(27 days)
The Short Introducer Sheaths are used to facilitate placing a catheter through the skin into a graft. The dilator is an accessory device which is used by placing it into the sheaths to create an occlusion and further provide support to the wall of the indwelling system.
The Rex Medical Short Introducer Sheaths, offered in both 6F and 7F sizes, are vascular access devices consisting of a central lumen, angled side arm extension, and a hemostasis valve. The device is used under identical indications for use as the predicate device, as other substantially equivalent 510(K) cleared devices.
The provided 510(k) summary for K032569 describes a medical device, the "Short Introducer Sheaths," and its substantial equivalence to a predicate device. However, it does not include the detailed information requested regarding specific acceptance criteria, and a study demonstrating that the device meets those criteria, particularly within the context of AI/ML performance evaluation.
The document focuses on demonstrating substantial equivalence through non-clinical bench testing, comparing the new device to a legally marketed predicate device (Rex Medical Inner-Lock Locking Introducer Sheath, K#022170). The submission clearly states "Discussion of Clinical Tests Performed: Not Applicable." This means there was no human-in-the-loop study, standalone algorithm study, or any clinical trial involving patients to generate performance data for AI/ML criteria.
Therefore, I cannot fulfill the request for information on acceptance criteria, a study proving the device meets them, sample sizes, expert qualifications, or AI-specific details, as that information is not present in the provided text.
Based on the provided document, here's what can be extracted regarding the non-clinical testing discussed:
1. A table of acceptance criteria and the reported device performance
The document states: "Test methodology and acceptance criteria were derived form ISO 11070. Sterile single-use intravascular catheter introducers."
However, specific numerical acceptance criteria (e.g., maximum force to insertion, burst pressure, flow rate thresholds) and the reported performance values against these criteria are not provided in this summary. The summary only mentions that the tests were performed and the conclusion was that there are "no differences in their technological characteristics, thereby not raising any new question of safety or effectiveness."
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document. The testing was non-clinical bench testing, so "data provenance" in the sense of patient data is not applicable.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not provided. The "ground truth" for non-clinical bench testing would be physical measurements and engineering specifications, not expert consensus on clinical data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not provided. This concept is typically relevant for clinical studies or studies involving human review of data.
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
No, an MRMC comparative effectiveness study was not done. The document explicitly states "Discussion of Clinical Tests Performed: Not Applicable." This is a medical device, not an AI/ML diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, a standalone algorithm performance study was not done. This is a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical bench testing, the "ground truth" would be established by "Test methodology and acceptance criteria were derived form ISO 11070. Sterile single-use intravascular catheter introducers." This implies engineering and technical specifications for physical performance (e.g., dimensions, material properties, mechanical strength).
8. The sample size for the training set
This information is not applicable as this is not an AI/ML device and no training set was used.
9. How the ground truth for the training set was established
This information is not applicable as this is not an AI/ML device and no training set was used.
Summary of Device and Equivalence:
- Device Name: Rex Medical Short Introducer Sheaths
- Intended Use: To facilitate placing a catheter through the skin into a graft. The dilator is an accessory device used by placing it into the sheaths to create an occlusion and further provide support to the wall of the indwelling system.
- Predicate Device: Rex Medical Inner-Lock Locking Introducer Sheath (K#022170)
- Basis for Equivalence: Non-clinical bench testing demonstrating that despite minor design differences (elimination of retention feature, single lumen design, slightly different wall thickness, bore ID, and sheath length, and a modified distal cap), there are "no differences in their technological characteristics, thereby not raising any new question of safety or effectiveness."
- Testing Standard Referenced: ISO 11070. Sterile single-use intravascular catheter introducers.
- Clinical Testing: Not Applicable.
- Materials: Identical to predicate device, with a color additive added to the base extrusion of the Short Introducer Sheath. Materials of the predicate device were tested according to ISO 10993-1 (Biological Evaluation of Medical Devices).
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SEP 1 6 2003
EXHIBIT #1
510(K) SUMMARY
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR §807.92.
The assigned 5l0(k) number is:
Submitter's Identification: 1.
Rex Medical 555 North Lane, Suite 6101 Conshohocken, PA 19428
Date Summary Prepared: August 19, 2003
Contact:
Mr. Michael Paris Catheter Engineer
2. Name of the Device:
Short Introducer Sheaths
3. Predicate Device Information:
K#022170, Rex Medical Inner-Lock Locking Introducer Sheath, Rex Medical
Device Description: 4.
