K Number
K162667
Date Cleared
2017-05-11

(227 days)

Product Code
Regulation Number
884.6110
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Kitazato IUI Catheter is used for the introduction of washed spermatozoa into the uterine cavity through the cervix. Kitazato IUI Stylet is used to provide rigidity and assist in maintaining the shape of the catheter shaft.

Device Description

The Kitazato IUI Catheter is a set of intrauterine insemination (IUI) catheters comprised of two different models that include either no stainless steel core (Type 4) or a stainless steel core (Type 5). Each type of catheter has a 10 cm or 18 cm catheter shaft length that incorporates an outer stiffener component and a syringe connector. The distal tip of the catheter shaft is rounded and includes two side holes 3 mm from the tip of the catheter for sperm delivery. The catheter shaft also includes depth marker bands at 5, 6, 7, and 8 cm from the distal tip to aid in delivery of the device to the targeted depth.

The catheter is composed of a polyvinyl chloride shaft and an acrylonitrile butadiene styrene (ABS) connector. The Stylet Cannula (Type 6) used with the Type 4 catheter is composed of a stainless steel cannula (SUS304) and an ABS syringe connector. The Stylet Cannula's stainless steel core provides rigidity and assists in maintaining the shape of the catheter shaft when the uterine cervix is sharply curved. The Stylet Cannula is inserted into the catheter shaft through the connector end and then the IUI Catheter is inserted into the cervix. During an IUI procedure, the catheter is introduced into the uterine cavity through the cervix, and the spermatozoa are injected into the uterine cavity by a syringe (not included) that is coupled at the connector end (6% taper connection) of the catheter shaft.

AI/ML Overview

This document describes the Kitazato IUI Catheter. Here's an analysis of the provided information concerning acceptance criteria and supporting studies:

1. Table of Acceptance Criteria and Reported Device Performance

TestAcceptance CriteriaReported Device Performance
Mechanical Tensile TestingPassed established specificationsPassed
Dimensional TestingConforms to outer diameter and length specificationsPassed
Appearance TestingPasses visual inspection for scratches, burrs, and foreign objectsPassed
Endotoxin Testing (per ANSI/AAMI ST72:2002/(R)2010)≤ 20 EU/deviceConforms to specification
Sterility Testing (per USP <71>)No microbial growthNo microbial growth
Biocompatibility Testing (per ISO 10993-1:2009 and 2016 FDA guidance)Cytotoxicity: Passed Sensitization: Passed Irritation: PassedPassed cytotoxicity, intracutaneous reactivity (irritation), and sensitization
Human Sperm Survival Assay (HSSA)≥ 70% motility at 24 hours≥ 70% motility at 24 hours
Color fastness of the depth marker bandsNo change in appearance after conditioningNo change in appearance
Shelf Life TestingEstablished three (3) year shelf lifeEstablished three (3) year shelf life
Package Integrity Testing (per ISO 11607-1:2006(R)2014, ISO 11607-2:2006)Passed dye penetration, seal strength, and visual inspectionPassed dye penetration, seal strength, and visual inspection

2. Sample Sizes Used for the Test Set and Data Provenance

The document does not specify the exact sample sizes used for each individual non-clinical performance test (e.g., number of catheters tested for tensile strength, number of samples for HSSA, etc.). It only states that the device "passed all the testing."

Data provenance is not explicitly mentioned as country of origin, however, the submission sponsor is KITAZATO Corporation in Japan, and the predicate device is from KITAZATO Medical Co., Ltd. This implies the studies were likely conducted or overseen by the Japanese manufacturer. The studies are non-clinical, implying they are laboratory-based tests rather than human studies, therefore the retrospective or prospective nature is not applicable in the same way it would be for clinical trials.

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

Not applicable. The reported studies are non-clinical performance tests for a medical device (catheter), not diagnostic studies requiring expert interpretation of results to establish ground truth.

4. Adjudication Method for the Test Set

Not applicable, as these are non-clinical performance tests with objective pass/fail criteria, not subjective human-interpreted data requiring adjudication.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

No. An MRMC comparative effectiveness study is designed for evaluating diagnostic tools where human readers are involved in interpreting results. This document describes non-clinical performance tests of a physical medical device.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

Yes, standalone performance was done in the sense that the device itself was subjected to a series of tests to verify its physical, chemical, and biological properties without human intervention in the device's function during the test itself (e.g., tensile strength, sterility, biocompatibility).

