K Number
K231096
Device Name
Automatic Continuous Effusion Shunt (ACES) System ACES System
Date Cleared
2023-08-18

(122 days)

Product Code
Regulation Number
876.5955
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Automatic Continuous Effusion Shunt (ACES) System is indicated for use in adult (>21 years of age) patients with • chylothorax • intractable aseptic pleural effusion
Device Description
The ACES System is an implanted pleural-peritoneal shunt system intended to palliate symptoms of recurrent pleural effusion, an accumulation of fluid in the cavity around the lungs. The ACES System comprises a pump that is, generally, a resilient flexible bulb having an inlet and an outlet. The inlet is attached to a first fenestrated barium striped tube that extends from the inlet valve to the patient's pleural cavity. The outlet is connected to a second fenestrated barium striped tube that extends from the outlet valve to the patient's peritoneal cavity. Each one-way valve is connected to a single pump chamber with an internal automatic pump extension and external manual compression and an integrated implant securement flange for suture fixation in the muscular facia. Internal (intercostal) automatic (passive) pump extension is placed between adjacent ribs in the external (subdermal) manual compression (active) pump extension is positioned under the skin and external to the ribs. Using a patient's own respiration, the internal automatic pump extension operates by being successively compressed and decompressed between adjacent ribs, as the patient breathes, whereby pumping the fluid from the pleural cavity to the peritoneal cavity, where it is naturally reabsorbed by the external manual compression pump extension allows for intraprocedural priming of the pump chamber as well as manual compression by the patient, post procedurally, at will or as directed by their physician for movement of fluid from the pleural cavity to the peritoneal cavity.
More Information

No
The device description details a mechanical pump system that relies on patient respiration and manual compression, with no mention of AI or ML components or functions.

Yes.

The device is indicated for use in patients with chylothorax and intractable aseptic pleural effusion, which are medical conditions, and it is intended to palliate symptoms of recurrent pleural effusion. The device description also states it is a shunt system that moves fluid from the pleural cavity to the peritoneal cavity. These functions directly address and manage a disease state or condition, aligning with the definition of a therapeutic device.

No
The device description clearly states its purpose is to "palliate symptoms of recurrent pleural effusion" by physically shunting fluid from the pleural cavity to the peritoneal cavity. It is a treatment device, not a diagnostic one.

No

The device description clearly details a physical, implanted shunt system with a pump, tubes, and valves, indicating it is a hardware medical device. The performance studies also focus on physical characteristics and biocompatibility of the hardware components.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used outside of the body.
  • Device Description: The Automatic Continuous Effusion Shunt (ACES) System is an implanted device. It is surgically placed within the patient's body to manage fluid accumulation.
  • Intended Use: The intended use is to palliate symptoms of recurrent pleural effusion and chylothorax by moving fluid from one body cavity to another. This is a therapeutic intervention, not a diagnostic test performed on a sample.

The description clearly indicates that the device is an internal shunt system, which falls under the category of medical devices used in vivo (within the living body) for treatment, not in vitro for diagnosis.

N/A

Intended Use / Indications for Use

The Automatic Continuous Effusion Shunt (ACES) System is indicated for use in adult (>21 years of age) patients with • chylothorax • intractable aseptic pleural effusion

Product codes (comma separated list FDA assigned to the subject device)

