K Number
K180178
Device Name
Introducer Set
Date Cleared
2018-09-10

(231 days)

Product Code
Regulation Number
870.1340
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Femoral artery Introducer Set: The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through artery while minimizing blood loss during interventional procedures.

Radial Artery Introducer Set. The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through the skin into the radial artery while minimizing blood loss during interventional procedures.

Device Description

This set classifies two types: Femoral Artery and Radial Artery. The Femoral Artery introducer set consist of a sheath introdcuer, dilator, needle, Guidewire. The Radial Artery introducer set consist of a sheath introdcuer lubricated with/without hydrophilic coating, dilator, I.V. cannula /Introducer needle,Guidewire (with/without hydrophilic coating).

The Introducer Set consists of sheath introducer, each packaged in a set to together with a dilator, introdcuer needle, and guidewire. The introducer sheath is fitted with a hemostasis valve to minimize blood loss during catheter introduction and/or exchange. A side port with tubing connected to a 3-way stopcocks is used for injection contrast medium. The dilator is provided to aid in the introduction of sheath to the target vessel. The Introducer needle/I.V. Cannula is provided a conduit for insertion of the guidewire into the vascular system. The guidewire is utilized as a guiding mechanism for the introducer sheath into the vascular system.

AI/ML Overview

The provided document is a 510(k) premarket notification summary for a medical device (KDL Introducer Set). It outlines the device's technical specifications, intended use, and comparison to a predicate device. However, this document describes a Class II medical device (a catheter introducer) and not an AI/ML-driven device. Therefore, the information typically requested in your prompt regarding acceptance criteria and studies for AI/ML device performance (such as sample size for test sets, data provenance, expert ground truth adjudication, MRMC studies, standalone algorithm performance, training set details, etc.) is not applicable to this type of traditional medical device.

Instead, the document details non-clinical performance testing and biocompatibility testing to demonstrate substantial equivalence to a predicate device.

Here's a breakdown of the relevant information provided in the document concerning how the device meets acceptance criteria:

1. Table of Acceptance Criteria and Reported Device Performance:

The document doesn't present a single table with "acceptance criteria" and "reported device performance" in the way one might for an AI/ML diagnostic output (e.g., sensitivity, specificity thresholds). Instead, it lists various "Testing item" and "Reference Standard/Guidance" for different components of the Introducer Set. The document then states:

"All sample tested met the standard applicable to each test." and "Base on the result of the performance and biocompatibility testing, the proposed device, Introducer Set, met all the predetermined acceptance criteria of design verification and validation as specified by applicable standards, guidance, and test protocols."

Here's a re-composition of this information into a table format based on the supplied text:

