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510(k) Data Aggregation

    K Number
    K210601
    Date Cleared
    2021-04-28

    (58 days)

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

    The Plato 17 Microcatheter is intended for the introduction of embolic coils and infusion of diagnostic agents, such as contrast media, to the peripheral and neuro vasculature systems. The Plato 17 Microcatheter is not intended for use in the coronary vasculature.

    Device Description

    Scientia Vascular's Plato® 17 Microcatheter is a single lumen, open-ended catheter designed to be flexible and axially stable, to aid the physician in the accessing of distal vasculature. The Plato 17 Microcatheter is supplied sterile and is for single use only. The Plato 17 Microcatheter is packaged with various tip configurations, including straight and pre-shaped (45° and 90°). The microcatheter shaft design includes nitinol, polymers of varying durometer and an internal liner providing lubricity for intraluminal delivered embolic coils and contrast media: the distal exterior section of the catheter shaft is hydrophilic coated to reduce friction during manipulation in vessels. The working length of the catheter is 160 cm. The microcatheter includes two radiopague tip markers to facilitate fluoroscopic visualization and a clear hub with luer lock and a strain relief. The Plato 17 Microcatheter is compatible with 0.014 inch guidewires or embolic coils.

    The microcatheter is provided with a steam shaping mandrel, peel-away introducer and a ruler. The shaping mandrel, peel-away introducer and ruler are accessories included to facilitate use of the microcatheter and are not intended to contact the patient's body.

    AI/ML Overview

    The Scientia Vascular, LLC's Plato® 17 Microcatheter was evaluated through non-clinical performance tests, including biocompatibility and functional testing, to demonstrate substantial equivalence to the predicate device, the Excelsior™ SL-10 Pre-Shaped Microcatheter (K042568) and reference device Excelsior XT-17 Microcatheter (K142565).

    1. Table of Acceptance Criteria and Reported Device Performance:

    TestAttribute and Acceptance CriteriaReported Device Performance
    Biocompatibility Testing (ISO 10993-1:2018)
    Cytotoxicity: MEM ElutionCell culture was observed for cytotoxic reactivity.Non-cytotoxic.
    SensitizationStudy animals with subject device were observed for dermal sensitization.No sensitization reaction.
    Intracutaneous Reactivity- by extractStudy animals with subject device were observed for dermal reaction.No significant dermal reactions at the injected site.
    Acute Systemic Toxicity - by extractStudy animals with the subject device were observed for abnormal clinical signs indicative of toxicity during the 72-hour test period.No signs of toxicity.
    Material-Mediated PyrogenicityStudy animals were observed for individual temperature rise.Non-pyrogenic.
    Direct Contact and Extract method Hemolysis TestThe difference between the hemolytic indexes of the subject device and the negative control was evaluated.Non-hemolytic.
    Partial Thromboplastin Time (PTT) TestThe clotting time was observed for both the subject device and the predicate.The difference in average clot time between the subject device and predicate was 7 seconds. The two samples are considered similar.
    Complement activation of SC5b-9Comparison of the subject device SC5b-9 value to the predicate device for all exposure times was performed.The subject device had similar or lower potential to activate the complement system when compared to the predicate.
    Hemocompatibility In-vitro Blood LoopThe catheters are placed in an in-vitro blood loop for three runs. The thrombus score for the subject device and predicate device is observed.The lab testing concluded that the subject device showed minimal thrombus formation and is considered thromboresistant.
    Functional Testing
    Visual and Dimensional InspectionVisual inspection of the catheter effective length to be free from surface defects, surface extraneous matter, and coating droplets. Catheter to meet the dimensional specifications per the design specifications.PASS
    Tensile StrengthThe minimum tensile force for all microcatheters must meet the tensile requirements of ISO 10555-1.PASS
    Tip FlexibilityComparable to the tip flexibility of the predicate catheter.PASS
    Flexural FatigueCatheter shall withstand cyclic fatigue without catheter damage.PASS
    Flow Characterization and Power InjectionCharacterize fluid (saline and contrast media) flow rate through the catheter. No leak or break in the catheter when subject to power injection.PASS
    Catheter Liquid Leak Under PressureNo liquid leakage on the hub or catheter body.PASS
    Catheter Static BurstMaximum catheter burst pressure > 300psi.PASS
    Torque Turns to FailureMaintain catheter integrity after applied hub rotations with the distal end held stationary.PASS
    Particulate Generation During Simulated UseThe amount of particulate matter that comes off the hydrophilic coated shaft during simulated use testing shall be determined and compared to the competitive products.PASS
    Coating Lubricity, Durability and IntegrityAfter 15 cycles the coating must maintain a minimum lubricity and maintain a minimum surface coating coverage.PASS
    Negative Collapse Pressure and Air IngressNo air ingress while under vacuum with a syringe held for 10 seconds. No catheter lumen collapse after applied vacuum with a syringe.PASS
    Kink RadiusThe catheter must maintain lumen integrity while wrapped around an anatomically relevant bend radius.PASS
    Tip Shape and Shape RetentionCatheter tip meets defined tip dimensional tolerances and must maintain tip shape.PASS
    Catheter ElongationCatheter shaft elongation at breakage should be comparable to the predicate.PASS
    Catheter Hub Luer ValidationPlato 17 Microcatheter hub will be compliant to requirements found in ISO 80369-7.PASS
    Simulated Use Model and Product Compatibility EvaluationSimulated use testing of the microcatheter was performed with accessory devices in a neurovascular model. The microcatheter and interfacing devices were delivered through the model and evaluated for effectiveness of delivery and functionality.PASS
    Accessory VerificationThe Peel-Away Introducer must facilitate introduction of catheter into a guide catheter. The tip shaping mandrel must facilitate steam shaping of the catheter tip and show no signs of corrosion. The ruler on the accessories card must meet design specifications.PASS
    RadiopacityCatheter tip markers to be visible under X-Ray fluoroscopy within the neuro vasculature.PASS
    Catheter Usability StudyPhysician evaluation of the microcatheter in a cadaver study demonstrates acceptable use when compared to current marketed devices. The microcatheter and interfacing devices were delivered through a representative procedure and evaluated for effectiveness of delivery and functionality.PASS
    Corrosion ResistanceNo corrosion is visible on the catheter samples in compliance with ISO 10555-1.PASS

