K Number
K211654
Device Name
Penumbra System (Reperfusion Catheter RED 72)
Manufacturer
Date Cleared
2021-08-16

(80 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Penumbra Reperfusion Catheters and Separators As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA therapy are candidates for treatment. Penumbra 3D Revascularization Device As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment. Penumbra Aspiration Tubing As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Aspiration Pump. Penumbra Aspiration Pump The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
Device Description
The Penumbra System® is comprised of the following devices: - Penumbra Reperfusion Catheter - Penumbra Aspiration Pump - Penumbra Aspiration Pump/Canister Tubing - Penumbra Aspiration Tubing - Penumbra Separator - Penumbra 3D Revascularization Device The Penumbra System is designed to remove thrombus from the vasculature using continuous aspiration. The Reperfusion Catheter targets aspiration from the pump directly to the thrombus. The 3D Revascularization Device is used with Reperfusion Catheters to facilitate aspiration and removal of the thrombus when needed. The Separator may be used to clear the lumen of the Reperfusion Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using a Reperfusion Catheter with an ID of 0.054 in. or larger. The Reperfusion Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire to the site of the primary occlusion. The Penumbra Reperfusion Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, a Penumbra Separator may be deployed from the Reperfusion Catheter to assist with thrombus removal. The Penumbra Separator is advanced and retracted through the Penumbra Reperfusion Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Reperfusion Catheter tip. For the aspiration source, the Penumbra Reperfusion Catheter is used in conjunction with the Aspiration Pump, which is connected using the Penumbra Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Penumbra Reperfusion Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Penumbra 3D Revascularization Device is provided with an introducer sheath. The Penumbra Separator is provided with an introducer and torque device. The Penumbra Reperfusion Catheters, 3D Revascularization Device and Separators are visible under fluoroscopy.
More Information

No
The device description focuses on mechanical components and aspiration technology, with no mention of AI or ML. The "Mentions AI, DNN, or ML" field is explicitly marked as "Not Found".

Yes
The device is used for "revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease," which is a therapeutic intervention aimed at treating a medical condition.

No

The device is designed for the revascularization (treatment) of acute ischemic stroke by removing thrombus, not for diagnosing the condition.

No

The device description clearly lists multiple hardware components including catheters, pumps, tubing, and separators, and describes their physical interaction and function in removing thrombus.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for diagnostic or monitoring purposes.
  • Device Description and Intended Use: The Penumbra System is designed for the mechanical removal of blood clots (thrombus) from blood vessels within the brain. It is a therapeutic device used in a surgical procedure (revascularization) to restore blood flow.
  • Lack of Specimen Analysis: The device does not involve the analysis of any biological specimens taken from the patient. It directly interacts with the thrombus within the blood vessel.

Therefore, the Penumbra System falls under the category of a therapeutic medical device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

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

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

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

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

Product codes

NRY

Device Description

The Penumbra System® is comprised of the following devices:

  • Penumbra Reperfusion Catheter ●
  • . Penumbra Aspiration Pump
  • Penumbra Aspiration Pump/Canister Tubing ●
  • Penumbra Aspiration Tubing ●
  • . Penumbra Separator
  • . Penumbra 3D Revascularization Device

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

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Fluoroscopy

Anatomical Site

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

Indicated Patient Age Range

Not Found

Intended User / Care Setting

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)

Design Verification Testing:

