K190239 · Olympus Medical Systems Corp. · KTI · Dec 10, 2019 · Ear, Nose, Throat
Device Facts
Record ID
K190239
Device Name
Single Use Aspiration Needle
Applicant
Olympus Medical Systems Corp.
Product Code
KTI · Ear, Nose, Throat
Decision Date
Dec 10, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 874.4680
Device Class
Class 2
Indications for Use
This instrument has been designed to be used with ultrasound guided fine needle aspiration (FNA) of submucosal and extramural lesions of the tracheobronchial tree.
Device Story
Single Use Aspiration Needle (NA-U401SX-4025N) is a manual instrument used with ultrasound endoscopes for fine needle aspiration (FNA) of tracheobronchial lesions. The device consists of a handle, insertion section (sheath, needle, stylet), and an aspiration port for a syringe. The needle tube features dimples for echo enhancement, allowing visualization on ultrasound images. During operation, the physician advances the needle from the sheath into the target tissue under ultrasound guidance; negative pressure is applied via an attached syringe to collect specimens. The device is intended for use in clinical settings by trained physicians. It facilitates tissue sampling for diagnostic purposes, potentially improving diagnostic accuracy for submucosal and extramural lesions.
Clinical Evidence
No clinical study was performed to demonstrate substantial equivalence. Evidence is based on bench testing, including piercing, ultrasound visibility, needle extraction/retraction, aspiration, endoscope compatibility, handle function, joint pull strength, and breakage strength. Biocompatibility and sterilization/shelf-life testing were also conducted.
Technological Characteristics
Materials: Polytetrafluoroethylene (PTFE), Stainless Steel, Nickel titanium. Sensing: Ultrasound-enhanced needle tip (dimpled) for visualization. Energy: Manual operation. Form factor: Single-use aspiration needle with handle and insertion sheath. Sterilization: ETO sterile. Standards: ISO 10993-1, ISO 10993-5, ISO 10993-10, ISO 10993-11, ISO 11135, ISO 10993-7, ISO 11607-1/2, ASTM F1980-16, ISO 14971.
Indications for Use
Indicated for ultrasound-guided fine needle aspiration (FNA) of submucosal and extramural lesions of the tracheobronchial tree in patients requiring tissue or cell collection.
Regulatory Classification
Identification
A bronchoscope (flexible or rigid) and accessories is a tubular endoscopic device with any of a group of accessory devices which attach to the bronchoscope and is intended to examine or treat the larynx and tracheobronchial tree. It is typically used with a fiberoptic light source and carrier to provide illumination. The device is made of materials such as stainless steel or flexible plastic. This generic type of device includes the rigid ventilating bronchoscope, rigid nonventilating bronchoscope, nonrigid bronchoscope, laryngeal-bronchial telescope, flexible foreign body claw, bronchoscope tubing, flexible biopsy forceps, rigid biopsy curette, flexible biopsy brush, rigid biopsy forceps, flexible biopsy curette, and rigid bronchoscope aspirating tube, but excludes the fiberoptic light source and carrier.
Echotip Ultra Endobronchial High Definition Ultrasound Needle, Echotip Procore Endobronchial High Definition Ultrasound Biopsy Needle (K160229)
Submission Summary (Full Text)
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December 10, 2019
Olympus Medical Systems Corp. % Daphney Germain-Kolawole Senior Project Manager, Regulatory Affairs Olympus Corporation of the Americas 3500 Corporate Parkway PO Box 610 Center Valley, Pennsylvania 18034-0610
Re: K190239
Trade/Device Name: Single Use Aspiration Needle Regulation Number: 21 CFR 874.4680 Regulation Name: Bronchoscope (Flexible Or Rigid) And Accessories Regulatory Class: Class II Product Code: KTI Dated: November 25, 2019 Received: November 26, 2019
Dear Daphney Germain-Kolawole:
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.
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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,
for James J. Lee Ph.D. Assistant Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K190239
Device Name Single Use Aspiration Needle
Indications for Use (Describe)
This instrument has been designed to be used with ultrasound guided fine needle aspiration (FNA) of submucosal and extramural lesions of the tracheobronchial tree.
| Type of Use (Select one or both, as applicable) | |
|--------------------------------------------------------------|--|
| <div><span style="text-decoration: overline;">☒</span></div> | |
X Prescription Use (Part 21 CFR 801 Subpart D)
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the word "OLYMPUS" in large, bold, dark blue letters. The letters are closely spaced and appear to be a sans-serif font. A thin, horizontal gold bar is located directly beneath the word, adding a subtle accent to the logo. The background is plain white.