KPM

Device Description

The ACES System is an implanted pleural-peritoneal shunt system intended to palliate symptoms of recurrent pleural effusion, an accumulation of fluid in the cavity around the lungs. The ACES System comprises a pump that is, generally, a resilient flexible bulb having an inlet and an outlet. The inlet is attached to a first fenestrated barium striped tube that extends from the inlet valve to the patient's pleural cavity. The outlet is connected to a second fenestrated barium striped tube that extends from the outlet valve to the patient's peritoneal cavity. Each one-way valve is connected to a single pump chamber with an internal automatic pump extension and external manual compression and an integrated implant securement flange for suture fixation in the muscular facia. Internal (intercostal) automatic (passive) pump extension is placed between adjacent ribs in the external (subdermal) manual compression (active) pump extension is positioned under the skin and external to the ribs. Using a patient's own respiration, the internal automatic pump extension operates by being successively compressed and decompressed between adjacent ribs, as the patient breathes, whereby pumping the fluid from the pleural cavity to the peritoneal cavity, where it is naturally reabsorbed by the external manual compression pump extension allows for intraprocedural priming of the pump chamber as well as manual compression by the patient, post procedurally, at will or as directed by their physician for movement of fluid from the pleural cavity to the peritoneal cavity.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Pleural cavity, peritoneal cavity

Indicated Patient Age Range

adult (>21 years of age)

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)

Performance testing was conducted to evaluate and characterize the performance of the device to support a determination of substantial equivalence to the predicate and reference devices, where applicable. A comparison was made against the predicate and reference devices, where data was available. The ACES System has undergone bench, biocompatibility, packaging, and sterilization testing to demonstrate the differences in technological characteristics do not raise different questions of safety and effectiveness.

Non-Clinical Performance Tests:

  • Simulated Use (Visual Inspection, Pressure Testing, Chamber Pumping (Automatic), Bulb Pumping (Manual), Chamber Flowrate (Automatic), Bulb Flowrate (Manual)): All samples passed the acceptance criteria.
  • Destructive (Tensile, Burst): All samples passed the acceptance criteria.
  • Backflow: All samples passed the acceptance criteria.
  • Securement (Suture Pull Out Force): All samples passed the acceptance criteria.
  • Coating (Vertical Pinch Test, Coating Length Verification, Toluidine Blue & Finger Rub Test): All samples passed the acceptance criteria.
  • Packaging: The packaged device and labeling shall withstand the conditions of ISTA 3A and ASTM D-4169; DC13; AL1 without loss of function, sterility, or legibility. Pass – All samples passed the acceptance criteria.
  • Shelf-Life: The packaged device and labeling shall withstand simulated storage conditions without loss of function, sterility, or legibility. Pass – All samples passed the acceptance criteria.
  • Sterilization: The sterilization process shall be validated to demonstrate a minimum of SAL of 10-6 for the product using Gamma radiation. Pass – All samples passed the acceptance criteria.

Biocompatibility:

  • Cytotoxicity (MEM Elution Cytotoxicity Assay (ISO) (GLP)): Pass - Non-cytotoxic.
  • Sensitization (Guinea Pig Maximization Test (ISO) Sensitization (GLP - 2 Extracts)): Pass - Non-sensitizer.
  • Irritation or Intracutaneous Reactivity (Intracutaneous Reactivity Test (ISO) (GLP - 2 Extracts)): Pass - Non-irritant.
  • Material Mediated Pyrogenicity (Material Mediated Pyrogenicity Test (ISO/USP) (GLP)): Pass - Non-pyrogenic.
  • Acute Systemic Toxicity (Acute Systemic Toxicity Test (ISO) (GLP - 2 Extracts)): Pass - Non-toxic.
  • Subacute/Subchronic Toxicity ((31-Day) Systemic Toxicity (Implant Method) and Implant Evaluation Test in Rabbits (ISO)): Pass - No systemic toxic effects were observed.
  • Implantation Effects ((91-Day) Systemic Toxicity (Implant Method) and Implant Evaluation Test in Rabbits (ISO)): Pass - No systemic toxic effects were observed; Pass - Slight reaction observed.
  • Genotoxicity (Ames Bacterial Reverse Mutation Assay (ISO) (GLP - 2 Extracts), Mouse Lymphoma Assay (ISO) (GLP - 2 Extracts)): Pass - Non-mutagenic.
  • Chronic Toxicity: Not evaluated. The biocompatibility of the Automatic Continuous Effusion Shunt System has been evaluated to support an implant duration of 12 months, beyond which point it is recommended the device be removed.
  • Carcinogenicity: Not evaluated.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K822686

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K012235, K912645

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 876.5955 Peritoneo-venous shunt.

