K Number
K151072
Device Name
Solo-Dex Fascile Continuous Peripheral Nerve Block Catheter and Needle Kit
Manufacturer
Date Cleared
2016-01-22

(276 days)

Product Code
Regulation Number
868.5150
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is intended for use in regional anesthesia and pain therapy to locate peripheral nerves by transferring electrical impulses from a nerve stimulator, or to be seen by ultrasound visualization of the device. The need to inject and facilitate the continuous and/or internittent administration of local anesthetics or analgesics to the targeted nerve bundle in surgical procedures. In packaged set configurations, the Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit, consisting of the peripheral nerve block needle, catheted peripheral nerve block procedural accessories, is intended to provide continuous and/or intermittent infusion of local anesthetics and analgesics for peripheral plexus anesthesia and pain management during pre-operative and post-operative periods associated with surgical procedures. The catheter may remain indwelling for up to 72 hours.
Device Description
Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is a needle comprised of an open tip catheter over a needle. The Fascile kit is comprised of different key components required to complete the Peripheral Nerve Block procedure.
More Information

Not Found

No
The summary describes a physical medical device (catheter and needle kit) used for nerve blocks, relying on electrical stimulation and ultrasound visualization. There is no mention of AI or ML in the intended use, device description, or performance studies. The performance studies focus on physical and functional characteristics of the device components.

Yes.
The device is intended for regional anesthesia and pain therapy to administer local anesthetics or analgesics to targeted nerve bundles, indicating a therapeutic purpose.

No

The device is intended to locate peripheral nerves using electrical impulses or ultrasound visualization, and then to administer local anesthetics/analgesics. It does not claim to diagnose a condition or disease.

No

The device description clearly outlines physical components like a needle, catheter, and procedural accessories, and the performance studies focus on the physical properties and functionality of these hardware components.

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

Here's why:

  • Intended Use: The intended use clearly describes a device used for regional anesthesia and pain therapy by locating nerves, facilitating the administration of local anesthetics or analgesics, and remaining indwelling for continuous infusion. This is a therapeutic and procedural use, not a diagnostic one.
  • Device Description: The device is described as a needle and catheter kit used for delivering substances to the body. This aligns with a therapeutic/procedural device, not a device used to examine specimens from the body.
  • Lack of Diagnostic Purpose: There is no mention of the device being used to diagnose a disease, condition, or state of health by examining specimens from the human body.
  • Input Imaging Modality: While ultrasound is used, it's for visualization of the device during the procedure, not for obtaining diagnostic images of the body's internal structures for analysis.
  • Performance Studies: The performance studies focus on the physical properties of the device (echogenicity, electrical transmission, tensile strength, flow rate, etc.) and its compatibility with drugs and procedures. These are typical performance metrics for a therapeutic/procedural device, not an IVD.

In summary, the Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is a medical device used for delivering medication and facilitating a medical procedure (nerve block), not for performing diagnostic tests on biological specimens.

N/A

Intended Use / Indications for Use

The Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is intended for use in regional anesthesia and pain therapy to locate peripheral nerves by transferring electrical impulses from a nerve stimulator, or to be seen by ultrasound visualization of the device. The need to inject and facilitate the continuous and/or internittent administration of local anesthetics or analgesics to the targeted nerve bundle in surgical procedures.

In packaged set configurations, the Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit, consisting of the peripheral nerve block needle, catheted peripheral nerve block procedural accessories, is intended to provide continuous and/or intermittent infusion of local anesthetics and analgesics for peripheral plexus anesthesia and pain management during pre-operative and post-operative periods associated with surgical procedures. The catheter may remain indwelling for up to 72 hours.

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

BSP

Device Description

Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is a needle comprised of an open tip catheter over a needle. The Fascile kit is comprised of different key components required to complete the Peripheral Nerve Block procedure.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound visualization

Anatomical Site

Peripheral nerves, peripheral plexus

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Biocompatibility Testing: Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter/Needle Kit
Tests conducted and passed: L929 Neutral Red Uptake Cytotoxicity Test, Intracutaneous Injection Test, Kligman Maximization Test, Systemic Injection Test, Rabbit Pyrogen Test, Hemolysis - Rabbit Blood Indirect Contact, Salmonella typhimurium and Escherichia coli Reverse Mutation Assay, Mouse Lymphoma Mutagenesis Assay with Confirmation, Rodent Blood MIcronucleus Assay Repeat Dose, 28-Day systemic Toxicity in Rats via Subcutaneous Implantation, Intramuscular Implantation Test. All results were PASS.

