Remanufactured LigaSure Exact Dissector, Without Nano-coating (LF2019)

K220481 · Stryker Sustainability Solutions · GEI · May 25, 2022 · General, Plastic Surgery

Device Facts

• Record ID: K220481
• Device Name: Remanufactured LigaSure Exact Dissector, Without Nano-coating (LF2019)
• Applicant: Stryker Sustainability Solutions
• Product Code: GEI · General, Plastic Surgery
• Decision Date: May 25, 2022
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4400
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

The Remanufactured LigaSure Sealer/Divider is a bipolar electrosurgical instrument intended for use in open surgical procedures where ligation and division of vessels, tissue bundles, and lymphatics is desired. The LigaSure Sealer/Divider can be used on vessels (arteries and veins) up to and including 7 mm. It is indicated for use in general surgery and in such surgical specialties as urologic, thoracic, plastic, and reconstructive. Procedure may include, but are not limited to, bowel resections, gall bladder procedures, Nissen fundoplication, and adhesiolysis. The instrument is also indicated for open ENT procedures in adults (thyroidectomy, radical neck dissection, parotidectomy, and tonsillectomy) for ligation and division of vessels, lymphatics and tissue bundles 2-3 mm away from unintended thermally-sensitive structures such as nerves and parathyroid glands. The LigaSure system has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the LigaSure system for these procedures.

Device Story

Bipolar electrosurgical instrument for open surgery; used with compatible electrosurgical generators. Device features scissor-like handle for jaw operation and RF energy activation; two-stage activation button provides tactile feedback; separate trigger actuates mechanical blade for tissue division. Operated by surgeon in OR; connects to generator via cable; vessel sealing initiated via handle button or footswitch. Device applies RF energy to seal vessels/tissue bundles up to 7mm; mechanical blade divides tissue. Remanufactured version of predicate; lacks original nano-coating on jaws. Benefits include effective hemostasis and tissue division in various surgical specialties.

Clinical Evidence

Bench testing and preclinical animal studies performed. Bench testing included biocompatibility, sterilization, electrical safety (IEC 60601-1, IEC 60601-2-2), and functional performance (burst pressure, jaw temperature, device reliability, seal/divide capability on 1-7mm vessels). Preclinical animal model (acute and chronic survival studies) evaluated thermal spread and hemostasis efficacy. No human clinical data provided.

Technological Characteristics

Bipolar electrosurgical instrument; 21cm length; 20.6mm curved jaws. Energy source: external electrosurgical generator (e.g., Valleylab FT10). Connectivity: wired cable with instrument-type identification. Sterilization: validated reprocessing. Software: none (mechanical/electrical device). Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2.

Indications for Use

Indicated for open surgical procedures in adults requiring ligation and division of vessels (up to 7mm), tissue bundles, and lymphatics. Specialties include general, urologic, thoracic, plastic, and reconstructive surgery. ENT indications include thyroidectomy, radical neck dissection, parotidectomy, and tonsillectomy. Contraindicated for tubal coagulation/sterilization.

Regulatory Classification

Identification

An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.

Predicate Devices

• LigaSure Exact Dissector, Nano-coated (K173281)

Submission Summary (Full Text)

{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 the FDA logo, which 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.

May 25, 2022

Stryker Sustainability Solutions Mr. Scott English Principal Regulatory Affairs Specialist 1810 W Drake Drive Tempe, Arizona 85283

# Re: K220481

Trade/Device Name: Remanufactured LigaSure Exact Dissector, Without Nano-coating (LF2019) Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: April 21, 2022 Received: April 25, 2022

Dear Mr. English:

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/cfpm/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 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

{1}------------------------------------------------

devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrl-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 ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Long Chen, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

# Indications for Use

510(k) Number (if known) K220481

#### Device Name

Remanufactured LigaSure Exact Dissector, Without Nano-coating (LF2019)

#### Indications for Use (Describe)

The Remanufactured LigaSure Sealer/Divider is a bipolar electrosurgical instrument intended for use in open surgical procedures where ligation and division of vessels, tissue bundles, and lymphatics is desired. The LigaSure Sealer/Divider can be used on vessels (arteries and veins) up to and including 7 mm. It is indicated for use in general surgery and in such surgical specialties as urologic, thoracic, plastic, and reconstructive. Procedure may include, but are not limited to, bowel resections, gall bladder procedures, Nissen fundoplication, and adhesiolysis.

