AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

CODMAN Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae, and is also intended for arterial and venous embolizations in the peripheral vasculature.

The DELTAMAXX Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Fill ORBIT GALAXY G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Xtrasoft ORBIT GALAXY G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms.

Device Description

The CODMAN® Microcoil Delivery System, DELTAMAXX Microcoil Delivery System, and ORBIT GALAXY® G2 Microcoil Delivery System consist of three components, a Microcoil System, a connecting cable, and a Detachment Control Box (DCB). Each component is sold separately. As shown in Figure 1, the Microcoil System consists of an microcoil attached to a Device Positioning Unit (DPU).

The Microcoil System is packaged in an introducer sheath designed to protect the coil in the packaging dispenser and to provide support for introducing the coil into the infusion catheter. The microcoil is the implantable segment of the device, and is detached from the Device Positioning Unit (DPU) using the Detachment Control System (Detachment Control Box and connecting cable).

The microcoil is fabricated from a platinum alloy wire. The wire is wound into a primary coil which may contain either a polypropylene suture (SR) or an absorbable polymer suture (Cerecyte®) and then formed into a secondary shape. The secondary shape may be straight, spherical, complex, or helical. The DPU is a variable stiffness wire and has a radiopaque marker band located three (3) cm from its distal end. The introducer sheath has three main components: an introducer tip, a translucent introducer body, and a re-sheathing tool.
The Detachment Control Box (DCB) provides the energy necessary to allow for a thermo-mechanical detachment of the microcoil from the DPU. The connecting cable delivers the energy necessary to detach the embolic coil from the Microcoil System's detachment zone. The connecting cable is connected between the Microcoil System's hub connector on the DPU and the output connector on the DCB.

The detachment control box may be one of two types: the blue EnPower Detachment Control Box or the black Detachment Control Box.
The connecting cables may be one of two types: one with a remote detach button (the EnPower Control Cable) catalog no. ECB000182-00, or one without a detach button (standard connecting cable) catalog no. CCB00157-00.
The EnPower Detachment Control Box works with the EnPower Control Cable and with the standard connecting cable. The black Detachment Control Box works only with the standard connecting cable. Both cables and Detachment Control Box are sold separately.

AI/ML Overview

The provided document is a 510(k) premarket notification for a medical device focusing on a packaging change. It does not contain information about the performance of the neurovascular embolization devices themselves, but rather the performance of the packaging.

Here's an analysis based on the provided text regarding the packaging acceptance criteria and study:

1. Table of Acceptance Criteria and Reported Device Performance (Packaging):

Acceptance Criteria CategorySpecific Test/EvaluationReported Device Performance (Packaging)
Packaging IntegrityVisual Inspection (after sterilization, handling, distribution)Sterile barrier system maintains packaging integrity; inspected seals were complete and uniform throughout the entire seal area of the proposed pouch for each time interval (accelerated and real-time aging).
Dye LeakPackaging integrity maintained.
Seal StrengthNo detected negative trends in seal strength; seals maintain their strength over time.
Product Functional Testing (on EnPower Control Cable)Implied successful, as the overall conclusion states the packaging does not raise new questions of safety and effectiveness, and the packaging modifications were validated. (Specific functional results are not detailed, but implied to be acceptable within packaging context)
Characterization Testing: Moisture and Humidity CreepImplied successful (no negative findings reported).
Sterile Pouch Shelf-LifeVisual InspectionProposed pouch's integrity was maintained; inspected seals were complete and uniform throughout the entire seal area for all time intervals (time-zero, 1yr, 3yr, 5yr, 10yr accelerated, and time-zero, 1yr, 3yr real-time).
Seal StrengthNo detected negative trends in seal strength; seals maintain their strength over time. Testing confirmed the device will remain sterile through the proposed shelf life and integrity of its packaging are not compromised.
SterilizationBioburden measurementMet acceptance criteria for representative products as packaged in the new pouch.
Identification of top three organismsSpecific results not detailed, but met acceptance criteria.
Bacteriostasis/Fungistasis (B/F)Specific results not detailed, but met acceptance criteria.
Bioburden recovery study (Extraction efficiency)Specific results not detailed, but met acceptance criteria.

