(264 days)
PiCCO Catheters are used as accessories for thermodilution and arterial blood pressure measurement.
PiCCO Catheters are indicated in patients where cardiovascular and circulatory volume status monitoring is necessary. Such as patients in surgical, medical, cardiac and burn specialty units as well as other specialty units where cardiovascular monitoring is desired and patients are undergoing surgical interventions of such magnitude that cardiovascular monitoring is necessary.
The PiCCO Catheter uses a thermistor to measure the blood temperature change during thermodilution. This thermistor is located in one of the two catheter lumen. The second catheter lumen ends in a Luer-Lock for connection to a pressure monitoring kit.
The thermistor is connected to a patient monitor via a dedicated plug.
The placement of the catheter into a large arterial vessel is done using the Seldinger Technique and is intended to use of up to 10 days.
The PiCCO Catheter Sets contain the following parts:
- PiCCO Catheter,
- Guidewire with dispenser and advancer,
- Introducer needles,
- Dilator (exception: the 3F Set does not include a dilator).
Five PiCCO Catheter models are available which differ in diameter and length. The PiCCO catheter set contains accessories fitting to the respective PiCCO catheter model in size.
The Catheter Set is packed into a preformed blister (PET), sealed with a Tyvek® lid and EtO sterilized.
The provided text describes a 510(k) submission for the PiCCO Catheter, which is a thermodilution probe. This submission aims to demonstrate substantial equivalence to a predicate device, rather than proving that the device meets specific acceptance criteria through a clinical study.
Therefore, many of the requested details about acceptance criteria, study design for proving performance, expert involvement, and ground truth establishment are not applicable to this type of regulatory submission as presented. The document focuses on demonstrating that the new device is as safe and effective as an already legally marketed predicate device, primarily through non-clinical performance and biocompatibility testing, along with a comparison of technological characteristics.
Here's an analysis of the provided text in response to your request, indicating where information is not applicable (N/A) to this 510(k) submission:
1. A table of acceptance criteria and the reported device performance
The document does not present specific acceptance criteria in a tabular format with corresponding reported device performance metrics in the way one would for a new device's efficacy study. Instead, it states that various tests were conducted and their results "demonstrate that the functionality and performance characteristics of the device are comparable to the predicate device."
For instance, performance testing for mechanical properties (e.g., gauging, leakage, separation force) were conducted against standards like ISO 594-1:1986 and ISO 594-2:1998, and shelf life testing was conducted according to ISO 10555-1:2013. The acceptance criterion for these tests is simply compliance with the applicable standard or demonstrated comparability, rather than specific quantitative performance targets against clinical metrics.
| Acceptance Criteria (Implied from testing) | Reported Device Performance (Summary) |
|---|---|
| Biocompatibility (ISO 10993-1) | Compliant (Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Chemical Characterization, Hemolysis, Pyrogenicity tests passed) |
| Performance Testing (ISO 594-1, ISO 594-2) | Compliant (Gauging, Liquid Leakage, Air Leakage, Separation Force, Unscrewing Torque, Ease of Assembly, Resistance to Overriding, Stress Cracking tests passed) |
| Shelf Life (ISO 10555-1) | Supports 60 months expiry (Accelerated aging data) |
| Guidewire Friction Force | Testing conducted (Result not quantified but implied compliant) |
| Electromagnetic Compatibility (IEC 60601-1-2) | Compliant |
| Functionality and Performance | Comparable to predicate device |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size:
- No specific sample sizes for clinical test sets are mentioned as clinical data were not required.
- For biocompatibility and performance testing, the sample sizes would be those dictated by the respective ISO standards for material and device testing. These are not explicitly stated in the document.
- Data Provenance:
- The testing was performed according to international standards (e.g., ISO, IEC). The location where the tests were physically performed is not specified, but the device owner is PULSION Medical Systems SE in Germany.
- The data is non-clinical performance data from laboratory and material tests, not patient data.
- It is prospective in the sense that these tests were conducted specifically for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
N/A. This is a non-clinical 510(k) submission. The "ground truth" for the test set is established by the specifications of the standards (ISO, IEC) for material and device performance, not by expert medical opinion in a diagnostic or clinical context.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
N/A. Since this is a non-clinical submission, there is no "adjudication" of results in the sense of multiple clinical reviewers reaching consensus. Test results are objective measurements against defined standards.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
N/A. This device is a physical catheter, not an AI-powered diagnostic tool requiring human reader studies.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
N/A. This device is a physical catheter and does not involve an algorithm with standalone performance.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for this 510(k) submission is based on adherence to recognized international standards and specifications for medical device materials (biocompatibility) and functional performance (e.g., mechanical integrity, shelf-life, EMC). There is no clinical ground truth (like pathology or outcomes data) directly used for this submission to prove efficacy, as clinical data was not required.
