Reprocessed CristaCath Diagnostic Electrophysiology Catheter

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, featuring a stylized human figure. To the right of that is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text. October 5, 2017 Innovative Health, LLC. Amy Stoklas-Oakes Director, Quality and Regulatory Affairs 1435 North Hayden Road Suite 100 Scottsdale, Arizona 85257 # Re: K171503 Trade/Device Name: Reprocessed CristaCath Diagnostic Electrophysiology (EP) Catheter (see Enclosed Model List) Regulation Number: 21 CFR 870.1220 Regulation Name: Electrode Recording Catheter or Electrode Recording Probe Regulatory Class: Class II Product Code: NLH Dated: August 28, 2017 Received: August 29, 2017 Dear Amy Stoklas-Oakes: 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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); {1}------------------------------------------------ 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 (DICE) 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 (DICE) 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. # Kenneth J. Cavanaugh -S for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ The following device model is included in the scope of this 510(k) submission: | Item Number | Description | Sheath<br>Usable<br>Length<br>(cm) | French<br>Size | Curve | Number of<br>Electrodes | Spacing<br>(mm) | |-------------|-----------------------------------------|------------------------------------|----------------|-------------------|-------------------------|-----------------| | D7A20131RT | CristaCath<br>Diagnostic EP<br>Catheter | 115 | 7F | D-<br>Type/Crista | 20 | 1-3-1 | {3}------------------------------------------------ # Indications for Use 510(k) Number (if known) K171503 #### Device Name Reprocessed CristaCath Diagnostic Electrophysiology (EP) Catheter Indications for Use (Describe) The Reprocessed Cristacath Diagnostic EP Catheter is indicated for electrophysiological mapping of cardiac structures, i.e. stimulation and recording only. The catheter is designed to facilitate electrograms in the atrial regions of the heart. | Type of Use (Select one or both, as applicable) | | |-------------------------------------------------|--| |-------------------------------------------------|--| X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) #### 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." {4}------------------------------------------------ ### SECTION 5: 510(k) SUMMARY As required by 21 CFR 807.92(c) #### Submitter's Name and Address: Innovative Health, LLC. 1435 N. Hayden Road, Suite 100 Scottsdale, AZ 85257 #### Contact Name and Information: Amy Stoklas-Oakes Innovative Health, LLC. Sr. Quality and Regulatory Manager (480) 525-5972 (office) (888) 965-7705 (fax) astoklas-oakes@innovative-health.com #### Date prepared: May 22, 2017 #### Device Information: | Trade/Proprietary Name: | Reprocessed CristaCath Diagnostic | |-------------------------|---------------------------------------------| | | Electrophysiology (EP) Catheter | | Common Name: | Diagnostic Electrophysiology Catheter | | Classification Name: | Catheter, Recording, Electrode, Reprocessed | | Classification Number: | Class II, 21 CFR 870.1220 | | Product Code: | NLH | #### Predicate Device: | 510(k) Number | 510(k) Title | Manufacturer | |---------------|-----------------------------------------------------------|-------------------------------------------| | K953768 | Cordis Webster A20 Diagnostic<br>Deflectable Tip Catheter | Cordis Webster, Inc.,<br>Biosense Webster | #### Device Description: The Reprocessed CristaCath Diagnostic Electrophysiology (EP) Catheters have been designed for electrophysiological mapping of cardiac structures. The catheters have a high-torque shaft with a tip section containing ten pairs of platinum electrodes that can easily be seen under fluoroscopy. The Deflectable Tip CristaCath catheters facilitate simultaneous local electrograms due to the greater number of electrodes and their deflection capabilities. The deflection is controlled at the proximal end by a tubular handpiece in which a piston slides. When the piston is pushed forward with the thumbknob, the tip is deflected (curved). When the piston is pulled back, the tip straightens. The high-torque shaft allows the plan of the curved tip to be rotated to facilitate accurate positioning of the catheter tip at the desired site. {5}------------------------------------------------ The item numbers included in the scope of this submission are as follows: | ltem Number | Description | Sheath<br>Usable<br>Length<br>(cm) | French<br>Size | Curve | Number of<br>Electrodes | Spacing<br>(mm) | |-------------|-----------------------------------------|------------------------------------|----------------|-------------------|-------------------------|-----------------| | D7A20131RT | CristaCath<br>Diagnostic EP<br>Catheter | 115 | 7F | D-<br>Type/Crista | 20 | 1-3-1 | Table 5.1: Item Numbers # Indications for Use: The Reprocessed CristaCath Diagnostic EP Catheter is indicated for electrophysiological mapping of cardiac structures, i.e. stimulation and recording only. The catheter is designed to facilitate electrograms in the atrial regions of the heart. #### Technological Characteristics: The purpose, design, materials, function, and intended use of the CristaCath Diagnostic EP Catheters are identical to the predicate devices. There are no changes to the claims, clinical applications, patient population, performance specifications, or method of operation. In addition, Innovative Health's reprocessing of these devices includes removal of visible soil and decontamination. Each device is inspected and function tested prior to packaging and labeling. # Functional and Safety Testing: Bench and laboratory testing was conducted to demonstrate performance (safety and effectiveness) of the Reprocessed CristaCath Diagnostic EP Catheters. This included the following: - Biocompatibility ● - Cleaning Validation ● - Sterilization Validation ● - Functional Testing - Visual Inspection ● - Dimensional Verification ● - Electrical Continuity and Resistance . - Simulated Use ● - . Mechanical Characteristics - Electrical Safety Testing ● - . Dielectric and Current Leakage - . Packaging Validation The Reprocessed CristaCath Diagnostic Electrophysiology (EP) Catheters are reprocessed no more than one (1) time. Each device is marked and tracked. After the device has reached the maximum number of reprocessing cycles, the device is rejected from further reprocessing. Reprocessing is performed only by Innovative Health. {6}------------------------------------------------ Innovative Health restricts its reprocessing to exclude devices previously reprocessed by other reprocessors. #### Conclusion: Innovative Health concludes that the Reprocessed CristaCath Diagnostic EP Catheters are as safe and effective as the predicate devices described herein.