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510(k) Data Aggregation

    K Number
    K211990
    Date Cleared
    2021-07-27

    (29 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Rist™ 071 Radial Access Guide Catheter is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

    Device Description

    The Rist™ 071 Radial Access Guide Catheter is a single lumen, variable stiffness catheter with a stainless steel and nitinol reinforced shaft to provide support. The embedded stainless-steel flat wire cross coil is in the proximal section of the catheter, which transitions to a nitinol round wire single coil in the distal end. The catheter has a radiopaque platinum/iridium marker band on the distal end to aid in visualization. The distal 25 cm of the Rist™ 071 Radial Access Guide Catheter has a hydrophilic coating which reduces the insertion force and allows the catheter to traverse the vasculature more easily. The catheter has a nominal outer diameter of 0.084 inches and a nominal inner diameter of 0.071 inches. It is available in three working lengths: 95 cm, 100 cm, and 105 cm. The Rist™ 071 Radial Access Guide Catheter has a PTFE-lined lumen to reduce friction with other devices introduced through the lumen. It is intended to provide access to the target site via transradial access and, once in place, provides a reinforcing conduit for other intravascular devices. A radial access dilator is included as an accessory. The Rist™ 071 Radial Access Guide Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    The Rist™ 071 Radial Access Guide Catheter is a medical device intended for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature. The acceptance criteria and supporting studies are detailed below.

    1. Table of Acceptance Criteria and Reported Device Performance

    The device underwent extensive testing, and the results consistently indicated that "All units met the acceptance criteria" or similar statements. Specific numerical acceptance criteria were not explicitly provided in the document for most tests, but the qualitative statement of meeting criteria is present.

    Test PerformedAcceptance Criteria (Explicit or Qualitative)Reported Device Performance
    Biocompatibility
    CytotoxicityNon-cytotoxicity, no abnormal events (pH change, debris)The test article is considered non-cytotoxic... No abnormal events such as pH change or debris were noted.
    SensitizationNo sensitization responseThe test article did not elicit a sensitization response.
    IrritationNo significant dermal reactionsNo significant dermal reactions were observed.
    Acute Systemic ToxicityNo abnormal clinical signs indicative of toxicityNone of the study subjects were observed with abnormal clinical signs indicative of toxicity.
    PyrogenicityNo pyrogenic response; all validity criteria metThe test article extracts did not cause a pyrogenic response and all validity criteria were met.
    Hemocompatibility (Complement Activation)Not statistically significant (p>0.05) to reference material/comparison articleThe test article results... were not statistically significant (p>0.05).
    Hemocompatibility (Hemolysis)Blank corrected percent hemolysis above negative control of 0.0%The test article returned a blank corrected percent hemolysis above the negative control of 0.0%.
    Hemocompatibility (Platelet & Leukocyte Count)Platelet count within specificationThe platelet count was within specification.
    Hemocompatibility (Partial Thromboplastin Time)No more material mediated coagulation abnormalities than predicate in intrinsic pathwayThe test article did not create any more material mediated coagulation abnormalities... when compared to the predicate.
    Sterilization ValidationProduct sterility per ANSI/AAMI/ISO 11135:2014 and AAMI TIR 28:2016Product was sterile.
    PackagingSterile barrier not compromisedAll units met all the packaging acceptance criteria.
    Catheter and Dilator Tensile StrengthMet tensile strength acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the tensile strength acceptance criteria.
    Catheter PTFE DelaminationMet PTFE delamination acceptance criteriaAll units met the catheter PTFE delamination acceptance criteria.
    TorqueMet torque acceptance criteriaAll units met the torque acceptance criteria.
    Catheter Burst PressureMet burst pressure acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the catheter burst pressure acceptance criteria.
    Particulate TestingMet particulate acceptance criteria per USP <788>All units met the particulate testing acceptance criteria.
    Coating IntegrityMet coating integrity acceptance criteria (no surface irregularities after conditioning and tortuous path)All units met the coating integrity acceptance criteria.
    Leak (Liquid)No leakage per ISO 10555-1:2013/Amd. 1:2017(E)All units met the liquid leak test acceptance criteria.
    Leak (Air)No air leaks per ISO 10555-1:2013/Amd. 1:2017(E)All units met the air leak test acceptance criteria.
    Catheter Dimensional InspectionID, OD, and working length met acceptance criteriaAll units met the catheter dimensional inspection acceptance criteria.
    Dilator Dimensional InspectionID and OD met acceptance criteriaAll units met the dilator dimensional inspection acceptance criteria.
    Chemical CompatibilityNo signs of degradation, no obstruction of ID after exposure to saline, dextrose, heparin, radiocontrastAll units met the chemical compatibility acceptance criteria.
    Visual Inspection of Catheter and DilatorSmooth tip transition points, no surface defectsAll units met the visual inspection acceptance criteria.
    Catheter Coating LengthLength of hydrophilic coating met specificationAll units met the catheter coating length acceptance criteria.
    Kink ResistanceMet kink resistance acceptance criteriaAll units met the kink resistance acceptance criteria.
    In vitro Simulated Use StudyProduct performance verified by physiciansAll acceptance criteria were met.
    Corrosion (from predicate)Met corrosion acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the corrosion acceptance criteria.
    Hub Compatibility (from predicate)Met hub compatibility acceptance criteria per ISO 594-1:1986 and ISO 594-2:1998All units met the hub compatibility acceptance criteria.
    Radiopacity (from predicate)Physicians identified distal tip location, catheter shape, and curve locations on fluoroscopic imagesAll acceptance criteria were met.
    Label Content (from predicate)Information included is accurateAll units met the acceptance criteria for label content.
    Label Legibility (from predicate)Labeling remained legible after transportation and conditioningAll units met the acceptance criteria for label legibility.
    Barcode (from predicate)Scanned barcode matched appropriate informationAll units met the acceptance criteria for barcode.
    Dilator Working Length (from predicate)Dilator length met specificationAll units met the acceptance criteria for dilator working length.
    Useability (from predicate)Evaluators confirmed usability as per Instructions for UseAll acceptance criteria were met.
    Shelf-Life TestingProduct and packaging met all acceptance criteria for 6-month shelf lifeAll acceptance criteria were met.

