The ZIP PEN Smoke Evacuation Pencil is a monopolar device designed for general electrosurgical applications including cutting and coagulation and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. This device conducts an electrosurgical current from an electrosurgical generator and delivers it to the target tissue to achieve the desired surgical effect
Device Story
Sterile, single-use, handheld monopolar electrosurgical pencil with integrated smoke evacuation. Device connects to an electrosurgical generator for power and a smoke evacuation system for suction. Components include a printed circuit board, dome switches for 'Cut' (yellow) and 'Coag' (blue) activation, flexible electrical cable, and a nozzle with a metal collet for electrode retention. Housing is over-molded to prevent liquid ingress. Used by surgeons in clinical settings to perform tissue cutting/coagulation while simultaneously capturing surgical smoke via attached tubing and filters. Benefits include reduced exposure to surgical smoke and streamlined surgical workflow.
Clinical Evidence
No clinical data. Substantial equivalence established via bench testing, including electrical safety, electromagnetic compatibility, and biocompatibility (cytotoxicity, irritation, sensitization).
Technological Characteristics
Monopolar electrosurgical pencil; polycarbonate nozzle; US 3-pin electrical connector. Sterilized via radiation (ANSI/AAMI/ISO 11137-2:2013). Complies with ANSI/AAMI/IEC 60601-1 and 60601-2-2. No software.
Indications for Use
Indicated for general electrosurgical applications including cutting and coagulation and smoke removal during electrosurgery in conjunction with an effective smoke evacuation system.
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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 18, 2015
Ms. Ronda K. Magneson Director of Regulatory Affairs Megadyne Medical Products, Incorporated 11506 South State Street Draper, Utah 84020
Re: K141587
Trade/Device Name: Zip Pen Smoke Evacuation Electrosurgical Pencil Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical, Cutting & Coagulation & Accessories Regulatory Class: Class II Product Code: GEI Dated: January 12, 2015 Received: January 14, 2015
Dear Ms. Magneson:
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. 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Jennifer R. Stevenson -S
For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K141587
### Device Name
ZIP PEN Smoke Evacuation Electrosurgical Pencil
Indications for Use (Describe)
The ZIP PEN Smoke Evacuation Pencil is a monopolar device designed for general electrosurgical applications including cutting and coagulation and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. This device conducts an electrosurgical current from an electrosurgical generator and delivers it to the target tissue to achieve the desired surgical effect
|X | Prescription Use (Part 21 CFR 801 Subpart D)
_ Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summarv
#### SUBMITTER 1.
Megadyne Medical Products, Inc. 11506 South State Street Draper, UT 84020 Phone: (801) 576-9669 Fax: (801) 576-9698
Contact Person (Primary): Ronda K. Magneson Director of Requlatory Affairs rmagneson@megadyne.com
Contact Person (Alternate): Katie Hoff Requlatory Affairs Specialist khoff@megadyne.com
Date Prepared: February 18, 2015
### DEVICE II.
Name of Device: ZIP Pen Smoke Evacuation Electrosurgical Pencil (catalog numbers 2525-10 and 2525-15) Smoke Evacuation Electrosurgical Pencil Common Name: Electrosurgical cutting and coagulation device and Classification Name: accessories (21 CFR 878,4400) Requlatory Class: Class II GEI Product Code:
### PREDICATE DEVICE lll.
Telescoping PenEvac, K961616 cleared May 28, 1996
### DEVICE DESCRIPTION IV.
The ZIP Pen Smoke Evacuation Electrosurgical Pencil is a sterile, single use hand held electrosurgical pencil and smoke evacuation handpiece. It is a monopolar device designed for general electrosurgical applications including cutting and coagulation and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system.
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The device consists of a printed circuit board, flexible electrical cable, dome switches, button switch mechanisms and sealing materials. The circuit board and electrical cable provide the means for powering the device. The dome switches operate the Cut and Coag functions. These components are enclosed within an upper housing and lower molded carriage and nozzle. which snap together. The buttons sit on top of the dome switches and extend through the upper housing and facilitate activation of the device. The button proximal to the electrode is yellow and controls the cut function of the device. The button distal to the electrode is blue and controls the coagulate function of the device. Within the nozzle, there is a metal collett that holds the electrode in place. The housing and other components are designed and assembled to prevent liquid from entering the electrical connections (preventing an electrical short). This is accomplished by over molding the circuit board with nonconductive materials.
Clear tubing connects to the nozzle and provides a path for capturing electrosuraical smoke. The electro-surgical cable leaves the tubing through an open port and terminates at a 3-prong electro-surgical plug. The remaining portion of the tubing (without cable inside) terminates at a connector that attaches to the smoke evacuation filter. The connector is attached to the tubing and is included as part of the smoke evacuation pencil for connection to the filter.
The ZIP Pen Smoke Evacuation Electrosurgical Pencil is available with 10 ft. and 15 ft. cord/tubing (catalog numbers 2525-10 and 2525-15, respectively) and is supplied with two additional items:
- A holster, which is used to hold the device when it is not in use during the � � procedure. The holster is a component of the device and will not be sold separately.
