K Number
K232437
Device Name
Paragon 8F Balloon Guide Catheter
Manufacturer
Date Cleared
2023-10-13

(60 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Paragon 8F Balloon Guide Catheter is in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the peripheral and neuro vascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures. The Paragon 8F Balloon Guide Catheter is also indicated for use as a conduit for retrieval devices.
Device Description
The Paragon™ 8F Balloon Guide Catheter (BGC) is a multi-lumen, braid-reinforced, variable stiffness catheter with a radiopaque marker on the distal end and a bifurcated luer hub on the proximal end. A compliant balloon is mounted on the distal end. Balloon inflation can be facilitated through the side port of the bifurcated luer hub. The 10 mm long balloon can be inflated up to a maximum volume of 0.6 mL. At this volume, the balloon diameter is 10 mm. The through-lumen extends from the center port of the bifurcated luer hub to the distal tip. The external distal segment of the catheter shaft has hydrophilic coating to reduce friction during use. The coating starts from the proximal balloon bond and extends proximally for 19 cm in length. There are two Paragon 8F BGC configurations which have working lengths of 85 cm. The difference in device length resides in the proximal shaft segment only. The 16 cm distal flexible segment and the balloon are identical for both configurations. The Paragon 8F Balloon Guide Catheter is compatible with minimum 0.110 inch inner diameter (ID) introducer sheaths, guidewires up to 0.038 inch outer diameter (OD), and 6F catheters up to 0.085 inch OD. The Paragon 8F Balloon Guide Catheter is sterile, non-pyrogenic, and intended for single use only.
More Information

No
The device description and performance studies focus on the physical characteristics and mechanical performance of a balloon guide catheter. There is no mention of AI, ML, image processing, or data analysis that would suggest the use of such technologies.

No
The device is described as a guide catheter used to facilitate the insertion and guidance of other intravascular catheters, and for temporary vascular occlusion or as a conduit for retrieval devices. It does not actively treat a disease or condition.

No

Explanation: The device is a catheter designed for facilitating the insertion and guidance of other intravascular catheters and providing temporary vascular occlusion. It is a tool used during procedures, not for diagnosing conditions.

No

The device description clearly details a physical catheter with multiple lumens, a balloon, and various material properties and dimensions. This is a hardware medical device.

Based on the provided information, the Paragon 8F Balloon Guide Catheter is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly describes a device used in vivo (within the body) to facilitate the insertion and guidance of other catheters and provide temporary vascular occlusion during angiographic procedures. It also acts as a conduit for retrieval devices. These are all procedures performed directly on a patient.
  • Device Description: The description details a physical catheter with a balloon, designed to be inserted into blood vessels. This is consistent with an in vivo medical device.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or compatibility testing.

IVD devices are used to perform tests outside the body on biological samples. The Paragon 8F Balloon Guide Catheter is a therapeutic and interventional device used inside the body.

N/A

Intended Use / Indications for Use

The Paragon 8F Balloon Guide Catheter is in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the peripheral and neuro vascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures. The Paragon 8F Balloon Guide Catheter is also indicated for use as a conduit for retrieval devices.

Product codes

DQY, QJP

Device Description

The Paragon™ 8F Balloon Guide Catheter (BGC) is a multi-lumen, braid-reinforced, variable stiffness catheter with a radiopaque marker on the distal end and a bifurcated luer hub on the proximal end. A compliant balloon is mounted on the distal end. Balloon inflation can be facilitated through the side port of the bifurcated luer hub. The 10 mm long balloon can be inflated up to a maximum volume of 0.6 mL. At this volume, the balloon diameter is 10 mm. The through-lumen extends from the center port of the bifurcated luer hub to the distal tip. The external distal segment of the catheter shaft has hydrophilic coating to reduce friction during use. The coating starts from the proximal balloon bond and extends proximally for 19 cm in length. There are two Paragon 8F BGC configurations which have working lengths of 85 cm. The difference in device length resides in the proximal shaft segment only. The 16 cm distal flexible segment and the balloon are identical for both configurations.

