(105 days)
The Arrow NextStep® Retrograde Catheter is indicated for use in attaining long-term vascular access for hemodialysis and apheresis. The Arrow NextStep Retrograde Catheter is inserted percutaneously and is preferentially placed into the internal jugular (JJ) vein. Alternately, this catheter may be inserted into the subclavian vein although the jugular vein is the preferred site. Catheters greater than 40 cm are intended for femoral vein insertion. The Arrow NextStep Retrograde catheter is intended for use in adult patients.
The NextStep Retrograde Chronic Hemodialysis Catheter (herein referred to as the proposed NSR catheter) is a long-term, single use catheter designed to provide access to the central venous system in a healthcare facility environment. The catheter is a two-piece, two-lumen, 15 Fr, step-tipped catheter designed for retrograde placement. The catheter is available in multiple lengths.
The catheters will be packaged sterile with various components to facilitate insertion.
The provided text describes a 510(k) premarket notification for a medical device, the NextStep Retrograde Chronic Hemodialysis Catheter. However, it does not contain a study that proves the device meets specific acceptance criteria in the way a clinical trial or performance study would.
Instead, the document focuses on demonstrating substantial equivalence to previously approved predicate devices. This means the manufacturer is arguing that their new device is as safe and effective as existing legally marketed devices, primarily through non-clinical testing and comparison of technological characteristics.
Therefore, many of the requested elements (like "acceptance criteria" in the sense of performance metrics, sample size for test sets, expert qualifications, adjudication methods, MRMC studies, or specific ground truth for test/training sets) are not applicable or not provided in this type of regulatory submission. The document explicitly states: "Clinical performance data was not used to determine substantial equivalence."
Here's the breakdown of what can be extracted from the document:
1. Table of Acceptance Criteria and Reported Device Performance:
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Acceptance Criteria (Implied for Substantial Equivalence): The primary "acceptance criteria" for a 510(k) submission are that the device is substantially equivalent to a legally marketed predicate device in terms of safety and effectiveness. This is achieved by demonstrating similar technological characteristics, intended use, and functional performance, backed by non-clinical testing. Specific performance metrics are compared against those of the predicate.
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Reported Device Performance (Non-clinical):
- Dialysis Flow Rate: Performed for longer length catheters.
- Hemolysis: Performed for longer length catheters.
- Additional Testing: Complies with Draft Guidance for Industry and Food and Drug Administration Staff - Class II Special Controls Guidance Document: Implanted Blood Access Devices for Hemodialysis (for longer length catheters).
- Bench Testing: Previously completed on predicate NextStep Retrograde catheters in accordance with ISO 10555-1 and 10555-3.
- Biocompatibility: In accordance with ISO 10993-1.
Note: The document states what tests were performed, but does not provide the specific numerical results or target values (acceptance criteria) for these tests within this summary.
2. Sample size used for the test set and the data provenance:
- Not applicable / Not provided. The document states "Clinical performance data was not used to determine substantial equivalence." Non-clinical bench testing was performed, but specific "test set" sample sizes or data provenance (e.g., country of origin) for these bench tests are not detailed in this summary.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable / Not provided. No clinical "ground truth" establishment by experts for a test set is discussed, as clinical data was not used.
4. Adjudication method for the test set:
- Not applicable / Not provided. Not relevant due to the lack of clinical test set and expert review.
5. 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:
- Not applicable. This device is a chronic hemodialysis catheter, not an AI-assisted diagnostic or imaging device, so MRMC studies or AI assistance are not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical medical device, not an algorithm, so standalone performance in this context is not relevant.
7. The type of ground truth used:
- Non-clinical Performance Standards/Predicate Device Performance: The "ground truth" for this submission largely relies on established international standards (e.g., ISO 10555-1, 10555-3, 10993-1) for medical device performance and biocompatibility, as well as the known performance characteristics of the predicate devices. The aim is to show the new device performs acceptably against these standards and is equivalent to the predicate.
8. The sample size for the training set:
- Not applicable / Not provided. No "training set" in the context of machine learning or AI is relevant here. For non-clinical bench testing, the sample sizes for the specific tests are not disclosed in this summary.
9. How the ground truth for the training set was established:
- Not applicable / Not provided. Similar to point 8, no training set or its ground truth establishment is relevant or described for this device and submission type.
§ 876.5540 Blood access device and accessories.
(a)
Identification. A blood access device and accessories is a device intended to provide access to a patient's blood for hemodialysis or other chronic uses. When used in hemodialysis, it is part of an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and provides access to a patient's blood for hemodialysis. The device includes implanted blood access devices, nonimplanted blood access devices, and accessories for both the implanted and nonimplanted blood access devices.(1) The implanted blood access device is a prescription device and consists of various flexible or rigid tubes, such as catheters, or cannulae, which are surgically implanted in appropriate blood vessels, may come through the skin, and are intended to remain in the body for 30 days or more. This generic type of device includes various catheters, shunts, and connectors specifically designed to provide access to blood. Examples include single and double lumen catheters with cuff(s), fully subcutaneous port-catheter systems, and A-V shunt cannulae (with vessel tips). The implanted blood access device may also contain coatings or additives which may provide additional functionality to the device.
