K Number
K203262
Device Name
Cannula for Organ Perfusion
Date Cleared
2021-07-01

(238 days)

Product Code
Regulation Number
876.5880
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Cannula for Organ Perfusion is a single-use device indicated for hypothermic flushing and replacement of residual blood in donor organs with a legally marketed organ preservation solution at the time of organ removal from the donor during the preparation of these organs for transplantation. This device is indicated for use with gravity flow; no testing has been provided for use with pump systems, such as mechanical perfusion devices.
Device Description
The Cannula for Organ Perfusion is a device designed and intended as a component to an organ perfusion and transport system / organ preservation solution, used in an organ transplantation procedure. The device is a cannula (available in several different sizes) intended for flushing and replacement of residual blood in donor organs with organ preservation solution during the preparation processes of these organs for transplantation. The cannulas are single use, sterile, non-toxic and nonpyrogenic devices. As a component to an organ perfusion and transport system / organ preservation solution, the Cannula for Organ Perfusion is also a Class II medical device, subject to Product Code KDN and MSB, 21 CFR 876.5880: "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." (21 CFR 876.5880(a)). The Cannulas come in multiple sizes, according to the French catheter scale, including 8F, 10F, 12F, 16F (adjustable to 18F with a slidable ring), 20F (adjustable to 28F with a slidable ring), 25F (adjustable to 34F with a slidable ring). In addition, there is a configuration of the cannula that is intended for "back table" procedures, which is available in a 16F size.
More Information

Not Found

No
The device description and intended use are purely mechanical, describing a cannula for fluid delivery during organ perfusion. There is no mention of any computational or analytical functions that would suggest the use of AI or ML.

No.
The device's intended use is for hypothermic flushing and replacement of residual blood in donor organs with preservation solution, which is a preparation step for transplantation rather than a treatment for a disease or condition in a living patient.

No

The device description and intended use clearly state that the Cannula for Organ Perfusion is used for flushing and perfusing donor organs, not for diagnosing any condition. It is a component of an organ perfusion and transport system.

No

The device description explicitly states it is a "cannula," which is a physical, single-use device made of materials and available in different sizes. It is a component of a hardware system for organ perfusion.

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

Here's why:

  • Intended Use: The intended use is for the physical process of flushing and replacing blood in donor organs with preservation solution during preparation for transplantation. This is a procedural device used on the organ, not a test performed on a sample from the organ or patient to provide diagnostic information.
  • Device Description: The description clearly states it's a cannula, a physical tool for delivering fluid. It's described as a component of an organ perfusion and transport system.
  • Regulatory Classification: The device is classified under 21 CFR 876.5880, which covers "Organ perfusion and transport system." This regulation describes devices used for the physical process of preserving organs, not for diagnostic testing.
  • Lack of Diagnostic Information: There is no mention of the device being used to analyze a sample, measure a biomarker, or provide any information about the health or condition of the organ or the donor.

IVD devices are specifically designed to be used in vitro (outside the body) to examine specimens (like blood, urine, tissue) to provide information for the diagnosis, monitoring, or treatment of a disease or condition. This cannula does not fit that description.

N/A

Intended Use / Indications for Use

Cannula for Organ Perfusion is a single-use device indicated for hypothermic flushing and replacement of residual blood in donor organs with a legally marketed organ preservation solution at the time of organ removal from the donor during the preparation of these organs for transplantation. This device is indicated for use with gravity flow; no testing has been provided for use with pump systems, such as mechanical perfusion devices.

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

KDN, MSB

Device Description

The Cannula for Organ Perfusion is a device designed and intended as a component to an organ perfusion and transport system / organ preservation solution, used in an organ transplantation procedure. The device is a cannula (available in several different sizes) intended for flushing and replacement of residual blood in donor organs with organ preservation solution during the preparation processes of these organs for transplantation. The cannulas are single use, sterile, non-toxic and nonpyrogenic devices. As a component to an organ perfusion and transport system / organ preservation solution, the Cannula for Organ Perfusion is also a Class II medical device, subject to Product Code KDN and MSB, 21 CFR 876.5880: "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." (21 CFR 876.5880(a)).

The Cannulas come in multiple sizes, according to the French catheter scale, including 8F, 10F, 12F, 16F (adjustable to 18F with a slidable ring), 20F (adjustable to 28F with a slidable ring), 25F (adjustable to 34F with a slidable ring). In addition, there is a configuration of the cannula that is intended for "back table" procedures, which is available in a 16F size.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Donor organs

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)

Non-Clinical Tests Performed:
Bench testing demonstrates that the Cannula for Organ Perfusion is safe, effective and meets device specifications:

  • Testing related to tensile strength yielded Pass results in accordance with ISO 10555-1.
  • Testing related to leakage and tightness yielded Pass results in accordance with ISO 10555-1.
  • Testing related to flow rate demonstrated adequate flow of liquid in accordance with ISO 10555-1.

Clinical Testing:
No clinical tests were conducted in support of this 510(k) submission.

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.

K021362, K902394

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.

Not Found

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

§ 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).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".

