K Number
K182522
Device Name
Penumbra System (Modified 110 Aspiration Tubing)
Manufacturer
Date Cleared
2018-10-12

(29 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Penumbra Reperfusion Catheters and Separators As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA ) or who fail IV t-PA therapy are candidates for treatment. Penumbra 3D Revascularization Device As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment. Penumbra Aspiration Tubing As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Aspiration Pump. Penumbra Aspiration Pump The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
Device Description
The Penumbra System is intended for the removal of thrombus from the neuro vasculature using continuous aspiration. Intended users for this device are physicians who have received appropriate training in interventional neuroradiology and the treatment of acute ischemic stroke. The Penumbra System is designed to remove thrombus from the vasculature using continuous aspiration. The Reperfusion Catheter targets aspiration from the pump directly to the thrombus. The 3D Revascularization Device is used with Reperfusion Catheters to facilitate aspiration and removal of the thrombus when needed. The Separator may be used to clear the lumen of the Reperfusion Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using a Reperfusion Catheter with an I.D. of 0.054in or largerfusion Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire to the primary occlusion. The Penumbra Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, a Penumbra Separator may be deployed from the Reperfusion Catheter to assist with thrombus removal. The Penumbra Separator is advanced and retracted through the Penumbra Reperfusion Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Reperfusion Catheter tip. For the aspiration source, the Penumbra Reperfusion Catheter is used in conjunction with the Aspiration Pump, which is connected using the Penumbra Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Penumbra Reperfusion Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Penumbra 3D Revascularization Device is provided with an introducer sheath. The Penumbra Separator is provided with an introducer and torque device. The Penumbra Reperfusion Catheters, 3D Revascularization Device and Separators are visible under fluoroscopy. The Penumbra Aspiration Tubing connects the Penumbra Aspiration Pump Canister to the Penumbra Reperfusion Catheter within the sterile field, providing a means for introducing vacuum during procedures. The Aspiration Tubing has a flow switch that allows the physician to start and stop the flow of aspiration. The Aspiration Tubing is available in three inner diameters: 0.071 in [1.80mm] for PST1, 0.088 in [2.24mm] for PST2, and 0.110 in [2.79mm] for PST3 and PST4. The Aspiration Tubing is designed and composed of materials which are commonly used in interventional devices. The Modified 110 Aspiration Tubing (PST4) is the subject device for this submission (K182522).
More Information

No
The document describes a mechanical aspiration system for removing blood clots and does not mention any AI or ML components.

Yes
The device is indicated for "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease," which is a treatment for a medical condition.

No

The Penumbra System components are indicated for "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease" and described as "intended for the removal of thrombus from the neuro vasculature using continuous aspiration." This indicates a therapeutic, not diagnostic, purpose.

No

The device description clearly outlines multiple hardware components including catheters, separators, tubing, and a pump, all of which are integral to the system's function.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The Penumbra System, including the Reperfusion Catheters, Separators, 3D Revascularization Device, Aspiration Tubing, and Aspiration Pump, is designed for the mechanical removal of thrombus (blood clots) from blood vessels in the brain. This is a therapeutic intervention performed directly on the patient's vasculature.
  • Intended Use: The intended use clearly states "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease." This describes a treatment procedure, not a diagnostic test performed on a sample.
  • Device Description: The description details the physical components and how they are used to aspirate and remove thrombus from within the blood vessels.
  • Lack of Sample Analysis: There is no mention of analyzing biological samples or providing diagnostic information based on such analysis.

The Penumbra System is a medical device used for a therapeutic procedure, not for in vitro diagnostic testing.

N/A

# Intended Use / Indications for Use
Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA ) or who fail IV t-PA therapy are candidates for treatment.

Penumbra 3D Revascularization Device

As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion 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)
NRY

# Device Description
The Penumbra System is intended for the removal of thrombus from the neuro vasculature using continuous aspiration. Intended users for this device are physicians who have received appropriate training in interventional neuroradiology and the treatment of acute ischemic stroke.