ComponentTesting ItemReference Standard/GuidanceReported Device Performance
Sheath IntroducerAppearanceSection 4.3 of ISO 11070:2014Met standard
O.D and I.D.Section 7.2 a) of ISO 11070:2014Met standard
Effective LengthSection 7.2 b) of ISO 11070:2014 (detail size see section V in this submission)Met standard
Luer connectorISO 594-2Met standard
Sheath introducer leakageSection 7.3 of ISO 11070:2014Met standard
Haemostasis valve leakageSection 7.4 of ISO 11070Met standard
Peak tensile forceSection 7.6 of ISO 11070Met standard
Coating Integrity (if applicable)In-house standardMet standard
Coating Friction force (if applicable)In-house standardMet standard
Radio-detectabilityASTM F640-12Met standard
DilatorAppearanceSection 4.3 of ISO 11070:2014Met standard
O.D. and I.D.Section 9.2 a), b) of ISO 11070:2014Met standard
Effective LengthSection 9.2 c) of ISO 11070:2014Met standard
Luer connectorISO 594-2Met standard
Strength of unionSection 9.3.3 of ISO 11070:2014Met standard
Coating Friction force (if applicable)In-house standard TBD (specific to radial artery and guidewire)Met standard
Coating Integrity (if applicable)In-house standard TBD (specific to radial artery and guidewire)Met standard
Radio-detectabilityASTM F640-12Met standard
Introducer NeedleAppearanceSection 4.3 of ISO 11070:2014Met standard
O.D and I.D.Table 1 of ISO 9626Met standard
Effective LengthSection 5.2 of ISO 11070:2014Met standard
Luer connectorISO 594-1:1986Met standard
Strength unionSection 5.4.2 of ISO 11070:2014Met standard
Corrosion resistanceSection 4.4 ISO 11070:2014Met standard
Needle pointSection 5.3 of ISO 11070Met standard
PatencySection 13.2 ISO 7864Met standard
StiffnessSection 5.8 of ISO 9626Met standard
Breakage resistanceSection 5.9 of ISO 9626Met standard
Limits for acidity and alkalinitySection 5.4 of ISO 9626Met standard
GuidewireAppearanceSection 4.3 of ISO 11070:2014Met standard
O.D.Section 8.2 a) of ISO 11070:2014Met standard
LengthSection 8.2 b) of ISO 11070:2014Met standard
Corrosion resistanceSection 4.4 ISO 11070:2014Met standard
Fracture testSection 8.4 of ISO 11070:2014Met standard
Flexing testSection 8.5 of ISO 11070:2014Met standard
Peak tensile forceSection 8.6 of ISO 11070:2014Met standard
Torque strength3b of FDA Guidance for Coronary and Cervicovascular Guidewire Guidance 1995Met standard
Torqueability3c of FDA Guidance for Coronary and Cervicovascular Guidewire Guidance 1995Met standard
Tip flexibility3d of FDA Guidance for Coronary and Cervicovascular Guidewire Guidance 1995Met standard
Coating Integrity (if applicable)In-house standard TBD (specific to radial artery and guidewire)Met standard
Coating Friction force (if applicable)In-house standard TBD (specific to radial artery and guidewire)Met standard
Radio-detectabilityASTM F640-12Met standard
BiocompatibilityIn Vitro HemolyticASTM F756-13 Standard Practice for assessments of hemolytic properties of materialMet standard
In Vitro CytotoxicityISO 10993-5:2009, Biocompatibility Evaluation of Medical Device - Part 5: Tests for In Vitro CytotoxicityMet standard
Intracutaneous ReactivityISO 10993-10:2010, Biocompatibility Evaluation of Medical Device - Part 10: Tests for Irritation and Skin SensitizationMet standard
Skin SensitizationISO 10993-10:2010, Biocompatibility Evaluation of Medical Device - Part 10: Tests for Irritation and Skin SensitizationMet standard
Acute Systemic ToxicityISO 10993-11:2006, Biocompatibility Evaluation of Medical Device - Part 11: Tests for systemic toxicityMet standard
PyrogenISO 10993-11:2006, Biocompatibility Evaluation of Medical Device - Part 11: Tests for systemic toxicityMet standard
In Vivo ThrombogenicityISO 10993-4:2002/Amd1:2006, Biocompatibility Evaluation of Medical Device - Part 4: Selection of tests for interactions with bloodMet standard

2. Sample size used for the test set and the data provenance:

  • Sample Size: The document does not specify the exact sample size for each test. It states "The performance tests were performed on the non-aged and ages to 3 years sample." This implies that samples were tested for immediate performance and also after accelerated aging simulating 3 years of shelf life. Specific lot sizes or number of units tested per parameter are not disclosed in this summary.
  • Data Provenance: Not explicitly stated, however, the manufacturer is Shanghai Kindly Medical Instruments Co., Ltd. in Shanghai, China. The testing would have been conducted by or for them, likely in China. The study is a non-clinical performance testing and biocompatibility assessment, rather than a clinical study with patient data.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

  • This question is not applicable as this is a traditional medical device undergoing physical and biological performance testing, not an AI/ML device relying on interpretation of medical images or data by experts to establish ground truth. The "ground truth" here is defined by the technical specifications and standards (e.g., ISO, ASTM).

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

  • This question is not applicable for the same reason as point 3. Testing involves objective measurements against established engineering and biocompatibility standards.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

  • This question is not applicable as the device is not an AI-driven product nor does it involve human readers interpreting medical cases.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

  • This question is not applicable as the device is not an algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

  • The "ground truth" for this device is based on engineering specifications, established international standards (ISO, ASTM), and FDA guidance documents for medical devices (specifically catheter introducers and guidewires). For biocompatibility, it's based on standard biological test methods outlined in ISO 10993 and ASTM F756.

