(89 days)
No
The summary describes a mechanical aspiration system and pump, with no mention of AI or ML in the device description, intended use, or performance studies.
Yes
The device is indicated for "removal of fresh, soft emboli and thrombi from vessels in the coronary and peripheral vasculature," which describes a therapeutic action.
No
The device is indicated for the removal of fresh, soft emboli and thrombi from vessels, and designed to remove thrombus. This is a therapeutic function, not a diagnostic one. Fluoroscopy is mentioned as a method to visualize the device, but it is not used by the device itself for diagnostic purposes.
No
The device description clearly outlines hardware components including aspiration catheters, a separator, aspiration tubing, and an electromechanical pump.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for the removal of emboli and thrombi from vessels in the coronary and peripheral vasculature. This is a therapeutic intervention performed in vivo (within the living body).
- Device Description: The description details a system designed to physically aspirate and remove material from the patient's blood vessels.
- Lack of Diagnostic Purpose: There is no mention of the device being used to analyze samples (blood, tissue, etc.) in vitro to provide diagnostic information about a patient's condition. IVD devices are used to perform tests on samples taken from the body.
This device is a medical device used for a therapeutic procedure, not an in vitro diagnostic test.
N/A
Intended Use / Indications for Use
INDIGO CAT RX Aspiration Catheters and INDIGO Separator 4
As part of the INDIGO Aspiration System, the INDIGO CAT RX Aspiration Catheters and Separator 4 are indicated for the removal of fresh, soft emboli and thrombi from vessels in the coronary and peripheral vasculature.
INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO CAT RX Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
Product codes (comma separated list FDA assigned to the subject device)
DXE
Device Description
The Indigo System (CAT RX and Separator 4) is designed to remove thrombus from the coronary and peripheral vessels by aspirating the proximal side of the thrombus. The intended users for this device are physicians who have received appropriate training in interventional techniques. The Indigo System (CAT RX and Separator 4) was most recently cleared under K163618.
The Indigo System (CAT RX and Separator 4) is designed to remove thrombus from the vasculature using continuous aspiration. The INDIGO CAT RX Aspiration Catheter is a dual lumen rapid exchange catheter that targets aspiration from the Pump directly to the thrombus, removing it via the INDIGO Aspiration Tubing and depositing it in the Pump Canister. The INDIGO Separator 4 may be used, if needed, to clear the lumen of the INDIGO CAT RX Aspiration Catheter should it become blocked with thrombus. The INDIGO CAT RX Aspiration Catheter is introduced through a guide catheter or long introducer sheath and into the coronary or peripheral vasculature and guided over a guidewire to the site of the primary occlusion. The INDIGO CAT RX Aspiration Catheter may be provided with a rotating hemostasis valve and a peelable sheath. The INDIGO Separator 4 is provided with an introducer and torque device. The INDIGO CAT RX Aspiration Catheter and INDIGO Separator 4 are visible under fluoroscopy.
The Penumbra Engine Pump and Canister
The Penumbra Engine Pump ("Engine Pump") is an electromechanical device designed to create vacuum pressure for use with the Indigo System (CAT RX and Separator 4). The Engine Pump maintains vacuum pressure for 3 hours of continuous use and has an operating life of >= 500 hours. The pump can be used in environments with 100 - 240 Vac and 50/60 Hz. The Engine Pump is intended for use in operating rooms or interventional catheterizations laboratories. The Engine Pump and Canister do not come into contact with the patient. The Engine Pump Canister is a 1000 mL minimum volume reservoir which is an accessory to the Engine Pump. The Canister has a lid with a stop-flow filter to prevent excess fluid from entering the pump. The patient port on the lid is sized to accept the Suction Connector on the Indigo Aspiration Tubing.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
vessels in the coronary and peripheral vasculature
Indicated Patient Age Range
Not Found
Intended User / Care Setting
intended users for this device are physicians who have received appropriate training in interventional techniques. The Engine Pump is intended for use in operating rooms or interventional catheterizations laboratories.
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-top Testing and Electrical Safety/EMC Testing:
All bench-top studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. Performance testing was based on the design specifications, risk analysis, performance standards, and guidance documents.
