K Number
K132931
Device Name
APOLLO SYSTEM
Manufacturer
Date Cleared
2014-01-17

(121 days)

Product Code
Regulation Number
882.1480
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Apollo™ System is used for the controlled aspiration of tissue and/or fluids during surgery of the Ventricular System. The Apollo™ disposable wand is inserted through the working channel of a neuroendoscopic trocar.
Device Description
The Apollo System is a two component surgical instrument designed to aid a physician in the removal of tissue and/or fluids during endoscopic-assisted microneurosurgery. The reusable component has three functions. These functions are vacuum generation, generation of vibrational energy, and saline irrigation. The disposable component, "the Wand" is a rigid cannula to remove tissue and/or fluid with the assistance of vibrational energy and aspiration. The disposable wand is designed to pass through the working channel of various neuro-endoscope trocars allowing visualization of the procedure. The method of action of removal is first vacuum aspiration, which draws the tissue and/or fluid into the lumen of the wand. Next, a vibrational wire is agitated inside the lumen of the wand facilitating movement of any tissue and/or fluid that may otherwise clog the lumen. Saline irrigation has the purpose of providing additional fluid to transport the tissue through the cannula. The irrigation and inner vibration wire components of the disposable wand provide an improvement over existing methods of suction aspiration through a cannula in that the use of the Apollo wand can prevent clogging. Intended users for this device are physicians who have received appropriate training in endoscopicassisted microneurosurgery.
More Information

Not Found

No
The description focuses on mechanical and fluid dynamics (vacuum, vibration, irrigation) for tissue removal. There is no mention of AI/ML, image processing, or data analysis for decision-making or control.

Yes.
The device's intended use is for the "controlled aspiration of tissue and/or fluids during surgery of the Ventricular System," which involves removing unwanted material from the body, leading to a therapeutic benefit.

No

The Apollo™ System is described as a surgical instrument used for the controlled aspiration of tissue and/or fluids during surgery. Its primary function is to remove tissue and fluids, not to diagnose conditions.

No

The device description clearly outlines both reusable and disposable hardware components (vacuum generator, vibrational energy generator, saline irrigation, rigid cannula, vibrational wire). The performance studies also include extensive bench-top testing of these physical components.

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

Here's why:

  • Intended Use: The intended use is for the controlled aspiration of tissue and/or fluids during surgery of the Ventricular System. This is a surgical procedure performed directly on a patient.
  • Device Description: The device is described as a surgical instrument designed to aid in the removal of tissue and/or fluids during endoscopic-assisted microneurosurgery. It involves physical removal of material from the body.
  • Lack of In Vitro Testing: IVD devices are used to examine specimens outside of the body (in vitro) to provide information for diagnosis, monitoring, or screening. The Apollo™ System's function is to remove material from the body during a surgical procedure.
  • Performance Studies: The performance studies focus on biocompatibility and bench-top testing of the device's physical and mechanical properties, not on the analysis of biological samples for diagnostic purposes.

The Apollo™ System is a surgical device used for tissue and fluid removal during a medical procedure, not for in vitro diagnostic testing of samples.

N/A

Intended Use / Indications for Use

The Apollo™ System is used for the controlled aspiration of tissue and/or fluids during surgery of the Ventricular System. The Apollo™ disposable wand is inserted through the working channel of a neuroendoscopic trocar.

