(102 days)
No
The description focuses on the mechanical design and function of the catheter for thrombus removal and fluid management, with no mention of AI or ML capabilities.
Yes
The "Intended Use / Indications for Use" states that the device is for "The non-surgical removal of thrombi and emboli from blood vessels," which indicates a therapeutic purpose. The device actively treats a medical condition (thrombi/emboli).
No
Explanation: The device is indicated for the non-surgical removal of thrombi and emboli and for injection, infusion, and/or aspiration of fluids. It is a therapeutic device designed for intervention rather than diagnosis.
No
The device description clearly details physical components such as shafts, a coring element, ports, a handle, and mentions materials like polymeric and metal. It is a physical medical device.
Based on the provided information, the RevCore Thrombectomy Catheter is not an In Vitro Diagnostic (IVD) device.
Here's why:
- IVD Definition: In Vitro Diagnostics are devices intended for use in the examination of specimens derived from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease or injury.
- RevCore Thrombectomy Catheter's Function: The RevCore Thrombectomy Catheter is a surgical device used within the body (in the peripheral vasculature) to physically remove thrombi and emboli. It is an interventional device, not a device that analyzes samples outside the body.
- Intended Use: The intended use clearly describes a procedure performed directly on the patient's blood vessels.
- Device Description: The description details a physical catheter with mechanical components designed for insertion and manipulation within the body.
Therefore, the RevCore Thrombectomy Catheter falls under the category of a surgical or interventional medical device, not an In Vitro Diagnostic.
N/A
Intended Use / Indications for Use
The RevCore Thrombectomy Catheter is indicated for:
• The non-surgical removal of thrombi and emboli from blood vessels.
• Injection, infusion , and/or aspiration of contrast media and other fluids into or from a blood vessel.
The RevCore Thrombectomy Catheter is intended for use in the peripheral vasculature system
Product codes
QEW
Device Description
The RevCore Thrombectomy Catheter is a single-use, sterile medical device designed for use in the peripheral vasculature. The RevCore Thrombectomy Catheter comprises reinforced polymeric and metal coaxial shafts terminating in an expandable coring element. Two ports are provided for de-airing the catheter shafts. To aid in fluoroscopic visualization, the RevCore Thrombectomy Catheter distal tip and coring element are radiopaque. The RevCore Thrombectomy Catheter consists of a distal laser-cut nitinol coring element, catheter shafts, and a handle, providing wall-to-wall contact, allowing the engagement and retrieval of clot from blood vessels and from implanted venous stents. The catheter shafts introduce the nitinol coring element percutaneously. The handle allows the physician to retract and turn the nitinol coring element to engage clot, as well as control the diameter of the nitinol coring element with a knob.
The RevCore Catheter is comprised of reinforced polymeric and metallic coaxial shafts terminating in an expandable coring element. Two ports are provided for de-airing the catheter shafts. To aid in fluoroscopic visualization, the RevCore Catheter distal tip is radiopaque.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
peripheral vasculature
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
A GLP Animal Study was successfully performed to evaluate the safety and performance of the RevCore Thrombectomy Catheter. The GLP animal testing met the predetermined acceptance criteria. All non-clinical test results demonstrated that acceptance criteria were met.
Key Metrics
Not Found
Predicate Device(s)
Reference Device(s)
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 870.5150 Embolectomy catheter.
(a)
Identification. An embolectomy catheter is a balloon-tipped catheter that is used to remove thromboemboli, i.e., blood clots which have migrated in blood vessels from one site in the vascular tree to another.(b)
Classification. Class II (performance standards).