    2. Sample Size for the Test Set and Data Provenance

    The document does not explicitly state the sample sizes used for each specific test in the "Test Set." However, it repeatedly mentions "All units" or "All units met" indicating that a sufficient number of samples were tested to achieve statistical significance or to demonstrate compliance.

    The data provenance is not specified in terms of country of origin. The studies are described as "Design verification and validation" (in-house testing) and based on applicable ISO/ASTM/USP standards, suggesting a laboratory-based, prospective testing approach. No mention of retrospective or prospective clinical data for the test set is present, as this is a pre-market submission focused on device performance rather than clinical outcomes.

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

    For the "In vitro Simulated Use Study," it states that "A simulated interventional procedure was performed by physicians." The exact number of physicians or their specific qualifications (e.g., "radiologist with 10 years of experience") are not provided.

    For the "Radiopacity" test (from the predicate device), "Physicians were shown fluoroscopic images." Again, the specific number and qualifications of these physicians are not detailed.

    4. Adjudication Method for the Test Set

    The document does not describe any formal adjudication method (e.g., 2+1, 3+1) for the tests. The results indicate a direct pass/fail or "met acceptance criteria" outcome, implying consensus on the directly measurable or observable results rather than a subjective assessment requiring adjudication. For physician-evaluated tests, the document indicates a general 'acceptance criteria met' without detailing disagreement resolution.

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

    No MRMC comparative effectiveness study was mentioned. The studies focused on device performance characteristics rather than comparing human reader performance with or without AI assistance. The device itself is a physical catheter, not an AI-powered diagnostic tool.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    No standalone algorithm performance study was done. This is consistent with the nature of the device as a physical medical instrument, not a software algorithm.

    7. Type of Ground Truth Used

    The ground truth for most performance tests was established by adherence to recognized international standards (ISO, ASTM, USP) and predefined internal specifications for various physical, chemical, and biological properties. This includes:

    • Physical Measurements: Dimensional accuracy (ID, OD, length), tensile strength metrics, burst pressure values, torque limits, kink resistance thresholds.
    • Chemical/Biological Properties: Biocompatibility assays (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity, hemocompatibility), chemical compatibility.
    • Functional Performance: Leak testing, coating integrity, particulate count, simulated use performance, radiopacity (as confirmed by physicians).
    • Sterility and Packaging Integrity: Demonstrated through sterilization validation and packaging tests.