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

GWG

Device Description

The Apollo System is a two component surgical instrument designed to aid a physician in the removal of tissue and/or fluids during endoscopic-assisted microneurosurgery. The reusable component has three functions. These functions are vacuum generation, generation of vibrational energy, and saline irrigation. The disposable component, "the Wand" is a rigid cannula to remove tissue and/or fluid with the assistance of vibrational energy and aspiration. The disposable wand is designed to pass through the working channel of various neuro-endoscope trocars allowing visualization of the procedure. The method of action of removal is first vacuum aspiration, which draws the tissue and/or fluid into the lumen of the wand. Next, a vibrational wire is agitated inside the lumen of the wand facilitating movement of any tissue and/or fluid that may otherwise clog the lumen. Saline irrigation has the purpose of providing additional fluid to transport the tissue through the cannula. The irrigation and inner vibration wire components of the disposable wand provide an improvement over existing methods of suction aspiration through a cannula in that the use of the Apollo wand can prevent clogging. Intended users for this device are physicians who have received appropriate training in endoscopicassisted microneurosurgery.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Ventricular System

Indicated Patient Age Range

Not Found

Intended User / Care Setting

physicians who have received appropriate training in endoscopic-assisted microneurosurgery.

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

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

The subject Apollo™ System components met all established requirements.

Biocompatibility Testing:
Biocompatibility tests conducted with Penumbra Apollo™ System were selected in accordance with ISO-10993 -1 guidelines (Biological Evaluation of Medical Devices) for a blood contacting permanent implant device. All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices.

TestResultsConclusions
In vitro Cytotoxicity (MEM Elution)Sample extracts exhibited Grade 2 (mild reactivity)Non-cytotoxic
Sensitization (Magnusson - Kligman Method)Samples exhibited Grade: 0 (No sensitization response)Does not elicit sensitization response
Irritation (Intracutaneous Reactivity)Sample exhibited Grade 0.0 (saline extract) and Grade 0.1 (sesame oil extract)Non-irritant
Systemic Toxicity - Systemic Injection (ISO)No evidence of systemic toxicity from sample extractsDoes not cause systemic toxicity
Material Mediated PyrogenNo animals had a temperature rise ≥ 0.5°CNon-pyrogenic
Subchronic Toxicity (Subacute Toxicity)Negative for signs of systemic toxicityDoes not cause systemic toxicity
Hemocompatibility - Thrombosis (Dog Thrombogenicity)Device exhibited acceptable reaction to bloodNon-thrombogenic
Coagulation (PTT)Test article clotting times similar to the predicate deviceAcceptable coagulation response
Hematology (Hemolysis - Direct Contact)Hemolytic index = 1.04% Corrected hemolytic index = 0.23%Non-hemolytic
Hematology (Hemolysis - Indirect (Extract) Contact)Hemolytic index = 0.53% Corrected hemolytic index = 0.00%Non-hemolytic
Genotoxicity - Ames MutagenicityTests show no zone of increased reversion or of toxicityNon-mutagenic
Mouse LymphomaNon-genotoxic and non-clastogenic)Non-mutagenic
In vivo Mouse micronucleusNo manifestation of toxicity nor biologically significant erythrpoietic disturbances resulting in delayed mutagenesis. No biologically significant increases in mPCE production.Non-mutagenic

In summary, non-clinical testing found the Penumbra Apollo™ System to be biocompatible according to the requirements of ISO 10993. Additionally, the product was found to be non-pyrogenic. The physical, mechanical and performance testing of the Penumbra Apollo™ System demonstrate that the product is substantially equivalent to the currently marketed predicate devices.

Bench-top Testing:
The physical, mechanical and performance testing of the Apollo™ System components demonstrates that the devices are substantially equivalent to the currently marketed predicate devices:
Design Verification testing was conducted to evaluate the physical and mechanical properties of the Apollo™ System components. All studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. All testing was performed using units which were 2x sterilized and met finished goods release requirements. The tests performed on the Apollo™ System components included:

