(86 days)
The Reverse Medical ReFlex™ Balloon Guide Catheter is indicated for use in facilitating and guidance of intravascular catheters into a selected blood vessel in the peripheral and neurovascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures.
The ReFlex™ Balloon Guide Catheter is a flexible, variable stiffness composite catheter shaft has a hydrophilic coating to reduce friction during use. A compliant balloon is mounted on the distal end of the catheter. The ReFlex™ Balloon Guide Catheter dimensions are included on the individual device labels. The ReFlex™ Balloon Guide Catheter inner lumen can accommodate guidewires up to 0.038 inches in diameter to aid in placement of the catheter system. The proximal end of the ReFlex™ Balloon Guide Catheter has a bifurcated luer fitting to allow attachment of accessories and infusion of liquids through the system. The ReFlex™ Balloon Guide Catheter is offered in various sizes to accommodate physician preferences and anatomical variations. The catheter is provided sterile, non-pyrogenic, and is intended for single use only.
Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Device: ReFlex™ Balloon Guide Catheter
K Number: K112262
1. Table of Acceptance Criteria and Reported Device Performance
The provided document describes various in vitro and in vivo tests conducted to demonstrate the substantial equivalence of the ReFlex™ Balloon Guide Catheter. The "acceptance criteria" are implied by the statement "Met established criteria" for each test. The reported device performance is that it successfully met these criteria.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Dimensional and Visual Inspection | Met established criteria |
| Guidewire Compatibility | Met established criteria |
| Microcatheter Compatibility | Met established criteria |
| Torque Strength | Met established criteria |
| Kink Resistance | Met established criteria |
| Tip Buckling Test | Met established criteria |
| Flexibility Test (including tip flexibility) | Met established criteria |
| Tensile Strength | Met established criteria |
| Catheter Leak Test (Liquid Leakage) | Met established criteria |
| Catheter Leak Test (Air Leakage) | Met established criteria |
| Dynamic Pressure Test | Met established criteria |
| Static Burst Test | Met established criteria |
| Aspiration Test | Met established criteria |
| Hub Gauging | Met established criteria |
| Corrosion Resistance | Met established criteria |
| USP Particulate Test | Met established criteria |
| Navigation, Accessibility, & Simulated Vascular Occlusion Capabilities in vitro | Met established criteria |
| Balloon Inflation/Deflation Times | Met established criteria |
| Balloon Cycle Fatigue | Met established criteria |
| Balloon Rated Volume (informational purposes) | Met established criteria |
| Balloon Compliance (informational purposes) | Met established criteria |
| System Deliverability, Compatibility, Visibility, and Temporary Vascular Occlusion Performance (in vivo) | Met established criteria |
| Acute Histopathology of Treated Vessels (in vivo) | Met established criteria |
| Biocompatibility Testing | Met established criteria |
Note on Biocompatibility: The document also lists specific biocompatibility tests and states that the blood-contacting materials "successfully passed all of the following biocompatibility tests:"
- Cytotoxicity (L929 MEM Elution Test)
- Sensitization (Kligman Maximization)
- Intracutaneous Reactivity (Irritation) (Intracutaneous Injection Test)
- Systemic Toxicity (Acute) (ISO Acute Systemic Injection Test)
- Hemocompatibility (Complement Activation, Hemolysis, Inactivated Partial Thromboplastin Time Test, In vivo thrombogenicity)
- Pyrogenicity (USP Material Mediated Rabbit Pyrogen Test)
- EtO Residuals (Ethylene oxide and Ethylene chlorohydrins residuals)
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes used for each individual test within the "Design Verification (Bench-Top Testing)" or "In vivo Tests" sections. It only states that "All testing was performed on units that were sterilized and met all inspection criteria."
The data provenance is not specified regarding country of origin, but the tests are described generally as "non-clinical data" and "bench-top testing" and "in vivo tests," implying laboratory and potentially animal studies, not human clinical trials. The data is thus prospective, as it was generated specifically for this device's submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not provided in the document. The studies described are primarily product performance and safety tests (mechanical, physical, biocompatibility, in vivo performance) rather than studies requiring expert consensus on a 'ground truth' in the context of diagnostic accuracy.
4. Adjudication Method for the Test Set
Adjudication methods (like 2+1, 3+1) are typically relevant for studies where human interpretation or judgment is involved, such as in clinical image reading or diagnosis. These are not applicable to the bench-top and animal (in vivo) performance studies described for this medical device. The "ground truth" for these tests would be objective measurements against established engineering, biological, or regulatory standards.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of how much human readers improve with AI vs without AI assistance
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This device is a physical medical instrument (a balloon guide catheter), not an AI-powered diagnostic or assistive technology for human readers. Therefore, the concept of human readers improving with AI assistance is not relevant to this submission.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, a standalone algorithm-only performance study was not done. This device is a physical medical instrument and does not involve an algorithm.
