K Number
K151985
Manufacturer
Date Cleared
2016-06-14

(333 days)

Product Code
Regulation Number
880.5970
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The PowerPICC® EtOH Catheter is indicated for short- or long-term peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

The PowerPICC SOLO® EtOH Catheter is indicated for short- or long-term peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

Device Description

Bard Access Systems, Inc.'s PowerPICC® EtOH and PowerPICC SOLO® EtOH Catheters are sterile, single use devices designed to provide access to the patient's vascular system. The devices are intended for short- or long-term use (>30 days) to sample blood and administer fluids intravenously. The catheters are compatible with intraluminal solutions containing up to 70% ethanol, capable of central venous pressure monitoring, and can withstand power injection of contrast media. The catheters are peripherally inserted central catheters (PICC) and utilize the same placement technique as the predicate devices.

The subject devices included in this notification are of varying French size and catheter configuration types, as summarized in the table below.

Summary of Subject Devices
Catheter Configuration | French size (Number of Lumens)
PowerPICC® EtOH | 4F (Single Lumen (SL))
| 5F (Dual Lumen (DL)) FT
| 5F (Triple Lumen (TL))
PowerPICC SOLO®2 EtOH | 4F (Single Lumen (SL))
| 5F (Dual Lumen (DL)) FT
| 5F (Triple Lumen (TL))

The subject catheters will be packaged with legally marketed components used in the placement procedure.

The following device descriptors apply to all French sizes and configurations of the subject Bard Access PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters:

  • The catheters are open-ended, radiopaque polyurethane;
  • The catheters have a reverse taper design;
  • Each catheter configuration has one power injectable lumen;
  • Catheter shaft tubing is marked with depth indicators, with "0" indicated to serve as a reference for the catheter insertion point;
  • Catheters are provided sterile in basic interventional radiology (IR), and basic, full, and max barrier nursing PICC configurations with legally marketed kit components;
  • Purple colorant is included in the catheter material to provide the catheter with an appearance that allows the end user to differentiate Bard's power injectable catheters from other manufacturers' power injectable catheters;
  • Yellow colorant was added to the catheter junction material to provide the catheter with an appearance that allows the end user to differentiate Bard's ethanol compatible catheters from other catheters not compatible with ethanol;
  • The catheter extension leg, luer hub, junction, and clamp ID tags are printed with markings to identify the catheter as PowerPICC® EtOH or PowerPICC SOLO®2 EtOH, and include information to facilitate proper use of the device; and
  • The PowerPICC® EtOH catheter clamp and PowerPICC SOLO®2 EtOH luer are labeled with EtOH to indicate ethanol compatibility.

The following device descriptors apply to all French sizes of the subject Bard Access Systems PowerPICC® EtOH Catheters:

  • Yellow colorant was added to the catheter extension leg clamp material to provide the catheter with an appearance that allows the end user to differentiate Bard's ethanol compatible catheter from other catheters that are not compatible with ethanol.

The following device descriptors apply to all French sizes of the subject Bard Access Systems PowerPICC SOLO®2 EtOH Catheters:

  • The PowerPICC SOLO®2 EtOH catheter is a clampless, proximally valved catheter, and
  • Yellow colorant was added to the lower portion of the luer hub to identify the catheter as a PowerPICC SOLO®2 EtOH catheter that is ethanol compatible.

The following device descriptors apply to specific French sizes of the subject Device Bard Access Systems PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Description Catheters:

  • The 5F TL catheter product labeling warns against power injection procedures through the two small lumens,
  • The 5F TL catheter's usable length is 50 cm,
  • The 5F DL FT and 4F SL catheter's usable length is 55 cm,
  • The 5 F DL FT catheter has a double taper design, and
  • The 5 F DL FT catheter product labeling warns against trimming the catheter in the "No Trim Zone" to maintain product functionality.
AI/ML Overview

The provided FDA submission for the PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters does not contain a table of acceptance criteria and reported device performance in the typical format one might expect for a detailed performance study. Instead, it states that "The subject devices met all predetermined acceptance criteria derived from the above listed references and demonstrated substantially equivalent performance as compared to the cited predicate devices."