The Paragon 8F Balloon Guide Catheter is compatible with minimum 0.110 inch inner diameter (ID) introducer sheaths, guidewires up to 0.038 inch outer diameter (OD), and 6F catheters up to 0.085 inch OD. The Paragon 8F Balloon Guide Catheter is sterile, non-pyrogenic, and intended for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Fluoroscopy

Anatomical Site

Peripheral and neuro vascular systems.

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Performance testing was conducted to support the Paragon™ 8F Balloon Guide Catheter submission. The results of the design verification and validation testing (Table 2) confirm that the subject device conforms to the pre-defined specifications and test acceptance criteria are met. All samples in all 27 tests including Visual Inspection, Dimensional Inspection, Simulated Use, Kink Resistance, Coating Lubricity, Radiopacity, Delivery/Retrieval, Balloon Inflation Time, Balloon Deflation Time, Distal Tip Stiffness, Coating Integrity, Torque Strength, Shaft & Hub Tensile, Liquid Leak, Air Leak, Hub Compatibility, RHV Luer, Static Burst, Dynamic Burst, Resistance to Lumen Collapse, Corrosion Resistance, Extension Tubing Tensile, Particulate, Balloon Fatigue, Balloon Joint Integrity, Balloon Burst Volume, Balloon Diameter to Inflation Volume (Compliance), Shelf Life, Transit Testing, Packaging - Bubble Leak, Packaging - Pouch Seal Strength, and Sterility, passed the pre-determined acceptance criteria.

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

Not Found

Predicate Device(s)

8F FlowGate Balloon Guide Catheter (K153729)

Reference Device(s)

087 Balloon Guide Catheter System (K192525), Neuron™ MAX System (K111380)

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

0

October 13, 2023

Image /page/0/Picture/1 description: The image contains 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 a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Wallaby Medical Joseph Tang Design Quality Engineer 22901 Mill Creek Drive Laguna Hills, California 92653

Re: K232437

Trade/Device Name: Paragon 8F Balloon Guide Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: DQY, QJP Dated: August 11, 2023 Received: August 14, 2023

Dear Joseph Tang:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

1

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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 -S

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

2

Indications for Use

510(k) Number (if known)

K232437

Device Name

Paragon 8F Balloon Guide Catheter

Indications for Use (Describe)

The Paragon 8F Balloon Guide Catheter is in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the peripheral and neuro vascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures. The Paragon 8F Balloon Guide Catheter is also indicated for use as a conduit for retrieval devices.

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)
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

|X] Prescription Use (Part 21 CFR 801 Subpart D)

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

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3

510(k) Summary (K232437)

As required by 21 CFR 807.92:

| Applicant: | Wallaby Medical
22901 Mill Creek Drive
Laguna Hills, CA 92653 | |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| Contact: | Primary contact: Joseph Tang
E-mail: joseph.tang@wallabyphenox.com
Phone: +1 714 904 6097 Secondary contact: Rachel McDaid
E-mail: rachel.mcdaid@wallabyphenox.com
Phone: +353 91 740 100 | |
| Date Prepared: | October 10th, 2023 | |
| Device Trade Name: | Paragon 8F Balloon Guide Catheter | |
| Device Common Name: | Balloon Guide Catheter | |
| Classification Name: | Percutaneous Catheter | |
| Regulation Number: | 21 CFR 870.1250 | |
| Product Code: | DQY, QJP | |
| Predicate Device: | 8F FlowGate Balloon Guide Catheter (K153729) | |
| Reference Device 1: | 087 Balloon Guide Catheter System (K192525) | |
| Reference Device 2: | Neuron™ MAX System (K111380) | |

Device Description

The Paragon™ 8F Balloon Guide Catheter (BGC) is a multi-lumen, braid-reinforced, variable stiffness catheter with a radiopaque marker on the distal end and a bifurcated luer hub on the proximal end. A compliant balloon is mounted on the distal end. Balloon inflation can be facilitated through the side port of the bifurcated luer hub. The 10 mm long balloon can be inflated up to a maximum volume of 0.6 mL. At this volume, the balloon diameter is 10 mm. The through-lumen extends from the center port of the bifurcated luer hub to the distal tip. The external distal segment of the catheter shaft has hydrophilic coating to reduce friction during use. The coating starts from the proximal balloon bond and extends proximally for 19 cm in length. There are two Paragon 8F BGC configurations which have working lengths of 85 cm. The difference in device length resides in the proximal shaft segment only. The 16 cm distal flexible segment and the balloon are identical for both configurations.