November 25, 2019
# 510(k) Summary
### 1 GENERAL INFORMATION
■ 510(k) Submitter: OLYMPUS MEDICAL SYSTEMS CORP. 2951 Ishikawa-cho, Hachioji-shi, Tokyo, Japan 192-8507
■ Contact Person: Lisa M. Boyle Olympus Corporation of the Americas 3500 Corporate Parkway PO Box 610 Center Valley, PA 18034-0610, USA Phone: 484-896-3676 Fax: 484-896-7128 Email: lisa.boyle@olympus.com
#### 2 DEVICE IDENTIFICATION
| ■ Device Name | Single Use Aspiration Needle |
|------------------------|--------------------------------------------------|
| ■ Model Name | NA-U401SX-4025N |
| ■ Common Name | Aspiration Needle |
| ■ Regulation Number | 21 CFR 874.4680 |
| ■ Regulation Name | Bronchoscope (flexible or rigid) and accessories |
| ■ Regulatory Class | II |
| ■ Product Code | KTI |
| ■ Classification Panel | Ear Nose & Throat |
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Image /page/4/Picture/0 description: The image shows the word "OLYMPUS" in large, bold, blue letters. The letters are sans-serif and appear to be a custom font. A thin, horizontal, yellow bar is located underneath the word. The logo is simple and modern.
### 3 PREDICATE DEVICE
#### ■ Predicate device
| Device name | 510(k) Submitter | 510(k) No. |
|----------------------------------|------------------------------------------|------------|
| ViziShot 2 FLEX (NA-U403SX-4019) | Olympus Surgical Technologies<br>America | K163469 |
#### ■ Reference device
| Device name | 510(k) Submitter | 510(k) No. |
|------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|------------|
| Single Use Aspiration Needle<br>NA-U401SX | OLYMPUS MEDICAL<br>SYSTEMS CORP. | K160098 |
| Echotip Ultra Endobronchial High<br>Definition Ultrasound Needle, Echotip<br>Procore Endobronchial High<br>Definition Ultrasound Biopsy Needle | Cook Ireland Ltd. | K160229 |
#### 4 DEVICE DESCRIPTION
#### ■ General Description of the subject device
The Single Use Aspiration Needle NA-U401SX-4025N (aka ViziShot 2) is used in conjunction with Olympus ultrasound endoscopes for ultrasound guided fine needle aspiration (FNA).
The subject devices consist of a handle section and insertion. The handle section is connected to the endoscope's instrument channel port via the single use adapter biopsy valve (MAJ-1414). The insertion section is composed of the sheath, needle and stylet. The needle tube is stored in the sheath and extended from the sheath to puncture the target tissue to collect specimen by moving the needle slider on the handle. A syringe is attached to the aspiration port on the handle section to aspirate the specimen. The needle is dimpled for echo enhancement.
The subject devices will be sold with or without the medallion syringe manufactured by Merit Medical, which consists of the VACLOK Syringe and Stopcock.
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# ■ Principle of Operation
Ultrasound emitted by the ultrasound transducer of the ultrasound endoscope diffusely reflects at dimples on the echo-enhanced region of the needle tube.
The ultrasound transducer detects the part of the ultrasound which diffusely reflects and the echo-enhanced region is indicated on an ultrasound image.
The needle tube and stylet are extracted from the sheath by moving the needle slider to the distal side and is drawn into the sheath by moving the needle slider in the counter direction.
The subject devices are used with specified ultrasound endoscopes for aspirating tissue or cells by piercing the target area in an ultrasound image and attaching the medallion syringe to the aspiration port on the handle section.
#### 5 INDICATIONS FOR USE
This instrument has been designed to be used with ultrasound endoscopes for ultrasound guided fine needle aspiration (FNA) of submucosal and extramural lesions of the tracheobronchial tree.
# 6 COMPARISON OF TECHNOLOGY CHARACTERISTICS WITH THE PREDICATE DEIVCE
The Single Use Aspiration Needle NA-U401SX-4025N has the same technological characteristics and design as the predicate device except for the following new features:
- Needle width
- Needle shape
- Needle tip shape
- Sheath composition
Validation from non-clinical testing demonstrated that these technological features do not raise any new issues of safety or effectiveness of the subject device.