The submission describes the types of tests performed and the standards referenced, implying that the acceptance criteria are linked to these standards and the performance of the predicate device. However, it does not explicitly list the specific numerical acceptance criteria (e.g., "burst pressure > X psi") or the exact reported performance values.

Here's a breakdown of the requested information based on the provided text:


1. Table of Acceptance Criteria and Reported Device Performance

As mentioned above, a direct table is not present. The document generally states that "The subject devices met all predetermined acceptance criteria... and demonstrated substantially equivalent performance." The acceptance criteria would have been derived from the referenced standards and safety/performance tests.

Acceptance Criteria CategoryGeneral Description of Acceptance Criteria (Inferred from context)Reported Device Performance
Material/Catheter PropertiesConformance to specifications for open-ended, radiopaque polyurethane, reverse taper design, depth indicators, colorants, markings.Met all predetermined acceptance criteria.
Mechanical PerformanceDemonstrated appropriate assembly leak, tensile strength, elongation, modulus, fatigue, ISO Luer compliance, burst pressure, radiopacity, catheter leak under vacuum, and valve function.Met all predetermined acceptance criteria.
FunctionalityDemonstrated required gravity flow, priming volume, power injection capability, central venous pressure monitoring, stylet compatibility, and ink adherence.Met all predetermined acceptance criteria.
BiocompatibilityConformance to ISO 10993 series for cytotoxicity, pyrogenicity, subacute/subchronic toxicity, sensitization, irritation/intracutaneous reactivity, acute systemic toxicity, subchronic/subcutaneous implant toxicity, genotoxicity, implantation studies, hemolysis, prothrombin time, unactivated thromboplastin time, dog thrombogenicity, platelet and leukocyte counts, and compliment activation, chronic toxicity.Met all predetermined acceptance criteria.
Sterilization & PackagingConformance to ISO 11135 and ISO 11607 standards for validation and routine control of ethylene oxide sterilization and packaging requirements.Met all predetermined acceptance criteria.
Risk ManagementConducted in accordance with ISO 14971:2012.Successfully completed.

2. Sample size used for the test set and the data provenance

  • Sample Size: Not explicitly stated for any of the tests. The document mentions "Verification and validation tests have been performed," but does not provide specific sample quantities (e.g., number of catheters tested for burst pressure).
  • Data Provenance: The tests are referred to as "in-house protocols" performed by Bard Access Systems. The country of origin is not specified but implicitly would be the USA given the company's address and FDA submission. The nature of these tests (retrospective or prospective) is not discussed but for device performance tests, they would inherently be prospective (i.e., conducted on newly manufactured devices).

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This type of information (expert review for ground truth) is typically relevant for AI/ML device submissions, particularly those involving image analysis or diagnostic interpretation. For a physical medical device like a catheter, "ground truth" is established by direct physical, chemical, and biological testing against established standards and validated methods. Therefore, this section is not applicable in the context of this device and submission. The "experts" would be the engineers, scientists, and technicians conducting and evaluating the performance and safety tests, and their qualifications are not detailed in this submission.

4. Adjudication method for the test set

Similarly, adjudication methods (like 2+1 or 3+1 consensus) are typically for subjective interpretations, such as clinical reads in AI/ML performance studies. For physical device performance tests, the results are generally objective and quantitative (e.g., a burst pressure value). Therefore, an explicit adjudication method is not applicable to the performance and safety tests described here. Results are evaluated against predetermined acceptance criteria.

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

An MRMC study is relevant for AI-assisted diagnostic devices. This submission pertains to a physical intravascular catheter. Therefore, an MRMC study was not conducted, and this section is not applicable.