The Indigo System (CAT RX and Separator 4) Engine Pump and Canister also underwent electrical safety and EMC testing in accordance with the requirements of IEC 60601-1 and IEC 60601-1-2. Testing was performed by Intertek, a nationally recognized test laboratory. The Engine Pump and Canister passed all tests and met all acceptance criteria.
Testing table:
Attribute: Pump - Electrical Safety; Sample Size: N=1; Specification: The Pump conforms to IEC 60601-1 and IEC 60601-1-2 requirements including international worldwide variants (CB Scheme). The Pump is compliant with EN ISO 10079-1.; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump - Environmental Testing; Sample Size: N=5; Specification: Pump performance specifications under environmental conditions; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump - Dimensional Inspection; Sample Size: N=5; Specification: Dimensional specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump - Inspection of Design Features; Sample Size: N=5; Specification: Design specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump - Performance; Sample Size: N=5; Specification: Performance specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump - Performance at variable voltage and frequency; Sample Size: N=5; Specification: Performance specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump and Canister - 500 hour Use Testing; Sample Size: N=5; Specification: Performance specifications after 500 hour use; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump Canister - Inspection of Design Features; Sample Size: N=5; Specification: Design specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump Canister - Performance; Sample Size: N=5; Specification: Performance specifications per Product Specification; Acceptance Criteria: 100% Pass; Results: 100% Pass
Attribute: Pump and Canister - Simulated Use; Sample Size: N=5; Specification: Pump and Canister use specifications; Acceptance Criteria: 100% Pass; Results: 100% Pass
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.
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.
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
§ 870.5150 Embolectomy catheter.
(a)
Identification. An embolectomy catheter is a balloon-tipped catheter that is used to remove thromboemboli, i.e., blood clots which have migrated in blood vessels from one site in the vascular tree to another.(b)
Classification. Class II (performance standards).
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May 15, 2018
Penumbra, Inc. Michaela Mahl Senior Manager of Regulatory Affairs One Penumbra Place Alameda, California 94502
Re: K180412
Trade/Device Name: Indigo Aspiration System (CAT RX and Separator 4) - Penumbra Engine Pump and Canister Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: DXE Dated: March 14, 2018 Received: March 15, 2018
Dear Michaela Mahl:
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); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
1
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.
M.A. Wilhelm
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) K180412
Device Name
Indigo Aspiration System (CAT RX Aspiration Catheter and Separator 4) - Penumbra Engine Pump and Canister
Indications for Use (Describe)
INDIGO CAT RX Aspiration Catheters and INDIGO Separator 4
As part of the INDIGO Aspiration System, the INDIGO CAT RX Aspiration Catheters and Separator 4 are indicated for the removal of fresh, soft emboli and thrombi from vessels in the coronary and peripheral vasculature.
INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO CAT RX Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
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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1 510(k) Summary (K180412)
(as required by 21 CFR 807.92)
Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Penumbra, Inc. is providing the summary of Substantial Equivalence for the Indigo Aspiration System® (CAT RX and Separator 4) - Penumbra Engine™ Pump and Canister.