TestMethodsConclusions
Disposable Component Testing - Tensile TestThe following device connections and bonds were tested for tensile strength: - Sonic Connector to Wire - RHV to Irrigation Catheter Shaft - Proximal Aspiration Tubing to Y-Connector - Wand-Canister Tubing to Male Swivel Connector - Wand-Canister TubingComponent bonds and connections meet or exceed minimal tensile specifications
Corrosionto Suction Connector - Aspiration Tubing to T-Connector Device was subjected to testing to evaluateDevice meets criteria as non-corrosive
Simulated Usepotential for corrosion Device tested for simulated use outputsDevice meets or exceeds simulated use testing specifications
FatigueDevice tested for fatigue based outputsDevice meets or exceeds fatigue testing specifications
Reusable Capital Equipment - IEC 60601-1Tested Apollo System for compliance with standardComplies with standard
IEC 60601-1-2Tested Apollo System for compliance with standardComplies with standard
The Apollo System controls shall be easily identifiable by the User.Tested Apollo System for usabilityControls are easily identifiable
The Apollo System controls shall be validated for UsabilityTested Apollo System for usabilityValidated for Usability
The Apollo System reusable component should supply uniform irrigation and vibrational energy for an entire caseTested Apollo System for functionalityMeets or exceeds specifications to supply uniform irrigation and vibrational energy for an entire case
The Apollo System will be a durable piece of capital equipmentTested Apollo System for durabilityThe Apollo System is a durable piece of capital equipment
The Apollo System should be quietTested Apollo System for audible noise levelThe Apollo System meets the audible noise specification
The Canister should have volume reference markingsVerified that Canister has volume reference markingsThe Canister adequately exhibits the design feature
Canister should be able to withstand maximum pressure delivered by the Apollo SystemTested the Canister at maximum pressureCanister meets specifications at maximum pressure
Canister lid should include a feature to prevent excess fluid from entering the Apollo System.Verified that the Canister contains a feature to prevent excess fluids from entering the Apollo SystemThe Canister adequately exhibits the design feature

All testing met specification. The results of the tests appropriately address the physical and mechanical performance expectations of the device. Based on these overall results, the physical and mechanical properties of the Apollo™ System components are acceptable for the intended use and substantially equivalent to the 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.

K983365, K122756

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

§ 882.1480 Neurological endoscope.

(a)
Identification. A neurological endoscope is an instrument with a light source used to view the inside of the ventricles of the brain.(b)
Classification. Class II (performance standards).

0

K132 931

JAN 1 7 2014

510(k) SUMMARY l

(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 Apollo™ System.

Sponsor/Applicant Name and Address 1.1

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

Sponsor Contact Information 1.2

Seth A. Schulman Director, Regulatory Affairs Phone: 510-748-3223 FAX: 510-217-6414 email: seth.schulman@Penumbrainc.com

Date of Preparation of 510(k) Summary 1.3

December 13, 2013

1.4 Device Trade or Proprietary Name

Apollo™ System

Device Common/Usual or Classification Name 1.5

Endoscope, neurological (Product Code: GWG, 21 CFR §882.1480)

Identification of the Legally Marketed Devices to which Equivalence is Being 1.6 Claimed:

| Name of Predicate Device | Name of Manufacturer (Town,
State) | 510(k) Number |
|-----------------------------|---------------------------------------|---------------|
| Aesculap Aspiration Cannula | Aesculap, Inc.
Center Valley, PA | K983365 |
| Penumbra Pump MAX™ | Penumbra, Inc.
Alameda, CA | K122756 |

1

1.7 Device Description:

The Apollo System is a two component surgical instrument designed to aid a physician in the removal of tissue and/or fluids during endoscopic-assisted microneurosurgery. The reusable component has three functions. These functions are vacuum generation, generation of vibrational energy, and saline irrigation. The disposable component, "the Wand" is a rigid cannula to remove tissue and/or fluid with the assistance of vibrational energy and aspiration. The disposable wand is designed to pass through the working channel of various neuro-endoscope trocars allowing visualization of the procedure. The method of action of removal is first vacuum aspiration, which draws the tissue and/or fluid into the lumen of the wand. Next, a vibrational wire is agitated inside the lumen of the wand facilitating movement of any tissue and/or fluid that may otherwise clog the lumen. Saline irrigation has the purpose of providing additional fluid to transport the tissue through the cannula. The irrigation and inner vibration wire components of the disposable wand provide an improvement over existing methods of suction aspiration through a cannula in that the use of the Apollo wand can prevent clogging. Intended users for this device are physicians who have received appropriate training in endoscopicassisted microneurosurgery.