8. The sample size for the training set:

  • This question is not applicable as this is a manufactured medical device, not an AI/ML model that requires a training set.

9. How the ground truth for the training set was established:

  • This question is not applicable for the same reason as point 8.

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Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 10, 2018

Shanghai Kindly Medical Instruments Co., Ltd. Su Jianhai Regulatory Affairs Supervisor No. 925, Jinyuan yi Road, 201803, Shanghai, China

Re: K180178 Trade/Device Name: KDL Introducer Set Regulation Number: 21 CFR 870.1340 Regulation Name: Catheter introducer Regulatory Class: Class II Product Code: DYB Dated: June 4, 2018 Received: August 13, 2018

Dear Jeffery Hui:

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. Although this letter refers to your product as a device, please be avare that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good

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manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Image /page/1/Picture/6 description: The image shows the name "Finn E. Donaldson -S" in a large font. To the right of the name is the text "Digitally signed by Finn E. Donaldson -S". Below that is the text "DN: c=US, o=U.S. Government, ou=HHS, ou=FDA, ou=People, 0.9.2342.19200300.100.1.1=2000979673, cn=Finn E. Donaldson -S Date: 2018.09.10 11:34:58 -04'00'".

for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K180178

Device Name KDL Introducer set

Indications for Use (Describe)

Femoral artery Introducer Set: The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through artery while minimizing blood loss during interventional procedures.

Radial Artery Introducer Set. The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through the skin into the radial artery while minimizing blood loss during interventional procedures.

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)

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510(k) Summary

510(k) Number: K180178

1. Date Prepared: August 31, 2018

2. Submitter

Shanghai Kindly Medical Instruments Co., Ltd. No. 925, Jinyuan yi Road, Shanghai, 201803, China Establishment Registration Number: 3009605245 Contact Person: Xu Jianhai Position: RA Supervisor Tel.:+086-021-59140056 Fax: +086-021-59140056 Email: xujianhai@kdlchina.com

3. Proposed Device

Trade Name: KDL Introducer Set Review Panel: Cardiovascular Regulation Number: 21 CFR 870.1340 Regulation name: Catheter introducer Regulation Class: Class II Product Code: DYB.

4. Predicate device

510(k) Number: K140768 Product Name: Brilliant™ Introducer Kit Manufacturer: Lepu Medical Tchnology (Beijing) Co., Ltd.

5. Device description

This set classifies two types: Femoral Artery and Radial Artery. The Femoral Artery introducer set consist of a sheath introdcuer, dilator, needle, Guidewire. The Radial Artery introducer set consist of a sheath introdcuer lubricated with/without hydrophilic coating, dilator, I.V. cannula /Introducer needle,Guidewire (with/without hydrophilic coating).

The Introducer Set consists of sheath introducer, each packaged in a set to together with a dilator, introdcuer needle, and guidewire. The introducer sheath is fitted with a hemostasis valve to

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minimize blood loss during catheter introduction and/or exchange. A side port with tubing connected to a 3-way stopcocks is used for injection contrast medium. The dilator is provided to aid in the introduction of sheath to the target vessel. The Introducer needle/I.V. Cannula is provided a conduit for insertion of the guidewire into the vascular system. The guidewire is utilized as a guiding mechanism for the introducer sheath into the vascular system.

Indications for Use Statement: 6.

Femoral artery Introducer Set: The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through the skin into the femoral artery while minimizing blood loss during interventional procedures.

Radial Artery Introducer Set: The Introducer set are intended to provide access and facilitate the introduction of guide wires, catheters and other accessory medical devices through the skin into the radial artery while minimizing blood loss during interventional procedures.

7. Non-clinical Test Conclusion

Testing were conducted to ensure the performance of the proposed device throughout the labeled shelf life, verify conformity to the applicable parts of standards and demonstrate substantial equivalence to the predicate device. The performance tests were performed on the non-aged and ages to 3 years sample. All sample tested met the standard applicable to each test.

