(30 days)
The Catapult Guide Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature.
The COMPASS Guiding Introducer Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature. The device is also intended to be used within a pediatric population.
The Fortress Introducer Sheath System is intended to provide access and to facilitate percutaneous introduction of guide wres, catheters and other devices into the femoral, popliteal and infrapopliteal arteries while maintaining haemostasis during diagnostic and interventional procedures.
The Introducer Sheath System devices consist of a coil reinforced introducer sheath with hemostasis valve and side port, as well as a dilator with a tapered tip and luer lock at the proximal end. The main introducer sheath tubing is connected at the proximal end to a hemostasis valve with side port tubing that is connected to a plastic color coded 3-way stopcock valve. The side port is used for flushing the introducer sheath. The sheath is introduced into the vascular system with the aid of the dilator. The hemostasis valve at the proximal end of the introducer sheath conforms and seals around guide wires and catheters to reduce blood leakage from the introducer sheath. A radiopaque marker helps identify the distal end of the introducer sheath. The introducer sheath has a lubricious hydrophilic coating on the outer surface in length of 20cm on the distal portion.
The System consists of the following components:
- A One Introducer Sheath with hemostasis valve
- A One or two dilator(s)
The provided text describes a 510(k) premarket notification for a medical device called the Catapult Guide Sheath / Introducer Sheath System. It details the device, its intended use, comparison to a predicate device, and the performance testing conducted to demonstrate substantial equivalence.
However, the questions you've asked are typical for the evaluation of AI/ML-driven medical devices, especially related to diagnostic or classification tasks (e.g., image analysis for disease detection). The device described in the document (Catapult Guide Sheath) is a physical medical device (an introducer sheath system) used for physical introduction of interventional and diagnostic devices into the vasculature, not an AI/ML software device.
Therefore, the provided document does not contain the information requested in your prompt regarding acceptance criteria and study proving device meets acceptance criteria for an AI/ML device. Many of the questions (e.g., sample size for test set, number of experts for ground truth, MRMC study, standalone performance, training set details) are irrelevant to the type of device being reviewed in this FDA submission.
Here's why and what information is available:
- Type of Device: The Catapult Guide Sheath is a Class II physical medical device (introducer catheter). It's a tool, not a diagnostic or AI algorithm.
- Purpose of Submission (510(k)): This submission is to demonstrate "substantial equivalence" to a legally marketed predicate device (Catapult Guide Sheath Introducer Sheath System, K240957). This is a common pathway for physical devices with modifications or new physical devices that are very similar to existing ones. The core of the substantial equivalence argument relies on demonstrating that the new device performs similarly to the predicate device, especially after a material change (insourced HVA).
- "Acceptance Criteria" for this device: For this type of device, "acceptance criteria" are related to mechanical performance, biocompatibility, sterilization, and shelf-life, ensuring the device functions as intended and is safe. These are detailed in Table 2, listing the tests performed and the applicable standards.
- "Study that proves the device meets the acceptance criteria": The document lists a series of non-clinical (laboratory) tests that were performed. These tests are the "study" demonstrating the device meets the performance requirements for substantial equivalence.
Therefore, I cannot fill out the detailed table and answer the specific questions about AI/ML device evaluation based on the provided text. The text focuses on the mechanical, material, and safety performance of a physical device, not the diagnostic or predictive performance of an AI algorithm.
If your intention was to ask about the evaluation of a physical medical device, I can re-frame the answer based on the provided document.
Assuming you are asking for information relevant to the physical medical device described, here's an attempt to interpret your questions in that context, recognizing that most are geared towards AI/ML:
Device: Catapult Guide Sheath / Introducer Sheath System
1. Acceptance Criteria and Reported Device Performance
For this physical device, "acceptance criteria" relate to meeting specifications derived from regulatory standards and predicate device performance. The "reported device performance" are the results of the listed tests that demonstrated compliance.
