K Number
K143208
Device Name
Denali Filter System - Femoral Delivery Kit, Denali Filter System - Jugular/Subclavain Delivery Kit
Manufacturer
Date Cleared
2014-12-09

(29 days)

Product Code
Regulation Number
870.3375
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Denali® Filter is indicated for use in the prevent pulmonary embolism via placement in the vena cava in the following situations: -Pulmonary thromboembolism when anticoagulants are contraindicated. -Failure of anticoagulant therapy for thromboembolic disease. -Emergency treatment following massive pulmonary embolism where anticipated benefits of conventional therapy are reduced. -Chronic. recurrent pulmonary embolism where anticoagulant therapy has failed or is contraindicated. The Denali® Filter may be removed according to the instructions supplied under the Section labeled: Optional Procedure for Filter Removal.
Device Description
The Denali® Vena Cava Filter is a venous interruption device designed to prevent pulmonary embolism. The Denali® Filter can be delivered via the femoral and jugular/subclavian approaches. A separate delivery system is available for each approach. The Denali® Filter is designed to act as a permanent filter. When clinically indicated, the Denali® Filter may be percutaneously removed after implantation according to the instructions provided under the "Optional Procedure for Filter Removal" section. The Denali® Filter of twelve shape-memory laser-cut nickel-titanium appendages. These twelve appendages form two levels of filtration with the legs providing the lower level of filtration and the arms providing the upper level of filtration. The Denal® Filter is intended to be used in the inferior vena cava (IVC) with a diameter less than or equal to 28mm. The Denali®Vena Cava Filter System consists of a short, 15cm, 10 French dilator, an introducer sheath, a long, 55cm, 8 French dilator, and a preloaded Denall® Filter in a storage tube with a pusher. The 15cm, 10 French dilator accepts a 0.035" quidewire and is intended for pre-dilatation. The long, 55cm, 8 French dilator accepts a 0.035" quidewire and allows for an 800 psi maximum pressure contrast power injection. Radiopaque marker bands on the end of the dilator aid in measuring the maximum indicated IVC diameter. They are spaced at a distance of 28mm (outer-to-outer). The 55cm, 8.4 French I.D. introducer sheath contains a radiopaque marker and hemostasis valve with a side port. The pusher advances the filter through the introducer sheath to the predeployment mark and is then used to fix the filter in place while the filter is unsheathed.
More Information

Not Found

No
The device description focuses on the mechanical design and materials of the filter and its delivery system. There is no mention of software, algorithms, or data processing that would indicate the use of AI/ML. The performance studies are based on in vitro testing of the physical device and delivery system.

Yes
The device is described as a "venous interruption device designed to prevent pulmonary embolism," which directly addresses a medical condition by preventing a life-threatening event.

No

This device is a vena cava filter, which is an implantable device designed to prevent pulmonary embolism by physically blocking blood clots. Its function is to treat or prevent a medical condition, not to diagnose one.

No

The device description clearly details a physical medical device (vena cava filter) and associated hardware components (delivery system, dilators, sheath, pusher). There is no mention of software as the primary or sole component.

Based on the provided text, the Denali® Filter is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly states the device is for preventing pulmonary embolism by being placed in the vena cava. This is an in-vivo (within the living body) application.
  • Device Description: The description details a physical implantable device (a filter) designed to be placed within a blood vessel. This is consistent with an in-vivo device.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, tissue, etc.) outside of the body. IVDs are used for diagnostic purposes on such specimens.

Therefore, the Denali® Filter is a medical device intended for in-vivo use, not an IVD.

N/A

Intended Use / Indications for Use

The Denali® Filter is indicated for use in the prevent pulmonary embolism via placement in the vena cava in the following situations:

-Pulmonary thromboembolism when anticoagulants are contraindicated.

-Failure of anticoagulant therapy for thromboembolic disease.

-Emergency treatment following massive pulmonary embolism where anticipated benefits of conventional therapy are reduced.

-Chronic. recurrent pulmonary embolism where anticoagulant therapy has failed or is contraindicated.

The Denali® Filter may be removed according to the instructions supplied under the Section labeled: Optional Procedure for Filter Removal.

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

DTK

Device Description

The Denali® Vena Cava Filter is a venous interruption device designed to prevent pulmonary embolism. The Denali® Filter can be delivered via the femoral and jugular/subclavian approaches. A separate delivery system is available for each approach. The Denali® Filter is designed to act as a permanent filter. When clinically indicated, the Denali® Filter may be percutaneously removed after implantation according to the instructions provided under the “Optional Procedure for Filter Removal” section.

The Denali® Filter of twelve shape-memory laser-cut nickel-titanium appendages. These twelve appendages form two levels of filtration with the legs providing the lower level of filtration and the arms providing the upper level of filtration. The Denal® Filter is intended to be used in the inferior vena cava (IVC) with a diameter less than or equal to 28mm.