The Paragon 8F Balloon Guide Catheter is compatible with minimum 0.110 inch inner diameter (ID) introducer sheaths, guidewires up to 0.038 inch outer diameter (OD), and 6F catheters up to 0.085 inch OD. The Paragon 8F Balloon Guide Catheter is sterile, non-pyrogenic, and intended for single use only.

4

Indications for Use

The Paragon 8F Balloon Guide Catheter is indicated for use in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the peripheral and neuro vascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures. The Paragon 8F Balloon Guide Catheter is also indicated for use as a conduit for retrieval devices.

Comparison to Predicate and Reference Devices

The table below provides the comparison of technological characteristics and indications for use of the subject device with the predicate and reference devices.

Device NameSubject Device:Predicate Device:Reference Device:Rationale for Difference
Paragon™ 8F8F FlowGate087 Balloon Guide(if applicable)
Balloon GuideBalloon GuideCatheter System
CatheterCatheter
510(k) No.K232437K153729K192525
ClassificationClass II, DQY, QJPClass II, DQYClass II, DQYSame
Indication for UseThe Paragon 8F
Balloon Guide
Catheter is indicated
for use in facilitating
the insertion and
guidance of an
intravascular
catheter into a
selected blood vessel
in the peripheral and
neuro vascular
systems. The balloon
provides temporary
vascular occlusion
during these and
other angiographic
procedures. The
Paragon 8F Balloon
Guide Catheter is
also indicated for use
as a conduit forFlowGate Balloon
Guide Catheters are
indicated for use in
facilitating the
insertion and guidance
of an intravascular
catheter into a
selected blood vessel
in the peripheral and
neuro vascular
systems. The balloon
provides temporary
vascular occlusion
during these and other
angiographic
procedures. The
Balloon Guide
Catheter is also
indicated for use as a
conduit for retrieval
devices.The 087 Balloon Guide
Catheter System is indicated
for use in facilitating the
insertion and guidance of an
intravascular catheter into a
selected blood vessel in the
peripheral and
neurovasculature. The
balloon provides temporary
vascular occlusion during
such procedures. The 087
Balloon Guide Catheter
System is also indicated for
use as a conduit for retrieval
devices.Same
Anatomicalretrieval devices.
Peripheral and neuroPeripheral and neuroPeripheral and neuroSame
Locationsvasculaturevasculaturevasculature
Catheter Shaft
MaterialOuter layer: Pebax,
Polyamide,
Polyurethane
Inner layer: PTFEOuter layer: Pebax,
Pebax with Barium
Sulfate, Polyamide
with Barium Sulfate
Inner layer: PTFEOuter layer: Pebax,
Polyamide, Polyurethane
Inner layer: PTFEThe differences in the outer
layer materials do not raise
new questions of safety
and effectiveness. The
subject device has been
evaluated via bench and
biocompatibility testing.
Shaft ReinforcementStainless steel braidStainless steel braidStainless steel coilSame
Shaft ConstructionSingle-wall lamination
shaft with four
equally spaced 0.5
mm wide inflation
lumens embedded in
the shaft's wall
forming a multi-
lumen shaft.Dual-wall lamination
shaft with an inner
and outer shaft
forming a coaxial
lumen shaft.Single-wall lamination shaft
with three inflation lumens
embedded in the shaft's wall
forming a multi-lumen shaft.The subject device has
small inflation channels
embedded in the shaft's
wall. These differences in
shaft construction do not
