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510(k) Data Aggregation
(169 days)
The Zenith Flex Aspiration System, including the 046 Zenith Flex Catheter, Aspiration Tubing Set, and VC-701 Cliq Aspirator Pump, is indicated in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who failed IV t-PA therapy are candidates for treatment.
The InNeuroCo 046 Zenith Flex Catheter is a variable stiffness catheter that has a catheter shaft reinforced with Nitinol to provide support. The proximal section has an embedded nitinol flat wire cross coil that transitions to a nitinol round wire sinqle coil in the distal end. It has a radiopaque Platinum/Iridium marker band on the distal end. The 046 Zenith Flex Catheter is available with an internal diameter of 0.046 inches. The outer diameter is 0.058 inches along the proximal shaft and 0.056 inches at the distal tip. The 046 Zenith Flex Catheter is available in two working lengths: 153 cm, and 160 cm. The 046 Zenith Flex Catheter has a PTFE-lined lumen to reduce friction as it travels over a guidewire. Accessories included with the device are a Tuohy-Borst Hemostasis Valve and peel-away introducer. The 046 Zenith Flex Catheter is supplied sterile, non-pyrogenic, and intended for single use only.
The other system components are: the Aspiration Tubinq Set and the VC-701 Cliq Aspirator Pump. The Aspiration Tubing Set is provided sterile and is intended for single use only. The aspiration pump is provided non-sterile and is used in multiple procedures.
The provided document is a 510(k) premarket notification for a medical device, the Zenith Flex Aspiration System (046 Zenith Flex Catheter). It primarily focuses on demonstrating substantial equivalence to a legally marketed predicate device (Penumbra 3 Max) and a reference device (071 Zenith Flex System).
The document does not describe an AI/ML-driven medical device, nor does it detail a study involving human readers or the establishment of ground truth in the context of diagnostic AI. Instead, it details the physical and mechanical performance testing of a catheter and its accessories. Therefore, many of the requested details, such as those related to AI algorithm performance, ground truth, expert adjudication, or MRMC studies, are not applicable to this document.
However, I can extract the acceptance criteria and performance information as presented for the physical device.
Here's a breakdown of the requested information based on the provided document:
1. A table of acceptance criteria and the reported device performance
The document provides a comprehensive table of non-clinical tests, their methods, acceptance criteria, and conclusions. Since the "performance" for all these tests is simply stated as having "met the acceptance criteria" or "passed," this table effectively serves as the performance report. I will summarize key categories, as a direct copy of the entire table would be extensive.
| Test Category | Test Method Summary | Acceptance Criteria | Reported Device Performance (Conclusions) |
|---|---|---|---|
| Biocompatibility | ISO 10993 Series (e.g., -4, -5, -10, -11) | - Must not cause febrile reaction > 0.5°C- Reactivity grade < 2- Hemolytic index < 5%- No statistical decrease in UPTT- No statistical increase in C3a or SC5b-9- Thrombus formation score <= control- Positive response in < 10% animals- Not induce significantly greater biological reaction than control | - Zenith Flex Catheter (K172167) results leveraged, as materials and processes are equivalent. All test articles met acceptance criteria.- Aspiration Tubing Set (identical to K172167 component) results leveraged. All test articles met acceptance criteria. |
| Physical & Mechanical | ISO 10555-1, ISO 80369, USP 788 (as guide), Benchtop anatomical model, Force gauge | - Within existing working length, diameter, and particulate specifications.- Meet existing Luer specifications.- Meet or exceed existing leak, burst pressure, tensile strength, torque, kink resistance, and lumen patency specifications.- No evidence of corrosion.- Meet or exceed PTFE Liner and Hydrophilic Coating Integrity specifications.- Withstand chemical exposure without degradation. | - All Zenith Flex Catheter test samples met acceptance criteria for Working Length, Hub compatibility, Diameters, Leak (Air/Liquid), Particulates, Catheter Burst, Tensile, PTFE Liner inspection, Hydrophilic Coating Integrity, Toque Strength, Kink Resistance, Lumen Patency, and Chemical Compatibility.- Performed comparatively against predicate device in Tip Flexibility and Friction Force.- All Aspiration Tubing Set test samples met acceptance criteria (many leveraged from K172167) for Visual Inspection, Tensile, Leak (Liquid/Air), Luer Compatibility, Suction Connector Separation Force, Vacuum Drop/Suction Connector Secure Attachment, Lumen Patency, and Dimensions. |
| Performance (Simulated Use) | Physician in a benchtop model, Simulated model with thrombi and aspiration pump | - Test samples must meet predetermined user needs.- Successfully removed thrombi. | - Zenith Flex Catheter test samples met the acceptance criteria for Simulated Use - Bench.- Zenith Flex System test samples met the acceptance criteria for Simulated Use – Usability and Aspiration (successfully removed thrombi). |
| Sterilization & Shelf Life | ISO 11135, AAMI TIR 28, ASTM F1980, ASTM F1929-12, ASTM F88-09 | - Sterilization load poses equal or lesser challenge.- Aged samples meet or exceed existing specifications.- No visual leaks or channels.- Tensile strength meets or exceeds existing specifications. | - Sterilization loads met acceptance criteria for Zenith Flex and Aspiration Tubing Set (leveraged from K172167).- Zenith Flex Catheter test samples met acceptance criteria for shelf life. Aspiration Tubing Set shelf life leveraged from K172167. All packaging tests (Dye Leak, Peel) for both catheter & tubing set met criteria (many leveraged from K172167). |
| Accessories (Peel-Away) | Pull to failure, Measurement of unsplit length and diameters | - Tensile strength meets or exceeds specified.- Length and diameter measurements meet specified. | - Peel-Away Introducer tests for Peel Force, Unsplit Length, and Diameters leveraged from K172167 and met acceptance criteria. |
| Accessories (Hemostasis) | Exposed to chemicals, Inside diameter measurement | - Withstand chemical exposure without degradation.- Inside diameter measurement meets specified. | - Hemostasis Valve tests for Chemical Compatibility and Dimensional leveraged from K172167 and met acceptance criteria. |
| Labeling | Visual inspection after printing, Readability with standard barcode reader | - Demonstrate text legibility.- Demonstrate readily readable barcodes. | - Labeling Legibility and Barcode tests leveraged from K172167 and met acceptance criteria. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: The document repeatedly states that "test samples" were used for various non-clinical (benchtop) and animal tests, and that these samples "met the acceptance criteria." However, it does not explicitly state the specific sample size (N) for each individual test. It implies N>0 and that enough samples were tested to demonstrate compliance.
- Data Provenance:
- Non-Clinical (Bench) Testing: This was conducted by InNeuroCo, Inc. (location: Sunrise, Florida, USA). The testing was done in a controlled lab environment.
- Animal Testing: Conducted in swine, implying a prospective study design for the animal component. The document does not specify the country of origin for the animal study, but given the company's US location and FDA submission, it's likely primarily US-based or conducted under equivalent regulatory standards.
- Clinical Data (Literature Review): A review of "published clinical study articles" was conducted. This refers to existing, likely retrospective, clinical data from external sources and studies. No new clinical trials were performed for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. This document describes a physical medical device (catheter system) and its performance validation through bench and animal testing. It does not involve diagnostic imaging or AI for which ground truth established by experts would be relevant. The "ground truth" for this device's performance is objective measurements (e.g., dimensions, burst pressure, tensile strength, successful thrombi removal in models) and histopathological/angiographic assessments in animal models.
