(28 days)
The Bashir™ S-B Endovascular Catheter is intended for the controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
The Bashir™ S-B Endovascular Catheter (Model 7101) is a continuous flush catheter designed to enable delivery of physician-specified fluids, including thrombolytics, into the peripheral circulation. The design of the Bashir™ S-B Endovascular Catheter allows for delivery and positioning of the catheter at the target peripheral location via a sheath, over a guidewire using fluoroscopic guidance. Depending on the target location, the infusion can be initiated either in the non-expanded position (for vessels with smaller diameters), or by controlled expansion of the infusion basket to a desired dimension inside the vessel by the interventional specialist under fluoroscopic guidance. The physician-specified solution is delivered via multiple laser-drilled holes through the infusion limbs of the Bashir™ S-B Endovascular Catheter after placement. After the completion of solution delivery, the infusion limbs are collapsed to a straight position and then the Bashir™ S-B Endovascular Catheter is retracted into the sheath and removed.
The Bashir™ S-B Endovascular Catheter is comprised of common materials used in vascular catheters. The catheter is mechanical and contains no electrical components.
This document describes the Bashir™ S-B Endovascular Catheter (Model 7101) and its substantial equivalence to a predicate device. The information provided primarily focuses on technical specifications and bench testing, rather than clinical study data involving human readers or AI.
Here's an analysis based on the provided text, addressing your specific questions:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Test/Metric | Acceptance Criteria | Reported Performance (or Conclusion) |
|---|---|---|---|
| Mechanical Performance | Trackability | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) |
| Advancement Force | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Slider Actuator Force | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Catheter Retraction | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Radial Force | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Delivery Flow Rate | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Infusion Pressure (various flow rates) | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Infusion Pressure (with pulse spray) | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Dimensional Verification | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Joint Tensile Strengths | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) | |
| Labeling/Usability | Label Legibility | Not specified (implied to be acceptable) | Pass (demonstrated substantial equivalence) |
| Usability Testing (device handle) | "pre-defined acceptance criteria" | Met pre-defined acceptance criteria | |
| Sterility & Shelf Life | Sterilization Validation | Sterility Assurance Level of 10^-6 (ISO 11135:2014) | Complied with ISO 11135:2014, validated to SAL of 10^-6 |
| Shelf Life | 2 years | Established through accelerated aging studies, supports 2 years |
2. Sample Size Used for the Test Set and Data Provenance
Since the performance testing primarily involved bench testing of the physical device, the concept of a "test set" in the context of clinical data or image-based AI is not directly applicable. The text mentions "performance data repeated for the modified device," implying a certain number of devices were produced and tested, but the exact sample sizes for each bench test are not specified.
The Usability Testing involved "ten (10) intended users." The provenance of this user data (e.g., country of origin, retrospective/prospective) is not specified, but it was likely prospective testing conducted by the manufacturer.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. This device is an endovascular catheter, and the evaluation did not involve establishing ground truth from images or clinical data by experts in the context of an AI study. Usability testing involved "intended users," whose specific qualifications (beyond being "intended users") are not detailed.
4. Adjudication Method for the Test Set
Not applicable. No expert adjudication method is mentioned, as the evaluation type was primarily physical device performance and usability.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs without AI Assistance
No. This submission does not describe an AI medical device, nor does it present any MRMC comparative effectiveness study involving human readers with or without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This device is a medical instrument, not an AI algorithm.
7. The Type of Ground Truth Used
- For Mechanical Performance: The "ground truth" would be established by engineering specifications, physical measurements, and industry standards for catheter performance (e.g., force required for advancement, flow rates).
- For Sterilization: The "ground truth" is adherence to ISO 11135:2014 and achieving a Sterility Assurance Level (SAL) of 10^-6.
- For Shelf Life: The "ground truth" is the stability of the device over time, established through accelerated aging studies predicting a 2-year shelf life.
- For Usability Testing: The "ground truth" is the "pre-defined acceptance criteria" for the usability of the device handle by intended users.
8. The Sample Size for the Training Set
Not applicable. This is not an AI device.
9. How the Ground Truth for the Training Set Was Established
Not applicable. This is not an AI device.
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February 3, 2022
Thrombolex, Inc. % Diane Horwitz Regulatory Eminence Clinical Research Inc. 5 Lake Como Ct. Greenville. South Carolina 29609
Re: K192598
Trade/Device Name: Bashir S-B Endovascular Catheter, Ref. No. 7101 Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: OEY, KRA
Dear Diane Horwitz:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated October 18, 2019. Specifically, FDA is updating this SE Letter as an administrative correction because FDA has created a new product code to better categorize your device technology.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Gregory O'Connell, OHT2: Office of Cardiovascular Devices, (301) 796-6075, Gregory.Oconnell(@FDA.HHS.gov.
Sincerely,
Image /page/0/Picture/9 description: The image shows a digital signature. The signature is for Gregory W. O'connell -S. The signature was created on February 3, 2022.
