K Number
K101885
Manufacturer
Date Cleared
2010-09-09

(65 days)

Product Code
Regulation Number
870.1250
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The C315 is indicated for the introduction of various types of pacing or defibrillator leads and catheters.

Device Description

The Medtronic C315 Delivery Catheter contains one catheter and one dilator constructed of Polyether Block Amide and Polyethylene respectively. It is designed to aid in the introduction of various types of pacing or defibrillator leads and catheters. There are seven models in the Medtronic C315 Delivery Catheter product family, all of which have the same inner and outer diameter (5.4Fr and 7.0Fr respectively). The models differ in useable length, which varies from 20cm to 43cm. Proximally, the C315 is equipped with a hemostatic valve, and the distal tip is radiopaque to facilitate imaging under fluoroscopy. The C315 is designed to be slittable, thereby allowing its removal after device placement. A variety of curves are available to accommodate various anatomies and different lead locations.

AI/ML Overview

The Medtronic C315 Delivery Catheter is a medical device designed to aid in the introduction of various types of pacing or defibrillator leads and catheters.

Here's an analysis of its acceptance criteria and the study that proves it meets those criteria:

1. Table of Acceptance Criteria and Reported Device Performance:

Acceptance Criteria (Test Performed)Reported Device Performance
Dimensional MeasurementMet specified design and performance requirements
Catheter Tensile StrengthMet specified design and performance requirements
Curve StiffnessMet specified design and performance requirements
Straight Shaft Distal Segment CompressionMet specified design and performance requirements
RadiopacityMet specified design and performance requirements
Curve RetentionMet specified design and performance requirements
Manual Slitting of CatheterMet specified design and performance requirements
Guide Catheter Leakage Test (Catheter Shaft Related)Met specified design and performance requirements
Guide Catheter Leakage Test (Valve Related)Met specified design and performance requirements
Torsional StrengthMet specified design and performance requirements
Chemical CompatibilityMet specified design and performance requirements
Straight Shaft Kink ResistanceMet specified design and performance requirements
Guide Catheter Interface TestingMet specified design and performance requirements
Transport SimulationMet specified design and performance requirements
Seal StrengthMet specified design and performance requirements
Pouch Seal AreaMet specified design and performance requirements
Dye Penetration TestMet specified design and performance requirements
Biocompatibility (various tests per ISO 10993-1:2009)Verified to be biocompatible
Sterilization Validation (EtO sterilization process)Data and information presented to support sterilization

2. Sample Size Used for the Test Set and Data Provenance:

The document describes "Device integrity testing" using "C315 devices." However, it does not specify the exact sample size for each individual bench test. The data provenance is retrospective, as it refers to testing done on the device to prove its equivalency to predicate devices. The country of origin of the data is not explicitly stated beyond Medtronic Ireland being the applicant.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:

This information is not applicable as the described studies are in-vitro bench tests and biocompatibility evaluations, not studies requiring expert interpretation of clinical data. Therefore, there is no "ground truth" established by experts in this context.

4. Adjudication Method for the Test Set:

This information is not applicable as the studies are bench tests and do not involve human interpretation or adjudication of results in the way clinical studies would. The assessment is against pre-defined engineering and biocompatibility specifications.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical investigation has been performed for this device."

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done:

Not applicable. This device is a physical catheter, not an algorithm or AI system. Therefore, standalone algorithm performance is not relevant.

7. The Type of Ground Truth Used:

For the in-vitro bench tests, the "ground truth" is defined by pre-established engineering specifications and performance requirements for medical device functionality and safety. For biocompatibility, the ground truth is established by adherence to international standards (ISO 10993-1:2009) and the results of various biological tests.

8. The Sample Size for the Training Set:

Not applicable. This device is a physical catheter, not an AI or machine learning model that requires a training set.

9. How the Ground Truth for the Training Set Was Established:

Not applicable. As mentioned above, there is no training set for this type of device.

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CONFIDENTIAL May not be reproduced without written permission from Medironic

Parkmore Business Park West

Senior Regulatory Affairs Specialist

Parkmore Business Park West

Phone: (011-353-91) 708990

Fax: (011-353-91) 708672

July 02, 2010

Galway Ireland

Galway Ireland

Medtronic Ireland

Elaine O'Connor

Medtronic Ireland

510(k) Summary

Date Prepared:

Applicant:

Primary Correspondent:

Alternate Correspondent:

Bruce Backlund Senior Regulatory Affairs Specialist Cardiac Rhythm Disease Management 8200 Coral Sea Street MS MVS11 Mounds View MN 55112 USA Phone: (763) 526-2357 Fax: (651) 367-0603 Email: bruce.j.backlund@medtronic.com

Email: elaine.oconnor(@medtronic.com

Proprietary Name:

Medtronic C315 Delivery Catheter

Medtronic Ireland C315 Delivery Catheter Special 510(k)

