K Number
K190001
Device Name
Supercath 5
Date Cleared
2019-09-20

(261 days)

Product Code
Regulation Number
880.5200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Supercath 5 is intended to access a vein or artery and to administer fluids and/or blood. The Supercath 5 is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi.
Device Description
The Supercath 5 (Proposed) is intended to access a vein or artery and to administer fluids and/or blood. The Supercath 5 (Proposed) is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi. The Supercath 5 (Proposed) catheter hub has a built-in check valve which together with the healthcare professional's finger pressure on the blood vessel, assists to reduce blood flashback when the metallic introducer needle is withdrawn following blood vessel puncture. The built-in check valve is not intended to stop bleeding completely. Pressing the button on the needle hub activates the coiled spring in the hub, retracting the metallic introducer needle into the needle hub. The Supercath 5 (Proposed) introducer needle has a side-notch to provide rapid visual confirmation of vessel entry. When the introducer needle is inserted into the vein, blood flows up and through the side-notch and returns down along the inside of the catheter tube. The Supercath 5 (Proposed) is available in 14G, 16G, 18G, 20G, 22G, 24G and 26G.
More Information

No
The description focuses on mechanical features and standard performance testing, with no mention of AI or ML.

No

The device is intended to access a vein or artery to administer fluids and/or blood, which describes diagnostic or supportive functions rather than direct therapeutic treatment of a condition or disease.

No

The device is described as an access device for administering fluids and/or blood, with features to assist in insertion (side-notch for visual confirmation of vessel entry) and safety (minimizing needlesticks, check valve for blood flashback). These functions are therapeutic/interventional in nature, not diagnostic.

No

The device description clearly details a physical catheter with a needle, check valve, and other mechanical components, indicating it is a hardware device.

Based on the provided information, the Supercath 5 is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is to "access a vein or artery and to administer fluids and/or blood." This describes a device used for direct patient intervention (accessing the body and delivering substances), not for examining specimens in vitro (outside the body).
  • Device Description: The description details the physical components and function of a catheter used for vascular access and fluid/blood administration. It does not mention any components or processes related to testing or analyzing biological samples.
  • Performance Studies: The performance studies focus on the physical and functional aspects of the catheter (biocompatibility, hemocompatibility, burst pressure, flow rate, tensile strength, sterilization, shelf-life). There are no studies related to diagnostic accuracy or the analysis of biological specimens.

IVD devices are specifically designed to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or treatment. The Supercath 5's function is to facilitate the delivery of substances into the body, not to analyze substances from the body.

N/A

Intended Use / Indications for Use

The Supercath 5 is intended to access a vein or attery and to administer fluids and/or blood. The Supercath 5 is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi.

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

FOZ

Device Description

The Supercath 5 (Proposed) is intended to access a vein or artery and to administer fluids and/or blood. The Supercath 5 (Proposed) is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi.

The maximum flow rate and maximum pressure setting for each catheter size are listed in the table shown as follows. The maximum flow rate may vary due to differences in injector characteristics, injectate viscosity and temperature, and other variables.

The Supercath 5 (Proposed) catheter hub has a built-in check valve which together with the healthcare professional's finger pressure on the blood vessel, assists to reduce blood flashback when the metallic introducer needle is withdrawn following blood vessel puncture. The built-in check valve is not intended to stop bleeding completely. Pressing the button on the needle hub activates the coiled spring in the hub, retracting the metallic introducer needle into the needle hub.

The Supercath 5 (Proposed) introducer needle has a side-notch to provide rapid visual confirmation of vessel entry. When the introducer needle is inserted into the vein, blood flows up and through the side-notch and returns down along the inside of the catheter tube.

The Supercath 5 (Proposed) is available in 14G, 16G, 18G, 20G, 22G, 24G and 26G.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Vein or artery

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)

