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510(k) Data Aggregation
(58 days)
Inneuroco Inc.
The Thinline Sheath Introducer is intended to provide access and facilitate the percutaneous introduction of various devices into veins and/or arteries while maintaining hemostasis for a variety of diagnostic and therapeutic procedures.
The Thinline Introducer Sheath is a single-lumen, coil-reinforced catheter. The Thinline Introducer Sheath is available in 11cm and 23cm lengths (French size 9F) and is designed to accept 0.038 inch diameter quide wires. A radiopaque outer laver is included for angiographic visualization. A valved hub with integrated suture ring is attached to the proximal end with extension tubing and a three way stop cock which allows attachments for flushing and aspiration. This catheter is designed for use in providing access and facilitating the percutaneous introduction of various devices into veins and/or arteries while maintaining hemostasis for a variety of diagnostic and therapeutic procedures. The dimensions for the Thinline Introducer Sheath are indicated on the product label. A dilator and guidewire accessory are included within the packaging. It is supplied sterile, non-pyrogenic, and is intended for single use only.
The provided document is a 510(k) Premarket Notification for a medical device called the "Thinline Sheath Introducer." This document details the device's characteristics, indications for use, and the testing conducted to demonstrate its substantial equivalence to a predicate device.
Crucially, this document is for a physical medical device (a catheter introducer) and contains no information about an AI/ML-driven device or its acceptance criteria related to AI performance metrics (like sensitivity, specificity, AUC).
Therefore, I cannot extract the information required to answer your questions regarding acceptance criteria for an AI/ML device, such as sample sizes for test sets, data provenance, expert ground truth establishment, MRMC studies, or standalone performance. The performance data presented in the document (Table 6.2) relates to physical and functional tests of the sheath introducer, such as tensile strength, burst pressure, and sterility, not AI algorithm performance.
If you can provide a document that discusses an AI/ML-driven medical device and its validation study, I would be able to answer your questions.
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(175 days)
InNeuroCo Inc.
The 091 Balloon Guide Catheter is indicated for use in facilitating the insertion and guidance of intravascular catheters into a selected blood vessel in the peripheral and neuro vascular systems. The balloon provides temporary vascular occlusion during these and other angiographic procedures. The Balloon Guide Catheter is also indicated for use as a conduit for Retrieval devices.
The 091 Balloon Guide Catheter is a coaxial-lumen, coil-reinforced, variable stiffness catheter with a compliant balloon at the distal end to provide temporary vascular occlusion during angiographic procedures. A radiopaque marker is included at the distal end of the distal tip of the catheter) for fluoroscopic visualization. A bifurcated luer hub on the proximal end of the catheter allows attachments for flushing, and aspiration. This catheter is designed for use in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the peripheral and neuro vascular systems. The dimensions and maximum recommended balloon inflation volume for the 091 Balloon Guide Catheter are indicated on the product label. A Peel-Away Introducer accessory is included within the packaging. It is supplied sterile, non-pyrogenic, and is intended for single use only.
This document describes the validation of the 091 Balloon Guide Catheter. Since the provided text focuses on the device's substantial equivalence to a predicate device for regulatory approval, the "acceptance criteria" and "device performance" primarily refer to engineering performance specifications and bench testing results, rather than clinical efficacy metrics for an AI/ML device. There is no mention of an AI/ML component in this premarket notification.
Therefore, the requested information specifically related to AI/ML device validation (e.g., sample sizes for training/test sets, expert ground truth adjudication, MRMC studies, standalone algorithm performance) is not applicable to this document. The document details the testing performed to ensure the device meets safety and performance standards for a medical device.
Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are generally implied by the "Pass" result for each test. The reported device performance is that it met all predetermined acceptance criteria for each test.
