K Number
K172899
Device Name
Vygon PICCs
Manufacturer
Date Cleared
2018-02-26

(157 days)

Product Code
Regulation Number
880.5970
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The catheter is indicated for short or long term peripheral access to the central venous system for intravenous therapy, power injection of contrast media, and allow(s) for central venous pressure monitoring, infusion or therapy, use 4 French or larger catheter. The maximum recommended infusion rate is 5mL/section of contrast media. For central venous pressure monitoring, it is recommended that catheter lumen of 20 gauge or larger be used.
Device Description
The Vygon PICCs are sterile, single-use, polyurethane PICCs with the same intended use, indications for use, similar design, similar sizes, similar or the same materials, and similar properties as the predicate device.
More Information

Not Found

No
The summary describes a standard PICC catheter and does not mention any AI or ML components or functionalities.

Yes
The device is described as a catheter indicated for "intravenous therapy," "infusion or therapy," and for accessing the central venous system, which are all therapeutic actions.

No

The device is a catheter for intravenous therapy, power injection, and central venous pressure monitoring, not for diagnosing a medical condition.

No

The device description explicitly states it is a "polyurethane PICC," which is a physical catheter, not software. The performance studies also focus on bench testing, sterilization, and biocompatibility, which are relevant to a physical device.

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

Here's why:

  • Intended Use: The intended use clearly describes a device used for accessing the central venous system for intravenous therapy, power injection, and pressure monitoring. These are all procedures performed in vivo (within the living body).
  • Device Description: The description confirms it's a catheter, a device used for insertion into the body.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens (like blood, urine, or tissue) in vitro (outside the body) to provide information about a physiological state, health, or disease.

IVD devices are specifically designed for testing samples taken from the body to diagnose or monitor conditions. This device is designed for direct intervention and access within the body.

N/A

Intended Use / Indications for Use

The catheter is indicated for short or long term peripheral access to the central venous system for intravenous therapy, power injection of contrast media, and allow(s) for central venous pressure monitoring. For blood sampling, infusion or therapy, use 4 French or larger catheter. The maximum recommended infusion rate is 5mL/sec for power injection of contrast media. For central venous pressure monitoring, it is recommended that catheter lumen of 20 gauge or larger be used.

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

LJS

Device Description

All characteristics of the Vygon PICCs are substantially equivalent to the predicate device, the Bard Access Systems 5 Fr DL PowerPICC® catheter. Both the subject and the predicate catheters are sterile, single-use, polyurethane PICCs with the same intended use, indications for use, similar design, similar sizes, similar or the same materials, and similar properties.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

central venous system

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Bench Testing: Vygon PICCs underwent various bench tests, including Dimensional Inspections, Catheter Conditioning (Saline), Leak Test, Priming Volume Test, Gravity Flow Test, Pump Flow Test, Tensile Test, Burst Test, Power Injection Conditioning, Printing Font Size, Ink Permanence, Luer Taper Test, Functional Testing, Ink Integrity Test, Aspiration Flow Test, Luer Color/Orientation Test, Clamp Closure Maintenance Test, and Clamp and ID Tag Fit Test, Clamp Actuation Test. All bench tests passed.
Aged Performance Testing: Vygon PICCs were tested for Power Injection Conditioning and Burst Test after accelerated 12 months of aging, and both passed.
Sterilization Testing: Sterilization tests included Seal Strength (passed), Bubble Leak (passed), LAL Testing (passed), and EO Residual Testing (passed).
Performance testing for catheter stiffness and catheter flexural fatigue tolerance was completed on the final finished sterile devices with acceptable results.
Biocompatibility Testing: Tests included Cytotoxicity (Non-cytotoxic), Sensitization (Non-sensitizer), Irritation (Non-irritant), Acute Systemic Injection (Non-toxic), Material Mediated Pyrogen (Non-pyrogenic), Hemolysis (extract and direct, both Non-hemolytic), Complement Activation (Similar when compared to predicate), Partial Thromboplastin Time (PTT) (Minimal activator (same as predicate)), Dog Thrombogenicity (Equivocal similar), and Implantation (Non-irritant). Extractable/Leachable Analysis was summarized, and Subacute/Subchronic Toxicity, Genotoxicity, Chronic Toxicity and Carcinogenicity were evaluated in a Toxicological Risk Assessment.
Clinical Testing: No clinical testing was performed.

