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510(k) Data Aggregation

    K Number
    K201682
    Date Cleared
    2020-09-28

    (98 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    RIST Neurovascular, Inc.

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

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

    It can be used to facilitate introduction of diagnostic agents in the neuro vasculature. It is not intended to facilitate introduction of diagnostic agents in coronary or peripheral arteries.

    Device Description

    The RIST Radial Access Catheter is a flexible, single lumen catheter compatible with 0.038inch quidewires. It is designed to deliver interventional devices into the peripheral, coronary, and neuro vasculature, facilitate introduction of diagnostic agents in the neuro vasculature, and is intended to provide access to the target site via transradial access. The RIST Radial Access Catheter consists of a radiopaque catheter shaft reinforced with stainless steel and has a luer connector at its proximal end for the attachment of accessories and the infusion of fluids. The distal tip of the catheter is shaped to have a smooth, rounded tip and is offered in two different distal segment shapes, namely Simmons 2 (SIM2) and Berenstein (BER), The catheter has a nominal outer diameter of 0.070 inches and a nominal inner diameter of 0.040 inches. It is available in two working lengths: 120 cm. The RIST Radial Access Catheter is compatible with the RIST Cath Radial Access Long Sheath (K191551) and off-the-shelf accessories. The RIST Radial Access Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    The provided text discusses the RIST Radial Access Catheter (K201682) and its substantial equivalence to predicate devices, primarily focusing on performance testing. However, it does not contain information related to an AI/ML device. The document is a 510(k) summary for a physical medical device (catheter) and the performance data presented pertains to physical properties, mechanical tests, and biocompatibility, not AI model performance.

    Therefore, I cannot extract the requested information regarding acceptance criteria and studies for an AI/ML device from this document. The questions you've asked (e.g., sample size for test set, number of experts for ground truth, MRMC studies, standalone performance, training set data) are specific to the evaluation of AI/ML models, which are not applicable to the RIST Radial Access Catheter described here.

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    K Number
    K200417
    Date Cleared
    2020-05-02

    (72 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    RIST Neurovascular, Inc.

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

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

    Device Description

    The RIST Radial Access Catheter is a flexible, single lumen catheter compatible with 0.035 inch and 0.038-inch guidewires. It is designed to deliver interventional devices into the peripheral, coronary, and neuro vasculature and is intended to provide access to the target site via transradial access. The RIST Radial Access Catheter consists of a radiopaque catheter shaft reinforced with stainless steel and has a luer connector at its proximal end for the attachment of accessories and the infusion of fluids. The distal tip of the catheter is shaped to have a smooth, rounded tip and is offered in two different distal segment shapes, namely Simmons 2 (SIM2) and Berenstein (BER). The catheter has a nominal outer diameter of 0.070 inches and a nominal inner diameter of 0.040 inches. It is available in two working lengths: 120 cm and 130 cm. The RIST Radial Access Catheter is compatible with the RIST Cath Radial Access Long Sheath (K191551) and off-theshelf accessories. The RIST Radial Access Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    The provided text is a 510(k) Summary for the RIST Radial Access Catheter. This document details the engineering and performance tests conducted to demonstrate the device's substantial equivalence to a predicate device, rather than the evaluation of an AI/ML medical device.

    Therefore, many of the typical acceptance criteria and study design elements requested in the prompt, such as:

    • A table of acceptance criteria and reported device performance related to AI/ML metrics (e.g., sensitivity, specificity, AUC)
    • Sample size for the test set and data provenance (e.g., country, retrospective/prospective) related to clinical data for AI/ML performance
    • Number of experts and their qualifications for establishing ground truth for AI/ML
    • Adjudication method for the test set for AI/ML
    • Multi-Reader Multi-Case (MRMC) comparative effectiveness study for human readers with and without AI
    • Standalone (algorithm-only) performance
    • Type of ground truth used (expert consensus, pathology, outcome data) for AI/ML
    • Sample size for the training set and how ground truth was established for training

    cannot be extracted from this document. The document describes a traditional medical device (catheter) and its physical and functional performance testing, not an AI or machine learning algorithm.

    The document focuses on establishing substantial equivalence based on:

    1. Indications for Use: Identical to the predicate device.
    2. Technological Characteristics: Comparison of materials, dimensions, and operational principles.
    3. Performance Data: A series of design verification and validation tests, and biocompatibility tests directly on the catheter itself.