The Denali®Vena Cava Filter System consists of a short, 15cm, 10 French dilator, an introducer sheath, a long, 55cm, 8 French dilator, and a preloaded Denall® Filter in a storage tube with a pusher. The 15cm, 10 French dilator accepts a 0.035" quidewire and is intended for pre-dilatation. The long, 55cm, 8 French dilator accepts a 0.035" quidewire and allows for an 800 psi maximum pressure contrast power injection. Radiopaque marker bands on the end of the dilator aid in measuring the maximum indicated IVC diameter. They are spaced at a distance of 28mm (outer-to-outer). The 55cm, 8.4 French I.D. introducer sheath contains a radiopaque marker and hemostasis valve with a side port. The pusher advances the filter through the introducer sheath to the predeployment mark and is then used to fix the filter in place while the filter is unsheathed.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

vena cava, inferior vena cava (IVC)

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)

To demonstrate substantial equivalence of the subject device to the predicate device, the technological characteristics and performance criteria were evaluated using in vitro testing performed as outlined below:

In Vitro Delivery System Testing

  • . Dimensional and Visual Inspection
  • Delivery System Component Tensile Testing .
  • . Simulated Use Testing
  • . Packaging Testing

The results from these tests demonstrate that the technological characteristics and performance of the Denali® Filter System - Femoral and Jugular/Subclavian Delivery Kit is comparable to the predicate device and that the subject device can perform in a manner substantially equivalent to the predicate device with the same intended use.

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.

K130366

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

§ 870.3375 Cardiovascular intravascular filter.

(a)
Identification. A cardiovascular intravascular filter is an implant that is placed in the inferior vena cava for the purpose of preventing pulmonary thromboemboli (blood clots generated in the lower limbs and broken loose into the blood stream) from flowing into the right side of the heart and the pulmonary circulation.(b)
Classification. Class II. The special controls for this device are:(1) “Use of International Standards Organization's ISO 10993 ‘Biological Evaluation of Medical Devices Part I: Evaluation and Testing,’ ” and
(2) FDA's:
(i) “510(k) Sterility Review Guidance and Revision of 2/12/90 (K90-1)” and
(ii) “Guidance for Cardiovascular Intravascular Filter 510(k) Submissions.”

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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 symbol of three human profiles facing to the right, stacked on top of each other.

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

December 9, 2014

C.R. Bard, Inc. % Laurie Sang Regulatory Affairs Specialist 1625 W. Third St. Tempe, Arizona 85281

Re: K143208

Trade/Device Name: Denali Filter System – Femoral. Jugular/Subclavian Delivery Kit Regulation Number: 21 CFR 870.3375 Regulation Name: Cardiovascular Intravascular Filter Regulatory Class: Class II Product Code: DTK Dated: November 7, 2014 Received: November 10, 2014

Dear Laurie Sang,

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

1

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 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,

Kenneth J. Cavanaugh -S

for

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

Enclosure

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Indications for Use

510(k) Number (if known) K143208

Device Name

Denali® Filter System - Femoral and Jugular/Subclavian Delivery Kit

Indications for Use (Describe)

The Denali® Filter is indicated for use in the prevent pulmonary embolism via placement in the vena cava in the following situations:

-Pulmonary thromboembolism when anticoagulants are contraindicated.

-Failure of anticoagulant therapy for thromboembolic disease.

-Emergency treatment following massive pulmonary embolism where anticipated benefits of conventional therapy are reduced.

-Chronic. recurrent pulmonary embolism where anticoagulant therapy has failed or is contraindicated.

The Denali® Filter may be removed according to the instructions supplied under the Section labeled: Optional Procedure for Filter Removal.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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DENALI® Filter System 510(k) Summary 21 CFR 807.92

As required by the Safe Medical Devices Act of 1990, coded under Section 513, Part (I)(3)(A) of the Food, Drug and Cosmetic Act, a 510(k) summary upon which substantial equivalence determination is based is as follows:

Submitter Information:

| Applicant: | Bard Peripheral Vascular, Inc
1625 West 3rd Street
Tempe, Arizona 85281 |
|------------|--------------------------------------------------------------------------------|
| Phone: | 480-350-6069 |
| Fax: | 480-449-2546 |
| Contact: | Laurie Sang, Regulatory Affairs Specialist |
| Date: | November 7, 2014 |

Subject Device Name:

| Device Trade Name: | Denali® Filter System - Femoral and
Jugular/Subclavian Delivery Kit |
|-----------------------|------------------------------------------------------------------------|
| Common or Usual Name: | Filter, Intravascular, Cardiovascular |
| Classification: | Class II |
| Classification Panel: | Cardiovascular Devices |
| Product Code: | DTK |
| Predicate Devices: | (K130366; Clearance May
15, 2013) |

Summary of Change:

The modification from the predicate device, compared to the subject Denalle Filter System - Femoral and Jugular/Subclavian Delivery Kit, is the device will include two introducers, a 10 French dilator and an 8 French dilator and pusher system. The new design will also incorporate a longer handle on the delivery system. Minor changes have been made to the device labeling.

