K Number
K171081
Device Name
Guider Catheter Introducer
Date Cleared
2017-05-09

(28 days)

Product Code
Regulation Number
870.1340
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The RXI Guider ™ Catheter Introducer is indicated for introducing various cardiovascular catheters into the heart, including the left side of the heart through the interatrial septum.
Device Description
The Guider Catheter Introducer set contains a fixed-curve introducer, integrated vessel dilator/transseptal needle (component branded as Lancer™), guidewire, and ECG adapter cable. The set is designed to facilitate vascular access to the heart and then provide catheter positioning within the cardiac anatomy. The Guider Catheter Introducer is an elongated shaft with central lumen capable of accepting the Lancer dilator/needle as well as various catheters. The Guider handle is also fitted with a hemostasis valve to minimize blood loss during catheter introduction, and/or exchange, as well as a sideport with 3way stopcock to allow blood aspiration, fluid infusion, and pressuremonitoring. The introducer shaft features distal side holes to facilitate aspiration and prevent cavitation plus an embedded platinum radiopaque tip marker to facilitate fluoroscopic visualization. The Lancer integrated dilator/needle combines a dilator and transseptal needle into a single component. The needle is used to puncture the interatrial septum to gain access to the left atrium. The Lancer consists of an elongated shaft with a tapered tip and central lumen to track over a guidewire in a similar fashion to conventional dilators. The lumen of the Lancer is fitted with a hollow stainless steel transseptal needle and both the shaft and needle are connected to the same proximal handle. The needle lumen will accept guidewire sizes up to 0.032 inches in diameter. Inside the Lancer handle, the needle is affixed to a spring-tensioned actuator that prevents needle extension until the operator purposely advances the needle via a slider button located on the outer surface of the handle. The proximal handle is fitted with a Luer connector to gain access to the central lumen of the needle. The handle is also fitted with an electrical connector to monitor an ECG from the needle while in the heart, utilizing the ECC adapter cable. The guidewire included in the set is manufactured by Lake Region Medical (K935170) and is supplied in a polypropylene retainer coil with a J-straightener and Luer fitting. The ECG adapter cable included is manufactured by Bioconnect (RF Industries, Inc.), is one (1) meter long, and has male/female DIN 0.080 inch touch- proof connectors on the ends.
More Information

No
The device description and performance studies focus on mechanical and functional aspects of a catheter introducer system. There is no mention of AI or ML in the text, and the "Mentions AI, DNN, or ML" section explicitly states "Not Found".

No.
The device is indicated for "introducing various cardiovascular catheters into the heart". It is an introducer, not a device that directly treats a disease or condition.

No

The device is described as a catheter introducer indicated for introducing various cardiovascular catheters into the heart. While it facilitates access and positioning within the cardiac anatomy and can monitor ECG from the needle, its primary function is to enable the delivery of other catheters, rather than to gather and interpret data for diagnosis itself.

No

The device description clearly outlines multiple physical components including a fixed-curve introducer, integrated vessel dilator/transseptal needle, guidewire, and ECG adapter cable. These are all hardware components.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the device is for "introducing various cardiovascular catheters into the heart." This is a procedural device used in vivo (within the body) to facilitate a medical procedure.
  • Device Description: The description details a catheter introducer set, including components like a dilator, needle, guidewire, and ECG adapter. These are all tools used for accessing and navigating within the cardiovascular system.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or compatibility testing. The ECG adapter is for monitoring electrical activity in vivo, not for analyzing a sample in vitro.

In summary, the RXI Guider ™ Catheter Introducer is a medical device used for a surgical/interventional procedure within the body, not for performing diagnostic tests on samples outside the body.

N/A

Intended Use / Indications for Use

The RXI Guider ™ Catheter Introducer is indicated for introducing various cardiovascular catheters into the heart, including the left side of the heart through the interatrial septum.