July 1, 2021

Bridge to Life Ltd. % H. Carl Jenkins Regulatory Affairs Counsel Wood Burditt Group 10 E. Scranton Ave., Ste. 201 Lake Bluff, IL 60044

Re: K203262

Trade/Device Name: Cannula for Organ Perfusion Regulation Number: 21 CFR§ 876.5880 Regulation Name: Isolated Kidney Perfusion and Transport System and Accessories Regulatory Class: II Product Code: KDN, MSB Dated: May 27, 2021 Received: May 28, 2021

Dear H. Carl Jenkins:

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 statutes and regulations administered by other Federal agencies.

1

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-regulatoryinformation/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 mediation-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) K203262

Device Name

Cannula for Organ Perfusion

Indications for Use (Describe)

Cannula for Organ Perfusion is a single-use device indicated for hypothermic flushing and replacement of residual blood in donor organs with a legally marketed organ preservation solution at the time of organ removal from the donor during the preparation of these organs for transplantation. This device is indicated for use with gravity flow; no testing has been provided for use with pump systems, such as mechanical perfusion devices.

Type of Use (Select one or both, as applicable)
XI Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

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3

Image /page/3/Picture/1 description: The image shows the logo for "The Wood Burditt Group". The words "the", "WOOD", "BURDITT", and "group" are arranged in a stacked format. A teal-colored curved line is present on the right side of the text, adding a design element to the logo.

The Wood Burditt Group LLC 10 E. Scranton Ave., Suite 201 Lake Bluff, IL 60044 847. 234. 7500 (tel.) 847. 574. 0728 (e-fax) www.woodburditt.com

K203262 -- 510(k) Summary

Date prepared: June 16, 2021

| Submitter / Contact Person | H. Carl Jenkins
The Wood Burditt Group
10 E. Scranton Ave, Suite 201
Lake Bluff, IL 60044

(ph) 847-234-7500 x 205
(fax) 847-578-0728
(email) hcjenkins@woodburditt.com |

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| Applicant & 510(k) Owner | Bridge to Life Ltd.
128 Suber Rd., Suite A
Columbia, SC 29210
(ph) 847-796-3070

FDA Establishment Registration Number: 3009110022
FEI Number: 3009110022
Owner/Operator Number: 10038889 |

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Device Information

Trade NameCannula For Organ Perfusion
Proprietary NameCannula For Organ Perfusion
Common NameOrgan Perfusion Cannula
Classification NameIsolated Kidney Perfusion and Transport System and Accessories
Classification PanelGastroenterology/Urology
Regulation21 CFR 876.5880
FDA Product CodeKDN; MSB
FDA ClassificationII

Reason for 510(k) Submission

The applicant device is a new device.

4

Device Description

The Cannula for Organ Perfusion is a device designed and intended as a component to an organ perfusion and transport system / organ preservation solution, used in an organ transplantation procedure. The device is a cannula (available in several different sizes) intended for flushing and replacement of residual blood in donor organs with organ preservation solution during the preparation processes of these organs for transplantation. The cannulas are single use, sterile, non-toxic and nonpyrogenic devices. As a component to an organ perfusion and transport system / organ preservation solution, the Cannula for Organ Perfusion is also a Class II medical device, subject to Product Code KDN and MSB, 21 CFR 876.5880: "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." (21 CFR 876.5880(a)).

Image /page/4/Figure/3 description: The image shows a medical instrument with several labeled parts. The instrument is a long, thin tube with a blue flexible connector on one end. The other end has an athraumatic tip, and there are also fixed and slidable rings along the tube's length, labeled d1, d2, and d3 respectively.

The Cannulas come in multiple sizes, according to the French catheter scale, including 8F, 10F, 12F, 16F (adjustable to 18F with a slidable ring), 20F (adjustable to 28F with a slidable ring), 25F (adjustable to 34F with a slidable ring). In addition, there is a configuration of the cannula that is intended for "back table" procedures, which is available in a 16F size.

Cannula sized1 mm (F)d2 mm (F)d3 mm (F)
8 F2.7 (8 F)4.7 (14 F)-
10 F3.3 (10 F)5.3 (16 F)-
12 F4.0 (12 F)6.3 (19 F)-
16 F5.3 (16 F)7.3 (22 F)8.7 (26 F)
20 F6.7 (20 F)9.3 (28 F)10.7 (32 F)
25 F8.3 (25 F)11.3 (34 F)13.3 (40 F)

5

The surgeon performing the organ perfusion procedure will select the appropriate cannula for the particular organ to be perfused.

Indications for Use:

Cannula for Organ Perfusion is a single-use device indicated for hypothermic flushing and replacement of residual blood in donor organs with a legally marketed organ preservation solution at the time of organ removal from the donor during the preparation of these organs for transplantation. This device is indicated for use with gravity flow; no testing has been provided for use with pump systems, such as mechanical perfusion devices.

Predicate / Reference Device Summary Table

Based on the comparison of the device features, materials, intended use and performance the Cannula for Organ Perfusion was shown to be substantially equivalent to the lawfully marketed predicate devices indicated in the table below.

