K Number
K140382
Device Name
AEROMINI TRACHEOBRONCHIAL STENT TECHNOLOGY
Date Cleared
2014-11-25

(284 days)

Product Code
Regulation Number
878.3720
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The MERIT ENDOTEK AEROmini Tracheobronchial Stent System is indicated for use in the treatment of tracheobronchial strictures produced by malignant neoplasms.
Device Description
The MERIT ENDOTEK AEROmini Tracheobronchial Stent System is comprised of two components: the radiopaque self-expanding nitinol stent and the delivery system. The stent is completely covered with a biocompatible polyurethane membrane. The stent expansion results from the physical properties of the metal and the proprietary geometry. The overall stent geometry is designed to maintain a constant length over the entire range of possible diameters. As a result of this unique design the stent has virtually no foreshortening, thus facilitating the selection of the appropriate stent length. The stent is deployed endoscopically with a dedicated delivery system with or without the aid of fluoroscopic imaging. The delivery system consists of two coaxial sheaths. The exterior sheath serves to constrain the stent until the sheath is retracted during deployment. The stent remains constrained by the delivery system until the trigger is pulled beyond the white deployment threshold mark located between the trigger and hand grip. This feature allows for repositioning of the stent proximally. In addition, the procedure can be aborted and the entire system can be withdrawn en bloc at any time before the trigger is pulled beyond the white deployment threshold mark located between the trigger and hand grip. A radiopaque tip and marker on the inner shaft aid the operator in determining stent position in relation to the deployment threshold mark, where repositioning or en bloc withdrawal is no longer possible. The inner sheath of the delivery system contains a central lumen that will accommodate a 0.035" guide wire. This feature is designed to allow guidance of the delivery system to the intended implant site while minimizing the risk of airway injury from the delivery system tip.
More Information

Not Found

No
The device description focuses on the mechanical properties of the stent and delivery system. There is no mention of AI, ML, or image processing for analysis or decision-making. The performance studies are based on standard mechanical and biocompatibility testing.

Yes
The device is a stent system used for the treatment of tracheobronchial strictures caused by malignant neoplasms, which is a therapeutic purpose.

No

The device is a stent system used for the treatment of tracheobronchial strictures, which is a therapeutic function, not a diagnostic one.

No

The device description clearly states it is comprised of a physical stent and a delivery system, which are hardware components.

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

Here's why:

  • Intended Use: The intended use is the "treatment of tracheobronchial strictures produced by malignant neoplasms." This describes a therapeutic intervention performed directly on the patient's body.
  • Device Description: The device is a "Tracheobronchial Stent System" which is a physical implant designed to open up narrowed airways.
  • Mechanism of Action: The device works by physically expanding within the airway to maintain patency.
  • Lack of In Vitro Testing: The description of the device and its use does not involve testing samples (like blood, urine, or tissue) outside of the body to diagnose a condition.

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 device used for treatment within the body.

N/A

Intended Use / Indications for Use

The MERIT ENDOTEK AEROmini Tracheobronchial Stent System is indicated for use in the treatment of tracheobronchial strictures produced by malignant neoplasms.

Product codes

JCT

Device Description

The MERIT ENDOTEK AEROmini Tracheobronchial Stent System is comprised of two components: the radiopaque self-expanding nitinol stent and the delivery system. The stent is completely covered with a biocompatible polyurethane membrane. The stent expansion results from the physical properties of the metal and the proprietary geometry. The overall stent geometry is designed to maintain a constant length over the entire range of possible diameters. As a result of this unique design the stent has virtually no foreshortening, thus facilitating the selection of the appropriate stent length. The stent is deployed endoscopically with a dedicated delivery system with or without the aid of fluoroscopic imaging. The delivery system consists of two coaxial sheaths. The exterior sheath serves to constrain the stent until the sheath is retracted during deployment. The stent remains constrained by the delivery system until the trigger is pulled beyond the white deployment threshold mark located between the trigger and hand grip. This feature allows for repositioning of the stent proximally. In addition, the procedure can be aborted and the entire system can be withdrawn en bloc at any time before the trigger is pulled beyond the white deployment threshold mark located between the trigger and hand grip. A radiopaque tip and marker on the inner shaft aid the operator in determining stent position in relation to the deployment threshold mark, where repositioning or en bloc withdrawal is no longer possible. The inner sheath of the delivery system contains a central lumen that will accommodate a 0.035" guide wire. This feature is designed to allow guidance of the delivery system to the intended implant site while minimizing the risk of airway injury from the delivery system tip.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

fluoroscopic imaging

Anatomical Site

Tracheobronchial

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

A battery of tests was performed based on the requirements of the below recognized performance standards and guidance, as well as biocompatibility, sterilization, and labeling standards and guidance. Conformity to these standards demonstrates that the proposed AEROmini met the standards' established acceptance criteria applicable to the substantial equivalence of the device.

