(66 days)
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
The Modified Trevo ProVue Retriever consists of a flexible, tapered core with a shaped section at the distal end. It is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. A radiopaque coil at the distal end allows fluoroscopic visualization. The shaped section is also radiopaque. Retriever dimensions are indicated on the product label. The Retriever has a hydrophilic coating to reduce friction during use. A torque device and an insertion tool are provided with the Retriever. The proximal end of the device is compatible with the Abbott guide wire extension to facilitate removal or exchange of a catheter while maintaining the Retriever position in the vessel.
The provided document describes the Modified Trevo ProVue Retriever, a device intended to restore blood flow in the neurovasculature for ischemic stroke patients. The submission primarily focuses on demonstrating substantial equivalence to a predicate device (Cleared Trevo ProVue Retriever, K122478) based on design, materials, and function, with a specific modification to the platinum wire weave.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance:
| Acceptance Criteria (Implicit from Testing) | Reported Device Performance |
|---|---|
| Maintain deliverability | All samples passed |
| Maintain deployment capability | All samples passed |
| Maintain reloadability | All samples passed |
| No new failure modes introduced | No new failure modes detected |
| No changes to existing failure modes | No changes to existing failure modes |
| Perform as designed | Device performs as designed |
| Suitable for intended use | Device is suitable for its intended use |
| Substantially equivalent to predicate device | Demonstrated as substantially equivalent |
2. Sample size used for the test set and the data provenance:
- Sample Size: The document does not specify the exact number of Modified Trevo ProVue Retriever samples tested. It states "All samples passed the acceptance criteria."
- Data Provenance: The testing was conducted as bench testing using a silicone neurovascular model cast from actual human neurovascular arteries. This is a retrospective approach in terms of model derivation, but the testing itself is prospective for the device being evaluated. The 'country of origin' of the data is not explicitly stated, but it's part of a submission to the US FDA by a US-based company (Concentric Medical, Inc. in Mountain View, CA).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not provided in the document. The "ground truth" for this type of bench testing is typically the physical and functional characteristics of the device itself and its interaction with the simulated environment, rather than expert interpretation of images or clinical outcomes. The "success" or "failure" of deliverability, deployment, and reloadability would be directly observed and measured against pre-defined engineering specifications.
4. Adjudication method for the test set:
- An adjudication method is not applicable or mentioned. This was a bench test evaluating physical performance, not a study requiring human interpretation or consensus for outcomes.
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:
- No MRMC study was conducted. This device is a mechanical thrombectomy device, not an AI-assisted diagnostic or therapeutic tool for which an MRMC study would be relevant.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- This question is not applicable as the device is a mechanical thrombectomy device, not an algorithm or AI system.
7. The type of ground truth used:
- The ground truth for this bench testing was based on engineering specifications and observable physical performance criteria (e.g., successful navigation, deployment, and retrieval within a simulated anatomical model without device failure). It involved assessing whether the device met its design requirements for deliverability, deployment, and reloadability.
8. The sample size for the training set:
- This question is not applicable. There is no training set mentioned, as this is bench testing of a medical device, not a machine learning model.
9. How the ground truth for the training set was established:
- This question is not applicable as there is no training set involved.
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JAN 17 2014
510(k) Summary
| Trade Name: | Modified Trevo ProVue Retriever | |
|---|---|---|
| Common Name: | Catheter, Thrombus Retriever | |
| Classification Name: | Thrombus Retriever, 21CFR 870.1250 Class II | |
| Product Code: | NRY | |
| Submitter: | Concentric Medical, Inc.301 E. Evelyn AvenueMountain View, CA 94041Tel 510-413-2681Fax 510-413-2558Facility Registration #2954917 | |
| Contact: | Sarah MeyerSenior Regulatory Affairs Specialist | |
| Date Prepared: | December 13, 2013 | |
| Predicate Device: | Concentric Trevo ProVue Retriever (K122478) | |
| Feature | Cleared Trevo ProVue Retriever(K122478) | Modified TrevoProVue Retriever |
| Indications for Use | The Trevo ProVue Retriever is intended to restoreblood flow in the neurovasculature by removingthrombus in patients experiencing ischemic strokewithin 8 hours of symptom onset. Patients who areineligible for intravenous tissue plasminogenactivator (IV t-PA) or who fail IV t-PA therapy arecandidates for treatment. | Same as cleareddevice |
| Device Description | The Retriever consists of a flexible, tapered corewire with a shaped section at the distal end. Aplatinum coil allows fluoroscopic visualization. Inaddition, the shaped section is also radiopaque. TheRetriever has a hydrophilic coating to reduce friction.The Retriever has a shaft marker to indicateproximity of Retriever tip relative to Microcatheter tip.A torque device and insertion tool are provided withthe Retriever. | Same as cleareddevice |
| Target Population | Patients with symptoms of an ischemic stroke | Same as cleareddevice |
| Anatomical Sites | Neurovasculature | Same as cleareddevice |
| Accessory DevicesProvided(not in direct contactwith patient) | Insertion tool and torque device provided in productpackage | Same as cleareddevice |
| Regulation Number | 21CFR 870.1250 | Same as cleareddevice |
| Regulation Name | Catheter, Thrombus Retriever | Same as cleareddevice |
| Regulatory Class | II | Same as cleareddevice |
| Product Code | NRY | Same as cleareddevice |
| Core Wire Material | Nitinol (nickel titanium alloy) | Same as cleareddevice |
