K Number
K161779
Date Cleared
2016-11-03

(127 days)

Product Code
Regulation Number
880.5200
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafety IV Catheter is indicated to sample blood or administer fluids intravenously. The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter may be used for any patient population with consideration given to adequacy for the vascular anatomy appropriateness for the solution being administered and duration of the therapy.

Device Description

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter are safety medical devices used for inserting a catheter into a patient's body for purpose of delivery of fluids or drainage of fluids from the patient. The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter are comprised of the following components: protective needle cover, color-coded catheter hub, radiopaque catheter tube, catheter holder, needle guide, medical grade stainless steel needle hub, porous plug and gauge chamber. The components combine for an ergonomic design that incorporate a safety feature that when the device is withdrawn, the needle is completely enclosed within the chamber protecting healthcare and other personnel from exposure to patient body fluids after the device has been discarded post-use. The retraction mechanism is activated by the push of a button.

AI/ML Overview

This document describes the safety and performance testing for the MedSource TrueSafe Safety IV Catheter and MedSource TrueSafe Comfort Safety IV Catheter.

1. Table of Acceptance Criteria and Reported Device Performance:

Test PerformedCriteriaResult
Needle PointFree from foreign parts with no blunt needles or dentsPass
Flow Rate Through CatheterFlow rate should be 55ml/minPass
Corrosion Resistance TestThere shall be no sign of corrosionPass
Method for Determining Tensile Force at BreakMinimum force at break shall be $\geq 5N$Pass
Catheter Collapse Through Aspiration TestThere shall be no ingress of air bubbles into the syringePass
Gauging TestNO-GO side of the steel gauge should not be inside the luer.Pass
Liquid Leakage From Conical Fitting Assembly Under PressureNo liquid leakage should be there, when the assembly is subjected to withstand a pressure of 3.0 to 3.2 bar for 30sec.Pass
Air Leakage from the Conical Fitting Assembly During AspirationThere should be no air bubble formation from the assembly up to 15sec.Pass
Separation Force of Conical Fitting AssemblyThere should be no detachment while applying a force of 10 newtons away from the fixture.Pass
Stress CrackingThere should not be any sign of cracking in the device luer fittingPass
Unscrewing Torque of Fitting AssemblyThere shall be no separation when the fitting is testedPass
Ease of AssemblyMale reference fitting should insert without any jerk and fit together securely.Pass
Resistance to OverridingThere shall not be any unusual damage on either of the female part or to the reference fitting.Pass
Radiopacity of CatheterVisually compare the images of the test specimen to the background on the film.Pass
Catheter Elongation TestingMeasure the gauge length and tensile strength at breakPass
Catheter Stiffness TestingAs per manufacturer data, Shore: D-60 ± 4Pass
Resistance to DisinfectionNo visual damage shall be present. As per ISO 527, the catheter shall show no degradation in tensile properties. Catheter tube elongation should be greater than 100% (as in control i.e., non-exposed samples)Pass
Needle Hub Detachment Force20N when testing needles of nominal O.D $\geq$ 0.6 mmPass
Needle Safety Mechanism Activation TestCheck whether the activation Lever activated smoothly without any jerk and check the complete length of the needle enclose to the safety chamber.Pass
Venipuncture Process: Needle Stick (Max Penetration Load)14G: 2.70N; 16G: 2.50N; 17G: 2.40N; 18G: 1.90N; 20G: 1.60N; 22G: 1.50N; 24G: 1.35N; 26G: 1.30NPass
Venipuncture Process: Needle Stick (Max Friction)14G: 0.70N; 16G: 0.60N; 17G: 0.60N; 18G: 0.50N; 20G: 0.40N; 22G: 0.35N; 24G: 0.34N; 26G: 0.45NPass
Venipuncture Process: Tightness Between Catheter Tube and Cannula Activation TestingThe distance should not exceed maximum value of 1.0mm and should be greater than 0.1mm. 97.5% confidence that the failure rate would be no higher than 0.7% and 99.5% confident that the failure rate is not higher than 1.1%.Pass
Biocompatibility (Sensitization Testing)Standard ISO 10993 Part 10Pass
Biocompatibility (Intracutaneous Reactivity Test)Standard 10993 Part 5Pass
Biocompatibility (In-Vitro Cytotoxicity)Standard ISO 10003 Part 5Pass
Biocompatibility (Systemic Toxicity)Standard ISO 10993 Part 11Pass
Biocompatibility (Hemocompatibility Test)Standard ISO 10993-1Pass

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

The document mentions several types of testing:

  • Nonclinical Bench Performance testing: The specific sample sizes for each of the listed bench tests (e.g., flow rate, corrosion, tensile strength) are not explicitly provided in the summary. However, these are generally performed on a sufficient number of units to demonstrate compliance with the referenced ISO standards.
  • Simulated Clinical Use Testing: This test used a sample size of 500 units.
  • Data Provenance: The document does not specify the country of origin of the data or whether the studies were retrospective or prospective. Given that it's a 510(k) submission and the tests are bench and simulated clinical use, they are inherently prospective in nature, performed specifically for regulatory submission.