Product codes (comma separated list FDA assigned to the subject device)

DYB

Device Description

The Guider Catheter Introducer set contains a fixed-curve introducer, integrated vessel dilator/transseptal needle (component branded as Lancer™), guidewire, and ECG adapter cable. The set is designed to facilitate vascular access to the heart and then provide catheter positioning within the cardiac anatomy.

The Guider Catheter Introducer is an elongated shaft with central lumen capable of accepting the Lancer dilator/needle as well as various catheters. The Guider handle is also fitted with a hemostasis valve to minimize blood loss during catheter introduction, and/or exchange, as well as a sideport with 3way stopcock to allow blood aspiration, fluid infusion, and pressuremonitoring. The introducer shaft features distal side holes to facilitate aspiration and prevent cavitation plus an embedded platinum radiopaque tip marker to facilitate fluoroscopic visualization.

The set includes the following accessories:

  • Lancer Integrated Dilator/Needle
  • J-Tip Guidewire
  • ECG Adapter

The Lancer integrated dilator/needle combines a dilator and transseptal needle into a single component. The needle is used to puncture the interatrial septum to gain access to the left atrium. The Lancer consists of an elongated shaft with a tapered tip and central lumen to track over a guidewire in a similar fashion to conventional dilators. The lumen of the Lancer is fitted with a hollow stainless steel transseptal needle and both the shaft and needle are connected to the same proximal handle. The needle lumen will accept guidewire sizes up to 0.032 inches in diameter. Inside the Lancer handle, the needle is affixed to a spring-tensioned actuator that prevents needle extension until the operator purposely advances the needle via a slider button located on the outer surface of the handle. The proximal handle is fitted with a Luer connector to gain access to the central lumen of the needle. The handle is also fitted with an electrical connector to monitor an ECG from the needle while in the heart, utilizing the ECC adapter cable.

The distal end of the Lancer handle and the proximal end of the Guider handle are designed with male/female surfaces to mate the components together in a snap-fit closure.

The guidewire included in the set is manufactured by Lake Region Medical (K935170) and is supplied in a polypropylene retainer coil with a J-straightener and Luer fitting. The Luer fitting is compliant to ISO 594-1 and ISO 594-2. The ECG adapter cable included is manufactured by Bioconnect (RF Industries, Inc.), is one (1) meter long, and has male/female DIN 0.080 inch touch- proof connectors on the ends.

There are four (4) models of the Guider Catheter Introducer set based on useable length and/or degree of tip curvature (the Lancer component is length-matched to the Guider introducer). All models have an inner diameter of 8.5 French. These include:

  • L1 (45°), 50 cm, 8.5 French
  • L1 (45°), 65 cm, 8.5 French
  • L2 (90°), 50 cm, 8.5 French
  • L2 (90°), 65 cm, 8.5 French

The Guider Catheter Introducers are shipped sterile in sealed Tyvek® pouches placed inside a cardboard shelf box and labeled single use only. Sterilization is by ethylene oxide.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Fluoroscopic Visualization
Intracardiac Echocardiographic Visualization

Anatomical Site

heart, interatrial septum

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Prescription Use (Part 21 CFR 801 Subpart D)

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)

Biocompatibility Testing:
The Guider Catheter Introducer underwent the following biocompatibility tests: Hemocompatibility (Hemolysis Test, Complement Activation, Platelet and Leukocyte, Partial Thromboplastin Time (PTT), Prothrombin Time Assay (PT)), Cytotoxicity (MEM Elution: L-929 Mouse Fibroblast Cells), Sensitization (Guinea Pig Maximization (2 extracts)), Irritation (Intracutaneous Reactivity Test (2 extracts)), Pyrogen (Materials Mediated Pyrogenicity Test), Systemic Toxicity (Acute Systemic Toxicity Test (Aqueous and Non-Aqueous Extract)), In vivo thrombogenicity (4-hour Thrombogenicity; 2 canines, Guider and Lancer separately). All testing completed passed with the results listed. The full protocols and results for each test are contained in this submission.

