(23 days)
The CPCA2000™ Counterpulsation System is a non-invasive external counterpulsation device intended for use in the treatment of patients with stable or unstable angina pectoris, congestive heart failure, acute myocardial infarction and cardiogenic shock. Use of this device may reduce pain and impairment associated with angina pectoris, congestive heart failure or myocardial infarction and may enhance coronary function.
The CPCA2000 Counter Pulsation System consists of a portable console containing computer, electrocardiogram. plethysmogram, pump and reservoir, integral strip chart recorder, and leg cuffs and hoses. The microprocessor is used to operate and monitor the system via proprietary software, with the operator using touch screen interface to control its operation. The screen displays information pertinent to operating the system, as well as treatment parameters and patient waveforms during use. An external floppy disk drive is used to record data onto transferable media, and a printer is used to produce a hard copy of site, patient and physiologic data. The system accommodates the use of any bed or treatment table.
The provided document is a 510(k) summary for the CPCA2000 Counterpulsation System. It focuses on demonstrating substantial equivalence to a predicate device and outlines non-clinical tests conducted.
It does not contain the kind of information typically found in a clinical study report that would establish acceptance criteria and prove a device meets them with specific performance metrics. This type of information is usually found in clinical trial results, which are not detailed in this regulatory submission.
Therefore, I cannot provide the requested information from the given document. The document primarily describes:
- Device Name: CPCA2000™ Counterpulsation System
- Intended Use: Treatment of patients with stable or unstable angina pectoris, congestive heart failure, acute myocardial infarction, and cardiogenic shock.
- Predicate Device: Enhanced External Counterpulsation Device - Model EECP-MC2 (K940264).
- Non-Clinical Tests:
- IEC60601-1-2; 2001 Medical Electrical Equipment Safety (Electromagnetic Compatibility)
- UL 2601-1 Medical Electrical Equipment Safety
- Software Verification & Validation (per CDRH guidance)
- Device Risk & Hazard Analysis (per 21CFR820.30(g), Design Validation)
The document asserts that the "principle technological and functional characteristics of the current device are same as the predicate devices" and that treating congestive heart failure patients "does not significantly change the safety and effectiveness of the device" or "require any changes in software, device design or treatment regimen." This suggests that the substantial equivalence argument relies heavily on the predicate device's established safety and effectiveness.
To answer your specific questions, a clinical study report would be required, which is not available in these provided materials.
§ 870.5225 External counter-pulsating device.
(a)
Identification. An external counter-pulsating device is a noninvasive, prescription device used to assist the heart by applying positive or negative pressure to one or more of the body's limbs in synchrony with the heart cycle.(b)
Classification. (1) Class II (special controls) when the device is intended for the treatment of chronic stable angina that is refractory to optimal anti-anginal medical therapy and without options for revascularization. The special controls for this device are:(i) Nonclinical performance evaluation of the device must demonstrate a reasonable assurance of safety and effectiveness for applied pressure, synchronization of therapy with the appropriate phase of the cardiac cycle, and functionality of alarms during a device malfunction or an abnormal patient condition;
(ii) Reliabilities of the mechanical and electrical systems must be established through bench testing under simulated use conditions and matched by appropriate maintenance schedules;
(iii) Software design and verification and validation must be appropriately documented;
(iv) The skin-contacting components of the device must be demonstrated to be biocompatible;
(v) Appropriate analysis and testing must be conducted to verify electrical safety and electromagnetic compatibility of the device; and
(vi) Labeling must include a detailed summary of the device-related and procedure-related complications pertinent to use of the device.
(2) Class III (premarket approval) for the following intended uses: Unstable angina pectoris; acute myocardial infarction; cardiogenic shock; congestive heart failure; postoperative treatment of patients who have undergone coronary artery bypass surgery; peripheral arterial disease associated with ischemic ulcers rest pain or claudication, threatened gangrene, insufficient blood supply at an amputation site, persisting ischemia after embolectomy or bypass surgery, and/or pre- and post-arterial reconstruction to improve runoff; diabetes complicated by peripheral arterial disease or other conditions possibly related to arterial insufficiency including nocturnal leg cramps and/or necrobiosis diabeticorum; venous diseases, including prophylaxis of deep vein thrombophlebitis, edema (e.g., chronic lymphedema) and/or induration (e.g., stasis dermatitis) associated with chronic venous stasis, venous stasis ulcers, and/or thrombophlebitis; athletic injuries, including Charley horses, pulled muscles and/or edematous muscles; necrotizing cellulitis.
(c)
Date premarket approval application (PMA) or notice of completion of product development protocol (PDP) is required. A PMA or notice of completion of a PDP is required to be filed with FDA on or before March 31, 2014, for any external counter-pulsating device, with an intended use described in paragraph (b)(2) of this section, that was in commercial distribution before May 28, 1976, or that has, on or before March 31, 2014, been found to be substantially equivalent to any external counter-pulsating device, with an intended use described in paragraph (b)(2) of this section, that was in commercial distribution before May 28, 1976. Any other external counter-pulsating device with an intended use described in paragraph (b)(2) of this section shall have an approved PMA or declared completed PDP in effect before being placed in commercial distribution.