  • Test: Dimensional/Visual Test, Test Method Summary: Confirms the units meet all dimensional and visual product specifications., Conclusion: Acceptance Criteria Met
  • Test: Friction Test, Test Method Summary: Confirms units meet product specification related to friction., Conclusion: Acceptance Criteria Met
  • Test: Fluoroscopy Test, Test Method Summary: Confirms the markerband is fluoroscopically visible., Conclusion: Acceptance Criteria Met
  • Test: Simulated Use Test, Test Method Summary: Confirms the functionality of units using clinically relevant benchtop model., Conclusion: Acceptance Criteria Met
  • Test: Particulate Test, Test Method Summary: Particulates generated during simulated use (including multiple deployment cycling) were evaluated., Conclusion: Acceptance Criteria Met
  • Test: Hub/Air Test, Test Method Summary: Confirms units have no leaks when tested., Conclusion: Acceptance Criteria Met
  • Test: Tensile Test, Test Method Summary: Confirms units meet product specification related to tensile strength., Conclusion: Acceptance Criteria Met
  • Test: Pressure Test, Test Method Summary: Confirms units meet product specification related to pressure., Conclusion: Acceptance Criteria Met
  • Test: Elongation Test, Test Method Summary: Confirms units meet product specification related to elongation., Conclusion: Acceptance Criteria Met
  • Test: Corrosion Resistance Test, Test Method Summary: Confirms there is no visible corrosion on the units when tested., Conclusion: Acceptance Criteria Met
  • Test: Torque Strength Test, Test Method Summary: Confirms units have sufficient torque strength., Conclusion: Acceptance Criteria Met
  • Test: Burst Pressure Test, Test Method Summary: Confirms units can withstand sufficient pressure., Conclusion: Acceptance Criteria Met

Shelf-Life:

  • Test: Shelf-Life, Test Method Summary: Confirms expiration date based on accelerated aging test studies., Conclusion: Acceptance Criteria Met

Sterilization:

  • Test: Sterilization Test, Test Method Summary: Confirms the units are sterilized in accordance with ISO 11135 and ISO 10993-7., Conclusion: Acceptance Criteria Met

Biocompatibility:

  • Test: Cytotoxicity: MEM Elution (ISO 10993-5), Conclusion: Pass, Non-cytotoxic
  • Test: Sensitization: Magnusson-Kligman Method (ISO 10993-10), Conclusion: Pass, Non-sensitizing
  • Test: Irritation: Intracutaneous Reactivity (ISO 10993-10), Conclusion: Pass, Non-irritating
  • Test: Systemic Toxicity: Acute Systemic Injection (ISO 10993-11), Conclusion: Pass, Non-toxic
  • Test: Systemic Toxicity: Material Mediated Pyrogen (ISO 10993-11), Conclusion: Pass, Non-pyrogenic
  • Test: Hemocompatibility: Thrombogenicity (ISO 10993-4), Conclusion: Pass, Non-thrombogenic
  • Test: Hemocompatibility: Partial Thromboplastin Time (PTT) (ISO 10993-4), Conclusion: Pass, Hemocompatible
  • Test: Hemocompatibility: Complement Activation (ISO 10993-4), Conclusion: Pass, Hemocompatible
  • Test: Hemocompatibility: Hemolysis, indirect contact (ISO 10993-4), Conclusion: Pass, Non-hemolytic
  • Test: Hemocompatibility: Hemolysis, direct contact (ISO 10993-4), Conclusion: Pass, Non-hemolytic

No animal or clinical study was conducted as bench testing was determined sufficient for verification and validation purposes.

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

Not Found

Predicate Device(s)

K173761

Reference Device(s)

K190010

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1250 Percutaneous catheter.

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

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August 16, 2021

Penumbra, Inc. Nikita Patel Regulatory Specialist I One Penumbra Place Alameda, California 94502

Re: K211654

Trade/Device Name: Penumbra System (Reperfusion Catheter RED 72) Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: May 27, 2021 Received: May 28, 2021

Dear Nikita Patel:

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,

Naira Muradyan, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K211654

Device Name

Penumbra System® (Reperfusion Catheter RED™ 72)

Indications for Use (Describe)

Penumbra Reperfusion Catheters and Separators

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

Penumbra 3D Revascularization Device

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

Penumbra Aspiration Tubing

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

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

Type of Use (Select one or both, as applicable)

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 the word "Penumbra" in red font. To the right of the word is a red circle with a white "P" inside. A white line extends from the right side of the word "Penumbra" to the left side of the "P" in the circle.

K211654

510(k) Summary

(as required by 21 CFR 807.92)

Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Penumbra, Inc. is providing the summary of Substantial Equivalence for the subject Penumbra System® (Reperfusion Catheter RED™ 72).

