K Number
K103255
Device Name
VASCULAR POSITIONING SYSTEM TM (VPS TM SYSTEM) STYLET
Manufacturer
Date Cleared
2011-02-18

(107 days)

Product Code
Regulation Number
870.1200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The VPS Stylet and Console are indicated for guidance and tip positioning for central venous catheters. The Stylet provides stiffness for use in placement of the catheter, intravascular capability for ECG detection and recording and intravascular ultrasound for catheter guiding and positioning. The VPS Stylet, when used with the VPS Console, provides real-time catheter tip location information by using the patient's physiological (cardiac electrical activity and blood flow) information. When the VPS System guidance indicator shows a blue bullseye, the catheter tip is in the desired location. The VPS System is indicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients. Limiting but not contraindicated situations for this technique are in patients where alterations of cardiac rhythm change the presentation of the P-wave as in atrial fibrillation, atrial flutter, severe tachycardia and pacemaker-driven rhythm, and in central venous catheterization procedures performed through femoral or saphenous vein access which change the presentation of the P-wave. In such patients, who are easily identifiable prior to central venous catheter insertion, the use of an additional method is required to confirm catheter tip location.
Device Description
The VPS System consists of a VPS Console and VPS Stylet. The VPS Console consists of two key integrated software-driven components: a data acquisition module; and a PC with processing and display capabilities. The VPS Stylet is a polyimide tube containing a Doppler sensor on a coax cable and an intravascular electrocardiogram (ivECG) signal sensing stainless steel wire. The Doppler sensor and the exposed portion of the ivECG are located at the distal end of the stylet and are used to detect and transmit physiological information to the VPS Console for analysis. The proximal end contains a connector to the VPS Console or to an extension cable that in turn connects to the VPS Console. The stylet can be inserted and removed from any catheter with a luminal diameter of at least 0.021 inches. The data acquisition module of the console transmits and receives ultrasound data while receiving electrical signals from the heart through sensors mounted at the tip of the VSP Stylet. Using signals gathered by the data acquisition module, the graphical user interface of the PC provides the user with guidance for tip positioning.
More Information

No
The description focuses on signal processing of physiological data (ECG and ultrasound) to provide real-time guidance. There is no mention of AI/ML algorithms, training data, or complex pattern recognition beyond basic signal analysis for tip positioning.

No
The device is used for guiding and positioning central venous catheters, and for confirming catheter tip placement. It does not treat a disease or condition.

Yes

The device is used for catheter tip placement confirmation, which is a diagnostic function to determine the correct location of the catheter.

No

The device description clearly states that the VPS System consists of both a VPS Console (hardware with software) and a VPS Stylet (hardware with sensors). It is not solely software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, treatment, or prevention of disease.
  • This Device's Function: The VPS Stylet and Console are used directly within the patient's body to guide and position a central venous catheter. It uses physiological signals (cardiac electrical activity and blood flow) from the patient to determine the catheter tip location.
  • No Specimen Examination: The device does not collect or examine any specimens taken from the patient. It interacts directly with the patient's internal physiology.

Therefore, based on the provided information and the definition of an IVD, this device falls under the category of a medical device used for guidance and positioning during a medical procedure, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The intended use of the VPS Stylet and Console (VPS System) is to quickly and accurately guide market available peripherally inserted central catheters (PICCs) to the goal location which is the cavo-atrial junction near the sino-atrial node.

The VPS Stylet and Console are indicated for guidance and tip positioning for central venous catheters. The Stylet provides stiffness for use in placement of the catheter, intravascular capability for ECG detection and recording and intravascular ultrasound for catheter guiding and positioning. The VPS Stylet, when used with the VPS Console, provides real-time catheter tip location information by using the patient's physiological (cardiac electrical activity and blood flow) information. When the VPS System guidance indicator shows a blue bullseye, the catheter tip is in the desired location. The VPS System is indicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients. Limiting but not contraindicated situations for this technique are in patients where alterations of cardiac rhythm change the presentation of the P-wave as in atrial fibrillation, atrial flutter, severe tachycardia and pacemaker-driven rhythm, and in central venous catheterization procedures performed through femoral or saphenous vein access which change the presentation of the P-wave. In such patients, who are easily identifiable prior to central venous catheter insertion, the use of an additional method is required to confirm catheter tip location.

