(131 days)
Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter: Used to place in vitro fertilized (IVF) embryos into the uterine cavity.
The Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter cover six subject devices from two of COOK's device families, Guardia™ Access and Guardia™. All embryo transfer catheters have an outer diameter of 2.8 Fr and range in length from 23 to 25 cm. The transfer catheters have internal or external supporting cannula, depth indicators, and may have an echogenic band. The Guardia™ Access guide catheters are precurved and feature a bulb-shaped tip. They measure 6.6 Fr in outer diameter and are 16.7 to 17.3 cm in length. All subject devices are single-use devices and sterilized by ethylene oxide exposure. They undergo lot release Mouse Embryo Assay (MEA) testing for embryo toxicity and USP endotoxin (LAL) testing for pyrogenicity. The subject devices are packaged in peel-open sterile barrier pouches with a three-year shelf life.
The provided text details the 510(k) summary for the Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter. This is a medical device, and the document focuses on demonstrating its substantial equivalence to a predicate device, rather than the performance of a software algorithm or AI model, which is typically what the request refers to when asking about "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of AI/ML performance.
Therefore, the information required to populate the fields related to AI/ML model performance, such as sample size for test/training sets, expert ground truth establishment, MRMC studies, or standalone algorithm performance, is not available in the provided document. The document describes the testing of a physical medical device, not a software or AI product.
However, I can extract the acceptance criteria and study descriptions for the physical device as presented in the document.
Here's a summary of the acceptance criteria and the studies conducted for the physical medical device:
Acceptance Criteria and Reported Device Performance (Physical Device)
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Sterilization Validation (per ISO 11135-1:2007) | Performed (details of specific acceptance metric not provided, but implied to be successful validation) |
| Biocompatibility (per ISO 10993-5, 10, 10, 10) | Cytotoxicity, Guinea Pig Maximization Sensitization, Intracutaneous Irritation testing performed (implied to meet acceptance). |
| Endotoxin Testing (per USP <85> and AAMI/ANSI ST72:2011/(R)2016) | <20 EU/device |
| Transportation Simulation (per ASTM D4169-05) | Performed (implied to meet acceptance). |
| Package Integrity (Bubble Leak Test) (per ASTM F2096-04) | Performed (implied to meet acceptance). |
| Package Integrity (Seal Strength Testing) (per ASTM F88-09) | Performed (implied to meet acceptance). |
| Package Integrity (Visual Inspection) | No package displayed damage (tears, folds, puncture holes, etc.) |
| Mouse Embryo Assay (MEA): ≥80% embryos developed to blastocyst in 96 hours (for 1-cell MEA) | The devices met acceptance criterion of "1-cell MEA ≥80% embryos developed to blastocyst in 96 hours." (Both before and after aging) |
| Dimensional Verification (against device input requirements) | Catheters measured and verified against device input requirements (implied to meet acceptance). |
| Transfer Catheter Aspiration Test (no air leaking into syringe) | Testing ensures there is no air leaking into the syringe through the transfer catheter (implied to meet acceptance). |
| Transfer Catheter Leak Test (no leak under predetermined injection pressure) | Testing ensures that fluid path catheter assembly does not leak under a predetermined injection pressure (implied to meet acceptance). |
| Tensile Testing (Catheter Hub-shaft) (tensile strength > predetermined criterion) | Testing demonstrated that the tensile strength value is greater than the predetermined acceptance criterion. |
| Echotip Band Test (outer diameter does not impede smooth passage) | Testing ensures that the outer diameter of the band does not impede smooth passage through the guide catheter (implied to meet acceptance). |
| Echotip Band Echogenicity Test (provides increased brightness via ultrasound) | Visual comparison testing by ultrasound imaging of catheters with and without an EchoTip band verified that the band provides increased brightness. |
Information NOT Applicable/Available (as this is not an AI/ML device)
- Sample size used for the test set and the data provenance: Not applicable to a physical device. Testing involved physical samples of the device.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical device refers to established engineering and biological standards and tests.
- Adjudication method for the test set: Not applicable.
- 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: Not applicable. This is for an AI/ML product.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable.
- The type of ground truth used: For MEA, it's a biological assay (embryo development). For other tests, it's engineering specifications, material properties, and regulatory standards.
- The sample size for the training set: Not applicable to a physical device's performance testing.
- How the ground truth for the training set was established: Not applicable.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
April 11, 2018
Cook Incorporated Naomi Funkhouser, MBA Regulatory Affairs Specialist/Scientist 750 Daniels Way P.O. Box 489 Bloomington, IN 47402
Re: K173686
Trade/Device Name: Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter Regulation Number: 21 CFR§ 884.6110 Regulation Name: Assisted Reproduction Catheters Regulatory Class: II Product Code: MOF Dated: March 9, 2018 Received: March 13, 2018
Dear Naomi Funkhouser:
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.
