K Number
K123803
Device Name
REVERSE MEDICAL MICRO VASCULAR PLUG (MVP) SYSTEM
Date Cleared
2013-07-02

(204 days)

Product Code
Regulation Number
870.3300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Reverse Medical™ Micro Vascular Plug (MVP™) System is intended for use to obstruct or reduce the rate of blood flow in the peripheral vasculature.
Device Description
The Reverse Medical Micro Vascular Plug (MVP) is a micro vascular occlusion device comprised of a detachable embolic plug attached to a composite delivery wire and designed for delivery via a microcatheter (0.021" ID). The MVP is a self-expandable, ovoid-shaped device made from Nitinol with an ePTFE partial cover. The device is secured at both ends with platinum marker bands. The Reverse Medical MVP is intended to reduce or occlude vascular blood flow of vessels having a diameter of 1.5 – 3.0mm. The proximal marker band attaches to a delivery wire that pushes through a commercially available catheter to the intended treatment site. The Reverse Medical Detachment Box regulates detachment of the implant device from the delivery wire by electrolytic means during deployment, and monitors, detects, signals and measures the time of detachment. The Reverse Medical Cable Set – 275 cm length (Model RMCS – 2.75US) is provided sterile. The cable set connects to the Detachment Box through a bayonet type dual pin connector that ensures correct polarity. The Reverse Medical Cable Set and Detachment Box will be sold separately. One 9-volt battery and a sterile needle (20 G or 22 G) will also be needed for use with the Reverse Medical Micro Vascular Plug (MVP).
More Information

Not Found

No
The device description focuses on mechanical and electrical components for vascular occlusion and detachment, with no mention of AI or ML for analysis, decision-making, or image processing.

Yes
The device is intended to obstruct or reduce blood flow in the peripheral vasculature, which is a therapeutic intervention.

No

This device is an embolic plug designed to obstruct or reduce blood flow, not to diagnose a condition.

No

The device description clearly outlines a physical implant (Nitinol plug with ePTFE cover), a delivery wire, a detachment box, and a cable set. These are all hardware components, not software.

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

Here's why:

  • Intended Use: The intended use is to "obstruct or reduce the rate of blood flow in the peripheral vasculature." This describes a therapeutic intervention performed directly on the patient's body.
  • Device Description: The device is a physical implant (micro vascular plug) designed to be delivered into blood vessels. It also includes components for delivery and detachment. This is consistent with a medical device used for treatment.
  • Lack of Diagnostic Activity: There is no mention of the device being used to analyze samples (blood, tissue, etc.) or to provide information for diagnosis. IVDs are used to examine specimens from the human body to provide information for diagnosis, monitoring, or screening.

Therefore, the Reverse Medical™ Micro Vascular Plug (MVP™) System is a therapeutic medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Reverse Medical™ Micro Vascular Plug (MVP™) System is intended for use to obstruct or reduce the rate of blood flow in the peripheral vasculature.

Product codes (comma separated list FDA assigned to the subject device)

KRD

Device Description

The Reverse Medical Micro Vascular Plug (MVP) is a micro vascular occlusion device comprised of a detachable embolic plug attached to a composite delivery wire and designed for delivery via a microcatheter (0.021" ID). The MVP is a self-expandable, ovoid-shaped device made from Nitinol with an ePTFE partial cover. The device is secured at both ends with platinum marker bands. The Reverse Medical MVP is intended to reduce or occlude vascular blood flow of vessels having a diameter of 1.5 – 3.0mm.

