(69 days)
The CPS Courier Guidewires are intended for use in the coronary and peripheral vasculature.
The Courier Guide wire is a disposable medical device designed for single use only. It consists of a 0.014" diameter stainless steel core wire, the distal end of which is reduced in diameter in a progressive fashion through a centreless grinding operation. The profile of this reduced section affords the product a reduced area of stiffness. The quide wire comes in 5 unique base models distinguished by their distal flexibility portions, the profile varied to provide a range of products of mixed stiffness. This reduced section is covered with a polymer coating of equivalent diameter to the main core body. Underneath the polymer at the distal tip there is a 0.010" platinum/tungsten alloy platinum coil attached to the distal tip of the core by means of solder joints. This provides greater visibility on x-ray equipment.
Here's an analysis of the provided 510(k) summary regarding the acceptance criteria and the study that proves the device meets those criteria:
1. Table of Acceptance Criteria and Reported Device Performance:
| Performance Characteristic | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|
| Mechanical Properties | Equivalent to predicate device, within design parameters | - Tensile strength: Successfully completed testing. - Torque strength: Successfully completed testing. - Torque response: Successfully completed testing. - Coating performance: Successfully completed testing. - Tip flexibility: Successfully completed testing. |
| Imaging Properties | Sufficient for visibility on X-ray equipment | - Radiopacity: Successfully completed testing. The device incorporates a 0.010" platinum/tungsten alloy platinum coil at the distal tip for greater visibility on x-ray equipment. |
| Device Compatibility | Compatible with catheters | - Catheter compatibility testing: Successfully completed testing. |
| Material/Shelf Life | Biocompatible and maintain performance over time | - Accelerated aging: Successfully completed testing. - Biocompatibility testing: Successfully completed in compliance with ISO 10993-1. |
| Overall Performance | Safe, effective, and performs as well as the predicate devices | - "The successful tests demonstrated the CPS Courier Guidewires consistently performed within their design parameters, are safe and effective and perform as well as the predicate devices." Implies meeting all relevant performance and safety benchmarks for guidewires, consistent with the predicate. |
Study Proving Acceptance Criteria are Met:
The document describes a series of performance tests. These tests collectively serve as the study demonstrating that the CPS Courier Guidewires meet the (implied) acceptance criteria, primarily by showing substantial equivalence to the predicate device and adherence to design parameters.
Detailed Information about the Study:
The provided 510(k) summary focuses on demonstrating substantial equivalence to a previously cleared predicate device (the Brivant Guidewire). The "study" in this context is a series of engineering and biocompatibility tests rather than a clinical trial involving human subjects or a diagnostic accuracy study.
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Sample Size: The document does not specify the exact sample sizes used for each individual test (tensile strength, torque response, etc.). These are typically described in detailed test reports, which are summarized here.
- Data Provenance: The document does not explicitly state the country of origin of the data. However, the submitter, Brivant Limited, is located in Galway, Ireland, suggesting the testing was likely conducted in Ireland or by a contract lab working for them. The testing is prospective, as it's being conducted specifically to support this 510(k) submission for a new device design.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This question is not applicable in the context of this device. The CPS Courier Guidewire is a mechanical device, not a diagnostic or imaging interpretation tool that requires expert human interpretation to establish "ground truth." The ground truth for mechanical and material properties is established through standardized engineering test methods (e.g., measuring tensile strength using a testing machine) and adherence to industry standards (e.g., ISO 10993-1 for biocompatibility).
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- This question is not applicable. Adjudication methods like '2+1' or '3+1' are used for resolving discrepancies in human expert interpretation in studies involving diagnostic accuracy or image review. For physical device testing, the results are typically quantitative measurements against predefined specifications; discrepancies would involve re-testing or investigation of the test setup, not expert adjudication of interpretations.
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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. The CPS Courier Guidewire is a medical device (guidewire) used in procedures, not an AI-powered diagnostic or decision-support tool. Therefore, an MRMC study comparing human reader performance with or without AI assistance is irrelevant to this submission.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- This question is not applicable. As previously stated, this is a physical medical device, not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The ground truth for this device is based on engineering specifications, material science principles, and established international standards. For example:
- Mechanical properties: Ground truth is defined by the physical measurement of properties (e.g., force required for tensile failure, torque applied) and comparison against design specifications and predicate device performance.
- Biocompatibility: Ground truth is established by meeting the requirements of ISO 10993-1, which involves standard tests for cytotoxicity, irritation, sensitization, etc., interpreted by toxicologists or biologists based on established scientific principles.
- Radiopacity: Ground truth is the visual confirmation of visibility under X-ray, often quantified by comparing it to known radiopaque materials or the predicate device.
- The ground truth for this device is based on engineering specifications, material science principles, and established international standards. For example:
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The sample size for the training set:
- This question is not applicable. The concept of a "training set" applies to machine learning algorithms. This device is not an AI/ML product. The tests conducted are for verification and validation of the physical device and its materials.
