K Number
K170532
Device Name
True Form Reshapable Guide Wire
Date Cleared
2017-07-21

(149 days)

Product Code
Regulation Number
870.1330
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The True Form Reshapable Guide Wire is intended to facilitate the placement of catheters within the peripheral and coronary vasculature for various diagnostic and interventional procedures. The True Form Reshapable Guide Wire should not be used in the neurovasculature
Device Description
The Merit True Form Reshapable Guide Wire consists of a stainless steel core wire, flattened at the distal end, with a 5cm Gold Plated Tungsten coil attached to the distal tip and is fully jacketed with a radiopaque filled polymer jacket. The True Form Reshapable Guide Wire is fully coated with a hydrophilic coating. The 5cm radiopaque coil is attached to the internal stainless steel core wire with a multitude of solder joints. The wires are placed within a spiralled hoop dispenser with a flush luer attached and clips to secure the wire within the hoop. Included within the pouch, with the spiralled hooped guidewire, is another pouch containing an Insertion Tool, a Tip Straightener, and a Torque device. The wire will be offered in straight and angled versions, in various lengths.
More Information

No
The device description and performance studies focus on the physical properties and mechanical performance of a guide wire, with no mention of software, algorithms, or data processing that would indicate AI/ML.

No.
The device is a guide wire, which is used to facilitate the placement of catheters for diagnostic and interventional procedures, not directly to treat a condition.

No

The device is a guide wire intended to facilitate the placement of catheters for diagnostic and interventional procedures, but it is not a diagnostic device itself. It aids in the placement of other devices which may then be used for diagnosis.

No

The device description clearly outlines physical components such as a stainless steel core wire, tungsten coil, polymer jacket, dispenser, insertion tool, tip straightener, and torque device. This indicates it is a hardware medical device, not software-only.

Based on the provided information, the Merit True Form Reshapable Guide Wire is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to "facilitate the placement of catheters within the peripheral and coronary vasculature for various diagnostic and interventional procedures." This describes a device used within the body to aid in a medical procedure, not a device used to examine specimens outside the body to diagnose a condition.
  • Device Description: The description details a physical guide wire with components like a core wire, coil, jacket, and coatings. It also mentions accessories for handling the wire. This aligns with a medical device used for navigation within the body.
  • Lack of IVD Characteristics: There is no mention of:
    • Analyzing biological specimens (blood, urine, tissue, etc.).
    • Detecting or measuring substances in biological specimens.
    • Providing information for the diagnosis, monitoring, or treatment of a disease or condition based on the analysis of biological specimens.

In summary, the Merit True Form Reshapable Guide Wire is a medical device used for guiding other instruments within the body, which is the definition of an interventional or diagnostic medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The True Form Reshapable Guide Wire is intended to facilitate the placement of catheters within the peripheral and coronary vasculature for various diagnostic and interventional procedures. The True Form Reshapable Guide Wire should not be used in the neurovasculature

Product codes

DQX

Device Description

The Merit True Form Reshapable Guide Wire consists of a stainless steel core wire, flattened at the distal end, with a 5cm Gold Plated Tungsten coil attached to the distal tip and is fully jacketed with a radiopaque filled polymer jacket. The True Form Reshapable Guide Wire is fully coated with a hydrophilic coating. The 5cm radiopaque coil is attached to the internal stainless steel core wire with a multitude of solder joints.

The wires are placed within a spiralled hoop dispenser with a flush luer attached and clips to secure the wire within the hoop. Included within the pouch, with the spiralled hooped guidewire, is another pouch containing an Insertion Tool, a Tip Straightener, and a Torque device.

The wire will be offered in straight and angled versions, in various lengths.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

peripheral and coronary vasculature

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

A battery of testing was conducted, on the Merit True Form Reshapable Guide Wire, in accordance with protocols based on requirements outlined in guidance's and industry standards and these were shown to meet the acceptance criteria that were determined to demonstrate substantial equivalence.