| Acceptance Criteria (Met via Standards & Predicate Comparability) | Reported Device Performance (Summary from Submission) | Notes |
|---|---|---|
| Mechanical Performance: | ||
| Dimensional Evaluation (Visual Inspection) | Achieved internal requirements based on predicate. | Confirms physical dimensions meet specifications. |
| Insertion Force (Mechanical/Visual) | Achieved internal requirements based on predicate. | Demonstrates ease of insertion. |
| Valve / Dilator snap-in fit test (Mechanical/Visual) | Achieved internal requirements based on predicate, and IEC 62366-1:2020. | Ensures components fit securely. |
| Air leakage during aspiration (Mechanical) | Compliant with ISO 10555-1:2013/AMD1:2017. | Prevents air embolism. |
| Liquid leakage through hemostasis valve (Mechanical) | Compliant with ISO 11070:2014, ISO 10555-1:2013/AMD1:2017, ISO 80369-1:2018, ISO 80369-7:2021. | Critical for maintaining hemostasis during procedures. |
| Tensile properties evaluation (Mechanical) | Compliant with ISO 11070:2014, ISO 10555-1:2013/AMD1:2017. | Ensures device structural integrity under tension. |
| Kink stability (Mechanical) | Compliant with EN 13868:2002 and internal requirements. | Prevents device kinking during use, which could obstruct flow or device passage. |
| Flow-rate (Mechanical) | Compliant with ISO 10555-1:2013/AMD1:2017. | Ensures adequate flow for flushing or contrast injection. |
| Luer Connector (Mechanical) | Compliant with ISO 80369-1:2018, ISO 80369-7:2021. | Ensures secure and universal connections to other medical devices. |
| Particle evaluation test (Mechanical/Visual/External) | Compliant with AAMI TIR42, ISO 8536-4, USP <788>. | Assesses particulate matter, ensuring patient safety. |
| Packaging integrity assessment (External laboratory testing) | Compliant with EN 868-5:2018, ASTM F88/F88M-21, ISO 11607-1. | Ensures sterility and physical integrity of the device until point of use. |
| Biocompatibility: | ||
| Biocompatibility testing/Biological Risk Assessment | Compliant with ISO 10993 series and FDA Guidance. | Ensures device materials are safe for biological contact. Specific tests depend on contact type (e.g., cytotoxicity, sensitization, irritation, hemocompatibility). |
| Chemical stability assessment | Met internal requirements based on predicate. | Ensures material integrity and safety over time. |
| Sterility & Shelf Life: | ||
| Sterilization adoption (Documented assessment / External lab) | Compliant with ISO 10993-7, ISO 11737-1, ISO 11135. | Confirms the ethylene oxide (EO) sterilization process is effective and residual EO is within limits, ensuring sterility. |
| Accelerated Age Study (Mechanical/External Laboratory) | Compliant with ASTM F1980-16 and various tests. | Predicts long-term performance and shelf-life of the device. |
2. Sample Size for the Test Set and Data Provenance
For a physical device, "test set" refers to the number of units tested. The specific sample sizes for each mechanical test are not detailed in this summary (they would be in the full submission). The data provenance is from non-clinical (laboratory) testing conducted by the manufacturer and external laboratories. It is not patient data, so "country of origin of the data," "retrospective or prospective" do not apply.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This question is not applicable. "Ground truth" in the context of AI/ML diagnostic devices refers to a definitive diagnosis or finding. For a physical device, the "ground truth" is established by the specifications and performance requirements derived from engineering principles and relevant ISO standards. No human experts are used to "establish ground truth" in this context; instead, engineers and technicians conduct specified physical and chemical tests.
4. Adjudication Method for the Test Set
Not applicable. There's no "adjudication" (e.g., consensus among readers) needed for a physical device's performance testing. Test results are quantitative measurements against defined criteria.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
Not applicable. MRMC studies are for evaluating human reader performance, typically with and without AI assistance, for diagnostic tasks. This device is not an AI diagnostic tool.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) Was Done
Not applicable. This is a physical device, not an algorithm. Its "standalone performance" refers to its mechanical and material properties as tested in the lab.
7. The Type of Ground Truth Used
For this physical device, the "ground truth" for performance is defined by:
- International standards (ISO, AAMI, ASTM, EN): These standards define acceptable limits and testing methodologies for medical device properties (e.g., leakage, tensile strength, biocompatibility, sterility).
- Predicate device performance: The previously cleared predicate device provides a benchmark for expected performance characteristics of the new device.
- Manufacturer's internal design specifications and risk analysis: Derived from the intended use and safety considerations.
8. The Sample Size for the Training Set
Not applicable. This device does not involve a "training set" as it's not an AI/ML algorithm.
9. How the Ground Truth for the Training Set Was Established
Not applicable. There is no "training set" or "ground truth" for training in the AI/ML sense for this device.
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & 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.