7. The Type of Ground Truth Used
For the various tests:
- Physical and Mechanical Tests (Bench-Top): The ground truth is based on established engineering specifications, industry standards, and internal design criteria. The results were compared against these predefined criteria (e.g., "Met established criteria").
- Biocompatibility Tests: The ground truth is based on recognized international standards and guidelines, specifically FDA General Program Memorandum #G95-1 and ISO 10993-1 guidelines, which specify acceptable biological responses to materials.
- Sterilization: Ground truth is based on ANSI / AAMI / ISO 11135 standards for achieving a Sterility Assurance Level (SAL) of 10^-6^ (stated as 10^-8^ in the document, which is stricter than common).
- In vivo Tests: The ground truth would be based on observed physiological responses, device functionality in a relevant biological model, and histopathological assessment against predefined safety and performance parameters in the animal model.
8. The Sample Size for the Training Set
Not applicable. This submission describes the testing of a physical medical device, not a machine learning model. Therefore, there is no "training set" in the context of AI/ML.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As there is no training set for an algorithm, there is no ground truth established for one.
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4. 510(k) Summary according to 807.92
Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Reverse Medical -Corporation is providing the summary of Substantial Equivalence for the ReFlex™ Balloon Guide Catheter.
4.1 Sponsor /Applicant Name and Address
Reverse Medical Corporation 13900 Alton Parkway Suite 123 Irvine, CA 92618
4.2 Sponsor Contact Information
Jeff Valko, President & CEO Phone: 949-215-0660 x201 Fax: 949-215-0661 Email: jvalko@reversemed.com
4.3 Date of Preparation of 510(k) Summary
August 5, 2011
4.4 Device Trade or Proprietary Name
ReFlex™ Balloon Guide Catheter
4.5 Device Common/Usual or Classification Name
Catheter, Percutaneous (Product Code: DQY)
4.6 Identification of the Legally Marketed Devices to which Equivalence is Being Claimed:
| Name of Predicate Devices | Name of Manufacturer(Town, State) | 510(k) Number |
|---|---|---|
| Concentric Balloon GuideCatheter | Concentric Medical, Inc.Mountain View, CA | K010954K021899 |
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K112262 page
510(k) Summary according to 807.92 (continued)
4,7 Device Description
The ReFlex™ Balloon Guide Catheter is a flexible, variable stiffness composite catheter shaft has a hydrophilic coating to reduce friction during use. A compliant balloon is mounted on the distal end of the catheter. The ReFlex™ Balloon Guide Catheter dimensions are included on the individual device labels. The ReFlex™ Balloon Guide Catheter inner lumen can accommodate guidewires up to 0.038 inches in diameter to aid in placement of the catheter system.
The proximal end of the ReFlex™ Balloon Guide Catheter has a bifurcated luer fitting to allow attachment of accessories and infusion of liquids through the system. The ReFlex™ Balloon Guide Catheter is offered in various sizes to accommodate physician preferences and anatomical variations. The catheter is provided sterile, non-pyrogenic, and is intended for single use only.
4.8 Intended Use
The Reverse Medical ReFlex™ Balloon Guide Catheter is indicated for use in facilitating and guidance of intravascular catheters into selected blood vessels in the peripheral and neurovascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures.
| Concentric Balloon Guide Catheter | ReFlex™ Balloon Guide Catheter | |
|---|---|---|
| 510(k) Numbers | K010954, K021899 | TBD |
| Classification | Class II, DQY | Class II, DQY |
| Indication | Indicated for use in facilitating andguidance of intravascular cathetersinto a selected blood vessel in theperipheral and neurovascularsystems. The balloon providestemporary vascular occlusion duringthese and other angiographicprocedures. | Indicated for use in facilitating andguidance of intravascular cathetersinto a selected blood vessel in theperipheral and neurovascularsystems. The balloon providestemporary vascular occlusion duringthese and other angiographicprocedures. |
| Shaft Materials | Coaxial lumen braided shaft variablestiffness catheter with radiopaquemarker on distal end. | Dual lumen wire reinforced shaftvariable stiffness catheter withradiopaque marker on distal end. |
| Proximal EndConfiguration | Luer Hub | Luer Hub |
| Radiographicmarkers/radiopacity | Radiopaque marker at distal tip | Radiopaque marker at distal tip |
| Balloon | Compliant | Compliant |
| Packaging | Catheter attached to packaging cardinside PET/PE/Tyvek pouchinside SBS carton. | Catheter in polyethylene hoop attachedto packaging card inside PET/PE/Tyvekpouch inside SBS carton. |
| Sterilization | EtO | EtO |
4.9 Comparison to Predicate Devices
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K112262 page 3 of 4
510(k) Summary according to 807.92 (continued)
4.10 Summary of Non-Clinical Data
4.10.1 Biocompatibility and Sterilization
The ReFlex™ Balloon Guide Catheter is classified as Externally Communicating Devices, Circulating Blood, Limited Contact (≤ 24 hours). Results of the testing demonstrate that the blood contacting materials are biocompatible.
