(80 days)
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.
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.
This document describes the acceptance criteria and study proving the performance of the Penumbra System® (Reperfusion Catheter RED™ 72). It is a 510(k) summary, indicating that the device is being cleared based on substantial equivalence to a legally marketed predicate device, rather than requiring a full premarket approval (PMA) with extensive clinical trials.
It's important to note that because this is a 510(k) submission based on substantial equivalence to an existing device (the Penumbra System (Reperfusion Catheter JET 7)), the studies primarily focus on engineering and biocompatibility performance data against established requirements, rather than clinical efficacy studies often seen with novel AI devices. There are no AI/ML components described in this document, thus the requested information regarding MRMC studies, standalone AI performance, human expert ground truth for imaging, and training/test set sample sizes for AI models are not applicable.
Here's the breakdown of the acceptance criteria and study details provided:
1. Table of Acceptance Criteria and Reported Device Performance
The document provides a series of design verification tests and biocompatibility tests. The acceptance criteria for each test are stated, and the conclusion is consistently that the "Acceptance Criteria Met" or "Pass."
Design Verification Testing:
| Test | Test Method Summary | Acceptance Criteria Met (Reported Performance) |
|---|---|---|
| Dimensional/Visual Test | Confirms the units meet all dimensional and visual product specifications. | Yes |
| Friction Test | Confirms units meet product specification related to friction. | Yes |
| Fluoroscopy Test | Confirms the markerband is fluoroscopically visible. | Yes |
| Simulated Use Test | Confirms the functionality of units using clinically relevant benchtop model. | Yes |
| Particulate Test | Particulates generated during simulated use (including multiple deployment cycling) were evaluated. | Yes |
| Hub/Air Test | Confirms units have no leaks when tested. | Yes |
| Tensile Test | Confirms units meet product specification related to tensile strength. | Yes |
| Pressure Test | Confirms units meet product specification related to pressure. | Yes |
| Elongation Test | Confirms units meet product specification related to elongation. | Yes |
| Corrosion Resistance Test | Confirms there is no visible corrosion on the units when tested. | Yes |
| Torque Strength Test | Confirms units have sufficient torque strength. | Yes |
| Burst Pressure Test | Confirms units can withstand sufficient pressure. | Yes |
| Shelf-Life | Confirms expiration date based on accelerated aging test studies. | Yes |
| Sterilization Test | Confirms the units are sterilized in accordance with ISO 11135 and ISO 10993-7. | Yes |
Biocompatibility Testing (Based on predicate/reference devices):
| Tests | Acceptance Criteria | Pass/Conclusion (Reported Performance) |
|---|---|---|
| Cytotoxicity: MEM Elution (ISO 10993-5) | Sample extracts must have a cytotoxic reactivity score of grade 2 or lower. | Pass (Non-cytotoxic) |
| Sensitization: Magnusson-Kligman Method (ISO 10993-10) | Test Group shall yield Grade < 1 score on Magnusson and Kligman scale (provided Control Group yields Grade < 1). | Pass (Non-sensitizing) |
| Irritation: Intracutaneous Reactivity (ISO 10993-10) | The difference between the average scores for the extract of the test article and the control is ≤ 1.0. | Pass (Non-irritating) |
| Systemic Toxicity: Acute Systemic Injection (ISO 10993-11) | Sample extracts must not cause significant biological reaction greater than control. That is: • Death in 2 or more animals. • Signs of toxicity in 2 or more animals (i.e. convulsions, prostration). • Weight loss > 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) |
| 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) |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the exact sample sizes (number of units) used for each design verification bench test, as is typical for 510(k) summaries of mechanical devices. However, it indicates that units were tested. The data provenance would be from internal testing conducted by Penumbra, Inc. (the manufacturer). This is a retrospective evaluation of the device's physical and functional properties. There is no indication of country of origin for specific test data beyond the manufacturer being in Alameda, California, USA.