The Rex Medical Short Introducer Sheaths, offered in both 6F and 7F sizes, are vascular access devices consisting of a central lumen, angled side arm extension, and a hemostasis valve. The device is used under identical indications for use as the predicate device, as well other substantially equivalent 510(K) cleared devices.
5. Intended Use:
The Short Introducer Sheaths are used to facilitate placing a catheter through the skin into a graft. The dilator is an accessory device which is used by placing it into the sheaths to create an occlusion and further provide support to the wall of the indwelling system.
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6. Comparison to Predicate Devices:
Discussion of Similarities:
The Rex Medical Short Introducer Sheaths are identical to the Rex Medical Inner-Lock Locking Introducer Sheaths as follows: Both devices make use of a dilator with a central lumen to pass over a guidewire during insertion; both devices incorporate the same integrated hemostasis valve, extension tube, clamp, female luer, and proximal cap. Both devices are indicated for dialysis graft access.
Discussion of Differences:
The Short Introducer Sheaths differ from the Inner-Lock Locking Introducer Sheaths by means that the retention feature has been eliminated for the short introducer sheath design. When eliminating the retention feature, the coaxial sheath tubing design, which is required to create the retention feature in the Inner-Lock, is no longer necessary so a less complicated single sheath lumen design was incorporated. The combined wall thickness for the Inner-Lock Sheath Coaxial Tubing is 0.012" (each tubing has a specified wall thickness of .006") and the Short Introducer sheath single lumen design has a wall thickness of 0.010". The usable sheath length for the Short Introducer Sheath design will be 5cm as opposed to the 4cm specified length of the Inner-Lock. The bore ID of the hub is specified as .110" for the Inner-Lock and will be increased to 0.118" for the Short Introducer Sheath. The distal cap used to manufacture the Inner-Lock sheath introducer provided a cut-out section for the rotator knob which is used to activate the retention feature. The Short Introducer Sheath does not require a rotator knob so the distal cap will not provide the cut-out section.
7. Discussion of Non-Clinical Tests Performed for Determination of Substantial Equivalence are as follows:
All testing performed on the Short Introducer Sheath were derived from the risk assessment which evaluated the slight deviation in design from the Inner-Lock Sheath Introducer. Test methodology and acceptance criteria were derived form ISO 11070. Sterile single-use intravascular catheter introducers. All materials used in the Short Introducer Sheath are identical to the Inner-Lock Locking Introducer Sheath with the exception that a color additive was added to the base extrusion. All materials used in the Inner-Lock Locking Introducer Sheath were tested according to ISO 10993-1, Biological Evaluation of Medical Devices.
Discussion of Clinical Tests Performed: 8.
Not Applicable
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9. Conclusions:
The subject device, Short Introducer Sheath, has identical indications use as the Rex Medical Inner-Lock Introducer Sheath. The bench testing contained in our submission demonstrates that there are no differences in their technological characteristics, thereby not raising any new question of safety or effectiveness. Thus, the Short Introducer Sheath is substantially equivalent to the Rex Medical Inner-Lock Introducer Sheath.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus or a bird-like figure with three curved lines above a wavy line.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 1 6 2003
Rex Medical c/o Ms. Susan D. Goldstein-Falk mdi Consultants 55 Northern Blvd., Suite 200 Great Neck, NY 11021
Re: K032569
Trade Name: Short Introducer Sheath Regulation Number: 21 CFR 870.1340 Regulation Name: Catheter Introducer Regulatory Class: Class II (two) Product Code: DYB Dated: August 19, 2003 Received: August 20, 2003
Dear Ms. Goldstein-Falk:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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
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Page 2 - Ms. Susan D. Goldstein-Falk
comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); 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. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4646. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
N. McCarthy
ram D. Zuckerman, M Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Exhibit B
of Page 1 1
510(k) Number (if known): K022561
Device Name: Rex Medical Short Introducer Sheaths
Indications For Use:
The Short Introducer Sheaths are used to facilitate placing a catheter through the skin into a graft. The dilator is an accessory device which is used by placing it into the sheaths to create an occlusion and further provide support to the wall of the indwelling system.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109)
Over-The Counter Use (Optional Format 1-2-96)
YQlaru
(Division Sign-Off)
Division of Cardiovascular Devices
OR
510(k) Number K032569
§ 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).