Contract Medical International GmbH Jan Kubicek Senior Regulatory Affairs Manager, Europe Lauensteiner Str. 37 Dresden, Saxony 01277 Germany
Re: K250439
Trade/Device Name: Catapult Guide Sheath Regulation Number: 21 CFR 870.1340 Regulation Name: Catheter introducer Regulatory Class: Class II Product Code: DYB. DRE Dated: February 14, 2025 Received: February 14, 2025
Dear Jan Kubicek:
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"
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(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).
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 OS 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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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).
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Sincerely,
Digitally signed by Sevan R. Sevan R. Oungoulian -S Oungoulian -S 13-51-42-04'00' 13:51:42 -04'00'
For
Misti Malone 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
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Indications for Use
510(k) Number (if known) K250439
Device Name
Catapult Guide Sheath Introducer Sheath System; COMPASS Guiding Introducer Sheath; Fortress Introducer Sheath System
Indications for Use (Describe)
The Catapult Guide Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature.
The COMPASS Guiding Introducer Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature. The device is also intended to be used within a pediatric population.
The Fortress Introducer Sheath System is intended to provide access and to facilitate percutaneous introduction of guide wres, catheters and other devices into the femoral, popliteal arteries while maintaining haemostasis during diagnostic and interventional procedures.
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
1.1 Submitter
| Submitter: | Contract Medical GmbH |
|---|---|
| Lauensteiner Strasse 37 | |
| 01277 Dresden | |
| Germany | |
| Contact Person: | Jan Kubicek, |
| Position: | Regulatory Affairs Manager |
| Phone: | +420494949556 |
| Email: | jan.kubicek@heraeus.com |
| Date Summary Prepared: | 14th February 2025 |
1.2 Device
| Device Trade Name: | Catapult Guide Sheath | |
|---|---|---|
| Device Common Name: | Introducer Sheath | |
| Modification: | Introduction of internally sourced HVA | |
| Classification Name: | Introducer Catheter, and | |
| Dilator, Vessel, For Percutaneous Catheterization | ||
| Device Class: | II | |
| Product Code: | DYB, and | |
| DRE |
1.3 Predicate Device
The predicate device is the Catapult Guide Sheath Introducer Sheath System (K240957).
1.4 Device Description
The Introducer Sheath System devices consist of a coil reinforced introducer sheath with hemostasis valve and side port, as well as a dilator with a tapered tip and luer lock at the proximal end. The main introducer sheath tubing is connected at the proximal end to a hemostasis valve with side port tubing that is connected to a plastic color coded 3-way stopcock valve. The side port is used for flushing the introducer sheath. The sheath is introduced into the vascular system with the aid of the dilator. The hemostasis valve at the proximal end of the introducer sheath conforms and seals around guide wires and catheters to reduce blood leakage from the introducer sheath. A radiopaque marker helps identify the distal end of the introducer sheath. The introducer sheath has a lubricious hydrophilic coating on the outer surface in length of 20cm on the distal portion.
The System consists of the following components:
- A One Introducer Sheath with hemostasis valve
- A One or two dilator(s)
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1.5 Indications for Use for introducer sheath systems of the Manufacturer
The Catapult Guide Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature.
The COMPASS Guiding Introducer Sheath is indicated to be used for introduction of interventional and diagnostic devices into the peripheral (and coronary) vasculature. The device is also intended to be used within a pediatric population.
The Fortress Introducer Sheath System is intended to provide access and to facilitate percutaneous introduction of guide wires, catheters and other devices into the femoral, popliteal and infrapopliteal arteries while maintaining haemostasis during diagnostic and interventional procedures.
1.6 Comparison of Technological Characteristics with the Predicate Device
Regarding the design, device features, method of sterilization, and mode of operation, the modification of Introducer Sheath System device does not differ from the predicate device.
Device size configurations and shapes for the modified Introducer Sheath System devices are unchanged.
Materials used for manufacture of the modified Introducer Sheath System devices are or very similar as those contained in the predicate device with exception of the insourced HVA (Hemostasis Valve Adaptor).