3. Number of Experts Used to Establish Ground Truth and Qualifications
Not applicable. This submission is for a mechanical medical device (catheter system), not an AI/ML device that requires human expert annotation for ground truth in image analysis. The "ground truth" for this device's performance is established by objective physical and chemical testing against engineering specifications and international standards (e.g., ISO, USP).
4. Adjudication Method for the Test Set
Not applicable. As there are no human expert readings or interpretations involved in the performance data presented (it's benchmark and material testing), there is no need for an adjudication method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No. An MRMC study is for evaluating the impact of AI on human reader performance, typically in diagnostic imaging. This device is a mechanical catheter system for stroke intervention, not an AI/ML diagnostic tool. Therefore, no such study was performed or required.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
No. This refers to the standalone performance of an AI algorithm. Since this is a mechanical device, this concept is not applicable. The standalone "performance" refers to the device meeting its physical and functional specifications during bench testing.
7. The Type of Ground Truth Used
The "ground truth" used for this device's performance evaluation comes from engineering specifications, international standards (e.g., ISO 10993 series), and validated test methods. This includes:
- Pre-defined dimensional and visual product specifications.
- Measured physical properties (friction, tensile strength, pressure, elongation, torque, burst pressure).
- Chemical and biological properties (cytotoxicity, sensitization, irritation, systemic toxicity, hemocompatibility) determined through laboratory assays adhering to GLP (Good Laboratory Practices) and ISO standards.
- Functionality in simulated clinical use benchtop models.
8. The Sample Size for the Training Set
Not applicable. This refers to a training set for an AI model. This device is a mechanical medical device, not an AI/ML product.
9. How the Ground Truth for the Training Set was Established
Not applicable. As there is no AI training set, there is no ground truth establishment for it. The "ground truth" for the device's design and manufacturing is based on established engineering principles, materials science, and medical device regulations.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" underneath in a smaller font.
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
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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,
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
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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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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) Number | Name of Device | Name of Manufacturer |
|---|---|---|
| Predicate Device | ||
| K173761 | Penumbra System (Reperfusion Catheter JET 7) | Penumbra, Inc. |
| Reference Device | ||
| K190010 | Penumbra System® (Reperfusion Catheter JET™ 7) | Penumbra, Inc. |
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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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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 Attribute | Predicate Device | Subject Device |
|---|---|---|
| Trade Name | Penumbra System (ReperfusionCatheter JET 7) | Penumbra System (ReperfusionCatheter RED 72) |
| FDA ProductClassification | Class II, NRY, 21 CFR 870.1250 | SAME |
| 510(k) Number | K173761 | K211654 |
| Indications for Use | Penumbra Reperfusion Catheters andSeparatorsAs part of the Penumbra System, theReperfusion Catheters and Separatorsare indicated for use in therevascularization of patients with | SAME |
| Device Attribute | Predicate Device | Subject 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 RevascularizationDevice | ||
| 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 ofOperation | See Section 1.4 | SAME |
| Stainless Steel, PTFE, Polyurethane, | ||
| Device Materials | Polyether Block Amide, Nylon 12,Nitinol, Platinum/Iridium | SAME |
| ID Band Color | Polyolefin, PET black [white foil] | SAME |
| Coating | Hydrophilic coating (proprietary) | Equivalent |
| Device Attribute | Predicate Device | Subject Device |
| Min. ID | 0.072 in. (1.83 mm) | SAME |
| Max. OD | 0.085 in. (2.16 mm) | SAME |
