K Number
K161640
Device Name
Penumbra System ACE 68 Reperfusion Catheter
Manufacturer
Date Cleared
2016-07-12

(28 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Penumbra Reperfusion Catheters and Separators As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid. middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Penumbra Aspiration Tubing As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Pump MAX. Penumbra Pump MAX The Penumbra Pump MAX is indicated as a vacuum source for Penumbra Aspiration Systems.
Device Description
The Penumbra System ACE 68 Reperfusion Catheter is a component to the currently available Penumbra System. The ACE 68 Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel in the neurovasculature. ACE 68 is provided sterile, non-pyrogenic, and intended for single use only.
More Information

No
The document describes a mechanical aspiration system for removing blood clots and does not mention any AI/ML components or capabilities.

Yes
The device is used for the revascularization of patients with acute ischemic stroke, which is a therapeutic intervention aimed at restoring blood flow.

No

Explanation: The device description and intended use clearly state that the Penumbra System components (catheters, separators, tubing, pump) are used for the "revascularization of patients with acute ischemic stroke" by aspirating thrombus. This is a therapeutic intervention, not a diagnostic one. The performance studies also focus on mechanical and physical properties relevant to its therapeutic function, not diagnostic accuracy.

No

The device description and performance studies clearly indicate this is a physical medical device (catheter) with associated hardware components (tubing, pump). There is no mention of software as the primary or sole component.

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 the revascularization of patients with acute ischemic stroke by physically removing blood clots from vessels. This is a therapeutic intervention performed in vivo (within the body).
  • Device Description: The description details a catheter and aspiration system designed to physically interact with and remove thrombus from blood vessels.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or compatibility testing.

IVD devices are used to perform tests in vitro (outside the body) on biological samples. This device is used in vivo to treat a medical condition.

N/A

Intended Use / Indications for Use

Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Pump MAX.

Penumbra Pump MAX
The Penumbra Pump MAX is indicated as a vacuum source for Penumbra Aspiration Systems.

Product codes

NRY

Device Description

The Penumbra System ACE 68 Reperfusion Catheter is a component to the currently available Penumbra System. The ACE 68 Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel in the neurovasculature. ACE 68 is provided sterile, non-pyrogenic, and intended for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries)

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

Bench-Top Testing. The physical and mechanical properties of the ACE 68 Reperfusion Catheter were assessed using standard test methods and pre-determined acceptance criteria. The following tests were performed and all tests passed successfully: Packaging Inspection, Dimensional/Visual, Kink Resistance, Markerband Visibility, Simulated Use (Intracranial Access, Vessel Access Entry Performance & Clot Removal), Particulate testing, Coating Integrity, Hub Air Aspiration, Static Burst Pressure Test, ACE 68 / Sheath or 8F Guide Catheter Friction Force, ACE 68 / 0.014 in. Guidewire Friction Force, Joint sections bond strength, Hub to shaft tensile strength, Hub to hypotube tensile strength, Elongation to failure, Torsion, Corrosion.

Shelf Life Testing. The device stability and packaging integrity of the ACE 68 Reperfusion Catheter were assessed using standard test methods and pre-determined acceptance criteria. Devices underwent transportation conditioning per ASTM D4169 and accelerated aging equal to 8 months. Results of successful testing verify the ACE 68 Reperfusion Catheter may be labeled with an 8-month shelf life.

Key Metrics

Not Found

Predicate Device(s)

K160449

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1250 Percutaneous catheter.

(a)
Identification. A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.(b)
Classification. Class II (performance standards).

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

July 12, 2016

Penumbra, Inc. Mr. Charles DeNault Regulatory Affairs Specialist III One Penumbra Place Alameda, California 94502

Re: K161640

Trade/Device Name: Penumbra System ACE 68 Reperfusion Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: June 13, 2016 Received: June 14, 2016

Dear Mr. DeNault:

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 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.

1

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,

Carlos L. Pena -S/A

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) K161640

Device Name

Penumbra System ACE 68 Reperfusion Catheter

Indications for Use (Describe)

Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid. middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Pump MAX.

Penumbra Pump MAX The Penumbra Pump MAX is indicated as a vacuum source for Penumbra Aspiration Systems.