7. The Type of Ground Truth Used

The ground truth for these non-clinical tests is established by recognized international standards and specifications (e.g., ANSI/AAMI, USP, ISO 10993, ISO 11607). For instance:

  • Mechanical properties: Engineering specifications for tensile strength, dimensions.
  • Sterility: Absence of microbial growth, as defined by USP <71>.
  • Endotoxin: Endotoxin levels below a specified threshold, as defined by ANSI/AAMI ST72.
  • Biocompatibility: Absence of cytotoxicity, sensitization, and irritation as evaluated against ISO 10993 standards and FDA guidance.
  • HSSA: A specific percentage of sperm motility after a defined period (≥70% at 24 hours).
  • Package Integrity: Meeting requirements of ISO 11607.

8. The Sample Size for the Training Set

Not applicable. This report details acceptance criteria and performance data for a medical device based on non-clinical testing, not a machine learning or AI algorithm that requires a training set.

9. How the Ground Truth for the Training Set Was Established

Not applicable for the same reason as above (no training set for a non-AI medical device).

{0}------------------------------------------------

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three stylized human profiles facing to the right.

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

May 11, 2017

Kitazato Corporation % Audrey Swearingen, RAC Director, Regulatory Affairs Emergo Global Consulting. LLC 2500 Bee Cave Road, Building 1, Suite 300 Austin, TX 78746

Re: K162667 Trade/Device Name: Kitazato IUI Catheter Regulation Number: 21 CFR§ 884.6110 Regulation Name: Assisted Reproduction Catheters Regulatory Class: II Product Code: MOF Dated: April 13, 2017 Received: April 14, 2017

Dear Audrey Swearingen:

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.

{1}------------------------------------------------

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/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,

Benjamin R. Fisher -S

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K162667

Device Name Kitazato IUI Catheter

Indications for Use (Describe)

Kitazato IUI Catheter consists of the following versions:

· Kitazato IUI Catheter with Outer Stiffener with or without Stylet Cannula, 18 cm, model number Type 4-v1 and Type 4v2

· Kitazato IUI Catheter with Outer Stiffener with or without Stylet Cannula, 10 cm, model number Type 4-v3 and Type 4v4

· Kitazato IUI Catheter with Outer Stiffener with Stainless Steel Core, 18 cm, model number Type 5-v1 and Type 5-v2

· Kitazato IUI Catheter with Outer Stiffener with Stainless Steel Core, 10 cm, model number Type 5-v3 and Type 5-v4 Kitazato IUI Catheter is used for the introduction of washed spermatozoa into the uterine cavity through the cervix. Kitazato IUI Stylet is used to provide rigidity and assist in maintaining the shape of the catheter shaft.

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)

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."

{3}------------------------------------------------

510(k) Summary

Kitazato IUI Catheter

K162667

1. Submission Sponsor

KITAZATO Corporation

1-1-8 Shibadaimon, Minato-ku

Tokyo 105-0012

JAPAN

Contact: Ms. Mari YAZAKI

Title: Quality Assurance Manager

Phone number: + (81) 3 - 3434 -2731

2. Submission Correspondent

Emergo Global Consulting, LLC

2500 Bee Cave Road

Building 1, Suite 300

Austin, TX 78746

Office Phone: (512) 327 - 9997

Contact: Ms. Audrey Swearingen, RAC

Title: Director, Regulatory Affairs

Email: project.management@emergogroup.com

3. Date Prepared

May 10, 2017

4. Device Identification

Trade/Proprietary Name:Kitazato IUI Catheter
Common/Usual Name:Intrauterine Insemination (IUI) Catheter
Classification Name:Assisted Reproduction Catheters
Classification Number:884.6110

{4}------------------------------------------------

MQF, Assisted Reproduction Catheter Product Code:

Device Class: Class II

Classification Panel: Obstetrics/Gynecology

5. Legally Marketed Predicate Device(s)

K131491, Kitazato IUI Catheter, KITAZATO Medical Co., Ltd.