The Penumbra System is designed to remove thrombus from the vasculature using continuous aspiration. The Reperfusion Catheter targets aspiration from the pump directly to the thrombus. The 3D Revascularization Device is used with Reperfusion Catheters to facilitate aspiration and removal of the thrombus when needed. The Separator may be used to clear the lumen of the Reperfusion Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using a Reperfusion Catheter with an I.D. of 0.054in or largerfusion Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire to the primary occlusion. The Penumbra Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, a Penumbra Separator may be deployed from the Reperfusion Catheter to assist with thrombus removal. The Penumbra Separator is advanced and retracted through the Penumbra Reperfusion Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Reperfusion Catheter tip. For the aspiration source, the Penumbra Reperfusion Catheter is used in conjunction with the Aspiration Pump, which is connected using the Penumbra Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Penumbra Reperfusion Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Penumbra 3D Revascularization Device is provided with an introducer sheath. The Penumbra Separator is provided with an introducer and torque device. The Penumbra Reperfusion Catheters, 3D Revascularization Device and Separators are visible under fluoroscopy.

The Penumbra Aspiration Tubing connects the Penumbra Aspiration Pump Canister to the Penumbra Reperfusion Catheter within the sterile field, providing a means for introducing vacuum during procedures. The Aspiration Tubing has a flow switch that allows the physician to start and stop the flow of aspiration. The Aspiration Tubing is available in three inner diameters: 0.071 in [1.80mm] for PST1, 0.088 in [2.24mm] for PST2, and 0.110 in [2.79mm] for PST3 and PST4. The Aspiration Tubing is designed and composed of materials which are commonly used in interventional devices. The Modified 110 Aspiration Tubing (PST4) is the subject device for this submission ([K182522](https://510k.innolitics.com/search/K182522)).

# Mentions image processing
Not Found

# Mentions AI, DNN, or ML
Not Found

# Input Imaging Modality
Not Found

# Anatomical Site
intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries)

# Indicated Patient Age Range
Not Found

# Intended User / Care Setting
physicians who have received appropriate training in interventional neuroradiology and the treatment of acute ischemic stroke.

# 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)
Non-Clinical Data Summary:
- Biocompatibility: Performed on the modified 110 Aspiration Tubing in accordance with EN ISO 10993-1 guidelines for limited exposure (

§ 870.1250 Percutaneous catheter.

(a)
Identification. A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.(b)
Classification. Class II (performance standards).

0

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 blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

October 12, 2018

Penumbra, Inc. Micaela Victoria Regulatory Affairs Specialist II One Penumbra Place Alameda, California 94502

Re: K182522

Trade/Device Name: Penumbra System (Modified 110 Aspiration Tubing) Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: September 11, 2018 Received: September 13, 2018

Dear Micaela Victoria:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,

Xiaolin Zheng -S

for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K182522

Device Name Penumbra System (Modified 110 Aspiration Tubing)

Indications for Use (Describe)

Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA ) or who fail IV t-PA therapy are candidates for treatment.

Penumbra 3D Revascularization Device

As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion 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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

*DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW *

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

Image /page/3/Picture/0 description: The image shows the word "Penumbra" in a red, sans-serif font. To the right of the word is a red circle with a white "P" inside. The "P" is stylized with a horizontal line extending from the right side of the "P" to the edge of the circle. The logo is simple and modern.

510(k) Summary - K182522 1

(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 Penumbra System® with modified 110 Aspiration Tubing.

1.1 Sponsor/Applicant Name and Address

Penumbra, Inc. One Penumbra Place Alameda, CA 94502 USA

1.2 Sponsor Contact Information

Micaela Victoria Regulatory Affairs Specialist II Phone: (510) 995-2082 FAX: (510) 217-6414 Email: mvictoria@penumbrainc.com

1.3 Date of Preparation of 510(k) Summary

October 09, 2018

1.4 Device Trade or Proprietary Name

Penumbra System® (Modified 110 Aspiration Tubing)

1.5 Device Classification

Regulatory Class:II
Classification Panel:Neurology
Classification Name:Percutaneous Catheter
Regulation Number:21 CFR §870.1250
Product Code:NRY

1.6 Predicate and Reference Devices

510(k) Number / Clearance DateName of DeviceName of Manufacturer
Predicate Device
K151623 cleared on August 6, 2015Penumbra System – 110 Aspiration TubingPenumbra, Inc.
One Penumbra Place
Alameda, CA 94502 USA
Additional Predicate Devices
K162901 cleared on April 20, 2017Penumbra System - 3D Revascularization DevicePenumbra, Inc.
One Penumbra Place
Alameda, CA 94502 USA
K173761 cleared on August 17, 2018Penumbra System – Reperfusion Catheter JET 7

4

Image /page/4/Picture/0 description: The image shows the Penumbra company 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.