ComponentTesting itemReference Standard/Guidance
SheathintroducerAppearanceSection 4.3 of ISO 11070:2014
O.D and I.D.Section 7.2 a) of ISO 11070:2014
Effective LengthSection 7.2 b) of ISO 11070:2014(detail size see section V in thissubmission )
Luer connectorISO 594-2
Sheath introducer leakageSection 7.3 of ISO 11070:2014
Haemostasis valve leakageSection 7.4 of ISO 11070
Peak tensile forceSection 7.6 of ISO 11070
Coating IntegrityIn-house standard
Coating Friction forceIn-house standard
Radio-dectectabilityASTM F640-12
DilatorAppearanceSection 4.3 of ISO 11070:2014
O.D. and I.D.Section 9.2 a), b) of ISO11070:2014
Effective LengthSection 9.2 c) of ISO 11070:2014
Luer connectorISO 594-2
Strength of unionSection 9.3.3 of ISO 11070:2014
Coating Friction forceIn-house standard
Coating IntegrityIn-house standard
Radio-dectectabilityASTM F640-12
AppearanceSection 4.3 of ISO 11070:2014
O.D and I.D.Table 1 of ISO 9626
Effective LengthSection 5.2 of ISO 11070:2014
Luer connectorISO 594-1:1986
Strength unionSection 5.4.2 of ISO 11070:2014
IntroducerneedleCorrosion resistanceSection 4.4 ISO 11070:2014
Needle pointSection 5.3 of ISO 11070
PatencySection 13.2 ISO 7864
StiffnessSection 5.8 of ISO 9626
Breakage resistanceSection 5.9 of ISO 9626
Limits for acidity andalkalinitySection 5.4 of ISO 9626
AppearanceSection 4.3 of ISO 11070:2014
O.D.Section 8.2 a) of ISO 11070:2014
LengthSection 8.2 b) of ISO 11070:2014
Corrosion resistanceSection 4.4 ISO 11070:2014
Fracture testSection 8.4 of ISO 11070:2014
Flexing testSection 8.5 of ISO 11070:2014
Peak tensile forceSection 8.6 of ISO 11070:2014
GuidewireToque strength3b of FDA Guidance for Coronaryand Cerebrovascular GuidewireGuidance 1995
Torqueability3c of FDA Guidance for Coronaryand Cerebrovascular GuidewireGuidance 1995
Tip flexibility3d of FDA Guidance for Coronaryand Cerebrovascular GuidewireGuidance 1995
Coating IntegrityIn-house standard
Coating Friction forceIn-house standard
Radio-dectectabilityASTM F640-12

The performance tests have completed per the following ISO standards:

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K180178

Page 3 of 6

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Test ItemReference Standards
In VitroHemolyticASTM F756-13 Standard Practice for assessments of hemolyticproperties of material
In VitroCytotoxicityISO 10993-5:2009, Biocompatibility Evaluation of Medical Device -Part 5: Tests for In Vitro Cytotoxicity
IntracutaneousReactivityISO 10993-10:2010, Biocompatibility Evaluation of Medical Device -Part 10: Tests for Irritation and Shin Sensitization
SkinSensitizationISO 10993-10:2010, Biocompatibility Evaluation of Medical Device -Part 10: Tests for Irritation and Shin Sensitization
Acute SystemicToxicityISO 10993-11:2006, Biocompatibility Evaluation of Medical Device -Part 11: Tests for systemic toxicity
PyrogenISO 10993-11:2006, Biocompatibility Evaluation of Medical Device -Part 11: Tests for systemic toxicity
In VivoThrombogenicityISO 10993-4:2002/Amd1:2006, Biocompatibility Evaluation ofMedical Device - Part 4: Selection of tests for interactions with blood

The biocompatibility tests have completed as follows

Clinical Test 8.

It is not applicable.

Summary Comparing the Technological Characteristics 9.

The subject device has the same intended use, principle of operation, design and technological characteristics as the predicate device. Size, material of components, sheath hub, side port tubing, 3-Way Stopcock Body and cap, dilator tube, dilator hub and Guidewire J-Straightener are different from the predicate device. The finished product has been evaluated the biocompatibility testing and tested on safety and performance testing, and the result were complied with the test requirements and standards. Any the difference of subject device and predicate device did not raise any issues.