2. Sample Size Used for the Test Set and Data Provenance:

  • Test Set Sample Size: The document does not explicitly state the specific number of units or pouches tested for each packaging integrity and shelf-life test. It mentions testing "representative products" and "each time interval" for shelf-life, implying multiple samples were used.
  • Data Provenance: The studies were conducted internally by Codman & Shurtleff, Inc. This is a retrospective analysis of the modified packaging, comparing it to the predicate device's packaging characteristics and ensuring the new packaging maintains similar performance.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

  • Not Applicable. For packaging integrity and sterilization validation, "ground truth" is established through standardized physical, chemical, and microbiological testing methods (e.g., visual inspection, seal strength measurement, dye leak tests, bioburden assays) and comparison against pre-defined engineering and regulatory specifications, rather than expert consensus on a clinical outcome.

4. Adjudication Method for the Test Set:

  • Not Applicable. As the tests are objective physical and microbiological measurements of packaging performance, an adjudication method for conflicting expert opinions is not relevant. The results would be interpreted against established acceptance criteria for each test.

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. This is a packaging modification submission for an existing neurovascular embolization device. It does not involve AI, image analysis, or human readers.

6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done:

  • No. This submission is about medical device packaging, not an algorithm.

7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.):

  • For the packaging validation, the "ground truth" is defined by established engineering standards, regulatory guidelines (e.g., ISO 11137 for sterilization), and predefined acceptance criteria for physical (e.g., seal strength, visual integrity) and microbiological (e.g., bioburden levels) properties of the sterile barrier system.

8. The Sample Size for the Training Set:

  • Not Applicable. This is not an AI/machine learning device; therefore, there is no "training set."

9. How the Ground Truth for the Training Set was Established:

  • Not Applicable. As there is no training set.

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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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with a design element resembling a wing or a flowing fabric above them.

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

December 24, 2014

Codman & Shurtleff, Inc. Ms. Hannah Foley Regulatory Affairs Specialist II 325 Paramount Drive Raynham, Massachusetts 02767

Re: K142429

Trade/Device Name: CODMAN Microcoil Delivery System, DELTAMAXX Microcoil Delivery System, ORBIT GALAXY G2 Microcoil Delivery System, EnPower Control Cable, and Connecting Cable Regulation Number: 21 CFR 882.5950 Regulation Name: Neurovascular Embolization Device Regulatory Class: Class II Product Code: HCG. KRD Dated: December 4, 2014 Received: December 5, 2014

Dear Ms. Hannah Foley.

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

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Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical devicerelated 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 Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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.

Carlos L. Pena -S FD/△

Carlos L. Peña, PhD, MS 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) K142429

Device Name CODMAN Microcoil Delivery System DELTAMAXX Microcoil Delivery System ORBIT GALAXY G2 Microcoil Delivery System

Indications for Use (Describe)

CODMAN Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae, and is also intended for arterial and venous embolizations in the peripheral vasculature.

The DELTAMAXX Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Fill ORBIT GALAXY G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Xtrasoft ORBIT GALAXY G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms.

Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

  • Codman & Shurtleff, Inc. I. Submitter 325 Paramount Drive Raynham, MA 02767
    Tel: (305) 265-6810 Fax: (305) 265-6889

Contact Person: Hannah Foley Date Prepared: December 22, 2014

II. Device

Table 1: Device
Device Proprietary NameCODMAN® Microcoil Delivery System, DELTAMAXX Microcoil Delivery System, ORBIT GALAXY® G2 Microcoil Delivery System, EnPower Control Cable (ECB) and Connecting Cable (CCB)
Common or Usual NameDevice, Neurovascular Embolization & Device, Vascular, For Promoting Embolization
Classification NameDevice, Neurovascular Embolization, Class II, 21 CFR 882.5950 & Device, Vascular, For Promoting Embolization, Class II 21 CFR 870.3300
Regulatory ClassificationII
Product CodesHCG, KRD

The corresponding predicate devices that are listed in Table 2 below pertain to the III. Predicate devices being bundled in this submission. Refer to Table 3 for proprietary names of the Device all applicable products.