Performance testing was conducted based on the risk analysis and based on the requirements of the following documents:
Guidance for Industry: Guidance for the Content of Premarket Notifications for Esophageal and Tracheal Prostheses (Issued April 28, 1998)
ISO 11135-1:2007, Sterilization of health care products - routine control of a sterilization process for medical devices
ASTM D4169 - 09 Standard Practice for Performance Testing of Shipping Containers and Systems
ASTM F2052-06e1:2006 Measurement of Magnetically Induced Displacement Force on Medical Devices in the MR Environment
ASTM F2119-07:2013, Standard Test Method for Evaluation of MR Image Artifacts from Passive Implants
ASTM F2182-09:2011, Standard Test Method for Measurement of Radio Frequency Induced Heating Near Passive Implants During MR Imaqinq
ASTM F2213-06:2011, Method for Measurement of Maqnetically Induced Torque on Medical Devices in MR Environment
ASTM F2503-08:2013 Marking Medical Devices and Other Items for Safety in the Magnetic Resonance Environment
ISO 10993-1:2009, Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing within a risk management process, and FDA guidance Required Biocompatibility Training and Toxicology Profiles for Evaluation of Medical Devices, May 1, 1995
ISO 10993-10:2010. Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization
ISO 10993-17:2002, Biological evaluation of medical devices - Part 17: Methods for the establishment of allowable limits
ISO 10993-18:2005, Biological evaluation of medical devices – Part 18: Chemical characterization of materials
ISO 10993-5:2009, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
ISO 10993-6. 2007. Biological Evaluation of Medical Devices - Part 6: Tests for Local Effects After Implantation
ISO 10993-7:2008, Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide Sterilization Residuals
ISO11607-1: 2006, Packaging for terminally sterilized medical devices
United States Pharmacopeia 36, National Formulary 31, 2013. Pyrogen Test
ISO 2233: 2000, Packaging - Complete, filled transport packages and unit loads - Conditioning for testing

The following tests were successfully conducted as per FDA Guidance for the Content of Premarket Notifications for Esophageal and Tracheal Prosthesis, April 28, 1998:
Deployment Testing. Expansion Force Testing. Compression Force Testing. Dimensional Testing. Tensile Strength Tests.

The following list details significant testing that was successfully completed:
Guide Wire Compatibility
Delivery Device Working Lenath
Delivery Device Stent Pod OD
Delivery Device Shaft OD
Trigger Stroke
Insertion Force
Distal Tip Insertion & Flexibility/Kink Resistance
Performance Repositioning Tests cont.
Delivery System Deployment Accuracy
Stent Expansion & Condition After Deployment
System Integrity
Stent Foreshortening
Removal Migration & Removal Force
AM-Strut Height
Suture Purse String Suture
Tensile Stent Tensile
Stent Fatique
Cover Integrity After Fatigue
Coating Integrity After Fatique
Stent Spring Back After Fatique
Compression Force After Fatigue
Expansion Force After Fatique
Trigger Safety
Delivery System Tensile Strength Tests
Fluoroscopic Visibility of Deployment Catheter
Endoscopic Visibility of Deployment Catheter
Atraumatic Tip
MR Compatibility
Biocompatibility
Cytotoxicity
Sensitization
Implantation
Irritation
Material Mediated Pyrogenicity
Chemical Characterization
Performance Packaging Performance Tests cont.
Seal Peel Strength
Visual Inspection
Bubble Emission

The results of the testing demonstrated that the subject AEROmini met the predetermined acceptance criteria applicable to the substantial equivalence of the device.

Key Metrics

Not Found

Predicate Device(s)

K082284

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.3720 Tracheal prosthesis.

(a)
Identification. The tracheal prosthesis is a rigid, flexible, or expandable tubular device made of a silicone, metal, or polymeric material that is intended to be implanted to restore the structure and/or function of the trachea or trachealbronchial tree. It may be unbranched or contain one or two branches. The metal tracheal prosthesis may be uncovered or covered with a polymeric material. This device may also include a device delivery system.(b)
Classification. Class II. The special control for this device is FDA's “Guidance for the Content of Premarket Notification Submissions for Esophageal and Tracheal Prostheses.”