ItemProposed DevicePredicate Device(K140768)Remark
Product NameIntroducer setBrilliantTM Introducer Kit/
Product CodeDYBDYBIdentical
Regulation No.21 CFR 870.134021 CFR 870.1340Identical
ClassificationClass IIClass IIIdentical
Intended UseThe Introducer set areintended to provide accessand facilitate theintroduction of guide wire,catheters and otheraccessory medical devicesthrough the skin into femoraland/or radial artery andminimize blood loss duringinterventional procedures.The Brilliant™ IntroducerKit are intended for use tofacilitate the introduction ofguide wires, catheters andother accessory medicaldevices through the skin intoa vein or artery andminimize blood lossassociated with suchintroduction.Identical
Principle ofOperationBy manually operatedBy manually operatedIdentical
ComponentsA Sheath Introducer, adilator, a Needle, a I.V.Needle,a Guidewire withstraightener.A sheath introducer, adilator, a guide wire with aguide wire collimator, apuncture needle;anintravascular catheter withintroducer needle, a scalpeland a syringeIdentical
AnatomicalLocationsFemoral artery and RadialarteryPeripheral VasculatureIdentical
Hydrophilic coatingOnly for Radial Sheath andGuidewire within type radialartery.Sheath, dilator, guidewireAnalysis 2
Sheath hemostasiscontrolHemostasis sealHemostasis sealIdentical
Product Specification
Sheath length110mm, 160mm70mm~240mmAnalysis 3
Sheath French Size5F~8F4F~7FAnalysis 4
Guidewire Diameter0.038", 0.021",0.025"0.018"~0.035"Analysis 5
Guidewire length45cm45cm and 70cmAnalysis 6
Needle18G, 21G, 20G20G and 22GAnalysis 7
Dilator168mm, 218mm125mm~295mmAnalysis 8
Package ContentSheath Introducer, Dilator,Guidewire, Needle orI.V.CannulaSheath Introducer, a dilator,a guidewire, a punctureneedle, intravascular catheterwith introducer needle, aIdentical
scalpel, a syringe.
Material
Outer SheathFluorinated EthylenePropylene (FEP)Fluorinated EthylenePropyleneIdentical
Sheath HubCopolyesterAcrylobutyistyreneAnalysis 9
Side Port TubingPolyvinylchloride(PVC)Polyurethane (PU)PolyurethaneAnalysis 10
Hemostasis ValveSiliconSiliconIdentical
3-Way StopcockBodyPolyethylene (PE)AcrylobutyistyreneAnalysis 11
CapPolycarbonate (PC)PolyethyleneAnalysis 12
ValvePolyethylene (PE)PolyethyleneIdentical
Dilator TubePolypropylene (PP)PolycarbonateAnalysis 13
Dilator HubAcrylobutyistyrene (ABS)AcrylobutyistyreneAnalysis 14
GuidewireStainless Steel, NickelTitanium Alloy,ThermoplasticPolyurethanes (TPU)Stainless Steel, StainlessSteel w/nitinol core, orPolyurethane jacketw/nitinol coilIdentical
GuidewireJ-Straightener(High Density Polyethylene)HDPEPolycarbonateAnalysis 15
Needle hubAcrylobutyistyrene(ABS)/PCPolycarbonateIdentical
Needle TubeStainless SteelStainless SteelIdentical
Protect CoverPP/PEUnknown/
Sterilization MethodEOEOIdentical
Sterility LevelSAL 10-6SAL 10-6Identical

Table 3-1 Technological Characteristics Comparison List

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K180178

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K180178 Page 6 of 6

10. Conclusion

Based on the result of the performance and biocompatibility testing, the proposed device, Introducer Set, met all the predetermined acceptance criteria of design verification and validation as specified by applicable standards, guidance, and test protocols. Therefore, the subject device is substantially equivalent to the legally market predicated device (K140768) in terms of intended use, principle of operation, design and technological characteristics.

§ 870.1340 Catheter introducer.

(a)
Identification. A catheter introducer is a sheath used to facilitate placing a catheter through the skin into a vein or artery.(b)
Classification. Class II (performance standards).