1.1 Submitter

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

Contact Person: Nikita Patel Regulatory Specialist Tel: (408) 823-1820 Fax: (510) 217-6414 E-mail: npatel(@penumbrainc.com

Date of Preparation:

August 12, 2021

1.2 Subject Device

Penumbra System® (Reperfusion Catheter RED™ 72)

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

Predicate Device & Reference Devices 1.3

510(k) NumberName of DeviceName of Manufacturer
Predicate Device
K173761Penumbra System (Reperfusion Catheter JET 7)Penumbra, Inc.
Reference Device
K190010Penumbra System® (Reperfusion Catheter JET™ 7)Penumbra, Inc.

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Image /page/4/Picture/0 description: The image shows the Penumbra company logo. The word "Penumbra" is written in red font. To the right of the word is a red circle with a white "P" inside. The logo is simple and modern.

Device Description 1.4

The Penumbra System® is comprised of the following devices:

  • Penumbra Reperfusion Catheter ●
  • . Penumbra Aspiration Pump
  • Penumbra Aspiration Pump/Canister Tubing ●
  • Penumbra Aspiration Tubing ●
  • . Penumbra Separator
  • . Penumbra 3D Revascularization Device

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

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Image /page/5/Picture/0 description: The image shows the logo for Penumbra, Inc., a global healthcare company focused on innovative therapies. The logo features the word "Penumbra" in a bold, red font. To the right of the name is a stylized "P" inside a red circle, with a thin white line connecting the "a" in Penumbra to the "P" symbol.

Indications For Use 1.5

Penumbra Reperfusion Catheters and Separators

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

Penumbra 3D Revascularization Device

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

Penumbra Aspiration Tubing

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

Penumbra Aspiration Pump

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

Device AttributePredicate DeviceSubject Device
Trade NamePenumbra System (Reperfusion
Catheter JET 7)Penumbra System (Reperfusion
Catheter RED 72)
FDA Product
ClassificationClass II, NRY, 21 CFR 870.1250SAME
510(k) NumberK173761K211654
Indications for UsePenumbra Reperfusion Catheters and
Separators
As part of the Penumbra System, the
Reperfusion Catheters and Separators
are indicated for use in the
revascularization of patients withSAME
Device AttributePredicate DeviceSubject Device
acute ischemic stroke secondary to
intracranial large vessel occlusive
disease (within the internal carotid,
middle cerebral – M1 and M2
segments, basilar, and vertebral
arteries) within 8 hours of symptom
onset. Patients who are ineligible for
intravenous tissue plasminogen
activator (IV t-PA) or who fail IV t-
PA therapy are candidates for
treatment.
Penumbra 3D Revascularization
Device
As part of the Penumbra System, the
Penumbra 3D Revascularization
Device is indicated for use in the
revascularization of patients with
acute ischemic stroke secondary to
intracranial large vessel occlusive
disease (within the internal carotid,
middle cerebral – M1 and M2
segments) within 8 hours of symptom
onset. Patients who are ineligible for
intravenous tissue plasminogen
activator (IV t-PA) or who fail IV t-
PA therapy are candidates for
treatment.
Penumbra Aspiration Tubing
As part of the Penumbra System, the
Penumbra Sterile Aspiration Tubing
is indicated to connect the Penumbra
Reperfusion Catheters to the
Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is
indicated as a vacuum source for
Penumbra Aspiration Systems.
Principles of
OperationSee Section 1.4SAME
Stainless Steel, PTFE, Polyurethane,
Device MaterialsPolyether Block Amide, Nylon 12,
Nitinol, Platinum/IridiumSAME
ID Band ColorPolyolefin, PET black [white foil]SAME
CoatingHydrophilic coating (proprietary)Equivalent
Device AttributePredicate DeviceSubject Device
Min. ID0.072 in. (1.83 mm)SAME
Max. OD0.085 in. (2.16 mm)SAME
Distal Flex Length30 cmSAME
Coating Length30 cmSAME
Effective Lengths115, 120, 125, 127, 132 cmSAME
AccessoriesPeelable Sheath, Shaping Mandrel,
RHVSAME
Packaging
MaterialsPolyester/Polyethylene/Tyvek,
Polystyrene, SBS PaperboardSAME
Condition SuppliedSterile and Single UseSAME
Sterilization
MethodEOSAME

Comparison of Technological Characteristics with the Predicate Device 1.6

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1.7 Performance Data

The following performance data were provided in support of the substantial equivalence determination:

  • Design Verification ●
  • Biocompatibility .
  • Shelf-Life ●
  • . Sterilization – LAL Validation

The subject device met all established requirements.