Image /page/3/Picture/12 description: The image shows the word "BARD" in a stylized, bold font. The letters are thick and geometric, with a unique design for the letter "A" that resembles an upside-down "V" with a horizontal line connecting the two sides. The overall impression is a strong and modern logo or wordmark.

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Device Description:

The Denali® Vena Cava Filter is a venous interruption device designed to prevent pulmonary embolism. The Denali® Filter can be delivered via the femoral and jugular/subclavian approaches. A separate delivery system is available for each approach. The Denali® Filter is designed to act as a permanent filter. When clinically indicated, the Denali® Filter may be percutaneously removed after implantation according to the instructions provided under the "Optional Procedure for Filter Removal" section.

The Denali® Filter of twelve shape-memory laser-cut nickel-titanium appendages. These twelve appendages form two levels of filtration with the legs providing the lower level of filtration and the arms providing the upper level of filtration. The Denal® Filter is intended to be used in the inferior vena cava (IVC) with a diameter less than or equal to 28mm.

The Denali®Vena Cava Filter System consists of a short, 15cm, 10 French dilator, an introducer sheath, a long, 55cm, 8 French dilator, and a preloaded Denall® Filter in a storage tube with a pusher. The 15cm, 10 French dilator accepts a 0.035" quidewire and is intended for pre-dilatation. The long, 55cm, 8 French dilator accepts a 0.035" quidewire and allows for an 800 psi maximum pressure contrast power injection. Radiopaque marker bands on the end of the dilator aid in measuring the maximum indicated IVC diameter. They are spaced at a distance of 28mm (outer-to-outer). The 55cm, 8.4 French I.D. introducer sheath contains a radiopaque marker and hemostasis valve with a side port. The pusher advances the filter through the introducer sheath to the predeployment mark and is then used to fix the filter in place while the filter is unsheathed.

Indications for Use of Device:

The Denali® Filter is indicated for use in the prevention of recurrent pulmonary embolism via placement in the vena cava in the following situations:

  • . Pulmonary thromboembolism when anticoaqulants are contraindicated
  • . Failure of anticoagulant therapy for thromboembolic disease
  • Emergency treatment following massive pulmonary embolism where anticipated . benefits of conventional therapy are reduced

Image /page/4/Picture/13 description: The image shows the word "BARD" in a stylized, all-caps font. The letters are bold and outlined in black, giving them a three-dimensional appearance. The "A" in "BARD" is designed with a unique, angular shape, setting it apart from the other letters.

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  • . Chronic, recurrent pulmonary embolism where anticoagulant therapy has failed or is contraindicated.
    The Denali® Filter may be removed according to the instructions supplied under the Section labeled: Optional Procedure for Filter Removal.

Technological Comparison to Predicate Devices:

The technological characteristics of the subject device, the Denali® Filter System -Femoral and Jugular/Subclavian Delivery Kit, are substantially equivalent to those of the predicate devices, in terms of the following:

  • Intended use
  • Indications for use
  • . Target population
  • . Delivery system design
  • Filter design and material .
  • . Fundamental scientific technology
  • . Packaging configuration (with addition of the extra dilator)
  • . Sterility Assurance and method of Sterilization

Performance Testing Summary:

To demonstrate substantial equivalence of the subject device to the predicate device, the technological characteristics and performance criteria were evaluated using in vitro testing performed as outlined below:

In Vitro Delivery System Testing

  • . Dimensional and Visual Inspection
  • Delivery System Component Tensile Testing .
  • . Simulated Use Testing
  • . Packaging Testing

Image /page/5/Picture/23 description: The image shows the word "BARD" in a stylized, bold font. The letters are connected, creating a unified design. The overall impression is modern and clean.

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The results from these tests demonstrate that the technological characteristics and performance of the Denali® Filter System - Femoral and Jugular/Subclavian Delivery Kit is comparable to the predicate device and that the subject device can perform in a manner substantially equivalent to the predicate device with the same intended use.

Conclusion:

The subject Denali Filter System met all predetermined acceptance criteria of design verification and validation as specified by applicable standards, guidance, test protocols and/or customer inputs. The Denali® Filter System - Femoral and Jugular/Subclavian Delivery Kit is substantially equivalent to the legally marketed predicate device.

Image /page/6/Picture/6 description: The image shows the word "BARD" in a stylized, bold, sans-serif font. The letters are outlined in black, creating a strong visual impact. The design of the letters is somewhat geometric, with the "A" resembling a triangle and the "D" having a rounded, almost semi-circular shape.