Table Summary of Bench (Performance) Testing

  • Needle & Catheter Echogenicity Test Method (TM-0001): Confirm needle/catheter echogenicity via ultrasound. Acceptance criteria: The test subject shall be visible in the ultrasonic machine. Result: Pass.
  • Needle Electro-Stimulation Test Method (TM-0002): Confirm needle will transmit an electronic signal observed on a RMS multi-meter. Acceptance criteria: In all current settings of stimulator from low 0.1 to high 5.0mA, the Fascile needle shall be able to transmit the signal as observed on the RMS multi-meter. Result: Pass.
  • Needle Sharpness Inspection (TM-SR004A): Visual and dimensional inspection for needle sharpness. Acceptance criteria: Continuity of needle tip / edge no deformation. Result: Pass.
  • Tensile Strength Test Method (TM-0005): Measure needle and catheter tensile strength. Acceptance criteria: Fascile catheter body: Tensile strength for 18Ga $\ge$ 2.25 lbf. Tensile strength for 16GA $\ge$ 2.25 lbf. Fascile catheter hub: Tensile strength for 18Ga $\ge$ 2.25 lbf. Tensile strength for 16GA $\ge$ 2.25 lbf. Fascile needle hub: Tensile strength for 20Ga $\ge$ 12.14 lbf. Tensile strength for 18GA $\ge$ 2.25 lbf. Fascile Bond strength: $\ge$ 2.25 lbf. Result: Pass.
  • Catheter and Extension Set Flow Test Method (TM-0008): Measure fluid flow rate through the extension set and catheter. Acceptance criteria: Flow through predefined holes of a Fascile catheter is visible. Flow through Fascile catheter and extension set attached to a flow control tubing (test) does not drop below 20% compared to the flow of a flow control tubing alone (control). Result: Pass.
  • Catheter Depth Mark Inspection (TM-SR008A): Visual and dimensional inspection for catheter depth marks. Acceptance criteria: Depth marks exist and marking gaps meet drawing. Result: Pass.
  • Catheter Curvature Inspection (TM-SR009A): Visual and dimensional inspection of catheter curvature. Acceptance criteria: Correctness of curve orientation respect to arrow on hub. Result: Pass.
  • Straightener Tube Test (TM-SR044A): Check for straightener tube functionality. Acceptance criteria: Needle easily moves through the catheter without damage. Result: Pass.
  • ISO 594-1:1986: Conical Fittings with a 6% (Luer) Taper for Syringes, needles and Certain other Medical Equipment - Part 1. ISO standard test methods for ensuring leak free fluid connectors. Acceptance criteria: Complies with the ISO standard. Result: Pass.
  • ISO 594-2:1998: Conical Fittings with a 6% (Luer) Taper for Syringes, needles and Certain other Medical Equipment - Part 2. ISO standard test methods for ensuring leak free fluid connectors. Acceptance criteria: Complies with the ISO standard. Result: Pass.

Animal Study: The Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit does not require animal performance testing. There are no animal testing requirements for this Class II product.

Clinical Study: The Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit does not require a clinical study. There are no clinical study requirements for this Class II product.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K121846

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 868.5150 Anesthesia conduction needle.

(a)
Identification. An anesthesia conduction needle is a device used to inject local anesthetics into a patient to provide regional anesthesia.(b)
Classification. Class II (performance standards).

0

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

January 22, 2016

Solo-Dex, Inc. % Albert Rego, Ph.D. Regulatory Consultant Albert Rego, Ph.D., Inc. 27001 La Paz Road, Suite 312 Mission Viejo, California 92691

Re: K151072

Trade/Device Name: Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit Regulation Number: 21 CFR 868.5150 Regulation Name: Anesthesia Conduction Needle Regulatory Class: Class II Product Code: BSP Dated: December 22, 2015 Received: December 24, 2015

Dear Dr. Albert Rego:

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

1

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.