    8. Sample Size for the Training Set

    No training set is applicable or mentioned. This device is a physical medical device, not a machine learning model that requires a training set.

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

    Not applicable as there is no training set for a physical device.

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    K Number
    K172448
    Date Cleared
    2017-12-21

    (129 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Riptide™ Aspiration System is intended for use 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 fail IV t-PA therapy are candidates for treatment.

    Device Description

    The Riptide™ Aspiration System is designed to restore blood flow in patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease. The Riptide™ Aspiration System is designed for use within the internal carotid, middle cerebral – M1 and M2 segments, basilar, and vertebral arteries. The Riptide™ Aspiration System is composed of the following components:

    • Arc™ Catheter .
    • Riptide™ Aspiration Tubing .
    • Riptide™ Aspiration Pump ●
    • Riptide™ Collection Canister with Intermediate Tubing .

    The Arc™ Catheter is introduced into the vasculature through the Split-Y Introducer Sheath. A lubricous, tapered liner is used to create a structure that has both proximal stiffness and distal flexibility. The Arc™ Catheter has a radiopaque marker band encapsulated at the distal tip for visualization under fluoroscopy. The Arc™ Catheter is navigated to the intended treatment site and positioned proximal to the site of occlusion. The Arc™ Catheter is the only component of the Riptide™ Aspiration System that is used intravascularly.

    The Riptide™ Aspiration Tubing serves as a conduit to supply vacuum from the Riptide™ Aspiration Pump to the distal tip of the Arc™ Catheter. The Riptide™ Aspiration Tubing provides a connection between the sterile and non-sterile environments. The proximal end of the Riptide™ Aspiration Tubing is connected to the Riptide™ Collection Canister (outside of the sterile environment) while the distal end of the Riptide™ Aspiration Tubing is connected to the Arc™ Catheter (inside the sterile environment). The Riptide™ Collection Canister is connected to the Riptide™ Aspiration Pump (also outside of the sterile environment) via the Intermediate Tubing.

    The Riptide™ Aspiration Pump is designed to generate vacuum for the Riptide™ Aspiration System. The vacuum pressure of the Riptide™ Aspiration Pump is set by turning the vacuum control valve until the vacuum gauge reads a minimum of 20inHg but not exceeding 25inHg. The Riptide™ Aspiration Pump is reusable, non-sterile, and intended to be utilized outside of the sterile environment.

    The Riptide™ Collection Canister is provided non-sterile and is pre-assembled with the Intermediate Tubing. The Riptide™ Collection Canister with Intermediate Tubing is single-use and the repository for aspirated material. The Riptide™ Collection Canister is placed into the receptacle of the Riptide™ Aspiration Pump while the Intermediate Tubing is connected to the vacuum inlet port.

    AI/ML Overview

    The provided text describes the acceptance criteria and the studies conducted to demonstrate the substantial equivalence of the Riptide™ Aspiration System to its predicate device, the Penumbra System® and Penumbra Pump MAX™.

    Here's the breakdown of the information requested:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document lists numerous tests conducted on various components of the Riptide™ Aspiration System, with an explicit statement that the device met the acceptance criteria for each. The specific acceptance criteria values are generally not quantified in the "Results" column, but rather stated qualitatively (e.g., "met the acceptance criteria").

    Table 1: Acceptance Criteria and Reported Device Performance (Summary)