Sterilization Validation:
The Guider Catheter Introducer will be offered as sterile to a 10th sterility assurance level (SAL) by an ethylene oxide (EO) sterilization process. The device will undergo EO sterilization at STERIS Isomedix. The sterilization protocol conducted by STERIS Isomedix established the procedures for validation of an ethylene oxide sterilization process for this device. The performance qualifications will be executed using the overkill approach as referenced in the international standard, ANSI/AAMI/ISO 11135. The following tests are conducted to assess the product sterilization: Biological Indicator Population Enumeration Testing, Bioburden Testing, Product Sterility Testing, Bacteriostasis/Fungistasis Testing, Biological Indicator Sterility Testing, EO Residuals Testing. Results: The Sterilization Validation for the Guider Catheter Introducer is pending. The protocol is contained in the submission.

Packaging Testing:
The devices underwent the following distribution and packaging testing: Environmental Conditioning, Distribution Simulation, Dimensional/Visual Inspection, Package Integrity/Bubble Test, Package Integrity/Peel Strength. Prior to the testing, all samples had undergone 2x EO sterilization cycles. The units/shippers were subjected to environmental conditioning followed by the distribution simulation per ASTM D 4169-09, Distributions Cycle 13; Assurance Level II, and thermal conditioning per ISTA 2A (2011). Results: The Guider Catheter Introducer passed all distribution and packaging testing. The full protocols and results for each test are contained in the submission.

Shelf Life Testing:
The Guider Catheter Introducer will be labeled with a 12-month shelf life. In addition to baseline testing after 2x EO sterilization, environmental conditioning and distribution simulation (T=0), additional devices were subjected to 12-month accelerated aging (T=12aa) and 12-month real- time aging (T=12rt, ongoing at time of submission). The T=12aa test devices were subjected to accelerated aging environmental conditions of 55°C ± 2°C and

§ 870.1340 Catheter introducer.

(a)
Identification. A catheter introducer is a sheath used to facilitate placing a catheter through the skin into a vein or artery.(b)
Classification. Class II (performance standards).

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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 circular seal with the text "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, with flowing lines representing hair or clothing.

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

May 09, 2017

Rhythm Xience, Inc. c/o Mark Job Regulatory Technology Services LLC 1394 25th Street NW Buffalo, MN 55313

Re: K171081

Trade/Device Name: Guider Catheter Introducer Regulation Number: 21 CFR 870.1340 Regulation Name: Catheter Introducer Regulatory Class: Class II Product Code: DYB Dated: April 7, 2017 Received: April 11, 2017

Dear Mr. Job:

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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

1

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" (21CFR 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. Hilleman

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)

K171081

Device Name GUIDER™ CATHETER INTRODUCER

Indications for Use (Describe)

The RXI Guider ™ Catheter Introducer is indicated for introducing various cardiovascular catheters into the heart, including the left side of the heart through the interatrial septum.

Type of Use (Select one or both, as applicable)
-------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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5.0 510(k) SUMMARY AS REQUIRED BY 21 CFR 807.92

510(k) Number: K or TBD [X]

Date Prepared: March 22, 2017

Table 5.1 SUBMITTER INFORMATION

Submitter:Rhythm Xience Inc.
Street Address:10025 Valley View Road
Suite 130
Eden Prairie, MN 55344
Contact Person:Jim Hassett
Phone:952-479-7903
Email:jimhassett@rhythm-xience.com

Establishment registration: awaiting 510(k) clearance prior to initial registration/listing

Table 5.2 DEVICE INFORMATION

Trade NameGuider™ Catheter Introducer
Common NameCatheter Introducer
Classification NameIntroducer, Catheter
Regulation /Product Code21 CFR 870.1340
Product CodeDYB
Regulatory Classification:Class II
Device Panel:Cardiovascular

The RXI Guider Catheter Introducer is substantially equivalent to the previously-cleared, St. Jude Medical (SJM) Swartz™ Braided Transseptal Guiding Introducer, K052644.