8. The sample size for the training set
N/A. There is no "training set" as this is a physical medical device, not a machine learning model.
9. How the ground truth for the training set was established
N/A. As there is no training set, this question is not applicable.
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February 21, 2018
PULSION Medical Systems SE % Mark Dinger Senior Regulatory Affairs Specialist Getinge 45 Barbour Pond Drive Wayne, New Jersey 07470
Re: K171620
Trade/Device Name: PiCCO Catheter Regulation Number: 21 CFR 870.1915 Regulation Name: Thermodilution Probe Regulatory Class: Class II Product Code: KRB Dated: January 15, 2018 Received: January 18, 2018
Dear Mark Dinger:
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-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820);
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Page 2 - Mark Dinger
and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
MA Willehemen
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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Indications for Use
510(k) Number (if known) K171620
Device Name PiCCO Catheter
Indications for Use (Describe)
PiCCO Catheters are used as accessories for thermodilution and arterial blood pressure measurement.
PiCCO Catheters are indicated in patients where cardiovascular and circulatory volume status monitoring is necessary. Such as patients in surgical, medical, cardiac and burn specialty units as well as other specialty units where cardiovascular monitoring is desired and patients are undergoing surgical interventions of such magnitude that cardiovascular monitoring is necessary.
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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GETINGE
510(K) SUMMARY
Prepared in accordance with 21 CFR Part 807.92
| 510(k) Number: | K171620 |
|---|---|
| Date Prepared: | 12 Jan 2018 |
| Device Owner: | PULSION Medical Systems SEHans-Riedl-Str. 1785622 FeldkirchenGermany |
| Contact Personnel: | Mark Dinger |
| Title: | Sr. Regulatory Affairs Specialist |
| Email: | mark.dinger@getinge.com |
| Phone: | 973-709-7691 |
| Fax: | 973-909-9954 |
| Trade Name: | PiCCO Catheter |
| Device GenericName: | Thermodilution Probe |
| Classification: | According to 21 CFR 870.1915 of the Federal Food, Drug andCosmetic Act, the device classification is Class II, Product codeKRB. |
| Predicate Device: | K072364 PULSION PULSIOCATH THERMODILUTION CATHETERS &ACCESSORIES |
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Device Description/
The PiCCO Catheter uses a thermistor to measure the blood Device Function: temperature change during thermodilution. This thermistor is located in one of the two catheter lumen. The second catheter lumen ends in a Luer-Lock for connection to a pressure monitoring kit.
The thermistor is connected to a patient monitor via a dedicated plug.
The placement of the catheter into a large arterial vessel is done using the Seldinger Technique and is intended to use of up to 10 days.
The PiCCO Catheter Sets contain the following parts:
-
- PiCCO Catheter,
-
- Guidewire with dispenser and advancer,
-
- Introducer needles,
-
- Dilator (exception: the 3F Set does not include a dilator).
Five PiCCO Catheter models are available which differ in diameter and length. The PiCCO catheter set contains accessories fitting to the respective PiCCO catheter model in size.
The Catheter Set is packed into a preformed blister (PET), sealed with a Tyvek® lid and EtO sterilized.
Scientific Concept Behind:
PiCCO catheter is used with the monitoring system for the measurement of cardiac output by the thermodilution method, measurement of arterial blood pressure, and for cardiac output determination by arterial pulse contour analysis. Additionally the thermodilution measurement allows the determination of the intrathoracic filling volumes and extravascular lung water.
To measure the thermodilution, a known volume of a cold or room-temperature bolus (e.g. normal saline 0.9%) is injected through a central venous catheter. The downstream temperature change is dependent on the flow and the volume through which the cold indicator has passed. A thermodilution curve is recorded by PiCCO Catheter, which also serves for pressure monitoring. The temperature measurement works as follows:
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The thermistor at the tip of the PiCCO catheter provides a temperature dependent resistance. The voltage measurement can detect resistance changes which can be related to temperature changes. The monitor calculates the Cardiac Output according to the Stewart-Hamilton formula using the area under the thermodilution curve. In addition, specific volumes can be calculated by multiplying cardiac output with characteristic time variables of the thermodilution curve.
The parameters can alternatively be displayed as absolute parameters or indexed to the patient´s body characteristics.