  1. Biocompatibility testing: The Supercath 5 (Proposed) contacts patient's skin and blood and is categorized as an External communicating. Circulating blood contact device with a Prolonged contact duration in accordance with ISO 10993-1:2009 and referencing FDA guidance entitled "Use of International Standard ISO 10993- 1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The nature of contact with the body and the category of the Supercath 5 (Proposed) are identical to those of the predicate devices. Biocompatibility testing was leveraged from the sponsor's own predicate devices (K140419 and K172496). The addition of administration of blood in the Indications for Use is supported by the Hemocompatibility testing (hemolysis, complement system, coagulation, platelets, and thrombosis) performed on the sponsor's own reference device (K160592).
  2. Power injection test: Catheter burst pressure exceeds the peak pressure present in the catheter at maximum flow conditions when tested according to ISO 10555-1:2013.
  3. Vent fitting test for the needle hub: The needle hub with the packing part is impervious to liquid infiltration when subjected to positive pressure in accordance with ISO 10555-5:2013.
  4. Flow rate test: The flow rate through catheter meets allowable limits when tested according to ISO 10555-1:2013.
  5. Ease of assembly performance testing for the plunger: The plunger passes through the check valve when tested according to ISO 594-2:1998 section 5.6.
  6. Tensile strength testing for the cap: The tensile strength of the cap meets acceptable minimum force until breakage when tested according to in-house standard.
  7. Sterilization validation in accordance with ISO 11135:2014 and shelf-life testing were conducted.

The results of testing above did not raise any new questions of safety or effectiveness.

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.

K140419, K172496

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.

K160592

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

§ 880.5200 Intravascular catheter.

(a)
Identification. An intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings and that is inserted into the patient's vascular system for short term use (less than 30 days) to sample blood, monitor blood pressure, or administer fluids intravenously. The device may be constructed of metal, rubber, plastic, or a combination of these materials.(b)
Classification. Class II (performance standards).

0

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September 20, 2019

TOGO MEDIKIT Co., Ltd. % Izumi Maruo Senior Consultant MIC International 4-1-17 Hongo Bunkyo-ku, Tokyo 113-0033 JAPAN

Re: K190001

Trade/Device Name: Supercath 5 Regulation Number: 21 CFR 880.5200 Regulation Name: Intravascular Catheter Regulatory Class: Class II Product Code: FOZ Dated: August 15, 2019 Received: August 19, 2019

Dear Izumi Maruo:

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.

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

for Nikhil Thakur Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K190001

Device Name Supercath 5

Indications for Use (Describe)

The Supercath 5 is intended to access a vein or attery and to administer fluids and/or blood. The Supercath 5 is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi.

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 a logo with a globe-like grid pattern in the background. In the foreground, there is a stylized human figure with arms outstretched, forming a 'P' shape with its body. The figure is positioned in front of the globe, creating a sense of global reach or connection.

TOGO MEDIKIT CO., LTD.
17148-6, Aza Kamekawa, Oaza Hichiya, Hyuga City
Miyazaki Prefecture 883-0062, Japan
TELEPHONE: +81-982-53-8027
FACSIMILE: +81-982-53-8008

Page 1 of 8

510(k) Summary - K190001

Owner/Company name, address a.

TOGO MEDIKIT CO., LTD. 17148-6 Aza Kamekawa, Oaza Hichiya Hyuga City, Miyazaki, 883-0062, Japan

Daisuke Nagamizu Manager, Regulatory Affairs Section, Quality Assurance Department Phone: 011-81-982-53-8000 Fax: 011-81-982-53-8008 qc@togomedikit.co.jp Email:

b. Contact/Application Correspondent

Izumi Maruo Senior Consultant MIC International 4-1-17 Hongo, Bunkyo-ku Tokyo, 113-0033, Japan

011-81-3-3818-8577 Phone: Fax: 011-81-3-3818-8573 Email: maruo@mici.co.jp

c. Date prepared

September 18, 2019

d. Name of device

Trade Name:Supercath 5
Common Name:Catheter, Intravascular, Therapeutic, Short-term less than 30
days
Regulation Name:Intravascular Catheter
Regulation Number:21 CFR 880.5200
Regulation Class:II
Product Code:FOZ
Classification Panel:General Hospital

Hereinafter, the Proposed Device is called as "Supercath 5 (Proposed)" in this submission because predicate devices have the same trade name.

4

Image /page/4/Picture/0 description: The image shows a logo with a globe-like structure made of intersecting lines, resembling a grid. Inside the globe, there is a stylized human figure with arms outstretched, as if embracing the world. The logo is presented in grayscale, giving it a simple and clean appearance.

TOGO MEDIKIT CO., LTD.
17148-6, Aza Kamekawa, Oaza Hichiya, Hyuga City
Miyazaki Prefecture 883-0062, Japan
TELEPHONE: +81-982-53-8027
FACSIMILE: +81-982-53-8008

e. Predicate and reference devices

Predicate devices

The Supercath 5 (Proposed) has two predicate devices because those two devices altogether cover the sizes which the Supercath 5 (Proposed) includes.