Design Verification Testing 1.7.1

The following design verification tests were performed on the subject device:

TestTest Method SummaryConclusion
Dimensional/Visual TestConfirms the units meet all dimensional and visual product specifications.Acceptance Criteria Met
Friction TestConfirms units meet product specification related to friction.Acceptance Criteria Met
Fluoroscopy TestConfirms the markerband is fluoroscopically visible.Acceptance Criteria Met
Simulated Use TestConfirms the functionality of units using clinically relevant benchtop model.Acceptance Criteria Met
Particulate TestParticulates generated during simulated use (including multiple deployment cycling) were evaluated.Acceptance Criteria Met
Hub/Air TestConfirms units have no leaks when tested.Acceptance Criteria Met
Tensile TestConfirms units meet product specification related to tensile strength.Acceptance Criteria Met
Pressure TestConfirms units meet product specification related to pressure.Acceptance Criteria Met
Elongation TestConfirms units meet product specification related to elongation.Acceptance Criteria Met

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TestTest Method SummaryConclusion
Corrosion Resistance TestConfirms there is no visible corrosion on the units when tested.Acceptance Criteria Met
Torque Strength TestConfirms units have sufficient torque strength.Acceptance Criteria Met
Burst Pressure TestConfirms units can withstand sufficient pressure.Acceptance Criteria Met
Shelf-LifeConfirms expiration date based on accelerated aging test studies.Acceptance Criteria Met
Sterilization TestConfirms the units are sterilized in accordance with ISO 11135 and ISO 10993-7.Acceptance Criteria Met

1.7.2 Biocompatibility

Biocompatibility of the subject device is supported by the biocompatibility testing of the predicate and reference devices. Compared with the predicate device (K173761), all materials are the same, aside from the hydrophilic coating, which is identical to the reference device (K190010). Therefore, the previous biocompatibility testing on the predicate and reference devices applies to the subject device and additional testing is not required. The studies were selected in accordance with ISO 10993-1 guidelines (Biological Evaluation of Medical Devices) for a limited exposure ( 10% in 3 or more animals. | Pass
Non-toxic |
| Systemic Toxicity: Material
Mediated Pyrogen
(ISO 10993-11) | Sample extracts must not cause a total rise in
body temperature of ≥ 0.5°C. | Pass
Non-pyrogenic |
| Hemocompatibility:
Thrombogenicity
(ISO 10993-4) | The test article must have similar or less
thrombus formation than predicate. | Pass
Non-thrombogenic |
| Hemocompatibility: Partial
Thromboplastin Time (PTT)
(ISO 10993-4) | Clotting times of test article must be similar to
predicate values. | Pass
Hemocompatible |

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TestsAcceptance CriteriaConclusion
Hemocompatibility:
Complement Activation
(ISO 10993-4)The concentration of SC5b-9 of test article must
be similar to predicate values.Pass
Hemocompatible
Hemocompatibility:
Hemolysis, indirect contact
(ISO 10993-4)Sample extracts must be non-hemolytic (≤ 2%
hemolytic index).Pass
Non-hemolytic
Hemocompatibility:
Hemolysis, direct contact
(ISO 10993-4)Sample must be non-hemolytic (≤ 2% hemolytic
index).Pass
Non-hemolytic

Biocompatibility test results demonstrate biological safety per ISO 10993 and USP requirements.

1.7.3 Performance Data - Animal, Clinical

No animal or clinical study was conducted as bench testing was determined sufficient for verification and validation purposes.

Conclusions 1.8

The subject Penumbra System® (Reperfusion Catheter RED™ 72) is substantially equivalent to the predicate device Penumbra System (Reperfusion Catheter JET 7). The subject device has identical intended use as the predicate device. The device testing described in the 510(k) Summary demonstrates the subject device is substantially equivalent to the predicate device in regard to intended use, operating principle, design concept, fundamental technology and device performance.