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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 (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.
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,
Joyce M. Whang -S
for Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K173686
Device Name
Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter
Indications for Use (Describe)
Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter: Used to place in vitro fertilized (IVF) embryos into the uterine cavity.
Type of Use (Select one or both, as applicable)
| Transaction(s) (Per 24 CFR 982.451, Subpart K) | One-Time Exception(s) (Per 24 CFR 982.451, Subpart K) |
|---|---|
| ------------------------------------------------------------------------------------------------------------ | ---------------------------------------------------------------------------------------------------- |
X | 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 logo for Cook Medical. The logo consists of the word "COOK" in white, block letters on a red background. Below the word "COOK" is the word "MEDICAL" in smaller, white block letters. The logo is simple and clean, with a focus on the company name.
510(k) Summary – K173686
| Submitted By: | |
|---|---|
| Applicant: | Cook Incorporated |
| Contacts: | Naomi FunkhouserRohini Patel |
| Applicant Address: | Cook Incorporated750 Daniels WayBloomington, IN 47404 |
| Contact Phone: | (812) 339-2235 x104371 |
| Contact Fax: | (812) 332-0281 |
| Date Prepared: | April 9, 2018 |
| Device Information: | |
| Trade Names: | Guardia Access Embryo Transfer Catheter Sets and SydneyIVF® Transfer Catheter |
| Common Name: | Embryo Transfer Catheter |
| Classification Name: | Assisted Reproduction Catheters (21 CFR 884.6110) |
| Classification Regulation: | MQF (Catheter, Assisted Reproduction) |
| Regulatory Class | II |
Predicate Device:
Embryo Transfer Catheter/Sets (K983594) manufactured by Cook Ob/Gyn. This predicate device has not been subject to any design related recalls.
Device Description:
The Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter cover six subject devices from two of COOK's device families, Guardia™ Access and Guardia™, as outlined in the table below:
| Product family | Device | Product Number | Component |
|---|---|---|---|
| Guardia™Access | Guardia™ Access Embryo TransferCatheter | K-JETS-6019 | Embryo transfer catheterand guide catheter |
| Guardia™ Access Embryo TransferCatheter with Internal Supporting Cannula | K-JETS-7019-INT | Embryo transfer catheterand guide catheter | |
| Guardia™Access | Guardia™ Access Embryo TransferCatheter | K-JETS-7019 | Embryo transfer catheterand guide catheter |
| Guardia™ AccessET Embryo TransferCatheter | K-JETS-6019-ET | Embryo transfer catheterand guide catheter | |
| Guardia™ AccessET Embryo TransferCatheter | K-JETS-7019-ET | Embryo transfer catheterand guide catheter | |
| Guardia™ | Sydney IVF® Embryo Transfer Catheter | K-JET-2823 | Embryo transfer catheter |
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Image /page/4/Picture/0 description: The image shows the Cook Medical logo. The logo has a red background with the word "COOK" in white, sans-serif font. Below the word "COOK" is the word "MEDICAL" in white, sans-serif font, on a red background that is slightly darker than the background behind the word "COOK".
All embryo transfer catheters have an outer diameter of 2.8 Fr and range in length from 23 to 25 cm. The transfer catheters have internal or external supporting cannula, depth indicators, and may have an echogenic band. The Guardia™ Access guide catheters are precurved and feature a bulb-shaped tip. They measure 6.6 Fr in outer diameter and are 16.7 to 17.3 cm in length.
All subject devices are single-use devices and sterilized by ethylene oxide exposure. They undergo lot release Mouse Embryo Assay (MEA) testing for embryo toxicity and USP endotoxin (LAL) testing for pyrogenicity. The subject devices are packaged in peel-open sterile barrier pouches with a three-year shelf life.
Indications for Use:
Guardia Access Embryo Transfer Catheter Sets and Sydney IVF® Transfer Catheter:
Used to place in vitro fertilized (IVF) embryos into the uterine cavity.