(a)
Identification. A peritoneo-venous shunt is an implanted device that consists of a catheter and a pressure activated one-way valve. The catheter is implanted with one end in the peritoneal cavity and the other in a large vein. This device enables ascitic fluid in the peritoneal cavity to flow into the venous system for the treatment of intractable ascites.(b)
Classification. Class II. The special controls for this device are FDA's:(1) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(2) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),” and
(3) Backflow specification and testing to prevent reflux of blood into the shunt.

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

August 18, 2023

Pleural Dynamics, Inc. % Joseph Ostendorf Regulatory Affairs Consultant Ostendorf Consulting, LLC 23879 Blue Spruce Road Sauk Centre, Minnesota 56378

Re: K231096

Trade/Device Name: Automatic Continuous Effusion Shunt (ACES) System Regulation Number: 21 CFR 876.5955 Regulation Name: Peritoneo-Venous Shunt Regulatory Class: Class II Product Code: KPM Dated: July 27, 2023 Received: July 27, 2023

Dear Joseph Ostendorf:

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,

Glenn B. Bell -S

for Gema Gonzalez Acting Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K231096

Device Name

Automatic Continuous Effusion Shunt (ACES) System

Indications for Use (Describe)

The Automatic Continuous Effusion Shunt (ACES) System is indicated for use in adult (>21 years of age) patients with • chylothorax

• intractable aseptic pleural effusion

Type of Use (Select one or both, as applicable)
-------------------------------------------------
Construction Use (Part 41 CFR 60-1 Subpart B)
On-Site Construction (41 CFR 60-4 Subpart A)

|× | Prescription Use (Part 21 CFR 801 Subpart D)

| | Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

Pleural Dynamics, Inc. 510(k) Summary

This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

510(k) Number:K231096
Date Prepared:August 17, 2023
Applicant:Pleural Dynamics, Inc.
952 Medina Road
Wayzata, MN 55391
+1 (763) 501-7223
Contact Person:Joseph Ostendorf
Regulatory Affairs Consultant
23879 Blue Spruce Road
Sauk Centre, MN 56378
SUBJECT DEVICE
Trade/Device Name:Automatic Continuous Effusion Shunt (ACES) System
Device Regulation Number:21 CFR § 876.5955
Device / Regulation Name:Peritoneo-venous shunt
Regulation Description /
Common Name:Shunt, Peritoneal
Product Code:KPM

Class II

Device Class / Regulation

Classification:

4

DEVICE DESCRIPTION (For the Device Subject to this 510(k) Premarket Notification)

The ACES System is an implanted pleural-peritoneal shunt system intended to palliate symptoms of recurrent pleural effusion, an accumulation of fluid in the cavity around the lungs.

The ACES System comprises a pump that is, generally, a resilient flexible bulb having an inlet and an outlet. The inlet is attached to a first fenestrated barium striped tube that extends from the inlet valve to the patient's pleural cavity. The outlet is connected to a second fenestrated barium striped tube that extends from the outlet valve to the patient's peritoneal cavity. Each one-way valve is connected to a single pump chamber with an internal automatic pump extension and external manual compression and an integrated implant securement flange for suture fixation in the muscular facia. Internal (intercostal) automatic (passive) pump extension is placed between adjacent ribs in the external (subdermal) manual compression (active) pump extension is positioned under the skin and external to the ribs.

Using a patient's own respiration, the internal automatic pump extension operates by being successively compressed and decompressed between adjacent ribs, as the patient breathes, whereby pumping the fluid from the pleural cavity to the peritoneal cavity, where it is naturally reabsorbed by the external manual compression pump extension allows for intraprocedural priming of the pump chamber as well as manual compression by the patient, post procedurally, at will or as directed by their physician for movement of fluid from the pleural cavity to the peritoneal cavity.

