spinal procedures, such as nucleotomy, discectomy, and foraminotomy.
Device Story
QEVO System consists of rigid endoscope and Endoscope Control Unit (ECU); captures internal surgical site images via rod lenses and CMOS sensor; transmits light via fiber optics from integrated LED source. System integrates with validated Zeiss host display devices (microscopes/monitors) for visualization. Used in OR by surgeons for general, neurological, and spinal procedures. Provides 2D visualization to assist surgical navigation and decision-making; benefits include enhanced visualization of internal anatomy during minimally invasive or open procedures.
Clinical Evidence
Bench testing only. No clinical data provided. Performance testing included optical safety (IEC 62471:2006) and biocompatibility (ISO 10993) for the insertion tube.
Technological Characteristics
Rigid endoscope with 45° view, 100° FOV, 5-30mm depth of field. 2MP CMOS sensor, 642 TV lines resolution. Integrated LED light source. Reusable; manual/automated cleaning and sterilization. Electrical safety: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-18.
Indications for Use
Indicated for patients undergoing general, neurological (ventricles/brain structures), or spinal (nucleotomy, discectomy, foraminotomy) surgical procedures requiring visualization of internal surgical sites.
Regulatory Classification
Identification
A neurological endoscope is an instrument with a light source used to view the inside of the ventricles of the brain.
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September 21, 2023
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Carl Zeiss Meditec, Inc. % Chaitali Gawde Senior Regulatory Affairs Specialist 5300 Central Parkway Dublin, California 94568
## Re: K232159
Trade/Device Name: QEVO System Regulation Number: 21 CFR 882.1480 Regulation Name: Neurological Endoscope Regulatory Class: Class II Product Code: GWG Dated: August 23, 2023 Received: August 24, 2023
## Dear Chaitali Gawde:
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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,
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Adam D. Pierce, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K232159
Device Name QEVO System
### Indications for Use (Describe)
The QEVO System is intended for viewing internal surgical sites during general surgical procedures and for use in visualization of ventricles and structures within the brain during neurological surgical procedures as well as for viewing internal surgical sites during anterior spinal procedures, such as nucleotomy, discectory, and foraminotomy.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <div style="display:flex; align-items:center;"><span style="font-size:20px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D)</div> |
|------------------------------------------------------------------------------------------------------------------------------------------|
| <div style="display:flex; align-items:center;"><span style="font-size:20px;">☐</span> Over-The-Counter Use (21 CFR 807 Subpart C)</div> |
| > Prescription Use (Part 21 CFR 801 Subpart D)
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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In accordance with 21 CFR 807.92 the 510(k) Summary for the QEVO System is provided below.
#### 1. SUBMITTER
| Applicant: | Carl Zeiss Meditec AG<br>Goeschwizer Strasse 51-52<br>D-07745 Jena<br>Germany |
|-------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Primary Correspondent | Chaitali Gawde<br>Senior Regulatory Affairs Specialist<br>Carl Zeiss Meditec, Inc.<br>5300 Central Parkway Dublin, CA 94568<br>(224) 300-3992 Phone<br>E-mail: chaitali.gawde@zeiss.com (preferred) |
| Secondary Correspondent | Maria Golovina<br>Head of Regulatory Affairs<br>Carl Zeiss Meditec, Inc.<br>5300 Central Parkway Dublin, CA 94568<br>(925) 216-1078 Phone<br>E-mail: maria.golovina@zeiss.com<br>(preferred) |
| Date Prepared: | |
September 21, 2023
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#### DEVICE 2.
| Device Trade Name: | QEVO System |
|--------------------|----------------------------------------|
| Common Name: | Neurological endoscope |
| Classification: | 21 CFR 882.1480 Neurological endoscope |
| Regulatory Class: | II |
| Product Code: | GWG |
#### 3. PREDICATE DEVICE (K170667)
| Predicate Device: | QEVO System with KINEVO 900 |
|-------------------|----------------------------------------|
| Manufacturer: | Carl Zeiss Meditec AG |
| Classification: | 21 CFR 882.1480 Neurological endoscope |
| Regulatory Class: | II |
| Product Code: | GWG |
#### 4. DEVICE DESCRIPTION
The QEVO System comprises of the QEVO ECU (Endoscope Control Unit) and QEVO endoscope. The system is intended for viewing internal surgical sites and for use in visualization during general and certain neurosurgical and spinal procedures.
The QEVO System has to be installed and integrated with a host display device (surgical microscope, a monitor, etc). Requirements for physical integration, connectivity, power supply, display resolution, and software integration are established and tested.
#### INTENDED USE/INDICATIONS FOR USE న్.
The QEVO System is intended for viewing internal surgical sites during general surgical procedures and for use in visualization of ventricles and structures within the brain during neurological procedures as well as for viewing internal surgical sites during anterior and posterior spinal procedures, such as nucleotomy, discectomy, and foraminotomy.