    ComponentTest CategoryIndividual TestAcceptance Criteria Statement (from document)
    Arc™ CatheterBiocompatibilityUSP PhysicochemicalMeets USP Physicochemical (Pass)
    ISO MEM Elution Using L-929 Mouse Fibroblast CellsNon-cytotoxic
    ISO Guinea Pig Maximization Sensitization TestNon-sensitizer
    ISO Intracutaneous Irritation TestNon-irritant
    ISO Acute Systemic Injection TestNon-cytotoxic
    ISO Materials Mediated Rabbit PyrogenNon-pyrogenic
    ASTM Hemolysis Assay – Direct Contact and Extract MethodNon-hemolytic
    Complement activation C3a and SC5b-9 AssayThe compliment activation of the C3a and SC5b assays were similar for test and comparison articles.
    Thromboresistance EvaluationThe test and control articles exhibited similar thromboresistant characteristics.
    ISO Bacterial Mutagenicity Test - Ames AssayNon-mutagenic
    ISO in vitro Mouse Lymphoma with Extended TreatmentNon-mutagenic (non-genotoxic and non-clastogenic)
    ISO in vivo Mouse Micronucleus AssayNon-mutagenic
    Partial Thromboplastin TimeNon-activator (of intrinsic coagulation pathway)
    in vitro Hemocompatibility AssayNo adverse effect on leukocyte or platelet counts.
    Arc™ CatheterBench - MicrobialEthylene Oxide (EO) ResidualMet the acceptance criteria for EO Residual.
    Ethylene Chlorohydrin (ECH)Met the acceptance criteria for ECH.
    Bacterial EndotoxinMet the acceptance criteria for Bacterial Endotoxin.
    Bench - PackagingVisual InspectionMet the acceptance criteria for Visual Inspection.
    Bubble LeakMet the acceptance criteria for Bubble Leak.
    Seal StrengthMet the acceptance criteria for Seal Strength.
    Bench - PerformanceLumen PatencyMet the acceptance criteria for Lumen Patency.
    Dimensional InspectionMet the acceptance criteria for Dimensional Inspection.
    Tip BucklingMet the acceptance criteria for Tip Buckling.
    Injection Flow RateMet the acceptance criteria for Injection Flow Rate.
    Suction Flow RateMet the acceptance criteria for Suction Flow Rate.
    Vacuum ResistanceMet the acceptance criteria for Vacuum Resistance.
    Air Aspiration LeakMet the acceptance criteria for Air Aspiration Leak.
    Hub/Shaft Peak Tensile ForceMet the acceptance criteria for Hub/Shaft Peak Tensile Force.
    Coating IntegrityCharacterization only.
    Coating Lubricity/DurabilityMet the acceptance criteria for Coating Lubricity/Durability.
    ParticulateMet the acceptance criteria for Particulate.
    Kink ResistanceMet the acceptance criteria for Kink Resistance.
    Liquid LeakMet the acceptance criteria for Liquid Leak.
    Static/Dynamic BurstMet the acceptance criteria for Static/Dynamic Burst.
    Corrosion ResistanceMet the acceptance criteria for Corrosion Resistance.
    Torque to FailureCharacterization only.
    Riptide™ Aspiration TubingBench - MicrobialEthylene Oxide (EO) ResidualMet the acceptance criteria for EO Residual.
    Ethylene Chlorohydrin (ECH)Met the acceptance criteria for ECH.
    Bioburden RecoveryMet the acceptance criteria for Bioburden Recovery.
    BioburdenMet the acceptance criteria for Bioburden.
    Bacterial EndotoxinMet the acceptance criteria for Bacterial Endotoxin.
    Bench - PackagingAseptic PresentationMet the acceptance criteria for Aseptic Presentation.
    Seal WidthMet the acceptance criteria for Seal Width.
    Dye LeakMet the acceptance criteria for Dye Leak.
    Visual InspectionMet the acceptance criteria for Visual Inspection.
    Bubble LeakMet the acceptance criteria for Bubble Leak.
    LegibilityMet the acceptance criteria for Legibility.
    Foreign MaterialMet the acceptance criteria for Foreign Material.
    Seal StrengthMet the acceptance criteria for Seal Strength.
    Bench - PerformanceDimensional InspectionMet the acceptance criteria for Dimensional Inspection.
    Identification of Heat Shrink BandsMet the acceptance criteria for Identification of the Heat Shrink Bands.
    Identification of Flow SwitchMet the acceptance criteria for Identification of the Flow Switch.
    Joint Tensile StrengthMet the acceptance criteria for Joint Tensile Strength.
    Leak (Vacuum and Pressure Decay)Met the acceptance criteria for Leak.
    Degree of CollapseMet the acceptance criteria for Degree of Collapse.
    Compatibility (Arc™ Catheter & Collection Canister)Met the acceptance criteria for Compatibility to the Arc™ Catheter and Riptide™ Collection Canister.
    Riptide™ Aspiration PumpBench - PerformanceDegrees of TiltMet the acceptance criteria for Degrees of Tilt.
    DurabilityMet the acceptance criteria for Durability.
    Maximum VacuumMet the acceptance criteria for Maximum Vacuum.
    Flow CapacityMet the acceptance criteria for Flow Capacity.
    Electrical SafetyMet the acceptance criteria for Electrical Safety.
    Electromagnetic CompatibilityMet the acceptance criteria for Electromagnetic Compatibility.
    Riptide™ Collection Canister with Intermediate TubingBench - PackagingPackaging IntegrityMet the acceptance criteria for Packaging Integrity.
    Packaging LabelingMet the acceptance criteria for Packaging Labeling.
    Bench - PerformanceVolume CapacityMet the acceptance criteria for Volume Capacity.
    Volume MarkingMet the acceptance criteria for Volume Marking.
    Canister StrengthMet the acceptance criteria for Canister Strength.
    Overfill ProtectionMet the acceptance criteria for Overfill Protection.
    Dimensional InspectionMet the acceptance criteria for Dimensional Inspection.
    Degree of CollapseMet the acceptance criteria for Degree of Collapse.
    Port IdentificationMet the acceptance criteria for Port Identification.
    Compatibility (Riptide™ Aspiration Pump)Met the acceptance criteria for Compatibility.
    Riptide™ Aspiration SystemBench - System PerformanceSimulated Clot RetrievalMet the acceptance criteria for Simulated Clot Retrieval.
    Vacuum PressureMet the acceptance criteria for Vacuum Pressure.
    Flow RateMet the acceptance criteria for Flow Rate.
    Lumen CollapseThe Arc™ Catheter is resistant to Lumen Collapse.
    UsabilityMet the acceptance criteria for Usability.