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

    The document does not explicitly state the specific sample sizes for each functional test performed. However, it mentions "study animals" for some biocompatibility tests (e.g., sensitization, intracutaneous reactivity, acute systemic toxicity, material-mediated pyrogenicity) and "catheter samples" for corrosion resistance. For the Catheter Usability Study, it mentions a "cadaver study." The provenance of the data (country of origin, retrospective/prospective) is not specified.

    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 "Catheter Usability Study," it states "Physician evaluation of the microcatheter in a cadaver study." The number of physicians and their specific qualifications are not provided. For other functional and biocompatibility tests, "ground truth" is established by adherence to recognized standards and objective measurements, not necessarily expert consensus in the clinical sense.

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

    The document does not describe any specific adjudication method for establishing ground truth, as most tests are bench-top or animal studies with objective pass/fail criteria or comparisons to predicate devices/standards. For the "Catheter Usability Study" involving physician evaluation, the method of aggregation or adjudication of physician opinions is not detailed.

    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 MRMC comparative effectiveness study was done as this device is a microcatheter, not an AI-assisted diagnostic tool. Therefore, the concept of human readers improving with AI assistance is not applicable.

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

    This refers to a physical medical device (microcatheter), not an algorithm or AI system. Therefore, standalone algorithm performance is not applicable.

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

    For biocompatibility tests, the ground truth is based on the biological responses observed in study animals or in vitro tests, evaluated against established scientific principles and standards (ISO 10993-1:2018). For functional tests, the ground truth is based on physical measurements, mechanical performance, and adherence to engineering standards (ISO 80369-7, ISO 80369-20, ISO 10555-1), as well as comparison to the predicate device where applicable. For the usability study, "acceptable use" by physicians in a cadaver study serves as a form of expert assessment.

    8. The sample size for the training set

    This device is a physical microcatheter, not a machine learning or AI model. Therefore, the concept of a "training set" is not applicable.

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

    As described in point 8, the concept of a "training set" and its associated ground truth is not applicable to this device submission.

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    K Number
    K201760
    Date Cleared
    2020-07-29

    (30 days)

    Product Code
    Regulation Number
    870.1330
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Zoom 14 Guidewire is intended for general vascular use within the neuro and peripheral vasculatures to introduce and position catheters and other interventional devices. The guidewire is not intended for use in the coronary vasculature.