Performance Testing-Bench:

  • Size Designation
  • Radiodetectability
  • Tip Shape Testing
  • Surface
  • Tensile Strenath
  • Torque Strength
  • Torqueability
  • Tip Flexibility
  • Fracture test
  • Flex test
  • Lubricitv
  • Corrosion Resistance
  • Device Compatibility
  • Tip Curve Shapeability
  • Particulate
  • Coating Durability
  • Packaging

Biocompatibility:

  • Cytotoxicity
  • Sensitization
  • Irritation
  • Acute Systemic Toxicity
  • Pyrogenicity
  • Genotoxicity
  • Hemolysis
  • Thrombogenicity
  • Complement Activation

All test results were comparable to the predicate devices and the subject Merit True Form Reshapable Guide Wire met the predetermined acceptance criteria. This has demonstrated that the subject device is substantially equivalent to the predicate devices.

Key Metrics

Not Found

Predicate Device(s)

K143587

Reference Device(s)

K060551

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1330 Catheter guide wire.

(a)
Identification. A catheter guide wire is a coiled wire that is designed to fit inside a percutaneous catheter for the purpose of directing the catheter through a blood vessel.(b)
Classification. Class II (special controls). The device, when it is a torque device that is manually operated, non-patient contacting, and intended to manipulate non-cerebral vascular guide wires, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.

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Public Health Service

Image /page/0/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized image of three human profiles facing to the right, stacked on top of each other. The profiles are black and are arranged to create a sense of depth. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circle around the profiles.

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

July 21, 2017

Merit Medical Systems, Inc. Michael O'Sullivan Senior Regulatory Affairs Specialist Parkmore Business Park West Galway, Ireland

Re: K170532

Trade/Device Name: True Form Reshapable Guide Wire Regulation Number: 21 CFR 870.1330 Regulation Name: Catheter Guide Wire Regulatory Class: Class II Product Code: DQX Dated: June 15, 2017 Received: June 19, 2017

Dear Michael O'Sullivan:

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 of medical device

1

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,

Kenneth J. Cavanaugh -S

for

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

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K170532

Device Name True Form Reshapable Guide Wire

Indications for Use (Describe)

The True Form Reshapable Guide Wire is intended to facilitate the placement of catheters within the peripheral and coronary vasculature for various diagnostic and interventional procedures.

The True Form Reshapable Guide Wire should not be used in the neurovasculature

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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Submitter Name:Merit Medical Systems, Inc.
Address:1600 West Merit Parkway
South Jordan, UT 84095
Telephone Number:(+353) 91 703700 (Ext. 3061)
Fax Number:(+353) 91 680104
Contact Person:Mark Mullaney
Registration Number:1721504
General
ProvisionsCorrespondent Name:Merit Medical Ireland Ltd.
Address:Parkmore Business Park
Parkmore, Galway, Ireland
Telephone Number:(+353) 91 703700 (Ext. 3223)
Fax Number:(+353) 91 680104
Contact Person:Michael O'Sullivan
Date of Preparation:20th February 2017
Registration Number:9616662
Subject
DeviceTrade Name:True Form Reshapable Guide Wire
Common/Usual Name:Guide Wire
Classification Name:Wire, Guide, Catheter
Predicate
DevicePremarket Notification Predicate #1:
Trade Name:Boston ChoICE PT
Classification Name:21 CFR 870.1330 Catheter guide wire
Premarket Notification:K143587
Manufacturer:Boston Scientific Corporation
Premarket Notification Reference Predicate #2:
Trade Name:Bard Porter
Classification Name:21 CFR 870.1330 Catheter guide wire
Premarket Notification:K060551
Manufacturer:Brivant Ltd.
ClassificationClass II
21 CFR § 870.1330
Product code:DQX
Division of Cardiovascular Devices
Intended UseThe True Form Reshapable Guide Wire is intended to facilitate the
placement of catheters within the peripheral and coronary
vasculature for various diagnostic and interventional procedures.
The True Form Reshapable Guide Wire should not be used in the
neurovasculature
Device
DescriptionThe Merit True Form Reshapable Guide Wire consists of a stainless
steel core wire, flattened at the distal end, with a 5cm Gold Plated
Tungsten coil attached to the distal tip and is fully jacketed with a
radiopaque filled polymer jacket. The True Form Reshapable Guide
Wire is fully coated with a hydrophilic coating. The 5cm radiopaque
coil is attached to the internal stainless steel core wire with a
multitude of solder joints.
The wires are placed within a spiralled hoop dispenser with a flush
luer attached and clips to secure the wire within the hoop. Included
within the pouch, with the spiralled hooped guidewire, is another
pouch containing an Insertion Tool, a Tip Straightener, and a Torque
device.
The wire will be offered in straight and angled versions, in various
lengths.
Comparison
to PredicateThe Technological characteristics of the subject Merit True Form
Reshapable Guide Wire are substantially equivalent to those of
Predicate Device #1, the Boston Choice PT[K143587] and
Reference Predicate #2, the Bard Porter [K060551]. The subject
device has the same basic design as the predicates, in that they all
consist of a metallic core wire covered in a radiopaque polymer
jacket with some or all the wire jacket having a hydrophilic coating.
The fundamental technology and operating principles of the subject
and the predicates are the same and while the indications for use
wordings are not identical, the intended use is the same, with all
wires used for the placement of devices during intravascular
procedures.
Safety &
Performance
TestsNo performance standards have been established under section
514 of the Food, Drug and Cosmetic Act for these devices. A battery
of testing was conducted, on the Merit True Form Reshapable Guide
Wire, in accordance with protocols based on requirements outlined

