K Number
K192408
Device Name
Custodiol HTK Solution
Date Cleared
2020-04-24

(233 days)

Product Code
Regulation Number
876.5880
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
CUSTODIOL® HTK solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. CUSTODIOL® HTK solution is not indicated for continuous machine perfusion of donor organs.
Device Description
The CUSTODIOL® HTK solution is intended for perfusion and flushing donor kidney, liver, heart, and pancreas prior to removal from the donor and for preserving these organs during hypothermic storage and transport to the recipient. CUSTODIOL® HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine/histidine HCI, so as to prolong the period for which the organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the CUSTODIOL® HTK solution is due to the sodium and potassium. The composition of HTK is similar to that of extracellular fluid. All of the components of the CUSTODIOL® HTK solution occur naturally in the body. The CUSTODIOL® HTK solution is relatively low in potassium concentration so that residual solution in the transplanted organ poses no danger to the recipient. This is particularly important in orqans that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation. The CUSTODIOL® HTK solution has a low viscosity, even at low temperatures. This characteristic assures rapid flow rates during initial perfusion, allowing the organ to be quickly cooled.
More Information

Not Found

No
The device description and performance studies focus on the chemical composition and physical properties of a preservation solution, with no mention of AI or ML technologies.

Yes
The device is used for organ preservation and does not directly treat a disease or condition in a living organism. Its purpose is to maintain the viability of organs for transplantation, which is a supportive rather than a therapeutic function.

No

The device is a preservation solution used for organs prior to transplantation, not a tool for diagnosing medical conditions. It aids in maintaining organ viability, not in identifying diseases or pathological states.

No

The device description clearly indicates it is a solution (liquid) used for organ preservation, not a software program.

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 perfusion, flushing, and preservation of donor organs (kidneys, liver, pancreas, and heart) prior to and during transplantation. This is a direct intervention on the organ itself, not a test performed in vitro (outside the body) on a sample from the body to diagnose a condition or provide information about a physiological state.
  • Device Description: The description details the composition and function of the solution in preserving the organ's viability during storage and transport. It focuses on the solution's properties for maintaining the organ's integrity, not for analyzing a biological sample.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information. The device's function is entirely focused on the physical preservation of the organ.

Therefore, CUSTODIOL® HTK solution falls under the category of a medical device used in the context of organ transplantation, but it is not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

CUSTODIOL® HTK solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. CUSTODIOL® HTK solution is not indicated for continuous machine perfusion of donor organs.

Product codes

KDL, MSB

Device Description

The CUSTODIOL® HTK solution is intended for perfusion and flushing donor kidney, liver, heart, and pancreas prior to removal from the donor and for preserving these organs during hypothermic storage and transport to the recipient. CUSTODIOL® HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine/histidine HCI, so as to prolong the period for which the organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the CUSTODIOL® HTK solution is due to the sodium and potassium. The composition of HTK is similar to that of extracellular fluid. All of the components of the CUSTODIOL® HTK solution occur naturally in the body. The CUSTODIOL® HTK solution is relatively low in potassium concentration so that residual solution in the transplanted organ poses no danger to the recipient. This is particularly important in orqans that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation. The CUSTODIOL® HTK solution has a low viscosity, even at low temperatures. This characteristic assures rapid flow rates during initial perfusion, allowing the organ to be quickly cooled.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

kidneys, liver, pancreas and heart

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Federal law restricts sale of this device to or on the order of a physician or licensed practitioner.

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)

6. Summary of Performance Testing

6.1. Bench Testing

6.1.1. Biocompatibility

CUSTODIOL® HTK systemic toxicity, genotoxicity as well as hemocompatibility are considered to be satisfactorily demonstrated by available data. Biological evaluation has been proved in accordance with:

  • USP , USP , USP , USP , USP , USP , EU.Ph → 2.2.1, EU. Ph. 2.2.2, Eu. Ph. 2.2.25, Eu. Ph.3.1, EU. Ph. 3.2, Eu. Ph. 3.2.2, Eu.Ph. 3.2.9, ISO 10993-11 (Tests performed on packaging / solution)
    CUSTODIOL® HTK cytotoxicity, irritation and sensitization additional tests were performed according to the ISO 10993-1/2/5/10/12 and are considered to be satisfactorily demonstrated.