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

This refers to the performance of an AI algorithm without human involvement. Since this is a physical medical device, not an AI/ML algorithm, a standalone algorithm performance study was not applicable and therefore not done.

7. The type of ground truth used

For this physical medical device, the "ground truth" for showing it meets acceptance criteria is established through:

  • Engineering Specifications: Conformance to dimensional tolerances, material composition, etc.
  • Validated Test Methods: The results of performance tests (e.g., burst pressure, flow rate, tensile strength) conducted according to recognized industry standards (ISO, ASTM) and internal protocols.
  • Biocompatibility Standards: Assessment against the criteria outlined in the ISO 10993 series for biological safety.
  • Predicate Device Performance: The primary comparison for substantial equivalence relies on demonstrating that the new device performs similarly to or better than legally marketed predicate devices, especially for existing functionalities. For new functionalities (like ethanol compatibility), dedicated tests (e.g., material degradation after ethanol exposure, though not explicitly detailed here) would establish its ground truth against the claim.

8. The sample size for the training set

This question relates to the development of AI/ML models. Since this submission is for a physical medical device and does not involve AI/ML, there is no training set in this context, and thus no sample size for a training set.

9. How the ground truth for the training set was established

Again, this is applicable to AI/ML device development. As there is no AI/ML component, there is no training set and therefore no ground truth established for a training set in this context.

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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 features a stylized representation of three human profiles facing right, stacked on top of each other. The profiles are rendered in a dark color, creating a silhouette effect. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the emblem.

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

June 14, 2016

C.R. Bard, Inc. Mr. Bryan Stone Regulatory Affairs Specialist 605 North 5600 West Salt Lake City, UT 84116

Re: K151985

Trade/Device Name: PowerPICC® EtOH Catheter and PowerPICC SOLO82 EtOH Catheter Regulation Number: 21 CFR 880.5970 Regulation Name: Percutaneous, implanted, long-term intravascular catheter Regulatory Class: II Product Code: LJS Dated: May 25, 2016 Received: May 26, 2016

Dear Mr. Stone:

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.

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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 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/Resourcesfor You/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,

Tina
Kiang -S

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

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known)

K151985

Device Name PowerPICC®EtOH Catheter

Indications for Use (Describe)

The PowerPICC®EtOH Catheter is indicated for short- or long-term peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

Catheter SizeMaximum FlowRate
4F Single Lumen5 ml/sec
5F Dual Lumen5 ml/sec
5F Triple Lumen4 ml/sec

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration

Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

PSC Publishing Services (301)

443-6740

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known)

K151985

Device Name PowerPICC SOLO®2 EtOH Catheter

Indications for Use (Describe)

The PowerPICC SOLO® EtOH Catheter is indicated for short- or long-term peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

Catheter SizeMaximum FlowRate
4F Single Lumen5 ml/sec
5F Dual Lumen5 ml/sec
5F Triple Lumen4 ml/sec

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

网 Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration

Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

EF

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

PSC Publishing Services (301)

443-6740

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Image /page/4/Picture/0 description: The image shows the logo for BARD ACCESS SYSTEMS. The word "BARD" is in a bold, sans-serif font, with the letter "A" stylized as an upside-down "V". Below the word "BARD" is the text "ACCESS SYSTEMS" in a smaller, sans-serif font.