INDICATIONS FOR USE (For the Device Subject to this 510(k) Premarket Notification)

The Automatic Continuous Effusion Shunt (ACES) System is indicated for use in adult (>21 years of age) patients with

  • chylothorax
  • intractable aseptic pleural effusion

5

DEVICE CLASSIFICATION, INTENDED USE/INDICATIONS FOR USE, AND TECHNOLOGICAL AND PERFORMANCE CHARACTERISTICS COMPARISONS

The following tables provide a side-by-side comparison of the ACES System to the predicate and reference devices to support this pre-market notification.

Device Classification Comparison
Subject Device
K231096Predicate Device
K822686Reference Device
K012235Reference Device
K912645
Trade/Device
Name:Automatic
Continuous
Effusion Shunt
(ACES) SystemDenver Peritoneo-
Venous ShuntDenver Pleural
Effusion Shunt and
Denver Pleural
Effusion Shunt with
External Pump
ChamberAtriums PDR
Thoracic Catheter
Regulation
Medical SpecialtyGastroenterology /
UrologyGastroenterology /
UrologyGastroenterology /
UrologyGeneral & Plastic
Surgery
Device Regulation
Number:21 CFR § 876.595521 CFR § 876.595521 CFR § 876.595521 CFR § 878.4200
Device /
Regulation Name:Peritoneo-venous
shuntPeritoneo-venous
shuntPeritoneo-venous
shuntIntroduction/drainage
catheter and
accessories
Regulation
Description /
Common Name:Shunt, PeritonealShunt, PeritonealShunt, PeritonealCatheter.
Ventricular, General
& Plastic Surgery
Product Code:KPMKPMKPMGBS
Device Class /
Regulation
Classification:Class IIClass IIClass IIClass I

