K Number
K162820
Device Name
AC3 Series IABP System
Date Cleared
2017-03-31

(175 days)

Product Code
Regulation Number
870.3535
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The AC3TM Series IABP (Intra-Aortic Balloon Pump) System is clinically indicated for the following conditions: a. Acute Coronary Syndrome b. Cardiac and Non-Cardiac Surgery c. Complications of Heart Failure
Device Description
The AC3 Series Intra-Aortic Balloon Pump (IABP) System, which is the subject of this submission, is substantially equivalent to the previously cleared Arrow AutoCAT®2 IABP System which was previously cleared via K060309. The AC3 Series IABP System is the next generation platform which is based on the existing AutoCAT2 IABP System; cleared Device via K060309 on 6 April 2006. The AC3 Series IABP System (AutoCAT3) includes a new Graphical User Interface. The primary algorithms that control the therapeutic function of the device have not been altered from the AutoCAT2. The AC3 Series IABP system provides counter-pulsation therapy to adult patients with impaired Left Ventricular (LV) Function. It provides hemodynamic support of blood pressure and reduced cardiac work through volume displacement principles. The IABP is attached to an IAB (Intra-aortic Balloon) catheter which is inserted into the femoral artery and positioned in the descending thoracic aorta. The IABP delivers Helium (HE) into the IAB during diastole to displace blood above and below the IAB, increasing blood pressure and perfusion to organs close to the IAB catheter. The IABP deflates or removes HE from the IAB just prior to or in the early phase of systole, reducing the pressure in the aorta and therefore the pressure the LV must generate to open the aortic valve and eject its contents into the circulatory system. This results in a decrease in work and oxygen demand. The AC3 Series IABP System consists of two main components: The pump control / display module which incorporates a touch screen and keypad for system operation The pneumatic drive module which is incorporated into the body of the device. The AC3 is designed to be used with 30, 35, 40, and 50cc Intra-Aortic Balloons with the appropriate connectors. (UltraFlex™, Ultra 80, NarrowFlex®, and RediGuard® Catheters). The system offers two modes of operation: Autopilot Mode, where most functions are automatically selected and controlled by the IABP Operator mode, where an operator can control most settings and selections.
More Information

No
The summary explicitly states that the primary algorithms controlling the therapeutic function have not been altered from the predicate device, and there is no mention of AI or ML in the document.

Yes.
The device provides counter-pulsation therapy to patients with impaired Left Ventricular (LV) Function and offers hemodynamic support, indicating a therapeutic function.

No

The AC3 Series IABP (Intra-Aortic Balloon Pump) System is described as providing "counter-pulsation therapy" and "hemodynamic support" to adult patients with impaired Left Ventricular (LV) Function. It delivers Helium to displace blood and regulate pressure, which is a therapeutic function rather than a diagnostic one. While it uses ECG for triggering, this is a control mechanism for its therapeutic delivery, not for diagnosing a condition.

No

The device description explicitly states that the system consists of two main components: a pump control/display module and a pneumatic drive module, both of which are hardware components. It also mentions being used with Intra-Aortic Balloon catheters.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states the device is for providing counter-pulsation therapy to adult patients with impaired Left Ventricular (LV) Function. This is a therapeutic intervention performed on the patient, not a test performed on a sample taken from the patient.
  • Device Description: The description details a system that physically interacts with the patient's circulatory system (inserting a balloon catheter into the aorta) to provide mechanical support. This is a medical device used for treatment, not for diagnosing a condition by analyzing a sample.
  • Lack of IVD Characteristics: The description does not mention analyzing biological samples (blood, urine, tissue, etc.) or using reagents, which are hallmarks of IVD devices.

The device is an Intra-Aortic Balloon Pump (IABP) System, which is a type of medical device used for circulatory support.

N/A

Intended Use / Indications for Use

The AC3TM Series IABP (Intra-Aortic Balloon Pump) System is clinically indicated for the following conditions:

  • a. Acute Coronary Syndrome
  • b. Cardiac and Non-Cardiac Surgery
  • c. Complications of Heart Failure

Product codes

DSP

Device Description

The AC3 Series Intra-Aortic Balloon Pump (IABP) System, which is the subject of this submission, is substantially equivalent to the previously cleared Arrow AutoCAT®2 IABP System which was previously cleared via K060309.