raise new questions
regarding safety and
effectiveness.
Device NameSubject Device:
Paragon™ 8F
Balloon Guide
CatheterPredicate Device:
8F FlowGate
Balloon Guide
CatheterReference Device:
087 Balloon Guide
Catheter SystemRationale for Difference
(if applicable)
The subject device has been
evaluated via bench and
biocompatibility testing.
RadiopacityDistal tip has one
radiopaque Pt-Ir
marker band and
stainless-steel
reinforcement in the
catheter shaft,
rendering the shaft
visible under
fluoroscopy.Distal tip has one
radiopaque Pt-Ir
marker band and
stainless-steel
reinforcement in the
catheter shaft,
rendering the shaft
visible under
fluoroscopy.Distal tip has two radiopaque
Pt-Ir marker bands and
stainless steel reinforcement
in the catheter shaft
rendering the shaft visible
under fluoroscopy.Same
CoatingHydrophilic CoatingNoneHydrophilic CoatingSince the predicate device
does not have a hydrophilic
coating, a reference device
is utilized for coating related
benchtop testing to
demonstrate substantial
equivalence.
Compliant Balloon
MaterialLow durometer
(52A)
polyurethaneSilicone elastomerLow durometer urethaneThe material differences do
not raise new questions of
safety and effectiveness. The
subject device has been
evaluated via bench and
biocompatibility testing.
HubPolyamidePolyurethaneSimilarThe material differences do
not raise new questions of
safety and effectiveness.
The subject device has been
evaluated via bench and
biocompatibility testing.
Strain ReliefPebaxPebax, PolyolefinPolyolefinThe material differences do
not raise new questions of
safety and effectiveness. The
subject device has been
evaluated via bench and
biocompatibility testing.
Accessories
Accessories
ProvidedRHV (1), Peel-Away
Sheaths (2), Three-Way
Stopcocks (2), 1 mL
Syringe (1),
Extension Tubing (1)RHV (1), Peel-Away
Sheaths (2), Luer-
Activated Valve (1),
Dilator (1), Tuohy
Borst Valve with
Sideport (1), Extension
Tubing (1)Three-Way Stopcock (1), Peel-
Away Sheath (1), Hub
Extension (1), 1 mL Syringe
(1)Similar. The differences do
not raise new questions of
safety and effectiveness.
Dimensions
Balloon Catheter
Labeled Outer
Diameter8F (0.109 in)8F (0.106 in)8.4F (0.110 in)Similar
Balloon Catheter
Labeled Inner
Diameter0.087 in0.084 in0.087 inSimilar
Working Lengths85 cm, 95 cm85 cm, 95 cm90 cm, 95 cm,
100 cmSame as the predicate
device.
Radiopaque Marker
Band Location0.04 in from the distal
tip edge0.08 in from the distal tip
edge0.06 in from the distal tip
edge (distal of the balloon)
and 0.66 in from the distal tip
edge (proximal of the
balloon)Similar
Maximum Balloon0.6mL0.6mL0.6mLSame
Device NameSubject Device:
Paragon™ 8F
Balloon Guide
CatheterPredicate Device:
8F FlowGate
Balloon Guide
CatheterReference Device:
087 Balloon Guide
Catheter SystemRationale for Difference
(if applicable)
Tip ShapesStraightStraightStraightSame
Packaging
PouchPolyamide/Tyvek pouchTyvek and LLDPE/Nylon
Film Pouch, Chipboard
cartonSimilarSimilar - packaging
materials are similar and
common for medical
devices and maintain
sterility of the device
throughout the shelf life.
TubingPolyethylene
tubesPolyethylene tubesPolyethylene tubesSame
Packaging CardHDPEHDPEHDPESame
Sterilization
MethodEtOEtOEtOSame
How SuppliedSterile, single useSterile, single useSterile, single useSame
Sterility Assurance
Level10-610-610-6Same
Shelf Life12 months36 months36 monthsA 12-month shelf life was
validated for the subject
device.