The instrument is also indicated for open ENT procedures in adults (thyroidectomy, radical neck dissection, parotidectorny, and tonsillectorny) for ligation of vessels, lymphatics and tissue bundles 2-3 mm away from unintended thermally-sensitive structures such as nerves and parathyroid glands.

The LigaSure system has not been shown to be effective for tubal coagulation for sterilization procedures. Do not use the LigaSure system for these procedures.

| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------------------------------------------------------------------------|
| <div> <span> <span style="font-size:16px">☒</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> |
| <div> <span> <span style="font-size:16px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |

#### 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

### Submitter:

Stryker Sustainability Solutions 1810 W. Drake Drive Tempe, Arizona 85283

## Contact:

Scott English, BS Principal Regulatory Affairs Specialist 901-451-1456 (o) 480-763-5310 (f) [e-mail]

Date of Preparation: May 24, 2022

Name of Device:

| Trade/Proprietary Name: | Remanufactured LigaSure Exact Dissector, Without Nano-coating<br>(LF2019) |
|-----------------------------|-----------------------------------------------------------------------------------------------------|
| Common Name: | Electrosurgical cutting and coagulation device and accessories |
| Classification Information: | Electrosurgical, Cutting & Coagulation Accessories<br>(21 CFR§878.4400, Product Code GEI, Class II) |

## Predicate Devices:

| Model<br>Number | 510(k)<br>Number | 510(k) Title | Original<br>Manufacturer |
|-----------------|------------------|---------------------------------------|--------------------------|
| LF2019 | K173281 | LigaSure Exact Dissector, Nano-coated | Covidien |

## Device Description:

The Remanufactured LigaSure Exact Dissector. Without Nano-coating (LF2019) is a bipolar electrosurgical instrument intended for use in open surqical procedures where ligation and division of vessels, tissue bundles, and lymphatics is desired. The instrument is intended to be used with Covidien electrosurgical generators that include vessel sealing capability. The instrument can be used on vessels (arteries and veins) up to and including 7 mm. The instrument creates a seal by application of radiofrequency (RF) electrosurgical energy to vascular structures (vessels and lymphatics) or tissue bundles interposed between the jaws of the instrument. A blade within the instrument is surgeon actuated to divide tissue. The following controls are located on the device:

- Scissor like design for opening and closing the instrument jaws and activating RF energy. The mechanism must be held in the closed position during vessel sealing and cutting.
- . An activation button at the bottom of the handle for generator power to initiate vessel sealing. The button has two stages that provide tactile feedback to the user. The first stage

{4}------------------------------------------------

button click does not apply energy, whereas the second stage click begins energy application.

- . A trigger for actuating the blade.
All controls can be operated with either the right or left hand. Vessel sealing can be initiated using the activation button or utilizing a footswitch connected to the generator. The instrument attached to the qenerator via a cable with a connector that identifies the instrument type to the qenerator.

For the LF2019, the Original Manufacturer applies a non-stick coating the jaws of the device to reduce tissue sticking. When remanufacturing the LF2019, Stryker Sustainability Solutions will not apply a non-stick coating to the iaws of the device.

The instrument is compatible with the Covidien Valleylab FT10 Enerqy Platform.

The scope of the submission only includes the Remanufactured LigaSure Exact Dissector. Without Nano-coating and not the Valleylab FT10 Energy Platform that is used to power the device, or the footswitch that connects to the generator. Stryker Sustainability Solutions does not reprocess, remanufacture, or market the generators or footswitch.