    However, I can provide the acceptance criteria and reported performance for the physical device based on the available information:


    Acceptance Criteria and Device Performance (for a physical catheter; not an AI/ML device)

    Acceptance Criteria (Test Performed)Reported Device Performance (Results)
    Design Verification Testing
    Tensile StrengthAll units met the Tensile Strength acceptance criteria.
    Torque StrengthAll units met the Torque Strength acceptance criteria.
    Particulates (per USP )The acceptance criteria for Particulate testing was met.
    Dimensional Verification - IDThe acceptance criteria for ID Dimensional Verification was met.
    Dimensional Verification - ODThe acceptance criteria for OD Dimensional Verification was met.
    Dimensional Verification - Working LengthThe acceptance criteria for Working Length Dimensional Verification was met.
    Dimensional Verification - Tip LengthThe acceptance criteria for Tip Length Dimensional Verification were met.
    Kink ResistanceAll units met the Kink Resistance acceptance criteria.
    Visual Inspection (Tip Taper/Transitions)All units met the Tip Taper/Transition Visual Inspection acceptance criteria.
    Shape Retention (Catheter Tip Shape)All units met the Shape Retention Acceptance criteria.
    Burst Test (per ISO 10555-1)All units met the Catheter Burst acceptance criteria.
    Liquid Leak Test (per ISO 10555-1)All units met the Liquid Leak acceptance criteria.
    Air Leak Test (per ISO 80369-7)All units met the Air Leak Test acceptance criteria.
    Chemical Compatibility (with saline, dextrose, heparin, radiocontrast)All units met the Chemical Compatibility acceptance criteria.
    Corrosion (per ISO 10555-1 Annex A)All units met the Corrosion acceptance criteria.
    Packaging - Visual InspectionAll units met the Packaging Visual Inspection.
    Packaging - Pouch Leak (per ASTM F-1929-15)All units met the Pouch Leak test.
    Packaging - Pouch Peel (per ASTM F-88/F88M-15)All units met the Pouch Peel test.
    Packaging - Seal WidthAll seals met the acceptance criteria for Seal Width.
    Comparative Testing
    Friction Force (in simulated-use anatomical model)The RIST Radial Access Catheter and predicate device had comparable friction forces.
    Design Validation Testing
    In vitro Simulated Use Study - Bench (performance by physicians in simulated procedure, compared to competitive device)All acceptance criteria were met. The performance was found to be substantially equivalent.
    Radiopacity (physician identification of distal tip, shape, curves from fluoroscopic images)All acceptance criteria were met. The performance was found to be substantially equivalent.
    In vitro Simulated Use Study - Usability (evaluators representative of intended user population, per IFU)All acceptance criteria were met. The catheter was able to be used as per the Instruction for Use.
    Leveraged Testing (from previous submissions)
    Hub Compatibility (Catheter luers per ISO 594)All units met the Hub Compatibility acceptance criteria.
    Labeling Legibility - LabelThe acceptance criteria for Labeling Legibility was met.
    BarcodeThe acceptance criteria for Barcode was met.
    Labeling Legibility - IFUThe acceptance criteria for IFU Legibility was met.
    Sterilization (per ANSI/AAMI/ISO 11135:2014 and AAMI TIR 28:2016)Product was sterile (achieved SAL of at least 10⁻⁶).
    Biocompatibility Testing (per EN ISO 10993-1)
    Cytotoxicity (ISO MEM Elution)The test article is considered non-cytotoxic.
    Sensitization (ISO Guinea Pig Maximization Sensitization)The test article did not elicit a sensitization response; classified as non-sensitizer.
    Irritation (ISO Intracutaneous Irritation)No significant dermal reactions observed; non-irritant.
    Systemic Toxicity (ISO Acute Systemic Injection)No abnormal clinical signs indicative of toxicity; non-cytotoxic (conclusion oddly repeats cytotoxicity).
    Complement Activation, SC5b-9 AssaySC5b-9 assay results not statistically significant when compared to reference material and comparison.
    Hemocompatibility (ASTM Hemolysis - Direct Contact and Extract Method)Test article returned a blank corrected percent hemolysis above the negative control of 0.0% (interpreted as non-hemolytic based on conclusion).
    Pyrogenicity (Materials Mediated Rabbit Pyrogen)Test article extracts did not cause a pyrogenic response; non-pyrogenic.