Table 1: Comparison to Predicate and Reference Devices

5

6

To establish substantial equivalence of the subject device the device meets the design specification and requirements, non-clinical bench and biological compatibility testing were conducted per the risk analysis. The testing performed and results are summarized below.

Design Verification Testing – Bench

Performance testing was conducted to support the Paragon™ 8F Balloon Guide Catheter submission. The results of the design verification and validation testing (Table 2) confirm that the subject device conforms to the pre-defined specifications and test acceptance criteria are met.

Performance Bench Testing Summary
TestDescriptionResults
Visual InspectionTo verify the visual surface requirements are met.Pass – all samples met the
pre-determined
acceptance criteria
Dimensional InspectionTo verify the dimensional specifications are met.Pass – all samples met the
pre-determined
acceptance criteria
Simulated UseTo evaluate the performance of the device and accessories
in simulated anatomy model.Pass – all samples met the
pre-determined
acceptance criteria
Kink ResistanceTo evaluate the device around bends of clinically relevant
radii and verify kink resistance requirements are met.Pass – all samples met the
pre-determined acceptance
criteria
Coating LubricityTo evaluate frictional forces and verify coating lubricity
requirements are met.Pass – all samples met the
pre-determined
acceptance criteria
RadiopacityTo evaluate marker band visibility under fluoroscopy.Pass – all samples met the
pre-determined
acceptance criteria
Performance Bench Testing Summary
TestDescriptionResults
Delivery/RetrievalTo evaluate the device in an anatomical model and verify frictional force requirements are met.Pass - all samples met the pre-determined acceptance criteria
Balloon Inflation TimeTo verify balloon inflation time requirements are met.Pass – all samples met the pre-determined acceptance criteria
Balloon Deflation TimeTo verify balloon deflation time requirements are met.Pass - all samples met the pre-determined acceptance criteria
Distal Tip StiffnessTo evaluate distal tip deflection force and verify distal tip stiffness requirements are met.Pass - all samples met the pre-determined acceptance criteria
Coating IntegrityTo evaluate device pre- and post-insertion and retrieval through a simulated vascular model and verify coating integrity requirements are met.Pass - all samples met the pre-determined acceptance criteria
Torque StrengthTo evaluate device integrity after applied hub rotations with distal end held stationary and verify torque strength requirements are met.Pass - all samples met the pre-determined acceptance criteria
Shaft & Hub TensileTo verify tensile strength requirements are met.Pass - all samples met the pre-determined acceptance criteria
Liquid LeakTo verify liquid leak requirements per ISO 10555-1 are met.Pass - all samples met the pre-determined acceptance criteria
Air LeakTo verify air leak requirements per ISO 10555-1 are met.Pass - all samples met the pre-determined acceptance criteria
Hub CompatibilityTo verify BGC bifurcated luer hub requirements per ISO 80369-7 are met.Pass - all samples met the pre-determined acceptance criteria
RHV LuerTo verify RHV luer requirements per ISO 80369-7 are met.Pass - all samples met the pre-determined acceptance criteria
Static BurstTo verify static burst requirements per ISO 10555-1 are met.Pass - all samples met the pre-determined acceptance criteria
Dynamic BurstTo verify dynamic burst requirements per ISO 10555-1 are met.Pass - all samples met the pre-determined acceptance criteria
Resistance to Lumen CollapseTo demonstrate that the main lumen does not collapse under aspiration.Pass – all samples met the pre-determined acceptance criteria
Corrosion ResistanceTo verify corrosion resistance requirements per ISO 10555-1 are met.Pass – all samples met the pre-determined acceptance criteria
Extension Tubing TensileTo verify tensile strength requirements per ISO 10555- 1 are met.Pass - all samples met the pre-determined acceptance criteria
ParticulateTo evaluate the device within a simulated anatomy model and verify particulate count is similar to the comparator device.Pass – all samples met the pre-determined acceptance criteria
Balloon FatigueTo evaluate repetitive balloon inflation and deflation cycles and verify fatigue requirements are met.Pass - all samples met the pre-determined acceptance criteria
Balloon Joint IntegrityTo evaluate tensile force and verify balloon joint integrity requirements are met.Pass - all samples met the pre-determined acceptance criteria
Performance Bench Testing Summary
TestDescriptionResults
Balloon Burst VolumeTo verify balloon burst volume requirements are met.Pass - all samples met the pre-determined acceptance criteria
Balloon Diameter to Inflation
Volume (Compliance)To characterize balloon diameter for pre-defined balloon inflation volumes.All samples were characterized
Shelf LifeTo verify device performance after accelerated aging.Pass - all samples met the pre-determined acceptance criteria
Transit TestingTo subject the device, accessories, and packaging to environmental conditioning and shipping simulation and verify performance requirements are met.Pass - all samples met the pre-determined acceptance criteria
Packaging - Bubble LeakTo evaluate packaging per ASTM F2096-11 and verify requirements are met.Pass - all samples met the pre-determined acceptance criteria
Packaging - Pouch Seal StrengthTo evaluate packaging per ASTM F88 Technique A (unsupported peel) and verify requirements are met.Pass - all samples met the pre-determined acceptance criteria
SterilityTo subject the device, accessories, and packaging to sterilization and verify the requirements are met.Pass - all samples met the pre-determined acceptance criteria

Table 2: Paragon™ 8F Balloon Guide Catheter Bench Testing Summary

7

8

Animal Study

Animal study was not deemed necessary to demonstrate substantial equivalence.

