K163373 · Gyrus Acmi, Inc. · GEI · Dec 12, 2016 · General, Plastic Surgery
Device Facts
Record ID
K163373
Device Name
PK AIM
Applicant
Gyrus Acmi, Inc.
Product Code
GEI · General, Plastic Surgery
Decision Date
Dec 12, 2016
Decision
SESE
Submission Type
Special
Regulation
21 CFR 878.4400
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The PK AIM is intended for mono polar cutting & coagulation, grasping, bipolar coagulation of selected soft tissues and sealing vessels up to and including 3.0 mm in diameter during electro surgery. This device is not intended to be used for tubal ligation or female sterilization.
Device Story
PK AIM is a 2-in-1 electrosurgical instrument combining a monopolar pencil and bipolar forceps in a single handle. Used in general surgery, it allows surgeons to switch between monopolar cutting/coagulation and bipolar coagulation via a sliding toggle switch on the handle. Activation occurs through hand-held buttons or an optional foot pedal. The device connects to the Olympus ESG-400 generator, which automatically recognizes the instrument and limits settings to appropriate parameters. The device is intended for single-patient use. By integrating two modalities into one tool, it enables surgeons to perform multiple tasks—grasping, cutting, and vessel sealing—without switching instruments, potentially reducing surgical time and improving workflow efficiency. The current submission implements a cable design modification to address capacitive coupling concerns.
Clinical Evidence
No clinical testing was conducted. Substantial equivalence is supported by bench testing, including electrical functionality, continuity, Hi-Pot, HF leakage, and electrical characterization, all of which met prescribed acceptance criteria.
Technological Characteristics
Materials: stainless steel electrodes, plastics, heatshrink, epoxy. Energy: monopolar and bipolar electrosurgery. Connectivity: proprietary connection to Olympus ESG-400 generator. Form factor: pencil-type handle with sliding toggle switch. Sterilization: Ethylene Oxide (EtO). Standards: ISO 10993, ISO 14971, IEC 60601-1, IEC 60601-2-2, ASTM-F2906-11, ISTA-2A, ASTMD4169-09.
Indications for Use
Indicated for monopolar cutting/coagulation, grasping, and bipolar coagulation of soft tissues and vessel sealing up to 3.0 mm in diameter during electrosurgery. Contraindicated for tubal ligation or female 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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 12, 2016
Gyrus ACMI, Inc. Mr. Graham Baillie Regulatory Affairs Manager 136 Turnpike Road Southborough, Massachusetts 01772
Re: K163373
Trade/Device Name: PK AIM Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and Accessories Regulatory Class: Class II Product Code: GEI Dated: November 29, 2016 Received: December 1, 2016
Dear Mr. Baillie:
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 of medical devicerelated 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.
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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/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 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, Jennifer R. Stevenson -A 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) K163373
Device Name PK AIM
Indications for Use (Describe)
The PK AIM is intended for mono polar cutting & coagulation, grasping, bipolar coagulation of selected soft tissues and sealing vessels up to and including 3.0 mm in diameter during electro surgery. This device is not intended to be used for tubal ligation or female sterilization.
Type of Use (Select one or both, as applicable)
| <span style="font-family: Arial;"> <span style="font-size: 10pt;"> <input checked="true" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) </span> </span> |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <span style="font-family: Arial;"> <span style="font-size: 10pt;"> <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </span> |
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## 510(k) Summary Gyrus ACMI, Inc. Olympus PK AIM
### General Information
Manufacturer:
Gyrus ACMI, Inc. 9600 Louisiana Ave North Brooklyn Park, MN 55445 Phone: 508-804-2690 Establishment Registration Number: 3011050570 510(k) Submitter Gyrus ACMI, Inc. 136 Turnpike Rd Southborough, MA 01772 Contact Person: Graham A. L. Baillie Manager, Regulatory Affairs 508-804-2738 Graham.baillie@olympus-osta.com Date Prepared: November 29, 2016 Device Description Classification Name: Electrosurgical cutting and coagulation device and accessories Regulation number 21 CFR 878.4400 Product code GEI Regulatory Class Class II Trade Name: Olympus PK Aim Generic/Common Name: Electrosurgical cutting and coagulation device Predicate Device
K161825
Olympus PK AIM
## Comparison to Predicate Device:
The Olympus PK AIM has been compared to the predicate Olympus PK AIM with respect to intended use, design and fundamental scientific technology. The comparisons and summary of testing results presented in this Special 510(k) Notification show this device to be substantially equivalent to the predicate PK AIM and raises no new concerns of safety or effectiveness.
Like the predicate PK AIM, the proposed PK AIM is intended for monopolar cutting and coagulation, grasping, bipolar coagulation of selected soft tissue, and like its predicate PK AIM the proposed device is also intended to seal vessels up to and including 3.0 mm in diameter during electrosurgery. Both predicate and proposed PK AIM devices are not intended to be used for tubal ligation or female sterilization.
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## Product Description
Both predicate and proposed PK AIM devices can be described as 2 in 1 devices with a pencil type handle that combines the technologies of a monopolar pencil and a bipolar forceps. The device has buttons that allow hand activation and a sliding toggle switch to allow the surgeon to switch between a forceps, and a pencil device. Foot pedals connected to the generator are also available to allow for foot pedal activation of the device. The proposed device plugs into the Olympus ESG-400 generator (K141225). The generator and device make up a medical electrosurgical system. The instrument is to be used only with the Olympus ESG-400 Generator. As a result of the PK AIM cable modifications which are the subject of this submission, no modifications were required or made to the ESG-400 Generator.