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes entwined around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus symbol. The logo is black and white.

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

November 25, 2014

Merit Medical Systems, Inc. Dan Lindsay, RAC Senior Regulatory Affairs Specialist 1600 West Merit Parkway South Jordan, UT 84095

Re: K140382

Trade/Device Name: AEROmini™ Tracheobronchial Stent System Regulation Number: 878.3720 Regulation Name: Tracheal Prosthesis Regulatory Class: Class II Product Code: JCT Dated: October 24, 2014 Received: October 27, 2014

Dear Mr. Lindsay,

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.

1

Page 2 - Mr. Lindsay

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.

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/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,

Teiashri Purohit-Sheth, M.D.

Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR

Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

4.0 Indications for Use

510(k) Number (if known): K140382

Device Name:

AEROmini™ Tracheobronchial Stent System

Indications for Use:

The MERIT ENDOTEK AEROmini Tracheobronchial Stent System is indicated for use in the treatment of tracheobronchial strictures produced by malignant neoplasms.

Prescription UseX
---------------------

AND/OR

Over-The-Counter Use
------------------------

(Part 21 CFR 801 Subpart D)

(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)

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| General

ProvisionsCorrespondent Name:Merit Medical Systems, Inc.
Address:1600 West Merit Parkway
South Jordan, UT 84095
Telephone Number:801-208-4408
Fax Number:801-253-6945
Contact Person:Dan W. Lindsay
Date of Preparation:June 3, 2014
Registration Number:1721504
Subject DeviceTrade Name:AEROmini™
Common/Usual Name:Tracheobronchial Stent
Classification Name:Tracheal Prosthesis
Predicate
DeviceTrade Name:AERO™ Tracheobronchial Stent Technology
System
Classification Name:Tracheal Prosthesis
Premarket Notification:K082284
Manufacturer:Merit Medical Systems, Inc.
ClassificationClass II
21 CFR § 878.3720
FDA Product Code: JCT
Review Panel: General and Plastic Surgery
Intended UseThe Merit ENDOTEK AEROmini™ Tracheobronchial Stent System is
indicated for use in the treatment of tracheobronchial strictures
produced by malignant neoplasms.
Device
DescriptionThe MERIT ENDOTEK AEROmini Tracheobronchial Stent System is
comprised of two components: the radiopaque self-expanding nitinol
stent and the delivery system. The stent is completely covered with a
biocompatible polyurethane membrane. The stent expansion results
from the physical properties of the metal and the proprietary geometry.
The overall stent geometry is designed to maintain a constant length
over the entire range of possible diameters. As a result of this unique
design the stent has virtually no foreshortening, thus facilitating the
selection of the appropriate stent length. The stent is deployed
endoscopically with a dedicated delivery system with or without the aid
of fluoroscopic imaging. The delivery system consists of two coaxial
sheaths. The exterior sheath serves to constrain the stent until the
sheath is retracted during deployment. The stent remains constrained
by the delivery system until the trigger is pulled beyond the white
deployment threshold mark located between the trigger and hand grip.
This feature allows for repositioning of the stent proximally. In addition,
the procedure can be aborted and the entire system can be withdrawn
en bloc at any time before the trigger is pulled beyond the white
deployment threshold mark located between the trigger and hand grip.
A radiopaque tip and marker on the inner shaft aid the operator in
determining stent position in relation to the deployment threshold mark,
where repositioning or en bloc withdrawal is no longer possible. The
inner sheath of the delivery system contains a central lumen that will
accommodate a 0.035" guide wire. This feature is designed to allow
guidance of the delivery system to the intended implant site while
minimizing the risk of airway injury from the delivery system tip.
Comparison to
Predicate
DeviceThe AEROmini is similar in design to the AERO Tracheobronchial Stent
Technology System. Both stents are fabricated as a single, integral
framework by laser-cutting a nitinol tube. A polyurethane polymer
cover is then applied and a hydrophilic coating is added to the inner
diameter surface of the stent. The subject and predicate devices are
preloaded on a flexible one-handed delivery system.
The AEROmini is offered in 5 new sizes with diameters as small as
8mm and lengths as short as 15mm. Other stent modifications include:
changes to the stent flares, anti-migration struts, new proximal stent
end suture eyelets. Changes to the delivery system include: material
changes, smaller profile diameter, tapered tip, new trigger safety, and
design changes intended to improve ergonomics. The AEROmini will
be provided sterile while the predicate was not.