510(k) Summary 21 CFR 807.92(a)

GeneralProvisionsSubmitter Name:Bard Access Systems, Inc.
Address:605 North 5600 WestSalt Lake City, UT 84116
Contact Person:Bryan StoneRegulatory Affairs Specialist II
Telephone Number:(801) 522-5876
Fax Number:(801) 522-5425
Date of Preparation:June 30, 2015
SubjectDevicesTrade Name:PowerPICC® EtOH CatheterandPowerPICC SOLO®2 EtOH Catheter
Common Name:Catheter, Intravascular, Therapeutic, Long-termGreater than 30days
Classification Name:Percutaneous, Implanted, Long -term intravascularcatheter
Product Code/Regulation:LJS/21 CFR §880.5970
PredicateDevicesPredicate Trade Name:5F DL PowerPICC® Catheter
Classification Name:Percutaneous, Implanted, Long -term intravascularcatheter
Premarket Notification:K051672
Manufacturer:Bard Access Systems, Inc.
Predicate Trade Name:6F TL PowerPICC® Catheter
Classification Name:Percutaneous, Implanted, Long -term intravascularcatheter
Premarket Notification:K053501
Manufacturer:Bard Access Systems, Inc.
Predicate Trade Name:4F Single Lumen (SL) PowerPICC® Catheter
Classification Name:Percutaneous, Implanted, Long -term intravascularcatheter
Premarket Notification:K070996
Manufacturer:Bard Access Systems, Inc.

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Predicate Trade Name:PowerPICC SOLO® Catheter Family
Classification Name:Percutaneous, Implanted, Long-term intravascularcatheter
Premarket Notification:K072230
Manufacturer:Bard Access Systems, Inc.

Bard Access Systems, Inc.'s PowerPICC® EtOH and PowerPICC SOLO® EtOH Catheters are sterile, single use devices designed to provide access to the patient's vascular system. The devices are intended for short- or long-term use (>30 days) to sample blood and administer fluids intravenously. The catheters are compatible with intraluminal solutions containing up to 70% ethanol, capable of central venous pressure monitoring, and can withstand power injection of contrast media. The catheters are peripherally inserted central catheters (PICC) and utilize the same placement technique as the predicate devices.

The subject devices included in this notification are of varying French size and catheter configuration types, as summarized in the table below.

Device Description

Summary of Subject Devices
Catheter ConfigurationFrench size (Number of Lumens)
PowerPICC® EtOH4F (Single Lumen (SL))
5F (Dual Lumen (DL)) FT
5F (Triple Lumen (TL))
PowerPICC SOLO®2 EtOH4F (Single Lumen (SL))
5F (Dual Lumen (DL)) FT
5F (Triple Lumen (TL))

The subject catheters will be packaged with legally marketed components used in the placement procedure.

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The subject devices included in this bundled 510(k) notification are of varying French size and catheter configuration types, and as such, the device descriptions are grouped and organized to capture catheter similarities.

The following device descriptors apply to all French sizes and configurations of the subject Bard Access PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters:

  • The catheters are open-ended, radiopaque polyurethane;
  • The catheters have a reverse taper design;
  • Each catheter configuration has one power injectable lumen;
  • Catheter shaft tubing is marked with depth indicators, with "0" ● indicated to serve as a reference for the catheter insertion point;
  • Catheters are provided sterile in basic interventional radiology (IR), and basic, full, and max barrier nursing PICC configurations with legally marketed kit components;
  • . Purple colorant is included in the catheter material to provide the catheter with an appearance that allows the end user to differentiate Bard's power injectable catheters from other manufacturers' power injectable catheters;
  • . Yellow colorant was added to the catheter junction material to provide the catheter with an appearance that allows the end user to differentiate Bard's ethanol compatible catheters from other catheters not compatible with ethanol;
  • . The catheter extension leg, luer hub, junction, and clamp ID tags are printed with markings to identify the catheter as PowerPICC® EtOH or PowerPICC SOLO®2 EtOH, and include information to facilitate proper use of the device; and
  • The PowerPICC® EtOH catheter clamp and PowerPICC SOLO®2 EtOH . luer are labeled with EtOH to indicate ethanol compatibility.