0
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March 14, 2023
Inari Medical, Inc. Suzanne Moreno Sr. Regulatory Affairs Specialist 6001 Oak Canyon, Suite 100 Irvine, California 92618
Re: K223609
Trade/Device Name: RevCore™ Thrombectomy Catheter. Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy Catheter Regulatory Class: Class II Product Code: QEW Dated: February 23, 2023 Received: February 24, 2023
Dear Suzanne Moreno:
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. 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
1
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,
Digitally signed by Gregory W. Gregory W. O'connell -S O'connell -S Date: 2023.03.14
09:29:30 -04'00'
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known) K223609
Device Name RevCoreTM Thrombectomy Catheter
Indications for Use (Describe) The RevCore Thrombectomy Catheter is indicated for:
· The non-surgical removal of thrombi and emboli from blood vessels.
· Injection, infusion , and/or aspiration of contrast media and other fluids into or from a blood vessel.
The RevCore Thrombectomy Catheter is intended for use in the peripheral vasculature system
Type of Use (Select one or both, as applicable) | |
---|---|
------------------------------------------------- | -- |
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary K223609 RevCore™ Thrombectomy Catheter
The following "510(k) Summary" of safety and effectiveness is being submitted in accordance with the requirements of 21 CFR 807.92.
1.0 Submitter Information [ 21 CFR 807.92(a) (1)]
Submitter: | Inari Medical, Inc. |
---|---|
Address: | 6001 Oak Canyon, Suite 100 |
Irvine, CA 92618 USA | |
Establishment | |
Registration #: | 3020347218 |
Contact: | Suzanne Moreno |
Title: | Sr. Regulatory Affairs Specialist |
Telephone: | (949) 694-9459 |
Suzanne.Moreno@inarimedical.com |
Date Prepared: January 04, 2023
2.0 Device Information [21 CFR 807.92 (a) (2)]
Device/Trade Name: | RevCore™ Thrombectomy Catheter |
---|---|
Device Classification: | Class II |
Primary Product Code: | QEW |
Regulation: | 21 CFR 870.5150 |
Regulation Name: | Embolectomy catheter |
Common Name: | Embolectomy catheter |
Classification Panel: | 74-Cardiovascular |
3.0 Predicate, and Reference Device Information [21 CFR 807.92(a) (3)]
| Predicate Device | 510(k)
No. | Decision
Date | 510(k) Holder |
|--------------------------------------------|---------------|------------------|---------------------|
| ClotTriever BOLD Catheter | K212632 | 10/18/2021 | Inari Medical, Inc. |
| Reference Device | 510(k)
No. | Decision
Date | 510(k) Holder |
| FlowTriever Retrieval/Aspiration
System | K201541 | 12/04/2020 | Inari Medical, Inc. |
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4.0 Device Description [21 CFR 807.92(a) (4)1
The RevCore Thrombectomy Catheter is a single-use, sterile medical device designed for use in the peripheral vasculature. The RevCore Thrombectomy Catheter comprises reinforced polymeric and metal coaxial shafts terminating in an expandable coring element. Two ports are provided for de-airing the catheter shafts. To aid in fluoroscopic visualization, the RevCore Thrombectomy Catheter distal tip and coring element are radiopaque. The RevCore Thrombectomy Catheter consists of a distal laser-cut nitinol coring element, catheter shafts, and a handle, providing wall-to-wall contact, allowing the engagement and retrieval of clot from blood vessels and from implanted venous stents. The catheter shafts introduce the nitinol coring element percutaneously. The handle allows the physician to retract and turn the nitinol coring element to engage clot, as well as control the diameter of the nitinol coring element with a knob.
5.0 Intended Use/Indications for use of device and Indications for Use [21 CFR 807.92(a) (5)]
Indications for Use
The RevCore Thrombectomy Catheter is indicated for:
- . The non-surgical removal of thrombi and emboli from blood vessels.
- Injection, infusion, and/or aspiration of contrast media and other fluids into . or from a blood vessel.
The RevCore Thrombectomy Catheter is intended for use in the peripheral vasculature.
