K Number
K212224
Date Cleared
2021-09-20

(66 days)

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

The TracStar LDP Large Distal Platform is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

The Zoom 88 Large Distal Platform is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

Device Description

The Imperative Care Large Distal Platform (LDP) Catheters include the TracStar™ LDP Large Distal Platform and Zoom™ 88 Large Distal Platform. The LDP Catheters are 0.038" diameter or smaller guidewire compatible single lumen guide catheters that provide access to peripheral, coronary and neuro vasculature. The catheters are comprised of a hollow cylindrical tube bonded at the proximal end to a standard luer fitting. The wall of the tube is constructed using a combination of metal coils/braids and medical grade polymers. The distal section of each catheter has a hydrophilic coating to enhance tracking through tortuous vasculature. An angled distal soft tip facilitates smooth tracking past vessel branches. A radiopaque marker provides visual confirmation of the distal tip location under fluoroscopy. LDP Catheters have an inner diameter of 0.088" (6F compatible), and a maximum outer diameter of 0.110". The LDP guide catheters are packaged with a rotating hemostasis valve (RHV) that is attached to the proximal luer to help maintain hemostasis.

AI/ML Overview

This document describes the premarket notification for the Imperative Care TracStar LDP Large Distal Platform and Zoom 88 Large Distal Platform, which are guide catheters. The submission is based on substantial equivalence to predicate devices, meaning extensive new studies were not required. The provided text details the acceptance criteria and study findings for this medical device.

1. Table of Acceptance Criteria and Reported Device Performance

Test AttributeAcceptance CriteriaReported Performance
Delivery, Compatibility, and Retraction (Trackability)The catheter shall be able to be delivered, deployed, and retracted per the IFU within a simulated neurological model without incurring any damage to the catheter.Pass
Flexibility and Kink ResistanceThere shall be no kinking of shaft (permanent deformation) after simulated use.Pass
Compatibility with other Devices (external)The catheters shall be able to be delivered through the minimum introducer sheath or guide catheter size indicated in the product labeling.Pass
Guidewire CompatibilityThe catheters shall be able to be delivered over the maximum size guidewire indicated in the product labeling.Pass
Interventional Device Compatibility (internal)The catheters shall be able to accommodate other interventional devices (e.g., support catheter, diagnostic catheter) up to the maximum size indicated in the product labeling.Pass
Luer CompatibilityDevices and accessories shall be compatible with standard syringe luer fittings per ISO 80369-7.Pass
Accessory CompatibilityDevices shall be compatible with an RHV.Pass
Catheter Bond StrengthThe catheter shall have sufficient bond strengths to remain intact throughout a procedure.Pass
Freedom from Leakage – positive pressureNo liquid leakage from the hub or catheter shaft at 46psi for 30 seconds.Pass
Freedom from leakage - negative pressureNo air leakage into a 20cc syringe when vacuum pulled for 15 seconds.Pass
Dynamic Burst PressureCatheter does not burst under pressures that could be seen when performing contrast injections with a standard 10cc syringe.Pass
Static Burst PressureCatheter does not burst under pressures that could be seen when performing contrast injections with a standard 10cc syringe.Pass
Catheter Torque StrengthWith the catheter tip held in a static position, there shall be no separation of any portion of the catheter when rotated at the hub at least two (2) full rotations (720 degrees).Pass
Kink ResistanceThere shall be no kinking of the catheter shaft (permanent deformation) after wrapping around anatomically relevant bend radii.Pass
PushabilityThe proximal shaft of the catheters shall have sufficient stiffness that the user can easily push the catheter to the target anatomy without buckling.Pass
Access ForceCatheters shall not require excessive force to safely navigate and track to the target anatomy.Pass

2. Sample Size Used for the Test Set and Data Provenance

The document does not explicitly state the specific sample sizes (number of units tested) for each individual bench and laboratory test. It generally refers to "bench and laboratory (in-vitro) testing." The data provenance is in-vitro, conducted in a laboratory setting. There is no information regarding country of origin of the data or if it was retrospective or prospective, as these terms typically apply to clinical studies with human participants.

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

This information is not provided. For performance testing of a medical device like a catheter, "ground truth" is typically established by physical measurements, engineering specifications, and adherence to recognized standards (like ISO 10555-1), rather than expert consensus on interpretive data.

4. Adjudication Method for the Test Set

This information is not applicable and not provided. Adjudication methods (e.g., 2+1, 3+1) are typically used in clinical studies involving interpretation of data (e.g., imaging) by multiple readers to resolve discrepancies. The performance tests described here are objective, pass/fail engineering tests.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The submission is for a medical device (catheter) and relies on bench and laboratory testing for substantial equivalence, not comparative clinical effectiveness with human readers.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

This question is not applicable to the device described. The TracStar LDP Large Distal Platform and Zoom 88 Large Distal Platform are physical guide catheters, not algorithms or AI software. Therefore, there is no "algorithm only" or "human-in-the-loop" performance to report.

7. The Type of Ground Truth Used

For the bench and laboratory tests, the "ground truth" is based on pre-defined engineering specifications and performance standards, particularly ISO 10555-1 for catheters. The results are objective measurements against these established criteria, leading to a "Pass" or "Fail" outcome.

8. The Sample Size for the Training Set

This information is not applicable. The device is a physical catheter, not an AI/ML algorithm that requires a training set. The substantial equivalence pathway relies on demonstrating that the new device performs similarly to a predicate device through bench testing, not on learning from a dataset.

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

This information is not applicable, as there is no training set for a physical medical 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).