- A "physician" was involved in "simulated use testing," but this was for usability and performance in a benchtop model, not for establishing a diagnostic ground truth. Their qualifications are not specified beyond being a "physician."
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. As an AI/ML related concept, adjudication by multiple experts is not relevant to the physical and mechanical testing of a catheter system.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No, not applicable. This document is for a physical medical device (catheter) and does not involve AI or human readers for diagnostic purposes.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No, not applicable. This is not an AI/ML device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For non-clinical bench testing: The "ground truth" for acceptance was based on predefined physical, mechanical, and performance specifications (e.g., measurements being within specified ranges, successful functional outcomes like thrombi removal, absence of leaks or degradation).
- For animal testing: The "ground truth" for effectiveness and safety was based on angiographic assessment of revascularization and histopathological assessment.
8. The sample size for the training set
- Not applicable. This is not an AI/ML device, so there is no "training set."
9. How the ground truth for the training set was established
- Not applicable. As there is no AI/ML component, there is no training set or associated ground truth establishment process in that context.
Ask a specific question about this device
(275 days)
The Zenith Flex System, including the Zetheter, Aspiration Tubing Set, and VC-701 Cliq Aspirator Pump, is indicated in the revascularization of patients with acute secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who failed IV t-PA therapy are candidates for treatment.
The Zenith Flex System consists of the Zenith Flex Catheter, the VC-701 Cliq Aspiration Pump and the Aspiration Tubing Set. The InNeuroCo Zenith Flex Catheter is a variable stiffness catheter shaft reinforced with Stainless-Steel and Nitinol to provide support. The Stainless-Steel is wound as a double coil in the proximal section and the Nitinol is a single coil in the distal section. It has a radiopaque Platinum/Iridium marker band on the distal end. The distal 25 cm of the Zenith Flex Catheter has a hydrophilic coating. The Zenith Flex Catheter is available with an internal diameter of 0.0715 inch. The outer diameter is of 0.0850 inch in the proximal section, and tapers to a nominal of 0.082 inch in the distal section. The Zenith Flex Catheter is available in three working lengths: 115 cm, 125 cm, and 132 cm. Accessories included with the device are a Tuohy-Borst Hemostasis Valve and two peel-away Introducers and a Scout introducer. The Scout may be used to introduce the Zenith Flex Catheter into distal vasculature, thereby helping the device reach the target anatomy. The Zenith Flex Catheter is supplied sterile, nonpyrogenic, and intended for single use only. The off-the-shelf aspiration pump is provided non-sterile.
This document is a 510(k) summary for the Zenith Flex System, a medical device for revascularization in acute ischemic stroke. It primarily focuses on demonstrating substantial equivalence to a predicate device through non-clinical (bench and animal) testing rather than clinical study. Thus, it does not describe a study involving an AI component or complex ground truth establishment for diagnostic output.
Here's an analysis based on the provided text, addressing your points where information is available:
1. A table of Acceptance Criteria and Reported Device Performance
The document provides extensive tables summarizing non-clinical testing. Here's a consolidated and simplified version of the information, focusing on the Zenith Flex Catheter, Aspiration Tubing Set, and VC-701 Cliq Aspirator Pump:
| Test Category | Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Biocompatibility | ||
| Pyrogenicity | Test article extracts must not cause a febrile reaction > 0.5°C in any individual subject. | Met acceptance criteria. (Leveraged from K171672, as materials/manufacturing are equivalent). |
| Cytotoxicity (MEM Elution) | Cultures treated with the test article must not have a reactivity grade > 2. | Met acceptance criteria. (Leveraged from K171672 for Catheter, and directly tested for Aspiration Tubing Set). |
| Hemolysis | Hemolytic index above negative control article must be < 5%. | Met acceptance criteria. (Leveraged from K171672). |
| Unactivated Partial | No statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | Met acceptance criteria. (Leveraged from K171672). |
| Thromboplastin Time (UPTT) | ||
| Complement Activation | No statistical increase between C3a or SC5b-9 concentrations in plasma exposed to the test article as compared to negative and untreated controls. | Met acceptance criteria. (Leveraged from K171672). |
| Thromboresistance | Test articles must receive a thrombus formation score less than or equal to that of the control. | Met acceptance criteria. (Leveraged from K171672). |
| Maximization Sensitization | Test article must elicit a positive response in < 10% of the test animals. | Met acceptance criteria. (Leveraged from K171672 for Catheter, and directly tested for Aspiration Tubing Set). |
| Intracutaneous Toxicity | Test article extracts must not induce a significantly greater biological reaction than the control. | Met acceptance criteria. (Leveraged from K171672 for Catheter, and directly tested for Aspiration Tubing Set). |
| Acute Systemic Toxicity | Test article extracts must not induce a significantly greater biological reaction than the control. | Met acceptance criteria. (Leveraged from K171672). |
| Physical/Mechanical Performance (Zenith Flex Catheter) | ||
| Chemical Compatibility | Product shall withstand exposure to chemicals without degradation. | Met acceptance criteria. |
| Radiographic Detectability | Product shall be visible under fluoro imaging. | Met acceptance criteria. |
| Visual Inspection | Test samples should meet visual inspection specifications. | Met acceptance criteria. |
| Working Length | Test samples should be within existing working length specification. | Met acceptance criteria. |
| Hub Compatibility | Hub shall meet existing Luer specifications. | Met acceptance criteria. (Leveraged from K171672). |
| Outside Diameter | Test samples should be within existing outside diameter specification. | Met acceptance criteria. |
| Leak - Air | Test samples should be within existing Air - Leak specifications. | Met acceptance criteria. |
| Leak - Liquid | Test samples should be within existing Leak - Liquid specifications. | Met acceptance criteria. |
| Particulates | Test samples should be within existing Particulate specifications. | Met acceptance criteria. |
| Simulated Use - Bench | Test samples must meet predetermined user needs. | Met acceptance criteria. |
| Catheter Burst | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | Met acceptance criteria. |
| Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Met acceptance criteria. |
| Corrosion | Test samples shall exhibit no evidence of corrosion. | Met acceptance criteria. (Leveraged from K152202). |
| Packaging - Dye Leak | Test sample shall not exhibit any visual leaks or channels. | Met acceptance criteria. (Leveraged from K171672 for Catheter, and directly tested for Catheter and Aspiration Tubing Set). |
| Packaging - Peel | Test sample tensile strength must meet or exceed existing tensile strength specifications. | Met acceptance criteria. (Leveraged from K171672 for Catheter, and directly tested for Catheter and Aspiration Tubing Set). |
| Kink Resistance | Test sample kink resistance must meet or exceed existing Kink Resistance specifications. | Met acceptance criteria. |
| Torque | Test sample torque results must meet or exceed existing torque specifications. | Met acceptance criteria. |
| PTFE Liner Inspection | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | Met acceptance criteria. |
| Hydrophilic Coating | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | Met acceptance criteria. |
| Integrity | ||
| Lumen Patency | Test sample results must meet or exceed existing lumen patency specifications. | Met acceptance criteria. |
| Tip Flexibility | Zenith Flex tip flexibility results were compared to predicate device results. | Performed comparatively against the predicate device. |