    Study Details (for a physical catheter, not AI/ML):

    1. Sample sizes used for the test set and the data provenance: The document generally states "All units" or "Samples" without specifying the exact number of units tested for each criterion. The data provenance is internal RIST Neurovascular testing, leveraging some data from previously cleared devices (K152202, K161262, K152876). The studies are evidently prospective, laboratory/benchtop tests, not clinical studies on human subjects, hence "country of origin of the data" in a clinical sense is not applicable.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: For the In vitro Simulated Use Study - Bench and Radiopacity tests, "physicians" were used. For the In vitro Simulated Use Study - Usability, "evaluators representative of the intended user population" were used. No specific number or qualifications (e.g., years of experience, specialty) of these experts are provided in the summary.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable and not mentioned, as these are primarily objective engineering performance tests rather than subjective human assessments requiring adjudication. For the tests involving physicians/evaluators, specific adjudication methods are not detailed.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done: No, an MRMC study was not done, as this is a physical medical device (catheter), not an AI/ML system being evaluated for diagnostic accuracy improvement.
    5. If a standalone performance was done: Yes, the described performance tests (e.g., tensile strength, torque strength, dimensional verification, kink resistance, burst, leak tests, biocompatibility, sterilization) were performed directly on the RIST Radial Access Catheter in a standalone manner to demonstrate its inherent properties and safety.
    6. The type of ground truth used: For most engineering tests, the ground truth is established by the specified ISO/ASTM standards and internal acceptance criteria (e.g., a specific pressure for burst test, a specific force for tensile strength). For the simulated use and radiopacity tests, the 'ground truth' is the observable, functional performance and perception by the evaluating physicians/users, often compared to the predicate device. Biocompatibility used standard biological test methods.
    7. The sample size for the training set: Not applicable. This is a physical device submission, not an AI/ML algorithm that requires a training set.
    8. 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
    K191551
    Date Cleared
    2019-12-23

    (194 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    RIST Neurovascular, Inc.

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

    The RIST Cath Radial Access Long Sheath is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

    Device Description

    The RIST Cath Radial Access Long Sheath (RIST Cath) is a single lumen, variable stiffness catheter with a stainless steel and nitinol reinforced shaft and has a radiopaque marker band on the distal end to aid in visualization. The catheter has a nominal outer diameter of 0.093 inches and a nominal inner diameter of 0.079 inches. It is available in two working lengths: 95 cm and 100 cm. The RIST Cath is intended to provide access to the target site via transradial access and once in place, provides a reinforcing conduit for other intravascular devices. The RIST Cath Radial Access Long Sheath has a PTFE-lined lumen to facilitate movement of other devices passing through its lumen. Accessories included with the device are a radial access dilator and a hemostasis valve. The RIST Cath is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that "All pre-determined acceptance criteria were met" for all listed tests. However, it does not explicitly state the numerical acceptance criteria for each test. It primarily reports that the device "met the acceptance criteria" for each specific test.

    Test PerformedAcceptance Criteria (Not explicitly quantified in the document)Reported Device Performance
    Tensile StrengthImplicit: Structurally sound after simulated useAll units met the Tensile Strength acceptance criteria.
    PTFE DelaminationImplicit: Liner remains adhered to outer jacketAll units met the PTFE Delamination acceptance criteria.
    Torque StrengthImplicit: Ability to function in a clinical settingAll units met the Torque Strength acceptance criteria.
    Hydrophilic CoatingImplicit: Coating integrity after simulationAll units met the Hydrophilic Coating acceptance criteria.
    ParticulatesImplicit: Particle quantities within expected parametersThe acceptance criteria for Particulate testing was met.
    Dimensional Verification - IDImplicit: ID within specified rangeThe acceptance criteria for ID Dimensional Verification was met.
    Dimensional Verification - ODImplicit: OD within specified rangeThe acceptance criteria for OD Dimensional Verification was met.
    Dimensional Verification - Working LengthImplicit: Working length within specified rangeThe acceptance criteria for Working Length Dimensional Verification was met.
    Kink ResistanceImplicit: Maintain structural integrityAll units met the Kink Resistance acceptance criteria.
    Visual Inspection (Transitions & Tip)Implicit: Integrity of transitions and tipAll units met the Transition and Tip Visual Inspection acceptance criteria
    Catheter BurstImplicit: Integrity under pressureAll units met the Catheter Burst acceptance criteria.
    Liquid Leak TestImplicit: No leakage under pressureAll units met the Liquid Leak acceptance criteria.
    Air Leak TestImplicit: No air leaks into assemblyAll units met the Air Leak Test acceptance criteria.
    Packaging - Pouch PeelImplicit: Pouch seal integrityAll units met the Pouch Peel test.
    Packaging - Pouch LeakImplicit: No dye penetration through sealAll units met the Pouch Leak acceptance criteria.
    Packaging - Visual InspectionImplicit: Integrity of pouch and sealsAll units met the Packaging Visual Inspection.
    Packaging - Seal WidthImplicit: Seal width within specified rangeAll seals met the acceptance criteria for Seal Width.
    Chemical CompatibilityImplicit: No degradation after exposure to chemicalsAll units met the Chemical Compatibility acceptance criteria.
    Hub CompatibilityImplicit: Compatibility with mating luer surfacesAll units met the Hub Compatibility acceptance criteria.
    CorrosionImplicit: Stainless steel reinforcement resists deteriorationAll units met the Corrosion acceptance criteria.
    Labeling Legibility - LabelImplicit: Legible after transportation and conditioningThe acceptance criteria for Labeling Legibility was met.
    Labeling Legibility - IFUImplicit: Legible after transportation and conditioningThe acceptance criteria for IFU Legibility was met.
    BarcodeImplicit: Scannable and contains appropriate informationThe acceptance criteria for Barcode was met.
    SterilizationProduct was sterile.Product was sterile.
    CytotoxicityImplicit: Non-cytotoxicThe RIST Cath is non-cytotoxic.
    SensitizationImplicit: Non-sensitizerThe RIST Cath is classified as a non-sensitizer.
    IrritationImplicit: Non-irritantThe RIST Cath is non-irritant.
    Material Mediated PyrogenicityImplicit: Non-pyrogenicThe RIST Cath is non-pyrogenic.
    Systemic ToxicityImplicit: No acute adverse effectsThe RIST Cath is non-cytotoxic.
    Hemolysis, ASTM Method (indirect)Implicit: Non-hemolyticThe difference between hemolytic indexes is 0.00 percent, placing in non-hemolytic range.
    Hemolysis, ASTM Method (direct)Implicit: Non-hemolyticThe RIST Cath is non-hemolytic.
    Complement Activation, C3a and SC5b-9Implicit: Similar to comparison articlesComplement activation of C3a and SC5b assays similar for test and comparison articles.
    Partial Thromboplastin Time (PTT)Implicit: Non-activatorP values of clotting time for test article and predicate were "Similar".
    Dog ThrombogenicityImplicit: Non-thrombogenicThe RIST Cath is non-thrombogenic.
    In vitro Simulated Use Study - BenchImplicit: Performance substantially equivalent to predicateAll acceptance criteria were met. Performance found substantially equivalent to predicate.
    In vitro Simulated Use Study - UsabilityImplicit: Usable as per Instructions for UseAll acceptance criteria were met. Usability demonstrated as per IFU.