Acceptance Criteria (Test Performed) | Reported Device Performance (Results) |
---|---|
Design Verification Testing | |
Tensile Strength (per ISO 10555-1, Section 4.6 and Annex B) | Pass |
PTFE delamination (visual inspection) | Pass |
Torque Strength (withstand one turn of the hub) | Pass |
Catheter Burst (per ISO10555-1, Section 4.10 and Annex F) | Pass |
Balloon Burst (not burst below specified volume) | Pass |
Visual Inspection (under 2.5X magnification) | Pass |
Particulates (per USP ) | Pass |
Liquid Leak Test (per ISO 10555-1, Section 4.7 and Annex C) | Pass |
Air Leak Test (per ISO 10555-1 section 4.7.2 and Annex D) | Pass |
Balloon Leak Test (per ISO 10555-4, section 4.4.2 and Annex B) | Pass |
Dimensional Verification (catheter and introducer meet specs) | Pass |
Chemical Compatibility (withstand exposure to saline, dextrose, heparin, contrast) | Pass |
Hub Compatibility (per ISO 594-1:1986 and ISO 594-2:1998) | Pass |
Kink Resistance (test to determine resistance to kinking) | Pass |
Balloon Air Purge Test (acceptable level of air removed) | Pass |
Balloon Fatigue Test (withstand specified inflation/deflation cycles) | Pass |
Balloon Compliance Test (not exceed specified dimensions for given volume) | Pass |
Flow Arrest (minimum occlusion time confirmed in flow model) | Pass |
Balloon Deflation Time (time to restore flow measured) | Pass |
Packaging Testing | |
Pouch Leak Test (per ASTM F-1929) | Pass |
Pouch Peel Test (per ASTM F88/F88M) | Pass |
Packaging - Visual Inspection (perforations, nicks, cuts, punctures, seal damage) | Pass |
Packaging - Seal Width (meet specified width) | Pass |
Design Validation Testing | |
In-vitro Simulated Use Study – Benchtop (performance verification by physicians) | Pass |
Usability Testing | |
In-vitro Simulated Use Study – Usability (IFU and labeling review, simulated use, worst-case models) | Pass |
Biocompatibility Testing | |
Cytotoxicity (MEM elution, 48 hr. inc., triplicate L929, 24 hr. ext.) | Pass |
Sensitization (Magnusson-Kligman Method, 2 extracts) | Pass |
Irritation (Intracutaneous Toxicity (ISO), 2 extracts) | Pass |
Material mediated pyrogenicity (Material Mediated Pyrogen) | Pass |
Acute Systemic Toxicity (Systemic Injection (ISO), 2 extracts) | Pass |
Hemolysis (ASTM Method, indirect and direct) | Pass |
Complement Activation (SC5b-9) | Pass |
Dog Thrombogenicity | Pass |
Sterilization Validation | |
Confirmatory sterilization study (sterility, EO residual, LAL, bioburden) | Pass |
Details of the Study:
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1. A table of acceptance criteria and the reported device performance: Provided above. All tests "Passed," indicating the device met all predetermined acceptance criteria.
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2. Sample size used for the test set and the data provenance: The document states that "Some of the tests were also conducted on the predicate device to help establish substantial equivalence." However, specific sample sizes for each test are not explicitly detailed in this summary. The data provenance is from bench testing and simulated use, conducted to support a regulatory submission in the United States. It is not patient data, so "retrospective or prospective" is not applicable.
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3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable in the context of an AI/ML device. For the "In-vitro Simulated Use Study – Benchtop," it states "A simulated interventional procedure was performed by physicians." For "Usability Testing," it mentions "Evaluators representative of the intended user population shall review... then attempt to use the catheters and accessories along with the expected compatible products in a simulated use environment, using worst-case neurovascular models." The specific number or qualifications of these physicians/evaluators are not detailed.
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4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable as this is not an AI/ML device with image interpretation or complex diagnostic outputs requiring expert adjudication. Performance was assessed against pre-defined engineering and functional criteria.
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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 physical medical device (catheter), not an AI/ML diagnostic or assistive tool.
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6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is a physical medical device (catheter), not an AI/ML algorithm.
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7. The type of ground truth used:
- Engineering/Performance Specifications: For most tests (e.g., Tensile Strength, Torque Strength, Burst, Leak tests, Dimensional Verification), the "ground truth" is defined by established engineering and materials standards (e.g., ISO 10555-1, USP , ASTM F-1929, ISO 594-1:1986).
- Simulated Use/Usability: For these tests, the "ground truth" is the successful and safe performance of the device by intended users in a simulated clinical environment, meeting pre-defined operational criteria.
- Biocompatibility: The "ground truth" is compliance with ISO 10993-1 and specific biological test methodologies (e.g., MEM elution, Magnusson-Kligman Method, ASTM Method for Hemolysis) to ensure the device is not harmful to biological systems.
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8. The sample size for the training set: Not applicable. This is a physical medical device, not an AI/ML device trained on data.
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9. How the ground truth for the training set was established: Not applicable.