6

Intended Use/Indications for Use Comparison
Subject Device
K231096Predicate Device
K822686Reference Device
K012235Reference Device
K912645
Intended
UseThe Automatic
Continuous Effusion
Shunt (ACES)
System is intended to
move fluid from one
location in the body
to another.The Denver
Peritoneo-Venous
Shunt is intended to
move fluid from one
location in the body
to another.The Denver Pleural
Effusion Shunt is
intended to move
fluid from one
location in the body
to another.The Atriums PDR
Thoracic Catheter is
intended to allow
movement of fluid
from the body.
Indications
for UseThe Automatic
Continuous Effusion
Shunt (ACES) System
is indicated for use in
adult (>21 years of
age) patients with
chylothorax intractable
aseptic pleural
effusionUnknownThe Denver Pleural
Effusion Shunt is
indicated for use in
patients with chylothorax intractable
aseptic pleural
effusion
The Denver Pleural
Effusion Shunt with
External Pump
Chamber is indicated
for adult, pediatric,
and neonatal patients
with chylothorax intractable
aseptic pleural
effusionAtrium thoracic
catheters are intended
to facilitate the
evacuation of air
and/or fluid from the
chest cavity or
mediastinum.
Technological and Performance Characteristics Comparison
Subject Device
K230196Predicate Device
K822686Reference Device
K012235Reference Device
K912645
ManufacturerPleural Dynamics,
Inc.BD
(Becton, Dickinson
and Company)BD
(Becton, Dickinson
and Company)Atrium Medical
Corporation
(MAQUET
Cardiovascular,
LLC)
ConstructSingle Pump
Chamber with
Double Valves and
Pleural and
Peritoneal LimbsSingle Pump
Chamber with
Valves with
Peritoneal and
Venous LimbsSingle Pump
Chamber with
Double Valves and
Pleural and
Peritoneal LimbsSingle Limb Tube
Materials of
ConstructionPump Chamber:
Silicone
Limbs: Silicone
with Barium
Sulfate StripePump Chamber:
Silicone
Limbs: Silicone
with Barium
Sulfate StripePump Chamber:
Silicone
Limbs: Silicone
with Barium
Sulfate StripeLimb: Silicone or
Polyvinyl Chloride
with Radiopaque
Stripe
Surface TreatmentYes - Covalently
Bonded Heparin
CoatingYes - Ionically
Bonded HeparinNone KnownYes - Covalently
Bonded Heparin
Coating
Technological and Performance Characteristics Comparison
Subject Device
K230196Predicate Device
K822686Reference Device
K012235Reference Device
K912645
Placement
TechniqueSeldinger
TechniqueSeldinger
TechniqueSeldinger
TechniqueSurgical Technique
Design IntentPlaced internally,
relative to the skin,
with an extension
of the pump
chamber positioned
between adjacent
ribs to manage
pleural effusion by
moving fluid from
the pleural cavity to
the peritoneal
cavity.Placed internally or
externally, relative
to the skin, with a
portion of the
peritoneal tube
positioned across
the abdominal wall
to manage ascites
by moving fluid
from the peritoneal
cavity to the venous
system.Placed internally or
externally, relative
to the skin, with a
portion of the
pleural tube
positioned between
adjacent ribs to
manage pleural
effusion by moving
fluid from the
pleural cavity to the
peritoneal cavity.Placed partially
internal and
partially external,
relative to the skin.
with a portion of
the tube positioned
between adjacent
ribs to drain the
cavity by moving
fluid or air from the
pleural cavity to
exterior of the
body.
Principles of
OperationPleural effusion
shunts are
permanently placed
drainage
management
systems designed to
move fluid from the
pleural cavity to the
peritoneal cavity.Peritoneo-Venous
shunts are
permanently placed
drainage
management
systems designed to
move fluid from the
peritoneal cavity to
the venous system.Pleural effusion
shunts are
permanently placed
drainage
management
systems designed to
move fluid from the
pleural cavity to the
peritoneal cavity.Thoracic catheters
are temporarily
placed access
devices designed to
move fluid from the
thorax to the
exterior of the
body.
Tubing Length30 cmUnknownUnknownUnknown
Tubing Inner
Diameter2.64 mmUnknownUnknownUnknown
Tubing Outer
Diameter4.88 mmUnknownUnknownUnknown
PumpAutomatic250 – 750 mL/dayN/AN/AN/A
Fluid
Flow
RateManualApproximately
2 mL per complete
pump compressionUnknownApproximately
2 mL per complete
pump compressionN/A
ImplantableYesYesYesYes
Single Patient UseYesYesYesYes
Design Prevents
BackflowYesYesYesNo
BiocompatibleYesYesYesYes
Provided SterileYesYesYesYes

7

8

SUMMARY OF PERFORMANCE TESTING AND STANDARDS

Performance testing was conducted to evaluate and characterize the performance of the device to support a determination of substantial equivalence to the predicate and reference devices, where applicable. A comparison was made against the predicate and reference devices, where data was available. The ACES System has undergone bench, biocompatibility, packaging, and sterilization testing to demonstrate the differences in technological characteristics do not raise different questions of safety and effectiveness.