    Device Description

    The Zoom 14 Guidewire is a modification of Scientia Vascular's Aristotle 14 Guidewire. It is a 0.014" diameter steerable guidewire with a shapeable tip to aid in accessing vasculature. The guidewire is supplied sterile and is for single use only. It is provided in a range of stiffness profiles: support and extra support. The product is provided in lengths of 200cm or 300cm. The distal portion of the guidewire tip includes a radiopaque platinum wire marker coil to facilitate fluoroscopic visualization. The guidewire has a hydrophilic polymer coating on the distal portion and a polytetrafluoroethylene (PTFE) coating on the proximal portion to reduce friction during manipulation in vessels. The guidewire is provided with a shaping mandrel, an introducer (to aid with the insertion of the guidewire into a catheter hub and/or a hemostasis valve) and a torque device (to attach to the proximal portion to facilitate gripping and manipulation of the guidewire during use). The mandrel, introducer and torque accessory devices are included to facilitate use of the guidewire and are not intended to contact the patient's body.

    AI/ML Overview

    The provided text describes the Zoom 14 Guidewire, a modification of Scientia Vascular's Aristotle 14 Guidewire. The submission is a 510(k) premarket notification, which means the manufacturer seeks to prove "substantial equivalence" to a legally marketed predicate device, rather than entirely new safety and effectiveness.

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance Criteria (Implied by "met testing acceptance criteria")Reported Device Performance (Zoom 14 Guidewire)
    Visual InspectionConformity to engineering drawings and absence of defects.The Zoom 14 Guidewires met testing acceptance criteria.
    DimensionalConformity to engineering drawings.The Zoom 14 Guidewires met testing acceptance criteria.
    Tensile TestingConformity to ISO 11070 requirements.The Zoom 14 Guidewires met testing acceptance criteria.
    Column BucklingForce required to buckle the tip at 5mm, 10mm, 20mm meets specified criteria.The Zoom 14 Guidewires met testing acceptance criteria.
    FlexingAbsence of defects, damage, or flaking of coating after flexing.The Zoom 14 Guidewires met testing acceptance criteria.
    FractureAbsence of fracture, loosening, or failure after wrapping around mandrel.The Zoom 14 Guidewires met testing acceptance criteria.
    TorqueabilityMeasurement of torque response (average input to output lag) meets specified criteria in an anatomical model.The Zoom 14 Guidewires met testing acceptance criteria.
    Torque StrengthTorque turns to failure in an anatomical model meets specified criteria.The Zoom 14 Guidewires met testing acceptance criteria.
    Model EvaluationSuccessful simulated use in a tortuous neurovasculature model.The Zoom 14 Guidewires met testing acceptance criteria.

    Note: The specific numerical or qualitative "acceptance criteria" are not explicitly detailed in the document but are implied by the statement "met testing acceptance criteria" for each test. The tests were performed in accordance with ISO 11070:2014 and the FDA Guidance Document "Coronary, Peripheral and Neurovascular Guidewires – Performance Tests and Recommended Labeling (2019)."

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

    The document does not explicitly state the sample size used for each functional test. The tests are non-clinical (bench testing and model evaluation) rather than human studies. Therefore, the concept of "country of origin of the data" and "retrospective or prospective" for a test set in the traditional sense of clinical data does not apply here. The data provenance is from the manufacturer's internal testing.

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

    This information is not applicable. The functional tests described are objective engineering and performance tests, not subjective evaluations requiring expert consensus for "ground truth" in the way clinical images or diagnoses would.

    4. Adjudication Method for the Test Set

    This information is not applicable as the tests are objective functional tests, not subjective evaluations requiring adjudication.

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

    No MRMC comparative effectiveness study was done. This is a 510(k) submission for a guidewire, which relies on non-clinical performance data and substantial equivalence to a predicate device, not a comparative clinical study with human readers assessing diagnostic accuracy.

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

    This information is not applicable. The device is a physical medical guidewire, not an algorithm or AI system. The "performance" described relates to its physical and mechanical properties.

    7. Type of Ground Truth Used

    The "ground truth" for the non-clinical performance tests is based on:

    • Engineering specifications and drawings: For visual and dimensional verification.
    • International standards (ISO 11070:2014): For tensile testing and other general guidewire performance.
    • FDA Guidance Document "Coronary, Peripheral and Neurovascular Guidewires – Performance Tests and Recommended Labeling (2019): Guiding the types of tests and likely acceptable ranges for performance.
    • Risk assessment (EN ISO 14971:2012): To determine which tests were necessary.
    • Anatomical models: For torqueability, torque strength, and simulated use evaluation.