1.1 Sponsor/Applicant Name and Address
Penumbra, Inc. One Penumbra Place Alameda, CA 94502 USA
Phone: (510) 748-3200
1.2 Sponsor Contact Information
Michaela Mahl Senior Manager of Regulatory Affairs Phone: (510) 748-3288 FAX: (510) 217-6414 Email: mmahl@penumbrainc.com
1.3 Date of Preparation of 510(k) Summary
May 14, 2018
1.4 Device Trade or Proprietary Name
Indigo Aspiration System® (CAT RX and Separator 4) - Penumbra Engine™ Pump and Canister
1.5 Device Classification
| Regulatory Class: | II |
|---|---|
| Classification Panel: | Cardiovascular |
| Classification Name: | Catheter, Embolectomy |
| Common Name: | Embolectomy Aspiration System |
| Regulation Number: | 21 CFR §870.5150 |
| Product Code: | DXE |
1.6 Predicate and Reference Devices
| 510(k) Number / Clearance Date | Name of Device | Name of Manufacturer |
|---|---|---|
| Predicate Device | ||
| K163618 cleared on May 24, 2017 | Indigo Aspiration System (CAT RX | |
| Aspiration Catheter and Separator 4) | Penumbra, Inc. | |
| One Penumbra Place | ||
| Alameda, CA 94502 USA |
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| 510(k) Number / Clearance Date | Name of Device | Name of Manufacturer |
|---|---|---|
| Reference Device | ||
| K122756 cleared on October 2, 2012 | Penumbra Pump MAX | Penumbra, Inc. |
| One Penumbra Place | ||
| Alameda, CA 94502 USA |
1.7 Predicate Comparison
| Predicate Device | Subject Device | |
|---|---|---|
| Trade Name | Indigo System (CAT RX and Separator 4) | |
| (with Penumbra Pump MAX and Canister) | Indigo System (CAT RX and Separator 4) | |
| (with Penumbra Engine Pump and | ||
| Canister) | ||
| 510(k) No. | K163618 | K180412 |
| Classification | Class II, DXE | SAME |
| Indication for Use | INDIGO CAT RX Aspiration Catheters and | |
| INDIGO Separator 4 | ||
| As part of the INDIGO Aspiration System, | ||
| the INDIGO CAT RX Aspiration Catheters | ||
| and Separator 4 are indicated for the | ||
| removal of fresh, soft emboli and thrombi | ||
| from vessels in the coronary and peripheral | ||
| vasculature. |
INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System,
the INDIGO Sterile Aspiration Tubing is
indicated to connect the INDIGO CAT RX
Aspiration Catheters to the Penumbra
Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated
as a vacuum source for Penumbra
Aspiration Systems. | SAME |
| Aspiration Pump | | |
| Trade Name | Penumbra Pump MAX and Canister | Penumbra Engine Pump and Canister |
| IEC 60601-1
Compliance | Yes | SAME |
| IEC 60601-1-2
Compliance | Yes | SAME |
| Voltage | 100-115 Vac/230 Vac | 100-240 Vac |
| Frequency | 50 Hz/60 Hz | SAME |
| Sterilization | Non sterile | SAME |
| Shelf Life | N/A | SAME |
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| Predicate Device | Subject Device | |
|---|---|---|
| Trade Name | Indigo System (CAT RX and Separator 4) | |
| (with Penumbra Pump MAX and Canister) | Indigo System (CAT RX and Separator 4) | |
| (with Penumbra Engine Pump and | ||
| Canister) | ||
| 510(k) No. | K163618 | K180412 |
| Classification | Class II, DXE | SAME |
| The Aspiration Catheters, Separators, and Aspiration Tubings are unchanged and remain identical | ||
| (including all labelling) to those of the currently cleared Indigo System (CAT RX and Separator 4) | ||
| (K163618). |
Device Description 1.8
The Indigo System (CAT RX and Separator 4) is designed to remove thrombus from the coronary and peripheral vessels by aspirating the proximal side of the thrombus. The intended users for this device are physicians who have received appropriate training in interventional techniques. The Indigo System (CAT RX and Separator 4) was most recently cleared under K163618.
The Indigo System (CAT RX and Separator 4) is designed to remove thrombus from the vasculature using continuous aspiration. The INDIGO CAT RX Aspiration Catheter is a dual lumen rapid exchange catheter that targets aspiration from the Pump directly to the thrombus, removing it via the INDIGO Aspiration Tubing and depositing it in the Pump Canister. The INDIGO Separator 4 may be used, if needed, to clear the lumen of the INDIGO CAT RX Aspiration Catheter should it become blocked with thrombus. The INDIGO CAT RX Aspiration Catheter is introduced through a guide catheter or long introducer sheath and into the coronary or peripheral vasculature and guided over a guidewire to the site of the primary occlusion. The INDIGO CAT RX Aspiration Catheter may be provided with a rotating hemostasis valve and a peelable sheath. The INDIGO Separator 4 is provided with an introducer and torque device. The INDIGO CAT RX Aspiration Catheter and INDIGO Separator 4 are visible under fluoroscopy.
