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510(k) Data Aggregation

    K Number
    K251485
    Date Cleared
    2025-06-13

    (30 days)

    Product Code
    Regulation Number
    870.5150
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Excipio LV Prime Thrombectomy Device is indicated for the nonsurgical removal of emboli and thrombi from peripheral blood vessels.

    Device Description

    The Excipio LV Prime Thrombectomy Device consists of a Thrombectomy Catheter to mechanically displace thrombus when used with an aspiration catheter. The device will be sold as a sterile, single use device.

    The Thrombectomy Catheter is a mechanical thrombus displacement device with a nitinol braided component (basket) at the distal end that can be opened and closed via an activation wire that attaches to the distal end of the braid and attaches to a proximal handle. The operator can open the braided component to a diameter that best matches the target vessel (6-16 mm in diameter). The thickness of the basket wires enhances the radiopacity to facilitate visualization under fluoroscopy without the need for additional radiopaque markers.

    AI/ML Overview

    Let's break down the information regarding the acceptance criteria and study for the Excipio LV Prime Thrombectomy Device, based on the provided FDA 510(k) clearance letter.

    It's important to note that this document is a 510(k) clearance letter, which focuses on demonstrating substantial equivalence to a predicate device. Therefore, the "study" described here is primarily a non-clinical bench testing campaign aimed at proving the new device performs similarly and meets a defined set of engineering and performance specifications. There is no clinical study involving human (or animal) subjects described in this document for the Excipio LV Prime Thrombectomy Device. Thus, concepts like "human readers," "AI assistance," "effect size," or "ground truth for training/test set" in the context of clinical outcomes or diagnostic accuracy are not applicable to this type of device and submission.


    Acceptance Criteria and Reported Device Performance

    The document describes non-clinical laboratory testing performed to support the substantial equivalence. The acceptance criteria for these tests are implicitly that the device met the criteria and functioned as intended, with a performance profile similar to predicate devices. Specific quantitative acceptance criteria or detailed reported performance values are not explicitly stated in this summary. Instead, it broadly states that the device "met all acceptance criteria" and "functioned as intended."

    Table of Acceptance Criteria and Reported Device Performance:

    Test PerformedAcceptance Criteria (Implicit)Reported Device Performance (Implicit)
    Visual InspectionDevice meets visual quality standards.Met all acceptance criteria.
    Dimensional InspectionDevice dimensions conform to design specifications.Met all acceptance criteria.
    Kink ResistanceDevice withstands kinking under specified conditions.Met all acceptance criteria.
    Torsional StrengthDevice exhibits sufficient torsional strength.Met all acceptance criteria.
    Tensile TestingDevice components meet tensile strength requirements.Met all acceptance criteria.
    Simulated UseDevice performs as expected during simulated operation.Functioned as intended.
    Radial ForceDevice exerts appropriate radial force.Met all acceptance criteria.
    Corrosion TestingDevice materials demonstrate resistance to corrosion.Met all acceptance criteria.
    Compatibility TestingDevice is compatible with specified ancillary devices/materials.Met all acceptance criteria.
    Clot removal testingDevice effectively removes clots under specified conditions.Met all acceptance criteria, functioned as intended, and has a performance profile that is similar to the predicate devices (specific to clot removal effectiveness in vitro).
    BiocompatibilityDevice materials are biocompatible per ISO 10993-1.Biocompatible and meets requirements per ISO 10993-1 (leveraging testing from predicate device for Cytotoxicity, Sensitization, Intracutaneous Irritation, Acute System Toxicity, Material Mediated Pyrogenicity, Hemolysis, Complement Activation, Thrombogenicity).
    SterilizationSterilization method is effective and validated.Assessed through sterilization adoption (leveraged from predicate due to limited device change).
    PackagingPackaging protects device and maintains sterility.Leveraged from predicate due to limited device change.

    Study Details: Non-Clinical Bench Testing

    Since this is a thrombectomy device and the submission is for 510(k) clearance based on substantial equivalence, the "study" referred to is a series of in vitro bench tests.

    1. Sample Size Used for the Test Set and Data Provenance:

      • The document does not explicitly state the specific number of units tested for each non-clinical test (e.g., how many devices were subjected to kink resistance or tensile testing). This level of detail is typically found in the full 510(k) submission, not the summary.
      • Data Provenance: All data is from in vitro bench testing conducted by the manufacturer, Contego Medical, Inc. The country of origin for this testing is not specified, but it would typically be conducted at the manufacturer's facilities or a contracted testing lab. This is by definition retrospective in the sense that the testing is performed before submission for clearance.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

      • Not Applicable. For non-clinical bench testing of a medical device, "ground truth" is established by engineering specifications, validated test methods, and industry standards (e.g., ISO standards). There are no "experts" establishing a clinical judgment ground truth in this context. The "experts" involved would be the design engineers, quality engineers, and test technicians who define the test protocols and interpret the results against the defined acceptance criteria.
    3. Adjudication Method for the Test Set:

      • None Applicable. Adjudication methods like "2+1" or "3+1" are used in clinical studies or image interpretation studies where multiple human readers' opinions need to be reconciled to establish a ground truth. For bench testing, results are typically objective measurements compared directly against predetermined pass/fail criteria.
    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

      • No, not done. An MRMC study is relevant to diagnostic imaging devices or other technologies where human interpretation is involved. This device is a mechanical thrombectomy device; its performance is evaluated by its physical characteristics and efficacy in removing thrombus in a lab setting, not by aiding human readers in diagnosis.
    5. Standalone (Algorithm Only Without Human-in-the-Loop Performance):

      • Not Applicable. This device is an invasive medical device, not a software algorithm. Its use inherently involves a human operator (a clinician) and is not "standalone" in the sense of an unassisted algorithm making decisions.
    6. Type of Ground Truth Used:

      • For the non-clinical testing, the "ground truth" is defined by:
        • Engineering specifications and design requirements: For dimensional, kink resistance, torsional strength, tensile, radial force, and corrosion testing.
        • Validated test methods and industry standards (e.g., ISO 10993-1): For biocompatibility, simulated use, and clot removal testing.
        • Manufacturer's internal quality standards.
    7. Sample Size for the Training Set:

      • Not Applicable. The concept of a "training set" applies to machine learning algorithms. This device is a physical, mechanical medical device, not an AI/ML system.
    8. How the Ground Truth for the Training Set Was Established:

      • Not Applicable. As above, there is no training set for this type of device.
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    K Number
    K230030
    Date Cleared
    2023-05-30

    (145 days)

    Product Code
    Regulation Number
    870.5150
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Excipio® SV Aspiration Catheter and Tubing is indicated for the non-surgical removal of fresh, soft emboli and thrombi from peripheral blood vessels.

    Device Description

    The Excipio SV Aspiration Catheter and Tubing consists of an aspiration catheter which is a single, large inner lumen catheter with a hydrophilic coating (20cm outside the distal end) designed to navigate through the peripheral vasculature and provide the maximum luminal area for aspiration. The aspiration catheter will be available in 7F and 8F sizes. Sterile, single use aspiration tubing will be distributed to facilitate a vacuum connection between the aspiration catheter and the collection canister of the vacuum pump.

    AI/ML Overview

    Since the provided text describes a medical device (catheter and tubing) rather than an AI/ML powered device, the requested information (such as sample size for test set, number of experts for ground truth, MRMC study, standalone performance, training set size, etc.) is not applicable or available in the document.

    The document discusses the non-clinical testing performed to establish substantial equivalence of the Excipio SV Aspiration Catheter and Tubing to a predicate device.

    Here's a summary of the available information based on the provided text, focusing on the acceptance criteria and performance data for this type of medical device:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Tests/AssessmentsReported Device Performance
    Excipio SV Aspiration CatheterVisual InspectionMet all acceptance criteria
    Dimensional InspectionMet all acceptance criteria
    Kink Resistance (material property)Met all acceptance criteria
    Torsional StrengthMet all acceptance criteria
    Tensile TestingMet all acceptance criteria
    Functional Testing: Vacuum CollapsePerformed similarly to the predicate device, functioned as intended
    Functional Testing: Kink ResistancePerformed similarly to the predicate device, functioned as intended
    Functional Testing: Torque TestingPerformed similarly to the predicate device, functioned as intended
    Functional Testing: Tip PullPerformed similarly to the predicate device, functioned as intended
    Functional Testing: Proximal Shaft to LuerPerformed similarly to the predicate device, functioned as intended
    Functional Testing: Coating LengthPerformed similarly to the predicate device, functioned as intended
    Coating IntegrityMet all acceptance criteria
    Particulate TestingMet all acceptance criteria
    TubingDimensional InspectionMet all acceptance criteria
    Tensile TestingMet all acceptance criteria
    Functional Testing: Vacuum CollapsePerformed similarly to the predicate device, functioned as intended
    Functional Testing: Kink ResistancePerformed similarly to the predicate device, functioned as intended
    System-level TestingSimulated Use TestingPerformed similarly to the predicate device, functioned as intended
    Visual InspectionMet all acceptance criteria
    Tubing TestingMet all acceptance criteria
    Packaging and Sterile Barrier TestingMet all acceptance criteria
    Biocompatibility (Catheter)Cytotoxicity, Sensitization, Irritation, Acute System Toxicity, Material Mediated Pyrogenicity, Hemolysis, Complement Activation, ThrombogenicityResults showed the device to be biocompatible
    Biocompatibility (Tubing)Cytotoxicity, Sensitization, IrritationResults showed the device to be biocompatible
    GLP Animal Study (Porcine)In vivo thrombogenicity, acute performance, and safetyUsable, non-thrombogenic, raised no new safety questions

    2. Sample Size for Test Set and Data Provenance

    • Sample Size for Test Set: Not specified for individual bench tests. The animal study was conducted using a "porcine model," but the number of animals is not provided.
    • Data Provenance: The "non-clinical laboratory testing" and "in vitro bench tests" were performed, indicating laboratory-generated data. The "GLP animal study (porcine)" indicates live animal data. Countries of origin are not specified for these tests. The data appears to be prospective as it was performed to support the 510(k) submission.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    • This information is not applicable and not provided. The testing described involves objective physical and biological measurements, not expert interpretation of outputs like in AI/ML performance evaluation.

    4. Adjudication Method

    • This information is not applicable and not provided. The testing described involves objective measurements against predefined criteria.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No, an MRMC comparative effectiveness study was not done. This type of study is relevant for evaluating the impact of AI on human reader performance, which is not applicable to this medical device submission.

    6. Standalone Performance

    • The document describes "Non-Clinical Testing/Performance Data" and "in vitro bench tests" which evaluate the device's performance properties as a standalone product (i.e., algorithm only without human-in-the loop performance). The animal study also evaluated standalone performance in an in-vivo setting.

    7. Type of Ground Truth Used

    • The "ground truth" for this device type is established by:
      • Engineering specifications and standards: For dimensional, strength, and functional tests (e.g., kink resistance, tensile strength, vacuum collapse).
      • Validated biological assays: For biocompatibility tests (e.g., cytotoxicity, hemolysis).
      • In-vivo observations and measurements: For the GLP animal study (e.g., thrombogenicity, acute performance, safety).

    8. Sample Size for the Training Set

    • This information is not applicable and not provided. There is no AI/ML component described, so no 'training set' is used.

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

    • This information is not applicable and not provided, as there is no AI/ML component or training set.
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