Tejashri 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

Indications for Use

510(k) Number (if known) K151072

Device Name

Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit

Indications for Use (Describe)

The Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is intended for use in regional anesthesia and pain therapy to locate peripheral nerves by transferring electrical impulses from a nerve stimulator, or to be seen by ultrasound visualization of the device. The need to inject and facilitate the continuous and/or internittent administration of local anesthetics or analgesics to the targeted nerve bundle in surgical procedures.

In packaged set configurations, the Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit, consisting of the peripheral nerve block needle, catheted peripheral nerve block procedural accessories, is intended to provide continuous and/or intermittent infusion of local anesthetics and analgesics for peripheral plexus anesthesia and pain management during pre-operative and post-operative periods associated with surgical procedures. The catheter may remain indwelling for up to 72 hours.

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 (As required by 21 CFR 807.92)

| I. SUBMITTER: | Solo-Dex, Inc.
3 Moonlight Isle
Ladera Ranch, CA 92694
USA |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Albert Rego Ph.D., Inc.
27001 La Paz Road, Suite 312
Mission Viejo, CA 92691
Contact: Albert Rego
Phone: (949) 770-8710 |
| Date Prepared: | January 20, 2016 |
| II. DEVICE: | |
| Trade Name: | Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and
Needle Kit |
| Common Name: | Anesthesia Conduction Needle
[Peripheral Nerve Block Needle, Anesthetic Conduction Needles,
W/Wo introducer (21 CFR 868.5150)] |
| Classification Panel: | Anesthesiology |
| Regulatory Class: | Class II |
| Product Code: | BSP |
| III. PREDICATE DEVICE: | Complex® C Continuous Peripheral Nerve Block Needle (K121846) |

IV. DEVICE DESCRIPTION:

Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit is a needle comprised of an open tip catheter over a needle. The Fascile kit is comprised of different key components required to complete the Peripheral Nerve Block procedure.

V. INDICATIONS FOR USE:

The Solo-Dex Fascile® Continuous Peripheral Nerve Block Needle is intended for use in regional anesthesia and pain therapy to locate peripheral nerves by transferring electrical impulses from a nerve stimulator, or to be seen by ultrasound visualization of the device. The need to inject and facilitate the continuous and/or intermittent administration of local anesthetics or analgesics to the targeted nerve bundle in surgical procedures.

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In packaged set configurations, the Solo-Dex Fascile® Continuous Peripheral Nerve Block Set, consisting of the peripheral nerve block needle, catheter, and related peripheral nerve block procedural accessories, is intended to provide continuous and/or intermittent infusion of local anesthetics and analgesics for peripheral plexus anesthesia and pain management during pre-operative and postoperative periods associated with surgical procedures. The catheter may remain indwelling for up to 72 hours.

VI. TECHNOLOGICAL CHARACTERISTICS:

Solo-Dex Fascile® Continuous Peripheral Nerve Block Needle has the same fundamental scientific technology as the Complex® C Continuous Peripheral Nerve Block Needle (K121846).

VII. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

The comparison of features and operation principles between Solo-Dex Fascile® Continuous Peripheral Nerve Block Needle from Solo-Dex, Inc., and Complex® C Continuous Peripheral Nerve Block Needle (K121846) from B. Braun Medical, Inc. is listed as follows:

ParameterSolo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit 510(k) - (K151072)Complex® C Continuous Peripheral Nerve Block Needle 510(k) (K121846), B. Braun Medical, Inc.Comparison Substantially Equivalent or Equivalent
Common NamePeripheral Nerve Block Needle, Anesthetic Conduction Needles, W/Wo introducer (21 CFR 868.5150)Peripheral Nerve Block Needle, Anesthetic Conduction Needles, W/Wo introducer (21 CFR 868.5150)Substantially Equivalent
General Characteristics
DescriptionSolo-Dex Fascile Continuous Peripheral Nerve Block Catheter and Needle Kit is a needle comprised of an open tip catheter over a needle. The Fascile kit is comprised of different key components required to complete the Peripheral Nerve Block procedure. The description of key components are as follows:
  1. Catheter and Needle Combination: The needle provides the clinician with the ability of placing the catheter / needle combination at the regional block site. Upon placement, the needle is withdrawn leaving the catheter intact and available for infusion when connected to a syringe or infusion pump.