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(169 days)
InNeuroCo, Inc
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 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.
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(156 days)
InNeuroCo Inc.
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 InNeuroCo 074 Zenith Flex Catheter is a variable stiffness catheter that has a 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/lridium marker band on the distal 25 cm of the 074 Zenith Flex Catheter has a hydrophilic coating. The 074 Zenith Flex Catheter is available with an internal diameter of 0.074 inches. The outer diameter is of 0.089 inches along its proximal shaft, and 0.083 inches along its distal shaft. The 074 Zenith Flex Catheter is available in three workinq lengths: 115 cm, 125 cm, and 132 cm. The 074 Zenith Flex Catheter has a PTFE lined lumen. Accessories included with the device are a Tuohy-Borst Hemostasis Valve, two peel-away Introducers, and a Scout introducer. The Scout may be used to introduce the 074 Zenith Flex Catheter into distal vasculature, thereby helping the device reach the target anatomy.
The provided text describes the Zenith Flex System (074 Zenith Flex Catheter) and its non-clinical data for demonstrating substantial equivalence. It does not describe a study involving an AI/Machine Learning device or algorithm. Therefore, I cannot provide details regarding acceptance criteria, sample size, ground truth, or adjudication methods in the context of an AI study.
However, I can extract the acceptance criteria and observed performance described for the non-clinical (bench and animal) testing of the Zenith Flex Catheter.
1. Table of Acceptance Criteria and Reported Device Performance
Test | Acceptance Criteria | Reported Device Performance |
---|---|---|
Zenith Flex Catheter & its accessories Biocompatibility | ||
Material Mediated Pyrogen | The test article extracts must not cause a febrile reaction greater than 0.5°C in any individual subject. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Cytotoxicity MEM Elution | The cultures treated with the test article must not have a reactivity grade greater than 2. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Hemolysis (ASTM Method, extract human blood) | The hemolytic index above the negative control article must be less than 5%. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Unactivated Partial Thromboplastin Time (UPTT) | There must be no statistical decrease between the UPTT of plasma exposed to the test article and to the negative or untreated control. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
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. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Dog Thromboresistance | The test articles must receive a thrombus formation score less than or equal to that of the control. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Maximization Sensitization | The test article must elicit a positive response in less than 10% of the test animals. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Intracutaneous Toxicity/Reactivity | The test article extracts must not induce a significantly greater biological reaction than the control. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Acute Systemic Toxicity Test | The test article extracts must not induce a significantly greater biological reaction than the control. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Chemical Compatibility | Product shall withstand exposure to chemicals without degradation. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Zenith Flex Catheter Performance Testing | ||
Working Length | Test samples should be within existing working length specification. | Zenith Flex Catheter test samples met the acceptance criteria. |
Hub compatibility | Hub shall meet existing Luer specifications. | Test articles met the acceptance criteria (leveraged from K171672, materials and manufacturing processes equivalent). |
Outside diameter | Test samples should be within existing outside diameter specification. | Zenith Flex Catheter test samples met the acceptance criteria. |
Leak - Air | Test samples should be within existing Air - Leak specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Leak - Liquid | Test samples should be within existing Leak - Liquid specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Particulates | Test samples should be within existing Particulate specifications. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Simulated Use - Bench | Test samples must meet predetermined user needs. | Zenith Flex Catheter test samples met the acceptance criteria. |
Catheter Burst | Test sample burst pressures must meet or exceed existing minimum burst pressure specification. | Zenith Flex Catheter test samples met the acceptance criteria. |
Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Corrosion | Test samples shall exhibit no evidence of corrosion. | Test articles met the acceptance criteria (leveraged from K152202, materials and manufacturing processes equivalent). |
PTFE Liner inspection | Test sample liner adhesion must meet or exceed existing PTFE Liner inspection specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Hydrophilic Coating Integrity | Test sample results must meet or exceed existing Hydrophilic Coating Integrity specifications. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Simulated Use Testing (Aspiration) | Successfully removed the thrombi. | Zenith Flex System test samples met the acceptance criteria. |
Labeling Legibility | Test samples shall demonstrate text legibility. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Barcode | Test samples shall demonstrate readily readable barcodes. | Test articles met the acceptance criteria (leveraged from K172167, materials and manufacturing processes equivalent). |
Sterilization (Catheter & Aspiration Tubing Set) | Sterilization load shall pose an equal or lesser challenge to sterilize than existing sterile product loads. | Sterilization loads met the acceptance criteria. |