Table 2: Prior 510(k) Clearances
510(k) NumberDate ClearedNameManufacturer
PredicateK08273910/17/2008Micrus Microcoil Delivery System(Includes Cables)Micrus EndovascularCorporation*
PredicateK08364601/02/2009DELTAPLUSH 10 Stretch-Resistant DPLand DELTAPLUSH 10 Cerecyte CPL(Includes Cables)Micrus EndovascularCorporation*
PredicateK12068604/04/2012ORBIT GALAXY® G2 MicrocoilDelivery System (Includes Cables)Codman & Shurtleff, Inc.
PredicateK12027403/02/2012DELTAMAXX 18 Microcoil System(Includes Cables)Codman & Shurtleff, Inc.
PredicateK07217310/05/2007Micrus Microcoil System “Cashmere”Micrus EndovascularCorporation*
PredicateK07344202/26/2008Micrus Microcoil Delivery SystemMicrus EndovascularCorporation*
PredicateK03287211/28/2003Micrus Microcoil Delivery System LongSpherical CoilsMicrus EndovascularCorporation*
PredicateK06203608/25/2006Micrus Microcoil Delivery SystemPresidio-18Micrus EndovascularCorporation*
PredicateK05316012/07/2005Micrus Microcoil Delivery SystemCerecyte-18Micrus EndovascularCorporation*
*On 09/27/10, Micrus Endovascular Corporation was acquired by Johnson & Johnson and now operates as a wholly-owned subsidiaryof Codman & Shurtleff, Inc within the Johnson & Johnson family of companies. Medos International SARL (Medos) will be therecognized legal manufacturer and Codman & Shurtleff, Inc. will be the subcontractor appointed by Medos.

No reference devices were used in this submission.

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The CODMAN® Microcoil Delivery System, DELTAMAXX Microcoil Delivery IV. Device Description System, and ORBIT GALAXY® G2 Microcoil Delivery System consist of three components, a Microcoil System, a connecting cable, and a Detachment Control Box (DCB). Each component is sold separately. As shown in Figure 1, the Microcoil System consists of an microcoil attached to a Device Positioning Unit (DPU).

Image /page/4/Figure/4 description: The image shows a diagram of a microcoil system. The system includes a hub connector on the left side, followed by a re-sheathing tool, an introducer sheath body, and an introducer sheath tip on the right side. The microcoil is located at the far right of the system. A device positioning unit (DPU) is labeled along the length of the system.

The Microcoil System is packaged in an introducer sheath designed to protect the coil in the packaging dispenser and to provide support for introducing the coil into the infusion catheter. The microcoil is the implantable segment of the device, and is detached from the Device Positioning Unit (DPU) using the Detachment Control System (Detachment Control Box and connecting cable).

  • . The microcoil is fabricated from a platinum alloy wire. The wire is wound into a primary coil which may contain either a polypropylene suture (SR) or an absorbable polymer suture (Cerecyte®) and then formed into a secondary shape. The secondary shape may be straight, spherical, complex, or helical. The DPU is a variable stiffness wire and has a radiopaque marker band located three (3) cm from its distal end. The introducer sheath has three main components: an introducer tip, a translucent introducer body, and a re-sheathing tool.
    The Detachment Control Box (DCB) provides the energy necessary to allow for a thermo-mechanical detachment of the microcoil from the DPU. The connecting cable delivers the energy necessary to detach the embolic coil from the Microcoil System's detachment zone. The connecting cable is connected between the Microcoil System's hub connector on the DPU and the output connector on the DCB.

  • . The detachment control box may be one of two types: the blue EnPower Detachment Control Box or the black Detachment Control Box.

  • The connecting cables may be one of two types: one with a remote detach button (the EnPower Control Cable) catalog no. ECB000182-00, or one without a detach button (standard connecting cable) catalog no. CCB00157-00.

  • The EnPower Detachment Control Box works with the EnPower Control Cable and with the standard connecting cable. The black Detachment Control Box works only with the standard connecting cable. Both cables and Detachment Control Box are sold separately.

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Table 3 provides a summary of the of the Microcoil Delivery Systems and Cables, IV. Device proprietary names, product model description, product catalog prefix, diameter and length, Description and predicate 510(k) numbers. (Cont.)

