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FLASH EVD System (10-0002)

7D Surgical ULC • Neurology • 12/27/2024

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

The FLASH EVD System is a Class II stereotactic instrument utilizing image guidance for precise neurosurgical instrument positioning, specifically designed for external ventricular drainage (EVD) catheter placement without requiring rigid patient fixation. Its substantial equivalence determination, demonstrating safety and effectiveness, was achieved through comprehensive non-clinical verification and validation activities, including rigorous testing and surgical simulations.

Summary

The FLASH EVD System, developed by 7D Surgical ULC, is a Class II stereotactic instrument designed to provide image guidance for the precise spatial positioning and orientation of neurosurgical instruments. It is specifically indicated for cranial surgery, particularly for the image-guided placement of external ventricular drainage (EVD) catheters to relieve elevated intracranial pressure. A notable feature is its ability to operate where a rigid anatomical structure can be identified, without requiring rigid fixation of the patient or a navigated instrument guide. The system's substantial equivalence determination was based on its similar intended use, technological characteristics, and functionality compared to a previously established predicate device. Comprehensive non-clinical verification and validation activities, including rigorous system, software, and instrumentation testing, surgical simulations on phantom models, and sterilization validation, supported its safety and effectiveness. The system demonstrated compliance with numerous recognized standards for biocompatibility, usability, product safety, and accuracy, confirming its performance without the need for additional clinical trials.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

FLASH EVD SystemStereotactic instrumentImage guidanceNeurosurgeryExternal ventricular drainage (EVD)Intracranial pressureSubstantial equivalenceNon-clinical validationPhantom modelsMedical device standards

Device Metadata

Submission Number
K242480
Company
7D Surgical ULC
Panel
Neurology
Product Code
N/A
Data Type
N/A
Clinical Function
N/A
AI Function
N/A
AI Subclass
N/A

Relevant Clinical Questions

  • Q1. What specific technological characteristics differentiate the FLASH EVD System's image guidance from its predicate device, and how do these contribute to its stated advantages like not requiring rigid patient fixation?; Could the non-clinical surgical simulations on phantom models fully replicate the challenges of varying patient anatomies or unexpected intraoperative shifts, and what was the achieved accuracy?; What are the long-term performance and reliability data for the FLASH EVD System, particularly regarding software stability and instrument calibration drift in a clinical setting?; While clinical trials were not required for equivalence, are there plans for post-market surveillance or observational studies to gather real-world effectiveness and safety data?; How does the system ensure robust identification of a 'rigid anatomical structure' in all cranial surgery scenarios, and what are the limitations or potential failure modes if such a structure is compromised or difficult to identify?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Post-§524B but no clear network capability detected

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score20/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment⚠ Not in summary - likely in full submission per §524B
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(drift)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Cybersecurity risk assessment not referenced in AI-generated device summary. FDA cybersecurity guidance (2023) expects this for cyber devices.

• Not detected in AI-generated device summary: SBOM, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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FLASH EVD System (10-0002) - 7D Surgical ULC | ESL FDA AI Device Intelligence