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510(k) Data Aggregation

    K Number
    K250276
    Manufacturer
    Date Cleared
    2025-05-15

    (104 days)

    Product Code
    Regulation Number
    870.3300
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Embolization Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Nitinol Enhanced Device (NED) is intended for arterial and venous embolization in the peripheral vasculature. This device is not intended for neurovascular use.

    Device Description

    The NED system is comprised of polymer-based occlusion devices intended for embolization procedures in 3-6 mm vessels of the peripheral vasculature. It is intended to be used with 0.027" labeled microcatheters. The NED consists of three components: the NED implants (framing and packing), the delivery system, which is supplied engaged with the implant, and the transfer/removal tool.

    The NED framing and packing implants are permanently implanted and include a 0.016" diameter polymer filament which compacts upon delivery. The implants work together to obstruct blood flow in the vessel. The framing implant is deployed first to form the initial pack and create a backing for additional implants to be deployed in accordance with physician discretion. The deployment of the framing implant is followed by the deployment of packing implants, the quantity of which is determined by the physician based on vessel size and occlusion. The physician also has the option to finish the implant pack with another framing implant. The UHMWPE braid on the implants and the nylon 6,6 tails on the packing implant provide a scaffold for thrombus to form and attach. The combination of the mechanical obstruction of blood flow and the formation of thrombus result in vessel occlusion.

    The delivery system is comprised of two components: the implant pusher and the introducer. The NED delivery system comes with the NED implant pre-loaded in its package, sterile and ready for use. The pusher is a 180 cm long 0.022" diameter single super-elastic nitinol wire with a 30 cm PTFE jacket and a platinum/iridium radiopaque marker near its distal end. The nitinol pusher coupler is located on the distal end of the pusher, which as described above, serves to engage with the coupler on the implant's proximal end. The NED pusher allows the physician to reposition the NED to ensure preferred vessel positioning prior to detachment. Further, the detachment mechanism provides the physician the ability to completely withdraw the NED before detachment, should a condition result that necessitates its removal. The introducer is a PTFE tube used to protect the implant and maintain coupling between the implant and pusher prior to use (as described in Section 2.1). Once the implant and pusher are transferred into the delivery microcatheter, the introducer is discarded.

    The transfer/removal tool is a disposable accessory included with the device that attaches to the hub of the delivery microcatheter prior to inserting the implant. The purpose of the transfer/removal tool is to facilitate the transfer of the implant from the device introducer into the delivery microcatheter hub and to facilitate the removal of the implant from the delivery microcatheter if necessary. The transfer/removal tool is designed to fit 0.027" labeled microcatheters. The tool is comprised of an ABS and PC Luer adapter assembly bonded with medical grade Dymax 1162-M UV adhesive. The tool utilizes a spring-loaded 300 series stainless steel tube to form the lumen.

    AI/ML Overview

    This FDA 510(k) clearance letter pertains to a physical medical device, the Nitinol Enhanced Device (NED), not a device that relies on algorithms/AI in a way that necessitates the detailed criteria requested. Therefore, many of the requested fields are not applicable or cannot be extracted from the provided document.

    The document primarily focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance testing for a vascular embolization device. It does not involve AI or software-driven performance assessment, and thus lacks information on acceptance criteria for AI performance, human expert evaluation, MRMC studies, or training/test set specifics for algorithms.

    However, I can extract the relevant non-clinical performance data and the study details that were provided to demonstrate the device meets its requirements for substantial equivalence.


    Acceptance Criteria and Study for Nitinol Enhanced Device (NED)

    The Nitinol Enhanced Device (NED) is a physical medical device, specifically a vascular embolization device. The provided FDA 510(k) clearance letter does not describe an AI/software-driven device, therefore, many of the typical acceptance criteria and study details associated with such devices (e.g., AI performance metrics, expert adjudication, training/test set sizes for algorithms) are not applicable to this submission.

    Instead, the device's acceptance criteria are met through a series of non-clinical performance tests designed to demonstrate the device's safety, functionality, and substantial equivalence to a legally marketed predicate device.

