K150029 · Emcision , Ltd. · GEI · Jun 24, 2015 · General, Plastic Surgery
Device Facts
Record ID
K150029
Device Name
Habib EUS RFA
Applicant
Emcision , Ltd.
Product Code
GEI · General, Plastic Surgery
Decision Date
Jun 24, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4400
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Habib EUS RFA 6700 is indicated for coagulation of soft tissue when used in conjunction with compatible radio frequency generator.
Device Story
Habib EUS RFA 6700 is a monopolar catheter delivered via 19 or 22G endoscopic needles during EUS procedures. Device connects to compatible RF generator via accessory cable; requires patient grounding pad. RF current emitted from exposed electrode tip induces ion agitation in surrounding tissue; friction converts energy to heat, causing coagulation necrosis. Used in clinical settings by physicians. Output is thermal energy for tissue coagulation. Benefits include targeted soft tissue ablation.
Clinical Evidence
Bench testing only. Testing included compatibility with endoscope needles, trackability, pushability, heating zone consistency, abrasive testing, fatigue bending resistance, pull testing, and package integrity (burst/seal dye penetration). Biocompatibility testing included elution cytotoxicity, hemolysis, implantation, intracutaneous toxicity, and acute systemic injection. Electrical safety and EMC testing performed per IEC 60601-1, IEC 60601-2-2, and IEC 60601-2-18.
Technological Characteristics
Monopolar electrosurgical catheter; stainless steel electrode tip; 0.33mm shaft diameter. Energy source: compatible RF generator (up to 460 kHz). Sterilization: Ethylene Oxide. Standards: IEC 60601-1, IEC 60601-2-2, IEC 60601-2-18, ISO 10993-1/4/5/7/10. Connectivity: wired connection to RF generator.
Indications for Use
Indicated for coagulation of soft tissue in patients requiring electrosurgical intervention, used in conjunction with a compatible RF generator.
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
LeVeen™ Standard Needle Electrode System (K140495)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 24, 2015
EMcision LTD. % Mr. Louis-Paul Marin MMA Certification Incorporated 2025 Michelin Laval, Quebec H7L 5B7 Canada
Re: K150029
Trade/Device Name: Habib EUS RFA 6700 Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: GEI, JOS Dated: May 21, 2015 Received: May 27, 2015
Dear Mr. Marin:
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
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device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Industry and Consumer Education 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) K150029
Device Name Habib EUS RFA 6700
### Indications for Use (Describe)
The Habib EUS RFA 6700 is indicated for coagulation of soft tissue when used in conjunction with compatible radio frequency generator.
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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### Habib EUS RFA 6700
### 510(k) Summary
| 1. | Type of submission: | Traditional |
|----|------------------------------|---------------------------------------------------------------------------|
| 2. | Preparation Date | June 22, 2015 |
| 3. | Submitter | EMcision Ltd. |
| | Address | Department of Surgery |
| | | Hammersmith Hospital |
| | | DuCane Road |
| | | London W12 0HS |
| | | United Kingdom |
| | | Phone 1-514-994-9649 |
| | Contact | François Poulin |
| 4. | Contact Person: | Louis-Paul Marin, ing., LL.B., LL.M.<br>President, MMA Certification Inc. |
| | Phone: | 1-450-781-1578 ext 225 |
| | Fax: | 1-450-681-9663 |
| | Email: | lpmarin@groupemma.ca |
| 5. | Identification of the Device | |
| | Proprietary Name/Trade Name | Habib EUS RFA 6700 |
| | Common Name: | Monopolar electrosurgical device |
| | Classification Name: | Electrosurgical cutting and coagulation device<br>and<br>accessories |
| | Device Classification: | II |
| | Regulation Number: | 878.4400 |
| | Panel: | 79 - General and Plastic Surgery |
| | Product Code: | GEL IOS |
#### 6. Identification of the Predicate
Predicate Device Name: 510(k) Number:
Predicate Device Name: 510(k) Number:
LeVeen™Standard Needle Electrode System
ACE Monopolar Attachment
K140495
K123061
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#### 7. Intended use of the subject device
The Habib EUS RFA 6700 is indicated for coagulation of soft tissue when used in conjunction with compatible radio frequency generator.
#### 8. Device Description
The Habib EUS RFA 6700 is a catheter that is delivered during an EUS procedure, through 19 or 22 Gauge (G) endoscopic needles. The Habib EUS RFA 6700 is monopolar configuration and thus, must be used in conjunction with patient grounding pad. RF energy is produced by connecting the catheter to a compatible RF generator via an accessory cable. When attached to a generator, RF current is emitted from the exposed portion of the electrode and this current translates into ion agitation within the surrounding tissue, which is converted by friction into heat and induces cellular death by mans of coagulation necrosis.
### 9. Performance Data
Performance bench testing, biocompatibility testing, and electrical testing were performed on the proposed Habib EUS RFA 6700, which demonstrates that it met the required specifications for the completed design verification, biocompatibility tests, and electrical tests.