The proximal marker band attaches to a delivery wire that pushes through a commercially available catheter to the intended treatment site. The Reverse Medical Detachment Box regulates detachment of the implant device from the delivery wire by electrolytic means during deployment, and monitors, detects, signals and measures the time of detachment. The Reverse Medical Cable Set – 275 cm length (Model RMCS – 2.75US) is provided sterile. The cable set connects to the Detachment Box through a bayonet type dual pin connector that ensures correct polarity. The Reverse Medical Cable Set and Detachment Box will be sold separately. One 9-volt battery and a sterile needle (20 G or 22 G) will also be needed for use with the Reverse Medical Micro Vascular Plug (MVP).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

peripheral vasculature

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)

Summary of Non-Clinical Data

  • Biocompatibility and Sterilization: The device was characterized as an implant, internal communicating device, which contacts circulating blood for exposure ≥ 30 days. The Reverse Medical MVP 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 Reverse Medical MVP successfully passed all of the following biocompatibility tests, demonstrating that the materials are biocompatible: Cytotoxicity (Non-Cytotoxic), Kligman Maximization Sensitization Test (Non-Sensitizing), Intracutaneous Injection (Non-Irritant), Systemic Injection (Non-Toxic), Material-Mediated Pyrogenicity (Non-Pyrogenic), Genotoxicity/Mutagenicity (Non-Mutagenic), In Vitro Mouse Lymphoma Assay (Non-Mutagenic), In Vivo Mouse Lymphoma (Non-Mutagenic), Hemolysis (Non-Hemolytic), Complement Activation C3a and SC5ba-9 (No greater biological response than corresponding control), Inactivated Partial Thromboplastin Time (Minimal, passed acceptance criteria), Platelet and Leukocycte Counts (Test articles: No range or acceptable level established.), Muscle Implantation (Intramuscular Implantation- 4 and 13 week, passed acceptance criteria).
  • Test Result Summary: 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 10 °.
    Design Verification (Bench-Top Testing)
    The physical, mechanical, and performance testing of the Reverse Medical MVP System 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 Reverse Medical MVP. 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 Reverse Medical MVP System included: Visual Inspection, Dimensional Inspection, Tensile Strength, USP Particulate, Radial Force, Microcatheter Compatibility, Detachment Time, Torque Strength, Plug Foreshortening, Nickel Release, Corrosion Resistance (potentiodynamic and galvanic), Flow Occlusion/Reduction, Magnetic Resonance Compatibility, Labeling, Packaging, Shelf Life, Sterility, Biocompatibility, Detachment Box and Cable Set. All tests performed passed successfully, demonstrating that the product is safe and effective for its labeled indications and is Substantially Equivalent to the currently marketed predicate devices.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K113658, K093002, K081465, K103008, K001083

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 870.3300 Vascular embolization device.

(a)
Identification. A vascular embolization device is an intravascular implant intended to control hemorrhaging due to aneurysms, certain types of tumors (e.g., nephroma, hepatoma, uterine fibroids), and arteriovenous malformations. This does not include cyanoacrylates and other embolic agents, which act by polymerization or precipitation. Embolization devices used in neurovascular applications are also not included in this classification, see § 882.5950 of this chapter.(b)
Classification. Class II (special controls.) The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Vascular and Neurovascular Embolization Devices.” For availability of this guidance document, see § 870.1(e).

0

Image /page/0/Picture/0 description: The image shows the logo for Reverse Medical. The logo is in black and white and features the words "Reverse Medical" in a bold, sans-serif font. To the upper right of the word "Medical" is the trademark symbol. Underneath the words is a curved line that starts thin on the left and gradually thickens as it curves upward to the right, ending in an arrowhead.

K123803

510(k) Summary

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 Reverse Medical MVP™ Micro Vascular Plug System.