| Distal ShapedSection Material | Nitinol | Same as cleareddevice |
| Feature | Cleared Trevo ProVue Retriever(K122478) | Modified TrevoProVue Retriever |
| Coil Material Distalto Distal ShapedSection | Platinum/Tungsten | Same as cleareddevice |
| Shaped SectionRadiopaque Wire | Platinum/Tungsten | Same as cleareddevice |
| Coil MaterialProximal toShaped Section | 304 Stainless Steel | Same as cleareddevice |
| Solder | Gold/Tin | Same as cleareddevice |
| Hydrophilic Coating | Sodium hyaluronate mixture | Same as cleareddevice |
| Nominal Design Attributes | ||
| Overall Length | 180 cm | Same as cleareddevice |
| Total ShapedSection Length(nominal) | 37 mm | Same as cleareddevice |
| Active ShapedSectionLength (nominal) | 20 mm | Same as cleareddevice |
| Distal Tip Length(nominal) | 4 mm | Same as cleareddevice |
| Proximal Core WireDiameter | 0.0180" | Same as cleareddevice |
| Shaped SectionDiameter (nominal) | 4 mm | Same as cleareddevice |
| Distal TaperLength (nominal) | 10 mm | Same as cleareddevice |
| Packaging | ||
| Materials andConfiguration | Polyethylene Hoop, polycarbonate mounting card,Tyvek/Film Pouch, HDPE Tubing Clips, Chipboardcarton | Same as cleareddevice |
| SterilizationMethod | 100% EtO | Same as cleareddevice |
| How Supplied | Sterile/Single Use | Same as cleareddevice |
Device Description
The Modified Trevo ProVue Retriever consists of a flexible, tapered core with a shaped section at the distal end. It is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. A radiopaque coil at the distal end allows fluoroscopic visualization. The shaped section is also radiopaque. Retriever dimensions are indicated on the product label. The Retriever has a hydrophilic coating to reduce friction during use. A torque device and an insertion tool are provided with the Retriever. The proximal end of the device is compatible with the Abbott guide wire extension to facilitate removal or exchange of a catheter while maintaining the Retriever position in the vessel.
Indications for Use
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
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Technological Characteristics and Product Feature Comparison
The Modified Trevo ProVue Retriever with a modified platinum wire weave is substantially equivalent to the predicate device in terms of design, materials used, and function. A comparison of the subject device with predicate device is summarized in the below table.
Comparison of Cleared Trevo ProVue Retriever to the Modified Trevo ProVue Retriever
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Risk Assessment
Risk assessment of the modifications has been conducted in accordance with EN ISO 14971:2012. Concentric Medical, Inc. has determined the modifications to the predicate device raise no new questions of safety or effectiveness.
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Results of testing have demonstrated the Modified Trevo ProVue Retriever is substantially equivalent to the predicate device. Furthermore, the modifications did not result in any new failure modes nor were there any changes to existing failure modes.
Testing Summary
The results of testing conducted on the Modified Trevo ProVue Retriever demonstrate that it performs as designed, is suitable for its intended use and is substantially equivalent to the predicate device. Specifically, the following tests were performed on the proposed device:
| Test | Test Method Summary | Results |
|---|---|---|
| SimulatedUse --Deliverability,Deployment,andReloadability | Simulated use testing used asilicone neurovascular modelcast from actual humanneurovascular arteries. Thisbench testing model replicatesthe tortuosity, diameter andlocation of the arteries in theneurovasculature including theinternal carotid artery (ICA)siphon. The model ends at themid carotid arteries and proximalsupport is provided by a guidecatheter. The modelincorporates a re-circulatingwater bath at 37°C pressurizedbetween 2 - 2.5 psi (100 - 126mm Hg) to simulate the humanarterial circulation. All testingfollows the proceduralinstructions outlined in theInstructions for Use. Simulatedthrombus is used to assess thedevices ability to retrieve clot | All samples passed theacceptance criteria.Device continues to meetsame design requirementsas predicate deviceK122478. |
In summary, the results of simulated testing for deliverability, deployment, and reloadability that were conducted on the Modified Trevo ProVue Retriever demonstrate that the proposed device is as safe, as effective, and performs as well as or better than the legally marketed predicate device.
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Summary of Substantial Equivalence
The Modified Trevo ProVue Retriever is substantially equivalent to the predicate device with regard to device design, materials, intended use, and patient population. The conclusions drawn from risk assessments and the testing conducted using the Modified Trevo ProVue Retriever demonstrate that the device performs as designed, is suitable for its intended use and is substantially equivalent to the legally marketed predicate device.
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Image /page/5/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized depiction of an eagle or bird-like figure with three curved lines representing its wings or body. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the emblem.
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
Concentric Medical % Ms. Sarah Meyer Senior Regulatory Affairs Specialist 301 East Evelyn Ave. Mountain View, CA 94041
Re: K133464
Trade/Device Name: Trevo ProVue Retriever Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: December 18, 2013 Received: December 19, 2013
Dear Ms. Meyer:
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
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Page 2 - Ms. Sarah Meyer
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 yours,
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
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Indications for Use
510(k) Number (if known): K133464
Device Name: Trevo ProVue Retriever
Indications For Use:
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
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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§ 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).