The AC3 Series IABP System is the next generation platform which is based on the existing AutoCAT2 IABP System; cleared Device via K060309 on 6 April 2006.

The AC3 Series IABP System (AutoCAT3) includes a new Graphical User Interface. The primary algorithms that control the therapeutic function of the device have not been altered from the AutoCAT2.

This premarket notification is applicable to the following part numbers:
Versions utilizing the Fiber Optic Sensor (FOS) or WAVE (Wind Kessel Aortic Valve Equation) capabilities:

  • IAP-0700 AC3 Optimus™ IABP
  • IAP-0701 AC3 Optimus™ IABP .

Versions without the FOS or WAVE capabilities:

  • IAP-0600 AC3™ IABP
  • IAP-0601 AC3™ IABP .

Note: The 01 ending indicates physical language labeling only. The part numbers IAP-0700 and IAP-0600 include the North American (NA) and European (EU) languages and the part numbers IAP-0701 and IAP-0601 include the NA, Asia, Japan and Latin America (AJLA) languages. All the part numbers will be commercially released OUS (outside of United States of America) after respective country registrations have been received. Functionally all the above mentioned part numbers are equivalent in performance and specifications.

System Description:
The AC3 Series IABP system provides counter-pulsation therapy to adult patients with impaired Left Ventricular (LV) Function. It provides hemodynamic support of blood pressure and reduced cardiac work through volume displacement principles. The IABP is attached to an IAB (Intra-aortic Balloon) catheter which is inserted into the femoral artery and positioned in the descending thoracic aorta.

The IABP delivers Helium (HE) into the IAB during diastole to displace blood above and below the IAB, increasing blood pressure and perfusion to organs close to the IAB catheter. The IABP deflates or removes HE from the IAB just prior to or in the early phase of systole, reducing the pressure in the aorta and therefore the pressure the LV must generate to open the aortic valve and eject its contents into the circulatory system. This results in a decrease in work and oxygen demand.

The AC3 Series IABP System consists of two main components:

  • The pump control / display module which incorporates a . touch screen and keypad for system operation
  • . The pneumatic drive module which is incorporated into the body of the device.

The AC3 is designed to be used with 30, 35, 40, and 50cc Intra-Aortic Balloons with the appropriate connectors. (UltraFlex™, Ultra 80, NarrowFlex®, and RediGuard® Catheters).

The system offers two modes of operation:

  • . Autopilot Mode, where most functions are automatically selected and controlled by the IABP
  • Operator mode, where an operator can control most . settings and selections.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

descending thoracic aorta

Indicated Patient Age Range

Adult patients

Intended User / Care Setting

The users consist of trained hospital personnel in Intensive care areas, Cardiac Cath Labs, Cardiac Operating Rooms and emergency departments. This device is for in-hospital use and for transport between departments in a specific hospital or between facilities as required by the patient condition and treatment required.

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

Not Found

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

Not Found

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

Extensive performance testing has been completed to demonstrate that the AC3 is substantially equivalent to the AutoCAT2 device previously cleared via K060309.

  • Electrical Safety and Electromagnetic Compatibility Testing: Conducted by an outside test house. Test reports confirm compliance with IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60606-1-8, IEC 60601-2-27, IEC 60601-2-34, IEC 60601-2-49, RTCA DO-160 Section 20 Category R, and Home Use Guidance Document.
  • Software Verification Testing: Software developed in accordance with IEC 62304:2006. Testing demonstrated that software requirements have been met.
  • Human Factors Testing / Usability Testing: 33 users participated. Performed 22 use cases based on critical tasks. No use errors observed. 96% of use cases completed successfully with no operational difficulty, 4% with minor operational difficulty. Conducted in accordance with FDA's Final Guidance document, Applying Human Factors and Usability Engineering to Medical Devices and IEC 62366:2007.
  • Cleaning and Disinfection: Conducted by an outside test house. Cleaning effectiveness verified in accordance with AAMI TIR12:2010 and AAMI TIR30:2011. Disinfection testing demonstrated a six log10 reduction in colony forming units (CFU) of selected organisms, in accordance with AAMI TIR12:2010 and ANSI/AAMI ST58:2013.
  • Environmental/ Mechanical Testing: Mechanical design verification conducted. Confirmed that the AC3 Series IABP System meets all requirements with respect to operational parameters and reliability.
  • Design Validation Testing:
    • ECG trigger validation: AC3 and AutoCAT2 IABP systems simultaneously assessed using the same real Electro-Cardiogram (ECG) waveform input from the American Heart Association (AHA) database. Data confirmed substantial equivalence in triggering reliability.
    • Reliability testing: AC3 pumps run continuously for 9 days (216 to 218 hours). All pumps successfully inflated and deflated the attached IAB catheter and met all acceptance criteria.
    • Rate limit testing: Verified successful inflation and deflation of 30cc, 35cc, 40cc, and 50cc IAB catheters connected to the IABP system. Testing confirmed all requirements met.