Device Trade or Proprietary Name

Reverse Medical MVP™Micro Vascular Plug System

Sponsor /Applicant Name and Address

Reverse Medical Corporation 13700 Alton Parkway Suite 167 Irvine, CA 92618

Sponsor Contact Information

Linda D'Abate Reverse Medical Vice President, RA/CA/QA

Date of Preparation of 510(k) Summary

June 24, 2013

Device Common/Usual or Classification Name

Device Embolization, Vascular (21 CFR 870.3300, Product Code: KRD)

Identification of the Legally Marketed Devices to which Equivalence is Being Claimed:

| Name of Predicate

DevicesManufacturer510(k) Number
AMPLATZER® Vascular Plug 4AGA Corporation
Plymouth, MNK113658
Azur Peripheral HydroCoil
Endovascular Embolization
System - Detachable 35MicroVention, Inc.
Tustin, CAK093002
Axium Detachable Coil Systemev3 Endovascular, Inc.
Irvine, CAK081465
InZone Detachment System
with the IZDS Connecting CableBoston Scientific, Inc
Freemont, CAK103008
Guglielmi Detachable Coil
Power SupplyBoston Scientific, Inc
Freemont, CAK001083

Device Description

The Reverse Medical Micro Vascular Plug (MVP) is a micro vascular occlusion device comprised of a detachable embolic plug attached to a composite delivery wire and designed for delivery via a microcatheter (0.021" ID). The MVP is a self-expandable, ovoid-shaped device made from Nitinol with an

2 2013 JUL

1

ePTFE partial cover. The device is secured at both ends with platinum marker bands. The Reverse Medical MVP is intended to reduce or occlude vascular blood flow of vessels having a diameter of 1.5 – 3.0mm.

The proximal marker band attaches to a delivery wire that pushes through a commercially available catheter to the intended treatment site. The Reverse Medical Detachment Box regulates detachment of the implant device from the delivery wire by electrolytic means during deployment, and monitors, detects, signals and measures the time of detachment. The Reverse Medical Cable Set – 275 cm length (Model RMCS – 2.75US) is provided sterile. The cable set connects to the Detachment Box through a bayonet type dual pin connector that ensures correct polarity. The Reverse Medical Cable Set and Detachment Box will be sold separately. One 9-volt battery and a sterile needle (20 G or 22 G) will also be needed for use with the Reverse Medical Micro Vascular Plug (MVP).

Intended Use

The Reverse Medical MVP is intended for use to obstruct or reduce the rate of blood flow in the peripheral vasculature.

New DevicePredicate Devices
Reverse Medical
MVP SystemAMPLATZER®
Vascular Plug 4Azur Peripheral
HydroCoil
Endovascular
Embolization
System –
Detachable 35Axium Detachable
CoilsInZone Detachment
System with the IZDS
Connecting CableGuglielmi Detachable
Coil Power Supply
510(k) No.K123803 Class II
KRD 870:3300K113658 Class II
KRD 870:3300K093002 Class II
KRD 870:3300K081465 Class II
KRD 870:3300K103008 Class II
KRD 870:3300 and
HCGK001083 Class II
HCG 882.5950
Indication for
useIndicated for use
to obstruct or
reduce the rate of
blood flow in the
peripheral
vasculature.Indicated for arterial
and venous
embolizations in the
peripheral
vasculature.Intended to reduce
or block the rate of
blood flow in
vessels of the
peripheral
vasculature.The AXIUM
Detachable Coils are
also indicated for
arterial and venous
embolizations in the
peripheral
vasculatureIntended for use with
all versions of BSC
Detachable Coils in the
embolization of
intracranial aneurysms
and other vascular
malformations of the
neuro and peripheral
vasculature.Intended for use with
all versions of Boston
Scientific/Target's
Guglielmi Detachable
Coils in the
embolization of
intracranial
aneurysms and other
vascular
malformations of the
neuro and peripheral
vasculature
Method of
PlacementDelivery wire
through a 0.021" ID
microcatheter.Delivery wireDelivery wireDelivery wire
(pusher)Delivery wireDelivery wire
Radiopaque
markersPlatinum marker
bands at each endRadiopaque marker
bands at each endN/ARadiopaque position
markerRadiopaque position
markerRadiopaque position
marker
Proximal End
ConfigurationProximal marker
band and
attachment for
pusher wireRadiopaque marker
band and micro
screw attachmentN/AN/AN/AN/A
Detachment
SystemYes - ElectrolyticYes - MechanicalYes - ThermalYes - MechanicalYes - ElectrolyticYes - Electrolytic
Battery
OperatedYesNoYesNoYesYes

Comparison to Predicate Devices

2

Summary of Non-Clinical Data

Biocompatibility and Sterilization

The device was characterized as an implant, internal communicating device, which contacts circulating blood for exposure ≥ 30 days.

