K Number
K211990
Date Cleared
2021-07-27

(29 days)

Product Code
Regulation Number
870.1250
Panel
NE
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Rist™ 071 Radial Access Guide Catheter is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

Device Description

The Rist™ 071 Radial Access Guide Catheter is a single lumen, variable stiffness catheter with a stainless steel and nitinol reinforced shaft to provide support. The embedded stainless-steel flat wire cross coil is in the proximal section of the catheter, which transitions to a nitinol round wire single coil in the distal end. The catheter has a radiopaque platinum/iridium marker band on the distal end to aid in visualization. The distal 25 cm of the Rist™ 071 Radial Access Guide Catheter has a hydrophilic coating which reduces the insertion force and allows the catheter to traverse the vasculature more easily. The catheter has a nominal outer diameter of 0.084 inches and a nominal inner diameter of 0.071 inches. It is available in three working lengths: 95 cm, 100 cm, and 105 cm. The Rist™ 071 Radial Access Guide Catheter has a PTFE-lined lumen to reduce friction with other devices introduced through the lumen. It is intended to provide access to the target site via transradial access and, once in place, provides a reinforcing conduit for other intravascular devices. A radial access dilator is included as an accessory. The Rist™ 071 Radial Access Guide Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

AI/ML Overview

The Rist™ 071 Radial Access Guide Catheter is a medical device intended for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature. The acceptance criteria and supporting studies are detailed below.

1. Table of Acceptance Criteria and Reported Device Performance

The device underwent extensive testing, and the results consistently indicated that "All units met the acceptance criteria" or similar statements. Specific numerical acceptance criteria were not explicitly provided in the document for most tests, but the qualitative statement of meeting criteria is present.

Test PerformedAcceptance Criteria (Explicit or Qualitative)Reported Device Performance
Biocompatibility
CytotoxicityNon-cytotoxicity, no abnormal events (pH change, debris)The test article is considered non-cytotoxic... No abnormal events such as pH change or debris were noted.
SensitizationNo sensitization responseThe test article did not elicit a sensitization response.
IrritationNo significant dermal reactionsNo significant dermal reactions were observed.
Acute Systemic ToxicityNo abnormal clinical signs indicative of toxicityNone of the study subjects were observed with abnormal clinical signs indicative of toxicity.
PyrogenicityNo pyrogenic response; all validity criteria metThe test article extracts did not cause a pyrogenic response and all validity criteria were met.
Hemocompatibility (Complement Activation)Not statistically significant (p>0.05) to reference material/comparison articleThe test article results... were not statistically significant (p>0.05).
Hemocompatibility (Hemolysis)Blank corrected percent hemolysis above negative control of 0.0%The test article returned a blank corrected percent hemolysis above the negative control of 0.0%.
Hemocompatibility (Platelet & Leukocyte Count)Platelet count within specificationThe platelet count was within specification.
Hemocompatibility (Partial Thromboplastin Time)No more material mediated coagulation abnormalities than predicate in intrinsic pathwayThe test article did not create any more material mediated coagulation abnormalities... when compared to the predicate.
Sterilization ValidationProduct sterility per ANSI/AAMI/ISO 11135:2014 and AAMI TIR 28:2016Product was sterile.
PackagingSterile barrier not compromisedAll units met all the packaging acceptance criteria.
Catheter and Dilator Tensile StrengthMet tensile strength acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the tensile strength acceptance criteria.
Catheter PTFE DelaminationMet PTFE delamination acceptance criteriaAll units met the catheter PTFE delamination acceptance criteria.
TorqueMet torque acceptance criteriaAll units met the torque acceptance criteria.
Catheter Burst PressureMet burst pressure acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the catheter burst pressure acceptance criteria.
Particulate TestingMet particulate acceptance criteria per USPAll units met the particulate testing acceptance criteria.
Coating IntegrityMet coating integrity acceptance criteria (no surface irregularities after conditioning and tortuous path)All units met the coating integrity acceptance criteria.
Leak (Liquid)No leakage per ISO 10555-1:2013/Amd. 1:2017(E)All units met the liquid leak test acceptance criteria.
Leak (Air)No air leaks per ISO 10555-1:2013/Amd. 1:2017(E)All units met the air leak test acceptance criteria.
Catheter Dimensional InspectionID, OD, and working length met acceptance criteriaAll units met the catheter dimensional inspection acceptance criteria.
Dilator Dimensional InspectionID and OD met acceptance criteriaAll units met the dilator dimensional inspection acceptance criteria.
Chemical CompatibilityNo signs of degradation, no obstruction of ID after exposure to saline, dextrose, heparin, radiocontrastAll units met the chemical compatibility acceptance criteria.
Visual Inspection of Catheter and DilatorSmooth tip transition points, no surface defectsAll units met the visual inspection acceptance criteria.
Catheter Coating LengthLength of hydrophilic coating met specificationAll units met the catheter coating length acceptance criteria.
Kink ResistanceMet kink resistance acceptance criteriaAll units met the kink resistance acceptance criteria.
In vitro Simulated Use StudyProduct performance verified by physiciansAll acceptance criteria were met.
Corrosion (from predicate)Met corrosion acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the corrosion acceptance criteria.
Hub Compatibility (from predicate)Met hub compatibility acceptance criteria per ISO 594-1:1986 and ISO 594-2:1998All units met the hub compatibility acceptance criteria.
Radiopacity (from predicate)Physicians identified distal tip location, catheter shape, and curve locations on fluoroscopic imagesAll acceptance criteria were met.
Label Content (from predicate)Information included is accurateAll units met the acceptance criteria for label content.
Label Legibility (from predicate)Labeling remained legible after transportation and conditioningAll units met the acceptance criteria for label legibility.
Barcode (from predicate)Scanned barcode matched appropriate informationAll units met the acceptance criteria for barcode.
Dilator Working Length (from predicate)Dilator length met specificationAll units met the acceptance criteria for dilator working length.
Useability (from predicate)Evaluators confirmed usability as per Instructions for UseAll acceptance criteria were met.
Shelf-Life TestingProduct and packaging met all acceptance criteria for 6-month shelf lifeAll acceptance criteria were met.