| Friction Force | Zenith Flex friction force results were compared to predicate device results. | Performed comparatively against the predicate device. |
| System Performance (Zenith Flex System) | ||
| Aspiration | Successfully removed the thrombi. | Met acceptance criteria. |
| Simulated Use - Usability | Test samples must meet predetermined user needs. | Met acceptance criteria. |
| Sterilization | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | Met acceptance criteria. |
| Shelf Life | Aged test samples must meet or exceed existing specifications. | Met acceptance criteria. |
| Aspiration Tubing Set Specific | ||
| Visual Inspection | Test samples should meet visual inspection specifications. | Met acceptance criteria. |
| Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Met acceptance criteria. |
| Leak - Liquid | Test samples should be within existing Leak - Liquid specifications. | Met acceptance criteria. |
| Leak - Air (Tubing & Control Switch) | Test samples should be within existing Air - Leak specifications. | Met acceptance criteria. |
| Luer Compatibility | Hub shall meet existing Luer specifications. | Met acceptance criteria. |
| Suction Connector | Test sample results must meet or exceed existing force specifications. | Met acceptance criteria. |
| Separation Force | ||
| Vacuum Drop / Suction | Test sample results must meet or exceed existing pressure specifications. | Met acceptance criteria. |
| Connector Secure Attachment | ||
| Lumen Patency | Test sample results must meet or exceed existing lumen patency specifications. | Met acceptance criteria. |
| Dimensions | Test samples should be within existing dimensional specifications. | Met acceptance criteria. |
| Labeling | ||
| Labeling Legibility | Test samples shall demonstrate text legibility. | Met acceptance criteria. (Leveraged from K171672). |
| Barcode | Test samples shall demonstrate readily readable barcodes. | Met acceptance criteria. (Leveraged from K171672). |
2. Sample Size Used for the Test Set and the Data Provenance
- Test Set Sample Size: The document does not explicitly state numerical sample sizes for each non-clinical test (e.g., "N=X catheters were tested"). It refers to "test samples" for bench testing and describes animal testing involving "several arteries of swine." For some tests, it states that results were "leveraged" from a previous submission (K171672 or K152202), implying a previous sample size was deemed sufficient for those components/materials.
- Data Provenance: The data is primarily from non-clinical (bench and animal) testing.
- Animal Testing: Performed on "swine." There's no indication of country of origin for the animal study, but given the FDA submission, it's presumed to be from a facility following GLP (Good Laboratory Practices). The study was prospective in nature for this device.
- Bench Testing: Performed in a lab setting. No country of origin is specified, but again, standard practice for FDA submissions implies testing in a controlled environment.
- Leveraged Data: Some results are leveraged from previous 510(k) submissions (K171672 for Zenith Catheter, and K152202 for Corrosion, for an "Intermediate Catheter"). This suggests the data was generated at an earlier time for similar or identical components/processes.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
There is no mention of "experts" in the context of establishing ground truth for a test set in the way one would for an AI/diagnostic device. The "ground truth" here is based on:
- Standardized Test Methods: Adherence to ISO, ASTM, and USP standards (e.g., ISO 10993-1, ISO 10555-1, ASTM F1929-12, USP 788, etc.). These methods define the criteria and procedures for measuring various physical, chemical, and biological properties.
- Animal Model Outcomes: In the animal study, effectiveness was assessed via "angiographic assessment of revascularization" and safety via "angiographic assessment and histopathological assessment." These assessments would be performed by qualified veterinary or medical professionals (e.g., veterinarians, pathologists), but their specific number or qualifications are not provided here.
- Physician Feedback: For "Simulated Use - Bench" and "Simulated Use - Usability" tests, it states "simulated use testing by a physician in a benchtop model." The number and specific qualifications of these physicians are not detailed.
4. Adjudication Method for the Test Set
Not applicable in the context of this submission. Adjudication typically applies to human interpretation of diagnostic data, which is not the primary focus here. The assessment of non-clinical tests relies on quantitative measurements against pre-defined acceptance criteria, or expert observation (e.g., pathologist reading histology slides), but not formal adjudication of conflicting expert opinions for ground truth.
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 specifically designed for evaluating the impact of AI on human reader performance in diagnostic imaging, which is not relevant for this device. The submission explicitly states: "No clinical study was conducted as bench and animal testing was determined sufficient for verification and validation purposes."
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This device, the Zenith Flex System (catheter, aspiration tubing, pump), is a physical medical device, not a software algorithm or AI tool. Therefore, "standalone" performance in the sense of an algorithm operating independently is not applicable. Its performance is measured through its physical and functional properties, and its interaction with biological systems (in the animal model).
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is established through:
- Quantitative Measurements: Direct measurements of physical properties against engineering specifications (e.g., diameter, length, tensile strength, burst pressure, leak rates).
- Biocompatibility Standards: Adherence to ISO 10993 guidelines, which define acceptable biological responses.
- Angiographic and Histopathological Assessment: For the animal study, the "effectiveness" (revascularization) and "safety" (tissue response, thrombus formation) endpoints were evaluated using these clinical and pathological methods. This is the closest to "outcomes data" or "pathology" in your list.
- Physician Feedback: For simulated use, "predetermined user needs" served as the criteria.
8. The Sample Size for the Training Set
Not applicable. This is a traditional medical device (catheter system), not an AI/machine learning device. Therefore, there is no "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this device.
Ask a specific question about this device
(53 days)
The Zenith Support Catheter is indicated for the introduction of interventional devices into the peripheral and neuro vasculature.
The InNeuroCo Zenith Support product consists of a catheter, a hemostasis valve, and a split sheath introducer. The Zenith Support catheter is a single lumen, variable stiffness catheter that has an outer polymer shaft and is reinforced with a Stainless Steel cross coil. The Zenith Support catheter has a radiopaque Platinum/Iridium marker band on the distal end. The Zenith Support is available with an internal diameter of 0.074 inches and a nominal outer diameter of 0.086 inches. There are three working lengths available: 95 cm, 105 cm, and 115 cm in either diameter. The Zenith Support catheter has a PTFE-lined lumen throughout the catheter shaft. The catheter is flexible and has a hydrophilic coating. The Zenith Support catheter is inserted through a guide catheter or vascular sheath, provides access to the target site, and once in place, provides a reinforcing conduit for other intravascular devices. Accessories included with the device are a Tuohy-Borst hemostasis valve with an extension luer and a split sheath introducer. The Zenith product line is supplied sterile, non-pyrogenic, and intended for single use only.
This request concerns the InNeuroCo Zenith Support Catheter, a percutaneous catheter used for introducing interventional devices into the peripheral and neuro vasculature. The provided document is a 510(k) premarket notification summary, which focuses on demonstrating substantial equivalence to a predicate device rather than a comprehensive study for novel device acceptance criteria.