(2) The nonimplanted blood access device consists of various flexible or rigid tubes, such as catheters, cannulae or hollow needles, which are inserted into appropriate blood vessels or a vascular graft prosthesis (§§ 870.3450 and 870.3460), and are intended to remain in the body for less than 30 days. This generic type of device includes fistula needles, the single needle dialysis set (coaxial flow needle), and the single needle dialysis set (alternating flow needle).
(3) Accessories common to either type include the shunt adaptor, cannula clamp, shunt connector, shunt stabilizer, vessel dilator, disconnect forceps, shunt guard, crimp plier, tube plier, crimp ring, joint ring, fistula adaptor, and declotting tray (including contents).
(b)
Classification. (1) Class II (special controls) for the implanted blood access device. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible. Material names and specific designation numbers must be provided.
(ii) Performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(A) Pressure versus flow rates for both arterial and venous lumens, from the minimum flow rate to the maximum flow rate in 100 milliliter per minute increments, must be established. The fluid and its viscosity used during testing must be stated.
(B) Recirculation rates for both forward and reverse flow configurations must be established, along with the protocol used to perform the assay, which must be provided.
(C) Priming volumes must be established.
(D) Tensile testing of joints and materials must be conducted. The minimum acceptance criteria must be adequate for its intended use.
(E) Air leakage testing and liquid leakage testing must be conducted.
(F) Testing of the repeated clamping of the extensions of the catheter that simulates use over the life of the device must be conducted, and retested for leakage.
(G) Mechanical hemolysis testing must be conducted for new or altered device designs that affect the blood flow pattern.
(H) Chemical tolerance of the device to repeated exposure to commonly used disinfection agents must be established.
(iii) Performance data must demonstrate the sterility of the device.
(iv) Performance data must support the shelf life of the device for continued sterility, package integrity, and functionality over the requested shelf life that must include tensile, repeated clamping, and leakage testing.
(v) Labeling of implanted blood access devices for hemodialysis must include the following:
(A) Labeling must provide arterial and venous pressure versus flow rates, either in tabular or graphical format. The fluid and its viscosity used during testing must be stated.
(B) Labeling must specify the forward and reverse recirculation rates.
(C) Labeling must provide the arterial and venous priming volumes.
(D) Labeling must specify an expiration date.
(E) Labeling must identify any disinfecting agents that cannot be used to clean any components of the device.
(F) Any contraindicated disinfecting agents due to material incompatibility must be identified by printing a warning on the catheter. Alternatively, contraindicated disinfecting agents must be identified by a label affixed to the patient's medical record and with written instructions provided directly to the patient.
(G) Labeling must include a patient implant card.
(H) The labeling must contain comprehensive instructions for the following:
(
1 ) Preparation and insertion of the device, including recommended site of insertion, method of insertion, and a reference on the proper location for tip placement;(
2 ) Proper care and maintenance of the device and device exit site;(
3 ) Removal of the device;(
4 ) Anticoagulation;(
5 ) Management of obstruction and thrombus formation; and(
6 ) Qualifications for clinical providers performing the insertion, maintenance, and removal of the devices.(vi) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices that include subcutaneous ports must include the following:
(A) Labeling must include the recommended type of needle for access as well as detailed instructions for care and maintenance of the port, subcutaneous pocket, and skin overlying the port.
(B) Performance testing must include results on repeated use of the ports that simulates use over the intended life of the device.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(vii) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices with coatings or additives must include the following:
(A) A description and material characterization of the coating or additive material, the purpose of the coating or additive, duration of effectiveness, and how and where the coating is applied.
(B) An identification in the labeling of any coatings or additives and a summary of the results of performance testing for any coating or material with special characteristics, such as decreased thrombus formation or antimicrobial properties.
(C) A Warning Statement in the labeling for potential allergic reactions including anaphylaxis if the coating or additive contains known allergens.
(D) Performance data must demonstrate efficacy of the coating or additive and the duration of effectiveness.
(viii) The following must be included for A-V shunt cannulae (with vessel tips):
(A) The device must comply with Special Controls in paragraphs (b)(1)(i) through (v) of this section with the exception of paragraphs (b)(1)(ii)(B), (b)(1)(ii)(C), (b)(1)(v)(B), and (b)(1)(v)(C), which do not apply.
(B) Labeling must include Warning Statements to address the potential for vascular access steal syndrome, arterial stenosis, arterial thrombosis, and hemorrhage including exsanguination given that the device accesses the arterial circulation.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(2) Class II (performance standards) for the nonimplanted blood access device.
(3) Class II (performance standards) for accessories for both the implanted and the nonimplanted blood access devices not listed in paragraph (b)(4) of this section.
(4) Class I for the cannula clamp, disconnect forceps, crimp plier, tube plier, crimp ring, and joint ring, accessories for both the implanted and nonimplanted blood access device. The devices subject to this paragraph (b)(4) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.