K Number
K113163
Device Name
PENUMBRA SYSTEM MAX
Manufacturer
Date Cleared
2011-11-23

(28 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Penumbra System is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.
Device Description
The Penumbra System MAX components are additional components of the currently available Penumbra System. The Penumbra System MAX components provide a larger lumen to assist in the efficient removal of thrombus from the brain. The devices are provided sterile, non-pyrogenic, and intended for single use only.
More Information

No
The summary describes a mechanical thrombectomy device and its components. There is no mention of AI, ML, image processing, or any software-based analysis that would suggest the use of these technologies. The performance studies are focused on mechanical and biological properties.

Yes
The device is described as being used for "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease," which is a therapeutic intervention.

No

Explanation: The device description states its purpose is "the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease" and to "assist in the efficient removal of thrombus from the brain." This indicates a therapeutic or interventional function, not a diagnostic one.

No

The device description explicitly states it includes "additional components" and describes physical and mechanical properties, bench-top testing, and animal studies related to hardware. It is a system with physical components for thrombus removal.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease." This describes a therapeutic intervention performed directly on the patient's body to restore blood flow.
  • Device Description: The device is described as components of a system designed to "assist in the efficient removal of thrombus from the brain." This is a mechanical device used for a physical procedure.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device does not interact with such specimens in this manner.
  • Performance Studies: The performance studies focus on biocompatibility, mechanical properties (bench-top testing), and animal studies evaluating safe use in a living organism. These are typical evaluations for therapeutic medical devices, not IVDs.

In summary, the Penumbra System is a therapeutic medical device used for a procedure within the body, not a diagnostic device used to analyze samples outside the body.

N/A

Intended Use / Indications for Use

The Penumbra System is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.

Product codes

NRY

Device Description

The Penumbra System MAX components are additional components of the currently available Penumbra System. The Penumbra System MAX components provide a larger lumen to assist in the efficient removal of thrombus from the brain. The devices are provided sterile, non-pyrogenic, and intended for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries)

Indicated Patient Age Range

Not Found

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)

Biocompatibility Testing:

  • In Vitro Cytotoxicity (ISO Elution Test (MEM Extract)): No evidence of cell lysis or toxicity
  • Acute Intracutaneous Reactivity (Irritation) (ISO Intracutaneous (Intradermal) Injection Test): No evidence of irritation
  • Acute Systemic Toxicity (ISO Acute Systemic Injection Test): No evidence of systemic toxicity
  • Rabbit Pyrogen Study (USP Material-Mediated Rabbit Pyrogen Test): No evidence of material-mediated pyrogenicity
  • Sensitization (ISO Maximization Test for Delayed Hypersensitivity): Non-Sensitizing
  • Hemo-compatibility (In Vitro Hemolysis, In Vitro Coagulation (PT, PTT), Complement Activation): Non-hemolytic, Coagulation times are within the normal range, Non-Thrombogenic, No greater biological response than corresponding control

Bench-top Testing:

  • Pouch Seal (Pouch Seal Strength): Sample Size 30, Result Pass
  • Dimensional / Visual Inspection: Result Pass
  • Simulated Use (Intracranial Access & Thrombus Removal): Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Hub /Shaft & Hub / HypotubeTensile Strength): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Joint Tensile Strength): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Hub Air Aspiration): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Burst Test): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Particulate Testing (Hydrophilic Coating)): Sample Size 10, Result Pass
  • Reperfusion Catheter4MAX / Sheath or 8F Guide compatibility (Friction Force): Result Pass
  • Reperfusion Catheter 4MAX / 0.014" Guidewire compatibility (Friction Force): Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 054 (Friction Force): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / 0.014" Guide wire compatibility (Friction Force): Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Flow Rate): Sample Size 3, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Elongation to Failure): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Corrosion): Sample Size 30, Result Pass
  • Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX (Torsion): Sample Size 30, Result Pass
  • Separator 3MAX: Dimensional / Visual Inspection (all sizes): Result Pass
  • Simulated Use: Hub Transition: N=30, Result Pass
  • Reperfusion Catheter 3MAX / Separator 3MAX / Aspiration Tubing Assembly Performance (Tracking): N=30, Result Pass
  • Separator 3MAX & Reperfusion Catheter Compatible: N=30, Result Pass
  • Separator 3MAX / Reperfusion Catheter / Pump and accessories / Aspiration Tubing (Aspiration Remove Clot): N=30, Result Pass
  • Separator 3MAX and Reperfusion Catheter Compatibility (Separator Advance / Retract): N=30, Result Pass
  • Separator Bond Joint Test:
    • Separator 054 and Wire Joint Break Force: N=30, Result Pass
    • Separator 041 and Wire Joint Break Force: N=30, Result Pass
    • Separator 032 and Wire Joint Break Force: N=30, Result Pass
    • Separator 026 and Wire Joint Break Force: N=30, Result Pass
    • Separator 3MAX and Wire Joint Break Force: N=30, Result Pass

Animal Study:

  • Study concluded no vessel injury, no abnormal gross or histology findings, and no significant vascular response in test vessel segments.

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

Not Found

Predicate Device(s)

K072718, K090752, K100769

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

0

NOV 2 3 2011

KIL3163 ps/5

10 510(k) Summary of Safety & Effectiveness

(as required by 21 CFR 807.92)

Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Penumbra Inc. is providing the summary of Substantial Equivalence for the Penumbra System® MAX components.

10.1 Sponsor/Applicant Name and Address

Penumbra, Inc. 1351 Harbor Bay Parkway Alameda, CA 94502, USA

10.2 Sponsor Contact Information

Seth Schulman Director, Regulatory Affairs Phone: (510) 748-3223 FAX: (510) 217-6414 Email: seth.schulman@penumbrainc.com

10.3 Date of Preparation of 510(k) Summary

October 24, 2011

10.4 Device Trade or Proprietary Name

Penumbra System® MAX

10.5 Device Classification

Regulatory Class: II Cardiovascular Classification Panel: Classification Name: Catheter, Thrombus Removal 21 CFR §870.1250 Regulation Number: Product Code: NRY

10.6 Predicate Devices

| 510(k) Number /
Clearance Date | Name of Predicate Device | Name of
Manufacturer |
|-----------------------------------|--------------------------------------------------------|-------------------------|
| K072718 [28Dec2007] | Penumbra System [026, 032, 041] | Penumbra, Inc. |
| K090752 [21Sep2009] | Penumbra System [054] | Penumbra, Inc. |
| K100769 [21May2010] | Penumbra System Separator Flex
[026, 032, 041, 054] | Penumbra, Inc. |

10.7 Device Description

The Penumbra System MAX components are additional components of the currently available Penumbra System. The Penumbra System MAX components provide a larger lumen to assist in the efficient removal of thrombus from the

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brain. The devices are provided sterile, non-pyrogenic, and intended for single use only.

10.8 Intended Use

The Penumbra System is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.

10.9 Summary of Non-Clinical Data

As required under Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, a summary of any information regarding safety and effectiveness of the device follows.

Included in this section are descriptions of the testing's, which substantiates the safe and effective performance of the Neuron MAX System as well as its substantial equivalence to the predicate devices:

  • Biocompatibility .
  • Design Verification (Bench-Top Testing) .
  • Animal Study .

The subject Penumbra System MAX components met all established requirements.

10.9.1 Biocompatibility Testing

The Penumbra System MAX components were classified in accordance with ISO 10993 -1 guidelines (Biological Evaluation of Medical Devices) for limited duration ( Concurrence of CDRH, Office of Device Evaluation (ODE) JEFFREY TOY

(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices

K113163

510(k) Number