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6.0 Summary of Substantial Equivalence [21 CFR 807.92 (a) (6)]
The RevCore Thrombectomy Catheter is similar/same in indications for use, fundamental design, principles of operation, materials, labeling/packaging, and sterilization compared to the Inari owned devices, the predicate, the ClotTriever BOLD Catheter (K212632), and the reference device, the FlowTriever Retrieval/Aspiration System (K201541).
Subject | Predicate Device | Reference Device | Subject | Predicate Device | Reference Device | ||
---|---|---|---|---|---|---|---|
Device | RevCore Thrombectomy Catheter | ClotTriever BOLD Catheter | FlowTriever Retrieval/Aspiration System | Device | RevCore | ||
Thrombectomy Catheter | ClotTriever BOLD | ||||||
Catheter | FlowTriever | ||||||
Retrieval/Aspiration | |||||||
System | |||||||
510(k) Number | K223609 | K212632 | K201541 | 510(k) Number | K223609 | K212632 | K201541 |
Manufacturer | Inari Medical | Inari Medical | Inari Medical | Device | |||
Description | The RevCore Catheter | ||||||
is a single-use, sterile, | |||||||
minimally invasive | |||||||
medical device designed | |||||||
for use in the peripheral | |||||||
vasculature. | The ClotTriever BOLD | ||||||
Catheter is a single-use, | |||||||
sterile, minimally invasive | |||||||
medical device designed | |||||||
for use in the peripheral | |||||||
vasculature. | The FlowTriever System | ||||||
is a single-use, sterile, | |||||||
minimally invasive | |||||||
medical device designed | |||||||
for use in the peripheral | |||||||
vasculature. | |||||||
Product code | QEW | QEW | QEW | ||||
KRA | The RevCore Catheter is | ||||||
comprised of reinforced | |||||||
polymeric and metallic | |||||||
coaxial shafts terminating | |||||||
in an expandable coring | |||||||
element. | The ClotTriever BOLD | ||||||
Catheter is comprised of | |||||||
reinforced polymeric and | |||||||
metallic coaxial shafts | |||||||
terminating in an | |||||||
expandable coring | |||||||
element and thrombus | |||||||
collection bag. | The FlowTriever | ||||||
Catheters are comprised | |||||||
of reinforced polymeric | |||||||
and metallic coaxial | |||||||
shafts terminating in an | |||||||
expandable coring | |||||||
element. | |||||||
Device Class | Class II | Class II | Class II | Two ports are provided | |||
for de-airing the catheter | |||||||
shafts. | Three ports are provided | ||||||
for de-airing the catheter | |||||||
shafts. | One port is provided for | ||||||
de-airing the catheter | |||||||
shafts. | |||||||
Indications for Use Statements | The RevCore Thrombectomy Catheter is indicated for: | ||||||
• The non-surgical removal of thrombi and emboli from blood vessels. | |||||||
• Injection, infusion, and/or aspiration of contrast media and other fluids into or from a blood vessel. | |||||||
The RevCore Thrombectomy Catheter is intended for use in the peripheral vasculature. | The ClotTriever BOLD Catheter is indicated for: | ||||||
• The non-surgical removal of thrombi and emboli from blood vessels. | |||||||
• Injection, infusion, and/or aspiration of contrast media and other fluids into or from a blood vessel. | |||||||
The ClotTriever BOLD Catheter is intended for use in the peripheral vasculature including deep vein thrombosis (DVT). | The FlowTriever 2 Catheter is indicated for: | ||||||
• The non-surgical removal of thrombi and emboli from blood vessels. | |||||||
• Injection, infusion, and/or aspiration of contrast media and other fluids into or from a blood vessel. | |||||||
The FlowTriever 2 Catheter is intended for use in the peripheral vasculature. | To aid in fluoroscopic | ||||||
visualization, the | |||||||
RevCore Catheter | |||||||