Predicate Device for gauges 14G, 16G, 18G, 20G, 22G, and 24G

Trade Name:Supercath 5
510(k) Number:K140419
Common Name:Catheter, Intravascular, Therapeutic, Short-term less than 30 days
Regulation Name:Intravascular Catheter
Regulation Number:21 CFR 880.5200
Regulation Class:II
Product Code:FOZ
Classification Panel:General Hospital

Hereinafter "Supercath 5 (K140419)" in this submission. This predicate device is primary predicate.

Predicate Device for 26G
Trade Name:Supercath 5
510(k) Number:K172496
Common Name:Catheter, Intravascular, Therapeutic, Short-term less than
30 days
Regulation Name:Intravascular Catheter
Regulation Number:21 CFR 880.5200
Regulation Class:II
Product Code:FOZ
Classification Panel:General Hospital

Hereinafter "Supercath 5 (K172496)" in this submission.

Reference Devices
Trade Name:Supercath 6
510(k) Number:K160592
Common Name:Catheter, Intravascular, Therapeutic, Short-term less than 30 days
Regulation Name:Intravascular Catheter
Regulation Number:21 CFR 880.5200
Regulation Class:II
Product Code:FOZ
Classification Panel:General Hospital

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Image /page/5/Picture/0 description: The image shows a logo with a globe-like structure in the background. In the foreground, there is a stylized human figure with arms raised, seemingly integrated into the globe design. The logo has a circular shape and appears to be in grayscale.

f. Description of the device

The Supercath 5 (Proposed) is intended to access a vein or artery and to administer fluids and/or blood. The Supercath 5 (Proposed) is designed for single use, and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22 gauge catheters may be used with power injectors at a maximum pressure of 300 psi.

The maximum flow rate and maximum pressure setting for each catheter size are listed in the table shown as follows. The maximum flow rate may vary due to differences in injector characteristics, injectate viscosity and temperature, and other variables.

| Gauge | Length | | Maximum
Flow Rate
(mL/sec) | Maximum
Pressure
(psi) |
|-------|--------|------|----------------------------------|------------------------------|
| | (in) | (mm) | | |
| 22G | 1 | 25 | 7 | 300 |
| 22G | 1 1/4 | 31 | 7 | 300 |
| 20G | 1 | 25 | 9 | 300 |
| 20G | 1 1/4 | 31 | 9 | 300 |
| 20G | 2 | 50 | 9 | 300 |
| 18G | 1 1/4 | 31 | 12 | 300 |
| 18G | 2 | 50 | 12 | 300 |

Table 1. The maximum flow rate and the maximum pressure setting

The Supercath 5 (Proposed) catheter hub has a built-in check valve which together with the healthcare professional's finger pressure on the blood vessel, assists to reduce blood flashback when the metallic introducer needle is withdrawn following blood vessel puncture. The built-in check valve is not intended to stop bleeding completely. Pressing the button on the needle hub activates the coiled spring in the hub, retracting the metallic introducer needle into the needle hub.

The Supercath 5 (Proposed) introducer needle has a side-notch to provide rapid visual confirmation of vessel entry. When the introducer needle is inserted into the vein, blood flows up and through the side-notch and returns down along the inside of the catheter tube.

The Supercath 5 (Proposed) is available in 14G, 16G, 18G, 20G, 22G, 24G and 26G.

g. Indications for Use Statement

The Supercath 5 is intended to access a vein or artery and to administer fluids and/or blood. The Supercath 5 is designed for single use and is designed to minimize inadvertent needlesticks and to reduce accidental needlesticks. The 18 - 22-gauge catheters may be used with power injectors at a maximum pressure of 300 psi.

6

Image /page/6/Picture/0 description: The image shows a logo with a globe-like background. In the center of the globe is a stylized human figure with arms raised. The figure is white, and the globe is made up of a grid pattern.

TOGO MEDIKIT CO., LTD.
17148-6, Aza Kamekawa, Oaza Hichiya, Hyuga City
Miyazaki Prefecture 883-0062, Japan
TELEPHONE: +81-982-53-8027
FACSIMILE: +81-982-53-8008

Page 4 of 8

h. Comparative Information

The Supercath 5 (Proposed) was modified from the Supercath 5 (K140419) and the Supercath 5 (K172496). The primary difference in the Supercath 5 (proposed) is the indications for use statement includes administration of blood and 18-22 gauge catheters may be used with power injectors. These changes do not affect the intended use of the device compared to the predicates.