DeviceApplicant510(k) #Featured Element(s) of Substantial Equivalence
Cannula Accessory of the LifePort Kidney Perfusion TransporterOrgan Recovery Systems, Inc.K021362Intended Use / Indications for Use
Fresenius Multiorgan Perfusion CannulaFreseniusK902394Intended Use / Indications for Use; Technology; Design

Technological Characteristics and Comparison:

The Cannula for Organ Perfusion is substantially equivalent to the cannula accessory of the LifePort Kidney Perfusion Transporter-specifically, the perfusion cannula component of the LifePort Kidney Perfusion Transporter-in terms of intended use, indications for use, FDA classification and FDA Product Code. Like the subject device, the cannula accessory of the LifePort Kidney Perfusion Transporter is used for flushing and replacement of residual blood in donor organs with organ preservation solution during the preparation processes of these organs for transplantation.

In addition, a comparison of the subject device to the Fresenius Multiorgan Perfusion Cannula demonstrates the safety and efficacy of the Cannula for Organ Perfusion in terms of substantially equivalent design, technology, use and suitability.

6

FeatureSubject DevicePredicate / Reference Devices
Intended Use / IndicationsCannula for Organ Perfusion
is a single-use device
indicated for hypothermic
flushing and replacement of
residual blood in donor organs
with a legally marketed organ
preservation solution at the
time of organ removal from
the donor during the
preparation of these organs for
transplantation. This device is
indicated for use with gravity
flow; no testing has been
provided for use with pump
systems, such as mechanical
perfusion devices.LifePort Kidney Perfusion
Transporter (K021362):
System component cannula for organ
perfusion, intended to be used in an
organ transplantation procedure.
Fresenius Multiorgan Perfusion
Cannula (K902394):
"For placement in the [organ] of a
heart beating cadaver to allow in situ
flushing of the cadaver organs with
organ preservation solution."
Single Use / DisposableSingle Use / DisposableFresenius Multiorgan Perfusion
Cannula (K902394):
Single Use / Disposable
Device DesignThe Cannula for Organ Perfusion
has a tapered connector at
proximal end of the cannula, and
an atraumatic distal end; cone
shaped.Fresenius Multiorgan Perfusion
Cannula (K902394):
Perfusion cannula has a proximal end
which consists of a funnel-shaped
connector (i.e., a cone shape)
Perfusion cannula has a distal end
which consists of an atraumatic tip
and cone-shaped cuff.
SterilizationEthylene Oxide
SAL 1 x 10-6Fresenius Multiorgan Perfusion
Cannula (K902394):
Ethylene Oxide
SAL 1 x 10-6
Regulation21 CFR 876.5880LifePort Kidney Perfusion
Transporter (K021362):
21 CFR 876.5880
FDA Product CodeKDN; MSBLifePort Kidney Perfusion
Transporter (K021362): KDN
FDA ClassificationIILifePort Kidney Perfusion
Transporter (K021362): II
Fresenius Multiorgan Perfusion
Cannula (K902394): II

7

Clinical Testing:

No clinical tests were conducted in support of this 510(k) submission.

Non-Clinical Tests Performed:

Bench testing demonstrates that the Cannula for Organ Perfusion is safe, effective and meets device specifications:

  • Testing related to tensile strength vielded Pass results in accordance with ISO 10555-1. -
  • Testing related to leakage and tightness yielded Pass results in accordance with ISO -10555-1.
  • Testing related to flow rate demonstrated adequate flow of liquid in accordance with ISO -10555-1.

Sterilization & Shelf Life:

Product is sterilized using ETO, with a Sterility Assurance Level (SAL) of 10-6.

The shelf life of the product has been established in accordance with real time aging testing results.

Biocompatibility:

All component materials of this medical device carry adequate quality certificates confirming their biological, physical-chemical and mechanical properties, and they are all intended for ETO sterilization.

In particular, the materials used in the manufacturing of the cannula comply with requirements of EN ISO 10993-1.

8

In accordance with ISO 10993-1, the Cannula for Organ Perfusion is classified as:

  • surgical invasive medical device
  • having external contact with the body through the circulating blood,
  • remaining in contact with the body for up to 24 hours.

The following biological tests were selected for the Cannula for Organ Perfusion:

  • cytotoxicity
  • sensitizing effect
  • intracutaneous reactivity
  • systemic (acute) toxicity
  • blood compatibility
  • rabbit pyrogenicity

In accordance with ISO 10993-1:2009, all tests were performed using the final product after the sterilization process of the product, using a validated sterilization process.

Additionally, the manufacturer has conducted a separate biological evaluation of the subject medical device. This study included the defined requirements, product classification, description of the adopted test selection criteria, specifications and approvals of materials used to manufacture the evaluated product, a list and summary of biological tests collected or performed and analysis of the data obtained from the evaluation.

Conclusion:

The applicant device is substantially equivalent in its intended use, technology / principal of operation, materials, and performance to the predicate and reference devices identified in this 510(k) submission. There is no significant difference that raises any issues of safety or effectiveness.