K213697 · Bien-Air Surgery SA · HBC · Oct 31, 2022 · Neurology
Device Facts
Record ID
K213697
Device Name
ORiGO System
Applicant
Bien-Air Surgery SA
Product Code
HBC · Neurology
Decision Date
Oct 31, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.4360
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The ORiGO System is a software-controlled motorized surgical system that includes attachments and tools for cutting bone, and provides irrigation fluid to the surgical site. The ORiGO System is used in the following surgical fields: -For cutting bones in neuro (cranial) and spinal surgeries.
Device Story
ORiGO System is a software-controlled electrical surgery system for use in operating rooms by clinicians. System comprises a control unit, foot pedal, micromotors (NANO, RAPIDO), motorized cranial perforator (PM PERFO), handpieces, attachments, cutting tools, and irrigation line. Device transforms electrical energy into rotational force to drive cutting tools for bone shaping/cutting. Peristaltic pump provides saline irrigation to surgical site. Clinician operates system via foot pedal and console controls; digital speed indication provided. System facilitates bone cutting in neuro/spinal procedures, potentially improving surgical efficiency and precision. Device is intended for professional use in healthcare facilities.
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical bench testing, including electromagnetic compatibility (IEC 60601-1, 60601-1-2), electrical safety (IEC 60601-1-6), software lifecycle (IEC 62304), usability engineering (IEC 62366-1), and biocompatibility (ISO 10993-1, ISO 10993-5, ISO 10993-10, ISO 10993-11, ISO 10993-4/ASTM F756).
Technological Characteristics
Electrical surgical system; console-based with foot pedal control. Materials: Stainless steel, diamond grit, carbide, full carbide. Max speed: 80,000 rpm. Integrated peristaltic irrigation pump. Sterilization: Steam autoclave (AAMI TIR 12, ISO 17664, ISO 17665). Software-controlled; conforms to IEC 62304.
Indications for Use
Indicated for cutting bone in neuro (cranial) and spinal surgeries. Prescription use only.
Regulatory Classification
Identification
An electric cranial drill motor is an electrically operated power source used with removable rotating surgical cutting tools or drill bits on a patient's skull.
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October 31, 2022
Bien-Air Surgery SA % Akiko Dohi Regulatory Scientist Ken Block Consulting, LLC 800 East Campbell Road, Suite 202 Richardson, Texas 75081
Re: K213697
Trade/Device Name: ORiGO System Regulation Number: 21 CFR 882.4360 Regulation Name: Electric Cranial Drill Motor Regulatory Class: Class II Product Code: HBC, HBE Dated: September 30, 2022 Received: September 30, 2022
Dear Akiko Dohi:
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.
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 Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K213697
Device Name ORiGO System
Indications for Use (Describe)
The ORiGO System is a software-controlled motorized system that includes attachments and tools for cutting bone, and provides irrigation fluid to the surgical site.
The ORiGO System is used in the following surgical fields:
-For cutting bones in neuro (cranial) and spinal surgeries.
Type of Use (Select one or both, as applicable)
| <span> <b> Prescription Use (Part 21 CFR 801 Subpart D) </b> </span> |
|-----------------------------------------------------------------------------------------|
| <span> <b> Over-The-Counter Use (21 CFR 801 Subpart C) </b> </span> |
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Image /page/3/Picture/1 description: The image shows the logo for Bien-Air Surgery. The text "Bien-Air" is in a stylized blue font, with a green line underneath. The word "Surgery" is written in a smaller blue font below the green line.