  2. Stimulating Cable: Fascile kit includes a stimulating cable that when connected to the needle provides electrical stimulation to the targeted nerve bundle if required | The Contiplex® C Continuous Peripheral Nerve Block Needle is a needle comprised of an open tip catheter over an insulated needle with a positioning component, a needle hub with integrated injection tubing and cable, and connection tubing. The key components in B. Braun system are as follows:

  3. Catheter and Needle Combination: The combination is used for placing the needle and catheter at the regional block site. After placement at the site, the needle is withdrawn with the catheter remaining at the site. The catheter may be attached to a syringe or infusion pump.

  4. Stimulating Cable: The stimulating cable is integrated into the needle. The needle may provide stimulation to the targeted nerve bundle if required. | Substantially Equivalent

Substantially Equivalent

Substantially Equivalent |
| Parameter | Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit 510(k) - (K151072) | Complex® C Continuous Peripheral Nerve Block Needle 510(k) (K121846), B. Braun Medical, Inc. | Comparison Substantially Equivalent or Equivalent |
| | 3. 0.2μ Filter: A 0.2μ filter is available within the kit and may be used for particle filtration of the anesthetic drug. The kit utilizes the Perifix 0.2μ filter (or equivalent). | 3. 0.2μ Filter: The B. Braun Perifix 0.2μ filter is available within the kit and may be used for particle filtra- tion of the anesthetic drug. | Substantially Equivalent |
| | 4. Adhesive strips and transparent occlusive dressing: Adhesive strips and occlusive dressing are available within the kit and may be used for securing the catheter at the insertion site. The adhesive strips and occlusive dressing are off the shelf components. | 4. Perifix PinPad Filter Fixation Device: The B. Braun Perifix PinPad is used for securing the Perifix 0.2μ Filter. | Substantially Equivalent (securement devices) |
| | 5. Extension Set: The Extension Set serves as the interface between the needle / catheter and the syringe / infusion pump. | 5. Extension Set: Same as Solo- Dex Fascile kit. | Substantially Equivalent |
| Indications for Use | The Solo-Dex Fascile® Continuous Peripheral Nerve Block Needle is in- tended for use in regional anesthesia and pain therapy to locate peripheral nerves by transferring electrical im- pulses from a nerve stimulator, or to be seen by ultrasound visualization of the device. The needle is used to in- ject and facilitate the continuous and/or intermittent administration of local anesthetics or analgesics to the targeted nerve bundle in surgical pro- cedures. | The Contiplex C Continuous Peripheral Nerve Block Needle is intended for use in regional anes- thesia and pain therapy to locate peripheral nerves by transferring electrical impulses from a nerve stimulator or by ultrasound visual- ization of the device. The needle is used to inject and facilitate the continuous administration of local anesthetics or analgesics to the target nerve bundle in general and orthopedic surgery. | Substantially Equivalent |
| | In packaged set configurations, the Solo-Dex Fascile® Continuous Periph- eral Nerve Block Set, consisting of the peripheral nerve block needle, cathe- ter, and related peripheral nerve block procedural accessories, is intended to provide continuous and/or intermit- tent infusion of local anesthetics and analgesics for peripheral plexus anes- thesia and pain management during pre-operative, peri-operative and post-operative periods associated with surgical procedures. The catheter may remain indwelling for up to 72 hours. | In set configuration, the B. Braun Contiplex C Continuous Peripheral Nerve Block Set, consisting of the peripheral nerve block needle catheter, and related peripheral nerve block procedural accesso- ries, is intended to provide contin- uous and/or intermittent infusion of local anesthetics and analgesics for peripheral plexus anesthesia and pain management during pre-operative, perioperative, and post- operative periods associated with general and orthopedic surgery. The catheter may remain indwell- ing for up to 72 hours. | |
| Technological Characteristics | | | |
| Basic Design | This is an over the needle catheter system. | This is an over the needle catheter system. | Substantially Equivalent |