1.8 Indications for Use:

The Apollo™ System is used for the controlled aspiration of tissue and/or fluids during surgery of the Ventricular System. The Apollo™ disposable wand is inserted through the working channel of a neuroendoscopic trocar.

| | Aesculap Aspiration
Cannula | Penumbra Apollo™
System |
|-------------------|---------------------------------|------------------------------------------------------------------------------------|
| 510(k) No. | K983365 | K132931 |
| Classification | Class II, GWG | Class II, GWG |
| Materials | | |
| Wand | Polymer, Metal | Same |
| Tubing | N/A (Not supplied with
Wand) | Polymer |
| Canister | N/A | Polymer |
| Capital Equipment | N/A | General electro-medical
equipment compliant
with IEC 60601-1
requirements |
| Sterilization | EtO | Same |
| Shelf-Life | 36-Months | Same |

Predicate Comparison 1.9

2

| | Aesculap Aspiration
Cannula | Penumbra Apollo™
System |
|----------------------------|----------------------------------|-------------------------------------|
| Vacuum Source | Hospital based suction
system | System based aspiration
pump |
| Vibration Energy
Source | N/A | System based vibration
generator |

| | Penumbra Pump
MAXTM | Penumbra ApolloTM
System Pump |
|-------------------------------|-------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) No. | K051758 | K132931 |
| Classification | Class II, JCX | Class II, GWG |
| Indication | The Penumbra
Aspiration Pump is
intended for general
suction use in hospitals
or clinics. | The ApolloTM System is
used for the controlled
aspiration of tissue
and/or fluids during
surgery of the
Ventricular System.
The ApolloTM
disposable wand is
inserted through the
working channel of a
neuroendoscopic trocar. |
| Specifications | | |
| IEC 60601-1
Compliance | Yes | SAME |
| IEC 60601-1-2
Compliance | Yes | SAME |
| Voltage | 100-115Vac / 230 Vac | SAME |
| Frequency | 50 Hz / 60 Hz | SAME |
| Vacuum Range | 0-29 inHg (0-98.2 kPa) | SAME |
| Flow Rate | 0-23 LPM
0-0.8 SCFM | SAME |
| Fuses | Two 5 amp slow blow
fuse (250 Vac) | SAME |
| Motor and Pump
Description | Oil-less, rotating pump | SAME |
| Sterilization | Non-Sterile | SAME |
| Shelf-Life | N/A | SAME |

1.10 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 Apollo™ System as well as its substantial equivalence to the predicate devices:

3

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

The subject Apollo™ System components met all established requirements.

1.10.1 Biocompatibility Testing

Biocompatibility tests conducted with Penumbra Apollo™ System were selected in accordance with ISO-10993 -1 guidelines (Biological Evaluation of Medical Devices) for a blood contacting permanent implant device. All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices.