Sterilization and Shelf Life

The subject device is sterilized using an Ethylene Oxide (EtO) sterilization cycle. The sterilization cycle was verified to ensure a sterility assurance level (SAL) of 10° in accordance with 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.

Shelf-life studies for the subject device have demonstrated that the subject device and packaging remain functional for the labeled use by date. Shelf-life studies for packaging integrity, seal strength, and device functionality were performed and met all acceptance criteria.

Biocompatibility

Biocompatibility evaluation for the subject device was performed in accordance with ISO 10993-1:2018, Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process. Biocompatibility testing completed for the device is included in Table 3.

9

Table 3: Biocompatibility Testing

| Test

Balloon Guide CatheterStandardResultsConclusion
MEM Elution
CytotoxicityCytotoxicity
10993-5Test article scored 0 at 48 hours.Non-cytotoxic
MTT - L-929
Cytotoxicity StudyCytotoxicity
10993-51XMEM test extract showed no cytotoxic
potential to L-929 mouse fibroblast cells
undiluted or at any dilution.Non-cytotoxic
ISO Intracutaneous
Irritation (GLP - 2
Extracts)Irritation or
Intracutaneous
Reactivity
10993-10The delta between the average scores of the
extract of the test article and the vehicle
control are 0.0; 0.0.Non-irritant
ISO Guinea Pig
Maximization
Sensitization (GLP - 2
Extracts)Sensitization
10993-10Test and control animal's response not
greater than "0".Did not elicit
sensitization response
ISO Acute Systemic
Toxicity (GLP - 2
Extracts)Systemic Toxicity
10993-11None of the animals were observed with
abnormal clinical signs indicative of toxicity
for 72 hours. All were alive at the end of
72 hours and body weight changes were
within acceptable parameters.Non-toxic
ISO Material
Mediated Rabbit
Pyrogen (GLP)Pyrogen
10993-11No rabbit temperature rise >=0.5°C.Non-pyrogenic
Complement
Activation -SC5b-9
Assays (GLP)Results were within acceptable range and
not statistically different than activated
NHS control or negative control.Not a potential
activator of
complement system
ASTM Hemolysis -
Direct Contact and
Extract Method (GLP)Blank corrected hemolytic index: 0.1.Test device is non-
hemolytic
Thromboresistance
Evaluation (GLP - 4
Hour - 3 Dog)Hemocompatibility
10993-4No adverse effects or clinical signs during test
period and no thrombus score >3 for
either test or control device.Thromboresistance of
the test device is
similar to control
In Vitro
Hemocompatibility
Assay with Sponsor-
Supplied Comparison
(GLP)Test article results were within acceptable
range.Test article not a risk
for adversely affecting
concentrations of
various cellular and
non-cellular
components in blood
Partial Thromboplastin
Time (PTT) with
Sponsor- Supplied
Comparison
Article (GLP)Test article was found to be 99.5% of the
negative control and not statistically
different from the comparison article.Not at risk for clotting
Chemical
Characterization-
Physiochemical Tests
for Plastics (Buffering
Capacity, Non-
Volatile Residue (NVR)
and Heavy
Metals)Chemical
Characterization 10993-
18Extractable and leachable chemical
characterization and the toxicological risk
assessment of the BGC device suggest that
the likelihood of having any adverse toxic
effect is negligible during intended clinical
use.The risk is acceptable
3-Way Stopcock and
Extension Tubing
MEM Elution
CytotoxicityCytotoxicity
10993-5Test article scored 0 at 24, 48, and 72
hours.Non-cytotoxic
ISO Intracutaneous
Irritation (GLP – 2Irritation or
IntracutaneousThe delta between the average scores of the
extract of the test article and the vehicleNon-irritant
TestStandardResultsConclusion
Extracts)Reactivity
10993-10control are ≤1.