Table 5.3 PREDICATE DEVICE

Predicate DeviceManufacturerFDA 510(k)
Swartz™ Braided Transseptal Guiding
IntroducerSt. Jude Medical, Inc.K052644

5.1 Device Description

The Guider Catheter Introducer set contains a fixed-curve introducer, integrated vessel dilator/transseptal needle (component branded as Lancer™), guidewire, and ECG adapter cable. The set is designed to facilitate vascular access to the heart and then provide catheter positioning within the cardiac anatomy (see Figure 5.1).

4

Image /page/4/Picture/0 description: The image shows a "Guider™ Introducer Kit" laid out on a white surface against a dark background. The kit includes several components, such as a Guider Introducer, a Lancer dilator/needle, an ECG adapter, and a guidewire. The components are neatly arranged and labeled, providing a clear view of the kit's contents. The kit appears to be a medical device used for introducing catheters or other instruments into the body.

Figure 5.1 Guider Introducer Set

The Guider Catheter Introducer is an elongated shaft with central lumen capable of accepting the Lancer dilator/needle as well as various catheters. The Guider handle is also fitted with a hemostasis valve to minimize blood loss during catheter introduction, and/or exchange, as well as a sideport with 3way stopcock to allow blood aspiration, fluid infusion, and pressuremonitoring. The introducer shaft features distal side holes to facilitate aspiration and prevent cavitation plus an embedded platinum radiopaque tip marker to facilitate fluoroscopic visualization (see Figure 5.2 and Figure 5.3).

Image /page/4/Figure/3 description: This image shows a medical instrument with a fixed-curve tip. The instrument also has a sideport with a 3-way stopcock. The proximal handle has a hemostasis valve.

Figure 5.2 Guider Catheter Introducer

5

Image /page/5/Figure/0 description: The image shows a medical instrument with a blue handle and a long, thin, gray tube. The effective lengths of the instrument are 50 cm and 65 cm. The fixed curve angles are 45 degrees and 90 degrees. The inner diameter (ID) at the tip is .114" and .110", while the outer diameter (OD) at the tip is .158" and .140".

Figure 5.3 Guider Dimensional Drawing

The set includes the following accessories (see Figure 5.4):

  • Lancer Integrated Dilator/Needle
  • J-Tip Guidewire
  • ECG Adapter

Image /page/5/Picture/6 description: The image shows medical equipment including a Lancer dilator/needle, a guidewire, and an ECG adapter. The Lancer dilator/needle is blue and has a long, thin needle. The guidewire is a thin, flexible wire that is used to guide the catheter through the blood vessel. The ECG adapter is red and has two clips that attach to the patient's skin. The equipment is laid out on a white surface.

Figure 5.4 Guider Accessories

6

The Lancer integrated dilator/needle combines a dilator and transseptal needle into a single component (see Figures 5.5 - 5.7). The needle is used to puncture the interatrial septum to gain access to the left atrium similar to the St. Jude Medical BRK™ Transseptal Needle (K072278). The Lancer consists of an elongated shaft with a tapered tip and central lumen to track over a guidewire in a similar fashion to conventional dilators. The lumen of the Lancer is fitted with a hollow stainless steel transseptal needle and both the shaft and needle are connected to the same proximal handle. The needle lumen will accept guidewire sizes up to 0.032 inches in diameter. Inside the Lancer handle, the needle is affixed to a spring-tensioned actuator that prevents needle extension until the operator purposely advances the needle via a slider button located on the outer surface of the handle. The proximal handle is fitted with a Luer connector to gain access to the central lumen of the needle. The handle is also fitted with an electrical connector to monitor an ECG from the needle while in the heart, utilizing the ECC adapter cable. This is done in a similar manner as pericardiocentesis kits whereby electrocardiograms are monitored from the needle during use (reference Figure 5.8, Boston Scientific Peri Vac Pericardiocentesis Kit, K032050).

