K Number
K103260
Manufacturer
Date Cleared
2011-02-18

(106 days)

Product Code
Regulation Number
870.1200
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The VPS Stylet and Console are indicated for guidance and tip positioning for central venous catheters. The Console is intended for use with the stylet supplied by VasoNova. The VPS System consists of a Console and associated power supply and cabling and a stylet. The VPS Console, when used with the VPS Stylet, 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 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.
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 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 VPS Stylet. Using signals gathered by the data acquisition module, the graphical user interface of the PC provides the user with guidance for tip positioning.
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.

AI/ML Overview

Here's an analysis of the acceptance criteria and study details from the provided text:

Acceptance Criteria and Device Performance

Acceptance CriteriaReported Device Performance
Proper PICC tip placement indication98.4% of placement procedures

Study Details

  1. Sample Size used for the test set and the data provenance:

    • Sample Size: 77 patients
    • Data Provenance: Not explicitly stated, but the study was prospective and single-armed, indicating it was conducted during the device's development/evaluation phase, likely in a clinical setting. Country of origin is not specified but given the submitter's address (Menlo Park, CA), it's reasonable to infer a US-based study, although not guaranteed. The study was prospective.
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • This information is not provided in the given text. The text only states that the VPS System "correctly indicated proper PICC tip placement" but doesn't detail how this "correctness" (ground truth) was established or who adjudicated it.
  3. Adjudication method for the test set:

    • This information is not provided in the given text.
  4. 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 involving human readers and AI assistance was not done or reported in this document. The study described focuses on the standalone performance of the device in indicating proper PICC tip placement. The VPS System is itself providing the "guidance indicator" for the user.
  5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    • Yes, a standalone performance study was done. The reported 98.4% accuracy reflects the device's ability to "correctly indicate proper PICC tip placement." While a human operator uses the device, the 98.4% figure represents the accuracy of the device's output compared to the ground truth of tip placement, not the performance of human readers using or not using the device. The device's "guidance indicator shows a blue bull's-eye" when the tip is in the desired location, implying an algorithmic determination.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The specific method for establishing ground truth is not explicitly stated. However, the intended use clearly states the system is an "alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation." This strongly suggests that the ground truth for the study was established using one or both of these traditional imaging methods (fluoroscopy or chest x-ray) to independently verify the actual PICC tip location.
  7. The sample size for the training set:

    • The text does not provide any information about a training set or its sample size. The clinical study described refers to the test set used to evaluate the device's performance.
  8. How the ground truth for the training set was established:

    • As no information about a training set is provided, this question cannot be answered from the given text.

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K103260 P1/3

FEB 1 8 2011

Traditional 510(k) Summary 5.0

Submitter Information
NameVasoNova, Incorporated
Address155 Jefferson Drive, Suite 100Menlo Park, CA 94025
Phone number(650) 388-5605
Fax number(650) 388-5611
EstablishmentRegistrationNumber3006795936
Name of contactpersonKim Tompkins, RN, MBA
Date preparedOctober 29, 2010
Name of device
Trade orproprietary nameVascular Positioning System™ (VPS™ System) Console
Common or usualnameCatheter, Ultrasound, Intravascular
Classification nameDiagnostic intravascular catheter, Class II
Classification panelCardiovascular
Regulation21 CFR §870.1200
Product Code(s)OBJ
Legally marketeddevice(s) to whichequivalence is claimedFlowPICC Console (K081626)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-drivencomponents: a data acquisition module; and a PC with processingand display capabilities. The data acquisition module of the consoletransmits and receives ultrasound data while receiving electricalsignals from the heart through sensors mounted at the tip of the VPSStylet. Using signals gathered by the data acquisition module, thegraphical user interface of the PC provides the user with guidance fortip positioning.The VPS Stylet is a polyimide tube containing a Doppler sensor on acoax cable and an intravascular electrocardiogram (ivECG) signalsensing stainless steel wire. The Doppler sensor and the exposedportion of the ivECG are located at the distal end of the stylet and areused to detect and transmit physiological information to the VPSConsole for analysis. The proximal end contains a connector to theVPS Console or to an extension cable that in turn connects to theVPS Console. The stylet can be inserted and removed from anycatheter with a luminal diameter of at least 0.021 inches.

