Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF)
K233840 · Zhuhai Dipu Medical Technology Co., Ltd. · GCJ · Jun 26, 2024 · Gastroenterology, Urology
Device Facts
Record ID
K233840
Device Name
Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF)
Applicant
Zhuhai Dipu Medical Technology Co., Ltd.
Product Code
GCJ · Gastroenterology, Urology
Decision Date
Jun 26, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.1500
Device Class
Class 2
Indications for Use
Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to provide real-time endoscopic visible and near-infrared fluorescence visualization. The System enables surgeons to perform minimally invasive surgery using standard endoscope visible light as well as visual assessment of vessels, blood flow and related tissue perfusion, and at least one of the major extra-hepatic bile ducts, using near-infrared imaging. Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to be used to perform intraoperative fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels and lymph nodes.
Device Story
Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF) provides real-time visible and near-infrared (NIR) fluorescence imaging during minimally invasive surgery. System components include 4K video processor, 4K camera head, endoscope, cold light source, and light guide cable. Device operates by illuminating surgical field with visible light for standard imaging and NIR laser diode for fluorescence excitation. When used with intravenous indocyanine green (ICG), system captures fluorescence response, processes signal, and displays output on video monitor. Used in hospital/healthcare facilities by physicians. Enables visual assessment of blood flow, tissue perfusion, bile ducts, and lymphatic structures. Benefits include enhanced intraoperative visualization to support surgical decision-making.
Clinical Evidence
No clinical tests were performed. Evidence consists of non-clinical bench testing (imaging performance, light source performance) and an in vivo animal study to verify safety, effectiveness, and imaging quality.
Technological Characteristics
System includes 4K video processor, 4K CMOS camera head, rigid endoscope, LED/NIR laser light source, and light guide cable. NIR laser is Class 3R (IEC 60825-1). Connectivity via DVI, HDMI, SDI. Sterilization via autoclave. Complies with AAMI/ANSI ES 60601-1, IEC 60601-1-2, IEC 60601-2-18, ISO 8600 series (1, 3, 4, 5), and IEC 62471.
Indications for Use
Indicated for patients undergoing minimally invasive surgery requiring intraoperative visualization of vessels, blood flow, tissue perfusion, major extra-hepatic bile ducts, and the lymphatic system (vessels and lymph nodes) using ICG-enhanced near-infrared fluorescence imaging.
Regulatory Classification
Identification
An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.
Special Controls
*Classification* —(1)*Class II (special controls).* The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.
In combination with the general controls of the FD&C Act, the integrated operating table-electromechanical surgical system is subject to the following special controls:
1. (1) Premarket clinical performance testing, or a combination of premarket clinical performance testing and postmarket surveillance (in accordance with special control (2)), must include the following:
1. (i) Objective performance measures (e.g., rate and number of conversions to other surgical modalities, rate of device related adverse events (including tissue injury, hematoma, and increased blood loss), and their severity, cause, and outcomes) must be reported with relevant descriptive comparator performance measures.
2. (ii) The data must demonstrate the performance of the device for providing accurate and precise control of attached surgical instruments in range of clinical conditions relevant to the device's intended use.
3. (iii) The test dataset must include data collected from a patient population representative of the intended patient population under anticipated conditions of use.
2. (2) Data obtained from postmarket surveillance must demonstrate, in consideration of the premarket data obtained in accordance with special control (1), that the device performs in accordance with special control (1), unless FDA determines, based on the totality of the premarket data, that data from postmarket surveillance is not required to demonstrate that the device performs as intended. Such postmarket surveillance must be conducted per a protocol determined appropriate by FDA to demonstrate that the device performs as intended (in consideration of the premarket data obtained in accordance with special control (1)), and must include initiation, enrollment, and reporting requirements to ensure timely periodic updates to FDA on post-market surveillance progress and outcomes.
