K Number
K133282
Device Name
REVERSE MEDICAL MICRO VASCULAR PLUG (MVP) SYSTEM
Date Cleared
2013-11-27

(33 days)

Product Code
Regulation Number
870.3300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Reverse Medical Micro Vascular Plug (MVP-5) 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 (0.027" 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 3.0 -5.0mm. The proximal marker band attaches to a delivery wire that pushes the device 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 the mechanical and electrical components of a vascular plug system and does not mention any AI or ML capabilities. The "Mentions AI, DNN, or ML" field is also explicitly marked as "Not Found".

Yes.
The device is intended to obstruct or reduce the rate of blood flow, which is a therapeutic intervention.

No

This device is an embolic plug designed to obstruct blood flow, which is a therapeutic intervention, not a diagnostic one.

No

The device description clearly outlines multiple hardware components including the embolic plug, delivery wire, detachment box, cable set, battery, and needle.

No, 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 is a therapeutic intervention performed within the body (in vivo).
  • Device Description: The device is a physical plug designed to be implanted in blood vessels. This is a medical device used for treatment, not for analyzing samples taken from the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), performing tests on these samples, or providing diagnostic information based on such analysis.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device is a therapeutic implant.

N/A

Intended Use / Indications for Use

The Reverse Medical MVP 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 (0.027" 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 3.0 -5.0mm.

The proximal marker band attaches to a delivery wire that pushes the device 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)

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, Kligman Maximization Sensitization Test, Intracutaneous Injection, Systemic Injection, Material-Mediated Pyrogenicity, Genotoxicity/Mutagenicity (In Vitro Mouse Lymphoma Assay, In Vivo Mouse Lymphoma), Hemolysis, Complement Activation C3a and SC5ba-9, Inactivated Partial Thromboplastin Time, Platelet and Leukocyte Counts, Muscle Implantation.
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.

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.

K123803

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

K13282

Image /page/0/Picture/1 description: The image shows the words "KEVERSE MEDICAL" in bold, black letters. Underneath the words is a curved line that ends with an arrow pointing upwards. The arrow is also black and bold.

  • NOV 2 7 2013

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 (MVP-5).

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 October 25, 2013

Device Common/Usual or Classification Name

Device Embolization, Vascular (Product Code: KRD)

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

Name of Predicate DeviceManufacturer510(k) Number
Reverse Medical MVP™Reverse Medical™K123803
Micro Vascular Plug
System (MVP-3)Corporation
Irvine, CA

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 (0.027" 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 3.0 -5.0mm.

The proximal marker band attaches to a delivery wire that pushes the device 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

1

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 Device | Predicate
Device |
|-------------------------------|--------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|
| | Reverse Medical
MVP-5 System | Reverse Medical
MVP-3 System |
| 510(k) No. | K123803 Class II
KRD 870:3300 | K123803 Class II
KRD 870:3300 |
| Indication for
use | Indicated for use to
obstruct or reduce
the rate of blood
flow in the
peripheral
vasculature. | Indicated for use to
obstruct or reduce
the rate of blood
flow in the
peripheral
vasculature. |
| Method of
Placement | Delivery wire
through a 0.027" ID
microcatheter. | Delivery wire
through a 0.021" ID
microcatheter. |
| Radiopaque
markers | Platinum marker
bands at each end | Platinum marker
bands at each end |
| Proximal End
Configuration | Proximal marker
band and
attachment for
pusher wire | Proximal marker
band and
attachment for pusher
wire |
| Detachment
System | Yes - Electrolytic | Yes - Electrolytic |
| Battery
Operated | Yes | Yes |

Comparison to Predicate Device

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:

2

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 Leukocyte 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:

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

3

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-5 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-5 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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles a human figure embracing another, possibly representing care or support.

Public Health Service

November 27, 2013

Food and Drug Administration 0903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring MD 20993-0002

Reverse Medical Corporation C/O Jeffrey Valko. President & CEO 13700 Alton Parkway, Suite 167 Irvine, CA 92618

Re: K133282

Trade/Device Name: Reverse Medical Micro Vascular Plug (MVP-5) System Regulation Number: 21 CFR 870.3300 Regulation Name: Vascular Embolization Device Regulatory Class: Class II Product Code: KRD Dated: October 25, 2013 Received: October 28, 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. Iisting 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 (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.

5

Page 2 - Mr. Jeffrey Valko


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/ResourcesforYou/Industry/default.htm.

Sincerely yours,

M.A. Hilleman

for

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

Enclosure

6

Reverse Medical Corporation Special 510(k): Device Modification

.

Attachment 2: Indication for Use Statement

510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________

・・・・・・・・・・・・

Device Name: Reverse Medical Micro Vascular Plug (MVP-5)

Indication for Use:

The Reverse Medical Micro Vascular Plug (MVP-5) 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)

M.A. Hillemann