Shelf Life (Catheter & Aspiration Tubing Set) | Aged test samples must meet or exceed existing specifications. | Zenith Flex Catheter & Aspiration Tubing Set test samples met the acceptance criteria. |
Torque Strength | Test sample results must meet or exceed existing torque specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Kink Resistance | Test sample results must meet or exceed existing kink resistance specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Lumen Patency | Test sample results must meet or exceed existing lumen patency specifications. | Zenith Flex Catheter test samples met the acceptance criteria. |
Tip Flexibility | Zenith Flex tip flexibility results were compared to predicate device results. | Zenith Flex Catheter test samples performed comparatively against the predicate device. |
Friction Force | Zenith Flex friction force results were compared to predicate device results. | Zenith Flex Catheter test samples performed comparatively against the predicate device. |
Simulated Use Testing - Usability | Test samples must meet predetermined user needs. | Zenith Flex System test samples met the acceptance criteria. |
Aspiration Tubing Set Performance Testing | ||
Visual Inspection | Test samples should meet visual inspection specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Tensile | Test sample ultimate tensile strength must meet or exceed existing tensile strength specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Leak - Liquid | Test samples should be within existing Leak - Liquid specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Leak - Air, Tubing and Control Switch | Test samples should be within existing Air - Leak specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Luer Compatibility | Hub shall meet existing Luer specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Suction Connector Separation Force | Test sample results must meet or exceed existing force specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Vacuum Drop / Suction Connector Secure Attachment | Test sample results must meet or exceed existing pressure specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Lumen Patency | Test sample results must meet or exceed existing lumen patency specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Dimensions | Test samples should be within existing dimensional specifications. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Packaging (Catheter and Aspiration Tubing Set) Testing | ||
Packaging - Dye Leak | Test sample shall not exhibit any visual leaks or channels. | Test articles met the acceptance criteria (leveraged from K172167, packaging is the same). |
Packaging - Peel | Test sample tensile strength must meet or exceed existing tensile strength specifications. | Test articles met the acceptance criteria (leveraged from K172167, packaging is the same). |
Aspiration Tubing Set Biocompatibility | ||
Cytotoxicity MEM Elution | The cultures treated with the test article must not have a reactivity grade greater than 2. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Maximization Sensitization | The test article must elicit a positive response in less than 10% of the test animals. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
Intracutaneous Toxicity/Reactivity | The test article extracts must not induce a significantly greater biological reaction than the control. | Test articles met the acceptance criteria (leveraged from K172167, aspiration tubing is the same). |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify exact sample sizes for each benchtop or animal test. It refers to "test samples" for bench testing and does not provide numerical counts.
For animal testing: "Clot was used to create occlusions within several arteries of swine. One side of each swine was treated with the subject Zenith Flex system and the contralateral side was treated with the reference device." The exact number of swine used is not provided.
Data provenance: The non-clinical data is generated from laboratory (bench) and animal (swine) studies. The country of origin for the studies is not specified.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable in this context. The non-clinical studies rely on objective measurements and observations in laboratory and animal settings, not on expert ground truth for interpretation of images or clinical outcomes. For 'Simulated Use - Bench' and 'Simulated Use Testing - Usability', a physician's assessment was used, but details on the number or qualifications of these physicians are not provided.
4. Adjudication Method for the Test Set
Not applicable, as the tests involve objective measurements and direct observation rather than 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
Not applicable. This is a medical device (catheter), not an AI/ML device for diagnostic interpretation. There was no MRMC study involving human readers and AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was Done
Not applicable. This is a medical device (catheter), not an AI/ML device.
7. The Type of Ground Truth Used
For bench testing, the ground truth is based on physical and chemical properties measured against established specifications (e.g., ISO, ASTM standards).
For animal testing, the ground truth for effectiveness was "angiographic assessment of revascularization," and for safety, "angiographic assessment and histopathological assessment."
8. The Sample Size for the Training Set
Not applicable. This is a medical device (catheter); there is no "training set" in the context of an AI/ML algorithm.
9. How the Ground Truth for the Training Set was Established
Not applicable.
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(275 days)
InNeuroCo, Inc.
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 |
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(53 days)
InNeuroCo, Inc
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)
InNeuroCo, Inc
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)
InNeuroCo, Inc
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)
INNEUROCO, INC
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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