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

For the nonclinical bench tests and simulated clinical use testing described, there is no mention of "experts" in the sense of medical professionals establishing a ground truth. These tests rely on predefined engineering and scientific criteria (e.g., ISO standards, physical measurements). The "ground truth" for these tests is the objective measurement against the specified criteria.

4. Adjudication Method for the Test Set:

Not applicable. The tests described are objective, quantitative measurements or visual assessments against predefined criteria from standards (e.g., ISO standards). There is no "adjudication" necessary between multiple observers or experts.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

No, an MRMC comparative effectiveness study was not conducted or reported in this document. This submission focuses on the substantial equivalence of the device through bench and simulated use testing, not on comparative effectiveness with human readers.

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

Not applicable. This device is a physical medical device (an IV catheter), not an algorithm or AI system. Therefore, standalone algorithm performance is not relevant.

7. The Type of Ground Truth Used:

The ground truth for the performance tests is based on:

  • Established engineering and performance standards: Primarily ISO 10555-1 and ISO 10555-5 for mechanical and functional aspects, and ISO 10993 series for biocompatibility.
  • Objective physical measurements: For parameters like flow rate, tensile force, needle stick force, distance measurements, etc.
  • Visual inspection criteria: For aspects like needle point defects, corrosion, and resistance to disinfection.
  • Pre-defined pass/fail criteria: For all tests, specific thresholds or observations determine a "Pass" or "Fail."

8. The Sample Size for the Training Set:

Not applicable. This device is a physical product and not an AI/ML algorithm that requires a "training set."

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

Not applicable, as there is no training set for this physical device.

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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 stylized eagle with three heads facing to the right. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular fashion around the eagle.

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

November 3, 2016

MedSource International, LLC Ms. Laura Riggen Ouality & Regulatory Affairs Manager 401 Norex Drive Chaska, Minnesota 55318

Re: K161779

Trade/Device Name: MedSource TrueSafe Safety IV Catheter and MedSource TrueSafe Comfort Safety IV Catheter Regulation Number: 21 CFR 880.5200 Regulation Name: Intravascular Catheter Regulatory Class: II Product Code: FOZ Dated: October 4, 2016 Received: October 6, 2016

Dear Ms. Laura Riggen:

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 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,

Tina Kiang -S

Tina Kiang, Ph.D. Acting 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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Indications for Use

510(k) Number (if known) K161779

Device Name

MedSource TrueSafe Safety IV Catheter and MedSource TrueSafe Comfort Safety IV Catheter

Indications for Use (Describe)

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafety IV Catheter is indicated to sample blood or administer fluids intravenously. The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter may be used for any patient population with consideration given to adequacy for the vascular anatomy appropriateness for the solution being administered and duration of the therapy.

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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FOR FDA USE ONLY

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510(K) Summary

Medsource International, LLC Submitter: 4201 Norex Drive Chaska, MN 55318

Contact Person: Laura Riggen, Quality and Regulatory Affairs Manager 4201 Norex Drive Chaska, MN 55318 Phone: 952-472-0131

Date Prepared: November 2, 2016

General Information:

Common Name: Catheter, intravascular, therapeutic, short-term Regulatory Reference: 21 CFR §880.5200 Regulation Name: Intravascular Catheter Product Code: FOZ Classification: Class II Panel: General Hospital Proprietary Name: MedSource TrueSafe Safety IV Catheter and MedSource TrueSafe Comfort Safety IV Catheter Predicate Device: MedSource IV Safety Catheter, K131555

Indications for Use:

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter is indicated to sample blood or administer fluids intravenously. The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter may be used for any patient population with consideration given to adequacy for the vascular anatomy appropriateness for the solution being administered and duration of the therapy.

Description of the Device:

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter are safety medical devices used for inserting a catheter into a patient's body for purpose of delivery of fluids or drainage of fluids from the patient.

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter are comprised of the following components: protective needle cover, color-coded catheter hub, radiopaque catheter tube, catheter holder, needle guide, medical grade stainless steel needle hub, porous plug and gauge chamber. The components combine for an ergonomic design that incorporate a safety feature that when the device is withdrawn, the needle is completely enclosed within the chamber protecting healthcare and other personnel from exposure to patient body fluids after the device has been discarded post-use. The retraction mechanism is activated by the push of a button.