Key results: Through performance bench testing the subject devices have demonstrated that they are substantially equivalent to the predicate device.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K051672

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5970 Percutaneous, implanted, long-term intravascular catheter.

(a)
Identification. A percutaneous, implanted, long-term intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings, such as luer hubs, and accessories that facilitate the placement of the device. The device allows for repeated access to the vascular system for long-term use of 30 days or more, and it is intended for administration of fluids, medications, and nutrients; the sampling of blood; and monitoring blood pressure and temperature. The device may be constructed of metal, rubber, plastic, composite materials, or any combination of these materials and may be of single or multiple lumen design.(b)
Classification. Class II (special controls) Guidance Document: “Guidance on Premarket Notification [510(k)] Submission for Short-Term and Long-Term Intravascular Catheters.”

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".

February 26, 2018

Vygon USA Jillian Mikovich Regulatory Affairs Manager 2750 Morris Rd. Suite A200 Lansdale, Pennsylvania 19460

Re: K172899

Trade/Device Name: Vygon PICCs Regulation Number: 21 CFR 880.5970 Regulation Name: Percutaneous, Implanted, Long-Term Intravascular Catheter Regulatory Class: Class II Product Code: LJS Dated: January 26, 2018 Received: January 29, 2018

Dear Jillian Mikovich:

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.

1

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); 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.

Tina
Kiang-S

Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K172899

Device Name

Vygon PICCs

Indications for Use (Describe)

The catheter is indicated for short or long term peripheral access to the central venous system for intravenous therapy, power injection of contrast media, and allow(s) for central venous pressure monitoring, infusion or therapy, use 4 French or larger catheter. The maximum recommended infusion rate is 5mL/section of contrast media. For central venous pressure monitoring, it is recommended that catheter lumen of 20 gauge or larger be used.

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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Image /page/3/Picture/0 description: The image shows the Vygon logo. The logo consists of the word "VYGON" in white letters on a green background, with a red triangle above the "V". Below the main logo, the words "Value Life" are written in a smaller, gray font.

K172899 510(k) Summary (21 CFR 807.92(c))

I. Submitter Information

Submitter Name:Vygon
Address:2750 Morris Road, Suite A200
Lansdale, PA 19446
Telephone:215-390-2002
Fax:215-672-6740
Contact Person:Jillian Mikovich
Email of Contact:jmikovich@vygonus.com
Date Prepared:February 23, 2018

II. Device

Device Name:Vygon PICCs
Common Name:Vygon PICCs
Common/Usual Name:Peripherally Inserted Central Catheter (PICC)
Classification Name:Percutaneous, Implanted, Long-Term Intravascular
Catheter
Classification Panel:General Hospital
Regulation Device Name:Catheter, Intravascular, Therapeutic, Long-Term Greater
Than 30 Days
Regulation Number:21 CFR 880.5970
Regulatory Class:2
Product Code:LIS

III. Predicate Device

Predicate Name:5 Fr DL PowerPICC® Catheter
Trade Name:5 Fr DL PowerPICC® Catheter
Common/Usual Name:Peripherally Inserted Central Catheter (PICC)
Classification Name:LJS - Percutaneous, Implanted, Long-Term Intravascular
Catheter
Premarket Notification:K051672
Manufacturer:Bard Access Systems, Inc.

Per the FDA Medical Device Recalls Database, this predicate has not been subject to a design related recall.