The Reverse Medical MVP 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 Reverse Medical MVP successfully passed all of the following biocompatibility tests, demonstrating that the materials are biocompatible:

TestResults/Acceptance
CytotoxicityNon-Cytotoxic
Kligman Maximization
Sensitization TestNon-Sensitizing
Intracutaneous InjectionNon-Irritant
Systemic InjectionNon-Toxic
Material-Mediated PyrogenicityNon-Pyrogenic
Genotoxicity/MutagenicityNon-Mutagenic
In Vitro Mouse Lymphoma AssayNon-Mutagenic
In Vivo Mouse LymphomaNon-Mutagenic
HemolysisNon-Hemolytic
Complement Activation C3a and
SC5ba-9No greater biological response than corresponding control
Inactivated PartialMinimal, passed acceptance criteria
Thromboplastin TimeNon-activator, passed acceptance criteria
Platelet and Leukocycte CountsTest articles: No range or acceptable level established.
Muscle ImplantationIntramuscular Implantation- 4 and 13 week, passed acceptance criteria

Test Result Summary

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 10 °.

Design Verification (Bench-Top Testing)

The physical, mechanical, and performance testing of the Reverse Medical MVP System 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 Reverse Medical MVP. 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 Reverse Medical MVP System included:

3

Verification and Test Summary

  • Visual Inspection .
  • . Dimensional Inspection
  • Tensile Strength .
  • USP Particulate
  • . Radial Force
  • . Microcatheter Compatibility
  • . Detachment Time
  • . Torque Strength
  • Plug Foreshortening ●
  • . Nickel Release
  • Corrosion Resistance (potentiodynamic and galvanic).
  • Flow Occlusion/Reduction �
  • Magnetic Resonance Compatibility .
  • Labeling ●
  • Packaging .
  • Shelf Life
  • Sterility
  • Biocompatibility .
  • Detachment Box and Cable Set

All tests performed passed successfully. The physical, mechanical, and performance testing of the Reverse Medical MVP System demonstrate that the product is safe and effective for its labeled indications and is Substantially Equivalent to the currently marketed predicate devices

Substantial Equivalence

The performance of the Reverse Medical MVP System 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, animal testing, and sterilization validation.

The Reverse Medical MVP System 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.

4

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus, which is a symbol often associated with medicine and healthcare. The caduceus is depicted with a simple, flowing design. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus.

Public Health Service

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

July 2, 2013

Reverse Medical Corporation c/o Mr. Jeffrey Valko 13700 Alton Parkway, Suite 167 Irvine, CA 92618

Re: K123803

Trade/Device Name: Reverse Medical Micro Vascular Plug System Regulation Number: 21 CFR 870.3300 Regulation Name: Device. Vascular, For Promoting Embolization Regulatory Class: Class II Product Code: KRD Dated: June 10, 2013 Received: June 11, 2013

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.

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.

5

Page 2 - Mr. Jeffrey Valko

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please . contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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/MedicalDeyices/Safety/ReportalProblem/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 -S

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

Enclosure

6

  1. Indications for Use

510(k) Number (if known):_

Device Name: Reverse Medical™ Micro Vascular Plug (MVP™)

Indication for Use:

: ・

The Reverse Medical™ Micro Vascular Plug (MVP™) System is intended for use to obstruct or reduce the rate of blood flow in the peripheral vasculature.

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)

Bram D. Zuckerman -S
2013.07.02 17:24:16
-04'00'