    Essentially, the ground truth is established by objective, verifiable technical standards and engineering benchmarks.

    8. Sample Size for the Training Set

    This information is not applicable. The "Zoom 14 Guidewire" is a physical medical device, not an AI or machine learning model that requires a training set. The device's design is based on the predicate device (Aristotle 14 Guidewire) and engineering principles, not statistical learning from a data set.

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

    This information is not applicable for the reasons stated above.

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

    The Aristotle 24 Guidewire is intended for general vascular use within the neuro and peripheral vasculatures to introduce and position catheters and other interventional devices. The guidewire is not intended for use in the coronary vasculature.

    Device Description

    The Aristotle 24 Guidewire is a modification of Scientia Vascular's Aristotle 18 Guidewire. It is a 0.024" diameter steerable guidewire with a shapeable tip to aid in accessing vasculature. The guidewire is supplied sterile and is for single use only. It is provided in a range of stiffness profiles: soft, standard, and support. The product is provided in one overall length of 200cm. The distal portion of the guidewire tip includes a radiopaque platinum wire marker coil to facilitate fluoroscopic visualization. The guidewire has a hydrophilic polymer coating on the distal portion and a polytetrafluoroethylene (PTFE) coating on the proximal portion to reduce friction during manipulation in vessels. The guidewire is provided with a shaping mandrel, an introducer (to aid with the insertion of the guidewire into a catheter hub and/or a hemostasis valve) and a torque device (to attach to the proximal portion to facilitate gripping and manipulation of the guidewire during use). The mandrel, introducer and torque accessory devices are included to facilitate use of the guidewire and are not intended to contact the patient's body.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for the Aristotle 24 Guidewire. This document primarily focuses on demonstrating substantial equivalence to a previously cleared predicate device (Aristotle 18 Guidewire) rather than acting as a traditional clinical study report with detailed acceptance criteria and performance data for a novel AI/software device.

    Therefore, many of the requested details, such as those related to AI algorithm performance (e.g., sample size for test set, number of experts for ground truth, MRMC studies, standalone performance, training set details), are not applicable to this document as it pertains to a physical medical device (guidewire) and its mechanical/biocompatibility testing, not an AI/ML algorithm.

    However, I can extract the relevant information regarding the acceptance criteria and the "study" (functional and non-clinical performance tests) that prove the device meets these criteria as described in the provided text for this specific medical device.

    Here's an interpretation based on the provided document, addressing the applicable points and noting where information is not relevant to this specific clearance:


    Acceptance Criteria and Device Performance for Aristotle 24 Guidewire (Based on 510(k) K192783)

    The Aristotle 24 Guidewire is a physical medical device, and its "acceptance criteria" are demonstrated through non-clinical performance and design characteristic comparisons to a predicate device. The goal is to show substantial equivalence, not to prove clinical efficacy through a comparative effectiveness study involving human readers or AI algorithms.

    1. Table of Acceptance Criteria and Reported Device Performance

    For a traditional medical device like a guidewire, the "acceptance criteria" are implicitly met when the device successfully passes a battery of functional, dimensional, and biocompatibility tests, demonstrating performance consistent with its intended use and safety profile, and comparable to a predicate device. The tables below outline the tests conducted and their general "results" as stated in the document.