The following device descriptors apply to all French sizes of the subject Bard Access Systems PowerPICC® EtOH Catheters:

  • Yellow colorant was added to the catheter extension leg clamp material to provide the catheter with an appearance that allows the end user to differentiate Bard's ethanol compatible catheter from other catheters that are not compatible with ethanol.
    Device Description

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The following device descriptors apply to all French sizes of the subject Bard Access Systems PowerPICC SOLO®2 EtOH Catheters:

  • The PowerPICC SOLO®2 EtOH catheter is a clampless, proximally valved catheter, and
  • Yellow colorant was added to the lower portion of the luer hub to ● identify the catheter as a PowerPICC SOLO®2 EtOH catheter that is ethanol compatible.

The following device descriptors apply to specific French sizes of the subject Device Bard Access Systems PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Description Catheters:

  • . The 5F TL catheter product labeling warns against power injection procedures through the two small lumens,
  • . The 5F TL catheter's usable length is 50 cm,
  • The 5F DL FT and 4F SL catheter's usable length is 55 cm, ●
  • . The 5 F DL FT catheter has a double taper design, and
  • . The 5 F DL FT catheter product labeling warns against trimming the catheter in the "No Trim Zone" to maintain product functionality.

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Intended Use

The PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters are intended for short- or long-term peripheral access to the central venous system for intravenous therapy and blood sampling.

PowerPICC® EtOH Catheter:

The PowerPICC®EtOH Catheter is indicated for short- or long-term peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

Catheter SizeMaximum Flow Rate
4F Single Lumen5 ml/sec
5F Dual Lumen5 ml/sec
5F Triple Lumen4 ml/sec

Indications For Use

PowerPICC SOLO®2 EtOH Catheter:

The PowerPICC SOLO®2 EtOH Catheter is indicated for short- or longterm peripheral access to the central venous system for intravenous therapy including prolonged exposure to intraluminal solutions containing up to 70% ethanol, power injection of contrast media, and allows for central venous pressure monitoring. For blood sampling, infusion, or therapy, use a 4 French or larger catheter. For central venous pressure monitoring, it is recommended that a catheter lumen of 20 gauge or larger be used.

Catheter SizeMaximum Flow Rate
4F Single Lumen5 ml/sec
5F Dual Lumen5 ml/sec
5F Triple Lumen4 ml/sec

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Technological characteristics of the subject PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters are substantially equivalent with respect to basic design and function to those of the predicate devices, PowerPICC® (K051672, K053501, and K070996; concurrences November 23, 2005, January 13, 2006, and May 8, 2007, respectively) by Bard Access Systems and PowerPICC SOLO® (K072230, concurrence October 5, 2007) by Bard Access Systems. The subject devices differ in technological characteristics when compared to the predicate devices, and include a change in material formulation, dimensional design, and indications for use.

Technological Characteristics

The indications for use of the subject devices are different compared to the predicate devices in that the subject devices are indicated for prolonged exposure to intraluminal solutions containing up to 70% ethanol. This difference in the indications for use does not alter the intended use of the device (ie., short- or long-term peripheral access to the central venous system for intravenous therapy and blood sampling). The purpose of this information is to clarify to the user the catheter's compatibility with ethanol; it does not prescribe a different general purpose or function of the device, nor does it prescribe a different patient population, therapeutic or diagnostic use of the subject device compared to the predicate device. This technological difference, as well as differences in material formulation and dimensional design, was evaluated using the same test requirements as the predicate devices, as defined in the Risk Assessment. Therefore, these differences in technological characteristics between the subject and predicate devices do not raise different questions of equivalence.