The following modification exist between the subject and predicate devices:
| HVA Part | Predicate HVA materials | Subject HVA Materials | |
|---|---|---|---|
| Hemostasis valvematerial | HVA Cap:Polycarbonate | HVA Cap:Copolyester | |
| HVA Body:Polycarbonate | HVA Body:Copolyester | ||
| Valve membrane:Silicone | Valve membrane:Silicone | ||
| Swivel Nut:Copolyester | Swivel Nut:Polycarbonate | ||
| O-Ring:N/A | O-Ring:Silicone | ||
| Lubricant:Silicone | Lubricant:Silicone | ||
| Stopcock andextension linematerial | Stopcock Body:Polycarbonate | Stopcock Body:Polycarbonate | |
| Stopcock Handle:Acetal | Stopcock Handle:HDPE | ||
| Stopcock Cap:ABS | Stopcock Cap:Polypropylene | ||
| Tubing:TPU - Tecothane | Tubing:TPU - Elastollan |
- . New insourced HVA as complete assembly
Table 1 – HVA material comparison between subject and predicate device
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Performance Data 1.7
Performance data demonstrate that the modification of the Introducer Sheath System devices is substantially equivalent to the predicate. The following performance data from non-clinical tests were provided in support of the substantial equivalence determination:
- . Mechanical testing, including tests required under relevant international standards were performed to verify and validate the design.
- . Biocompatibility Risk Assessment (BRA) and performed biocompatibility device testing to demonstrate biocompatibility.
- . Sterilization information to confirm sterility of the device upon exposure to the selected sterilization EO cycle.
- . Accelerated aging testing to confirm product performance at the end of the shelf life.
The list of tests performed in support of determination of substantial equivalence is provided in Table 2.
| No. | Verification / Validation Activity | Test Type | Applicable Standard(s)(Recognized Consensus # ifapplicable] |
|---|---|---|---|
| 1 | Dimensional Evaluation | Visual | Internal requirement based onpredicate performance |
| 2 | Insertion Force | Mechanical/Visual | Internal requirement based onpredicate performance |
| 3 | Valve / Dilator snap-in fit test | Mechanical/Visual | Internal requirement based onpredicate performanceIEC 62366-1:2020 (5-129) |
| 4 | Air leakage during aspiration | Mechanical | ISO 10555-1:2013/AMD1:2017(6-408) |
| 5 | Liquid leakage throughhemostasis valve | Mechanical | ISO 11070:2014ISO 10555-1:2013/AMD1:2017(6-408)ISO 80369-1:2018 (5-121)ISO 80369-7:2021 (5-133) |
| 6 | Tensile properties evaluation | Mechanical | ISO 11070:2014ISO 10555-1:2013/AMD1:2017(6-408) |
| 7 | Kink stability | Mechanical | EN 13868:2002 (N/A)Internal requirement based onpredicate performance |
| 8 | Flow-rate | Mechanical | ISO 10555-1:2013/AMD1:2017(6-408) |
| No. | Verification / Validation Activity | Test Type | Applicable Standard(s)(Recognized Consensus # ifapplicable] |
| 9 | Luer Connector | Mechanical | ISO 80369-1:2018 (5-121)ISO 80369-7:2021 (5-133) |
| 10 | Particle evaluation test | Mechanical/Visual/External | AAMI TIR42 (3-172)ISO 8536-4 (6-447)USP <788> |
| 11 | Packaging integrity assessment | External laboratory testing | EN 868-5:2018ASTM F88/F88M-21(14-573)ISO 11607-1 Second edition2019-02 (14-530) |
| 12 | Biocompatibility testingBiological Risk Assessment | External LaboratoryDocumented assessment | ISO 10993-1:2018 (2-258)ISO 10993-4:2017 (2-248)ISO 10993-5:2009 (2-245)ISO 10993-10:2021 (2-296)ISO 10993-11:2017 (2-255)ISO 10993-12:2021 (2-289)ISO 14971:2019 (5-125)FDA Guidance Use ofInternational Standard ISO10993-1 |
| 13 | Chemical stability assessment | Documented assessment | Internal requirement based onpredicate performance |
| 14 | Sterilization adoption | Documented assessment /External laboratory testing | ISO 10993-7:2008 (2-275)ISO 11737-1:2018/AMD1:2021(14-577)ISO 11135:2014 (14-529)ISO 10993-1:2018 (2-258)AAMI TIR28:2009 (N/A) |
| 15 | Accelerated Age Study | Mechanical/ ExternalLaboratory | ASTM F1980-16 (14-497)Various per performed tests |
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Table 2 - Testing overview
Conclusions 1.8
The results of performed testing based on risk analysis demonstrate that the new modification of Introducer Sheath System devices perform comparably with the predicate and other legally marketed devices. The modified Introducer Sheath System devices with is substantially equivalent to the predicate device in terms of intended use, design and materials, technological characteristics, and principle of operation.
§ 870.1340 Catheter introducer.
(a)
Identification. A catheter introducer is a sheath used to facilitate placing a catheter through the skin into a vein or artery.(b)
Classification. Class II (performance standards).