The Penumbra Engine Pump and Canister
The Penumbra Engine Pump ("Engine Pump") is an electromechanical device designed to create vacuum pressure for use with the Indigo System (CAT RX and Separator 4). The
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Image /page/6/Picture/0 description: The image shows the Penumbra logo. The word "Penumbra" is written in a red, sans-serif font. To the right of the word is a red circle with a white "P" inside. The logo is simple and modern.
Engine Pump maintains vacuum pressure for 3 hours of continuous use and has an operating life of ≥ 500 hours. The pump can be used in environments with 100 - 240 Vac and 50/60 Hz. The Engine Pump is intended for use in operating rooms or interventional catheterizations laboratories. The Engine Pump and Canister do not come into contact with the patient. The Engine Pump Canister is a 1000 mL minimum volume reservoir which is an accessory to the Engine Pump. The Canister has a lid with a stop-flow filter to prevent excess fluid from entering the pump. The patient port on the lid is sized to accept the Suction Connector on the Indigo Aspiration Tubing.
1.9 Indications for Use
INDIGO CAT RX Aspiration Catheters and INDIGO Separator 4
As part of the INDIGO Aspiration System, the INDIGO CAT RX Aspiration Catheters and Separator 4 are indicated for the removal of fresh, soft emboli and thrombi from vessels in the coronary and peripheral vasculature.
INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO CAT RX Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
1.10 Summary of Non-Clinical Data
As required under Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, a summary of any information regarding substantial equivalence of the device follows.
Included in this section are summary descriptions of the testing (or rationale for not testing if not applicable to the Engine Pump and Canister) which substantiates the performance of the subject Indigo System (CAT RX and Separator 4) with Engine Pump and Canister as well as its substantial equivalence to the predicate device:
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- Biocompatibility ●
- Design Verification (Bench-Top Testing and Electrical Safety/EMC Testing) .
- Shelf Life .
- Sterilization ●
- Packaging ●
The subject Indigo System (CAT RX and Separator 4) with Engine Pump and Canister met all established requirements.
1.10.1 Biocompatibility
The subject and predicate Indigo System (CAT RX and Separator 4) sterile devices are identical. There are no changes to the previously provided biocompatibility data of the Indigo System (CAT RX and Separator 4) materials sterile devices, which were reviewed and cleared under K163618. No additional biocompatibility testing is required or was performed for the Indigo System (CAT RX and Separator 4) sterile devices.
The Indigo System (CAT RX and Separator 4) Engine Pump is a non-sterile reusable piece of capital equipment. The pump does not contact the patient, nor is it introduced into the sterile field. As such, biocompatibility testing is not required and was not performed for the pump. The Indigo System (CAT RX and Separator 4) Engine Pump Canister also does not contact the patient, nor is it introduced into the sterile field. Furthermore, blood or body fluids collected in the canister are not re-introduced to the patient. As such, biocompatibility testing is not required and was not performed for the Canister.
1.10.2 Design Verification (Bench-top Testing and Electrical Safety/EMC Testing)
The subject and predicate Indigo System (CAT RX and Separator 4) sterile devices are identical. There are no changes to the design specifications and performance characteristics of the Indigo System (CAT RX and Separator 4) sterile devices. Therefore, all previous bench-top testing data which were reviewed and cleared under K163618 continue to support the subject Indigo System (CAT RX and Separator 4) sterile devices. No additional bench-top testing is required or was performed for the Indigo System (CAT RX and Separator 4) sterile devices.
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Bench-top testing was conducted to evaluate the physical and mechanical properties of the subject Indigo System (CAT RX and Separator 4) Engine Pump and Canister. All bench-top studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. Performance testing was based on the design specifications, risk analysis, performance standards, and guidance documents.