2. Sample Size for the Test Set and Data Provenance

The document does not explicitly state the sample sizes used for each specific test in the "Test Set." However, it repeatedly mentions "All units" or "All units met" indicating that a sufficient number of samples were tested to achieve statistical significance or to demonstrate compliance.

The data provenance is not specified in terms of country of origin. The studies are described as "Design verification and validation" (in-house testing) and based on applicable ISO/ASTM/USP standards, suggesting a laboratory-based, prospective testing approach. No mention of retrospective or prospective clinical data for the test set is present, as this is a pre-market submission focused on device performance rather than clinical outcomes.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

For the "In vitro Simulated Use Study," it states that "A simulated interventional procedure was performed by physicians." The exact number of physicians or their specific qualifications (e.g., "radiologist with 10 years of experience") are not provided.

For the "Radiopacity" test (from the predicate device), "Physicians were shown fluoroscopic images." Again, the specific number and qualifications of these physicians are not detailed.

4. Adjudication Method for the Test Set

The document does not describe any formal adjudication method (e.g., 2+1, 3+1) for the tests. The results indicate a direct pass/fail or "met acceptance criteria" outcome, implying consensus on the directly measurable or observable results rather than a subjective assessment requiring adjudication. For physician-evaluated tests, the document indicates a general 'acceptance criteria met' without detailing disagreement resolution.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No MRMC comparative effectiveness study was mentioned. The studies focused on device performance characteristics rather than comparing human reader performance with or without AI assistance. The device itself is a physical catheter, not an AI-powered diagnostic tool.

6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

No standalone algorithm performance study was done. This is consistent with the nature of the device as a physical medical instrument, not a software algorithm.

7. Type of Ground Truth Used

The ground truth for most performance tests was established by adherence to recognized international standards (ISO, ASTM, USP) and predefined internal specifications for various physical, chemical, and biological properties. This includes:

  • Physical Measurements: Dimensional accuracy (ID, OD, length), tensile strength metrics, burst pressure values, torque limits, kink resistance thresholds.
  • Chemical/Biological Properties: Biocompatibility assays (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity, hemocompatibility), chemical compatibility.
  • Functional Performance: Leak testing, coating integrity, particulate count, simulated use performance, radiopacity (as confirmed by physicians).
  • Sterility and Packaging Integrity: Demonstrated through sterilization validation and packaging tests.

8. Sample Size for the Training Set

No training set is applicable or mentioned. This device is a physical medical device, not a machine learning model that requires a training set.

9. How the Ground Truth for the Training Set Was Established

Not applicable as there is no training set for a physical device.

§ 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).