The information primarily revolves around non-clinical data and justifications for not re-testing certain parameters due to the device's similarity to its predicate. Therefore, detailed information on ground truth establishment, expert qualifications, adjudication methods, or MRMC studies is not available as this type of submission typically relies on a comparison to an already approved device.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document provides a "SUMMARY OF NON-CLINICAL DATA" (page 8, "Table 1: Non-Clinical Testing Analysis") which serves this purpose. Many tests were not re-tested for the Zenith Support Catheter because no material changes were made from the predicate device (Zenith 074) and manufacturing processes were identical or within the predicate's tolerance.
| Test | Acceptance Criteria | Reported Device Performance (Analysis/Outcome) |
|---|---|---|
| Biocompatibility | No re-testing for Zenith Support Catheter: "There are no material changes from the predicate device. Manufacturing process is identical to the predicate. Only the segment lengths were changed and pitch adjustments were within the predicate device's tolerance." This applies to all biocompatibility tests below. | |
| - Material Mediated Pyrogen | The test article extracts must not cause a febrile reaction greater than 0.5°C in any individual subject. | Not re-tested. |
| - Cytotoxicity MEM Elution | The cultures treated with the test article must not have a reactivity grade greater than 2. | Not re-tested. |
| - Hemolysis (ASTM Method, extract human blood) | The hemolytic index above the negative control article must be less than 5%. | Not re-tested. |
| - Hemolysis (ASTM method, direct contact human blood) | The hemolytic index above the negative control article must be less than 5%. | Not re-tested. |
| - Unactivated Partial Thromboplastin Time | There must be no statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | Not re-tested. |
| - Complement Activation | There must be no statistical increase between either the C3a or SC5b-9 concentrations in plasma exposed to the test article as compared to the negative and untreated controls. | Not re-tested. |
| - Dog Thromboresistance | The test articles must receive a thrombus formation score less than or equal to that of the control. | Not re-tested. |
| - Maximization Sensitization | The test article must elicit a positive response in less than 10% of the test animals. | Not re-tested. |
| - Intracutaneous Toxicity/Reactivity | The test article extracts must not induce a significantly greater biological reaction than the control. | Not re-tested. |
| - Acute Systemic Toxicity Test | The test article extracts must not induce a significantly greater biological reaction than the control. | Not re-tested. |
| Animal Testing - Angiographic Evaluation | No units tested can cause vessel injury. | Not re-tested. "The tips, materials, and transitions are identical to the predicate, and the initial evaluation for the predicate included the use of the device without the Scout Introducer." |
| Chemical Compatibility | Chemicals have no negative effect on the catheter or accessories. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Radiographic Detectability | Product shall be visible under fluoro imaging. | Not re-tested. "The marker bands are identical to the predicate." |
| Visual Inspection | Catheter shall appear free from damage, including a rounded tip and smooth transition points. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Working Length | Test samples should be within existing working length specification. | Not re-tested. "The segment lengths do not impact the cut to length step in addition the working length test compares the output to the target length." |
| Hub compatibility | Hub shall meet existing Luer specifications. | Not re-tested. "The hub is identical to the predicate device." |
| Outside Diameter | Test samples should be within existing outside diameter specifications. | Not re-tested. "OD is unaffected by the working length change." |
| Leak – Air | Test samples should be within existing Air - Leak specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Leak – Liquid | Test samples should be within existing Leak - Liquid specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Particulates | Test samples should be within existing Particulate specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Simulated Use - Bench | Test samples must meet predetermined user needs. | Re-tested Yes. "Zenith Support Catheter test samples met the acceptance criteria for Simulated Use-Bench to demonstrate that it is substantially equivalent to the predicate device." |
| Catheter Burst | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Not re-tested. "The bonds and joints are the same as the predicate Zenith 074 device. Any pitch adjustments are within the tolerance of the predicate device." |
| Corrosion | Test samples shall exhibit no evidence of corrosion. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Packaging - Dye Leak | Test sample shall not exhibit any visual leaks or channels. | Not re-tested. "The packaging is identical to the cleared reference SDA device." (Note: The reference here is to an "SDA device," not the Zenith 074 predicate, indicating identical packaging to another cleared device.) |
| Packaging - Peel | Test sample tensile strength must meet or exceed existing tensile strength specifications. | Not re-tested. "The packaging is identical to the cleared reference SDA device." (Again, referring to SDA device for packaging.) |
| Kink Resistance | Test sample kink resistance must meet or exceed existing Kink Resistance specifications. | Not re-tested. "All transitions are the same, only the location of the transition changes, in addition, the pitch adjustments are within the Zenith 074 tolerance." |
| Torque | Test sample torque results must meet or exceed existing torque specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| PTFE Liner Inspection | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Hydrophilic Coating Integrity | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | Not re-tested. "There are no material changes from the predicate device, and pitch adjustments are within the tolerance of the predicate device." |
| Labeling Legibility | Test samples shall demonstrate text legibility. | Not re-tested. "The label is almost identical to the predicate device, except that the Scout Introducer is removed from the labeling." |
| Barcode | Test samples shall demonstrate readily readable barcodes. | Not re-tested. "Barcodes are similar to the predicate." |
| Sterilization | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | Not re-tested. "The Zenith Support Catheter was adopted into the Zenith Family Sterilization Cycle." |
| Shelf Life | Aged test samples must meet or exceed existing specifications. | Not re-tested. "There are no material changes from the predicate device, therefore shelf life testing conducted for the Zenith 074 still applies." |
2. Sample Size Used for the Test Set and the Data Provenance
Due to the nature of a 510(k) summary relying on substantial equivalence, specific sample sizes for re-tested parameters (like Simulated Use - Bench) are not explicitly stated. For most tests, the data provenance is essentially inherited from the predicate device (Zenith 074) and another reference device (InNeuroCo SDA) because the new device's materials and manufacturing are identical or within tolerance. The document indicates these are non-clinical studies (benchtop and animal models for predicate devices). The geographical origin of the data is not specified beyond the manufacturer being based in Florida, USA. All studies are retrospective in relation to the current device's testing, as they refer to data from predicate devices.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This information is not provided. For non-clinical tests, "ground truth" is typically established by laboratory procedures and measurements against defined standards (e.g., ISO, ASTM). For the "Simulated Use - Bench" test, it states it was conducted "by a physician," implying at least one expert, but qualifications and number are not detailed.
4. Adjudication Method for the Test Set
Not applicable/not provided. This type of detail (e.g., 2+1, 3+1 consensus) is typical for clinical studies, especially those involving expert interpretation of medical images, which is not the focus of this non-clinical submission.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is a medical device (catheter), not an AI/Software as a Medical Device (SaMD) product. Therefore, MRMC studies and AI-assisted performance metrics are not relevant or performed for this submission.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. The device is a physical catheter, not an algorithm.
7. The Type of Ground Truth Used
For the majority of the non-clinical tests not re-performed, the "ground truth" (or accepted performance) is based on:
- Established performance of the predicate device (Zenith 074): This implies that the predicate device previously met these standards.
- International Standards (ISO 10993, ISO 10555-1, ISO 594-1, ISO 594-2, ISO 11135) and ASTM standards (ASTM F1929-12, ASTM F88-09, ASTM F1980): These standards define methodologies and acceptable ranges for material properties, biocompatibility, and device functionality.
- USP 788: For particulates.
For the re-tested "Simulated Use - Bench" test, the ground truth was "predetermined user needs," likely established through design validation or clinical input.
8. The Sample Size for the Training Set
Not applicable. The Zenith Support Catheter is a physical medical device. The concept of "training set" is relevant for AI/machine learning models, which this device is not.