The proposed device is comprised of a mixture of plastics, metals, heatshrink and epoxy. The predicate Olympus PK AIM passed all applicable biocompatibility testing and additional information was provided within in the original PK AIM K152219 for any patient contacting materials that contain colorants. Except for the cable design modification that is being implemented to address a capacitive coupling concern, the subject Olympus PK AIM and predicate Olympus PK AIM are physically identical no other design or material changes.
## Technological Characteristics
The proposed Olympus PK AIM uses monopolar energy in order to cut and bipolar energy in order to coagulate soft tissue in general surgical procedures. For safety and convenience the ESG-400 generator recognizes the proposed Olympus PK AIM when it is connected and limits generator settings to those dedicated for use with the proposed Olympus PK AIM device. These settings are called out in the IFU.
The Olympus PK AIM can be activated using buttons located on the device handle, or via a foot pedals which are sold separately. The hand activation allows the physician to activate either cut or coagulation (coag) mode without taking their eyes off the surgical site. A sliding toggle switch located on the handle allows the user to switch between using the device as a monopolar pencil or bipolar forceps.
# Material
No material or packaging changes were made to the predicate PK AIM cleared under K161825.
## Indications for Use
The intended use of the modified/proposed PK AIM device, as described in its labeling, has not changed as a result of the cable modification.
The PK AIM is intended for mono polar cutting & coagulation, grasping, bipolar coagulation of selected soft tissues and sealing vessels up to and including 3.0 mm in diameter during electro surgery. This device is not intended to be used for tubal ligation or female sterilization.
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## Compliance to Voluntary Standards
The design of the Olympus PK AIM device complies with the following standards:
ISO 10993-1, 2009 ISO 10993-5, 2009 ISO 10993-7 2008 ISO 10993-10, 2010 ANSI/AAMI/ISO 11607-1, 2006 ANSI/AAMI/ISO 11135-1, 2007 ISO 14971, 2007 ISO 15223-1; 2012 IEC 60601-1: 2005 IEC 60601-2-2: 2009
## Summary of Sterilization and Shelf Life Discussion
Like the predicate Olympus PK AIM, (K161825), the proposed Olympus PK AIM will be distributed in a sterile state and is intended for single patient use only. The sterilization method used continues to be ethylene oxide and will now be labeled with a shelf life of 3 years.
| Description | Specification/objective |
|-----------------------------|------------------------------------------------------|
| Cable/Cord Length | Meet length specification |
| Electrical Functionality | Generator confirmation |
| Package Testing | ISTA-2A, ASTMD4169-09 |
| IEC 60601 | Meet relevant requirements |
| Label/Package damage | Visual inspection |
| Bubble Leak | ASTM-F2906-11 |
| Continuity | Meet specification |
| Hi-Pot | Meet specification |
| HF Leakage | Meet monopolar HF leakage<br>from bipolar electrodes |
| Electrical Characterization | Meet internal comparable<br>power outputs |
#### Summary of bench, Performance Testing (no clinical testing was conducted)
All performance testing passed or met prescribed acceptance criteria
## Substantial Equivalence
The proposed Olympus PK AIM has the same intended use, scientific technology and similar design as its predicate Olympus PK AIM device. The predicate PK AIM and proposed PK AIM device are both a pencil and a forceps device with a dual cord. The proposed and predicate devices were shown to perform substantially equivalent in bench testing. There were no new issues of safety or effectiveness with the proposed device. Please see the following substantial equivalence comparison table.
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| Design<br>Feature | Proposed<br>Olympus PK AIM | Predicate<br>Olympus PK AIM<br>K161825 | Comments |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------|
| Function of<br>Device | Forceps/Pencil | Forceps/Pencil | Same as predicate<br>PK AIM |
| Tip Size | Forceps<br>1mm tip, 2mm base<br>Pencil<br>2mm | Forceps<br>1mm tip, 2mm base<br>Pencil<br>2mm | Same |
| Energy | Monopolar/Bipolar | Monopolar/Bipolar | Same |
| Activation | Hand / Footpedal | Hand / Footpedal | Same |
| Plug | Dual (mono/bi) | Dual (mono/bi) | Same |
| Electrode<br>Materials | Stainless Steel | Stainless Steel | Same |
| Sterility | 10-6<br>EtO | 10-6<br>EtO | Same |
| Single Use | Yes | Yes | Same |
| Intended Use | The PK AIM is<br>intended for mono polar<br>cutting & coagulation,<br>grasping, bipolar<br>coagulation of selected<br>soft tissues and sealing<br>vessels up to and<br>including 3.0 mm in<br>diameter during electro<br>surgery. This device is<br>not intended to be used<br>for tubal ligation or<br>female sterilization. | The PK AIM is<br>intended for mono polar<br>cutting & coagulation,<br>grasping, bipolar<br>coagulation of selected<br>soft tissues and sealing<br>vessels up to and<br>including 3.0 mm in<br>diameter during electro<br>surgery. This device is<br>not intended to be used<br>for tubal ligation or<br>female sterilization. | Predicate and<br>proposed PK AIM<br>devices have<br>identical intended<br>uses. |
# Equivalence Comparison Table:
## Conclusion:
In summary, the Olympus PK AIM is substantially equivalent to its predicate device and presents no new questions of safety or efficacy.
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.