6.1.2. Sterilization

CUSTODIOL® HTK Solution is supplied in STERILE via steam sterilization.

6.1.3. Shelf-Life

CUSTODIOL® HTK Solution shelf life has been validated up to 12 months through stability studies, biocompatibility testing, and packaging validation.

6.2. Animal Testing

Animal tests are deemed not necessary to demonstrate safety of CUSTODIOL® HTK Solution.

6.3. Clinical Testing

Clinical data are available and able to demonstrate reliability of CUSTODIOL® HTK Solution. To support the substantial equivalence for this 510(k), no further clinical data were required. The safety and efficacy of CUSTODIOL® HTK Solution as an organ preservation solution has not been clinically demonstrated in extended criteria donors (ECD), donation after cardiac arrest (DCD) or other marginal donor populations.

7. 510(k) Summary Conclusions

Based on the available 510(K) information, Dr. Franz Köhler Chemie GmbH CUSTODIOL® HTK solution is considered "substantially equivalent" to selected predicate device. Differences concerning the clinical application, intended use, biological aspects, design, technical features as well as performance specifications do not lead to any new risks. Both tests and validations performed on our devices support our statements.

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

Not Found

Predicate Device(s)

K043461

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 876.5880 Isolated kidney perfusion and transport system and accessories.

(a)
Identification. An isolated kidney perfusion and transport system and accessories is a device that is used to support a donated or a cadaver kidney and to maintain the organ in a near-normal physiologic state until it is transplanted into a recipient patient. This generic type of device may include tubing, catheters, connectors, an ice storage or freezing container with or without bag or preservatives, pulsatile or nonpulsatile hypothermic isolated organ perfusion apparatus with or without oxygenator, and disposable perfusion set.(b)
Classification. Class II (performance standards).

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April 24, 2020

Dr. Franz Kohler Chemie GmbH Clifton Czarnojon Quality Manager Werner-von-Siemens-Strabe 14-28 Bensheim, Hessen 64625 GERMANY

Re: K192408

Trade/Device Name: Custodiol HTK Solution Regulation Number: 21 CFR 876.5880 Regulation Name: Isolated Kidney Perfusion and Transport System and Accessories Regulatory Class: II Product Code: KDL, MSB Dated: March 23, 2020 Received: March 25, 2020

Dear Clifton Czarnojon:

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/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,

Carolyn Y. Neuland, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices 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) K192408

Device Name CUSTODIOL® HTK Solution

Indications for Use (Describe)

CUSTODIOL® HTK solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. CUSTODIOL® HTK solution is not indicated for continuous machine perfusion of donor organs.

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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Arzneimittel

1. General Info

Submission Date 2019-03-23

Device's Name

Submitter

Werner-von-Siemens-Straße 14-28 64625 Bensheim Germany Tel.: +49 6251 1083-0 Fax: +49 6251 1083-146 E-Mail: info@koehler-chemie.de Internet: www.koehler-chemie.de

Dr. Franz Köhler Chemie GmbH

CUSTODIOL® HTK Solution

Official Contact Person

Clifton Czarnojon Quality Manager Tel.: +49 6251 1083-242 E-Mail: c.czarnojon@koehler-chemie.de

Common Device Name Set, Perfusion, Kidney, Disposable Classification Name Isolated kidney perfusion and transport system and accessories Classification Panel Gastroenterology/Urology Product Code KDL, MSB Requlation Number 21 CFR 876.5880

2

Device Class

2019-03-23

K192408

Image /page/3/Picture/14 description: The image shows a red logo. The logo is a stylized letter 'k' that is made up of three diagonal lines. The lines are thick and bold, and they overlap each other to create the shape of the letter. The logo is simple and modern, and the red color makes it stand out.

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Arzneimittel

2. Summary of Legally Marketed Devices

In the table below is listed the predicate device deemed substantially equivalent to Dr. Franz Köhler Chemie GmbH CUSTODIOL® HTK Solution.