4

5

FDA quidance and recognized performance standards have been established for Tracheal Prosthesis under Section 514 of the Food, Drug and Cosmetic Act. A battery of tests was performed based on the requirements of the below recognized performance standards and guidance, as well as biocompatibility, sterilization, and labeling standards and guidance. Conformity to these standards demonstrates that the proposed AEROmini met the standards' established acceptance criteria applicable to the substantial equivalence of the device. Performance testing was conducted based on the risk analysis and based on the requirements of the following documents:

The following tests were successfully conducted as per FDA Guidance for the Content of Premarket Notifications for Esophageal and Tracheal Prosthesis, April 28, 1998:

Deployment Testing. Expansion Force Testing. Compression Force Testing. Dimensional Testing. Tensile Strength Tests.

Performance

Tests

Guidance for Industry: Guidance for the Content of Premarket Notifications for Esophageal and Tracheal Prostheses (Issued April 28, 1998)

ISO 11135-1:2007, Sterilization of health care products - routine control of a sterilization process for medical devices ASTM D4169 - 09 Standard Practice for Performance Testing of

Shipping Containers and Systems ASTM F2052-06e1:2006 Measurement of Magnetically Induced Displacement Force on Medical Devices in the MR Environment ASTM F2119-07:2013, Standard Test Method for Evaluation of MR Image Artifacts from Passive Implants

ASTM F2182-09:2011, Standard Test Method for Measurement of Radio Frequency Induced Heating Near Passive Implants During MR Imaqinq

ASTM F2213-06:2011, Method for Measurement of Maqnetically Induced Torque on Medical Devices in MR Environment ASTM F2503-08:2013 Marking Medical Devices and Other Items for

Safety in the Magnetic Resonance Environment ISO 10993-1:2009, Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing within a risk management process, and FDA guidance Required Biocompatibility Training and Toxicology Profiles for

Evaluation of Medical Devices, May 1, 1995

ISO 10993-10:2010. Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization

ISO 10993-17:2002, Biological evaluation of medical devices - Part 17: Methods for the establishment of allowable limits

ISO 10993-18:2005, Biological evaluation of medical devices – Part 18: Chemical characterization of materials

ISO 10993-5:2009, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity

6

ISO 10993-6. 2007. Biological Evaluation of Medical Devices - Part 6: Tests for Local Effects After Implantation ISO 10993-7:2008, Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide Sterilization Residuals ISO11607-1: 2006, Packaging for terminally sterilized medical devices United States Pharmacopeia 36, National Formulary 31, 2013. Pyrogen Test ISO 2233: 2000, Packaging - Complete, filled transport packages and unit loads - Conditioning for testing The following list details significant testing that was successfully completed: Guide Wire Compatibility Delivery Device Working Lenath Delivery Device Stent Pod OD Delivery Device Shaft OD Trigger Stroke Insertion Force Distal Tip Insertion & Flexibility/Kink Resistance Performance Repositioning Tests cont. Delivery System Deployment Accuracy Stent Expansion & Condition After Deployment System Integrity Stent Foreshortening Removal Migration & Removal Force AM-Strut Height Suture Purse String Suture Tensile Stent Tensile Stent Fatique Cover Integrity After Fatigue Coating Integrity After Fatique Stent Spring Back After Fatique Compression Force After Fatigue Expansion Force After Fatique Trigger Safety Delivery System Tensile Strength Tests Fluoroscopic Visibility of Deployment Catheter Endoscopic Visibility of Deployment Catheter Atraumatic Tip MR Compatibility Biocompatibility Cytotoxicity Sensitization Implantation Irritation Material Mediated Pyrogenicity Chemical Characterization

7

Performance Packaging Performance Tests cont. Seal Peel Strength Visual Inspection Bubble Emission The results of the testing demonstrated that the subject AEROmini met the predetermined acceptance criteria applicable to the substantial equivalence of the device. Based on the indications for use, design, and performance testing, the Summary of subject AEROmini meets the requirements that are considered Substantial essential for its intended use and is substantially equivalent to the Equivalence predicate device, the AERO Tracheobronchial Stent Technology System, K082284.