TestResultsConclusions
In vitro Cytotoxicity (MEM Elution)Sample extracts exhibited
Grade 2 (mild reactivity)Non-cytotoxic
Sensitization (Magnusson - Kligman Method)Samples exhibited Grade: 0
(No sensitization response)Does not elicit
sensitization
response
Irritation (Intracutaneous Reactivity)Sample exhibited Grade 0.0
(saline extract) and Grade 0.1
(sesame oil extract)Non-irritant
Systemic Toxicity
Systemic Injection (ISO)No evidence of systemic
toxicity from sample extractsDoes not cause
systemic toxicity
Material Mediated PyrogenNo animals had a temperature
rise ≥ 0.5°CNon-pyrogenic
Subchronic Toxicity (Subacute Toxicity)Negative for signs of systemic
toxicityDoes not cause
systemic toxicity
Hemocompatibility
Thrombosis (Dog Thrombogenicity)Device exhibited acceptable
reaction to bloodNon-
thrombogenic
Coagulation (PTT)Test article clotting times
similar to the predicate deviceAcceptable
coagulation
response
Hematology (Hemolysis - Direct Contact)Hemolytic index = 1.04%
Corrected hemolytic index =
0.23%Non-hemolytic
Hematology (Hemolysis - Indirect (Extract)
Contact)Hemolytic index = 0.53%
Corrected hemolytic index =
0.00%Non-hemolytic
Genotoxicity
Ames MutagenicityTests show no zone of
increased reversion or of
toxicityNon-mutagenic
Mouse LymphomaNon-genotoxic and non-
clastogenic)Non-mutagenic

4

TestResultsConclusions
In vivo Mouse micronucleusNo manifestation of toxicity
nor biologically significant
erythrpoietic disturbances
resulting in delayed
mutagenesis. No biologically
significant increases in mPCE
production.Non-mutagenic

In summary, non-clinical testing found the Penumbra Apollo™ System to be biocompatible according to the requirements of ISO 10993. Additionally, the product was found to be non-pyrogenic. The physical, mechanical and performance testing of the Penumbra Apollo™ System demonstrate that the product is substantially equivalent to the currently marketed predicate devices.

1.10.2 Bench-top Testing

The physical, mechanical and performance testing of the Apollo™ System components demonstrates that the devices are substantially equivalent to the currently marketed predicate devices:

Design Verification testing was conducted to evaluate the physical and mechanical properties of the Apollo™ System components. All studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. All testing was performed using units which were 2x sterilized and met finished goods release requirements. The tests performed on the Apollo™ System components included:

5

TestMethodsConclusions
Disposable Component Testing
Tensile TestThe following device
connections and bonds
were tested for tensile
strength:
  • Sonic Connector to
    Wire
  • RHV to Irrigation
    Catheter Shaft
  • Proximal Aspiration
    Tubing to Y-Connector
  • Wand-Canister Tubing
    to Male Swivel
    Connector
  • Wand-Canister Tubing | Component
    bonds and
    connections meet
    or exceed
    minimal tensile
    specifications |
    | Corrosion | to Suction Connector
  • Aspiration Tubing to
    T-Connector
    Device was subjected to
    testing to evaluate | Device meets
    criteria as non- |
    | Simulated Use | potential for corrosion
    Device tested for
    simulated use outputs | corrosive
    Device meets or
    exceeds
    simulated use
    testing
    specifications |
    | Fatigue | Device tested for fatigue
    based outputs | Device meets or
    exceeds fatigue
    testing
    specifications |
    | Reusable Capital Equipment | | |
    | IEC 60601-1 | Tested Apollo System
    for compliance with
    standard | Complies with
    standard |
    | IEC 60601-1-2 | Tested Apollo System
    for compliance with
    standard | Complies with
    standard |
    | The Apollo System controls shall be easily
    identifiable by the User. | Tested Apollo System
    for usability | Controls are
    casily identifiable |
    | The Apollo System controls shall be validated for
    Usability | Tested Apollo System
    for usability | Validated for
    Usability |
    | The Apollo System reusable component should
    supply uniform irrigation and vibrational energy for
    an entire case | Tested Apollo System
    for functionality | Meets or exceeds
    specifications to
    supply uniform
    irrigation and
    vibrational
    energy for an
    entire case |
    | The Apollo System will be a durable piece of capital
    equipment | Tested Apollo System
    for durability | The Apollo
    System is a |
    | Test | Methods | Conclusions |
    | The Apollo System should be quiet | Tested Apollo System
    for audible noise level | The Apollo
    System meets the
    audible noise
    specification |
    | The Canister should have volume reference
    markings | Verified that Canister
    has volume reference
    markings | The Canister
    adequately
    exhibits the
    design feature |
    | Canister should be able to withstand maximum
    pressure delivered by the Apollo System | Tested the Canister at
    maximum pressure | Canister meets
    specifications at
    maximum
    pressure |
    | Canister lid should include a feature to prevent
    excess fluid from entering the Apollo System. | Verified that the
    Canister contains a
    feature to prevent
    excess fluids from
    entering the Apollo
    System | The Canister
    adequately
    exhibits the
    design feature |