9. How the Ground Truth for the Training Set was Established
Not applicable as there is no "training set" for this physical device.
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(113 days)
The 091 Long Sheath is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasulature.
The InNeuroCo, Inc. 091 Long Sheath is a variable stiffness catheter that has a catheter shaft reinforced with a stainless steel double coil. It has a radiopaque Platinum/lridium marker band on the distal end. The distal 10 cm of the 091 Long Sheath Catheter has a hydrophilic coating. The catheter has a nominal outer diameter of 0.109 inches and a nominal inner diameter of 0.091 inches. It is available in three working lengths: 70 cm, and 90 cm. The 091 Long Sheath has a PTFE-lined lumen. The 091 Long Sheath is inserted at a vascular access point to provide access to the target site and once in place, provides a reinforcing conduit for other intravascular devices. Accessories included with the device are a Tuohy-Borst Hemostasis Valve and a Vessel Dilator. The 091 Long Sheath is supplied sterile, non-pyrogenic, and intended for single use only.
The provided text is a 510(k) summary for the InNeuroCo 091 Long Sheath peripheral, coronary, and neuro vasculature catheter. It outlines the device's characteristics and its comparison to a predicate device, along with the results of performance testing to demonstrate substantial equivalence.
Based on the provided document, here's a description of the acceptance criteria and the study proving the device meets these criteria:
This document describes the validation of a medical device, the InNeuroCo 091 Long Sheath, for regulatory approval. It is not an AI/ML device, and therefore several of the requested sections (e.g., number of experts, adjudication methods, MRMC study, standalone performance, training set details) are not applicable as they relate to the validation of AI/ML algorithms, not traditional medical devices like catheters.
Acceptance Criteria and Device Performance Study for the InNeuroCo 091 Long Sheath
The InNeuroCo 091 Long Sheath is a percutaneous catheter intended for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature. The study conducted was a series of non-clinical (bench and animal) tests to demonstrate substantial equivalence to a legally marketed predicate device (Stryker AXS Infinity LS, K152876).
1. Table of Acceptance Criteria and Reported Device Performance
| Test | Test Method Summary | Acceptance Criteria | Reported Device Performance (Conclusions) |
|---|---|---|---|
| Biocompatibility-Material Mediated Pyrogen Testing | Completed per ISO 10993-11 | The test article extracts must not cause a febrile reaction greater than 0.5°C in any individual subject. | Test results for the InNeuroCo Super Distal Access (K161262) and the Zenith Catheter (K171672) were leveraged as materials and manufacturing processes are equivalent. Met acceptance criteria. |
| Biocompatibility-Cytotoxicity MEM Elution | Completed per ISO 10993-5 | The cultures treated with the test article must not have a reactivity grade greater than 2. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Hemolysis ASTM Method, extract human blood | Completed per ISO 10993-4 | The hemolytic index above the negative control article must be less than 5%. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Hemolysis, ASTM method, direct contact (human blood) | Completed per ISO 10993-4 | The hemolytic index above the negative control article must be less than 5%. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Unactivated Partial Thromboplastin Time | Completed per ISO 10993-4 | There must be no statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Complement Activation | Completed per ISO 10993-4 | There must be no statistical increase between either the C3a or SC5b-9 concentrations in plasma exposed to the test article as compared to the negative and untreated controls. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Dog Thrombogenicity | Completed per ISO 10993-4 | The test articles must receive a thrombus formation score less than or equal to that of the control. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Maximization Sensitization | Completed per ISO 10993-10 | The test article must elicit a positive response in less than 10% of the test animals. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Intracutaneous Toxicity/Reactivity | Completed per ISO 10993-10 | The test article extracts must not induce a significantly greater biological reaction than the control. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Biocompatibility-Acute Systemic Toxicity Test | Completed per ISO 10993-11 | The test article extracts must not induce a significantly greater biological reaction than the control. | Leveraged results from InNeuroCo Super Distal Access (K161262) and Zenith Catheter (K171672). Met acceptance criteria. |
| Animal Testing-Angiographic Evaluation | Product evaluated within a porcine model for clinically significant injury. | No units tested can cause vessel injury. | Test article met the acceptance criteria for Animal Testing. |
| Bench Testing - Chemical Compatibility | Catheter exposed to chemicals readily available in a clinical setting. | Chemicals have no negative effect on the catheter or accessories. | Leveraged results from InNeuroCo Super Distal Access (K161262). Met acceptance criteria. |
| Bench Testing - Visual Inspection | Completed per ISO 10555-1 | Catheter shall appear free from damage, including a rounded tip and smooth transition points. | 091 Long Sheath test samples met the acceptance criteria. |
| Bench Testing - Dimensions | Completed per ISO 10555-1 | Test samples should be within existing dimensional specifications. | 091 Long Sheath test samples met the acceptance criteria. Leveraged results for Hemostasis Valve from InNeuroCo Super Distal Access (K161262), which also met the criteria. |
| Bench Testing - Hub compatibility | Completed per ISO 594-1 and ISO 594-2 | Hub shall meet existing Luer specifications. | Leveraged results for the 091 Long Sheath and Dilator from InNeuroCo Intermediate Catheter (K152202) and for the Hemostasis Valve from Super Distal Access (K161262). All tested samples met the acceptance criteria. |
| Bench Testing - Leak - Air | Completed per ISO 10555-1 | Test samples should be within existing Air – Leak specifications. | 091 Long Sheath test samples met the acceptance criteria. |
| Bench Testing - Leak - Liquid | Completed per ISO 10555-1 | Test samples should be within existing Leak - Liquid specifications. | 091 Long Sheath test samples met the acceptance criteria. |
| Bench Testing - Particulates | Completed per USP 788 | Test samples should be within existing Particulate specifications. | 091 Long Sheath test samples met the acceptance criteria. |
| Bench Testing - Simulated Use | LS underwent simulated use testing by a physician in a benchtop model. | Test samples must meet predetermined user needs. | 091 Long Sheath test samples met the acceptance criteria. |
| Bench Testing - Catheter Burst | Completed per ISO 10555-1 | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | 091 Long Sheath test samples met the acceptance criteria. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Bench Testing - Tensile | Completed per ISO 10555-1 | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - Corrosion | Completed per ISO 10555-1 | Test samples shall exhibit no evidence of corrosion. | Leveraged results from InNeuroCo Intermediate Catheter (K152202). All samples met the acceptance criteria. -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Bench Testing - Packaging - Dye Leak | Completed per ASTM F1929-12 | Test sample shall not exhibit any visual leaks or channels. | 091 Long Sheath test samples met the acceptance criteria. -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Bench Testing - Packaging - Peel | Completed per ASTM F88-09 | Test sample tensile strength must meet or exceed existing tensile strength specifications. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - Kink Resistance | Samples are subjected to different diameters until kink is observed. | Test sample kink resistance must meet or exceed existing Kink Resistance specifications. | 091 Long Sheath test samples met the acceptance criteria. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Bench Testing - Torque | Conditioned samples are torqued to failure. | Test sample torque results must meet or exceed existing torque specifications. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - PTFE Liner inspection | LS was challenged to demonstrate liner adherence. | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - Hydrophilic Coating Integrity | Conditioned samples were repeatedly exposed to friction to demonstrate that the hydrophilic coating is not affected. | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - Labeling Legibility | Label is legible after printing. | Test samples shall demonstrate text legibility. | 091 Long Sheath test samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bench Testing - Barcode | Barcode is readable with a standard barcode reader. | Test samples shall demonstrate readily readable barcodes. | 091 Long Sheath test samples met the acceptance criteria. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Sterilization | ISO 11135 and AAMI TIR 28 | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | 091 Long Sheath sterilization load met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Bacterial Endotoxin | AAMIST72 | Test samples must meet the bacterial endotoxin acceptance criteria. | The 091 Long Sheath samples met the acceptance criteria. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| Shelf Life | ASTM F1980 | Aged test samples must meet or exceed existing specifications. | 091 Long Sheath test samples met the acceptance criteria. ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The exact sample sizes for each specific test are not explicitly enumerated in the provided summary table. The statements typically indicate "Test samples" or "All samples," implying that a sufficient number were tested according to the referenced ISO or ASTM standards.