| Parameter | Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit 510(k) - (K151072) | Complex® C Continuous Peripheral Nerve Block Needle 510(k) (K121846), B. Braun Medical, Inc. | Comparison Substantially Equivalent or Equivalent |
| Principle of Operation: Nerve Location | The proposed device incorporates two methods for locating the targeted nerve bundle: (1) Stimulation and (2) Ultrasonic. Both devices are used for placing an indwelling catheter in position local to the target nerve. | The predicate device incorporates two methods for locating the targeted nerve bundle: (1) Stimulation and (2) Ultrasonic. Both devices are used for placing an indwelling catheter in position local to the target nerve. | Substantially Equivalent |
| Primary Difference Between Two Devices | 1. Fascile utilizes multiple catheter / needle lengths (70 mm, 100 mm and 150 mm) based on the kit configuration. A clinician selects the appropriate needle/catheter lengths based on the location of the nerve block site.
2. Fascile kits include 3, 5 and 20 ml syringes and (2) hypodermic needles as accessories for clinician use if desired.
3. Fascile kits provide securement device(s) for the catheter after placement. | 1. Contiplex C utilizes a dedicated length catheter / needle length of 188 mm. The clinician adjusts the catheter / needle length, based on the location of the nerve block site, using the provided C-Clip positioning device.
2. Contiplex C kits do not include syringes or hypodermic needles as accessories for clinician use.
3. Contiplex C kits provide a securement device for the filter after catheter placement. | Substantially Equivalent in terms of form, fit, function |
| Configuration | Fascile has a primary Catheter and Needle combination along with supporting accessories. The typical kit configuration includes syringes, needles, securement devices, filter and extension set. Except for the extension set, all accessories are off the shelf items. | Contiplex C has a primary Catheter and Needle combination along with supporting accessories. The Contiplex C kit configuration includes an extension set, filter and securement device. | Substantially Equivalent |
| Primary Needle | | | |
| Echogenic Needle | Fascile Needle is designed to be Echogenic. Needle is made from stainless steel. | Needle is designed to be Echogenic. Needle is made from stainless steel. | Substantially Equivalent |
| Needle Stimulation: Conductivity | Fascile Needle provides conductivity by means of a cable and external current source. | Contiplex C Needle provides conductivity by means of an integrated cable and external current source. | Substantially Equivalent |
| Needle Sharp (Penetration) | Fascile Needle is sharp enabling a clinician to penetrate tissue. Needle tip: Touhy. | Contiplex C Needle is sharp enabling a clinician to penetrate tissue. Needle tip: block bevel. | Substantially Equivalent |
| Needle and Catheter Hub Bond Strength | Conforms to ISO- 10555, Intravascular Catheters- Sterile and single Use Catheters - Part 1: General Requirements | Bond Strength testing is claimed in 510(k) Summary | Substantially Equivalent |
| Parameter | Solo-Dex Fascile® Continuous Peripheral Nerve Block Catheter and Needle Kit 510(k) - (K151072) | Complex® C Continuous Peripheral Nerve Block Needle 510(k) (K121846), B. Braun Medical, Inc. | Comparison Substantially Equivalent or Equivalent |
| Primary Catheter Design | The catheter has an open end with side ports facilitating drug delivery. The catheter has a curved distal tip designed to keep the catheter near the nerve. | Contiplex C catheter has an open end at the tip for drug delivery. | Substantially Equivalent |
| Catheter Material | Catheter is made from a flexible plastic material. | Catheter is made from a flexible plastic material. | Substantially Equivalent |
| Depth Marks | Catheter is printed with depth marks. | Catheter is printed with depth marks. | Substantially Equivalent |
| Curvature to Position Around the Nerve(s) | The catheter curvature allows the catheter to remain close to the nerve. | Contiplex C is a straight catheter. | Substantially Equivalent in terms of form, fit, function |
| Other Components Extension Set - not made with Diethylhexylphthalate (DEHP) | Yes | Yes | Substantially Equivalent |
| Single, Single Use, and Disposable | Yes | Yes | Substantially Equivalent |
| Performance Data Biocompatibility (Externally Communicating Devices (needle, Catheter, and Extension Set) | Conformance to ISO 10993-1. Needle testing for limited exposure (24hrs and 24hrs and