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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October 18, 2019
Thrombolex, Inc. % Diane Horwitz, PhD Regulatory Consultant Eminence Clinical Research, Inc. 5 Lake Como Ct. Greenville, South Carolina 29609
Re: K192598
Trade/Device Name: Bashir™ S-B Endovascular Catheter, Ref. No. 7101 Regulation Number: 21 CFR 870.1210 Regulation Name: Continuous Flush Catheter Regulatory Class: Class II Product Code: KRA Dated: September 19, 2019 Received: September 20, 2019
Dear Dr. Horwitz:
We have reviewed vour 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
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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,
Digitally signed Eleni by Eleni Whatley For Whatley 09:39:55 -04'00' Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K192598
Device Name
Bashir™ S-B Endovascular Catheter, Ref. No. 7101
Indications for Use (Describe)
The Bashir™ S-B Endovascular Catheter is intended for the controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
| 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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Image /page/4/Picture/1 description: The image shows the word "THROMBOLEX" in large, bold, red letters. Below the word is the phrase "INNOVATIVE ENDOVASCULAR CATHETERS" in smaller, gray letters. The "X" in "THROMBOLEX" is stylized with a red line extending upwards and to the right, creating a visual emphasis. The trademark symbol is also present next to the word.
510(k) SUMMARY
GENERAL INFORMATION 1.
1.1 Submitter and 510(k) Owner
Thrombolex, Inc. 75 Britain Dr. New Britain PA 18901
1.2 Official Correspondent
Diane Horwitz, Ph.D. 5 Lake Como Ct. Greenville, SC 29609 Telephone: 703.307.2921 Email: dhorwitz@ecr-inc.com
1.3 Date of Preparation
October 17, 2019
2. NAME OF THE DEVICE
2.1.1 Trade/Proprietary Name
Bashir™ S-B Endovascular Catheter, Ref. No. 7101
2.1.2 Common/Usual Name
Continuous Flush Catheter
Classification Information 2.1.3
| Classification Name: | Continuous Flush Catheter |
|---|---|
| Classification Regulation: | 21 CFR 870.1210 |
| Class: | 2 |
| Product Code: | KRA – Continuous Flush Catheter |
| Panel: | Cardiovascular |
3. PREDICATE DEVICE
The predicate device is the Bashir™ Endovascular Catheter, Reference No. 7201, K183290.
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4. DESCRIPTION OF THE DEVICE
The Bashir™ S-B Endovascular Catheter (Model 7101) is a continuous flush catheter designed to enable delivery of physician-specified fluids, including thrombolytics, into the peripheral circulation. The design of the Bashir™ S-B Endovascular Catheter allows for delivery and positioning of the catheter at the target peripheral location via a sheath, over a guidewire using fluoroscopic guidance. Depending on the target location, the infusion can be initiated either in the non-expanded position (for vessels with smaller diameters), or by controlled expansion of the infusion basket to a desired dimension inside the vessel by the interventional specialist under fluoroscopic guidance. The physician-specified solution is delivered via multiple laser-drilled holes through the infusion limbs of the Bashir™ S-B Endovascular Catheter after placement. After the completion of solution delivery, the infusion limbs are collapsed to a straight position and then the Bashir™ S-B Endovascular Catheter is retracted into the sheath and removed.
The Bashir™ S-B Endovascular Catheter is comprised of common materials used in vascular catheters. The catheter is mechanical and contains no electrical components.
5. INDICATION FOR USE
The Bashir™ S-B Endovascular Catheter is intended for the controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
6. COMPARISON OF THE INTENDED USE WITH THE PREDICATE DEVICE
The Bashir™ S-B Endovascular Catheter is intended to be used in the same interventional procedures in the same target population (patients with thrombosis in the peripheral vasculature) and have the same primary function of providing a conduit for infusion of solutions. The Bashir™ S-B Endovascular Catheter has an identical intended use/indications for use statement compared to the predicate device.
TECHNOLOGICAL CHARACTERISTICS COMPARED TO THE 7. PREDICATE
The Bashir™ S-B Endovascular Catheter is substantially equivalent to the predicate device regarding its similar intended use, fluid infusion function, design, materials, packaging and sterility.
The parent device was modified to shorten the infusion basket from 12.5 cm to 10 cm to facilitate use in different anatomical size and/or locations within the peripheral vasculature to increase efficiency of exposure of the clot to thrombolytic solutions. Features of the handle were changed to improve ergonomics and torque resistance of the connector.
Through product testing, Thrombolex has demonstrated that the technological differences between the subject device and the predicate device do not raise different issues of safety or effectiveness.
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8. PERFORMANCE TESTING
This 510(k) notification provides performance data to establish the substantial equivalence of the Bashir™ S-B Endovascular Catheter to the predicate device. The following is a summary of the performance data repeated for the modified device.
Performance Testing - Bench: Performance testing was repeated to confirm that the device modifications did not adversely affect the device performance.
The testing included an evaluation of: Trackability, advancement force, slider actuator force, catheter retraction, radial force, delivery flow rate, infusion pressure at various flow rates, infusion pressure with pulse spray, dimensional verification, joint tensile strengths and label legibility. The performance data demonstrate that the new device is substantially equivalent to the predicate device.
Sterilization and Shelf Life: The devices are sterilized using standard methods and the sterilization cycles have been validated following international standards. The shelf life of the devices was established through stability studies. The sterilization validation complied with ISO 11135: 2014. The sterilization cycle was validated to a sterility assurance level of 10 . The shelf life of the Bashir Catheters was established through accelerated aging studies, and support a shelf life of 2 years.
Usability Testing: Usability testing was performed using the to-be-marketed modified device handle by ten (10) intended users and was found to be meet pre-defined acceptance criteria.
CONCLUSIONS 9.
The information presented in this 510(k) submission demonstrates that the Bashir™ Endovascular S-B Catheter is substantially equivalent to the predicate device.
§ 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).