distal tip is radiopaque. | To aid in fluoroscopic | ||||||
visualization, the | |||||||
ClotTriever BOLD | |||||||
Catheter distal tip is | |||||||
radiopaque. | To aid in fluoroscopic | ||||||
visualization, the | |||||||
FlowTriever Catheter | |||||||
distal tip is radiopaque. | |||||||
Principles of | |||||||
operation | The coring element is | ||||||
composed of self- | |||||||
expanding nitinol and the | |||||||
diameter is manually | |||||||
controlled by a knob in | |||||||
the handle. | The coring element is | ||||||
composed of self- | |||||||
expanding nitinol and the | |||||||
diameter is manually | |||||||
controlled by a plunger in | |||||||
the handle. | The disk(s) are | ||||||
composed of self- | |||||||
expanding nitinol which | |||||||
are deployed by manually | |||||||
retracting the outer | |||||||
Delivery Catheter. | |||||||
The coring element is | |||||||
retracted through the | |||||||
vessel to engage and | |||||||
remove thrombus and | |||||||
emboli. | The coring element is | ||||||
retracted through the | |||||||
vessel to engage and | |||||||
remove thrombus and | |||||||
emboli. | The coring element is | ||||||
retracted through the | |||||||
vessel to engage and | |||||||
remove thrombus and | |||||||
emboli. | |||||||
The device and captured | |||||||
clot can then be removed | |||||||
from the vessel through | |||||||
the introducer sheath. | The device and captured | ||||||
clot can then be removed | |||||||
from the vessel through | |||||||
the introducer sheath. | The device and captured | ||||||
clot can then be removed | |||||||
from the vessel through | |||||||
the introducer sheath. |
The comparisons are listed in the table below:
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Subject | Predicate Device | Reference Device | |
---|---|---|---|
Device | RevCore | ||
Thrombectomy Catheter | ClotTriever BOLD | ||
Catheter | FlowTriever | ||
Retrieval/Aspiration | |||
System | |||
510(k) Number | K223609 | K212632 | K201541 |
Power Source | Manually operated | Manually operated | Manually operated |
Sterile | SAL 10-6, EO | SAL 10-6, EO | SAL 10-6, EO |
Number of | |||
disks / coring | |||
elements | Model 44-101: 1 | Model 42-102: 1 | Model 11-102: 1 |
Model 10-104: 3 | |||
Recommended | |||
vessel size | |||
treatment range | Model 44-101: | ||
6mm - 20mm | Model 42-102 | ||
6mm - 16mm | Model 11-102 | ||
6mm - 16mm | |||
Model 10-104 | |||
19mm - 25mm | |||
Maximum Disk / | |||
Coring Element | |||
Size | Model 44-101: 24.0mm | Model 42-102: 16.0mm | Model 11-102: 17.0mm |
Model 10-104: 27.9mm | |||
Disk / coring | |||
element | |||
material | Nitinol | Nitinol | Nitinol |
Delivery | |||
Catheter shaft | |||
materials | Pebax 6333 SA01 MED, | ||
Pebax 5533 SA01 MED, | |||
304V stainless steel, | |||
PTFE Liner | Pebax 6333 SA01 MED, | ||
Pebax 5533 SA01 MED, | |||
304V stainless steel, | |||
PTFE Liner | Pebax 7233 SA01 MED, | ||
Pebax 4033 SA01 MED, | |||
304V stainless steel, | |||
PTFE Liner | |||
Tip Materials | Pebax 7233 SA01 MED, | ||
45% Tungsten | Pebax 7233 SA01 MED, | ||
70% Tungsten | Pebax 7233 SA01 MED, | ||
70% Tungsten | |||
Delivery | |||
Catheter OD | 3.9 mm | 3.9 mm | 3.8 mm |
Delivery | |||
Catheter length | 80 cm | 80 cm | 120 cm |
Guidewire | |||
compatibility | .035" | .035" | .035" |
7.0 Performance Testing [21 CFR 807.92(b)(1)]
In accordance with the Design Failure Modes and Effects Analysis, verification and validation tests were identified to support the substantial equivalence of the RevCore Thrombectomy Catheter to the predicate device, the ClotTriever BOLD Catheter (K212632), and the reference device, the FlowTriever Retrieval/Aspiration System (K201541).