Technological characteristics

The similarities of the subject device to the predicate devices are:

  • Same catheter material (Polyurethane)
  • Radiopaque
  • Flashback Visualization
  • Side-Notch Needle ●
  • Same Needlestick Injury Prevention Feature ●
  • Check Valve
  • Ethylene Oxide Sterilized ●
  • Single Sterile Wrapped ●
  • Multiple Gauge Sizes and Needle Lengths ●

The Supercath 5 (Proposed) contains following modifications as compared to the predicate devices:

  • Change of material formulation of the plug, the wing, the plunger, the cap, and the protector
  • The adjustable attachment on the tip of the grip is not used for all models
  • Addition of a packing part for blood on the needle hub for all models ●
  • Addition of power injection to 18G, 20G, and 22G ●
  • Addition of administration of blood in the Indications for Use ●

Performance testing was done to support the modifications of the subject device

Followings are comprehensive comparison table for the proposed, predicate, and reference devices:

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Image /page/7/Picture/0 description: The image shows a logo featuring a stylized human figure within a globe. The figure is composed of simple lines and shapes, suggesting a person with arms raised. The globe is represented by a grid pattern, giving it a three-dimensional appearance. The logo is in grayscale and appears to be a symbol for an organization or concept related to global humanity.

TOGO MEDIKIT CO., LTD
17148-6, Aza Kamekawa, Oaza Hichiya, Hyuga City
Miyazaki Prefecture 883-0062, Japan
TELEPHONE: +81-982-53-8027

Table 2 Comparison table between the Supercath 5 (Proposed), the predicate and the reference devises

| Item | Supercath
(Proposed) | Predicate Devices | | Reference Device | Substantial
Equivalence
Analysis |
|------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
| | 5 | Supercath
(K140419) | 5
Supercath
(K172496) | 5
Supercath
(K160592) | 6 |
| Indications for Use
Statement | The Supercath 5 is
intended to access a
vein or artery and to
administer fluids
and/or blood. The
Supercath 5 is
designed for single
use, and is designed
to minimize
inadvertent
needlesticks and to
reduce accidental
needlesticks. The 18

  • 22 gauge catheters
    may be used with
    power injectors at a
    maximum pressure
    of 300 psi. | The Supercath 5 is
    intended to access a
    vein or artery and to
    administer fluids.
    The Supercath 5 is
    designed for single
    use and for
    short-term use (less
    than 30 days), is
    designed to
    minimize
    inadvertent
    needlesticks and to
    reduce accidental
    needlesticks. | The Supercath 5 is
    intended to access a
    vein or artery and to
    administer fluids.
    The Supercath 5 is
    designed for single
    use, and is designed
    to minimize
    inadvertent
    needlesticks and to
    reduce accidental
    needlesticks. | The Supercath 6 is
    intended to access a
    vein or artery and to
    administer fluids.
    The Supercath 6 is
    designed for single
    use and for
    short-term use (less
    than 30 days), is
    designed to
    minimize
    inadvertent
    needlesticks and to
    reduce accidental
    needlesticks. The 18
  • 22 gauge catheters
    may be used with
    power injectors at a
    maximum pressure
    of 300 psi. | Substantially
    equivalent.
    For detail about
    substantial
    equivalence
    analysis for
    Indications for Use
    statement, please
    see above. |
    | Needlestick injury
    prevention feature | The metallic introducer needle is retracted into the needle hub when the activation button
    on the needle hub is pressed. | | | | Same |
    | Flashback
    visualization | Yes | Yes | Yes | | Same. |
    | Side-notch needle*1 | Yes | Yes | Yes | | Same |

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Image /page/8/Picture/0 description: The image shows a logo that appears to be for an organization or company. The logo features a stylized human figure standing within a globe-like structure. The figure is abstract, with a large head and arms raised, giving the impression of someone reaching upwards or outwards. The globe is represented by a grid of lines, suggesting a network or global connection.