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Verification and validation tests have been performed in accordance with Design Controls as per 21 CFR §820.30. The following guidance documents and standards in conjunction with in-house protocols were used to determine appropriate methods for evaluating the performance of the device:

  • · Guidance on Premarket Notification [510(k)] Submission for Short-Term and Long-Term Intravascular Catheters, March 16, 1995
  • ISO 10555-1: 2013, Sterile, sinqle-use intravascular catheters, Part 1: General requirements
  • ISO 10555-3: 2013, Intravascular catheters--Sterile and single-use catheters, Part 3: Central venous catheters
  • · ISO 594-1: 1986, Conical fittings with 6% luer taper for syringes, needles and certain other medical equipment – Part 1: General Requirements
  • · ISO 594-2: 1998, Conical fittings with 6% luer taper for syringes, needles and certain other medical equipment – Part 2: Lock Fittings
  • ISO 10993-1:2009, Biological Evaluation of Medical Devices Part 1: Evaluation and Testing, and the FDA Modified ISO 10993 Test Profile
  • FDA Draft Guidance Use of International Standards ISO 10993 Biological Evaluation of Medical Devices Part 1: Evaluation and Testing (2013)
  • ISO 10993-7:2008, Biological Evaluation of Medical Devices Part 7: Ethylene Oxide Sterilization Residuals
  • ISO 11135:2014, Medical Devices Validation and Routine Control of Ethylene Oxide Sterilization
  • ASTM F640-79 (reapproved 2000): 2012, Standard Test Methods for Radiopacity of Plastics for Medical Use
  • Design Control Guidance for Medical Device Manufacturers, March 11, 1997
  • · ISO 11607-1: 2006, Packaging for terminally sterilized medical devices – Part 1: Requirements for materials, sterile barrier systems and packaging systems
  • ISO 11607-1 AMD 1: 2014, Packaging for terminally sterilized medical devices – Part 1: Requirements for materials, sterile barrier systems and packaqing systems

Safety & Performance Tests

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The subject devices met all predetermined acceptance criteria derived from the above listed references and demonstrated substantially equivalent performance as compared to the cited predicate devices.

Risk management, including a failure modes and effects analysis (FMEA), of the subject device was conducted in accordance with ISO 14971:2012, Medical Devices – Risk Management for Medical Devices.

Performance Testing- Bench:

  • . Dimensional Analysis
  • . Assembly Leak
  • . Tensile Strength
  • . Catheter Elongation and Modulus
  • . Catheter Fatigue
  • ISO Luer Compliance
  • Visual Inspection
  • Gravity Flow
  • Priming Volume
  • Power Injection
  • Burst
  • Radiopacity ●
  • Catheter Leak Under Vacuum
  • Central Venous Pressure Monitoring ●
  • . Stylet Compatibility
  • Ink Adherence
  • . Valve Function

Biocompatibility Testing:

  • Cytotoxicity
  • Pyrogenicity
  • Subacute/Subchronic Toxicity ●
  • Sensitization
  • Irritation/Intracutaneous Reactivity
  • . Acute Systemic Toxicity
  • Subchronic/Subcutaneous Implant Toxicity
  • Genotoxicity Testing
  • . Implantation studies (2-26 week)
  • Hemolysis ●
  • Prothrombin Time Assay
  • Unactivated Thromboplastin Time Assay
  • . Dog Thrombogenicity
  • Platelet and Leukocyte Counts

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  • Compliment Activation .
  • Chronic Toxicity .

Summary of Substantial Equivalence

Based on the intended use, technological characteristics, and safety and performance testing, the subject PowerPICC® EtOH and PowerPICC SOLO®2 EtOH Catheters met the requirements that are considered sufficient for the intended use and are as safe and as effective as predicate devices cited.

§ 880.5970 Percutaneous, implanted, long-term intravascular catheter.

(a)
Identification. A percutaneous, implanted, long-term intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings, such as luer hubs, and accessories that facilitate the placement of the device. The device allows for repeated access to the vascular system for long-term use of 30 days or more, and it is intended for administration of fluids, medications, and nutrients; the sampling of blood; and monitoring blood pressure and temperature. The device may be constructed of metal, rubber, plastic, composite materials, or any combination of these materials and may be of single or multiple lumen design.(b)
Classification. Class II (special controls) Guidance Document: “Guidance on Premarket Notification [510(k)] Submission for Short-Term and Long-Term Intravascular Catheters.”