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

Not Found

Predicate Device(s)

K060309

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.3535 Intra-aortic balloon and control system.

(a)
Identification. An intra-aortic balloon and control system is a prescription device that consists of an inflatable balloon, which is placed in the aorta to improve cardiovascular functioning during certain life-threatening emergencies, and a control system for regulating the inflation and deflation of the balloon. The control system, which monitors and is synchronized with the electrocardiogram, provides a means for setting the inflation and deflation of the balloon with the cardiac cycle.(b)
Classification. (1) Class II (special controls) when the device is indicated for acute coronary syndrome, cardiac and non-cardiac surgery, or complications of heart failure. The special controls for this device are:(i) Appropriate analysis and non-clinical testing must be conducted to validate electromagnetic compatibility and electrical safety of the device;
(ii) Software verification, validation, and hazard analysis must be performed;
(iii) The device must be demonstrated to be biocompatible;
(iv) Sterility and shelf-life testing must demonstrate the sterility of patient-contacting components and the shelf life of these components;
(v) Non-clinical performance evaluation of the device must demonstrate mechanical integrity, durability, and reliability to support its intended purpose; and
(vi) Labeling must include a detailed summary of the device- and procedure-related complications pertinent to use of the device.
(2) Class III (premarket approval) when the device is indicated for septic shock and pulsatile flow generation.
(c)
Date premarket approval application (PMA) or notice of completion of product development protocol (PDP) is required. A PMA or notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before March 31, 2014, for any intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation that was in commercial distribution before May 28, 1976, or that has, on or before March 31, 2014, been found to be substantially equivalent to any intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation that was in commercial distribution before May 28, 1976. Any other intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation shall have an approved PMA or declared completed PDP in effect before being placed in commercial distribution.

0

Image /page/0/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

Public Health Service

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

March 31, 2017

Arrow International, Inc. Alifiya Jagmag Manager, Regulatory Affairs 16 Elizabeth Dr. Chelmsford, Massachusetts 01824

Re: K162820

Trade/Device Name: AC3 Series IABP System Regulation Number: 21 CFR 870.3535 Regulation Name: Intra-Aortic Balloon and Control System Regulatory Class: Class II Product Code: DSP Dated: March 3, 2017 Received: March 6, 2017

Dear Alifiya Jagmag:

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

1

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,

M.A. Hillebrenner

for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K162820

Device Name AC3TM Series IABP System

Indications for Use (Describe)

The AC31M Series IABP (Intra-Aortic Balloon Pump) System is clinically indicated for the following conditions:

  • a. Acute Coronary Syndrome
  • b. Cardiac and Non-Cardiac Surgery
  • c. Complications of Heart Failure

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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3

