K Number
K050889
Device Name
FIBRIN ANALYSIS SYSTEM ENDOLUMINAL BRUSH
Date Cleared
2005-08-26

(142 days)

Product Code
Regulation Number
880.5970
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter
Device Description
The CRS Endoluminal Brush product line is an accessory to central venous catheters. Each single use Endoluminal Brush kit contains 2 pairs of latex free gloves, 1- 70% isopropyl alcohol cleaning agent, 1 fibrin brush in transport bag, 1- 10 cc syringe, 2 patient labels, 1 medical drape, 1 over wrap, and Instructions for Use. The brush consists of nylon bristles wound into a flexible stainless steel wire, which is further wound into a tubular, metal, rigid handle. The Brush is enclosed within a no ratiner would at the distal end and is attached to a standard luer lock at its proximal end. The luer lock fitting complies with catheter manufacturers' requirement that only luer-lock connections be used with catheters. The various CRS Endoluminal Brush products defined by the product codes differ mainly in the length of the flexible wire and the diameter of the Brush bristles.
More Information

Not Found

No
The device description and intended use focus on a mechanical brush for sample collection, with no mention of AI/ML terms, image processing, or data analysis capabilities.

No
The device is described as an accessory to central venous catheters and is intended to collect samples for microbiological analysis, which is a diagnostic purpose, not a therapeutic one.

No
The device is intended to collect a sample for microbiological analysis, not to perform the analysis itself. It is a sample collection accessory, not a diagnostic tool.

No

The device description clearly outlines physical components like brushes, wires, handles, syringes, and other accessories, indicating it is a hardware-based medical device.

Based on the provided information, the CRS Endoluminal Brush is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The primary intended use is to collect a sample (biofilm or fibrin) from a catheter for microbiological analysis. The device itself is a tool for sample collection, not for performing the diagnostic test on the sample.
  • Device Description: The description focuses on the physical components of the brush and the kit, designed for the mechanical act of sample collection.
  • Lack of Diagnostic Function: There is no mention of the device performing any analysis, measurement, or interpretation of the sample to provide diagnostic information. The sample is collected and then suitable for microbiological analysis, which would be performed using separate IVD devices or laboratory procedures.

IVD devices are typically used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. The CRS Endoluminal Brush facilitates the collection of the specimen, but it doesn't perform the diagnostic analysis itself.

N/A

Intended Use / Indications for Use

The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter

Product codes (comma separated list FDA assigned to the subject device)

LJS

Device Description

The CRS Endoluminal Brush product line is an accessory to central venous catheters. Each single use Endoluminal Brush kit contains 2 pairs of latex free gloves, 1- 70% isopropyl alcohol cleaning agent, 1 fibrin brush in transport bag, 1- 10 cc syringe, 2 patient labels, 1 medical drape, 1 over wrap, and Instructions for Use. The brush consists of nylon bristles wound into a flexible stainless steel wire, which is further wound into a tubular, metal, rigid handle. The Brush is enclosed within a no ratiner would at the distal end and is attached to a standard luer lock at its proximal end. The luer lock fitting complies with catheter manufacturers' requirement that only luer-lock connections be used with catheters. The various CRS Endoluminal Brush products defined by the product codes differ mainly in the length of the flexible wire and the diameter of the Brush bristles.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

inner lumen surface of an in-dwelling central venous catheter

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Hospital

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The results of bench and clinical testing indicates that the new device is as safe and effective as the predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K993614

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5970 Percutaneous, implanted, long-term intravascular catheter.

(a)
Identification. A percutaneous, implanted, long-term intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings, such as luer hubs, and accessories that facilitate the placement of the device. The device allows for repeated access to the vascular system for long-term use of 30 days or more, and it is intended for administration of fluids, medications, and nutrients; the sampling of blood; and monitoring blood pressure and temperature. The device may be constructed of metal, rubber, plastic, composite materials, or any combination of these materials and may be of single or multiple lumen design.(b)
Classification. Class II (special controls) Guidance Document: “Guidance on Premarket Notification [510(k)] Submission for Short-Term and Long-Term Intravascular Catheters.”