# Intended Use:

The Remanufactured LigaSure Sealer/Divider is a bipolar electrosurgical instrument intended for use in open surgical procedures where ligation and division of vessels, tissue bundles, and lymphatics is desired. The LigaSure Sealer/Divider can be used on vessels (arteries and veins) up to and including 7 mm. It is indicated for use in general surgery and in such surgical specialties as urologic, thoracic, plastic, and reconstructive. Procedure may include, but are not limited to, bowel resections, gall bladder procedures, Nissen fundoplication, and adhesiolysis.

The instrument is also indicated for open ENT procedures in adults (thvroidectorny, radical neck dissection, parotidectorny, and tonsillectomy) for ligation and division of vessels, lymphatics and tissue bundles 2-3 mm away from unintended thermally-sensitive structures such as nerves and parathyroid glands.

The LigaSure system has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the LigaSure system for these procedures.

# Indications for Use Comparison:

The indications for use for the proposed device are the same in comparison to the predicate device.

# Technological Comparison:

The design, materials, and intended use of the Remanufactured LigaSure Exact Dissector, Without Nano-coating are equivalent to the predicate device. The mechanism of action of the remanufactured device is identical to the predicate device in that the same standard mechanical design, materials, and size is utilized. There are no changes to the claims, intended use, clinical application, patient population, performance specifications, or method of operation. In addition, Stryker Sustainability Solutions' remanufacturing of the device includes removal of adherent visible soil and decontamination. Each individual device is tested for appropriate function of its

{5}------------------------------------------------

# K220481

components prior to packaging and labeling operations. The only differences between the Remanufactured LigaSure Exact Dissector, Without Nano-coating and the predicate LigaSure Exact Dissector, Nano-coated are that the device is remanufactured, and some device components are replaced with equivalent components during the remanufacturing operation. The nano-coating is not replaced during the remanufacturing operation.

| | Predicate Device | Subject Device |
|-----------------------|----------------------------------|----------------------------------|
| Uses | Single Patient Use | Single Patient Use |
| Device Length | 21cm | 21cm |
| Jaw Length | 20.6mm | 20.6mm |
| Jaw Shape | Curved | Curved |
| Mechanism for Cutting | Mechanical - User actuated blade | Mechanical - User actuated blade |

# Performance Data:

Bench and laboratory testing was conducted to demonstrate performance (safety and effectiveness) of the Remanufactured LigaSure Exact Dissector. Without Nano-coating. This included the following tests:

- Biocompatibility ●
- . Validation of Reprocessing
- Sterilization ●
- Electrical Safety and Electromagnetic Compatibility ●
- Functional Performance Tests .
- Blade Trigger Actuation Force o
- Clamp Arm Closing and Seal Button Force O
- O Clamp Arm Opening Force
- Clamp Arm Deflection O
- Jaw Clamp Force O
- Blade Excursion O
- Jaw Opening Angle O
- Burst Pressure O
- Maximum Jaw Temperature O
- Device Reliability O
- Functional Attribute Testing O

The functional performance testing involved electrical safety and electromagnetic compatibility testing in accordance with IEC 60601-1, IEC 60601-1-2, and IEC 60601-2-2, and verification/comparative testing (to the predicate device). The bench testing involved evaluation of the device's performance and ability to seal and divide vessels from 1mm to 7mm, including burst pressure, maximum jaw temperature, device functionality, device reliability, and functional attribute tests.

Additionally, preclinical laboratory evaluations in an animal model were performed, which included acute and chronic survival studies were done to evaluate thermal spread and the ability to achieve hemostasis of vessels of the remanufactured device.

# Conclusion:

The results of bench testing and preclinical laboratory evaluations demonstrate that the Remanufactured LigaSure Exact Dissector, Without Nano-coating is at least as safe and

{6}------------------------------------------------

effective as the predicate and perform as well as the identified legally marketed predicate device as described herein.