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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1 510(k) Summary

(as required by 21 CFR 807.92)

Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Penumbra. Inc. is providing the summary of Substantial Equivalence for the Penumbra System® ACE™ 68 Reperfusion Catheter.

1.1 Sponsor/Applicant Name and Address

Penumbra, Inc. One Penumbra Place Alameda, CA 94502 USA

1.2 Sponsor Contact Information

Charles DeNault Regulatory Affairs Specialist III Phone: (510) 748-3302 FAX: (510) 217-6414 Email: cdenault(@penumbrainc.com

Date of Preparation of 510(k) Summary 1.3

June 13, 2016

Device Trade or Proprietary Name 1.4

Penumbra System® ACE™ 68 Reperfusion Catheter

1.5 Device Classification

Regulatory Class: II Classification Panel: Neurology Classification Name: Percutaneous Catheter Regulation Number: 21 CFR §870.1250 Product Code: NRY (Catheter, Thrombus Removal)

1.6 Predicate Devices

| 510(k)

NumberClearance DateName of Predicate DeviceName of Manufacturer
K160449May 25, 2016Penumbra System and Penumbra
Aspiration PumpPenumbra. Inc.
One Penumbra Place
Alameda, CA 94502 USA

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1.7 Predicate Comparison

Design modifications were made to the subject device. Changes include a reduction of the device markerband length as well as dimensional changes to the device PTFE liner, coil reinforcement filaments, and extrusions.

PredicateSubject
General
510(k) No.K160449K161640
ClassificationClass II, NRYSAME
IndicationPenumbra Reperfusion Catheters and
Separators
As part of the Penumbra System, the
Reperfusion Catheters and Separators are
indicated for use in the revascularization of
patients with acute ischemic stroke secondary to
intracranial large vessel occlusive disease
(within the internal carotid, middle cerebral -
M1 and M2 segments, basilar, and vertebral
arteries) within 8 hours of symptom onset.
Penumbra Aspiration Tubing
As part of the Penumbra System, the Penumbra
Sterile Aspiration Tubing is indicated to
connect the Penumbra Reperfusion Catheters to
the Penumbra Pump MAX.
Penumbra Pump MAX
The Penumbra Pump MAX is indicated as a
vacuum source for Penumbra AspirationSAME
MaterialsSystems.
Proximal hubGrilamid (TR55-LX)SAME
Strain Relief [Hub
Sleeve]Grilamid (TR55)SAME
Strain Relief304 Stainless Steel (SS)SAME
ID BandPolyolefin, PET yellow [black ink]SAME
LinerPTFESAME
Coil Reinforcement304V SS, Nitinol (55% Ni, 45% Ti)SAME
Proximal ExtrusionsVestamid, Pebax 72D, Pebax 55D/72D
blendSAME
Distal ExtrusionsPebax 63D, Pebax 55D, Pebax 40D/55D
Blend, Pebax 40D, Pebax 35D/40D Blend,
Pebax 35D, Tecoflex 80A/Pebax 35D,
Tecoflex 80A, Pellethane 80ASAME
Extrusion ColorantsClear/Natural or PurpleSAME
MarkerbandPlatinum/Iridium (90% Pt, 10% Ir)SAME
PredicateSubject
CoatingSRDX Harmony (proprietary)SAME
Dimensions
Proximal OD0.084 in. maxSAME
Proximal ID0.068 in. minSAME
Distal OD0.084 in. maxSAME
Distal ID0.068 in. minSAME
Effective Lengths115, 120, 125, 127, 132 cmSAME
Distal Flex Length30 cmSAME
Coating Length30 cmSAME
Tip ShapeStraightSAME
Accessories
Peelable SheathPTFESAME
Rotating Hemostasis
ValvePolycarbonate, silicone o-ringSAME
Shaping Mandrel0.038 in. OD stainless steelSAME
Packaging Materials
PouchPolyester/Polyethylene/TyvekSAME
Packaging HoopPolyethyleneSAME
Packaging Tray
(Kit configuration)Polyethylene terephthalate, PolystyreneSAME
Packaging CardPolyethyleneSAME
Display CartonSBS PaperboardSAME
Other
SterilizationEOSAME
Shelf-Life36 Months8 Months
UseSingle use, disposableSAME

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Image /page/5/Picture/0 description: The image shows the word "Penumbra" in red font. To the right of the word is a red circle with a white "P" inside. The logo is simple and modern. The font is sans-serif.