The predicate device has not been subject to a design-related recall.

6. Indication for Use Statement

Kitazato IUI Catheter consists of the following versions:

  • . Kitazato IUI Catheter with Outer Stiffener with or without Stylet Cannula, 18 cm, model number Type 4-v1 and Type 4-v2
  • . Kitazato IUI Catheter with Outer Stiffener with or without Stylet Cannula, 10 cm, model number Type 4-v3 and Type 4-v4
  • Kitazato IUI Catheter with Outer Stiffener with Stainless Steel Core, 18 cm, model number Type 5-v1 and Type 5-v2
  • Kitazato IUI Catheter with Outer Stiffener with Stainless Steel Core, 10 cm, model number Type 5-v3 and Type 5-v4

Kitazato IUI Catheter is used for the introduction of washed spermatozoa into the uterine cavity through the cervix.

Kitazato IUI Stylet is used to provide rigidity and assist in maintaining the shape of the catheter shaft.

7. Device Description

The Kitazato IUI Catheter is a set of intrauterine insemination (IUI) catheters comprised of two different models that include either no stainless steel core (Type 4) or a stainless steel core (Type 5). Each type of catheter has a 10 cm or 18 cm catheter shaft length that incorporates an outer stiffener component and a syringe connector. The distal tip of the catheter shaft is rounded and includes two side holes 3 mm from the tip of the catheter for sperm delivery. The catheter shaft also includes depth marker bands at 5, 6, 7, and 8 cm from the distal tip to aid in delivery of the device to the targeted depth.

The catheter is composed of a polyvinyl chloride shaft and an acrylonitrile butadiene styrene (ABS) connector. The Stylet Cannula (Type 6) used with the Type 4 catheter is composed of a stainless steel cannula (SUS304) and an ABS syringe connector. The Stylet Cannula's stainless steel core provides rigidity and assists in maintaining the shape of the catheter shaft when the uterine cervix is sharply curved. The Stylet Cannula is inserted into the catheter shaft through the connector end and then the IUI Catheter is inserted into the cervix. During an IUI procedure, the catheter is introduced into the uterine cavity through the cervix, and the spermatozoa are injected into the uterine cavity by a syringe (not included) that is coupled at the connector end (6% taper connection) of the catheter shaft.

Model configurations and specifications for the Kitazato IUI Catheters are listed below:

{5}------------------------------------------------

CodeModelProduct NameCode Catheter BodyCenter Core MaterialCatheter LengthOuter DiameterDepth markStylet Cannula
131184Type4-v1Catheter with Outer Stiffener with StyletPolyvinyl-chlorideNone18 cm1.70mm/5 FrYesYes
131182Type4-v2Cannula(not made with DEHP)None18 cm2.00mm/6FrYesYes
131104Type4-v3NoneNone10 cm1.70mm/5 FrYesYes
131102Type4-v4None10 cm2.00mm/6FrYesYes
131181Type5-v1Catheter with Outer Stiffener withPolyvinyl-chlorideS.S. SUS 30418 cm2.00mm/6FrYesNo
131186Type5-v2Stainless Steel Core(not made with DEHP)S.S. SUS 30418 cm2.00mm/6FrYesNo
131101Type5-v3S.S. SUS 30410 cm2.00mm/6FrYesNo
131106Type5-v4S.S. SUS 30410 cm2.00mm/6FrYesNo
140918Type6-v1Stylet cannulan/aS.S. SUS 30418 cm0.65 mmn/an/a
140118Type6-v2S.S. SUS 30410 cm0.65 mmn/an/a

8. Substantial Equivalence Discussion

The following table compares the Kitazato IUI Catheter to the predicate device with respect to indications for use, principles of operation, technological characteristics, and performance testing. The comparison of the devices provides more detailed information regarding the basis for the determination of substantial equivalence. Based on the information below, the subject and predicate device have comparable intended uses, and the differences in technology noted do not raise different questions of safety or effectiveness as compared to the predicate.