K101885

SEP 0 9 2010

8

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Common Name:C315 Delivery Catheter
Device Classification Name:Catheter, PercutaneousClass II, 21 CFR 870.1250
Product Code:DQY
Device Description:The Medtronic C315 Delivery Catheter contains one catheter andone dilator constructed of Polyether Block Amide andPolyethylene respectively. It is designed to aid in the introductionof various types of pacing or defibrillator leads and catheters.There are seven models in the Medtronic C315 Delivery Catheterproduct family, all of which have the same inner and outerdiameter (5.4Fr and 7.0Fr respectively). The models differ inuseable length, which varies from 20cm to 43cm. Proximally, theC315 is equipped with a hemostatic valve, and the distal tip isradiopaque to facilitate imaging under fluoroscopy. The C315 isdesigned to be slittable, thereby allowing its removal after deviceplacement. A variety of curves are available to accommodatevarious anatomies and different lead locations.
Indications For Use:The C315 is indicated for the introduction of various types ofpacing or defibrillator leads and catheters. This is identical to thepredicate Acumen Single Lumen Delivery Sheath (510(k) clearedK080500).
Substantially EquivalentDevices:The Medtronic C315 Delivery Catheter product family uses similartechnology and has similar intended uses, function, materials andmethod of operation to the predicates Acumen Single LumenDelivery Sheath (510(k) K080500) and Attain Command™ 6250product family (510(k) K090659).
Summary of TechnologicalCharacteristics:The Medtronic C315 Delivery Catheter consists of a hydrophiliccoated inner liner to aid lubricity, and an outer jacket, with a wirebraid encapsulated between the inner liner and outer layers. Thedistal tip is radiopaque to facilitate imaging under fluoroscopy andthe hub at the proximal end of the shaft consists of an integratedvalve and flushing side port. The catheter is packaged with adilator. The technological characteristics of the Medtronic C315Delivery Catheter are identical to the predicate Acumen SingleLumen Delivery Sheath (510(k) K080500).
Summary of Studies:Device integrity testing was performed to support the equivalency of the Medtronic C315 Delivery Catheter product family to the predicates. The following in-vitro bench tests were completed using C315 devices:● Dimensional Measurement● Catheter Tensile Strength● Curve Stiffness● Straight Shaft Distal Segment Compression● Radiopacity● Curve Retention● Manual Slitting of Catheter● Guide Catheter Leakage Test (Catheter Shaft Related)● Guide Catheter Leakage Test (Valve Related)● Torsional Strength● Chemical Compatibility● Straight Shaft Kink Resistance● Guide Catheter Interface Testing● Transport Simulation● Seal Strength● Pouch Seal Area● Dye Penetration TestThe Medtronic C315 Delivery Catheter product family met all specified design and performance requirements.
Summary of Clinical Data:No clinical investigation has been performed for this device.

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Medtronic Ireland C315 Delivery Catheter
Special 510(k)

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MedIronic Ireland
C315 Delivery Catheter
Special 510(k)

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The testing which supports the biocompatibility of the Medtronic Biocompatibility C315 Delivery Catheter product family is consistent with Information: International Standard ISO10993-1:2009 "Biological Evaluation of Medical devices- Part 1: Evaluation and Testing." When classified according to this standard, the catheter and dilator included in the Medtronic C315 Delivery Catheter product family are categorized as external communicating devices with limited exposure i.e. whose contact with circulating blood is ≤ 24 hours. The following Biocompatibility tests were performed: Cytotoxicity Using ISO Elution Method . ASTM Hemolysis Study . Material Mediated Pyrogen t ISO Maximization Sensitization Study . ISO Intracutaneous Study . ISO Systemic Toxicity Study . C3a and SC5b-9 Complement Activation Assay Study . Physicochemical Tests for Plastic . ASTM Partial Thromboplastin Time Study (PTT) . In Vivo Thromboresistance Study in the Dog, Jugular Vein . The biocompatibility evaluation completed verifies that the Medtronic C315 Delivery Catheter product family is biocompatible. The Medtronic C315 Delivery Catheter product family will be Sterilization Validation: The Meditorne CSTS Donvery Casinory Casine (EtO) sterilization nrocess. Through the data and information presented, Medtronic Ireland Conclusion: I hrough the data and information product family to considers the modifications to the predicate devices.

Medtronic Ireland C315 Delivery Catheter Special 510(k)

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/4/Picture/1 description: The image shows the logo for the United States Department of Health and Human Services. The logo consists of a stylized eagle with three tail feathers, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged in a circle around the eagle. The logo is black and white.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Medtronic, Inc. c/o Ms. Elaine O'Connor Primary Regulatory Affairs Specialist Medtronic Ireland Parkmore Business Park West Galway Ireland

SEP 0 9 2010

Re: K101885

Trade/Device Name: Medtronic C315 Delivery Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II (two) Product Code: DOY Dated: August 19, 2010 Received: August 23, 2010

Dear Ms. O'Connor:

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. 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.

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Page 2 - Ms. O'Connor

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 (reporting of medical device-related adverse events) (21 CFR 803); 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

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

Enclosure

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CONFIDENTIAL

May not be reproduced without written permission from Medtronic

7

Indication for UseK101885
510(k) Number (if known):K101885
SEP 09 2010
Device Name:Medtronic C315 Delivery Catheter
Indications for Use:The C315 is indicated for the introduction of various types of pacing or defibrillator leads and catheters.

Prescription Use (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)

W.M.P

(Division Sign-Off) Division of Cardiovascular Devices

510(k) Number K106885

Medtronic Ireland C315 Delivery Catheter Special 510{k}

§ 870.1250 Percutaneous catheter.

(a)
Identification. A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.(b)
Classification. Class II (performance standards).