The following performance bench tests were performed:
- Compatibility with endoscope needle -
- -Trackability and pushability test
- Consistency of heating zone -
- Abrasive test -
- Fatigue bending resistance -
- -Pull test
- -Shipping and transportation test
- -Package evaluation using the burst test
- -Visual inspection of medical packaging to determine integrity
- -Package seal dye penetration test
- Functional validation for soft tissue indication -
The following biocompatibility tests were performed:
- Elution Cytotoxicity and Hemolysis -
- Implantation Test -
- -Intracutaneous toxicity
- -Acute systemic injection
### 10. Electromagnetic and Electrical Testing
Testing was performed per the requirements of the following electromagnetic compatibility and electrical standards:
- -IEC 60601-1:2006 + A1:2012, EN 60601-1:2006, ANSI/AAMI ES60601-1:2005 + C1:2009 + A2:2012 + A1:2010, and CAN/CSA-C22.2 No. 60601-1:2014: Medical electrical equipment -Part 1: General requirements for basic safety and essential performance
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- -IEC 60601-2-2:2009 + C1:2014 Medical electrical equipment = Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
- -EN IEC 60601-2-18:2009 Endoscopic equipment; In conjunction with BS EN 60601-1:2006 +A11 and IEC 60601-1:2005 Medical electrical equipment - Part 1 - General requirements for basic safety and essential performance
- -EN 55011:2007 Limits and methods of measurements of electromagnetic disturbance characteristics of industrial, scientific and medical (ISM) radio-frequency equipment
- EN 61000-3-2: 2006 Electromagnetic compatibility (EMC) -- Part 3-2: Limits for harmonic current emissions (equipment input current <= 16 A per phase)
- -EN 61000-3-3:2006 Electromagnetic compatibility (EMC) - Part 3-3: Limits - Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems, for equipment with rated current <= 16 A per phase and not subject to conditional connection
- -EN 61000-4-3:2006 Electromagnetic compatibility (EMC) - Part 4-3: Testing and measurement techniques – Radiated, radio-frequency, electromagnetic field immunity test
- -EN 61000-4-8:1993 Electromagnetic compatibility (EMC) - Part 4-8: Testing and measurement techniques - Power frequency magnetic field immunity test
### 11. Substantial Equivalence Determination
The subject device, the Habib EUS RFA 6700 is substantially equivalent to legally marketed predicate devices, the Ace Monopolar Attachment and the LeVeen™ Standard Needle Electrode System with respect to indications for use and technology characteristics. The Table below presents side by side comparisons for each major component of for each device:
| Item | Predicate Device<br>Ace Monopolar<br>Attachment<br>(K123061) | Predicate Device<br>LeVeen™ Standard Needle<br>Electrode System<br>(K140495) | Subject Device<br>Habib EUS RFA 6700<br>(K150029) |
|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Similarities | | | |
| Classification | II | II | II |
| Code of Federal<br>Regulation | 878.440 | 878.4400 | 878.4400 |
| Prescription<br>Medical Devices | Yes | Yes | Yes |
| Intended Use | The Ace Monopolar<br>Attachement is intended<br>to be used with the<br>compatible ERBE<br>Monopolar Disposable<br>Electrosurgical Pencil for<br>coagulation and cutting of<br>soft tissue when used in<br>conjunction with<br>compatible ERBE<br>Electrosurgical Generator<br>(ESU) System. | The LeVeen™ Needle<br>Electrode Family (which<br>includes the LeVeen™<br>Standard Needle<br>Electrode System and the<br>LeVeen™ CoAccess™<br>Need Electrode System)<br>is intended to be used in<br>conjunction with the<br>RF3000 Generator for the<br>thermal coagulation<br>necrosis of soft tissues,<br>including partial or<br>complete ablation of<br>nonresectable liver | The Habib EUS RFA<br>6700 is indicated for<br>coagulation and ablation<br>of soft tissue when used<br>in conjunction with<br>compatible radio<br>frequency generator. |
| | | lesions. | |
| Active Accessory<br>Configuration | Monopolar | Monopolar | Monopolar |
| Material of<br>electrode tip | Stainless Steel | n/a | Stainless Steel |
| Safety Standards | IEC 60601-1<br>IEC 60601-1-2<br>IEC 60601-2-2<br>ISO 10993-1<br>ISO10993-5<br>ISO 10993-10 | IEC 60601-1<br>IEC 60601-2-2 | IEC 60601-1<br>IEC 60601-2-2<br>IEC 60601-2-18<br>ISO 10993-1<br>ISO 10993-4<br>ISO 10993-5<br>ISO 10993-7<br>ISO 10993-10 |
| Performance<br>Tests | - Arcing Test<br>- Charring Test<br>- Thermal Spread Test<br>- Dropping Test<br>- Pulling Test | - Insulated Cannula<br>Outer Diameter<br>- Cannula Insulation<br>- Adhesion<br>- Cannula Tensile<br>- Cannula/Array<br>- Housing Handle<br>- Compression<br>Strength | - Compatibility with<br>endoscope needle<br>- Trackability and<br>pushability test<br>- Consistency of<br>heating zone test<br>- Abrasion test<br>- Fatigue bending<br>resistance test<br>- Pull Test<br>- Shipping and<br>Transportation Test<br>- Burst Test (Package<br>evaluation)<br>- Package Seal Dye<br>Penetration Test<br>- Functional Validation<br>for Soft Tissue<br>Indication |
| Differences | | | |
| Sterilization | Gamma irradiation | Ethylene Oxide | Ethylene Oxide |
| Dimension | Shaft $ ⌀ $ 2.35mm | Shaft $ ⌀ $ 1.5-2.4mm | Shaft $ ⌀ $ 0.33mm |
| Delivery Mode | Electrosurgical pencil | Cannula (percutaneous) | Endoscopic needle,<br>laparoscopes, ports,<br>trocars |
| Rated Frequency | n/a | 480 kHz | Up to 460 kHz |
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### 13. Conclusion
The Habib EUS RFA 6700 is substantially equivalent to the predicates Ace Monopolar Attachment (K123061) and LeVeen™Standard Needle Electrode System (K140495). The minor differences between the Habib EUS RFA 6700 and the predicates do not raise any new questions of safety or effectiveness. All product performance testing and electrical testing performance clearly demonstrate that the Habib EUS RFA 6700 is safe and effective.
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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.
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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.
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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.
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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.
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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.