Product codes

OBJ

Device Description

The VPS System consists of a VPS Console and VPS Stylet.
The VPS Console consists of two key integrated software-driven components: a data acquisition module; and a PC with processing and display capabilities.
The VPS Stylet is a polyimide tube containing a Doppler sensor on a coax cable and an intravascular electrocardiogram (ivECG) signal sensing stainless steel wire. The Doppler sensor and the exposed portion of the ivECG are located at the distal end of the stylet and are used to detect and transmit physiological information to the VPS Console for analysis. The proximal end contains a connector to the VPS Console or to an extension cable that in turn connects to the VPS Console. The stylet can be inserted and removed from any catheter with a luminal diameter of at least 0.021 inches.
The data acquisition module of the console transmits and receives ultrasound data while receiving electrical signals from the heart through sensors mounted at the tip of the VSP Stylet. Using signals gathered by the data acquisition module, the graphical user interface of the PC provides the user with guidance for tip positioning.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound

Anatomical Site

cavo-atrial junction near the sino-atrial node, central venous, femoral or saphenous vein

Indicated Patient Age Range

adult patients

Intended User / Care Setting

Not Found

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 VPS System correctly indicated proper PICC tip placement in 98.4% of the placement procedures in a prospective, single-armed, open design study clinical study of 77 patients.

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

Not Found

Predicate Device(s)

K081625, K093775

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1200 Diagnostic intravascular catheter.

(a)
Identification. An intravascular diagnostic catheter is a device used to record intracardiac pressures, to sample blood, and to introduce substances into the heart and vessels. Included in this generic device are right-heart catheters, left-heart catheters, and angiographic catheters, among others.(b)
Classification. Class II (performance standards).

0

KIP3522 6/14

5.0 Traditional 510(k) Summary

FEB 18 2011

510(k) SUMMARY

A summary of 510(k) safety and effectiveness information in accordance with the requirements of 21 CFR 807.92

Submitter Information
NameVasoNova, Inc.
Address155 Jefferson Drive, Suite 100
Menlo Park, CA 94025
Phone number650.388.5605
Fax number650.388.5611
Establishment
Registration
Number3006795936
Name of contact
personKim Tompkins, RN, MBA
Date preparedOctober 27, 2010
Name of device
Trade or proprietary
nameVascular Positioning System™ (VPS™ System) Stylet
Common or usual
nameCatheter, Ultrasound, Intravascular
Classification nameClass II
Classification panelCardiovascular
Regulation21 CFR §870.1200
Product Code(s)OBJ
Legally marketed
device(s) to which
equivalence is claimedFlowPICC Stylet (K081625)
Sapiens™ Tip Location System (TLS) (K093775)
Reason for 510(k)
submissionExpanded labeling
Device descriptionThe VPS System consists of a VPS Console and VPS Stylet.
The VPS Console consists of two key integrated
software-driven components: a data acquisition module;
and a PC with processing and display capabilities.
The VPS Stylet is a polyimide tube containing a Doppler
sensor on a coax cable and an intravascular
electrocardiogram (ivECG) signal sensing stainless steel
wire. The Doppler sensor and the exposed portion of the
ivECG are located at the distal end of the stylet and are
used to detect and transmit physiological information to
the VPS Console for analysis. The proximal end
contains a connector to the VPS Console or to an
extension cable that in turn connects to the VPS
Console. The stylet can be inserted and removed from
any catheter with a luminal diameter of at least 0.021
inches.
The data acquisition module of the console transmits
and receives ultrasound data while receiving electrical
signals from the heart through sensors mounted at the
tip of the VSP Stylet. Using signals gathered by the data
acquisition module, the graphical user interface of the
PC provides the user with guidance for tip positioning.
Intended use of the
deviceThe intended use of the VPS Stylet and Console (VPS
System) is to quickly and accurately guide market
available peripherally inserted central catheters (PICCs)
to the goal location which is the cavo-atrial junction near
the sino-atrial node.
Indications for useThe VPS Stylet and Console are indicated for guidance and
tip positioning for central venous catheters. The Stylet
provides stiffness for use in placement of the catheter,
intravascular capability for ECG detection and recording
and intravascular ultrasound for catheter guiding and
positioning. The VPS Stylet, when used with the VPS
Console, provides real-time catheter tip location information
by using the patient's physiological (cardiac electrical
activity and blood flow) information. When the VPS System
guidance indicator shows a blue bullseye, the catheter tip is
in the desired location. The VPS System is indicated for
use as an alternative method to fluoroscopy or chest x-ray
for central venous catheter tip placement confirmation in
adult patients.
Limiting but not contraindicated situations for this technique
are in patients where alterations of cardiac rhythm change
the presentation of the P-wave as in atrial fibrillation, atrial
flutter, severe tachycardia and pacemaker-driven rhythm,
and in central venous catheterization procedures performed
through femoral or saphenous vein access which change
the presentation of the P-wave. In such patients, who are
easily identifiable prior to central venous catheter insertion,
the use of an additional method is required to confirm
catheter tip location.

1

.

