The Captivator and Captiflex Polypectomy Snares are used endoscopically in the removal and/or cauterization of diminutive polyps, sessile polyps, pedunculated polyps and tissue from within the GI tract.
Device Story
Single-use polypectomy snares consisting of flexible wire cable and loop; operated via three-ring handle. Device passed through endoscope; loop extended/retracted to capture tissue. Monopolar electrical current delivered to cut and cauterize polyps. Used in clinical GI endoscopy settings by physicians. Output is physical tissue removal/cauterization. Benefits include effective endoscopic polyp resection.
Clinical Evidence
Bench testing only. Testing included loop extension/retraction functionality, snare actuation force, and comparative maximum cutting force on a non-compressible pin gauge. Modified snares met all pre-defined acceptance criteria and demonstrated performance comparable to predicate devices.
Technological Characteristics
Flexible wire cable and loop; three-ring handle mechanism. Monopolar electrosurgical energy source. Single-use. Various loop sizes (27mm, 30mm, 33mm) and shapes (crescent, oval, hexagonal).
Indications for Use
Indicated for endoscopic removal and/or cauterization of diminutive, sessile, or pedunculated polyps and tissue within the GI tract.
Regulatory Classification
Identification
An endoscopic electrosurgical unit and accessories is a device used to perform electrosurgical procedures through an endoscope. This generic type of device includes the electrosurgical generator, patient plate, electric biopsy forceps, electrode, flexible snare, electrosurgical alarm system, electrosurgical power supply unit, electrical clamp, self-opening rigid snare, flexible suction coagulator electrode, patient return wristlet, contact jelly, adaptor to the cord for transurethral surgical instruments, the electric cord for transurethral surgical instruments, and the transurethral desiccator.
{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 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.
October 8, 2020
Boston Scientific Corporation Stephanie Gorman Sr. Regulatory Affairs Specialist 100 Boston Scientific Way Marlborough, MA 01752
Re: K202478
Trade/Device Name: Captivator Single-Use Polypectomy Snares (27mm, 30mm, 33mm), Captiflex Single-Use Polypectomy Snares (27mm) Regulation Number: 21 CFR 876.4300 Regulation Name: Endoscopic Electrosurgical Unit and accessories Regulatory Class: II Product Code: FDI Dated: August 27, 2020 Received: August 28, 2020
Dear Stephanie Gorman:
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
{1}------------------------------------------------
requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801 and Part 809 ); medical device reporting (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 (OS) 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,
For Shanil P. Haugen, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known) K202478
#### Device Name
Captivator Single-Use Polypectomy Snares (27mm, 30mm, 33mm) Captiflex Single-Use Polypectomy Snares (27mm)
Indications for Use (Describe)
The Captivator and Captiflex Polypectomy Snares are used endoscopically in the removal and/or cauterization of diminutive polyps, sessile polyps, pedunculated polyps and tissue from within the GI tract.
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------|-----------------------------------------------------------|
| <span></span> Prescription Use (Part 21 CFR 801 Subpart D) | <span></span> Over-The-Counter Use (21 CFR 801 Subpart C) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
### 510(k) SUMMARY
# 1. Submitter
Boston Scientific Corporation 100 Boston Scientific Way Marlborough, MA 01752
| Primary Contact: | Stephanie Gorman<br>Sr. Regulatory Affairs Specialist, Endoscopy |
|--------------------|------------------------------------------------------------------|
| Telephone: | (508) 683-5692 |
| E-mail: | Stephanie.Gorman@bsci.com |
| Secondary Contact: | Ashley Santos<br>Director, Regulatory Affairs Endoscopy |
| Telephone: | (508) 683-4359 |
| E-mail: | Ashley.Santos@bsci.com |
Date Prepared: August 27, 2020
## 2. Proposed Device
| Trade Name: | Captivator Single-Use Polypectomy Snares (27mm, 30mm, 33mm)<br>Captiflex Single-Use Polypectomy Snares (27mm) |
|---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Polypectomy Snares |
| Product Code: | FDI, FGX |
| Regulation Class: | Class II |
| Regulation Number: | 876.4300 |
| Regulation Name: | Endoscopic Electrosurgical Unit and accessories |
| 3. Predicate Device | |
| Trade Name: | Captivator Single-Use Polypectomy Snares<br>Captivator II Single-Use Polypectomy Snares<br>Captiflex Single-Use Polypectomy Snares<br>Profile Single-Use Polypectomy Snares<br>Sensation Single-Use Polypectomy Snares<br>Rotatable Single-Use Polypectomy Snares |
| Manufacturer: | Boston Scientific Corporation |
| Clearance Number: | K131700 |
| Common Name: | Polypectomy Snares |
| Product Code: | FDI, FGX |
| Regulation Class: | Class II |
| Regulation Number: | 876.4300 |
| Regulation Name: | Endoscopic Electrosurgical Unit and accessories |
{4}------------------------------------------------
# 4. Device Description
The Captivator and Captiflex Single-Use Polypectomy Snares consist of a flexible wire cable and loop which can be extended and retracted from the snare's flexible outer sheath using a three-ring handle. When passed through an endoscope the snare can be activated to deliver a monopolar electrical current to cut and cauterize tissue with the loop.