Table 1 – Comparison of Characteristics
-----------------------------------------
ManufacturerKITAZATO CorporationKITAZATO Medical Co., Ltd.SignificantDifferences
Trade NameKitazato IUI CatheterKitazato IUI Catheter Type3 with Outer Stiffener withStylet Cannula
510(k) NumberK162677K131491N/A
Product CodeMQFMQFSame
Regulation Number884.6110884.6110Same
Regulation NameAssisted ReproductionCatheterAssisted ReproductionCatheterSame
Indications for UseKitazato IUI Catheterconsists of the followingKitazato IUI Catheter consistDifferent. The Stylet isnot included separately
ManufacturerKITAZATO CorporationKITAZATO Medical Co., Ltd.SignificantDifferences
Trade NameKitazato IUI CatheterKitazato IUI Catheter Type3 with Outer Stiffener withStylet Cannula
versions:Kitazato IUI Catheterwith Outer Stiffenerwith or without StyletCannula, 18 cm, modelnumber Type 4-v1 andType 4-v2 Kitazato IUI Catheterwith Outer Stiffenerwith or without StyletCannula, 10 cm, modelnumber Type 4-v3 andType 4-v4 Kitazato IUI Catheterwith Outer Stiffenerwith Stainless SteelCore, 18 cm, modelnumber Type 5-v1 andType 5-v2 Kitazato IUI Catheterwith Outer Stiffenerwith Stainless SteelCore, 10 cm, modelnumber Type 5-v3 andType 5-v4 Kitazato IUI Catheter is usedfor the introduction ofwashed spermatozoa intothe uterine cavity throughthe cervix.Kitazato IUI Stylet is used toprovide rigidity and assist inmaintaining the shape ofthe catheter shaft.of the following versions:Kitazato IUI Catheterwith Outer Stiffenerwith Stylet Cannula, 18cm, model numberType 3-v1 Kitazato IUI Catheterwith Outer Stiffenerwithout Stylet Cannula,18 cm, model numberType 3-v2 Kitazato IUI Catheter is usedfor the introduction ofwashed spermatozoa intothe uterine cavity throughthe cervix.in the indications for usestatement of thepredicate device.However, the inclusionof a stylet does notrepresent a newintended use.
Overall DesignThe device consists of typesof IUI catheters with anouter stiffener with nostainless steel core (Type 4),outer stiffener withstainless steel core (Type 5)The device consists of typesof IUI catheters with anouter stiffener with andwithout a stylet cannula(Type 3). The catheter has aDifferent; the subjectdevice includes a versionof the IUI catheter thatutilizes a stainless steelcore. The inclusion ofthis stainless steel core
ManufacturerKITAZATO CorporationKITAZATO Medical Co., Ltd.Significant
Trade NameKitazato IUI CatheterKitazato IUI Catheter Type3 with Outer Stiffener withStylet CannulaDifferences
and stylet cannula for Type4 catheters. The catheterhas a smooth distal tip withtwo side holes. All typeshave a syringe connectorhub compatible with a 6%taper syringe (not included).The catheters are packagedin a barrier sterilizationpackage.side holes. All types have asyringe connector hubcompatible with a 6% tapersyringe (not included). Thecatheters are packaged in abarrier sterilizationpackage.does not raise differentquestions of safety oreffectiveness.
SterileEthylene Oxide (EO)RadiationDifferent; howeverDifferences in thesterilization method donot raise differentquestions of safety andeffectiveness.
Single-UseYesYesSame
French SizeType 4 (catheter shaft):1.7 mm / 5 Fr2 mm / 6 FrType 5 (catheter shaft):2 mm / 6 FrOuter stiffener shaft ofcatheter: 2.5 mm / 7.5 FrCatheter shaft2 mm / 6 FrOuter stiffener shaft2.5 mm/ 7.5 FrSimilar
Length10 and 18 cm18 cmDifferent; However, nodifferent questions ofsafety and effectivenessare raised due to ashorter length of thesubject device.
Depth MarksCentimeter marks arelocated at 5, 6, 7, 8 cm fromtip on the outer stifferCentimeter marks arelocated at 5, 6, 7, 8 cm fromtip on the outer stifferSame
TipClosed and smoothlyrounded; two side holesend typeClosed and smoothlyrounded; two side holesend typeSame
Stainless steel coreType 4: NoNoDifferent; the Type 5
ManufacturerKITAZATO CorporationKITAZATO Medical Co., Ltd.SignificantDifferences
Trade NameKitazato IUI CatheterKitazato IUI Catheter Type3 with Outer Stiffener withStylet Cannula
Type 5: Yesversion of the subjectdevice contains astainless steel core.However, no differentquestions of safety andeffectiveness are raisedby this inclusion.
StyletType 4: YesType 5: NoYesDifferent; the Type 5model does not utilizethe optional Type 6stylet cannula. However,an internal stainlesssteel core is present toprovide additionalrigidity during insertion.No different questionsof safety andeffectiveness are raised.
Stylet length10 and 18 cm18 cmDifferent; however, nodifferent questions ofsafety and effectivenessare raised due to theshorter length.
Stylet width0.65 mm0.65 mmSame
MaterialsPolyvinyl chloride, ABS,stainless steelPolyvinyl chloride, ABS,stainless steelSame
Biocompatible per ISO10993-1YesYesSame
HSSA≥ 70% motility at 24 hours≥ 70% motility at 24 hoursSame
Endotoxin<20 EU/device<20 EU/deviceSame