,

2

| SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE

COMPARED TO THE PREDICATE DEVICE
CharacteristicNew DevicePredicate
Materials, design6 foot long polymeric tube
which contains a Doppler
sensor at the distal tip and an
intravascular
electrocardiogram (ivECG)
signal sensing wire.Identical (FlowPICC,
K081625)
Intended UseWhen the VPS System
guidance indicator shows a
blue bull's-eye, the catheter tip
is in the desired location. The
VPS System is indicated for
use as an alternative method
to fluoroscopy or chest x-ray
for central venous catheter tip
placement confirmation in adult
patients.Sapiens™ TLS is
indicated for use as an
alternative method to
chest X-ray or fluoroscopy
for central venous
catheter tip placement
confirmation in adult
patients. (Sapiens TLS,
K093775)
PERFORMANCE DATA
SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION
OF SUBSTANTIAL EQUIVALENCE
Performance Test Summary-New Device
CharacteristicStandard/Test/FDA GuidanceResults Summary
Performance Testing:Tensile strength, torque strength,
tip flexibility, catheter
compatibility and electrical safety
testing were performed on the
VPS StyletMet all
specifications
Biocompatibility TestingCytotoxicity: ISO Elution Test
(MEM extract), Cytotoxicity: ISO
Direct Contact, Cytotoxicity: ISO
Agar Diffusion Test, Murine Local
Lymph Node Assay, Hemolysis,
Partial Thromboplastin Test,
Intracutaneous (intradermal)
Reactivity Test (ISO), Acute
systemic toxicity test, Ames
Mutagenicity Test, Prothrombin
Time Test, Thrombogenicity
study in Dogs (ISO), ISO implant
test (7 days), ISO implant test
(90 days)Compliant with ISO
10993-1:2003
Sterilization and Shelf-life
Testing:Sterilization validation and EtO
Residuals testing per ANSI-
AAMI-ISO 11135-1:1994 -
Sterilization Validation. Shelf-life
testing to 24 months has been
performed.Passed

3

Comparative Performance Information Summary
CharacteristicRequirementNew DevicePredicate
Device(s)
SterilitySterileSterileSame
BiocompatibilitySame
ECGSame
UltrasoundSame (FlowPICC,
only)

SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE AND/OR OF CLINICAL INFORMATION

Clinical Performance Data/Information

The VPS System correctly indicated proper PICC tip placement in 98.4% of the placement procedures in a prospective, single-armed, open design study clinical study of 77 patients.

CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA

The VPS Stylet is identical in design and materials to the FlowPICC Stylet (K081625) and has been clinically demonstrated to be substantially equivalent to the Sapiens™ TLS Tip Location System (K093775) with regard to intended use.

4

Image /page/4/Picture/0 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" written around the perimeter. Inside the circle is an abstract image of an eagle.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

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

VasoNova, Incorporated c/o Ms. Kim Tompkins VP, Regulatory/Clinical Corporate Compliance Officer 155 Jefferson Drive, Suite 100 Menlo Park, CA 94025

FEB 18 201

Re: K103255

Trade/Device Name: Vascular Positioning System™ (VPSTM) Stylet Regulation Number: 21 CFR 870.1200 Regulation Name: Diagnostic intravascular catheter Regulatory Class: Class II (two) Product Code: OBJ Dated: February 1, 2011 Received: February 2, 2011

Dear Ms. Tompkins:

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 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.

and the country of the country of the country of the county of the county of the county of

5

Page 2 – Ms. Kim Tompkins

Enclosure

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 lisung (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.hypn1 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/Resourcesfor You/Industry/default.htm.

http://www.fda.gov/MedicalDevices/ResourcesforYourIndustry/default.htm.

Sincerely vours.

W. Mcd

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

6

4.0 Indications for Use Statement

510(k) Number:To be determined
Device Name:VasoNova™ Vascular Positioning System™ (VPS™ System)
Stylet
Intended Use:The VPS Stylet and Console are indicated for guidance and tip
positioning for central venous catheters. The Stylet provides stiffness for
use in placement of the catheter, intravascular capability for ECG
detection and recording and intravascular ultrasound for catheter guiding
and positioning. The VPS Stylet, when used with the VPS Console,
provides real-time catheter tip location information by using the patient's
physiological (cardiac electrical activity and blood flow) information. When the VPS System guidance indicator shows a blue bullseye, the catheter tip is in the desired location. The VPS System is indicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients.
Limiting but not contraindicated situations for this technique are in patients where alterations of cardiac rhythm change the presentation of the P-
wave as in atrial fibrillation, atrial flutter, severe tachycardia and
pacemaker-driven rhythm, and in central venous catheterization
procedures performed through femoral or saphenous vein access which
change the presentation of the P-wave. In such patients, who are easily
identifiable prior to central venous catheter insertion, the use of an additional method is required to confirm catheter tip location.

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

Over-the-Counter Use: NO (Part 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)

W.M.D.

(Division Sign-Off)
Division of Cardiovascular Devices

510(k) Number K103253