Materials Used:
| Catheter: | Thermoplastic Polyurethane (TPU), Polyamide (PA),Acrylnitril-Butadien-Styrol (ABS), lead-free solder,printing (Medical Device ink), Nickel Alloy |
|---|---|
| Dilator: | High Density Polyethylene (HD-PE) |
| Guidewire: | Stainless steel, Nickel-Titanium Alloy (Nitinol);Protective parts: Polyethylene (PE), Acrylnitril-Butadien-Styrol (ABS), Polypropylene (PP) |
| Needle: | Stainless steel, Styrene Butadiene Copolymer (SBC)and acrylic-based multipolymer |
| PrimaryPackaging: | Glycol-modified polyethylene terephthalate (PETG)and High Density Polyethylene (HD-PE) |
- Intended Use: PiCCO Catheters are used as accessories for thermodilution and arterial blood pressure measurement.
- Indications for Use: PiCCO Catheters are indicated in patients where cardiovascular and circulatory volume status monitoring is necessary. Such as patients in surgical, medical, cardiac and burn specialty units as well as other specialty units where cardiovascular monitoring is desired and patients are undergoing surgical interventions of such magnitude that cardiovascular monitoring is necessary
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GETIL
| TechnologicalCharacteristicsComparison: | The proposed PICCO Catheter and the predicate device have the following similarities:the same intended use the same operating principles incorporate the same basic design sterilized using the same materials and processes the same packaging The proposed PICCO Catheter and the predicate device have the following differences:Clarified indication for use statement and labeling Change of material at PICCO Catheter Removed Coating at guidewire The differences are not considered a significant technological difference. Therefore, the proposed PICCO Catheter is substantially equivalent to the predicate device. |
|---|---|
| Safety andPerformance: | PULSION Medical Systems development process required that the following activities to be completed during the development of the PICCO Catheter in support of a substantial equivalence determination:Biocompatibility testing Performance testing Electromagnetic compatibility testing Shelf life testing Biocompatibility Testing: |
The biocompatibility evaluation for the PiCCO Catheters was conducted in accordance with International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. The battery of testing included the following tests:
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- Cytotoxicity ●
- Sensitization
- Irritation
- Acute Systemic Toxicity
- Chemical Characterization
- Hemolysis (indirect)
- Pyrogenicity
Performance testing:
Technical and functional requirements for the PiCCO Catheter have been verified within performance testing for the changes. The following verifications were conducted:
- . Testing according ISO 594-1:1986, ISO 594-2:1998: Gauging, Liquid Leakage, Air Leakage, Separation Force, Unscrewing Torque, Ease of Assemblv. Resistance to Overriding, Stress Cracking
- Shelf Life Testing: Peak Tensile Force measurement ● before and after aging in accordance to ISO 10555-1:2013
- Guidewire Friction Force Testing
Electrical safety and Electromagnetic compatibility (EMC):
The PiCCO Catheters are non-active accessories for patient monitoring systems. Therefore electrical safety data are not included.
The Electromagnetic Compatibility of the PiCCO Catheters complies with the applicable requirements of IEC 60601-1-2:2007: Medical electrical equipment Part 1-2: General requirements for safety - Collateral standard: electromagnetic compatibility - requirements and tests.
Shelf life testing:
Accelerated aging was conducted to demonstrate 60 months (5 years) of shelf life. The study was conducted with increments of 12, 36, and 60 months.
It is concluded that the accelerated data currently available supports a 60 months expiry time from the time of manufacture. Additional real time aging studies with increments of 12, 36 and 60 months are ongoing to support the 60 months expiry dating.
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GETIL
The results of the tests conducted demonstrate that the functionality and performance characteristics of the device are comparable to the predicate device.
The results of the tests conducted demonstrate that the functionality and performance characteristics of the device are comparable to the predicate device.
| Performance Testing | |
|---|---|
| Animal: | In vivo and in vitro biocompatibility testing has been performedfor the changes in PICCO Catheter. |
| Non ClinicalPerformance: | Completion of all verification activities demonstrated that thesubject device meets all design and performance requirements.Verification activities performed confirmed that the differences inthe design did not adversely affect the safety and effectiveness ofthe subject device. |
| ClinicalPerformance: | Clinical data were not required for this device. |
| Conclusion: | The PICCO Catheter has the same intended use and the samefundamental scientific technology as the predicate device. Theperformance and other testing established that the PICCOCatheter meets the same technical and functional requirementsand is as safe as effective and performs as well than the legallymarketed device. Based upon the information submitted in thisTraditional 510(k) premarket notification, PULSION's PICCOCatheter is substantially equivalent to the currently marketedpredicate device (K072364). |
§ 870.1915 Thermodilution probe.
(a)
Identification. A thermodilution probe is a device that monitors cardiac output by use of thermodilution techniques; this device is commonly attached to a catheter that may have one or more probes.(b)
Classification. Class II (performance standards).