Figure 5.5 Lancer integrated dilator/needle. Panel A is a profile technical drawing depicting the internal components of the handle. Panel B illustrates the handle features.

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Image /page/7/Figure/0 description: The image shows a medical device, specifically a needle inside the lumen of a dilator shaft. The device has a long, thin, blue shaft with a handle on one end. A magnified view shows the needle inside the dilator shaft, with markings along the shaft. The image provides a detailed view of the device's construction.

Figure 5.6 Lancer with inset depicting internal needle in baseline retracted position

Image /page/7/Figure/2 description: The image shows a diagram of a medical instrument. The instrument has a blue handle that is 9 cm long. The instrument has a long, thin tube with a fixed curve angle of 70 degrees at the end, and the needle at the end has an ID of .035" and an OD of .042".

Figure 5.7 Lancer Dimensional Drawing

8

Image /page/8/Picture/0 description: The image shows a medical kit in a white tray. The kit contains various medical supplies, including syringes, a guidewire, and an ECG adapter. The ECG adapter is labeled with an arrow pointing to it. The kit appears to be for a medical procedure, possibly involving cardiac monitoring.

Figure 5.8 Boston Scientific PeriVac Pericardiocentesis Kit

The distal end of the Lancer handle and the proximal end of the Guider handle are designed with male/female surfaces to mate the components together in a snap-fit closure (see Figure 5.9).

Image /page/8/Figure/3 description: The image shows a Lancer connected to a Guider. The Lancer and Guider are connected via a male/female interface. The Lancer is on the left side of the image, and the Guider is on the right side of the image.

Figure 5.9 Guider to Lancer mating feature

9

The guidewire included in the set is manufactured by Lake Region Medical (K935170) and is supplied in a polypropylene retainer coil with a J-straightener and Luer fitting. The Luer fitting is compliant to ISO 594-1 and ISO 594-2. The ECG adapter cable included is manufactured by Bioconnect (RF Industries, Inc.), is one (1) meter long, and has male/female DIN 0.080 inch touch- proof connectors on the ends.

The patient-contacting materials used in the Guider Catheter Introducer set are listed in Table 5.4. A detailed listing of all materials used in the set is provided in the submission.

ComponentMaterials
Guider
ShaftPebax (6333, 3533) with Barium Sulfate and gray colorant
Polytetrafluoroethylene (PTFE)
Polyvinyl chloride (PVC)
Ethyl Cyanoacrylate
Polycarbonate, High Density Polyethylene (HDPE)
Acrylic UV Curable
Polypropylene, White
Siloxane Lubricant (Nusil MED-4162)
304 Stainless Steel
Platinum
SideportPolycarbonate, High Density Polyethylene (HDPE)
Polyvinyl Chloride (PVC)
UV Adhesive
Hemostasis Valve
AssemblyPolyisoprene
Buna-N, Durometer Shore A50
304 Stainless Steel
Acrylonitrile butadiene styrene (ABS) with white colorant
Acrylic UV Curable
Silicone, Nusil Med-420
Ethyl Cyanoacrylate
Lancer Dilator/Needle
ShaftPolyethylene Hexene Copolymer
Ethylene Homopolymer
Barium Sulfate with blue colorant
Hypotube304 Stainless Steel
Needle304 Stainless Steel
Luer FittingPolycarbonate
Guidewire
GuidewirePolytetrafluoroethylene (PTFE) coated stainless steel

Table 5.4 Guider Catheter Introducer set List of Materials

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There are four (4) models of the Guider Catheter Introducer set based on useable length and/or degree of tip curvature (the Lancer component is length-matched to the Guider introducer). All models have an inner diameter of 8.5 French. These include:

    1. L1 (45°), 50 cm, 8.5 French
    1. L1 (45°), 65 cm, 8.5 French
    1. L2 (90°), 50 cm, 8.5 French
    1. L2 (90°), 65 cm, 8.5 French

The Guider Catheter Introducers are shipped sterile in sealed Tyvek® pouches placed inside a cardboard shelf box and labeled single use only. Sterilization is by ethylene oxide.