TOGO MEDIKIT CO., LTD

17148-6, Aza Kamekawa, Oaza Hichiya, Hyuga City
Miyazaki Prefecture 883-0062, Japan
TELEPHONE: +81-982-53-8027
FACSIMILE: +81-982-53-8008

| Item | Supercath
(Proposed) | Predicate Devices | Supercath
(K140419) | Supercath
(K172496) | Reference Device | Supercath
(K160592) | Substantial
Equivalence
Analysis |
|-------------------------------------------------------------|---------------------------------------------------|-----------------------------------------------------------|-------------------------------------------|------------------------|------------------|------------------------|--------------------------------------------------------------------------------------------------------------|
| Radiopaque | Yes | | Yes | Yes | | | Same |
| Adjustable
attachment*2 | No | | Yes | No | | | Please see 2 |
| Additional packing
part for blood on the
needle hub
3 | Yes | | No | No | | | Performance data |
| Sterilization | Ethylene oxide | | Ethylene oxide | Ethylene oxide | | | Same |
| Packaging | Blister | | Blister | Blister | | | Same. |
| Use with Power
Injectors (18G, 20G,
22G) | Yes | | No | No | | Yes | Performance Data |
| Multiple gauge
sizes and needle
length | Yes (14G, 16G, 18G,
20G, 22G, 24G, and
26G) | | Yes (14G, 16G, 18G,
20G, 22G, and 24G) | 26G | | | The two predicate
devices altogether
cover the sizes
which the Supercath
(Proposed)
includes. |
| Material of catheter
tube | Polyurethane | | Polyurethane | Polyurethane | | | Same. |

*! Side-notch needle is the introducer needle with a side-noth, to provide rapid visual confirmation of vessel entry. When the introducer needle is inserted into the vein, blood flows upward into the side-notch alown along the inside of the catheter tube. This does not affect the intended use of the device.

*2: The adjustable attachment is used just when manufacturing the Supercath 5 (K140419). The attachment the tip of the introducer needle and the tip of the catheter. This does not affect the intended use of the device.

*3: The packing part on the needle hub improves the prevention of the device. This does not affect the intended use of the device.

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Image /page/9/Picture/0 description: The image shows a logo with a stylized human figure standing inside a globe. The human figure is white, and the globe is made up of intersecting lines, giving it a grid-like appearance. The logo is simple and abstract, focusing on the concept of humanity within a global context.

i. Performance data

Evaluations of the modifications in support of the substantial equivalence determination is shown below;

1. Biocompatibility testing

The Supercath 5 (Proposed) contacts patient's skin and blood and is categorized as an External communicating. Circulating blood contact device with a Prolonged contact duration in accordance with ISO 10993-1:2009 and referencing FDA guidance entitled "Use of International Standard ISO 10993- 1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The nature of contact with the body and the category of the Supercath 5 (Proposed) are identical to those of the predicate devices.

Biocompatibility testing was leveraged from the sponsor's own predicate devices (K140419 and K172496).

The addition of administration of blood in the Indications for Use is supported by the Hemocompatibility testing (hemolysis, complement system, coagulation, platelets, and thrombosis) performed on the sponsor's own reference device (K160592).

  1. Power injection test

Catheter burst pressure exceeds the peak pressure present in the catheter at maximum flow conditions when tested according to ISO 10555-1:2013.

  1. Vent fitting test for the needle hub

The needle hub with the packing part is impervious to liquid infiltration when subjected to positive pressure in accordance with ISO 10555-5:2013.

    1. Flow rate test
      The flow rate through catheter meets allowable limits when tested according to ISO 10555-1:2013.
  1. Ease of assembly performance testing for the plunger

The plunger passes through the check valve when tested according to ISO 594-2:1998 section 5.6.

  1. Tensile strength testing for the cap

The tensile strength of the cap meets acceptable minimum force until breakage when tested according to in-house standard.

  1. Sterilization validation in accordance with ISO 11135:2014 and shelf-life testing were conducted.

10

Image /page/10/Picture/0 description: The image shows a logo with a globe-like structure in the background. In the foreground, there is a stylized human figure with arms outstretched, superimposed over the globe. The figure appears to be made of interconnected lines or segments, giving it a modern and abstract look. The overall design is simple and monochromatic, with a focus on the interconnectedness of the human figure and the global sphere.

The results of testing above did not raise any new questions of safety or effectiveness.

j. Conclusion

Based on the Indications for Use, technological characteristics, and performance testing, Togo Medikit concludes that the Supercath 5 (proposed) is substantially equivalent to the predicate devices.