Section 5- 510(k) Summary

| 5.1
Statement | This 510(k) summary is being submitted in accordance with the
requirements of Safe Medical Device Act (SMDA) 1990 and CFR
807.92. |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 5.2
Submitter | Arrow International, Inc. (Subsidiary of Teleflex, Inc.)
16 Elizabeth Drive
Chelmsford, MA 01824
Establishment Registration: 3010532612
Arrow International, Inc. (Subsidiary of Teleflex, Inc.)
Reading, PA 19605:
Owner/ Operator: 2518433 |
| 5.3
Company
Contact | Alifiya Jagmag
Manager, Regulatory Affairs
Arrow International, Inc.
16 Elizabeth Drive
Chelmsford, MA 01824
Alifiya.Jagmag@teleflex.com
Phone: 978-250-5100 extension 725172
Date Prepared: 30 March 2017 |
| 5.4 | Proprietary Name: AC3TM Series IABP System |
| Device Name | Common Name: Intra-Aortic Balloon Control System |
| | Classification Name: Intra-aortic balloon and control system
(21 CFR 870.3535), Regulatory Class: II, Product Code: DSP |

5.5The AC3 Series Intra-Aortic Balloon Pump (IABP) System, which is
Predicatethe subject of this submission, is substantially equivalent to the
Legallypreviously cleared Arrow AutoCAT®2 IABP System which was
Marketed
Devicespreviously cleared via K060309.

4

5.6 The AC3 Series IABP System is the next generation platform which is based on the existing AutoCAT2 IABP System; cleared Device via K060309 on 6 April 2006. Description

The AC3 Series IABP System (AutoCAT3) includes a new Graphical User Interface. The primary algorithms that control the therapeutic function of the device have not been altered from the AutoCAT2.

This premarket notification is applicable to the following part numbers:

Versions utilizing the Fiber Optic Sensor (FOS) or WAVE (Wind Kessel Aortic Valve Equation) capabilities:

  • IAP-0700 AC3 Optimus™ IABP ●
  • IAP-0701 AC3 Optimus™ IABP .

Versions without the FOS or WAVE capabilities:

  • IAP-0600 AC3™ IABP ●
  • IAP-0601 AC3™ IABP .

Note: The 01 ending indicates physical language labeling only. The part numbers IAP-0700 and IAP-0600 include the North American (NA) and European (EU) languages and the part numbers IAP-0701 and IAP-0601 include the NA, Asia, Japan and Latin America (AJLA) languages. All the part numbers will be commercially released OUS (outside of United States of America) after respective country registrations have been received. Functionally all the above mentioned part numbers are equivalent in performance and specifications.

System Description:

The AC3 Series IABP system provides counter-pulsation therapy to adult patients with impaired Left Ventricular (LV) Function. It provides hemodynamic support of blood pressure and reduced cardiac work through volume displacement principles. The IABP is attached to an IAB (Intra-aortic Balloon) catheter which is inserted into the femoral artery and positioned in the descending thoracic aorta.

The IABP delivers Helium (HE) into the IAB during diastole to displace blood above and below the IAB, increasing blood pressure and perfusion to organs close to the IAB catheter. The

5

IABP deflates or removes HE from the IAB just prior to or in the early phase of systole, reducing the pressure in the aorta and therefore the pressure the LV must generate to open the aortic valve and eject its contents into the circulatory system. This results in a decrease in work and oxygen demand.

The AC3 Series IABP System consists of two main components:

  • The pump control / display module which incorporates a . touch screen and keypad for system operation
  • . The pneumatic drive module which is incorporated into the body of the device.

The AC3 is designed to be used with 30, 35, 40, and 50cc Intra-Aortic Balloons with the appropriate connectors. (UltraFlex™, Ultra 80, NarrowFlex®, and RediGuard® Catheters).

The system offers two modes of operation:

  • . Autopilot Mode, where most functions are automatically selected and controlled by the IABP
  • Operator mode, where an operator can control most . settings and selections.

| 5.7

DeviceIndications For Use:
Indications
and Intended
useThe AC3 IABP (Intra-Aortic Balloon Pump) System is clinically
indicated for the following conditions:
a. Acute Coronary Syndrome
b. Cardiac and Non-Cardiac Surgery
c. Complications of Heart Failure

6

5.8 Extensive performance testing has been completed to demonstrate that the AC3 is substantially equivalent to the AutoCAT2 device Performance previously cleared via K060309. Testing

Following is a summary of the testing that has been completed to demonstrate substantial equivalence.

Electrical Safety and Electromagnetic Compatibility Testing Electrical Safety and Compliance testing was conducted by an outside test house.

Test reports provided confirm that the AC3 is in compliance with the standards as noted in Table 5.1 below.