- Data Provenance: The data is a mix of:
- Direct testing: For many bench tests (e.g., Visual Inspection, Leaks, Particulates, Simulated Use, Catheter Burst, Tensile, Kink Resistance, Torque, PTFE Liner inspection, Hydrophilic Coating Integrity, Labeling Legibility, Barcode, Sterilization, Bacterial Endotoxin, Shelf Life). These tests were conducted on the 091 Long Sheath.
- Leveraged data: For all biocompatibility tests, Chemical Compatibility, Hub compatibility, and Corrosion, data was leveraged from previously approved InNeuroCo devices (Super Distal Access K161262, Zenith Catheter K171672, and Intermediate Catheter K152202). This leveraging is justified by stating that the materials and manufacturing processes are equivalent.
- Animal Testing: Product evaluated within a porcine model for angiographic evaluation.
- Retrospective/Prospective: All described testing appears to be prospective (new tests conducted for this device and leveraged results from other devices), not retrospective analysis of existing clinical data.
- Country of Origin: Not specified in the document, but given the FDA 510(k) submission, it would be expected to follow US or internationally recognized standards. The company address is in Florida, USA.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
- Not Applicable. This is a traditional medical device (catheter) validation, not an AI/ML algorithm. Ground truth for device performance is established through standardized physical, chemical, biological, and animal testing, not human expert interpretation of data.
- For "Simulated Use" testing, it mentions "by a physician," indicating one or more physicians were involved in that specific assessment, but their number and specific qualifications are not detailed beyond "physician."
4. Adjudication Method for the Test Set
- Not Applicable. As this is not an AI/ML study, there is no need for adjudication of conflicting expert opinions on a dataset. Test results are objective measurements against defined acceptance criteria.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- No. This type of study is specifically designed for evaluating the impact of AI on human reader performance, which is not relevant for the validation of a physical medical device like a catheter.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not Applicable. There is no AI algorithm being validated in this submission. The "device" is a physical catheter.
7. The Type of Ground Truth Used
- The "ground truth" for this device's performance is established by:
- Standardized Test Methods: Adherence to established international (ISO, ASTM, USP) and industry standards for material properties, mechanical performance, biocompatibility, and sterility.
- Physical Measurements: Objective measurements of dimensions, burst pressure, tensile strength, etc.
- Chemical/Biological Assays: Results from biocompatibility tests (e.g., cytotoxicity, hemolysis, pyrogenicity, sensitization) and bacterial endotoxin tests.
- Functional Demonstrations: Successful performance in simulated use environments and in an animal model (porcine model for angiographic evaluation, showing no vessel injury).
- Predetermined Specifications: Comparison against established product specifications and the performance of the predicate device.
8. The Sample Size for the Training Set
- Not Applicable. This is not an AI/ML device, so there is no "training set."
9. How the Ground Truth for the Training Set was Established
- Not Applicable. As there is no AI/ML training set, this question is not relevant.
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(135 days)
The Zenith is indicated for the introduction of interventional devices into the peripheral and neuro vasculature.
The InNeuroCo Zenith product consists of a catheter, a hemostasis valve, two split sheath introducers, and a Scout introducer. The Zenith catheter is a single lumen, variable stiffness catheter that has an outer polymer shaft and is reinforced with a Stainless Steel cross coil. The Zenith catheter has a radiopaque Platinum/lridium marker band on the distal end. The Zenith product line is available in two internal diameters: 0.065 inches and 0.074 inches. The 0.065 catheter has a tapered design and is 0.079 inches outer diameter in the distal end and a 0.081 inches outer diameter in the proximal end. The 0.074 catheter has a nominal outer diameter of 0.086 inches. There are three working lengths available: 115 cm, 125 cm, and 132 cm in either diameter. The Zenith catheter has a PTFE-lined lumen throughout the catheter shaft. The catheter is flexible and has a hydrophilic coating. The Zenith catheter is inserted through a quide catheter or vascular sheath, provides access to the target site, and once in place, provides a reinforcing conduit for other intravascular devices. Accessories included with the device are a Tuohy-Borst hemostasis valve with an extension luer and two split sheath introducers. There is another introducer, named Scout, which provides support to the Zenith catheter while tracking to target site. The Zenith product line is supplied sterile, nonpyrogenic, and intended for single use only.
The provided text describes the regulatory clearance (510(k)) of a medical device, the "Zenith" percutaneous catheter, and a summary of non-clinical data supporting its substantial equivalence to predicate devices. The document does not describe an AI/ML-enabled device or a study involving human readers or comparative effectiveness with AI. Therefore, several aspects of your request (e.g., sample sizes for test set/training set, number of experts, adjudication method, MRMC study, standalone performance, provenance of data) are not applicable to this document.
However, I can extract the acceptance criteria and study conclusions for the non-clinical performance and biocompatibility tests described.