| Parameter | K173686 (subject device) | K983594 (predicate device) |
|---|---|---|
| Indication for Use | Used to place in vitrofertilized (IVF) embryosin the uterine cavity. | The embryo transfer catheters/sets areused to place embryos in the uterinecavity. |
| Design - transfer catheter | Same as predicate | • Graduation marks• Open end• Locking hub• With or without echotip |
| Design - guide catheter | Same as predicate | • No graduation marks• Positioner• Bulb tip• Precurved• No echotip |
| Dimension - transfer catheter | OD 2.8 Fr / Length 23-25 cm | OD 2-8 Fr / Length 12-30 cm |
| Dimensions – guide catheter | OD 6.6 Fr / Length 16.7 or 17.3 cm | OD 5-8.5 Fr / Length 12-30 cm |
| Materials - transfer catheter | Polyethylene, polyurethane,stainless steel | Polyethylene, teflon, stainless steel |
| Materials - guide catheter | Polyurethane, silicone,polymethylpentene | Polyethylene, echosight polyethylene,teflon, stainless steel |
Comparison of Intended Use and Technological Characteristics with the Predicate Device:
The subject and predicate devices have the same intended use. They also have the comparable designs. There are differences in dimensions and materials between the subject and predicate devices, but these differences do not raise different questions of safety and effectiveness. The difference in dimensions can be addressed by bench performance testing. The differences in materials can be evaluated by biocompatibility testing and Mouse Embryo Assay Testing.
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Image /page/5/Picture/0 description: The image shows the logo for Cook Medical. The logo consists of the word "COOK" in white, uppercase letters on a red background. Below the word "COOK" is the word "MEDICAL" in white, uppercase letters on a red background. The red background for the word "MEDICAL" is in a rectangular shape with a diagonal cut on the left side.
Summary of Non-Clinical Performance Testing:
The following studies have been performed to support substantial equivalence to the predicate device:
- . Sterilization Validation testing per ISO 11135-1:2007
- Biocompatibility studies, as follows: ●
- Cytotoxicity testing per 10993-5:2009 o
- Guinea Pig Maximization Sensitization testing per ISO 10993-10:2002 or ISO 10993o 10:2010
- Intracutaneous Irritation testing per ISO 10993-10:2002 or ISO 10993-10:2010 o
- Endotoxin testing per USP <85> and AAMI/ANSI ST72:2011/(R)2016 (<20 EU/device) ●
- Transportation Simulation study per ASTM D4169-05
- . Package Integrity testing after real-time aging:
- Bubble Leak test per ASTM F2096-04 o
- Seal Strength testing per ASTM F88-09 o
- Visual Inspection: No package displayed damage (tears, folds, puncture holes, etc.) o
- Mouse Embryo Assay (MEA) before and after aging: .
One-cell mouse embryos were exposed to subject devices and cultured at 37℃ in an atmosphere containing 5% CO2. The percent of embryos developed to the expanded blastocyst stage within 96 hours were assessed in comparison with the control group. The testing demonstrated that the devices met acceptance criterion of "1-cell MEA ≥80% embryos developed to blastocyst in 96 hours."
- Bench Performance studies before and after aging demondtrated that all predetermined acceptance criteria were met in the following tests:
- Dimensional verification of catheter Catheters are measured and verified against o device input requirements.
- Transfer Catheter Aspiration Test Testing ensures there is no air leaking into the O syringe through the transfer catheter.
- Transfer Catheter Leak Test Testing ensures that fluid path catheter assembly O does not leak under a predetermined injection pressure.
- o Tensile Testing (Catheter Hub- shaft) - Testing demonstates that the tensile strength value is greater than the predetermined acceptance criterion.
- Echotip Band Test Testing ensures that the outer diameter of the band does not O impede smooth passage through the guide catheter.
- Echotip Band Echogenicity Test Visual comparison testing by ultrasound imaging O of catheters with and without an EchoTip band verified that the band provides increased brightness.
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Image /page/6/Picture/0 description: The image shows the logo for Cook Medical. The logo is set against a red background. The word "COOK" is written in large, white, sans-serif font. Below "COOK" is the word "MEDICAL" in a smaller, white, sans-serif font, set against a dark red background.
COOK INCORPORATED 750 DANIELS WAY BLOOMINGTON, IN 47404 USA 812.339.2235 TOLL FREE: 800.457.4500 WWW.COOKMEDICAL.COM
Conclusion:
The subject and predicate devices have the same intended use. Although there are differences in technological characteristics between the subject and predicate devices, these differences do not raise different questions of safety or effectiveness. The performance data demonstrate that the subject devices are substantially equivalent to the predicate device.
§ 884.6110 Assisted reproduction catheters.
(a)
Identification. Assisted reproduction catheters are devices used in in vitro fertilization (IVF), gamete intrafallopian transfer (GIFT), or other assisted reproduction procedures to introduce or remove gametes, zygote(s), preembryo(s), and/or embryo(s) into or from the body. This generic type of device may include catheters, cannulae, introducers, dilators, sheaths, stylets, and component parts.(b)
Classification. Class II (special controls) (mouse embryo assay information, endotoxin testing, sterilization validation, design specifications, labeling requirements, biocompatibility testing, and clinical testing).