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Intended use of the deviceThe intended use of the VPS Stylet and Console (VPS System) is toquickly and accurately.guide market available peripherally insertedcentral catheters (PICCs) to the goal location which is the lower thirdof the SVC or at the cavo-atrial junction.
Indications for useThe VPS Stylet and Console are indicated for guidance and tippositioning for central venous catheters. The Console is intendedfor use with the stylet supplied by VasoNova. The VPS Systemconsists of a Console and associated power supply and cabling anda stylet. The VPS Console, when used with the VPS Stylet, providesreal-time catheter tip location information by using the patient'sphysiological (cardiac electrical activity and blood flow) information.When the VPS System guidance indicator shows a blue bull's-eye,the catheter tip is in the desired location. The VPS System isindicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adultpatients.Limiting but not contraindicated situations for this technique are inpatients 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.
SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE COMPARED TO THE PREDICATEDEVICE
CharacteristicVPS ConsoleFlowPICC Console(K081626)Sapiens TLS(K093775)
Guidance indicatorColored icons, waveformdataColored icons, waveformdataWaveform data
Guidance signal type(s)ivECG, DopplerultrasoundivECG, DopplerultrasoundivECG
Signal ConductorTwo conductor styletwiresTwo conductor styletwiresSaline column via salineadapter orcommercially-available(unspecified)conducting stylet orguidewire via electricaladapter
Acoustic OutputOne setting; notcontrolled by the userOne setting; notcontrolled by the userN/A
Method of UsePercutaneousIntravascularPercutaneousIntravascularPercutaneousIntravascular
User InterfacePC-based system withkeyboard and touchscreen and mousePC-based system withkeyboard and touchscreen and mousePC-based system withkeyboard and mouse

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PERFORMANCE DATA
SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE
Performance Test Summary-New Device:
CharacteristicStandard/Test/FDA GuidanceResults Summary
ElectromagneticCompatibilityIEC 60601-2:2007Compliant
Electrical Safety andAcoustic SafetyIEC 60601-1:1988 + A1:1991; A2:1995IEC 60601-1-4:1996 + A1:1999 (Cons. Ed 1.1)IEC 60601-2-37:2001 +A1:2004; A2:2005VasoNova SOPCompliant
SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE AND/OROF CLINICAL INFORMATION
Clinical Performance Data/Information.
The VPS System correctly indicated proper PICC tip placement in 98.4% of the placementprocedures in a prospective, single-armed, open design clinical study of 77 patients.
CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA

The vast similarities of the VPS Console to the VasoNova FlowPICC Console predicate device support the substantial equivalence in intended use, function, and basic composition. The nonclinical testing to voluntary standards and applicable FDA guidance documents provide additional evidence the VPS Console is substantially equivalent to the VasoNova FlowPICC Console predicate device in terms of safety, efficacy, and performance.

The clinical testing of the VPS Console supports the substantial equivalence in indications for use to the Romedex Sapiens™ TLS predicate device.

The minor differences between the VPS Console and the predicate devices do not raise new issues of safety or effectiveness.

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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a stylized graphic of three wavy lines above the text. The text is arranged in a circular pattern around the graphic.

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 1 8 201

Re: K103260

Trade/Device Name: Vascular Positioning System™ (VPSTM) Console 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 3, 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 county of the county of the county of the county of the county of the count

:

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Page 2 - Ms. Kim Tompkins

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 lisuing (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/ucm1118001 http://www.faor. 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 D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use Statement 4.0

510(k) Number: To be determined

Device Name: VasoNova™ Vascular Positioning System™ (VPS™ System) Console

  • The VPS Stylet and Console are indicated for guidance and tip Intended Use: positioning for central venous catheters. The Console is intended for use with the stylet supplied by VasoNova. The VPS System consists of a Console and associated power supply and cabling and a stylet. The VPS Console, when used with the VPS Stylet, 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 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.
    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.W.

(Division Sign-Off)
Division of Cardiovascular Devices

510(k) Number K103260

§ 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).