6

All testing met specification. The results of the tests appropriately address the physical and mechanical performance expectations of the device. Based on these overall results, the physical and mechanical properties of the Apollo™ System components are acceptable for the intended use and substantially equivalent to the predicate devices.

1.10.3 Sterilization

The Penumbra Apollo™ System contains several components. The following table identifies which components are sterile or non-sterile. None of the Penumbra Apollo™ System components can be end-user sterilized.

ComponentSterility
WandSterile
TubingSterile
CanisterNon-Sterile
GeneratorNon-Sterile
PumpNon-Sterile
I.V. PoleNon-Sterile
FootswitchNon-Sterile
Table 1: Component Sterility=
-----------------------------------------

The Penumbra Apollo™ System disposable wands and tubing are packaged and submitted to a contract ISO certified facility for the sterilization of medical devices.

7

The EtO validation and routine sterilization process of the Penumbra Apollo™ System disposable wands and tubing is based on EN ISO 11135' ensuring a Sterility Assurance Level (SAL) of 10-6.

1.10.4 Shelf-Life

The expiration period for the Penumbra Apollo™ System disposable wands and tubing are currently established for 12-months based on 1 yr. accelerated aging test results. The shelf life protocol specifies a test regimen using both accelerated and confirmatory realtime testing methodologies to enable Penumbra to extend the shelf life as additional data becomes available. Upon successful completion of the protocol, Penumbra will maintain a 36-month shelf life for the product.

Penumbra Apollo™ System disposable wands and tubing used in the shelf life studies were produced according to approved production procedures. Acceptance criteria were based on the sterile finished goods testing requirements. All devices used in the shelf-life studies completed 2x sterilization processes prior to test initiation. Packaging materials (both primary and secondary) were tested to validate their properties over the intended shelf life.

1.10.5 Summary of Substantial Equivalence

The Apollo™ System components are substantially equivalent to the predicate devices with regard to intended use, operating principle, design concept, materials, shelf-life, packaging and sterilization processes.

EN ISO 11135: 2007 Sterilization of health care products -- Ethylene oxide -- Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices

8

Image /page/8/Picture/0 description: The image shows the seal for the Department of Health & Human Services USA. The seal is circular with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. In the center of the seal is an abstract image of an eagle.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

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

January 17, 2014

Penumbra, Inc. % Mr. Seth A. Schulman Director, Regulatory Affairs 1351 Harbor Bay Parkway Alameda, CA 94502

Re: K132931

Trade/Device Name: Penumbra Apollo™ System Regulation Number: 21 CFR 882.1480 Regulation Name: Neurological Endoscope Regulatory Class: Class II Product Code: GWG Dated: December 13, 2013 Received: December 18, 2013

Dear Mr. Schulman:

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

9

Page 2 - Mr. Seth A. Schulman

,……

forth in the quality systems (OS) 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 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/ResourcesforYou/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/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 vours.

Joyce M. Whang -S

for Carlos L. Peña, Ph.D., M.S. . Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

10

Indications for Use

510(k) Number (if known): K132931

Device Name: Penumbra Apollo™ System

Indications For Use:

The Apollo™ System is used for the controlled aspiration of tissue and/or fluids during surgery of the Ventricular System. The Apollo™ disposable wand is inserted through the working channel of a neuroendoscopic trocar.

V Prescription Use _ (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 Center for Devices and Radiological Health (CDRH)

Joyce M. Whang -S

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