5.2 Indications for Use

The Guider Catheter Introducer is indicated for introducing various cardiovascular catheters into the heart, including the left side of the heart through the interatrial septum.

5.3 Summary of Testing

The Guider Catheter Introducer set underwent the tests listed in Table 5.5. Testing was conducted at three different time intervals:

  • Baseline 2x sterilization, environmental conditioning and distribution simulation (T=0) 1)
    1. Accelerated aging - 2x sterilization and 12-month accelerated aging (T=12aa)
    1. Real-time aging - 2x sterilization and 12-month real-time aging (T=12rt).

The testing was performed by the following vendors and locations:

  • Biocompatibility testing and an animal study was performed at American Preclinical Services, ● Inc., located in Minneapolis, MN.
  • Sterilization testing was performed by Steris Isomedix, located in Minneapolis, MN.
  • Environmental Conditioning, Distribution Simulation Testing, Accelerated Aging, Peel Strength and Bubble Leak Testing were performed by Distribution Dynamic Labs, Inc. (DDL) in Eden Prairie, MN.
  • Particulate testing was performed at Nelson Labs located in Salt Lake City, UT.
  • . Electrical testing was performed at Medical Equipment Compliance Associates, LLC. (MECA) located in Franklin, WI.
  • All other testing was performed internally at CRI-Devices in Maple Grove, MN. ●

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Table 5.5 SUMMARY OF TESTING
Test TypeTest Name
BiocompatibilityHemocompatibility
Cytotoxicity
Sensitization
Irritation
Pyrogenicity
Systemic Toxicity
Thrombogenicity
Sterilization ValidationLAL
Bioburden
EO residuals
PackagingEnvironmental Conditioning
Distribution Simulation -Post Environmental Conditioning
Visual Evaluation - Post Environmental Conditioning/
Distribution Simulation
Bubble Test - Post Environmental Conditioning/ Distribution
Simulation/ Visual Evaluation
Seal Strength- Post Environmental Conditioning/ Distribution
Simulation/ Visual Evaluation/ Bubble Leak
Shelf Life12 Month Accelerated Aging
12 Month Real Time Aging
InspectionCorrosion Resistance
Surface Inspection
Tip Curve Retention
Dimensional Verification
Functional TestingPushability/Trackability
Sheath Compatibility (Insertion/Withdrawal Force)
System Leak (Hemostasis, Luer, Aspiration)
Coating Integrity (Particulate, Friction)
Radiopacity
Needle Actuation
Electrical Continuity Pin-Needle
MechanicalKink Resistance
Torque Resistance
Tip/Marker band Tensile
Sheath to Hemostasis Valve Tensile
Shaft to Handle Tensile
Needle to Button Tensile
Luer to Hypo. Tensile
Flushing Tubing to Stopcock Tensile
Flushing Tubing to Hemostasis Valve Tensile
ElectricalElectrical Safety IEC 60601
Animal Study ComparingAccess from packaging
to Predicate DeviceVisual Inspection
Preparation
Preliminary Device Function
Advancement of Guidewire to Superior Vena Cava
Test TypeTest Name
Fluoroscopic Visualization
Intracardiac Echocardiographic Visualization
Fossa Ovalis Localization
Maintenance of component orientation
ECG Monitoring
Fossa Ovalis Puncture
Needle Lumen Function
Dilator Crossing of Fossa Ovalis
Sheath Crossing of Fossa Ovalis
Removal of Device
Overall Performance
Device Function -Aspirate, Flush, Transduce

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5.3.1 Biocompatibility

The Guider Catheter Introducer underwent the following biocompatibility tests as shown in Table 5.6. All testing completed passed with the results listed.