    Study Information:

    The provided document describes non-clinical bench testing and non-clinical animal testing. It explicitly states "Not Applicable" for clinical performance data. Therefore, questions related to human reader studies, ground truth establishment for a test set of clinical images, and training set details are not directly addressed in this document.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Test Set Sample Size:
      • Bench Testing: The document does not specify the exact sample sizes (number of units tested) for each individual bench test. The nature of these tests often involves a batch of devices or components.
      • Animal Testing: The document mentions "a porcine model" but does not specify the number of animals used for the animal testing.
    • Data Provenance:
      • Bench Testing: Conducted by the manufacturer, Micro Therapeutics, Inc. d/b/a ev3 Neurovascular, as part of their R&D and regulatory submission process. Location not specified, but the company is based in Irvine, California, USA.
      • Animal Testing: Conducted "in a porcine model." Location not specified.
      • Retrospective/Prospective: These are non-clinical studies (bench and animal), so the terms retrospective/prospective in the context of human data acquisition do not directly apply. They are inherently prospective in the sense that the tests were designed and executed to evaluate this specific device for its regulatory submission.

    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)

    • Not Applicable. The studies described are non-clinical (bench and animal). There is no mention of human expert-established ground truth for a test set of clinical images or data. The "ground truth" for these tests comes from objective measurements against defined standards (e.g., ISO, ASTM, USP standards, or internal specifications) and observations in animal models.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not Applicable. As no human expert evaluation of clinical data for ground truth establishment is described, adjudication methods are not relevant to this 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

    • No. The document explicitly states "Performance Data - Clinical: Not Applicable." This means no human reader studies (MRMC or otherwise) were conducted or submitted as part of this 510(k). The device is not an AI-powered system that assists human readers.

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

    • No. This device is a medical instrument (aspiration system for stroke), not an AI algorithm. Therefore, a standalone algorithm performance study is not applicable.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Bench Testing: Ground truth is established by objective measurements against pre-defined engineering specifications, international standards (ISO, ASTM, USP), and validated test methods. For example, "The Arc™ Catheter met the acceptance criteria for EO Residual" means the measured residual levels were below the established safe limits per ISO 10993-7.
    • Animal Testing: Ground truth is established through direct observation and measurement in a controlled porcine model, in accordance with "21 CFR Part 58 for Good Laboratory Practice (GLP) for Non-Clinical Laboratory Studies". The goal was to evaluate "safety, efficacy, and usability" and compare it to the predicate device.

    8. The sample size for the training set

    • Not Applicable. No AI/machine learning component is described for this device, so there is no concept of a "training set" in the context of algorithm development.

    9. How the ground truth for the training set was established

    • Not Applicable. As there is no training set for an AI algorithm mentioned, this question is not relevant.
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