Predicate Device 1
Subject DeviceTrade
NameModel
Number510(k)
510(k)
Holder
CUSTODIOL® HTK
SolutionCUSTODIOL® HTK
SolutionN.A.K043461Dr. Franz Köhler Chemie
GmbH

3. Device Description

The CUSTODIOL® HTK solution is intended for perfusion and flushing donor kidney, liver, heart, and pancreas prior to removal from the donor and for preserving these organs during hypothermic storage and transport to the recipient. CUSTODIOL® HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine/histidine HCI, so as to prolong the period for which the organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the CUSTODIOL® HTK solution is due to the sodium and potassium. The composition of HTK is similar to that of extracellular fluid. All of the components of the CUSTODIOL® HTK solution occur naturally in the body. The CUSTODIOL® HTK solution is relatively low in potassium concentration so that residual solution in the transplanted organ poses no danger to the recipient. This is particularly important in orqans that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation. The CUSTODIOL® HTK solution has a low viscosity, even at low temperatures. This characteristic assures rapid flow rates during initial perfusion, allowing the organ to be quickly cooled.

3.1. Indication for Use

CUSTODIOL® HTK solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. CUSTODIOL® HTK solution is not indicated for continuous machine perfusion of donor organs.

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Arzneimittel

4. Product Info

CUSTODIOL® HTK contains:

ComponentIngredientFunction
Active ComponentsSodium chlorideElectrolyte
Potassium chlorideElectrolyte
Magnesium chloride hexahydrateElectrolyte
Calcium chloride dihydrateElectrolyte
HistidineBuffering agent
Histidine hydrochloride monohydrateBuffering agent
TryptophanCell protective agent
MannitolOsmolytic agent
α-ketoglutaric acidCell protective agent
ExcipientsPotassium hydroxidepH adjusting agent
Water for injectionsSolvent

5. Subject / Predicate /Reference Devices Comparative Tables

5.1. Indication for Use Comparison

Indication for UseIntended User
Subject Device / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° - / CUSTODIOL® HTK Solution
CUSTODIOL® HTK solution is indicated for perfusion and flushing
of donor kidneys, liver, pancreas and heart prior to removal from
the donor or immediately after removal from the donor. The
solution is left in the organ vasculature during hypothermic
storage and transportation to the patient. CUSTODIOL® HTK
solution is not indicated for continuous machine perfusion of
donor organs.Federal law restricts sale of this device to or on the order of a physician or
licensed practitioner.
Predicate Device 1 / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° K043461 / CUSTODIOL® HTK Solution
CUSTODIOL® HTK Solution is indicated for perfusion and flushing
donor kidneys, liver, pancreas, and heart prior to removal from
the donor or immediately after removal from the donor. The
solution is left in the organ vasculature during hypothermic
storage and transportation (not for continuous perfusion) to the
recipient.Federal law restricts sale of this device to or on the order of a physician or
licensed practitioner.
Results after Predicate Device 1 Comparison
Substantially
EquivalentSubstantially
Equivalent

5.1.1. Indication for Use Conclusions

As clearly demonstrated, in the table above, there are no differences between candidate and predicate device Indication for Use. Therefore, Indication for Use are deemed substantially equivalent.

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Image /page/6/Picture/3 description: The image shows a red logo. The logo is a stylized letter 'K' with a bold, angular design. The color is a deep red, and the background is white.

5.2. Biological Characteristics Comparison

| Nature of Body Contact

  •         Type                                                                           | Nature of Body Contact
    
  •         Category | Nature of Body Contact
    
  •         Contact | Contact
    

Duration | |
|------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------|-------------------------------------------------|-----------------------------------|-------------------------------|
| Subject Device / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° - / CUSTODIOL® HTK Solution | | | | |
| Direct | Indirect | | | |
| ☑ | ☐ | Implant device | Tissues, blood, circulating blood | B - Prolonged (>24 h to 30 d) |
| Predicate Device 1 / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° K043461 / CUSTODIOL® HTK Solution | | | | |
| Direct | Indirect | | | |
| ☑ | ☐ | Implant device | Tissues, blood, circulating blood | B - Prolonged (>24 h to 30 d) |
| Results after Predicate Device 1 Comparison | | | | |
| Substantially
Equivalent | Substantially
Equivalent | Substantially
Equivalent | Substantially
Equivalent | |

5.2.1. Biological Characteristics Conclusions

Biological comparison has been provided in the aforementioned table. As clearly demonstrated, there are no differences between candidate and predicate device. Therefore, biological characteristics are deemed substantially equivalent.

