UNIDRIVE S II ENT, DrillCut-X II-35 Shaver Handpiece, DrillCut-X II-35 N Shaver Handpiece
K200318 · KARL STORZ Endoscopy-America, Inc. · ERL · Oct 22, 2020 · Ear, Nose, Throat
Device Facts
Record ID
K200318
Device Name
UNIDRIVE S II ENT, DrillCut-X II-35 Shaver Handpiece, DrillCut-X II-35 N Shaver Handpiece
Applicant
KARL STORZ Endoscopy-America, Inc.
Product Code
ERL · Ear, Nose, Throat
Decision Date
Oct 22, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 874.4250
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The UNIDRIVE® S III ENT system consists of an active control unit used in conjunction with the High-Speed Micro Motor and DrillCut-X® II Shaver handpieces. The system is intended for use by qualified surgeons to provide controlled cutting, drilling, debriding, sawing, and shaving for the ablation, excision, removal, or transection of tissue or bone during head, neck, ENT, or otoneurological surgical procedures.
Device Story
UNIDRIVE S III ENT is a motorized surgical system; consists of active control unit, high-speed micro motor, and DrillCut-X II shaver handpieces. Used by surgeons in OR/clinical settings for cutting, drilling, debriding, sawing, and shaving tissue or bone during head, neck, ENT, or otoneurological procedures. System provides controlled mechanical action; modifications include addition of DrillCut-X II-35 and II-35 N handpieces with increased rotational speed (35,000 RPM). Output is mechanical rotation for surgical instruments; assists surgeons in tissue/bone removal. Benefits include enhanced surgical precision and efficiency in ENT procedures.
Clinical Evidence
No clinical data. Substantial equivalence established via non-clinical bench testing, including electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), risk management (ISO 14971), biocompatibility (ISO 10993), and cleaning/sterilization validation (ANSI/AAMI standards). Bench testing confirmed performance specifications for rotation speed and torque.
Technological Characteristics
Motorized surgical drill system. Components: control unit, high-speed micro motor, shaver handpieces. Rotational speed: up to 35,000 RPM. Electrical safety: Class I. Standards: IEC 60601-1, IEC 60601-1-2, ISO 14971, ISO 10993, ANSI/AAMI ST81, ST79, TIR 12, TIR 39, ISO 17665-1/2. Reprocessing: validated cleaning and sterilization methods.
Indications for Use
Indicated for qualified surgeons performing ablation, excision, removal, or transection of tissue or bone during head, neck, ENT, or otoneurological surgical procedures.
Regulatory Classification
Identification
An ear, nose, and throat electric or pneumatic surgical drill is a rotating drilling device, including the handpiece, that is intended to drive various accessories, such as an ear, nose, and throat bur (§ 874.4140), for the controlled incision or removal of bone in the ear, nose, and throat area.
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October 22, 2020
Karl Storz Endoscopy-America, Inc. Alita McElroy Regulatory Affairs Specialist 2151 E. Grand Avenue El Segundo, California 90245
Re: K200318
Trade/Device Name: UNIDRIVE S II ENT, DrillCut-X II-35 Shaver Handpiece, DrillCut-X II-35 N Shaver Handpiece Regulation Number: 21 CFR 874.4250 Regulation Name: Ear, nose, and throat electric or pneumatic surgical drill Regulatory Class: Class II Product Code: ERL Dated: July 21, 2020 Received: July 23, 2020
Dear Alita McElroy:
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/cfpmr/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
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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.
Joyce C. Lin-S
for Malvina Eydelman, M.D. Director OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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) K200318
Device Name UNIDRIVE S III ENT
#### Indications for Use (Describe)
The UNIDRIVE® S III ENT system consists of an active control unit used in conjunction with the High-Speed Micro Motor and DrillCut-X® II Shaver handpieces. The system is intended for use by qualified surgeons to provide controlled cutting, drilling, debriding, sawing, and shaving for the ablation, excision, removal, or transection of tissue or bone during head, neck, ENT, or otoneurological surgical procedures.