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7.1 Performance Testing
The following tests were performed for the RevCore Thrombectomy Catheter:
Packaging Tests & Inspections
- Pouch Seal Inspection ●
- Pouch Dye Penetration ●
- Pouch Bubble Leak ●
- Aseptic Presentation
Dimensions & Key Characteristics
- Visual and Dimensional Inspections ●
- o RevCore Catheter
- RevCore Coring Element o
- RevCore Delivery Catheter o
- Guidewire Compatibility ●
Performance & Functional Evaluation
- Deairing/Flushing Testing ●
- Knob Torque Testing ●
- Deployment and Retraction Force through the Delivery Catheter ●
- Coring Element Retraction into Delivery Catheter Inspection ●
- Distal Catheter Kink Radius Testing ●
- Coring Element Durability Inspection (Post-Simulated Use) ●
- Insertion through Sheath
- Retraction Force through Sheath ●
- Sheath Inspection (Post-Simulated Use) ●
- Leakage Testing, Sheath (Post-Simulated Use) ●
- Vacuum Testing, Sheath (Post-Simulated Use) ●
- Leakage Testing, RevCore Catheter (Post-Simulated Use) ●
- Delivery Catheter Durability Inspection (Post-Simulated Use) ●
- Simulated Use Tracking and Tensile Testing (Post-Simulated Use) ●
- Simulated Use Tracking and Torque Testing (Post-Simulated Use) ●
- Corrosion Testing
- Particulate Matter Determination ●
- Luer Testing ●
- Safety Testing in Stent Model ●
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Characterization Tests
- Radial Force Characterization ●
- Efficacy Testing (Clot & Stent Model) ●
- SEM of Stents/RevCore Coring Elements Post-Treatment
Leveraged Tests
- Pouch Seal Strength ●
- Simulated Use Tracking and Rotation Testing ●
- Delivery Catheter Radiopacity ●
Pre-Clinical Study
A GLP Animal Study was successfully performed to evaluate the safety and performance of the RevCore Thrombectomy Catheter. The GLP animal testing met the predetermined acceptance criteria.
7.2 Biocompatibility
Biocompatibility testing for the RevCore Thrombectomy Catheter was completed in accordance with ISO 10993-1 including:
- Cytotoxicity ●
- Sensitization ●
- Intracutaneous Reactivity ●
- Acute Systemic Toxicity ●
- Pyrogenicity (Material Mediated)
- Hemocompatibility ●
- o Hemolysis
- Complement Activation O
- Thrombogenicity O
- Platelet and Leukocyte O
- Partial Thromboplastin Time (PTT) о
7.3 Sterilization
The subject device is sterilized using EtO to achieve a sterility assurance level (SAL) of 10°. The subject device has been adopted into a validated sterilization process in accordance with the principles of ISO 11135:2014 (Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation, and routine control of a sterilization process for medical devices, and AAMI TIR 28:2016 (Product adoption and process equivalence for ethylene oxide sterilization) without deviations.
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7.4 Clinical Data [21 CFR 807.92(b) (2)]
Based on the similarities in the safety and effectiveness profiles of the subject predicate, and reference devices per their intended uses, no clinical studies were deemed necessary to support this submission.
All non-clinical test results demonstrated that acceptance criteria were met; therefore, the device conforms to established product specifications.
8.0 Conclusions Safety and Effectiveness SW [21 CFR 807.92(b) (3)]
The subject device has successfully passed all acceptance criteria for nonclinical performance testing and biocompatibility, demonstrating that the subject device is substantially equivalent to the legally marketed predicate ClotTriever BOLD Catheter (K212632).