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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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CPS Courier Guidewire Special 510(k)
K073082
1/2
510(k) Summary
This 510(k) summary is being submitted in accordance with the requirements of 21 CFR 807.92.
(1) Submitter's Name / Contact Person: Brivant Limited,
Parkmore West Business Park Galway. Ireland
JAN - 9 2008
Contact Person:
Tomas Furey, Vice President Regulatory Affairs Tel: +353 91 385037 Fax: +353 91 766598
(2) Summary Preparation Date:
October 25, 2007
(3) Device Name and Classification:
Trade Name:
Common Name:
Classification Name:
Device Classification:
CPS Courier Guidewire, Extra Firm, Straight Tip. Catalogue Number: 901008-01
CPS Courier Guidewire, Extra Firm, J Tip. Catalogue Number: 901008-02
CPS Courier Guidewire, Firm, Straight Tip. Catalogue Number: 901008-03
CPS Courier Guidewire, Firm, J Tip. Catalogue Number: 901008-04
CPS Courier Guidewire, Medium, Straight Tip. Catalogue Number: 901008-05
CPS Courier Guidewire, Medium, J Tip. Catalogue Number: 901008-06
CPS Courier Guidewire, Soft, Straight Tip. Catalogue Number: 901008-07
CPS Courier Guidewire, Soft, J Tip. Catalogue Number: 901008-08
CPS Courier Guidewire, Extra Soft, Straight Tip. Catalogue Number: 901008-09
CPS Courier Guidewire, Extra Soft, J Tip. Catalogue Number: 901008-10
Guidewire
Catheter, Guidewire
Class II, 21 CFR §870.1330
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CPS Courier Guidewire Special 510(k)
Pg 2/2
(4) Summary of Substantial Equivalence
The CPS Courier quidewires have minor design differences with the predicate Brivant guidewire. The Brivant Guidewire has the same intended use and fundamental technology as the predicate Brivant Guidewire. The technical features are closely similar and where there are differences these differences are minor such that they do not affect safety or effectiveness and there is also supporting data to demonstrate that the new technical features have not diminished safety or effectiveness - as a result the CPS Courier Guidewire is substantially equivalent to the Brivant Guidewire predicate.
(5) Description of the Device:
The Courier Guide wire is a disposable medical device designed for single use only. It consists of a 0.014" diameter stainless steel core wire, the distal end of which is reduced in diameter in a progressive fashion through a centreless grinding operation. The profile of this reduced section affords the product a reduced area of stiffness. The quide wire comes in 5 unique base models distinguished by their distal flexibility portions, the profile varied to provide a range of products of mixed stiffness. This reduced section is covered with a polymer coating of equivalent diameter to the main core body. Underneath the polymer at the distal tip there is a 0.010" platinum/tungsten alloy platinum coil attached to the distal tip of the core by means of solder joints. This provides greater visibility on x-ray equipment.
(6) Statement of Intended Use:
The CPS Courier Guidewires are intended for use in the coronary and peripheral vasculature.
(7) Technological Characteristics.
Comparisons of the proposed and predicate device show that the technological characteristics such as materials, performance characteristics, sterilization and packaging are substantially equivalent to the currently marketed device.
(8) Summary of Testing:
Performance testing involving the following testing has been completed tensile strength, torque strength, torque response, coating performance, radiopacity, tip flexibility, catheter compatibility testing, accelerated aging and biocompatibility testing in compliance with ISO 10993-1 has been successfully completed. The successful tests demonstrated the CPS Courier Guidewires consistently performed within their design parameters, are safe and effective and perform as well as the predicate devices.
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Public Health Service
JAN - 9 2008
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Brivant, LTD c/o Mr. Thomas Furey Vice President Regulatory Affairs Parkmore West Business Park Galway, Ireland
Re: K073082
Trade Name: CPS Courier Guidewire Regulation Number: 21 CFR 870.1330 Regulation Name: Catheter guidewire Regulatory Class: Class II Product Code: DQX Dated: December 18, 2007 Received: December 20, 2007
Dear Mr. Furey:
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 comply with all the Act's requirements, including, but not limited to: registration and listing (21
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Page 2 - Mr. Thomas Furey
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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometrics' (OSB) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Dina R. Vuchner
ABram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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દ્વાર)
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CPS Courier Guidewire Special 510(k)
Indications for Use
510(k) Number (if known): K073082
Device Name: CPS Courier Guidewire
Indications for Use:
The CPS Courier Guidewires are intended for use in the coronary and peripheral vasculature.
Prescription Use X (Per 21 CFR 801 Subpart D)
AND/OR
Over the Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Dune R. Richter
(Division Sign-Off)
Division of Cardiovascular Devices
510(k) Number K073082
§ 870.1330 Catheter guide wire.
(a)
Identification. A catheter guide wire is a coiled wire that is designed to fit inside a percutaneous catheter for the purpose of directing the catheter through a blood vessel.(b)
Classification. Class II (special controls). The device, when it is a torque device that is manually operated, non-patient contacting, and intended to manipulate non-cerebral vascular guide wires, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.