The Indigo System (CAT RX and Separator 4) Engine Pump and Canister also underwent electrical safety and EMC testing in accordance with the requirements of IEC 60601-1 and IEC 60601-1-2. Testing was performed by Intertek, a nationally recognized test laboratory. The Engine Pump and Canister passed all tests and met all acceptance criteria.
| Attribute | Sample
Size | Specification | Acceptance Criteria | Results |
|------------------------------------------------------------|----------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|-----------|
| Pump - Electrical
Safety | N=1 | The Pump conforms to IEC 60601-1
and IEC 60601-1-2 requirements
including international worldwide
variants (CB Scheme). The Pump is
compliant with EN ISO 10079-1. | 100% Pass | 100% Pass |
| Pump - Environmental
Testing | N=5 | Pump performance specifications
under environmental conditions | 100% Pass | 100% Pass |
| Pump - Dimensional
Inspection | N=5 | Dimensional specifications per
Product Specification | 100% Pass | 100% Pass |
| Pump - Inspection of
Design Features | N=5 | Design specifications per Product
Specification | 100% Pass | 100% Pass |
| Pump - Performance | N=5 | Performance specifications per
Product Specification | 100% Pass | 100% Pass |
| Pump - Performance at
variable voltage and
frequency | N=5 | Performance specifications per
Product Specification | 100% Pass | 100% Pass |
| Pump and Canister -
500 hour Use Testing | N=5 | Performance specifications after 500
hour use | 100% Pass | 100% Pass |
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| Attribute | Sample
Size | Specification | Acceptance Criteria | Results |
|-----------------------------------------------------|----------------|---------------------------------------------------------|---------------------|-----------|
| Pump Canister -
Inspection of Design
Features | N=5 | Design specifications per Product
Specification | 100% Pass | 100% Pass |
| Pump Canister -
Performance | N=5 | Performance specifications per
Product Specification | 100% Pass | 100% Pass |
| Pump and Canister -
Simulated Use | N=5 | Pump and Canister use
specifications | 100% Pass | 100% Pass |
1.10.3 Shelf Life
The subject and predicate Indigo System (CAT RX and Separator 4) sterile devices are identical. There are no changes to the previously provided shelf life data for the sterile devices which were reviewed and cleared under K163618. No additional shelf life testing is required or was performed for the Indigo System (CAT RX and Separator 4) sterile devices.
The proposed Indigo System (CAT RX and Separator 4) Engine Pump is a reusable piece of capital equipment that is provided non-sterile. Therefore, shelf life testing is not applicable to the Engine Pump and shelf life testing was not performed. The Engine Pump is established for 500 hours of use based on completed life (reliability) testing. The Engine Pump Canister does not have an established shelf life.
1.10.4 Sterilization
The subject and predicate Indigo System (CAT RX and Separator 4) sterile devices are identical. There are no changes to the previously provided sterilization data of the devices, which were reviewed and cleared under K163618. No additional sterilization testing is required or was performed for these devices.
Sterilization testing is not applicable to the proposed Indigo System (CAT RX and Separator 4) Engine Pump and Canister. Both are supplied non-sterile and are not intended to be sterilized.
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1.10.5 Packaging
The packaging materials and process of the subject and predicate Indigo System (CAT RX and Separator 4) sterile devices are identical. There are no changes to the previously provided packaging material listing or the packaging process for these devices, which were reviewed and cleared under K163618. No additional packaging testing is required or was performed for the Indigo System (CAT RX and Separator 4) sterile devices.
The packaging materials for the proposed Indigo System (CAT RX and Separator 4) Engine Pump and Canister are similar to those used for the predicate Indigo System (CAT RX and Separator 4) Penumbra Pump MAX and Canister. The Engine Pump and Canister are packaged to ensure that damage does not occur during shipping. The Engine Pump is packaged in a protective, corrugated, cardboard 275 B/C Flute Double Wall RSC shipping container with custom shaped foam inserts. Pumps used for Design Verification and Packaging Validation testing first underwent transportation conditioning per ASTM D4169, Distribution Cycle 3, Assurance Level 3 to ensure packaging integrity. The Canister is packaged individual in Clay coated Solid Bleach Sulfate product boxes. The Canister box is then packaged in protective, corrugated, cardboard 275 B/C Flute Double Wall RSC shipping containers (18 canister boxes per shipper).
1.11 Summary of Substantial Equivalence
The subject Indigo System (CAT RX and Separator 4) disposable devices are unchanged and remain identical to those of the predicate Indigo System (CAT RX and Separator 4) with regard to indications, function, design, materials, biocompatibility, packaging, and sterilization. The subject Indigo System (CAT RX and Separator 4) Engine Pump and Canister are substantially equivalent to the predicate device with regard to intended use, operating principle, design concept, materials, and packaging processes.