- A 2.5 inch Megadyne E-Z Clean electrode. The electrode is a separate, . currently marketed device that received clearance in 2008 via K081791.
The associated accessories include:
- Nozzle Extension can be used in electrosurgery procedures where a longer 0 electrode is required to extend the smoke capture nozzle to the surgical site.
- Filter -- the ULPA and charcoal filters can be used with smoke evacuation � units. They filter surgical smoke and odors removed from the surgical site.
- Adapter can be used to facilitate the tubing connection to a variety of smoke � evacuation filter/units on the market.
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### V. INDICATIONS FOR USE
The ZIP Pen Smoke Evacuation Electrosurgical Pencil is a monopolar device designed for general electrosurgical applications including cutting and coagulation and for removing smoke generated by electrosurgery when used in conjunction with an effective smoke evacuation system. The device conducts electrosurgical current from an electrosurqical generator and delivers it to the target tissue to achieve the desired surgical effect.
The indications for use for the subiect device are fundamentally identical to that of the predicate device, and any minor variations in wording do not affect the safety and effectiveness of the device when used as labeled.
### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE VI. PREDICATE DEVICE
The ZIP Pen Smoke Evacuation Electrosurgical Pencil shares the same technological characteristics and is constructed of similar materials, chemical composition, and use the same energy source found in the predicate device. It is a handheld electrosurgical device used for cutting, coagulation and smoke removal during electrosurgical procedures. At a high level, the subject and predicate devices are based on the following same technological elements:
- Operation function switches used to switch between "Cut" and "Coag" .
- Electrode monopolar 0
- Nozzle construction polvcarbonate �
- Power supply monopolar electrosurgical generator o
- Electrical connector US-3-pin �
- Use of a smoke evacuation svstem �
- Use of filters to filter surgical smoke removed from the surgical site. o
### VII. PERFORMANCE DATA
The following performance data were provided in support of the substantial equivalence determination.
## Sterilization
The ZIP Pen Smoke Evacuation Electrosurgical Pencil and the nozzle extensions are sterilized by exposure to radiation to a Sterility Assurance Level (SAL) of 10° Effectiveness of the sterilization cycle and sterilizing dose was qualified according to the requirements of ANSI/AAMI/ISO 11137-2:2013, Sterilization of health care products -Radiation - Part 2: Establishing the sterilization dose.
These devices have a shelf life of 3 vears.
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## Biocompatibility Testing
The biocompatibility testing for the ZIP Pen Smoke Evacuation Electrosurgical Pencil was conducted in accordance with the FDA Blue Book Memorandum #G95-1 "Use of International Standard ISO 10993, Biological Evaluation of Medical Devices Part 1: Evaluation and Testing," May 1, 1995, and International Standard ISO 10993-1, "Biological Evaluation of Medical Devices -- Part 1: Evaluating and Testing Within a Risk Management Process," as recognized by the FDA. The series of testing included the following tests:
- o Cytotoxicity
- 0 Intracutaneous reactivity (Irritation)
- Maximization sensitization (Sensitization) 0
The ZIP Pen Smoke Evacuation Electrosurgical Pencil fulfilled all requirements of the test protocol and the standard.
## Electrical Safety and Electromagnetic Compatibility (EMC)
Electrical safety and EMC testing were conducted on the ZIP Pen Smoke Evacuation Electrosurgical Pencil. The system complies with the ANSI / AAMI / IEC 60601-1 and the ANSI / AAMI / IEC 60601-2-2 standards for safety and EMC.
## Software Verification and Validation Testing
Not applicable. The ZIP Pen Smoke Evacuation Electrosurgical Pencil does not contain software.
## Performance Testing - Bench
The ZIP Pen Smoke Evacuation Electrosurgical Pencil was exposed to performance bench testing to ensure conformance with the ANSI / AAMI / IEC 60601-1 and the ANSI / AAMI / IEC 60601-2-2 standards. The following tests were performed:
- 0 High frequency dielectric withstand
- 0 Mains frequency dielectric withstand
- � Continuity
- Leakage current 6
- Fluid Ingress 0
# Animal Study
Not applicable. Animal studies were not performed on the device.
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## Clinical Studies
Clinical studies were not performed as the indications for use are equivalent to the predicate device, and clinical testing is not required by applicable requlations.
### CONCLUSIONS VIII.
The ZIP Pen Smoke Evacuation Electrosurgical Pencil has the same intended purpose, indications and technological characteristics as the Telescoping PenEvac (K961616). The subject device also successfully passed all applicable performance and biocompatibility testing and is appropriate for its intended use.
The ZIP Pen Smoke Evacuation Electrosurgical Pencil does not raise different questions regarding safety and effectiveness as compared to predicate device. The ZIP Pen Smoke Evacuation Electrosurgical Pencil fuifills the relevant requirements of IEC 60601-2-2 and ISO 10993-1. Therefore, the subject device is as safe, as effective, and performs as well as or better than the predicate device, and is substantially equivalent to the predicate device.
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.