StandardDescription
IEC 60601-1
3rd editionMedical electrical equipment - Part 1: General
requirements for basic safety and essential
performance
IEC 60601-1-2
3rd editionMedical Electrical Equipment - Part 1-2:
General Requirements for Basic Safety and
Essential Performance - Collateral Standard:
Electromagnetic Compatibility - Requirements
and Tests
IEC 60601-1-6
3rd editionMedical Electrical Equipment - Part 1-6:
General Requirements for Basic Safety and
Essential Performance - Collateral Standard:
Usability
IEC 60606-1-8
2nd editionMedical electrical equipment - Part 1-8:
General requirements for basic safety and
essential performance - Collateral Standard:
General requirements, tests and guidance for
alarm systems in medical electrical equipment
and medical electrical systems
IEC 60601-2-27
3rd editionMedical electrical equipment - Part 2-27:
Particular requirements for the basic safety
and essential performance of
electrocardiographic monitoring equipment
medical electrical equipment - Part 2-27:
Particular requirements for the basic safety
and essential performance of
electrocardiographic monitoring equipment

Table 5.1: IEC Standards Applicable to the AC3 IABP

7

StandardDescription
IEC 60601-2-34
3rd editionMedical electrical equipment. Particular
requirements for the basic safety and
essential performance of invasive blood
pressure monitoring equipment
IEC 60601-2-49
2nd editionMedical electrical equipment. Particular
requirements for the basic safety and
essential performance of multifunction patient
monitoring equipment
RTCA DO-160
Section 20
Category RRadio Frequency Susceptibility (Conducted
and Radiated)
N/ADesign Considerations for Devices Intended
for Home Use Guidance Document

Software Verification Testing

The software has been developed in accordance with IEC 62304:2006, Medical device software-Software lifecycle processes. Software Verification testing has been completed to demonstrate that the software requirements have been met. Documentation has been supplied to also comply with FDA's quidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices".

Human Factors Testing / Usability Testing

Testing was completed to demonstrate that the changes to the user interface did not negatively impact the performance of the device. Testing was completed in accordance with FDA's Final Guidance document, Applying Human Factors and Usability Engineering to Medical Devices and in accordance with IEC 62366:2007.

As part of this evaluation 33 users participated in the evaluation. Each participant was asked to perform 22 uses cases that were developed based on critical tasks and areas for potential risk due to potential use errors. There were no use errors observed during testing and 96% of the use cases were completed successfully with no operational difficulty (on the first attempt) whereas 4% of the use cases were completed with only minor operational difficulty.

Cleaning and Disinfection

8

Cleaning: A study was conducted by an outside test house in accordance with the following recognized standards:

  • AAMI TIR12:2010 - Designing, testing, and labeling reusable medical devices for reprocessing in health care facilities.
    AAMI TIR30:2011 - A compendium of processes, materials, ● test methods, and acceptance criteria for cleaning reusable medical devices, and Reprocessing Medical Devices in Health Care Settings

Testing was completed to verify the effectiveness of the recommended cleaning methods. Components of the device that represented the worst case based on the material and the use profile of the components were selected for inclusion in the protocol..

Disinfection: Testing was also completed to demonstrate the recommended method of disinfection would result in a six log10 reduction in colony forming units (CFU) of selected organisms. Testing was completed in accordance with the following recognized standards:

AAMI TIR12:2010 - Designing, testing, and labeling ● reusable medical devices for reprocessing in health care facilities.

ANSI/AAMI ST58:2013 - Chemical sterilization and high-. level disinfection in health care facilities, and Reprocessing Medical Devices in Health Care Settings.

Testing demonstrated the AC3 Series IABP system could effectively be cleaned and disinfected using the recommended methods.

Environmental/ Mechanical Testing

Mechanical design verification testing was conducted to confirm that the AC3 Series IABP System meets all requirements with respect to operational parameters and reliability and is substantially equivalent to the predicate device, AutoCAT2 IABP. The result of this testing confirms that the device meets all acceptance criteria and specifications as required.