Table 3: CODMAN®, DELTAMAXX, and ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables
Proprietary Names / Product Model DescriptionProductCatalogPrefixDiameter (mm) xLength (cm)Ranges510(k)No.
CODMAN® Microcoil Delivery System:
MICRUSPHERE 10 Platinum CoilSPH102-10mm x 2.5-30cmK082739
MICRUSPHERE 18 Platinum CoilSPH182-19mm x 2.5-30cmK082739
HELIPAQ 10 Platinum CoilHEL102-10mm x 2-30cmK082739
HELIPAQ 18 Platinum CoilHEL182-20mm x 4-30cmK082739
INTERPAQ Straight 10 Platinum CoilSTR102-6mm x 4-30cmK082739
ULTIPAQ 10 Stretch Resistant CoilFSR102-4mm x 1-8cmK082739
HELIPAQ 10 Stretch Resistant CoilHSR102-10mm x 1-30cmK082739
CASHMERE 14 Stretch Resistant CoilSRC142-12mm x 2.5-30cmK072173
MICRUSPHERE XL 10 Stretch Resistance CoilSSR102-8mm x 2.5-25mmK073442,K032872
MICRUSPHERE XL 18 Stretch Resistance CoilSSR188-18mm x 25-40cmK073442,K062036,K053160
DELTAPAQ 10 Stretch Resistant CoilDFS101.5-10mm x 1-25cmK082739
DELTAPLUSH 10 Stretch Resistant CoilDPL101.5-4mm x 1-8cmK083646
PRESIDIO 10 Platinum CoilPP4104-8mm x 11.5-29cmK082739
DELTAMAXX 18 Stretch Resistant CoilDMX183-24mm x 12-60cmK120274
ORBIT GALAXY® G2 Stretch Resistant Complex Coil Fill641CF2-20mm x 1.5-30cmK120686
ORBIT GALAXY® G2 Stretch Resistant Complex Coil XTRASOFT641CX2-6mm x 1.5-20cmK120686
ORBIT GALAXY® G2 Stretch Resistant Helical Coil XTRASOFT641HX2mm x 1.5-8cmK120686
EnPower Control Cable (Microcoil Delivery Systems' Cable)ECB5-6ftK082739,K083646,K120686,K120274
Connecting Cable (Microcoil Delivery Systems' Cable)CCB5-6ftK082739,K083646,K120686,K120274

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CODMAN® Microcoil Delivery System is intended for endovascular embolization of V. Indications intracranial aneurysms, other neurovascular abnormalities such as arteriovenous for Use malformations and arteriovenous fistulae, and is also intended for arterial and venous embolizations in the peripheral vasculature.

The DELTAMAXX Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae, and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Fill ORBIT GALAXY® G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms, other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae, and is also intended for arterial and venous embolizations in the peripheral vasculature.

The Xtrasoft ORBIT GALAXY® G2 Microcoil Delivery System is intended for endovascular embolization of intracranial aneurysms.

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VI. Comparison of Technological Characteristics With Predicate Device

There are no new technological characteristics being introduced with the proposed packaging change to the CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables. The CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables were shown to be substantially equivalent to the predicate devices through comparison of indications for use, function, operating principle, bench testing, sterilization, biocompatibility, and materials.

The modifications proposed in this submission are for packaging only. Therefore the summary table provided below is a comparison of technological characteristics focused on the CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables' packaging.

Table 4: Product Packaging Comparison Information
CharacteristicsPredicate Devices: CODMAN® Microcoil Delivery System (K082739, K073442, K072173, K083646) DELTAMAXX Microcoil Delivery System (K120274) ORBIT GALAXY® G2 Microcoil Delivery System (K120686)This Submission: CODMAN® Microcoil Delivery System DELTAMAXX Microcoil Delivery System ORBIT GALAXY® G2 Microcoil Delivery System
Dimensions
Pouch Size11" x 10"14" x 10"
Carton Size10.125" x 11" x 0.703"Same as Predicates
Dispenser HoopLength: 260cm & Diameter: 8.75"Same as Predicates
Material
Pouch MaterialTPF-0521 PET/adhesive/LDPE/w/heat seal coating sealed to TPF-0501A PET/ LDPETPS-4050 Nylon/LDPE Film w/ heat seal coating sealed to TPS-4050 Nylon/LDPE Film
Dispenser Hoop MaterialTubing: Medical Grade Polyethylene Clip: Medical Grade MDPESame as Predicates
EnPower Control(ECB)/Connecting (CCB) Cable Mounting Card Material0.024" Clay Coated Solid Bleached SulfateSame as Predicates
Carton Material0.024" Clay Coated Solid Bleached SulfateSame as Predicates
Source
Pouch VendorTolas Health Care PackagingSame as Predicates
Carton VendorRoyal Paper Box &Constellation Anderson DDB Health & LifestylesSame as Predicates
Dispenser HoopsContech Packaging, Inc.Same as Predicates
Pouch Sealing Method
SealerSencorp Model 12-PV/2Same as Predicates
Sterilization
Sterilization MethodE-Beam RadiationSame as Predicates
Microcoil Delivery Systems' Target Surface Dose37kGySame as Predicates
EnPower Control (ECB) / Connecting (CCB) Cables Target Surface Dose42kGySame as Predicates
Shelf-Life
Microcoil Delivery Systems' Product Shelf Life5 yearsSame as Predicates
EnPower Control (ECB) / Connecting (CCB) Cables Product Shelf Life3 yearsSame as Predicate
Note: The EnPower Control (ECB) and Connecting (CCB) Cables are part of all Microcoil Delivery Systems Listed.