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A side by side comparison of the subject device and the predicate device is provided below.
| | Subject Device | Predicate Device (PD) |
|--------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Item | NA-U401SX-4025N | NA-U403SX-4019 (K163469) |
| Indications for<br>Use | This instrument has been designed<br>to be used with ultrasound<br>endoscopes for ultrasound guided<br>fine needle aspiration (FNA) of<br>submucosal and extramural lesions<br>of the tracheobronchial tree. | The ViziShot 2 FLEX has been<br>designed to be used with<br>ultrasound endoscopes for<br>ultrasound guided fine needle<br>aspiration (FNA) of submucosal<br>and extramural lesions of the<br>tracheobronchial tree. Do not use<br>this device for any purpose other<br>than its intended use. |
| Regulation<br>Number | Similar to PD | 874.4680 |
| Regulation<br>Name | Identical | Bronchoscope (flexible or rigid)<br>and accessories |
| Regulatory<br>Class | Identical | II |
| Product Code | Identical | KTI |
| Classification<br>Panel | Identical | Ear Nose & Throat |
| Syringe (for<br>aspiration) | Identical | Equipped |
| Mode of action | Identical | Single/multiple puncture and<br>aspirate |
| Energy used | Identical | Manual |
| Visualization | Identical | Ultrasound guided |
| Product<br>Specification<br>and Properties | Bench testing confirms that the NA-U401SX-4025N meets its essential<br>performances, which are technologically equivalent to those of the<br>reference device. | |
| Reprocessing | Identical | Single Use, ETO Sterile |
| Needle Width | 25G | 19G |
| Patient<br>Contacting<br>Materials | Polytetrafluoroethylene, Stainless<br>Steel, Nickel titanium | Stainless Steel, PTFE, PEBAX,<br>Nitinol |
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## 7 PERFORMANCE DATA
The following performance data was provided in support of the substantial equivalence determination.
#### 1) Sterilization/Shelf-life testing
Sterilization/shelf-life testing for the Single Use Aspiration Needle NA-U401SX-4025N was conducted in accordance with the FDA's Guidance for Industry and Food and Drug Administration Staff, "Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile".
Accelerated aging test for the NA-U401SX-4025N was conducted in accordance with ASTM F1980-16, the standard guide for accelerated aging of sterile barrier systems for medical devices. The real-time aging test for three years will be performed to demonstrate longer stability and support the results of the accelerated aging test.
#### 2) Biocompatibility testing
Biocompatibility testing for the Single Use Aspiration Needle NA-U401SX-4025N was conducted in accordance with the FDA's Guidance for Industry and Food and Drug Administration Staff, Use of International Standard ISO 10993-1:2009, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The following tests were completed:
- Cytotoxicity
- . Intracutaneous Study
- Sensitization
- . Systemic Toxicity
- . Pyrogen Study
#### 3) Performance testing - Bench
Bench testing for the Single Use Aspiration Needle NA-U401SX-4025N as listed below was conducted to ensure that the subject devices perform as intended and meet design specifications.
- Piercing
- Ultrasound visibility
- Needle extraction and retraction
- Aspiration
- Endoscope compatibility ।
- Handle function ।
- Joint Pull Strength
- Breakage Strength
#### 4) Performance testing - Animal
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Image /page/8/Picture/0 description: The image shows the word "OLYMPUS" in large, bold, blue letters. The letters are spaced closely together, and the word is centered in the image. There is a registered trademark symbol to the right of the word. The background is white.
No animal study was performed to demonstrate substantial equivalence.
#### 5) Performance testing - Clinical
No clinical study was performed to demonstrate substantial equivalence.
#### 6) Risk analysis
A Risk analysis for the Single Use Aspiration Needle NA-U401SX-4025N was conducted in accordance with established in-house acceptance criteria based on ISO 14971:2007. The design verification tests and their acceptance criteria were identified and performed as a result of this risk analysis assessment.
The following standards have been applied to the Single Use Aspiration Needle NA-U401SX-4025N.
- ISO 10993-1: 2009
- AAMI/ANSI/ISO 10993-5: 2009
- ISO 10993-10: 2010
- ISO 10993-11: 2006
- ISO 11135: 2014
- ISO 10993-7: 2008+Cor1
- ISO 11607-1: 2006+A1
- ISO 11607-2: 2006+A1
- ASTM F1980-16
- ISO 14971: 2007
#### 8 CONCLUSIONS
Based on the indications for use, technological characteristics, performance testing and technological comparison to the predicate devices, the NA-U401SX-4025N raise no new issue of safety and effectiveness. Therefore, the NA-U401SX-4025N is substantially equivalent to the predicate devices.
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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.