Design Validation Testing

ECG trigger validation Testing was conducted using recordings of real Electro-Cardiogram (ECG) waveforms from the American Heart Association (AHA) database to confirm that the AC3 Series IABP system ECG Triggering was equivalent to the AutoCAT2 ECG Triggering. As part of this testing an AutoCAT2 and AC3

9

Series IABP system were simultaneously assessed using the same ECG input. The data confirmed that the devices are substantially equivalent with regard to their triggering reliability.

Reliability testing was also completed to confirm that the AC3 Series IABP system could run continuously and perform as intended. As part of this test AC3 pumps were run continuously for 9 days; from 216 to 218 hours. All pumps successfully inflated and deflated the attached IAB catheter and met all acceptance criteria for this test.

Rate limit testing was completed to verify that the AC3 Series IABP system was able to successfully inflate and deflate the various size IAB catheters i.e. 30cc, 35cc, 40cc and 50cc that were connected to the IABP system. Testing confirmed that the inflation and deflation of connected balloons met all requirements.

Table 5.2 provides a comparison of the AutoCAT2 IABP cleared via K060309 and the AC3 Series IABP system that is the subject of this submission.

10

| Attribute | AutoCAT2 Series IABP
(Predicate Device) | AC3 Series IABP system
(Subject Device) | Comparison |
|---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for
Use | The AutoCAT2 Intra-
Aortic Balloon Pump
(IABP) is clinically
indicated for the
following conditions:
a. Acute Coronary
Syndrome
b. Cardiac and Non-
Cardiac Surgery
c. Complications of
Heart Failure | The AC3 Series Intra-
Aortic Balloon Pump
(IABP) System is
clinically indicated for
the following conditions:
a. Acute Coronary
Syndrome
b. Cardiac and
Non-Cardiac
Surgery
c. Complications of
Heart Failure | No change.
Same as
AutoCAT2 |
| Intended Use | The AutoCAT2 IABP is
intended to provide
counter-pulsation
therapy to adult patients
with impaired Left
ventricular function.
The users consist of
trained hospital
personnel in Intensive
care areas, Cardiac Cath
Labs, Cardiac Operating
Rooms and emergency
departments. This
device is for in-hospital
use and for transport
between departments in
a specific hospital or
between facilities as
required by the patient
condition and treatment
required. | The AC3 Series IABP
system is intended to
provide counter-
pulsation therapy to
adult patients with
impaired Left ventricular
function.
The users consist of
trained hospital
personnel in Intensive
care areas, Cardiac
Cath Labs, Cardiac
Operating Rooms and
emergency
departments. This
device is for in-hospital
use and for transport
between departments in
a specific hospital or
between facilities as
required by the patient
condition and treatment
required. | No change.
Same as
AutoCAT2 |
| Compatible
Disposable | 30, 35, 40, and 50cc
Intra-aortic balloons | 30, 35, 40, and 50cc
Intra-aortic balloons | No change.
Same as |
| Attribute | AutoCAT2 Series IABP
(Predicate Device) | AC3 Series IABP system
(Subject Device) | Comparison |
| Sets | marked with Arrow | marked with Arrow | AutoCAT2 |
| Sterility | Non-sterile | Non-sterile | No change.
Same as
AutoCAT2 |
| Environmental
Specifications | Operating Temperature:
5°C to 45°C (without
Fiber Optic Sensor)
5°C to 35°C (with Fiber
Optic Sensor) | Operating Temperature:
0°C to 45°C (without
Fiber Optic Sensor)
0°C to 35°C (with Fiber
Optic Sensor) | Greater range
of operating
temperature
and storage
and transport
humidity
conditions all
other
specifications
remains the
same. |
| | Specification Storage
and transport
Temperature: -15°C to
40°C | Specification Storage
and transport
Temperature: -15°C to
40°C | |
| | Storage and transport
Atmospheric Pressure:
200 hPa - 1060 hPa
(150mmHg - 796mmHg) | Storage and transport
Atmospheric Pressure:
200 hPa - 1060 hPa
(150mmHg - 796mmHg) | |
| | Storage and Transport
Humidity: 15% - 80% | Storage and Transport
Humidity: 15% - 85% | |
| | Stepper motor driven
bellows pneumatic
system with augmented