0

AUG 26 2005

K050889 page

EXHIBIT 2

510(k) Summary CRS Medical Diagnostics, Inc. 662 Capitol Drive Pewaukee Wisconsin 53072 Tel 262-264-0047 Fax 262-264-0051 August 19, 2005 Contact: Robert S. Brewer, Chairman of the Board

    1. Identification of the Device: Proprietary-Trade Name: CRS Endoluminal Brush Catheter, intravascular, therapeutic, long-term greater than 30 Classification Names: days, product code LJS Common/Usual Name: Endoluminal Brush
    1. Equivalent legally marketed devices The CRS Endoluminal Brush is IDENTICAL to the FAS Endoluminal Brush, K993614
    1. Indications for Use (intended use) The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter
    1. Description of the Device: The CRS Endoluminal Brush product line is an accessory to central venous catheters. Each single use Endoluminal Brush kit contains 2 pairs of latex free gloves, 1- 70% isopropyl alcohol cleaning agent, 1 fibrin brush in transport bag, 1- 10 cc syringe, 2 patient labels, 1 medical drape, 1 over wrap, and Instructions for Use. The brush consists of nylon bristles wound into a flexible stainless steel wire, which is further wound into a tubular, metal, rigid handle. The Brush is enclosed within a no ratiner would at the distal end and is attached to a standard luer lock at its proximal end. The luer lock fitting complies with catheter manufacturers' requirement that only luer-lock connections be used with catheters. The various CRS Endoluminal Brush products defined by the product codes differ mainly in the length of the flexible wire and the diameter of the Brush bristles.
    1. Safety and Effectiveness, comparison to predicate device. The results of bench and clinical testing indicates that the new device is as safe and effective as the predicate devices.

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K050889
page 2 of 2

CharacteristicPredicate FAS Endoluminal Brush K993614CRS Endoluminal Brush K050889
Intended Use:Intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheterSame
Instructions for Use:Provided with illustrationsSame
Target Population:Patients with indwelling catheters.Same
Anatomical Size:Patient catheterSame
Area of Use:HospitalSame
Design:Per patent 5,405,755Same
Standards Met:ANSI/AAMI
Biocompatibility;
Non-pyrogenicSame
Materials:Nylon bristles wound into a stainless steel flexible wireSame
Supplied items:Measuring tape, patient drape, instructions for use, wire clippers, specimen container with cap, patient identification label2 Pair Latex-free Gloves
Endoluminal Brush In
Transparent Sheath
Cleaning Agent
1 10cc Syringe
1 Overwrap Drape
1 Medical Drape
2 Patient Identification Labels
Package insert
Sterility:Provided packaged and sterile, Gamma
Single Use OnlyProvided packaged and sterile, EO
Single Use Only
Electrical Safety:N/AN/A
Chemical Safety:N/AN/A
Energy Used and/or Delivered:N/AN/A

6. Substantial Equivalence Chart, CRS Endoluminal Brush

7. Conclusion

The CRS Endoluminal Brush does not raise any issues of safety or effectiveness compared to the predicate device because it is in fact the predicate device..

2

Indications for Use

510(k) Number K050889

Device Name: CRS Endoluminal Brush

Indications For Use:

The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is The CNS Endoluminal Brain is inter lumen surface of an in-dwelling central venous catheter

Prescription Use _____________________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart D)

AND/OR AND/OR AND/OR

Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________ (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)


Page 1 of 1

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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, enclosed within a circle. The text "DEPARTMENT OF HEALTH AND HUMAN SERVICES - USA" is written around the perimeter of the circle.

AUG 26 2005

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

CRS Medical Diagnostics, Incorporated C/O Daniel Kamm, P.E. Regulatory Engineer Kamm & Associates P.O. Box 7007 Deerfield, Illinois 60015

Re: K050889

Trade/Device Name: CRS Endoluminal Brush Regulation Number: 21 CFR 880.5970 Regulation Name: Percutaneous, Implanted, Long-term Intravascular catheter Regulatory Class: II Product Code: LJS Dated: June 22, 2005 Received: June 27, 2005

Dear Mr. Kamm:

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 aga\inst 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.

4

Page 2 - Mr. Kamm

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); 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 vour 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 (240) 276-0115. 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/industry/support/index.html.

Sincerely yours,

Susan Punno
for Chiu Lin, Ph.D.

Chiu Lin, Ph.D. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

K050889

Indications for Use

510(k) Number K050889

Device Name: CRS Endoluminal Brush

Indications For Use:

The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Page 1 of 1

Anton Vm

(Division Sign-Off) (Division Sign-Off)
Division of Anesthesiology, General Hospital, Division of Ancotheolorsion of Antal Devices

510(k) Number _