Device Description 1.8

The Penumbra System ACE 68 Reperfusion Catheter is a component to the currently available Penumbra System. The ACE 68 Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel in the neurovasculature. ACE 68 is provided sterile, non-pyrogenic, and intended for single use only.

Indications for Use 1.9

Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to

6

Penumbr

intracranial large vessel occlusive disease (within the internal carotid, middle cerebral -M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Pump MAX.

Penumbra Pump MAX

The Penumbra Pump MAX is indicated as a vacuum source for Penumbra Aspiration Systems.

1.10 Summary of Non-Clinical Data

As required under Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, a summary of any information regarding substantial equivalence of the devices follows.

Included in this section is a summary description of the testing, which substantiates the performance of the subject ACE 68 Reperfusion Catheter as well as its substantial equivalence to the predicate devices:

  • . Design Verification (Bench-Top Testing)
  • . Shelf Life Testing

The subject ACE 68 Reperfusion Catheters met all established requirements.

1.10.1 Design Verification (Bench-Top Testing)

The physical and mechanical properties of the ACE 68 Reperfusion Catheter were assessed using standard test methods and pre-determined acceptance criteria. The following tests were performed and all tests passed successfully:

AttributeSpecificationResults
Packaging InspectionConfirm the packaging and dimensions of the units meet all product specifications.Pass
Dimensional/Visualproduct specifications.Pass
Kink ResistanceNo kinking when formed in a defined radiusPass
Markerband VisibilityThe markerband is fluoroscopically visiblePass
Simulated Use (Intracranial
Access, Vessel Access Entry
Performance & Clot
Removal)Simulated use testing of the Reperfusion Catheter and Separator
was performed with accessory devices in an anatomical model
which simulated the tortuosity of the neurovasculature. Devices
were delivered through the tortuous anatomical model to
evaluate the effectiveness of the devices to remove clots and that
the Reperfusion Catheter does not collapse under vacuum.Pass
Particulate testing≥ 10 μm will be ≤ 6000 particles
≥ 25 μm will be ≤ 600 particlesPass

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Image /page/7/Picture/0 description: The image shows the word "Penumbra" in red font, followed by a red circle with a white "P" inside. The word "Penumbra" is written in a sans-serif font and is slightly bolded. The red circle with the white "P" is located to the right of the word "Penumbra" and is slightly smaller in size.

AttributeSpecificationResults
≥ 75 µm will be measured for informational purposes only
(FIPO)FIPO
≥ 125 µm will be measured for informational purposes only
(FIPO)FIPO
Coating IntegrityCoating has not delaminated, peeled, or flaked prior to or after
simulated use particulate testingPass
Hub Air AspirationNo leaks detected when vacuum is pulled on the injection lumenPass
Static Burst Pressure Test45 psi for 30 sec minimumPass
ACE 68 / Sheath or 8F
Guide Catheter Friction
ForceMinimum value per specificationPass
ACE 68 / 0.014 in.
Guidewire Friction ForceMinimum value per specificationPass
Joint sections bond strengthMinimum value per specificationPass
Hub to shaft tensile strengthMinimum value per specificationPass
Hub to hypotube tensile
strengthMinimum value per specificationPass
Elongation to failureElongation ≥ 5%Pass
TorsionNumber of turns will be recorded for informational purposes
only.FIPO
CorrosionNo visible corrosion on Reperfusion Catheter immediately after
corrosion testing procedurePass

1.10.2 Shelf Life Testing

The device stability and packaging integrity of the ACE 68 Reperfusion Catheter were assessed using standard test methods and pre-determined acceptance criteria. Devices underwent transportation conditioning per ASTM D4169 and accelerated aging equal to 8 months. Results of successful testing verify the ACE 68 Reperfusion Catheter may be labeled with an 8-month shelf life.

1.11 Summary of Substantial Equivalence

The subject Penumbra System ACE 68 Reperfusion Catheter is substantially equivalent to the predicate device with regard to intended use, operating principle, design concept, materials, shelf-life, packaging and sterilization processes.