deflation and no
disposable parts. | Stepper motor driven
bellows pneumatic
system with augmented
deflation and no
disposable parts. | No change.
Same as
AutoCAT2 |
| | Pumping volume: 0.5cc –
50cc, adjustable in 0.5cc
increments | Pumping volume: 0.5cc
– 50cc, adjustable in
0.5cc increments | |
| | Performance
Specifications | Sealed Lead Acid battery
(minimum of 90 minutes)
with an optional battery
upgrade to double
battery life. | Sealed Lead Acid
battery (minimum of 90
minutes) with an
optional battery upgrade
to double battery life. |
| | | Power supply 85 to 265V
47 to 63Hz
Power consumption
225W or 3.1A | Power supply 85 to
265V 47 to 63Hz
Power consumption
110V- 5.1A
220V- 2.8A |
| Attribute | AutoCAT2 Series IABP
(Predicate Device) | AC3 Series IABP
system
(Subject Device) | Comparison |
| | Universal Power Supply | Universal Power Supply | specifications. |
| | 10.3 Inch Color LCD
display.
26 Hard keys available | 13.3 Inch High
Resolution touchscreen
display | AC3 Series
IABP system
has a larger, |
| | for all functions. No
touch screen. | 6 hard keys for
frequently used or
safety functions. | high resolution
touchscreen
with an
improved user
interface |
| Display | Hard keys are backlit
LEDs for selection. | Hard keys and text are
both backlit LEDs and
color coded | Improved
visibility of keys
in dark |
| | No Alarm indication
corner switch | AC3 Display head has a
color coded corner
switch that illuminates
when an alarm is active. | The Corner
switch acts as a
visual indicator
for the priority
of alarm and
also allows the
user to reset
alarm. |
| | 2 Operational Modes:
Autopilot and Operator
mode | 2 Operational Modes:
Autopilot and Operator
mode | No change.
Same as
AutoCAT2 |
| Operational
Modes | Autopilot mode Includes:
• Automatic trigger
selection
• Automatic
ECG/Arterial Pressure
(AP) source selection
• Automatic timing
method selection and
timing control
• Best Signal Analysis
• Deflation Timing
Management | Autopilot mode
Includes:
• Automatic trigger
selection
• Automatic ECG/
Arterial Pressure (AP)
source selection
• Automatic timing
method selection and
timing control
• Best Signal Analysis
• Deflation Timing
Management | AC3 and
AutoCAT2
series IABP
systems have
the same
Autopilot mode
functionality. |
| | Operator mode includes:
• 7 modes for trigger
selection | Operator mode
includes:
• 7 modes for trigger | AC3 and
AutoCAT2
series IABP |
| Attribute | AutoCAT2 Series IABP
(Predicate Device) | AC3 Series IABP system
(Subject Device) | Comparison |
| | • ECG Source: 2 selections and 1 key press to change leads
• ECG gain: Automatic, Manual and User adjustable
• AP Source: 3 selections
• AP Scaling: Automatic, Manual and User selectable
• Timing can be selected using Soft keys and the selected timing setting is displayed on the screen. | selection
• ECG Source: 2 selections and 1 key press to change leads
• ECG gain: Automatic, Manual and User adjustable
• AP Source: 3 selections
• AP Scaling: Automatic, Manual and User selectable
• Touchscreen has the timing controls under the Timing Key. A reminder message is shown if the user leaves the timing screen in 1:2 or lower assist. | systems have the same Operator mode functionality. |
| FiberOptix® Technology | AutoCAT2 WAVE® only:
Allows Arterial Pressure (AP) to be measured by Fiber Optic method while using Arrow FiberOptix® IAB catheter. | AC3 Optimus™ only:
Allows Arterial Pressure (AP) to be measured by Fiber Optic method while using Arrow FiberOptix® IAB catheter. The AC3 Series IABP system has an updated position for the FOS connection. | New position for the FOS connection will facilitate connection |

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5.9 The AC3 Series IABP System has the same indications for use and incorporates the same fundamental technology as the legally Conclusion marketed predicate devices. Performance test results and verification Regarding activities demonstrate that the proposed device meets its intended Substantial use. It is for these reasons that the proposed device can be found Equivalence substantially equivalent to the predicate device.