Blood contacting materials were tested in accordance with the tests recommended in the FDA General Program Memorandum #G95-1 (5/1/95): Use of International Standard ISO 10993-1 guidelines "Biological Evaluation of Medical Devices Part 1: Evaluation and Testing." The ReFlex™ Balloon Guide Catheter successfully passed all of the following biocompatibility tests:
| Test | Method |
|---|---|
| Cytotoxicity | L929 MEM Elution Test |
| Sensitization | Kligman Maximization |
| Intracutaneous Reactivity (Irritation) | Intracutaneous Injection Test |
| Systemic Toxicity (Acute) | ISO Acute Systemic Injection Test |
| Hemocompatibility | Complement Activation |
| Hemocompatibility | Hemolysis |
| Hemocompatibility | Inactivated Partial Thromboplastin Time Test |
| Hemocompatibility | In vivo thrombogenicity |
| Pyrogenicity | USP Material Mediated Rabbit Pyrogen Test |
| EtO Residuals | Ethylene oxide and Ethylene chlorohydrinsresiduals |
Sterilization conditions have been validated according to ANSI / AAMI / ISO 11135, Sterilization of Health Care Products-Part 1: Requirement, validation and routine control of a sterilization process for medical devices to provide a Sterility Assurance Level (SAL) of 108.
4.10.2 Design Verification (Bench-Top Testing)
The physical, mechanical, and performance testing of the ReFlex™ Balloon Guide Catheter demonstrate that the product is substantially equivalent to the currently marketed predicate devices. Design verification testing was conducted to evaluate the physical and mechanical properties of the ReFlex™ Balloon Guide Catheter. All studies were conducted in accordance with Reverse Medical Design Control procedures. All testing was performed on units that were sterilized and met all inspection criteria. Tests on the ReFlex™ Balloon Guide Catheter included:
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K112262 page 4 of 4
Verification and Test Summary
| In vitro Tests | Result |
|---|---|
| Dimensional and Visual Inspection | Met established criteria |
| Guidewire Compatibility | Met established criteria |
| Microcatheter Compatibility | Met established criteria |
| Torque Strength | Met established criteria |
| Kink Resistance | Met established criteria |
| Tip Buckling Test | Met established criteria |
| Flexibility Test (including tip flexibility) | Met established criteria |
| Tensile Strength | Met established criteria |
| Catheter Leak Test (Liquid Leakage) | Met established criteria |
| Catheter Leak Test (Air Leakage) | Met established criteria |
| Dynamic Pressure Test | Met established criteria |
| Static Burst Test | Met established criteria |
| Aspiration Test | Met established criteria |
| Hub Gauging | Met established criteria |
| Corrosion Resistance | Met established criteria |
| USP Particulate Test | Met established criteria |
| Navigation, Accessibility, & Simulated Vascular Occlusion Capabilities in vitro | Met established criteria |
| Balloon Inflation/Deflation Times | Met established criteria |
| Balloon Cycle Fatigue | Met established criteria |
| Balloon Rated Volume (informational purposes) | Met established criteria |
| Balloon Compliance (informational purposes) | Met established criteria |
| In vivo Tests | Result |
| System Deliverability, Compatibility, Visibility, and Temporary VascularOcclusion Performance | Met established criteria |
| Acute Histopathology of Treated Vessels | Met established criteria |
| Biocompatibility Testing | Met established criteria |
The physical, mechanical, and performance testing of the subject ReFlex™ Balloon Guide Catheter demonstrate that the product is Substantially Equivalent to the currently marketed predicate devices.
4.11 Substantial Equivalence
The performance of the ReFlex™ Balloon Guide Catheter in this submission demonstrates that the product is substantially equivalent to the performance of the predicate devices. The equivalence was shown through comparison of component materials and specifications, performance, biocompatibility testing, and sterilization validation.
The ReFlex™ Balloon Guide Catheter is substantially equivalent in intended use, design, technology/principles of operation, materials, and performance to the predicate devices. Differences between the devices do not raise any significant issues of safety or effectiveness.
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Image /page/4/Picture/1 description: The image is a black and white logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three lines representing its body and wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
NOV - 2 2011
Reverse Medical Corporation c/o Mr. Jeffrey Valko 13700 Alton Parkway Suite 167 Irvine, CA 92618
Re: K112262
Trade Name: ReFlex Balloon Guide Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous catheter Regulatory Class: Class II (two) Product Code: DQY Dated: October 10, 2011 Received: October 11, 2011
Dear Mr. Valko:
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 – Mr. Jeffrey Valko
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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Brom D. Zucker
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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N11000:2 page
3. Indications for Use
510(k) Number (if known): K112262
Device Name: Reverse Medical ReFlex™ Balloon Guide Catheter
Indications for Use:
The Reverse Medical ReFlex™ Balloon Guide Catheter is indicated for use in facilitating and guidance of intravascular catheters into a selected blood vessel in the peripheral and neurovascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures.
Prescription Use _ X (Part 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)
510(k) i
§ 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).