Here's the information derived from the document, focusing on the available details:
1. Table of Acceptance Criteria and Reported Device Performance
| Test | Acceptance Criteria | Reported Device Performance (Conclusion) |
|---|---|---|
| Biocompatibility - Material Mediated Pyrogen | The test article extracts must not cause a febrile reaction greater than 0.5°C in any individual subject. | Zenith test samples met the acceptance criteria for Material Mediated Pyrogen to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Cytotoxicity MEM Elution | The cultures treated with the test article must not have a reactivity grade greater than 2. | Zenith test samples met the acceptance criteria for Cytotoxicity MEM Elution to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Hemolysis ASTM Method, extract human blood | The hemolytic index above the negative control article must be less than 5%. | Zenith test samples met the acceptance criteria for Hemolysis ASTM Method, extract human blood to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Hemolysis, ASTM method, direct contact (human blood) | The hemolytic index above the negative control article must be less than 5%. | Zenith test samples met the acceptance criteria for Hemolysis, ASTM method, direct contact (human blood) to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Unactivated Partial Thromboplastin Time | There must be no statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | Zenith test samples met the acceptance criteria for Unactivated Partial Thromboplastin Time to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Complement Activation | There must be no statistical increase between either the C3a or SC5b-9 concentrations in plasma exposed to the test article as compared to the negative and untreated controls. | Zenith test samples met the acceptance criteria for Complement Activation to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Dog Thromboresistance | The test articles must receive a thrombus formation score less than or equal to that of the control. | Zenith test samples met the acceptance criteria for Dog Thromboresistance to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Maximization Sensitization | The test article must elicit a positive response in less than 10% of the test animals. | Zenith test samples met the acceptance criteria for Maximization Sensitization to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Intracutaneous Toxicity/Reactivity | The test article extracts must not induce a significantly greater biological reaction than the control. | Zenith test samples met the acceptance criteria for Intracutaneous Toxicity/Reactivity to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Biocompatibility - Acute Systemic Toxicity Test | The test article extracts must not induce a significantly greater biological reaction than the control. | Zenith test samples met the acceptance criteria for Acute Systemic Toxicity Test to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Animal Testing - Angiographic Evaluation | No units tested can cause vessel injury. | Zenith test samples met the acceptance criteria for Animal Testing- Angiographic Evaluation to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Chemical Compatibility | Chemicals have no negative effect on the catheter or accessories. | Zenith test samples met the acceptance criteria for Chemical Compatibility to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Radiographic Detectability | Product shall be visible under fluoro imaging. | Zenith test samples met the acceptance criteria for Radiographic Detectability to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Visual Inspection | Catheter shall appear free from damage, including a rounded tip and smooth transition points. | Zenith test samples met the acceptance criteria for Visual Inspection to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Working Length | Test samples should be within existing working length specification. | Zenith test samples met the acceptance criteria for Working Length to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Hub compatibility | Hub shall meet existing Luer specifications. | Zenith test samples met the acceptance criteria for Hub compatibility to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Outside diameter | Test samples should be within existing outside diameter specification. | Zenith test samples met the acceptance criteria for Outside diameter to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Leak – Air | Test samples should be within existing Air – Leak specifications. | Zenith test samples met the acceptance criteria for Leak – Air to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Leak – Liquid | Test samples should be within existing Leak – Liquid specifications. | Zenith test samples met the acceptance criteria for Leak – Liquid to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Particulates | Test samples should be within existing Particulate specifications. | Zenith test samples met the acceptance criteria for Particulates to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Simulated Use - Bench | Test samples must meet predetermined user needs. | Zenith test samples met the acceptance criteria for Simulated Use - Bench to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Catheter Burst | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | Zenith test samples met the acceptance criteria for Catheter Burst to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Zenith test samples met the acceptance criteria for Tensile to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Corrosion | Test samples shall exhibit no evidence of corrosion. | Test results for the predicate device were leveraged for the Zenith as the materials and manufacturing processes are equivalent. (Implies Zenith is expected to meet this, based on predicate data.) |
| Packaging - Dye Leak | Test sample shall not exhibit any visual leaks or channels. | Zenith test samples met the acceptance criteria for Packaging - Dye Leak to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Packaging - Peel | Test sample tensile strength must meet or exceed existing tensile strength specifications. | Zenith test samples met the acceptance criteria for Packaging - Peel to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Kink Resistance | Test sample kink resistance must meet or exceed existing Kink Resistance specifications. | Zenith test samples met the acceptance criteria for Kink Resistance to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Torque | Test sample torque results must meet or exceed existing torque specifications. | Zenith test samples met the acceptance criteria for Torque to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| PTFE Liner inspection | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | Zenith test samples met the acceptance criteria for PTFE Liner inspection to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Hydrophilic Coating Integrity | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | Zenith test samples met the acceptance criteria for Hydrophilic Coating Integrity to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Labeling Legibility | Test samples shall demonstrate text legibility. | Zenith test samples met the acceptance criteria for labeling legibility to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Barcode | Test samples shall demonstrate readily readable barcodes. | Zenith test samples met the acceptance criteria for barcode testing to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Sterilization | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | Zenith sterilization load met the acceptance criteria for sterilization to demonstrate that the Zenith is substantially equivalent to the predicate device. |
| Shelf Life | Aged test samples must meet or exceed existing specifications. | Zenith test samples met the acceptance criteria for shelf life to demonstrate that the Zenith is substantially equivalent to the predicate device. |
Regarding the specific requested points that are relevant to this type of device clearance:
2. Sample size used for the test set and the data provenance:
- The document does not explicitly state the sample sizes for each non-clinical test performed (e.g., how many catheters were burst-tested, how many animals in the angiographic evaluation). It refers to "test samples" or "units tested."
- The data provenance is from non-clinical laboratory and animal studies (e.g., ISO standards, ASTM standards, porcine model). It is not human subject data, so concepts like "country of origin" or "retrospective/prospective" as they apply to clinical studies are not applicable.
- For biocompatibility tests, it mentions "extract human blood" for some hemolysis tests.
- For the Angiographic Evaluation, it explicitly states it was a "porcine model."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This is not applicable as the studies described are non-clinical (laboratory and animal testing). The "ground truth" for these tests comes from adherence to established scientific and regulatory standards (e.g., ISO 10993, ASTM, USP) and predefined physical/chemical limits.
- For "Simulated Use - Bench," it mentions "by a physician," implying one or more physicians were involved in the benchtop evaluation, but their number and specific qualifications are not detailed beyond "physician."
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable to non-clinical laboratory or animal studies. Ground truth is determined by test results against defined acceptance criteria.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- Not applicable. This device is a percutaneous catheter, not an AI/ML diagnostic or assistive device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an algorithm/AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For non-clinical tests, the "ground truth" is determined by meeting predefined technical specifications, industry standards (e.g., ISO, ASTM), and biological safety parameters. For example, a burst pressure test's ground truth is a numerical value compared to a specification. For biocompatibility, it's the absence of adverse biological reactions per standard protocols. For the animal study, it's the absence of "clinically significant injury."
8. The sample size for the training set:
- Not applicable. This is not an AI/ML device that requires training data.
9. How the ground truth for the training set was established:
- Not applicable. This is not an AI/ML device that requires a training set or its associated ground truth establishment.
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(137 days)
The Super Distal Access (SDA) is indicated for the introduction of interventional devices into the peripheral and neuro vasculature.
The Super Distal Access (SDA) is a single lumen, variable stiffness catheter and has a shaft reinforced with a Stainless Steel/Nitinol coil. The SDA has a radiopaque Platinum/Iridium marker band on the distal end. The catheter has a maximum outer diameter of 0.084 inches. It has a tapered design that includes a nominal inner diameter of 0.062 inches in the distal end and 0.068 inches in the proximal end. There are three working lengths available: 115 cm, 125 cm, and 135 cm. The Super Distal Access has a PTFE-lined lumen in the distal end a Polyimide/PTFE-lined lumen in the proximal end. The catheter is flexible and has a hydrophilic coating. The SDA is inserted through a guide catheter or vascular sheath, provides access to the target site, and once in place, provides a reinforcing conduit for other intravascular devices. Accessories included with the device are a Tuohy-Borst hemostasis valve with an extension luer and a split sheath introducer. The SDA is supplied sterile, non-pyrogenic, and intended for single use only.