Reference Device
K180939 cleared on May, 3, 2018Indigo Aspiration System – Advanced 110
Aspiration TubingPenumbra, Inc.
One Penumbra Place
Alameda, CA 94502 USA

1.7 Predicate Comparison

Predicate DeviceSubject Device1
Trade NamePenumbra SystemSAME
510(k) No.K151623 [Primary Predicate]K182522
ClassificationClass II, NRYSAME
Indication for UseThe Penumbra System / Penumbra System
MAX are intended for use in the
revascularization of patients with acute
ischemic stroke secondary to intracranial large
vessel occlusive disease (within the internal
carotid, middle cerebral - M1 and M2
segments, basilar, and vertebral arteries)
within 8 hours of symptom onset.
The Penumbra System is intended for use in
the revascularization of patients with acute
ischemic stroke secondary to intracranial large
vessel occlusive disease (within the internal
carotid, middle cerebral - M1 and M2
segments, basilar, and vertebral arteries)
within 8 hours of symptom onset. The
Reperfusion Catheters ACE 64 and ACE 68Penumbra Reperfusion Catheters and
Separators
As part of the Penumbra System, the
Reperfusion Catheters and Separators are
indicated for use in the revascularization
of patients with acute ischemic stroke
secondary to intracranial large vessel
occlusive disease (within the internal
carotid, middle cerebral - M1 and M2
segments, basilar, and vertebral arteries)
within 8 hours of symptom onset.
Patients who are ineligible for
intravenous tissue plasminogen activator
(IV t-PA) or who fail IV t-PA therapy are
candidates for treatment.
are intended for use in revascularization
within the Internal Carotid Artery (ICA)
within 8 hours of symptom onset.Penumbra 3D Revascularization Device
As part of the Penumbra System, the
Penumbra 3D Revascularization Device
is indicated for use in the
revascularization of patients with acute
ischemic stroke secondary to intracranial
large vessel occlusive disease (within the
internal carotid, middle cerebral – M1
and M2 segments) within 8 hours of
symptom onset. Patients who are
ineligible for intravenous tissue
plasminogen activator (IV t-PA) or who
fail IV t-PA therapy are candidates for
treatment.
Penumbra Aspiration Tubing
As part of the Penumbra System, the
Penumbra Sterile Aspiration Tubing is
indicated to connect the Penumbra
Predicate DeviceSubject Device1
Trade NamePenumbra SystemSAME
510(k) No.K151623 [Primary Predicate]K182522
ClassificationClass II, NRYSAME
Reperfusion Catheters to the Penumbra
Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is
indicated as a vacuum source for
Penumbra Aspiration Systems.
Aspiration Tubing
Current 110 Aspiration TubingModified 110 Aspiration Tubing
Tubing Inner
Diameter (ID)0.110 inSAME
Tubing Outer
Diameter (OD)0.188 inSAME
Overall Length112.0 in100.0 in
Distal Length7.0 inN/A (Single Piece Construction)
Materials
Tubing MaterialPolyurethane & NylonSAME
Rotating Male
LuerPolycarbonate with EPDM OR Silicone O-
RingSAME
Tubing/Luer Joint
AdhesiveCyclohexanoneSAME
Female LuerPolycarbonateN/A
Suction Connector
MaterialPolyvinylchloride (PVC)SAME
Tubing/Suction
Connector Joint
AdhesiveLoctiteCyclohexanone
Flow Control
Switch Body
MaterialPolycarbonateSAME
Flow Control
Switch Slider
MaterialAcetalAcetal
Flow Control
Switch Slider
Material PinAcetalNylon
CollarABSN/A
ValveSiliconeN/A
"ON" LogoPolyolefinHeat Stamp Foil
"OFF" LogoPolyolefinHeat Stamp Foil
Predicate DeviceSubject Device1
Trade NamePenumbra SystemSAME
510(k) No.K151623 [Primary Predicate]K182522
ClassificationClass II, NRYSAME
Packaging
MaterialsPouchPolyester/Polyethylene/Tyvek®Nylon/ADH/HDPE/Tyvek®
Display
BoxSBS PaperboardSAME
Label StockLabel stockSAME
SterilizationEOSAME
Shelf Life36 monthsSAME

l The Penumbra System Reperfusion Catheters, Separators, and Aspiration Pumps are unchanged and remain identical to those of the currently cleared Penumbra System (K162901, K173761, and K180008,).