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There were no changes made that affect the CODMAN®, DELTAMAXX, VII. Performance ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables' intended use, operational principle, design principle, product materials, manufacturing or Data sterilization processes. The modifications proposed in this submission are for the packaging only. Therefore, design verification and validation of the product was

Verification and validation activities were focused on demonstrating package integrity of the proposed pouches. Appropriate testing was identified based on a review of the products' risk analyses and previous use of the Nylon/LDPE Film pouch. Testing was conducted as appropriate for the inclusion of the proposed pouches based on current standards, and all testing was performed on final sterile product, unless otherwise specified. The following performance data were provided in support of the substantial equivalence determination.

Packaging Integrity Testing

not warranted.

Packaging Integrity testing demonstrated that the sterile barrier system of the proposed pouch maintains packaging integrity after exposure to sterilization, simulated handling and distribution. The validation also demonstrates that the packaging design and materials are acceptable for the CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoils Delivery System. The following tests were performed:

  • . Visual Inspection
  • . Dye Leak
  • Seal Strength
  • . Product Functional Testing on EnPower Control Cable

Characterization Testing: Moisture and Humidity Creep

Sterile Pouch Shelf-Life Testing

Pouch Shelf Life visual inspection demonstrated that the proposed pouch's integrity was maintained. The inspected seals were complete and uniform throughout the entire seal area of the proposed pouch for each time interval (Accelerated Aging: time-zero, 1yr, 3yr, 5yr, 10yr) (Real-Time Aging: time-zero, 1 yr, 3 yr) in the sterilized test groups. There were no detected negative trends in seal strength. These results demonstrate that the seals maintain their strength over time. Testing confirmed that the device will remain sterile through the proposed shelf life and integrity of its packaging are not compromised during transportation and distribution. The following tests were performed:

  • Visual Inspection
  • . Seal Strength

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  • . In vitro Cytotoxicity

Sterilization

Sterilization method validation in accordance with ISO 11137: 2006. Only the material and size of the pouch are changing. There are no changes to the product. All of the bioburden related test results met the acceptance criteria for the representative products as packaged in the new pouch, and the full shipper weights and densities remain within the acceptable dose mapped results. Therefore, the packaging change to the CODMAN®, DELTAMAXX, ORBIT GAXALY® G2 Microcoil Delivery Systems, EnPower Control and Connecting Cables are considered acceptable. The following tests were performed:

  • Bioburden measurement
  • Identification of top three organisms
  • Bacteriostasis/Fungistasis (B/F)
  • Bioburden recovery study (Extraction efficiency) .

Animal Testing

No animal studies were required as appropriate verification and validation of the packaging modifications were achieved based on the similarities of the proposed device to the predicate device, and from results of bench testing.

Summary of Clinical Testing

No clinical studies were required as appropriate verification and validation of the packaging modifications were achieved based on the similarities of the proposed device to the predicate device, and from results of bench testing.

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Based upon the design, materials, function, intended use, and the non-clinical VIII. Conclusion testing performed by Codman, it is concluded that the proposed packaging for CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables is substantially equivalent to the currently marketed CODMAN®, DELTAMAXX, ORBIT GALAXY® G2 Microcoil Delivery Systems and Cables and therefore, does not raise any new questions of safety and effectiveness.

§ 882.5950 Neurovascular embolization device.

(a)
Identification. A neurovascular embolization device is an intravascular implant intended to permanently occlude blood flow to cerebral aneurysms and cerebral ateriovenous malformations. This does not include cyanoacrylates and other embolic agents, which act by polymerization or precipitation. Embolization devices used in other vascular applications are also not included in this classification, see § 870.3300.(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 § 882.1(e).