3. (3) Animal performance testing must evaluate the extent of port site trauma due to repositioning of table during surgical procedures when utilizing robotic minimally invasive and laparoscopic approaches
4. (4) The device manufacturer must develop, and update as necessary, a device-specific use training program that ensures proper device setup/use/shutdown, accurate control of instruments to perform the intended surgical procedures, troubleshooting and handling during unexpected events or emergencies, and safe practices to mitigate use error.
5. (5) The device manufacturer may only distribute the device to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program.
(6) Human factors assessment must demonstrate that the user can correctly use the device system across all intended use environments with the provided instructions and training materials, including patient access during normal operating conditions and emergency situations, and effects arising from the integrated nature of the operating table and robotic surgical arms.
(7) Labeling must include:
(i) A detailed summary of clinical performance testing conducted with the device, including study population, results, adverse events, and comparisons to any comparator groups identified;
(ii) A statement in the labeling that the safety and effectiveness for the representative specific procedures was based on evaluation of the device as a surgical tool and did not include evaluation of outcomes related to the treatment of the patient's underlying disease or condition, unless FDA determines that it can be removed or modified based on clinical performance data submitted to FDA;
(iii) Identification of compatible devices;
(iv) The list of surgical procedures for which the device has been determined to be safe with clinical justification;
(v) Reprocessing instructions for reusable components;
(vi) A shelf life for any sterile components;
(vii) A description of the device-specific use training program;
(viii) A statement that the device is only for distribution to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program; and
(ix) A summary of any completed postmarket surveillance data collected as required by special control (2), including updated labeling to accurately reflect outcomes observed in postmarket surveillance.
(8) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use and must include:
(i) Device motion accuracy and repeatability;
(ii) System testing;
(iii) Instrument reliability;
(iv) Crosstalk;
(v) Table motion control;
(vi) Thermal effects on tissue;
(vii) User-device interface performance;
(viii) Workspace access testing; and
(ix) Performance testing with compatible devices.
(9) Software verification, validation, and hazard analysis must be performed.
(10) Electromagnetic compatibility and electrical, thermal, and mechanical safety testing must be performed.
(11) Performance data must demonstrate the sterility of all patient-contacting device components.
(12) Performance data must support the shelf life of the device components provided sterile by demonstrating continued sterility and package integrity over the labeled shelf life.
(13) Performance data must validate the reprocessing instructions for the reusable components of the device.
(14) Performance data must demonstrate that all patient-contacting components of the device are biocompatible.
(15) Performance data must demonstrate that all patient-contacting components of the device are non-pyrogenic.
(16) The device manufacturer must submit a report to the FDA annually on the anniversary of initial marketing authorization for the device, until such time as FDA may terminate such reporting, which comprises the following information:
(i) Cumulative summary, by year, of complaints and adverse events since date of initial marketing authorization; and
(ii) Identification and rationale for changes made to the device, labeling, or device specific use training program, which did not require submission of a premarket notification during the reporting period.
Predicate Devices
PINPOINT Endoscopic Fluorescence Imaging System (K182606)
Submission Summary (Full Text)
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June 26, 2024
Zhuhai Dipu Medical Technology Co., Ltd. % Jovce Yang Consultant Shenzhen Joyantech Consulting Co., Ltd. 1713A, 17th Floor, Block A, Zhongguan Times Square Nanshan District Shenzhen, 518000 China
Re: K233840
Trade/Device Name: Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF) Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope And Accessories Regulatory Class: Class II Product Code: GCJ, IZI Dated: [NOTE: Use date of most recent supplement] Received: May 29, 2024
Dear Joyce Yang:
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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrh/ofdocs/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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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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).
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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-devices/deviceadvice-comprehensive-regulatory-assistance/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.
Digitally signed by TANISHA TANISHA L. HITHE S L. HITHE -S Date: 2024.06.26 18:41:34 -04'00'
Tanisha Hithe Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical & Infection Control 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) K233840
Device Name
Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF)
Indications for Use (Describe)
Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to provide real-time endoscopic visible and near-infrared fluorescence visualization. The System enables surgeons to perform minimally invasve surgery using standard endoscope visible light as well as visual assessment of vessels, blood flow and related tissue perfusion, and at least one of the major extra-hepatic bile ducts, using near-infrared imaging.
Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to be used to perform intraoperative fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels and lymph nodes.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary K233840
Date of Summary prepare: June 25, 2024
# 1. Submission Sponsor
| Applicant Name: | Zhuhai Dipu Medical Technology Co., Ltd. |
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Address: | 1F, Building 13, GMP Production Workshop,<br>Zhuhai International Health Harbor, No. 628 Airport<br>West Road, Sanzao Town, Jinwan District, Zhuhai,<br>China |
| Contact person: | WANG HUAN |
| Phone: | +8613521289729 |
| Email: | huan.wang@digipmc.com |
#### 2. Submission correspondent
| Name: | Shenzhen Joyantech Consulting Co., Ltd |
|-----------------|---------------------------------------------------------------------------------------------|
| Address: | 1713A, 17th Floor, Block A, Zhongguan Times<br>Square, Nanshan District, Shenzhen<br>518000 |
| Contact person: | Joyce Yang |
| Phone: | +86-755-86069197 |
| Email: | joyce@cefda.com |
#### 3. Device Identification
| Trade Name: | Endoscopic Fluorescence Camera System |
|-----------------------|---------------------------------------|
| Common or Usual Name: | Endoscopic Imaging System |
| Model: | DPM-ENDOCAM-03PF |
| Classification name: | Endoscope and accessories |
| Review Panel: | Gastroenterology/Urology |
| Product Code: | GCJ, IZI |
| Device Class: | Class II |
| Regulation Number: | 21 CFR § 876.1500 |
#### Legally Marketed Predicate Device 4.
| Trade Name | PINPOINT Endoscopic Fluorescence Imaging<br>System |
|-------------------|----------------------------------------------------|
| Regulation number | 21 CFR § 876.1500 |
| Regulation class | Class II |
| Regulation name | Endoscope and accessories |
| 510(k) Number | K182606 |
| Product Code | GCJ; IZI |
| Manufacturer | Novadaq Technologies ULC. |
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#### Device Description 5.
The proposed system, Endoscopic Fluorescence Camera System (DPM-ENDOCAM-03PF) is comprised of a 4K video processor (DPM-ENDOCAM-03P-MF), a 4K camera head (DPM-ENDOCAM-03P-CAM), Endoscope (DPM-ENDOSCOPE-0130/DPM-ENDOSCOPE-0100), a cold light source (DPM-LIGHT-03) and a light guide cable (DPM-FB-01).
Endoscopic Fluorescence Camera System is capable of providing real-time endoscopic visible and near-infrared fluorescence imaging.
During surgical procedures, the system may be operated to provide visualization similar to that provided by conventional imaging systems used in surgical endoscopy. The area of interest is illuminated with visible light from the light source and the resulting reflecting light is imaged by the camera and displayed on the video monitor. When used with the VIS-only laparoscopes, the System is only capable of the conventional mode of visualization described herein.
To provide NIR fluorescence imaging, the system is used with the imaging agent, indocyanine green (ICG). The patient is injected with ICG imaging agent. The ICG fluoresces when illuminated through the laparoscope with NIR excitation light from the light source, and the fluorescence response is then imaged with the camera, processed and displayed on a video monitor.
## 6. Intended Use/ Indications for Use
Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to provide real-time endoscopic visible and near-infrared fluorescence visualization. The System enables surgeons to perform minimally invasive surgery using standard endoscope visible light as well as visual assessment of vessels, blood flow and related tissue perfusion, and at least one of the major extra-hepatic bile ducts, using near-infrared imaging.
Upon intravenous administration and use of an ICG consistent with its approved label, the Endoscopic Fluorescence Camera System is intended to be used to perform intraoperative fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels and lymph nodes.