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Part NumberModel DescriptionColor
MS-84414TrueSafe Safety IV Catheter 14 Gauge x 1.75"Orange
MS-84416TrueSafe Safety IV Catheter 16 Gauge x 1.77"Gray
MS-84418TrueSafe Safety IV Catheter 18 Gauge x 1.88"Green
MS-844182TrueSafe Safety IV Catheter 18 Gauge x 1.16"Green
MS-84420TrueSafe Safety IV Catheter 20 Gauge x 1.88"Pink
MS-844202TrueSafe Safety IV Catheter 20 Gauge x 1.16"Pink
MS-84422TrueSafe Safety IV Catheter 22 Gauge x 1.00"Blue
MS-84424TrueSafe Safety IV Catheter 24 Gauge x 0.75"Yellow
MS-84314TrueSafe Comfort Safety IV Catheter 14 Gauge x 1.75"Orange
MS-84316TrueSafe Comfort Safety IV Catheter 16 Gauge x 1.77"Gray
MS-84318TrueSafe Comfort Safety IV Catheter 18 Gauge x 1.88"Green
MS-843182TrueSafe Comfort Safety IV Catheter 18 Gauge x 1.16"Green
MS-84320TrueSafe Comfort Safety IV Catheter 20 Gauge x 1.88"Pink
MS-843202TrueSafe Comfort Safety IV Catheter 20 Gauge x 1.16"Pink
MS-84322TrueSafe Comfort Safety IV Catheter 22 Gauge x 1.00"Blue
MS-84324TrueSafe Comfort Safety IV Catheter 24 Gauge x 0.75"Yellow

The device is available in six gauges identified also by specific colors.

Description of the Device Design:

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort IV Safety Catheter are substantially equivalent to the MedSource Safety Catheter (K131555).

Submission Device ↓Predicate Device ↓Comparison ↓
Comparison Point ↓MedSourceTrueSafe Safety IVCatheter andMedSourceTrueSafe ComfortSafety IV CatheterMedSource IV SafetyCatheter (K131555)
Technology
Mode of OperationAseptic technique,proper skinpreparation andcontinued protectionof the side areessential. ObserveUniversal Precautionson ALL patients.Aseptic technique,proper skin preparationand continuedprotection of the sideare essential. ObserveUniversal Precautionson ALL patients.Same
A. Remove needlecover in a straightoutward motion andinspect catheter unit.Rotate catheter 360°.cover in a straightoutward motion andinspect catheter unit.Rotate catheter 360°.
B. Performvenipuncture.B. Performvenipuncture.
C. Observe bloodreturn. Blood returnwill also be visiblethrough the catheter.Lower and advancecatheter unit 1/8".C. Observe bloodreturn. Blood returnwill also be visiblethrough the catheter.Lower and advancecatheter unit 1/8".
D. Holding the flashchamber stationary,advance the catheteroff the needle into thevein.D. Holding the flashchamber stationary,advance the catheter offthe needle into the vein.
E. Beforewithdrawing needlefrom the catheter,depress button toretract the needle intothe clear safetyshield.Immediately discardunit in a punctureresistant, leak proofsharps container.If needle retractiondoes not occur,depress button again.Dispose of anyunshielded needlesimmediately.Keep needlepointaway from body andfingers at all times.F. Connect tubing oradapter.G. Secure CatheterE. Before withdrawingneedle from thecatheter, depress buttonto retract the needleinto the clear safetyshield.Immediately discardunit in a punctureresistant, leak proofsharps container.If needle retractiondoes not occur, depressbutton again. Disposeof any unshieldedneedles immediately.Keep needlepoint awayfrom body and fingersat all times.F. Connect tubing oradapter.G. Secure Catheter

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Distal EndconfigurationBeveledBeveledSame
Proximal EndconfigurationCupperCupperSame
Needle StickPrevention FeaturePush-button needleshieldingPush-button needleshieldingSame
Catheter LengthCatheter O.D.Needle GaugeGauge Length ODmm mm24G 19 0.722G 25 0.920G 25 1.118G 25 1.316G 30 1.714G 45 2.1Gauge Length ODmm mm24G 19 0.722G 25 0.920G 25 1.118G 25 1.316G 30 1.714G 45 2.1Same
SterilizationMethodETOETOSame
Sterility AssuranceLevel (SAL)10-610-6Same
Shelf Life5 Years5 YearsSame
Materials
CatheterPUR/PTFEPUR/PTFESame
NeedleStainless StealStainless StealSame
Catheter BodyK-ResinK-ResinSame
Catheter HolderPolyacetal (POM)Polyacetal (POM)Same
Needle HubK-ResinK-ResinSame
Activation LeverPolyacetal (POM)Polyacetal (POM)Same
FlashbackChamberABSABSSame
Hydrophobic FilterPoly-ethylenePoly-ethyleneSame

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Differences to Predicate Device

The MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter has a notched-needle design to allow for instant blood flash while inserting the needle. This gives the caregiver an instant indication of vein penetration. A push off tab was added to the catheter hub to allow for a more careful insertion on the catheter. The Needle cover was modified for a better fit on the device to eliminate unintended activations. The differences do not raise new questions of safety and effectiveness as the differences enhance the products features. The instant blood flash and the push off tab enhance the care giver experience and allow for better insertion and vein penetration.