Table 5-1 lists the Captivator and Captiflex Single-Use Polypectomy Snares within scope of this 510(k).
| Sellable<br>UPN/Product Code<br>(Box Quantity) | UPN/Product Code<br>(Single Unit) | Product Description | Loop Size |
|------------------------------------------------|-----------------------------------|-----------------------------------------|-----------|
| M00562371 (Box 10) | M00562370 | Captivator Medium Crescent<br>Stiff | 27mm |
| M00562401 (Box 10) | M00562400 | Captiflex Medium Oval<br>Flexible | 27mm |
| M00562402 (Box 40) | | | |
| M00561311 (Box 10) | M00561310 | Captivator Large Oval<br>Medium Stiff | 30mm |
| M00562341 (Box 10) | M00562340 | Captivator Medium<br>Hexagonal Stiff | 27mm |
| M00562321 (Box 10) | M00562320 | Captivator Medium Oval Stiff | 27mm |
| M00561291 (Box 10) | M00561290 | Captivator Extra Large Round<br>Stiff | 33mm |
| M00562391 (Box 10) | M00562390 | Captivator Large Oval Thin<br>Wire Flex | 30mm |
Table 5-1. Impacted Captivator and Captiflex Single-Use Polypectomy Snares
### 5. Indications for Use
The Captivator and Captiflex Polypectomy Snares are used endoscopically in the removal and /or cauterization of diminutive polyps, sessile polyps, pedunculated polyps and tissue from within the GI tract.
### 6. Technological Characteristics
The modified Captivator (27mm, 30mm and 33mm) and Captiflex (27mm) Polypectomy Snares share the same intended use, indications for use, and fundamental scientific technology as the predicate devices (K131700).
### 7. Performance Data
Bench testing has been performed on the Captivator (27mm, 33mm) and Captiflex (27mm) Single-Use Polypectomy Snares to demonstrate that the modified handle design meets required performance specifications and has restored performance to that of the predicate Captivator and Captiflex Snares (K131700). The testing included the following:
- Loop Extension Functionality
- Loop Retraction Functionality
- Snare Actuation Force ●
{5}------------------------------------------------
- . Maximum Cutting Force
The modified Captivator and Captiflex Snares met all pre-defined specifications identified for snare loop extension functionality, retraction functionality, and actuation force in a simulated-use tortuous path. All snare configurations were tested for loop extension and retraction functionality. For snare actuation force, the largest snare (M00561290) was tested to represent all snares within scope of the change as a worst-case with regards to friction and resistance.
In addition, comparative maximum cutting force testing was performed on the predicate Captivator, Captiflex and Sensation Single-Use Polypectomy Snares and the modified snares. This bench testing was performed by measuring the maximum allowable force that could be applied by the snare on a non-compressible pin gauge. A summary of the maximum cutting force test results can be found in Table 5-2 and Table 5-3 below.
#### Table 5-2. Predicate Captivator (27mm, 30mm, 33mm), Captiflex (27mm) and Sensation (30mm) Single-Use Polypectomy Snares Maximum Cutting Force
| UPN | Description | Mean (lbf) | Standard Deviation (lbf) |
|-----------|----------------------------------------------------|------------|--------------------------|
| M00562400 | Captiflex Medium Oval<br>Flexible – 27mm | 5.4 | 0.54 |
| M00562390 | Captivator Large Oval Thin<br>Wire Flexible – 30mm | 4.4 | 0.38 |
| M00561310 | Captivator Large Oval<br>Medium Stiff – 30mm | 5.0 | 0.34 |
| M00561290 | Captivator II Extra Large<br>Rounded Stiff – 33mm | 5.7 | 0.36 |
| M00562650 | Sensation Large Oval<br>Medium Stiff – 30mm | 12.0 | 0.55 |
#### Table 5-3. Modified Captivator (27mm, 30mm, 33mm) and Captiflex (27mm) Single-Use Polypectomy Snares Maximum Cutting Force
| UPN | Description | Mean (lbf) | Standard Deviation (Ibf) |
|-----------|---------------------------------------------|------------|--------------------------|
| M00562400 | Captiflex Medium Oval<br>Flexible | 6.4 | 0.47 |
| M00562390 | Captivator Large Oval Thin<br>Wire Flexible | 6.2 | 0.39 |
| M00561310 | Captivator Large Oval<br>Medium Stiff | 6.7 | 0.85 |
| M00561290 | Captivator II Extra Large<br>Rounded Stiff | 7.1 | 0.77 |
| M00562320 | Captivator Medium Oval Stiff | 7.4 | 0.81 |
| M00562340 | Captivator Medium<br>Hexagonal Stiff | 6.2 | 0.57 |
| M00562370 | Captivator Medium Crescent<br>Stiff | 6.8 | 0.45 |
All sizes of the modified Captivator and Captiflex Snares within scope of the 510(k) were tested.
{6}------------------------------------------------
The bench testing performed demonstrates that the modified Captivator Snares are substantially equivalent to the predicate snares (K131700).
# 8. Conclusion
The modified Captivator (27mm, 30mm, 33mm) and Captiflex (27mm) Polypectomy Snares met all bench testing acceptance criteria. Boston Scientific has demonstrated that the modified Captivator (27mm, 30mm, 33mm) and Captiflex (27mm) Polypectomy Snares are substantially equivalent to the predicate devices (K131700).
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.