5.3. Design / Technical Characteristics Comparison

| Image | Delivery
Status | Material | Packaging |
|------------------------------------------------------------------------------------------------------------------------|-----------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|
| Image: Subject Device | Sterile | Sodium chloride
Potassium chloride
Potassium hydrogen 2-ketoglutarate
Magnesium chloride · 6H2O
Histidine · HCl · H2O
Histidine
Tryptophan
Mannitol
Calcium chloride · 2H2O | Bottles of 500 ml
Bottles of 1000 ml
Bags of 1000 ml
Bags of 2000 ml
Bags of 5000 ml |
| Subject Device / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° - / CUSTODIOL® HTK Solution | | | |
| Image: Predicate Device 1 | Sterile | Sodium chloride
Potassium chloride
Potassium hydrogen 2-ketoglutarate
Magnesium chloride · 6H2O
Histidine · HCl · H2O
Histidine
Tryptophan
Mannitol
Calcium chloride · 2H2O | Bottles of 500 ml
Bottles of 1000 ml |
| Predicate Device 1 / Dr. Franz Köhler Chemie GmbH / Product Code KDL/MSB / 510(k) N° K043461 / CUSTODIOL® HTK Solution | | | |
| N.A. | Substantially
Equivalent | Substantially
Equivalent | Different; Substantial Equivalence demonstrated through
non-clinical testing a) |
| Results after Predicate Device 1 Comparison | | | |

Plastic naterial sed for inforn bags onforn to P. Eur. Mongraphs . and 3. "Material or the manufacture
of containers for pharmaceutical use "requirementical packaging/deliver a) study has been carried out. Furthermore, CUSTODIOL® HTK solution has been tested for cytotoxicity, irritation and sensitization. Compatibility of plastic materials used in infusion base was confirmed for CUSTODIOL® HTK solutions of the comparative investigations performed with the plastic materials of the infusion that the applied conditions of sterilization procedure have no influence on the quality of the product.

5.3.1. Design / Technical Characteristics Conclusions

Design/Technical comparison has been provided in the aforementioned table. As clearly demonstrated, differences between candidate and predicate device were evaluated through non-clinical testing, which supported that the devices are substantially equivalent.

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6. Summary of Performance Testing

6.1. Bench Testing

6.1.1. Biocompatibility

CUSTODIOL® HTK systemic toxicity, genotoxicity as well as hemocompatibility are considered to be satisfactorily demonstrated by available data. Biological evaluation has been proved in accordance with:

  • USP , USP , USP , USP , USP , USP , EU.Ph → 2.2.1, EU. Ph. 2.2.2, Eu. Ph. 2.2.25, Eu. Ph.3.1, EU. Ph. 3.2, Eu. Ph. 3.2.2, Eu.Ph. 3.2.9, ISO 10993-11 (Tests performed on packaging / solution)
    CUSTODIOL® HTK cytotoxicity, irritation and sensitization additional tests were performed according to the ISO 10993-1/2/5/10/12 and are considered to be satisfactorily demonstrated.

6.1.2. Sterilization

CUSTODIOL® HTK Solution is supplied in STERILE via steam sterilization.

6.1.3. Shelf-Life

CUSTODIOL® HTK Solution shelf life has been validated up to 12 months through stability studies, biocompatibility testing, and packaging validation.

6.2. Animal Testing

Animal tests are deemed not necessary to demonstrate safety of CUSTODIOL® HTK Solution.

6.3. Clinical Testing

Clinical data are available and able to demonstrate reliability of CUSTODIOL® HTK Solution. To support the substantial equivalence for this 510(k), no further clinical data were required. The safety and efficacy of CUSTODIOL® HTK Solution as an organ preservation solution has not been clinically demonstrated in extended criteria donors (ECD), donation after cardiac arrest (DCD) or other marginal donor populations.

7. 510(k) Summary Conclusions

Based on the available 510(K) information, Dr. Franz Köhler Chemie GmbH CUSTODIOL® HTK solution is considered "substantially equivalent" to selected predicate device. Differences concerning the clinical application, intended use, biological aspects, design, technical features as well as performance specifications do not lead to any new risks. Both tests and validations performed on our devices support our statements.