## 7. Technological characteristics comparison
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| Comparison<br>item | Subject Device | Predicate Device(K182606) | Comme<br>nts |
|-------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| Product<br>Name | Endoscopic Fluorescence Camera<br>System | PINPOINT Endoscopic<br>Fluorescence Imaging System | / |
| Product<br>Code | GCJ, IZI | GCJ, IZI | Same |
| Regulation<br>Number | 21 CFR § 876.1500 | 21 CFR § 876.1500 | Same |
| Classificatio<br>n | Class II | Class II | Same |
| Type of use | Prescription Use | Prescription Use | Same |
| Intended use<br>& Indications<br>for Use | Upon intravenous<br>administration and use of an<br>ICG consistent with its<br>approved label, the Endoscopic<br>Fluorescence Camera System<br>is intended to provide real-time<br>endoscopic visible and near-<br>infrared fluorescence<br>visualization. The System<br>enables surgeons to perform<br>minimally invasive surgery<br>using standard endoscope<br>visible light as well as visual<br>assessment of vessels, blood<br>flow and related tissue<br>perfusion, and at least one of<br>the major extra-hepatic bile<br>ducts, using near-infrared<br>imaging.<br>Upon intravenous<br>administration and use of an<br>ICG consistent with its<br>approved label, the Endoscopic<br>Fluorescence Camera System<br>is intended to be used to<br>perform intraoperative<br>fluorescence imaging and<br>visualization of the lymphatic<br>system, including lymphatic<br>vessels and lymph nodes. | Upon intravenous administration of<br>TRADENAME (ICG drug product),<br>the PINPOINT Endoscopic<br>Fluorescence<br>Imaging System is used with<br>TRADENAME to perform<br>intraoperative fluorescence<br>angiography, and it is also indicated<br>for use in fluorescence imaging of<br>biliary ducts, and when indicated,<br>during intraoperative<br>cholangiography.<br>The PINPOINT Endoscopic<br>Fluorescence Imaging System is<br>indicated for use to provide real time<br>endoscopic visible and<br>near-infrared fluorescence imaging.<br>The PINPOINT System enables<br>surgeons to perform minimally<br>invasive surgery<br>using standard endoscope visible<br>light as well as visual assessment of<br>vessels, blood flow and related<br>tissue perfusion, and<br>at least one of the major extra-<br>hepatic bile ducts (cystic duct,<br>common bile duct or common<br>hepatic duct), using nearinfrared<br>imaging.<br>Fluorescence imaging of biliary<br>ducts with the PINPOINT System is<br>intended for use with standard of<br>care white light,<br>and when indicated, intraoperative | Same |
| Comparison<br>item | Subject Device | Predicate Device(K182606) | Comme<br>nts |
| | | cholangiography. The device is not<br>intended for standalone use for<br>biliary duct<br>visualization.<br>Upon interstitial administration of<br>TRADENAME (ICG drug product),<br>the PINPOINT System is used to<br>perform<br>intraoperative fluorescence imaging<br>and visualization of the lymphatic<br>system, including lymphatic vessels<br>and lymph<br>nodes. | |
| Applicable<br>user | Physicians | Physicians | Same |
| Environment<br>of use | Healthcare facility/hospital | Healthcare facility /hospital | Same |
| Single use /<br>Reusable | Reusable | Reusable | Same |
| Sterile /non-<br>sterile | Marketed as non-sterile | Marketed as non-sterile | Same |
| Device<br>System<br>components | - Video Processor<br>- Camera Head<br>- Endoscope<br>- Light Source<br>- Light Guide Cable | - Endoscopic video processor /<br>illuminator (VPI)<br>- Laparoscope<br>- Camera head<br>- Light guide cable | Same |
| Video output<br>signals | DVI, HDMI, SDI | HD-SDI, DVI | Similar |
| Video output<br>resolution | 4096×2160p;<br>3840×2160p;<br>1920×1080p | 1920×1080 | Similar |
| Voltage | 100-230V~ | 100-240V~ | Similar |
| Frequency | 50/60 Hz | 50/60 Hz | Same |