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Image /page/4/Picture/0 description: The image shows the Vygon logo. The logo consists of the word "VYGON" in white letters inside a green rounded rectangle with a red triangle above the "V". Below the rectangle, the words "Value Life" are written in a smaller, gray font.

IV. Indications for Use

The catheter is indicated for short or long term peripheral access to the central venous system for intravenous therapy, power injection of contrast media, and allow(s) for central venous pressure monitoring. For blood sampling, infusion or therapy, use 4 French or larger catheter. The maximum recommended infusion rate is 5mL/sec for power injection of contrast media. For central venous pressure monitoring, it is recommended that catheter lumen of 20 gauge or larger be used.

The Indications for Use statement for the Vygon PICCs is not identical to the predicate device, 5 Fr DL PowerPICC® Catheter, Indications for Use; however, the differences do not alter the intended therapeutic use of the device. Both the subject and predicate devices have the same intended use for short or long term peripheral access to the central venous system for intravenous therapy and blood sampling.

V. Technological Characteristics

All characteristics of the Vygon PICCs are substantially equivalent to the predicate device, the Bard Access Systems 5 Fr DL PowerPICC® catheter. Both the subject and the predicate catheters are sterile, single-use, polyurethane PICCs with the same intended use, indications for use, similar design, similar sizes, similar or the same materials, and similar properties. See comparison table below.

| Attribute | Predicate:
Predicate Device
DL | Subject Device 1
SL | Subject Device 2
DL | Subject Device 3
TL |
|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | 5 Fr DL
PowerPICC®
Catheter | Vygon PICC 4 Fr
SL | Vygon PICC 5 Fr
DL | Vygon PICC 6 Fr
TL |
| 510(k) Number | K051672 | K172899 | K172899 | K172899 |
| 510(k)
Submitter | Bard Access
Systems (BAS) | Vygon USA | Vygon USA | Vygon USA |
| Trade Name | 5 Fr DL
PowerPICC®
Catheter | Vygon PICC 4 Fr
SL | Vygon PICC 5 Fr
DL | Vygon PICC 6 Fr
TL |
| Common
Name | Peripherally
Inserted Central
Catheter (PICC) | Same as Predicate | Same as Predicate | Same as Predicate |
| Attribute | Predicate:
Predicate Device
DL | Subject Device 1
SL | Subject Device 2
DL | Subject Device 3
TL |
| Device Name | 5 Fr DL
PowerPICC®
Catheter | Vygon PICC 4 Fr
SL | Vygon PICC 5 Fr
DL | Vygon PICC 6 Fr
TL |
| Classification
Name | Catheter,
Intravascular,
Therapeutic, Long-
Term Intravascular
Catheter | Same as Predicate | Same as Predicate | Same as Predicate |
| Regulatory
Class | 2 | Same as Predicate | Same as Predicate | Same as Predicate |
| Classification
Regulation | 21 CFR 880.5970 | Same as Predicate | Same as Predicate | Same as Predicate |
| Product Code | LJS | Same as Predicate | Same as Predicate | Same as Predicate |
| Review Panel /
Division | General Hospital | Same as Predicate | Same as Predicate | Same as Predicate |
| Indications for
Use | The PowerPICC®
catheter is
indicated for short
or long term
| The catheter is
indicated for short
or long term
peripheral access to
the central venous
system for
intravenous
therapy, power
injection of contrast
media, and allow(s)
for central venous
pressure
monitoring. For
blood sampling,
infusion or therapy,
use 4 French or
larger catheter. The
maximum
recommended
infusion rate is
5mL/sec for power
injection of contrast
media. For central
venous pressure
monitoring, it is | The catheter is
indicated for short
or long term
peripheral access to
the central venous
system for
intravenous
therapy, power
injection of contrast
media, and allow(s)
for central venous
pressure
monitoring. For
blood sampling,
infusion or therapy,
use 4 French or
larger catheter. The
maximum
recommended
infusion rate is
5mL/sec for power
injection of contrast
media. For central
venous pressure
monitoring, it is | The catheter is
indicated for short
or long term
peripheral access to
the central venous
system for
intravenous
therapy, power
injection of contrast
media, and allow(s)
for central venous
pressure
monitoring. For
blood sampling,
infusion or therapy,
use 4 French or
larger catheter. The
maximum
recommended
infusion rate is
5mL/sec for power
injection of contrast
media. For central
venous pressure
monitoring, it is |
| Attribute | Predicate:
Predicate Device
DL | Subject Device 1
SL | Subject Device 2
DL | Subject Device 3
TL |
| Device Name | 5 Fr DL
PowerPICC®
Catheter | Vygon PICC 4 Fr
SL | Vygon PICC 5 Fr
DL | Vygon PICC 6 Fr
TL |
| | catheter may not
exceed 300 psi. | catheter lumen of
20 gauge or larger
be used. | catheter lumen of
20 gauge or larger
be used. | catheter lumen of
20 gauge or larger
be used. |
| Intended Use | The catheters are
intended for short
or long term
peripheral access
to the central
venous system for
intravenous
therapy and blood
sampling. | Same as Predicate | Same as Predicate | Same as Predicate |