## 510(k) SUMMARY
| Submitter: | Bien-Air Surgery SA<br>Rue de l'Ouest 2b<br>Le Noirmont, Jura, 2340 Switzerland | | | Subject Device | Predicate Device |
|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Jonas Guerdat<br>Chief Executive Officer<br>TEL: +41-32-344-64-40<br>jonas.guerdat@bienair.com | Trade Name | ORIGO System | OSSEODUO Shaver and Drill System | |
| Date Prepared: | September 30, 2022 | 510(k) Submitter | Bien Air Surgery SA | Bien Air Surgery SA | |
| Submission Type: | Traditional 510(k) | [510(k) Number] | [K213697] | [K173066] | |
| Subject Device: | Manufacturer:<br>Trade Name:<br>Common Name:<br>Regulation Number:<br>Regulation Name:<br>Regulatory Class:<br>Classification Product Code:<br>Subsequent Product Code:<br>Classification Name: | Bien-Air Surgery SA<br>ORIGO System<br>Electrical Surgery System and Accessories<br>21 CFR 882.4360<br>Electric cranial drill motor<br>Class II<br>HBC<br>HBE<br>Motor, Drill, Electric | Product Code -<br>Primary | HBC | HBC |
| Predicate Device: | Clearance:<br>Manufacturer:<br>Trade Name:<br>Common Name:<br>Regulation Number:<br>Regulation Name:<br>Regulatory Class:<br>Classification Product Code:<br>Subsequent Product Code:<br>Classification Name: | K173066 dated June 22, 2018<br>Bien-Air Surgery SA<br>OSSEODUO Shaver and Drill System<br>Cranial Drill Motor and Accessories<br>21 CFR 882.4360<br>Electric cranial drill motor<br>Class II<br>HBC<br>HBE<br>Motor, Drill, Electric | Product Code -<br>Subsequent | HBE | HBE |
| Device Description: | The ORIGO System is a software-controlled electrical surgery system intended to be used in an operating room by a clinician in a healthcare facility/hospital setting for cranial and spinal surgical procedures.<br><br>The ORIGO System consists of the ORIGO Control Unit, the ORIGO Foot Pedal, the ORIGO System-compatible two micromotors and one motorized handpiece with corresponding motor cables, handpieces, attachments, cutting tools, the ORIGO System Irrigation Line, and other accessories.<br><br>The ORIGO System transforms electrical energy through motors and converts it to rotational force to shape and cut bones through attached cutting tools.<br><br>Three micromotor subsystems of the ORIGO System include NANO, RAPIDO, and PM PERFO. The NANO and RAPIDO are micromotors. The PM PERFO is a motorized cranial perforator handpiece.<br><br>PM2 Handpieces are intended to be connected to the NANO Micromotor and RAPIDO Micromotor. Cranio-Guards are attached to the PM2 Handpieces, and craniotomy is performed using PM2 Craniotomy Burs. Other PM2 80K Burs are attached to the PM2 Handpieces without attachment. The PM2 80K Burs are used for cutting bones in cranial and spinal surgical procedures. | | Indications for<br>Use | The ORIGO System is a software-<br>controlled motorized surgical system that<br>includes attachments and<br>tools for cutting bone, and provides<br>irrigation fluid to the surgical site.<br>The ORIGO System is used in the<br>following surgical fields:<br>* For cutting bones in neuro (cranial) and<br>spinal surgeries. | The OSSEODUO system is intended for<br>shaping bones in spine and cranium<br>surgical operation. Shaver handpiece is<br>not intended for use in neurosurgical<br>procedures. |
| Intended Use | Cutting bone | Cutting bone | | | |
Bien-Air Surgery SA
Länggasse 56 Rue de l'Ouest 2b
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Image /page/4/Picture/1 description: The image shows the logo for Bien-Air Surgery. The words "Bien Air" are in a stylized blue font, with a green curved line underneath. To the right of the words is a red medical cross symbol. The word "Surgery" is written in a smaller blue font below the green line.
PM PERFO is intended to be used for a cranial perforation.
The ORiGO System is equipped with a peristaltic pump, which delivers saline irrigation solution to surgical sites through a 5m ORiGO System Irrigation Line.
The ORiGO System is a prescription-only device.
The ORiGO System is a software-controlled motorized surgical system that Indications for Use: includes attachments and tools for cutting bone, and provides irrigation fluid to the surgical site. The ORiGO System is used in the following surgical fields: * For cutting bones in neuro (cranial) and spinal surgeries.
Comparison with the predicate device shows the characteristics of the subject Summary of Technological device, the ORiGO System, to be substantially equivalent to the predicate Characteristics: devices. As such, the ORiGO System and predicate devices have the same technological characteristics:
- Method of operation
- Motor subsystems and devices included in the systems ●
Following technological differences exist between the subject and the predicate devices:
- . Additional cutting tools
- . Longer motor cables and irrigation line
- Reprocessing instructions .
These differences in the technological characteristics are minor and do not raise different questions of safety and effectiveness.
The following table summarizes the comparison of the subject ORiGO System to the predicate device in indications for use, design, operational principle, and technological characteristics.