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------|
| <div> <span> </span> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div> <span> </span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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# K200318 510(k) Summary
This 510(k) Summary is being submitted in accordance with the requirements of the Safe Medical Devices Act (SMDA) of 1990 and 21 CFR 807.92. All data included in this document is accurate and complete to the best of KSEA's knowledge.
| Submitter: | KARL STORZ Endoscopy-America, Inc.<br>2151 E. Grand Avenue<br>EI Segundo, CA 90245 |
|-----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Alita McElroy<br>Regulatory Affairs Specialist<br>Phone: (424) 218-8376<br>Fax: (424) 218-8519 |
| Date of Preparation: | October 22, 2020 |
| Type of 510(k)<br>Submission: | Traditional |
| Device<br>Identification: | Trade Name: UNIDRIVE S III ENT<br>Classification Name: Drill, Surgical, ENT (Electric Or<br>Pneumatic) Including Handpiece |
| Regulatory Class: | II |
| Product Code: | ERL |
| Regulation: | 21 CFR 874.4250 (Ear, nose and throat electric or pneumatic<br>surgical drill) |
| Predicate Device(s): | Predicate Device: UNIDRIVE S III ENT (K150969)<br>The predicate device has not been subject to a design-related<br>recall. |
| Device Description: | The UNIDRIVE S III ENT is a motorized surgical device<br>system used for the excision, ablation, removal or transection<br>of bones/tissues during head, neck, ENT, or otoneurological<br>surgical procedures. The system components include a control<br>unit used in conjunction with the High-Speed Micro Motor that<br>houses the high-speed handpieces and DrillCut-X® II Shaver<br>handpieces.<br>The modifications made to the UNIDRIVE® S III ENT system<br>is the addition of the DrillCut-X® II-35 and DrillCut-X® II-35<br>N Shaver handpieces. Additional accessories used with the<br>UNIDRIVE S III ENT system include the shaver blades, sinus<br>burrs and the sinus burr 35k. |
| Intended Use: | The UNIDRIVE S III ENT system consists of an active control<br>unit used in conjunction with the High-Speed Micro Motor and<br>DrillCut-X® II Shaver handpieces. The system is intended for<br>use by qualified surgeons to provide controlled cutting,<br>drilling, debriding, sawing, and shaving for the ablation,<br>excision, removal, or transection of tissue or bone during head,<br>neck, ENT, or otoneurological surgical procedures. |
| Indications For Use: | The UNIDRIVE S III ENT system consists of an active control<br>unit used in conjunction with the High-Speed Micro Motor and<br>DrillCut-X® II Shaver handpieces. The system is intended for<br>use by qualified surgeons to provide controlled cutting,<br>drilling, debriding, sawing, and shaving for the ablation,<br>excision, removal, or transection of tissue or bone during head,<br>neck, ENT, or otoneurological surgical procedures. |
| Technological<br>Characteristics: | The UNIDRIVE S III ENT is a modification of and<br>substantially equivalent to the UNIDRIVE S III ENT<br>(K150969) in terms of its indication for use, principle of<br>operation, patient-contacting materials and reprocessing<br>methods.<br>The subject device includes the addition of the DrillCut-X® II-<br>35 and DrillCut-X® II-35 N Shaver handpieces that have a<br>maximum rotational speed of 35,000 RPM in comparison with<br>the shaver handpieces of the predicate device that have a<br>maximum rotational speed of 12,000 RPM. |
| Non-Clinical<br>Performance Data: | The device has been tested and passed the electrical safety<br>testing and EMC testing, which is certified to be Class I<br>protection against electrical shock.<br>The UNIDRIVE S III ENT system follows the FDA<br>recognized consensus standards and is tested according to the<br>following standards:<br>• IEC 60601-1<br>• IEC 60601-1-2<br>• ISO 14971<br>• ISO 10993 |
| | |
| | Cleaning and sterilization validations were conducted for<br>patient-contacting components. The reprocessing data<br>submitted complies with the following standards:<br>ANSI/AAMI ST81:2004/(R) 2010 ANSI/AAMI ST79: 2010/A4:2013 AAMI TIR 12:2010 ANSI/AAMI/ISO 17665-1:2006 ANSI/AAMI/ISO 17665-2:2009 AAMI TIR 39:2009 The following bench testing was performed to ensure that the<br>UNIDRIVE S III ENT system meets its design specification Inspection of rotation speed and torque Bench testing demonstrated substantial equivalence to the<br>predicate device. |
| Clinical<br>Performance Data: | Clinical testing was not required to demonstrate the substantial<br>equivalence to the predicate device. Non-clinical bench testing<br>was sufficient to assess safety and effectiveness and to<br>establish the substantial equivalence of the modifications. |
| Substantial<br>Equivalence: | The conclusions drawn from the nonclinical test such as the<br>risk evaluation on the modification of the system, biological<br>evaluation summary, cleaning and sterilization summary<br>demonstrated that the subject device is as safe and as effective<br>as the predicate device. Both systems also comply with<br>identical standards and safety testing, where applicable.<br>As such, we concluded that the substantial equivalence of the<br>subject and the predicate device has been met, and the<br>differences between the subject and predicate do not raise new<br>questions of safety and effectiveness. |
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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.