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Image /page/5/Picture/0 description: The image shows the Vygon logo. The logo consists of the word "VYGON" in white letters inside a green rounded rectangle with a red triangle above the "V". Below the rectangle, the words "Value Life" are written in gray.

2750 Morris Road, Suite A200 • Lansdale, PA 19446 • Telephone: 215-390-2002 • Fax: 215-672-6740 Email: email@vygonus.com • Website: www.vygonusa.com

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Table 1: Substantial Equivalence Comparison Table

VI. Performance Testing

Vygon PICCs were tested per Table 2 and Table 3 below.

Special controls for the Product Code LJS include the guidance document "Guidance on Premarket Notification [510(K)] Submissions for Short-Term and Long-Term Intravascular Catheters" and the consensus standards:

  • ISO 10555-1 Second edition 2013-06-15 Intravascular catheters -- Sterile and single-● use intravascular catheters -- Part 1: General requirements
  • ISO 10555-3 Second edition 2013-06-15 Intravascular catheters -- Sterile and singleuse catheters -- Part 3: Central venous catheters
  • . ISO 10555-1 and ISO 10555-3 requirements have been addressed and met.

Other requirements listed in the guidance document "Guidance on Premarket Notification [510(K)] Submissions for Short-Term and Long-Term Intravascular Catheters" have been met in the development of the device and are described below.

Bench Testing

Bench tests are listed below.

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Image /page/7/Picture/0 description: The image is a logo for Vygon. The logo consists of the word "VYGON" in white letters on a green rounded rectangle. There is a red triangle above the "V" in Vygon. Below the green rectangle, the words "Value Life" are written in gray.

StandardSterile Device TestResult
ISO 9626:2016Dimensional InspectionsPassed
ISO 10555-1:2014Catheter Conditioning (Saline)Passed
ISO 10555-1:2014Leak TestPassed
Internal RequirementPriming Volume TestPassed
ISO 10555-1:2014Gravity Flow TestPassed
ISO 10555-1:2014Pump Flow TestPassed
ISO 10555-1:2014Tensile TestPassed
ISO 10555-1:2014Burst TestPassed
ISO 10555-1:2014Power Injection ConditioningPassed
Internal RequirementPrinting Font SizePassed
ASTM F1842-15Ink PermanencePassed
ISO 594-1: 1986 ViaLuer Taper TestPassed
ISO 80369-7:2016
Functional Testing
ASTM F1842-15Ink Integrity TestPassed
Vygon Internal
RequirementAspiration Flow TestPassed
Vygon Internal
RequirementLuer Color/Orientation TestPassed
Vygon Internal
RequirementClamp Closure Maintenance TestPassed
Vygon Internal
RequirementClamp and ID Tag Fit TestPassed
Vygon Internal
RequirementClamp Actuation TestPassed