Nonclinical Tests

Nonclinical Bench Performance testing was performed to show that the MedSource TrueSafe Safety IV Catheter meets the standards set forth in ISO 10555-1: Sterile, singleuse intravascular Catheter-General Requirements and ISO 10555-5: Sterile, single-use, intravascular Catheter-Over needle peripheral catheter.

Test PerformedCriteriaResult
Needle PointFree from foreign parts with no blunt needles or dentsPass
Flow RateThroughCatheterFlow rate should be 55ml/minPass
CorrosionResistance TestThere shall be no sign of corrosionPass
Method forDeterminingTensile Force atBreakMinimum force at break shall be $≥ 5N$Pass
CatheterCollapseThroughAspiration TestThere shall be no ingress of air bubbles in to the syringePass
Gauging TestNO-GO side of the steel gauge should not be inside the luer.Pass
Liquid LeakageFrom ConicalFitting AssemblyUnder PressureNo liquid leakage should be there, when the assembly issubjected to withstand a pressure of 3.0 to 3.2 bar for 30sec.Pass
Air Leakagefrom the ConicalFitting AssemblyDuringThere should be no air bubble formation from the assemblyup to 15sec.Pass

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Aspiration
Separation Forceof ConicalFitting AssemblyThere should be no detachment while applying a force of 10newtons away from the fixture.Pass
Stress CrackingThere should not be any sign if cracking in the device luerfittingPass
UnscrewingTorque of FittingAssemblyThere shall be no separation when the fitting is testedPass
Ease ofAssemblyMale reference fitting should insert without any jerk and fittogether securely.Pass
Resistance toOverridingThere shall not be any unusual damage on either of thefemale part or to the reference fitting.Pass
Radiopacity ofCatheterVisually compare the images of the test specimen to thebackground on the film.Pass
CatheterElongationTestingMeasure the gauge length and tensile strength at breakPass
CatheterStiffness TestingAs per manufacturer data, Shore: D-60 ± 4Pass
Resistance toDisinfectionNo visual damage shall be present. As per ISO 527, thecatheter shall show no degradation in tensile properties.Catheter tube elongation should be greater than 100% ( as incontrol i.e., non-exposed samples)Pass
Needle HubDetachmentForce20N when testing needles of nominal O.D ≥ 0.6 mmPass
Needle SafetyMechanismActivation TestCheck whether the activation Lever activated smoothlywithout any jerk and check the complete length of the needleenclose to the safety chamber.Pass
VenipunctureProcess: NeedleStickGAUGEMAX PENETRATION LOAD(Newton)MAX FRICTION(Newton)Pass
142.70N0.70N
162.50N0.60N
172.40N0.60N
181.90N0.50N
201.60N0.40N
221.50N0.35N
241.35N0.34N
261.30N0.45N
VenipunctureProcess:TightnessBetweenCatheter TubeThe distance should not exceed maximum value of 1.0mmand should be greater than 0.1mm.Pass

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and CannulaActivationTestingThat 97.5% of the time the failure rate would be no higherthan 0.7% and 99.5% confident that the failure rate is nothigher than 1.1%.Pass
BiocompatibilitySensitization Testing (Primary Skin Irritation)Standard ISO 10993 Part 10Pass
BiocompatibilityIntracutaneous Reactivity TestStandard 10993 Part 5Pass
BiocompatibilityIn-Vitro CytotoxicityStandard ISO 10003 Part 5Pass
BiocompatibilitySystemic ToxicityStandard ISO 10993 Part 11Pass
BiocompatibilityHemocompatibility TestStandard ISO 10993-1Pass

Simulated Clinical Use Testing

500 units were tested, 0 units failed to activate the safety feature. Based on that, it can be determined that 97.5% of the time the failure rate would be no higher than 0.7% and 99.5% confident that the failure rate is not higher than 1.1%

Conclusion:

As shown by data in the table above, there are no significant performance specification differences between the MedSource TrueSafe Safety IV Catheter and the MedSource TrueSafe Comfort Safety IV Catheter and the substantially equivalent device. Therefore, we conclude that the devices are substantially equivalent.

§ 880.5200 Intravascular catheter.

(a)
Identification. An intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings and that is inserted into the patient's vascular system for short term use (less than 30 days) to sample blood, monitor blood pressure, or administer fluids intravenously. The device may be constructed of metal, rubber, plastic, or a combination of these materials.(b)
Classification. Class II (performance standards).