    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a physical medical device without explicit AI performance metrics, the "acceptance criteria" are generally implied by successful completion of various engineering, biocompatibility, and functional tests according to established standards. The "reported device performance" refers to the successful outcome of these tests.

    Acceptance Criteria CategorySpecific Test/StandardReported Device Performance
    Material & Design SafetyNitinol Corrosion TestingPassed all testing (in accordance with ASTM F2129 and ASTM F3044)
    Product Evaluation for Sharp EdgesPassed all testing
    Chemical Characterization of MaterialsPassed all testing (including ICP-MS, GC/MS, LC/MS, Headspace GC/MS, and Toxicological Risk Assessment)
    Biocompatibility EvaluationPassed all testing (per ISO 10993-1)
    End-to-End Tensile StrengthPassed all testing
    Fiber Pull-Out ForcePassed all testing
    Functional PerformanceSuccessful DeploymentPassed all testing
    Ease of DeliveryPassed all testing
    Delivery and Deployment Force TestingPassed all testing
    Retraction Force TestingPassed all testing
    Detachment Mechanism TestingPassed all testing
    Vessel Distension MeasurementPassed all testing
    Compatibility with Delivery CathetersPassed all testing
    Visual Inspection Post-deploymentPassed all testing
    Implant with Delivery System Removal TestPassed all testing
    Implant Retrieval TestPassed all testing
    Imaging CompatibilityRadiopacity TestPassed all testing
    MRI CompatibilityPassed all testing (MR Cond Up to 3.0 Tesla specified)
    CT Artifact EvaluationPassed all testing
    Pre-Clinical/In VivoGLP Safety Study (Acute Ovine Study)Passed all testing
    GLP Subchronic Ovine Product Validation StudyPassed all testing
    Sterilization & Shelf LifePackaging IntegrityPassed all testing
    Shelf Life Validation (packaging and device)Passed all testing

    2. Sample Size Used for the Test Set and Data Provenance

    This information is not detailed in the provided 510(k) summary. For physical device testing, sample sizes are typically determined based on statistical requirements for each specific test (e.g., number of units tested for tensile strength, number of animals in GLP studies). The document only states that the device "passed all testing."

    • Test Set Sample Size: Not specified for individual tests.
    • Data Provenance: The GLP Safety Study (Acute Ovine Study) and GLP Subchronic Ovine Product Validation Study were conducted using ovine (sheep) models. Details on the origin of the animals or whether these were prospective studies are not provided, but GLP (Good Laboratory Practice) studies are inherently prospective and controlled. The in-vitro and bench testing would have been conducted in a laboratory setting.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    Not Applicable. This device is not an AI/software device requiring human expert ground truth for image interpretation or similar tasks. The "ground truth" for this device's performance is established by objective measurements against engineering specifications, biological responses in animal models, and adherence to established standards.

    4. Adjudication Method for the Test Set

    Not Applicable. There was no human expert adjudication of results as there were no subjective clinical assessments of AI performance or image interpretation involved. Performance was assessed through objective measurements and compliance with standards.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC study was not done. This type of study is relevant for AI-assisted diagnostic or interpretative devices. The NED is a physical embolization device.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not Applicable. The NED is a physical medical device; there is no 'algorithm only' component to evaluate.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance is based on:

    • Engineering Specifications: Successful completion and meeting pre-defined requirements for mechanical properties (e.g., tensile strength, detachment force), delivery characteristics, and material compatibility.
    • Established Standards: Adherence to national and international standards (e.g., ASTM, ISO 10993-1) for material properties (corrosion, biocompatibility) and functional tests.
    • Biological Outcomes: In vivo studies (Acute Ovine Study, Subchronic Ovine Product Validation Study) provided ground truth on the biological response to the implanted device, including safety and product validation in a living system.

    8. The Sample Size for the Training Set

    Not Applicable. There is no 'training set' as this is not an AI/machine learning device.

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

    Not Applicable. There is no 'training set' or associated ground truth establishment process for this type of device.

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