The provided text describes the non-clinical performance testing for the Super Distal Access (SDA) device to demonstrate its substantial equivalence to a predicate device. It includes acceptance criteria and conclusions for various tests.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and the Reported Device Performance:
| Test | Acceptance Criteria | Reported Device Performance (Conclusion) |
|---|---|---|
| Biocompatibility - Material Mediated Pyrogen | The test article extracts must not cause a febrile reaction greater than 0.5°C in any individual subject. | SDA test samples met the acceptance criteria for Material Mediated Pyrogen to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Cytotoxicity MEM Elution | The cultures treated with the test article must not have a reactivity grade greater than 2. | SDA test samples met the acceptance criteria for Cytotoxicity MEM Elution to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Hemolysis ASTM Method, extract human blood | The hemolytic index above the negative control article must be less than 5%. | SDA test samples met the acceptance criteria for Hemolysis ASTM Method, extract human blood to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Hemolysis, ASTM method, direct contact (human blood) | The hemolytic index above the negative control article must be less than 5%. | SDA test samples met the acceptance criteria for Hemolysis, ASTM method, direct contact (human blood) to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Unactivated Partial Thromboplastin Time | There must be no statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | SDA test samples met the acceptance criteria for Unactivated Partial Thromboplastin Time to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Complement Activation | There must be no statistical increase between either the C3a or SC5b-9 concentrations in plasma exposed to the test article as compared to the negative and untreated controls. | SDA test samples met the acceptance criteria for Complement Activation to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Dog Thromboresistance | The test articles must receive a thrombus formation score less than or equal to that of the control. | SDA test samples met the acceptance criteria for Dog Thromboresistance to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Maximization Sensitization | The test article must elicit a positive response in less than 10% of the test animals. | SDA test samples met the acceptance criteria for Maximization Sensitization to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Intracutaneous Toxicity/Reactivity | The test article extracts must not induce a significantly greater biological reaction than the control. | SDA test samples met the acceptance criteria for Intracutaneous Toxicity/Reactivity to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Biocompatibility - Acute Systemic Toxicity Test | The test article extracts must not induce a significantly greater biological reaction than the control. | SDA test samples met the acceptance criteria for Acute Systemic Toxicity Test to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Animal Testing - Angiographic Evaluation | No units tested can cause vessel injury. | SDA test samples met the acceptance criteria for Animal Testing - Angiographic Evaluation to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Chemical Compatibility | Chemicals have no negative effect on the catheter or accessories. | SDA test samples met the acceptance criteria for Chemical Compatibility to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Radiographic Detectability | Product shall be visible under fluoro imaging. | SDA test samples met the acceptance criteria for Radiographic Detectability to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Visual Inspection | Catheter shall appear free from damage, including a rounded tip and smooth transition points. | SDA test samples met the acceptance criteria for Visual Inspection to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Working Length | Test samples should be within existing working length specification. | SDA test samples met the acceptance criteria for Working Length to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Hub compatibility | Hub shall meet existing Luer specifications. | SDA test samples met the acceptance criteria for Hub compatibility to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Outside diameter | Test samples should be within existing outside diameter specification. | SDA test samples met the acceptance criteria for Outside diameter to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Leak - Air | Test samples should be within existing Air - Leak specifications. | SDA test samples met the acceptance criteria for Leak - Air to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Leak - Liquid | Test samples should be within existing Leak - Liquid specifications. | SDA test samples met the acceptance criteria for Leak – Liquid to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Particulates | Test samples should be within existing Particulate specifications. | SDA test samples met the acceptance criteria for Particulates to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Simulated Use - Bench | Test samples must meet predetermined user needs. | SDA test samples met the acceptance criteria for Simulated Use - Bench to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Catheter Burst | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | SDA test samples met the acceptance criteria for Catheter Burst to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | SDA test samples met the acceptance criteria for Tensile to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Corrosion | Test samples shall exhibit no evidence of corrosion. | Test results for the predicate device were leveraged for the SDA as the materials and manufacturing processes are equivalent. |
| Packaging - Dye Leak | Test sample shall not exhibit any visual leaks or channels. | Test results for the predicate device were leveraged for the SDA as the materials and manufacturing processes are equivalent. |
| Packaging - Peel | Test sample tensile strength must meet or exceed existing tensile strength specifications. | Test results for the predicate device were leveraged for the SDA as the materials and manufacturing processes are equivalent. |
| Kink Resistance | Test sample kink resistance must meet or exceed existing Kink Resistance specifications. | SDA test samples met the acceptance criteria for Kink Resistance to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Torque | Test sample torque results must meet or exceed existing torque specifications. | SDA test samples met the acceptance criteria for Torque to demonstrate that the SDA is substantially equivalent to the predicate device. |
| PTFE Liner inspection | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | SDA test samples met the acceptance criteria for PTFE Liner inspection to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Hydrophilic Coating Integrity | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | SDA test samples met the acceptance criteria for Hydrophilic Coating Integrity to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Labeling Legibility | Test samples shall demonstrate text legibility. | SDA test samples met the acceptance criteria for labeling legibility to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Barcode | Test samples shall demonstrate readily readable barcodes. | SDA test samples met the acceptance criteria for barcode testing to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Sterilization | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | SDA sterilization load met the acceptance criteria for sterilization to demonstrate that the SDA is substantially equivalent to the predicate device. |
| Shelf Life | Aged test samples must meet or exceed existing specifications. | SDA test samples met the acceptance criteria for shelf life to demonstrate that the SDA is substantially equivalent to the predicate device. |
2. Sample size used for the test set and the data provenance:
- Sample Size: The document repeatedly states "SDA test samples met the acceptance criteria". However, it does not specify the exact sample size (N) used for each test.
- Data Provenance: The biocompatibility tests were "conducted pursuant to 21CFR58, Good Laboratory Practices." The animal testing occurred in a "porcine model". Other non-clinical tests mention "conditioned samples" or "test samples". The origin of the data (country) is not explicitly stated, but the submission is to the U.S. FDA. The tests are prospective as they were conducted for the purpose of this submission to demonstrate substantial equivalence of the new device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):
- For the "Simulated Use - Bench" test, it states the product was evaluated "by a physician in a benchtop model." It does not specify the number or qualifications of this physician or any other experts involved in establishing ground truth for other tests. These appear to be laboratory and engineering tests rather than requiring expert clinical "ground truth" in the diagnostic sense.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- The document does not describe any adjudication method. The tests are primarily objective performance metrics against pre-defined acceptance criteria, not subjective interpretations requiring adjudication.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No, this document does not describe an MRMC comparative effectiveness study. This is a 510(k) submission for a medical catheter (Super Distal Access), not an AI-powered diagnostic device. Therefore, the concept of "human readers improve with AI vs without AI assistance" is not applicable here.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No, this document does not describe any algorithm-only or human-in-the-loop performance studies. As mentioned, this is a physical medical device, not a software algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The "ground truth" for this device's performance is established by objective measurements and observations against engineering standards, biocompatibility guidelines (e.g., ISO 10993 series, ASTM standards, USP 788), and pre-defined specifications. For example, for "Biocompatibility - Material Mediated Pyrogen", the ground truth is the measured febrile reaction in test subjects. For "Radiographic Detectability", the ground truth is visibility under fluoro imaging. In some cases, such as "Animal Testing - Angiographic Evaluation", the "ground truth" is absence of vessel injury observed in a porcine model.
8. The sample size for the training set:
- This concept is not applicable here. This is a physical medical device undergoing non-clinical performance testing, not a machine learning model that requires a training set.
9. How the ground truth for the training set was established:
- This concept is not applicable here, as there is no training set for a machine learning model.
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