| Distal Flex Length | 30 cm | SAME |
| Coating Length | 30 cm | SAME |
| Effective Lengths | 115, 120, 125, 127, 132 cm | SAME |
| Accessories | Peelable Sheath, Shaping Mandrel,RHV | SAME |
| PackagingMaterials | Polyester/Polyethylene/Tyvek,Polystyrene, SBS Paperboard | SAME |
| Condition Supplied | Sterile and Single Use | SAME |
| SterilizationMethod | EO | SAME |
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:
| Test | Test Method Summary | Conclusion |
|---|---|---|
| Dimensional/Visual Test | Confirms the units meet all dimensional and visual product specifications. | Acceptance Criteria Met |
| Friction Test | Confirms units meet product specification related to friction. | Acceptance Criteria Met |
| Fluoroscopy Test | Confirms the markerband is fluoroscopically visible. | Acceptance Criteria Met |
| Simulated Use Test | Confirms the functionality of units using clinically relevant benchtop model. | Acceptance Criteria Met |
| Particulate Test | Particulates generated during simulated use (including multiple deployment cycling) were evaluated. | Acceptance Criteria Met |
| Hub/Air Test | Confirms units have no leaks when tested. | Acceptance Criteria Met |
| Tensile Test | Confirms units meet product specification related to tensile strength. | Acceptance Criteria Met |
| Pressure Test | Confirms units meet product specification related to pressure. | Acceptance Criteria Met |
| Elongation Test | Confirms units meet product specification related to elongation. | Acceptance Criteria Met |
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| Test | Test Method Summary | Conclusion |
|---|---|---|
| Corrosion Resistance Test | Confirms there is no visible corrosion on the units when tested. | Acceptance Criteria Met |
| Torque Strength Test | Confirms units have sufficient torque strength. | Acceptance Criteria Met |
| Burst Pressure Test | Confirms units can withstand sufficient pressure. | Acceptance Criteria Met |
| Shelf-Life | Confirms expiration date based on accelerated aging test studies. | Acceptance Criteria Met |
| Sterilization Test | Confirms 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 (< 24 hours), externally communicating device with circulating blood contact. All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices (GLP).
| Tests | Acceptance Criteria | Conclusion |
|---|---|---|
| Cytotoxicity:MEM Elution(ISO 10993-5) | Sample extracts must have a cytotoxic reactivityscore of grade 2 or lower. | PassNon-cytotoxic |
| Sensitization:Magnusson-Kligman Method(ISO 10993-10) | Test Group shall yield Grade < 1 score onMagnusson and Kligman scale (providedControl Group yields Grade < 1). | PassNon-sensitizing |
| Irritation:Intracutaneous Reactivity(ISO 10993-10) | The difference between the average scores forthe extract of the test article and the control is≤ 1.0. | PassNon-irritating |
| Systemic Toxicity:Acute Systemic Injection(ISO 10993-11) | Sample extracts must not cause significantbiological reaction greater than control. That is:• Death in 2 or more animals.• Signs of toxicity in 2 or more animals (i.e.convulsions, prostration).• Weight loss > 10% in 3 or more animals. | PassNon-toxic |
| Systemic Toxicity: MaterialMediated Pyrogen(ISO 10993-11) | Sample extracts must not cause a total rise inbody temperature of ≥ 0.5°C. | PassNon-pyrogenic |
| Hemocompatibility:Thrombogenicity(ISO 10993-4) | The test article must have similar or lessthrombus formation than predicate. | PassNon-thrombogenic |
| Hemocompatibility: PartialThromboplastin Time (PTT)(ISO 10993-4) | Clotting times of test article must be similar topredicate values. | PassHemocompatible |
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Image /page/9/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, followed by a stylized "P" symbol enclosed in a red circle. The "P" symbol is created with a white outline and a horizontal line extending from the "P" to the word "Penumbra."
| Tests | Acceptance Criteria | Conclusion |
|---|---|---|
| Hemocompatibility:Complement Activation(ISO 10993-4) | The concentration of SC5b-9 of test article mustbe similar to predicate values. | PassHemocompatible |
| Hemocompatibility:Hemolysis, indirect contact(ISO 10993-4) | Sample extracts must be non-hemolytic (≤ 2%hemolytic index). | PassNon-hemolytic |
| Hemocompatibility:Hemolysis, direct contact(ISO 10993-4) | Sample must be non-hemolytic (≤ 2% hemolyticindex). | PassNon-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.
§ 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).