Non-Clinical Performance Tests
TestTest Method SummaryResults and Conclusions
Simulated UseVisual InspectionPass – All samples passed the acceptance criteria
Pressure TestingPass – All samples passed the acceptance criteria
Chamber Pumping (Automatic)Pass – All samples passed the acceptance criteria
Bulb Pumping (Manual)Pass – All samples passed the acceptance criteria
Chamber Flowrate (Automatic)Pass – All samples passed the acceptance criteria
Bulb Flowrate (Manual)Pass – All samples passed the acceptance criteria
DestructiveTensilePass – All samples passed the acceptance criteria
BurstPass – All samples passed the acceptance criteria
BackflowBackflowPass – All samples passed the acceptance criteria
SecurementSuture Pull Out ForcePass – All samples passed the acceptance criteria
CoatingVertical Pinch TestPass – All samples passed the acceptance criteria
Coating Length VerificationPass – All samples passed the acceptance criteria
Toluidine Blue & Finger Rub TestPass – All samples passed the acceptance criteria
PackagingThe packaged device and labeling shall withstand the conditions of ISTA 3A and ASTM D-4169; DC13; AL1 without loss of function, sterility, or legibility.Pass – All samples passed the acceptance criteria
Shelf-LifeThe packaged device and labeling shall withstand simulated storage conditions without loss of function, sterility, or legibility.Pass – All samples passed the acceptance criteria
SterilizationThe sterilization process shall be validated to demonstrate a minimum of SAL of 10-6 for the product using Gamma radiation.Pass – All samples passed the acceptance criteria

9

Biocompatibility
TestTest SummaryConclusions
CytotoxicityMEM Elution Cytotoxicity Assay
(ISO)
(GLP)Pass - Non-cytotoxic
SensitizationGuinea Pig Maximization Test
(ISO) Sensitization
(GLP - 2 Extracts)Pass - Non-sensitizer
Irritation or Intracutaneous
ReactivityIntracutaneous Reactivity Test
(ISO)
(GLP - 2 Extracts)Pass - Non-irritant
Material Mediated PyrogenicityMaterial Mediated Pyrogenicity
Test (ISO/USP)
(GLP)Pass - Non-pyrogenic
Acute Systemic ToxicityAcute Systemic Toxicity Test
(ISO)
(GLP - 2 Extracts)Pass - Non-toxic
Subacute/Subchronic Toxicity(31-Day) Systemic Toxicity
(Implant Method) and Implant
Evaluation Test in Rabbits (ISO)Pass - No systemic toxic effects
were observed
Implantation Effects(91-Day) Systemic Toxicity
(Implant Method) and Implant
Evaluation Test in Rabbits (ISO)Pass - No systemic toxic effects
were observed
Pass - Slight reaction observed
GenotoxicityAmes Bacterial Reverse Mutation
Assay (ISO)
(GLP - 2 Extracts)
Mouse Lymphoma Assay (ISO)
(GLP - 2 Extracts)Pass - Non-mutagenic
Chronic ToxicityNot evaluatedThe biocompatibility of the
Automatic Continuous Effusion
Shunt System has been evaluated
to support an implant duration of
12 months, beyond which point it
is recommended the device be
removed.
Carcinogenicity

10

BASIS FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE

The Device Classification. Intended Use, and elemental Scientific Technology for the ACES System are the same as those described for the Predicate Device (K822686). The Surface Treatment is the same as that of the Reference Device (K912645). The Indications for Use and Principle of Operation is the same as that of the Reference Device (K012235).

The ACES System does not raise different questions regarding safety and effectiveness when compared to the predicate and reference devices and has been determined by Pleural Dynamics, Inc. to be substantially equivalent.

In summary, the ACES System has the same or similar following characteristics to the predicate and reference devices, which have previously received 510(k) clearance:

  • Has the same device classification (Predicate Device K822686) ●
  • . Has the same intended use (Predicate Device K822686)
  • Has the similar indications for use (Reference Device K012235)
  • Uses similar technological and performance characteristics (Reference Device K012235) ●
  • Uses the similar principles of operation (Reference Device K012235) ●
  • Same special controls are met (Predicate Device K822686) ●

Therefore, the conclusions drawn from the non-clinical tests demonstrate the device is as safe, as effective, and performs as well as the legally marketed device predicate, and reference devices, where applicable, per 21 CFR 807.92(b)(3). The ACES System is substantially equivalent to the predicate device and reference devices, where applicable.

SUBSTANTIAL EQUIVALENCE CONCLUSIONS

Through the thorough comparison of technological and performance characteristics, the subject device is determined to be substantially equivalent to the predicate device.