**Bien-Air Surgery SA**
Offices
Registered office & Production
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Image /page/5/Picture/1 description: The image shows the logo for Bien-Air Surgery. The logo is in blue and green. The word "Bien-Air" is in a stylized font, with a green line underneath. The word "Surgery" is in a smaller, sans-serif font and is also blue. There is a red cross in the upper right corner of the image.
| | Subject Device | Predicate Device |
|-------------------------|---------------------------------------------------------------|---------------------------------------------------------------|
| Controller | Console with Foot Pedal | Console with Foot Pedal |
| Energy Source | Electrical | Electrical |
| Speed Indication | Digital | Digital |
| Function | Drill | Drill and microdebrider |
| Drill Motor Speed | Max 80,000 rpm | Max 80,000 rpm |
| Irrigation | 1 peristaltic pump integrated into the console for irrigation | 1 peristaltic pump integrated into the console for irrigation |
| Sterilization | Steam Autoclave<br>AAMI TIR 12, ISO 17664, ISO 17665 | Steam Autoclave<br>AAMI TIR 12, ISO 17664, ISO 17665 |
| Direct Contact Material | Stainless Steel, Diamond Grit, Carbide, Full Carbide | Stainless Steel, Diamond Grit |
The ORiGO System was developed and produced under considerations of all Summary of Performance applicable technical standards, internal specifications, and FDA guidance Testing: documents. The conformance of the ORiGO System with applicable international and internal standards was verified during non-clinical bench testing and evaluation. Tests were performed on the subject device, which demonstrated that the device is safe and effective, performs comparably to and is substantially equivalent to the predicate device.
> Electromagnetic compatibility and electrical safety of the ORiGO System have been demonstrated in conformity with the FDA recognized consensus standard IEC 60601-1, 60601-1-2, and 60601-1-6 "Medical electrical equipment - Part 1: General requirements for basic safety and essential performance".
> Software life cycle of the ORiGO System have been demonstrated in conformity with the FDA recognized consensus standard IEC 62304 "Medical device software - Software life cycle processes".
> Usability engineering to the ORiGO System has been demonstrated in conformity with the FDA recognized consensus standard IEC 62366-1 "Medical devices - Part 1: Application of usability engineering to medical devices".
> Documentation was provided demonstrating compliance of the ORiGO System devices to all FDA expectations stated in the FDA guidance documents "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling," "Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile, Pyrogen and Endotoxins Testing: Questions and Answers," "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"," "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices," Information to Support a Claim of Electromagnetic Compatibility (EMC) of "Electrically-Powered Medical Devices, Management of Cybersecurity in Medical Devices," and "Postmarket Management of Cybersecurity in Medical Devices."
> Together, these verification/validation activities successfully demonstrated that the device correctly performs as designed, has been validated for its intended use, and raises no new questions regarding either safety or effectiveness when compared to the predicate devices. Therefore, the verification/validation testing conducted supports a determination of substantial equivalence for the ORiGO System.
Bien-Air Surgery SA Offices Registered office & Production
Länggasse 56 Rue de l'Ouest 2b CH-2504 Bienne CH-2340 Le Noirmont Phone +41 (0)32 344 64 40 Phone +41 (0)32 953 35 35
surgery@bienair.com www.bienair.com
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Image /page/6/Picture/1 description: The image shows the logo for Bien-Air Surgery. The words "Bien-Air" are in a stylized blue font, with a green curved line underneath. The word "Surgery" is in a smaller blue font below the green line.
Biocompatibility evaluations of the ORiGO System devices were selected in Biocompatibility Testing: accordance with ISO 10993-1 Fifth edition 2018-08 "Biological evaluation of medical devices - Part 1: evaluation and testing within a risk management process" and the FDA guidance document "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"." The testing was conducted on the subject devices as determined by the risk analysis for the device and included: ● Cytotoxicity per ISO10993-5 ● Sensitization per ISO10993-10 Irritation per ISO10993-10 ● ● Acute Systemic Toxicity per ISO 10993-11 Pyrogenicity per ISO 10993-11 ● Indirect (extract) Hemolysis per ISO 10993-4 and ASTM F756 . Clinical testing was not required for a determination of substantial equivalence Discussion of the Clinical Tests: of the ORiGO System. Conclusion: Bien-Air Surgery SA considers the ORiGO System to be substantially equivalent to the predicate devices listed above. This conclusion is based on the similarities in primary intended use, principles of operation, functional design,
and established medical use.
Bien-Air Surgery SA
CH-2340 Le Noirmont
CH-2504 Bienne
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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.
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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.