Test typeTest nameResult
HemocompatibilityHemolysis Test; ASTM F756
Method; Direct Contact and Extract
ContactPass,
Non- Hemolytic
HemocompatibilityComplement Activation; C3a Assay
and SC5b-9 AssayPass,
Non-Reactive
HemocompatibilityPlatelet and LeukocytePass
HemocompatibilityPartial Thromboplastin Time (PTT)Pass, Non-Activator
HemocompatibilityProthrombin Time Assay (PT)Pass
CytotoxicityMEM Elution: L-929 Mouse
Fibroblast CellsPass,
Non-Cytotoxic
SensitizationGuinea Pig Maximization (2
extracts)Pass,
Non-Sensitizer
IrritationIntracutaneous Reactivity Test (2
extracts)Pass,
Non-Irritant
PyrogenMaterials Mediated Pyrogenicity
TestPass,
Non- Pyrogenic

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Test typeTest nameResult
Systemic ToxicityAcute Systemic Toxicity Test
(Aqueous and Non-Aqueous
Extract)Pass, Non-Toxic
In vivo
thrombogenicity4-hour Thrombogenicity; 2 canines,
Guider and Lancer separatelyPass, Non-Thrombogenic

Results

The Guider Catheter Introducer passed all biocompatibility testing. The full protocols and results for each test are contained in this submission.

5.3.2 Sterilization

The Guider Catheter Introducer will be offered as sterile to a 10th sterility assurance level (SAL) by an ethylene oxide (EO) sterilization process. The device will undergo EO sterilization at STERIS Isomedix, located at 380 90th Ave NW, Minneapolis, MN 55433. The sterilization protocol conducted by STERIS Isomedix established the procedures for validation of an ethylene oxide sterilization process for this device. The performance qualifications will be executed using the overkill approach as referenced in the international standard, ANSI/AAMI/ISO 11135.

The following tests are conducted to assess the product sterilization:

  • · Biological Indicator Population Enumeration Testing
  • · Bioburden Testing
  • · Product Sterility Testing
  • · Bacteriostasis/Fungistasis Testing
  • · Biological Indicator Sterility Testing
  • · EO Residuals Testing

Results

The Sterilization Validation for the Guider Catheter Introducer is pending. The protocol is contained in the submission.

5.3.3 Packaging

The Guider Catheter Introducer sets are situated on a high-density polyethylene (HDPE) backer card and are shipped sterile in sealed Tyvek® pouches placed inside a cardboard shelf box and are labeled as single use only. The devices underwent the following distribution and packaging testing:

  • · Environmental Conditioning
  • · Distribution Simulation
  • · Dimensional/Visual Inspection
  • · Package Integrity/Bubble Test

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  • Package Integrity/Peel Strength
    Prior to the testing, all samples had undergone 2x EO sterilization cycles at STERIS Isomedix. The sterilized units were packaged into shippers. The units/shippers were subjected to environmental conditioning followed by the distribution simulation per ASTM D 4169-09, Distributions Cycle 13; Assurance Level II, and thermal conditioning per ISTA 2A (2011).

Testing was performed by Distribution Dynamic Labs, Inc. (DDL, Inc.) located at 10200 Valley View Road, Eden Prairie, MN 55344.

Results

The Guider Catheter Introducer passed all distribution and packaging testing. The full protocols and results for each test are contained in the submission.

5.3.4 Shelf Life

The Guider Catheter Introducer will be labeled with a 12-month shelf life. In addition to baseline testing after 2x EO sterilization, environmental conditioning and distribution simulation (T=0), additional devices were subjected to 12-month accelerated aging (T=12aa) and 12-month real- time aging (T=12rt, ongoing at time of submission). The T=12aa test devices were subjected to accelerated aging environmental conditions of 55°C ± 2°C and