ISO Guinea Pig
Maximization
Sensitization (GLP - 2
Extracts)Sensitization
10993-10Test and control animal's response not
greater than "0".Did not elicit sensitization
response
ISO Acute Systemic
Toxicity (GLP – 2
Extracts)Systemic Toxicity
10993-11None of the animals were observed with
abnormal clinical signs indicative of toxicity
for 72 hours. All were alive at the end of
72 hours and body weight changes were
within acceptable parameters.Non-toxic
ISO Material
Mediated Rabbit
Pyrogen (GLP)Pyrogen 10993-11No rabbit temperature rise >=0.5°C.Non-pyrogenic
ASTM Hemolysis –
Direct Contact and
Extract Method
(GLP)Hemocompatibility
10993-4Blank corrected hemolytic index: 0.1.Test device is non-
hemolytic
1 mL Syringe
MEM Elution
CytotoxicityCytotoxicity
10993-5Test article scored 0 at 48 hours.Non-cytotoxic
ISO Intracutaneous
Irritation (GLP – 2
Extracts)Irritation or
Intracutaneous
Reactivity
10993-10The delta between the average scores of
the extract of the test article and the
vehicle control are ≤1.Non-irritant
ISO Guinea Pig
Maximization
Sensitization (GLP-2
Extracts)Sensitization
10993-10Test and control animal's response not
greater than "0".Did not elicit sensitization
response
ISO Acute Systemic
Toxicity (GLP-2
Extracts)Systemic Toxicity
10993-11None of the animals were observed with
abnormal clinical signs indicative of toxicity
for 72 hours. All were alive at the end of
72 hours and body weight changes were
within acceptable parameters.Non-toxic
ISO Material
Mediated Rabbit
Pyrogen (GLP)Pyrogen 10993-11No rabbit temperature rise >=0.5°C.Non-pyrogenic
ASTM Hemolysis -
Direct Contact and
Extract Method (GLP)Hemocompatibility
10993-4Blank corrected hemolytic index: 0.1Test device is non-
hemolytic
Peel-Away Sheath
MTT - L-929
Cytotoxicity StudyCytotoxicity
10993-5Test article scored 0 at 24, 48, and 72
hours.Non-cytotoxic
ISO Intracutaneous
Irritation (GLP – 2
Extracts)Irritation or
Intracutaneous
Reactivity
10993-10The delta between the average scores of the
extract of the test article and the vehicle
control are =0.5°C.Non-pyrogenic
Mediated Rabbit
TestStandardResultsConclusion
Pyrogen (GLP)
ASTM Hemolysis -
Direct Contact and
Extract Method (GLP)Hemocompatibility
10993-4Blank corrected hemolytic index: 0.1.Test device is non-
hemolytic
RHV
Cytotoxicity MEM
ElutionCytotoxicity
10993-5Percent Cell Lysis: 0%
Cytotoxic Score: 0Non-Cytotoxic
ISO Intracutaneous
Irritation (GLP – 2
Extracts)Irritation or
Intracutaneous
Reactivity
10993-10The delta between the average scores of the
extract of the test article and the vehicle
control are 0.0; 0.0.Negligible Irritant
ISO Guinea Pig
Maximization
Sensitization (GLP - 2
Extracts)Sensitization
10993-10Test and control animal's response not
greater than "0".Did not elicit sensitization
response
ISO Acute Systemic
Toxicity (GLP - 2
Extracts)Systemic Toxicity 10993-
11None of the animals were observed with
abnormal clinical signs indicative of toxicity
for 72 hours. All were alive at the end of
72 hours and body weight changes were
within acceptable parameters.Non-toxic
ISO Materials
Mediated Rabbit
Pyrogen (GLP)Pyrogen 10993-11No rabbit temperature rise ≥0.5°C.Non-pyrogenic
ASTM Hemolysis -
Direct Contact and
Extract Method
(GLP)Hemocompatibility
10993-4Blank corrected hemolytic index: 0.0, 0.1.Test device is non-
hemolytic

10

11

Clinical Study

Clinical study was not deemed necessary to demonstrate substantial equivalence.

Conclusion

The Paragon™ 8F Balloon Guide Catheter is substantially equivalent to the predicate device, 8F FlowGate Balloon Guide Catheter (K153729), based on successful completion of non-clinical bench testing, biocompatibility, sterility, and comparison of the device operating principle, technological characteristics, and indications for use.