| Power<br>consumption | Video Processor: 350VA<br>Light Source: 200VA | 300VA | Similar |
| Comparison<br>item | Subject Device | Predicate Device(K182606) | Comme<br>nts |
| Image<br>sensors | 4K CMOS sensor assembly | CMOS HD sensor assembly | Similar |
| Aspect ratio | 16:9 | 16:9 | Same |
| Light<br>sources | - Visible (VIS): Light-emitting diode<br>array<br>- Near infrared (NIR): NIR laser diode | - Visible (VIS): Light-emitting diode<br>array<br>- Near infrared (NIR): NIR laser<br>diode | Same |
| Light<br>guide<br>cable | Transmission spectrum: Visible + NIR | Transmission spectrum: Visible<br>+<br>NIR | Same |
| | Sterilization: Autoclave | Sterilization: Autoclave | Same |
| Imaging<br>agent | SPY AGENT GREEN | SPY AGENT GREEN | Same |
| Type of<br>protection<br>against<br>electric<br>shock<br>(as per IEC<br>60601-1) | Class I | Class I | Same |
| Degree of<br>protection<br>against<br>electric<br>shocks<br>(as per IEC<br>60601-1) | CF-type | CF-type | Same |
| Laser<br>classification<br>(as per IEC<br>60825-1) | Class 3R | Class 3R | Same |
| Radio<br>frequency<br>emissions<br>(as per<br>CISPR 11) | Group 1, Class A | Group 1, Class A | Same |
# Table 1 Technological characteristics comparison
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As shown in the comparison table, the proposed system and its predicate has the same intended use and indications for use and similar technological characteristics.
### 8. Summary of non-clinical testing
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The non-clinical test results demonstrated that the proposed device complies with the following standards:
- AAMI/ANSI ES 60601-1:2005/(R)2012 Medical Electrical Equipment- Part 1: . General requirements for basic safety and essential performance.
- equipment- Part 1-2: IEC 60601-1-2:2014 Medical electrical General . requirements for basic safety and essential performance- Collateral standard: Electromagnetic compatibility- Requirements and tests.
- IEC 60601-2-18:2009 Medical electrical equipment Part 2-18: Particular . requirements for the basic safety and essential performance of endoscopic equipment
- IEC 60825:2014 Safety of laser products Part 1: Equipment classification and . requirements was assessed and showed that subject device is a Class 3R laser device.
- IEC 62471:2006 Photobiological safety of lamps and lamp systems .
- ISO 8600-1:2015 Endoscopes Medical endoscopes and endotherapy devices --. Part 1: General requirements
- ISO 8600-3:2019 Endoscopes Medical endoscopes and endotherapy devices . Part 3: Determination of field of view and direction of view of endoscopes with optics
- ISO 8600-4:2014 Endoscopes Medical endoscopes and certain accessories -. Part 4: Determination of maximum width of insertion portion
- ISO 8600-5:2020 Optics and photonics Medical endoscopes and endotherapy . devices - Part 5 Optics and photonics - Medical endoscopes and endotherapy devices - Part 5: Determination of optical resolution of rigid endoscopes with optics: Determination of optical resolution of rigid endoscopes with optics
Performance testing was conducted on imaging performance and light source performance to support the marketing claims and to confirm that safety and effectiveness of the Endoscopic Fluorescence Camera System is at least equivalent to the predicate device. The in vivo fluorescence imaging study on animal model was performed to examine/detect corresponding reqions in order to simulate the clinical use, study the imaging effect, and verify the safety and effectiveness.
#### Brief discussion of clinical tests 9.
No clinical tests were performed.
### 10. Conclusions
The subject device and the predicate device have the same intended use, similar technological characteristics. The technological differences will not cause safety and…