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#### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE 6.
| Table 1. Subject to Predicate Device Comparison Table | |
|-------------------------------------------------------|--|
|-------------------------------------------------------|--|
| Device Comparison<br>Table Attribute | QEVO<br>System<br>(K232159)<br>Subject Device | QEVO System with KINEVO 900<br>(K170667)<br>Predicate Device | Equivalency Analysis |
|-------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Carl Zeiss Meditec AG | Carl Zeiss Meditec AG | Identical |
| 510(k) Number | K232159 | K170667 | N/A |
| Device Name | QEVO System | QEVO System with KINEVO 900 | N/A |
| Intended Use | The QEVO System is intended for<br>viewing internal surgical sites during<br>general surgical procedures and for use<br>in visualization of ventricles and<br>structures within the brain during<br>neurological surgical procedures as well<br>as for viewing internal surgical sites<br>during anterior and posterior spinal<br>procedures, such as nucleotomy,<br>discectomy, and foraminotomy. | The KINEVO 900 with QEVO System<br>is intended for viewing internal surgical<br>sites during general surgical procedures<br>and for use in visualization of<br>ventricles and structures within the<br>brain during neurological surgical<br>procedures as well as for viewing<br>internal surgical sites during anterior<br>and posterior spinal procedures, such as<br>nucleotomy, discectomy, and<br>foraminotomy. | Equivalent<br>Since, system is<br>disconnected from a<br>specific model of<br>surgical microscope<br>while the QEVO System<br>portion remains<br>identical. |
| Classification Regulation<br>Product Code | 882.1480, Class II<br>Neurological endoscope<br>GWG | 882.1480, Class II<br>Neurological endoscope<br>GWG | Identical |
| System Components | Rigid endoscope, ECU | Rigid endoscope, ECU | Identical |
| Compatible Host Display<br>Device | Any Zeiss device that is validated to meet<br>the QEVO requirements for physical<br>integration, connectivity, power supply,<br>display resolution, and software<br>integration | KINEVO 900 | Equivalent<br>Connectivity parameters<br>identical to those on the<br>KINEVO 900 are<br>available on other Zeiss<br>devices. |
| Light Transmission | Light source in endoscope main body,<br>light transmission through insertion tube<br>via fiber optics | Light source in endoscope main body,<br>light transmission through insertion<br>tube via fiber optics | Identical |
| Device Comparison<br>Table Attribute | QEVO<br>System<br>(K232159)<br>Subject Device | QEVO System with KINEVO 900<br>(K170667)<br>Predicate Device | Equivalency Analysis |
| Light Source | Integrated LED (intensity adjustable) | Integrated LED (intensity adjustable) | Identical |
| Image Transmission | Rigid rod lenses + CMOS imaging sensor<br>in endoscope main body | Rigid rod lenses + CMOS imaging sensor<br>in endoscope main body | Identical |
| Direction of View | 45° | 45° | Identical |
| Field of View | 100° | 100° | Identical |
| Depth of Field | 5-30mm | 5-30mm | Identical |
| Image Resolution | 2 Mega Pixel (Full HD imager)<br>642 TV lines (optical resolution at 15% MTF) | 2 Mega Pixel (Full HD imager)<br>642 TV lines (optical resolution at 15% MTF) | Identical |
| Image Display | External monitor | External monitor | Identical |
| 2D / 3D Imaging | 2D Only | 2D Only | Identical |
| Recording | Via USB-port | Via USB-port | Identical |
| Insertion Tube Working<br>Length | 120mm | 120mm | Identical |
| Insertion Tube Outer<br>Diameter | 3.6mm | 3.6mm | Identical |
| Single Use/ Reusable | Reusable | Reusable | Identical |
| Reprocessing | Manual and automated cleaning,<br>sterilization | Manual and automated cleaning,<br>sterilization | Identical |
| Electrical Safety | IEC 60601-1, IEC 60601-1-2, IEC<br>60601-2-18 compliant | IEC 60601-1, IEC 60601-1-2, IEC<br>60601-2-18 compliant | Identical |
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#### 7. SUMMARY OF STUDIES
### Sterilization and Shelf Life
The QEVO endoscope is used sterile but is not provided sterilized before first use. It must also be end user cleaned and sterilized between uses. The reprocessing instructions have not been modified and are identical to the predicate device.
## Biocompatibility
The only patient contacting component of the subject device is the Insertion tube. The contact category for this component is Tissue/Bone/Dentin Communicating, < 24 hours. The materials were testing in accordance with ISO 10993.
## Performance Testing - Bench
There have been no changes in the System Requirements and Verification since the predicate. The following performance testing was provided, to support the substantial equivalence of the subject device:
- . Optical Safety - The QEVO Endoscope and ECU were assessed for conformity with the relevant requirements of IEC 62471:2006: Photobiological safety of lamps and lamp systems and were found to comply.
The determination of substantial equivalence was not based on an assessment of performance data.
#### 8. CONCLUSION
The OEVO System and the predicate device are both intended to be used for viewing internal surgical sites during surgical procedures. The indications for use are identical to those of the predicate device with an exception, that the subject device isn't intended to be used with a specific model of surgical microscope.
The technological characteristics and risk profile of the subject device is identical to the predicate device; and therefore, are identical in their relationship to safety and effectiveness.
Testing methods are identical to those of the predicate device; are identical in their relationship to safety and effectiveness.
Therefore, the subject device meets the requirements for substantial equivalence to the predicate device.
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.