Table 2: Vygon PICCs Performance Testing

| Standard | Sterile, Aged (Accelerated 12 Months)
Device Test | Result |
|------------------|------------------------------------------------------|--------|
| ISO 10555-1:2014 | Power Injection Conditioning | Passed |
| ISO 10555-1:2014 | Burst Test | Passed |

Table 3: Vygon PICCs Aged Performance Testing

Sterilization Testing

Sterilization tests are listed in Table 4 and Table 5 below.

| Standard | Sterile, Aged (Accelerated 13 Months)
Packaging Test | Result |
|--------------------|---------------------------------------------------------|--------|
| ASTM F88 / F88M-15 | Seal Strength | Passed |

2750 Morris Road, Suite A200 • Lansdale, PA 19446 • Telephone: 215-390-2002 • Fax: 215-672-6740 Email: email@vygonus.com • Website: www.vygonusa.com

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Image /page/8/Picture/0 description: The image shows the Vygon logo. The word "VYGON" is in white letters on a green background. Above the "V" is a red triangle pointing downwards. Below the logo is the text "Value Life" in a smaller, gray font.

ASTM F2096-11Bubble LeakPassed
Table 4: Vygon PICCs Aged Packaging Testing
StandardSterile Device TestResult
ANSI/AAMI ST72:2011LAL TestingPassed
ISO 10993-7:2008EO Residual TestingPassed

Table5: Vygon PICCs Sterile Testing

In addition, performance testing for catheter stiffness and catheter flexural fatigue tolerance was completed on the final finished sterile devices with acceptable results.

Clinical Testing

No clinical testing was performed.

Biocompatibility Testing

Biocompatibility tests are listed below in Table 6.

StandardTest NameResult
ISO 10993-5:2009/(R)2014CytotoxicityNon-cytotoxic
AAMI/ANSI/ISO 10993-
10:2010/(R)2014SensitizationNon-sensitizer
AAMI/ANSI/ISO 10993-
10:2010/(R)2014IrritationNon-irritant
ISO 10993-11:2006Acute Systemic InjectionNon-toxic
USP37Material Mediated PyrogenNon-pyrogenic
ISO 10993-4: 2002/(R) 2013
& A1: 2006/ (R) 2013Hemolysis (extract)Non-hemolytic
ISO 10993-4: 2002/(R) 2013
& A1: 2006/ (R) 2013Hemolysis (direct)Non-hemolytic
ISO 10993-4: 2002/(R) 2013
& A1: 2006/ (R) 2013Complement Activation
Predicate: PowerPICC®
CatheterSimilar when compared to
predicate
ISO 10993-4: 2002/(R) 2013
& A1: 2006/ (R) 2013Partial Thromboplastin Time
(PTT)
Predicate: PowerPICC®
CatheterMinimal activator (same as
predicate)
ISO 10993-4: 2002/(R) 2013
& A1: 2006/ (R) 2013Dog ThrombogenicityEquivocal similar
AAMI/ANSI/ISO 10993-
6:2007/(R)2014ImplantationNon-irritant

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Image /page/9/Picture/0 description: The image shows the Vygon logo. The logo features the word "VYGON" in white letters on a green, rounded rectangle. Above the "V" is a small, red triangle. Below the logo is the text "Value Life" in a smaller, gray font.

StandardTest NameResult
ISO 10993-18 (Nelson Labs
Report does not specify
year.)Extractable/Leachable AnalysisSummarized in project
#MJ16357-BIO01
ISO 10993-17:2008Subacute/Subchronic Toxicity,
Genotoxicity, Chronic Toxicity
and CarcinogencityEvaluated in Toxicological
Risk Assessment

Table 6: Vygon PICCs Biocompatibility Testing

VII. Conclusion

Through performance bench testing the subject devices have demonstrated that they are substantially equivalent to the predicate device, 5 Fr DL PowerPICC® Catheter, K051672.