4

Merit Medical Systems, Inc.
Merit True Form Reshapable Guide Wire
Traditional Premarket Notification 510(k)

5

in guidance's and industry standards and these were shown to meet the acceptance criteria that were determined to demonstrate substantial equivalence.

Where appropriate, the tests were based on the requirements of the following documents:

  • FDA guidance Coronary and Cerebrovascular Guide Wire ● Guidance January 1995.
  • . ISO 11070:2014, Sterile Single-Use Intravascular Catheter Introducers.
  • ISO 11135:2014 Sterilization of health care products-. Ethylene oxide-: Requirements for the development, validation and routine control of a sterilization process for medical devices.
  • ASTM F1980-07 Standard Guide for Accelerated Aging of ● Sterile Barrier Systems for Medical Devices
  • . ISO 10993-1:2009, Biological Evaluation of Medical Devices Part 1: Evaluation and Testing within a risk management process, and the FDA Modified ISO 10993 Test Profile FDA Memo G95-1.

The following is a list of all testing that was successfully completed:

Performance Testing-Bench

  • Size Designation ●
  • . Radiodetectability
  • Tip Shape Testing ●
  • Surface .
  • Tensile Strenath ●
  • Torque Strength ●
  • Torqueability
  • . Tip Flexibility
  • Fracture test ●
  • Flex test ●
  • Lubricitv ●
  • Corrosion Resistance
  • Device Compatibility ●
  • Tip Curve Shapeability ●
  • Particulate ●
  • Coating Durability ●
  • Packaging

6

Merit Medical Systems, Inc.
Merit True Form Reshapable Guide Wire
Traditional Premarket Notification 510(k)

Biocompatibility

Cytotoxicity Sensitization Irritation Acute Systemic Toxicity Pyrogenicity Genotoxicity Hemolysis Thrombogenicity Complement Activation All test results were comparable to the predicate devices and the subject Merit True Form Reshapable Guide Wire met the predetermined acceptance criteria. This has demonstrated that the subject device is substantially equivalent to the predicate devices.
Summary of Substantial Equivalence
Based on the Indications for Use, design, safety and performance testing, the subject Merit True Form Reshapable Guide Wire meets the requirements that are considered essential for its intended use and is substantively equivalent to Predicate Device #1, the Boston Choice PT [K143587], manufactured by Boston Scientific Corporation and Reference Predicate #2, the Bard Porter [K060551], manufactured by Brivant Ltd.