{6}------------------------------------------------

{7}------------------------------------------------

{8}------------------------------------------------

{9}------------------------------------------------

9. Non-Clinical Performance Data

As part of demonstrating safety and effectiveness of the Kitazato IUI Catheter that are subject to this 510(k) submission and in showing substantial equivalence to the predicate device, Kitazato Corporation completed a number of non-clinical performance tests.

The Kitazato IUI Catheter passed all the testing as shown below to support substantial equivalence to the subject device:

  • . Mechanical Tensile Testing: Tensile strength of the shaft and connector passed the established specifications
  • . Dimensional Testing: Passes outer diameter and length according to specifications
  • . Appearance Testing: Passes visual inspection for scratches, burrs, and foreign objects
  • . Endotoxin Testing per ANSI/AAMI ST72:2002/(R)2010: Endotoxin values conform to the specification of ≤20 EU/device
  • . Sterility Testing per USP <71>: No microbial growth
  • . Biocompatibility Testing per ISO 10993-1:2009 and 2016 FDA guidance document Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1:Evaluation and testing within a risk management process."
    • O Cytotoxicity (ISO Extraction Method, ISO 10993-5:2009
    • O Sensitization (ISO Guinea Pig Maximization Sensitization, ISO 10993-10:2010
    • Irritation (ISO Intracutaneous Reactivity Test, ISO 10993-10:2010 o

The subject device passed testing for cytotoxicity, intracutaneous reactivity, and sensitization.

  • Human Sperm Survival Assay (HSSA): ≥70% motility at 24 hours
  • Color fastness of the depth marker bands: no change in appearance of depth marks following conditioning
  • . Shelf Life Testing: Established three (3) year shelf life following real time aging. The following parameters were assessed during shelf life testing: tensile strength, dimension, appearance, sterility, endotoxin, HSSA, and color fastness.
  • . Package Integrity Testing per ISO 11607-1:2006(R)2014, Packaging for Terminally Sterilized Medical Devices – Part 1: Requirements for Materials, Sterile Barrier Systems and Packaging systems and ISO 11607-2:2006, Packaging for Terminally Sterilized Medical Devices – Part 2: Validation Requirements for Forming, Sealing, and Assembly Processes: passed dye penetration, seal strength, and visual inspection.

10. Statement of Substantial Equivalence

The results of the performance testing described above demonstrate that the Kitazato IUI Catheter is as safe and effective as the predicate device and supports a determination of substantial equivalence.

§ 884.6110 Assisted reproduction catheters.

(a)
Identification. Assisted reproduction catheters are devices used in in vitro fertilization (IVF), gamete intrafallopian transfer (GIFT), or other assisted reproduction procedures to introduce or remove gametes, zygote(s), preembryo(s), and/or embryo(s) into or from the body. This generic type of device may include catheters, cannulae, introducers, dilators, sheaths, stylets, and component parts.(b)
Classification. Class II (special controls) (mouse embryo assay information, endotoxin testing, sterilization validation, design specifications, labeling requirements, biocompatibility testing, and clinical testing).