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

    The document does not explicitly state the sample size used for the test set (number of devices tested for each performance criterion). However, for test methods like "Tensile Strength" and "PTFE Delamination," it mentions "All units met..." which suggests that a certain number of units were tested. The overall context is a premarket notification (510(k)) for a medical device seeking substantial equivalence, meaning the data is likely derived from retrospective testing performed by the manufacturer. The data provenance (country of origin) is not specified.

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

    For the "In vitro Simulated Use Study - Bench," it states that "A simulated interventional procedure was performed by physicians." For the "In vitro Simulated Use Study - Usability," "Evaluators representative of the intended user population evaluated the RIST Cath Radial Access Long Sheath..."

    • Number of experts: Not explicitly stated (e.g., "3 physicians").
    • Qualifications of experts: "Physicians" for the bench study and "Evaluators representative of the intended user population" for the usability study. Specific specialties or years of experience are not provided.

    4. Adjudication Method for the Test Set

    The document does not describe any specific adjudication method (e.g., 2+1, 3+1). The "Results" column consistently states that "All units met the acceptance criteria" or similar, implying a direct assessment against predefined criteria rather than a consensus among multiple adjudicators for subjective outcomes.

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

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not performed. This type of study typically assesses the impact of an AI system on human reader performance, which is not relevant for this medical device (a catheter sheath).

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    Not applicable. This device is a physical medical device (a catheter sheath), not an algorithm or AI system. Therefore, a "standalone algorithm performance" study is not relevant. The performance studies are focused on the physical characteristics and functionality of the device itself.

    7. Type of Ground Truth Used

    The ground truth for the various performance tests is established by:

    • Engineering specifications and standards: Many tests reference ISO standards (e.g., ISO 10555-1, ISO 80369-7, ISO 11135:2014) or ASTM standards (e.g., ASTM F-88/F88M-15).
    • Established testing protocols and acceptance criteria: For each test, there were pre-determined acceptance criteria based on the device's design and intended function.
    • Visual inspection and measurements: For dimensional checks, visual inspections, etc.
    • Biological testing standards: For biocompatibility tests, standards like EN ISO 10993-1 were followed.
    • Clinical simulation by physicians: For the in-vitro simulated use study, the performance parameters assessed by physicians against expected clinical performance would serve as the ground truth.

    There is no mention of pathology, outcomes data, or expert consensus in the sense of comparing device performance against a gold standard interpretation of a clinical condition (which would be common for diagnostic AI).

    8. Sample Size for the Training Set

    Not applicable. This device is a physical medical device and does not involve a "training set" in the context of machine learning or AI algorithms.

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

    Not applicable, as there is no training set for this type of device.

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