5

Image /page/5/Picture/0 description: The image shows the word "Penumbra" in a bold, red font. To the right of the word is a circular logo, also in red, with a white "P" inside. The logo is simple and modern, and the overall design is clean and professional.

6

Image /page/6/Picture/0 description: The image shows the logo for Penumbra, Inc., a healthcare company. 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 of it. The logo is simple and modern, and the red color is eye-catching.

Device Description 1.8 -

The Penumbra System is intended for the removal of thrombus from the neuro vasculature using continuous aspiration. Intended users for this device are physicians who have received appropriate training in interventional neuroradiology and the treatment of acute ischemic stroke.

The Penumbra System is designed to remove thrombus from the vasculature using continuous aspiration. The Reperfusion Catheter targets aspiration from the pump directly to the thrombus. The 3D Revascularization Device is used with Reperfusion Catheters to facilitate aspiration and removal of the thrombus when needed. The Separator may be used to clear the lumen of the Reperfusion Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using a Reperfusion Catheter with an I.D. of 0.054in or largerfusion Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire to the primary occlusion. The Penumbra Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, a Penumbra Separator may be deployed from the Reperfusion Catheter to assist with thrombus removal. The Penumbra Separator is advanced and retracted through the Penumbra Reperfusion Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Reperfusion Catheter tip. For the aspiration source, the Penumbra Reperfusion Catheter is used in conjunction with the Aspiration Pump, which is connected using the Penumbra Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Penumbra Reperfusion Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Penumbra 3D Revascularization Device is provided with an introducer sheath. The Penumbra Separator is provided with an introducer and torque device. The Penumbra Reperfusion Catheters, 3D Revascularization Device and Separators are visible under

7

Image /page/7/Picture/0 description: The image shows the Penumbra company logo. The logo consists of the word "Penumbra" in a red, sans-serif font, followed by a red circle with a white "P" inside. The "P" is stylized with a horizontal line extending from the left side of the letter to the edge of the circle.

fluoroscopy.

The Penumbra Aspiration Tubing connects the Penumbra Aspiration Pump Canister to the Penumbra Reperfusion Catheter within the sterile field, providing a means for introducing vacuum during procedures. The Aspiration Tubing has a flow switch that allows the physician to start and stop the flow of aspiration. The Aspiration Tubing is available in three inner diameters: 0.071 in [1.80mm] for PST1, 0.088 in [2.24mm] for PST2, and 0.110 in [2.79mm] for PST3 and PST4. The Aspiration Tubing is designed and composed of materials which are commonly used in interventional devices. The Modified 110 Aspiration Tubing (PST4) is the subject device for this submission (K182522).

1.9 Indications for Use

Penumbra Reperfusion Catheters and Separators

As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

Penumbra 3D Revascularization Device

As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

Penumbra Aspiration Tubing

As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Aspiration Pump.

Penumbra Aspiration Pump

The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.

8

Image /page/8/Picture/0 description: The image shows the Penumbra company 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 of it. A white line extends from the left side of the "P" to the right side of the word "Penumbra".

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 which substantiates the performance of the subject Penumbra System with modified 110 Aspiration Tubing as well as its substantial equivalence to the predicate device:

  • Biocompatibility .
  • Design Verification (Bench-Top Testing) ●
  • Shelf Life ●
  • Sterilization ●
  • Packaging ●

The subject Penumbra System with modified 110 Aspiration Tubing met all established requirements.

1.10.1 Biocompatibility

Biocompatibility testing was performed on the modified 110 Aspiration Tubing and the results are summarized in the table below. The studies were selected in accordance with EN ISO 10993-1 guidelines (Biological Evaluation of Medical Devices) for a limited exposure (≤ 24 hours), surface device, with skin contact. All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices (GLP). The modified 110 Aspiration Tubing met all acceptance criteria and successfully passed all biocompatibility tests per EN ISO 10993-1 guidelines.

| Test / Standard | Acceptance Criteria | Results | Pass /
Fail |
|--------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|----------------|
| Cytotoxicity (MEM Elution)
/ EN ISO 10993-5 | Sample extracts must yield a
cell lysis grade of 2 or lower | Grade 2: Mild | Pass |
| Sensitization / EN ISO
10993-10 | Test Group shall yield Grade