    Acceptance Criteria CategorySpecific Test/CharacteristicTest Method Summary (as described)Reported Device Performance (as described)
    BiocompatibilityIn-vitro Blood Flow Thrombogenicity StudyNot detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    MEM elutionNot detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    Toxicological risk assessmentNot detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    ASTM Hemolysis (direct contact and extract)Not detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    Partial Thromboplasting TimeNot detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    Compliment ActivationNot detailedNot explicitly stated "met," but implied satisfactory as no concerns raised. Materials are identical to predicate.
    SterilizationSterility Assurance Level (SAL)100% Ethylene Oxide (EO) to achieve SAL of at least 10^-6, adopted into EO sterilization processing group in accordance with AAMI TIR 28:2016.Aristotle 24 and Aristotle 18 are similar regarding device and packaging characteristics affecting sterilization ability. Implied successful sterilization to SAL 10^-6.
    Functional TestingDimensional VerificationTests per ISO 11070; Dimensional inspection per engineering drawings.The Aristotle 24 Guidewires met testing acceptance criteria.
    Tensile StrengthTensile testing per ISO 11070.The Aristotle 24 Guidewires met testing acceptance criteria.
    Flexing TestTests per ISO 11070; Inspection for defects and damage or flaking of the coating after flexing.The Aristotle 24 Guidewires met testing acceptance criteria.
    FractureTests per ISO 11070; Inspection for fracture, loosening, or failure after wrapping around mandrel.The Aristotle 24 Guidewires met testing acceptance criteria.
    TorqueabilityMeasurement of torque response (average input to output lag) in an anatomical model.The Aristotle 24 Guidewires met testing acceptance criteria.
    Torque StrengthTorque turns to failure in an anatomical model.The Aristotle 24 Guidewires met testing acceptance criteria.
    Tip FlexibilityMeasure force to deflect guidewire tips to 45 and 90 degrees at 5mm, 10mm, and 20mm test lengths.The Aristotle 24 Guidewires met testing acceptance criteria.
    Tip Shape, RetentionGuidewires must be shapeable and must retain shaped angle after simulated use.The Aristotle 24 Guidewires met testing acceptance criteria.
    ParticulateParticulates of various size ranges counted after simulated use in a tortuous path.The Aristotle 24 Guidewires met testing acceptance criteria.
    Coating Lubricity and DurabilityFrictional force of coated guidewires was determined after simulated use in a tortuous path.The Aristotle 24 Guidewires met testing acceptance criteria.
    Coating IntegrityCoating uniformity and integrity visually examined on dyed samples after simulated use in a tortuous path.The Aristotle 24 Guidewires met testing acceptance criteria.
    Simulated Use Model Testing and Product CompatibilityAnatomical model designed to simulate the tortuous anatomy of the neurovasculature used for simulated use testing.The Aristotle 24 Guidewires met testing acceptance criteria.
    Usability EvaluationPhysicians evaluated subject and predicate guidewires for various performance characteristics in a human cadaver.The Aristotle 24 Guidewires met testing acceptance criteria.

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

    For the functional testing of the guidewire, specific sample sizes are not explicitly stated in the document. The testing involves physical samples of the Aristotle 24 Guidewire. The provenance of this "data" is the non-clinical bench testing conducted by Scientia Vascular LLC. This is not a retrospective or prospective clinical study, but rather laboratory testing.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    The concept of "experts establishing ground truth" in the context of an AI algorithm is not applicable here. For a physical device like a guidewire, "ground truth" is established by adherence to engineering specifications, national/international standards (e.g., ISO 11070), and validated test methods.

    However, for the "Usability Evaluation," it states "Physicians evaluated subject and predicate guidewires."

    • Number of experts: Not specified (plural "Physicians" indicates more than one).
    • Qualifications of experts: Explicitly stated as "Physicians." No further details on their years of experience or specialization are provided within this document.

    4. Adjudication Method for the Test Set

    This concept (e.g., 2+1, 3+1) is typically relevant for expert review of images or data in AI/diagnostic studies to establish a consensus ground truth. It is not applicable to the functional and mechanical testing of a physical medical device. The "adjudication" for mechanical tests is whether the device passes or fails predefined engineering specifications.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and effect size.

    No, an MRMC comparative effectiveness study was not done. This type of study is specifically designed to evaluate the impact of an AI system on human reader performance, which is not relevant for the clearance of a guidewire.

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

    Not applicable. This device is a physical guidewire, not an algorithm.

    7. The Type of Ground Truth Used

    For the functional and biocompatibility testing, the "ground truth" is defined by:

    • Adherence to internal engineering specifications and design parameters.
    • Compliance with recognized industry standards (e.g., ISO 11070:2014 for guidewires, EN ISO 14971:2012 for risk management, AAMI TIR 28:2016 for sterilization).
    • Equivalence to the performance characteristics of the predicate device (Aristotle 18 Guidewire) as established by its clearance and prior testing.

    For the "Usability Evaluation," the "ground truth" was likely subjective feedback and performance metrics collected from the evaluating physicians using the device in a cadaver model.

    8. The Sample Size for the Training Set

    Not applicable. This is not an AI/ML algorithm that requires a "training set."

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

    Not applicable. This is not an AI/ML algorithm that requires a "training set."


    Summary of the Study Proving Acceptance Criteria:

    The "study" conducted for the Aristotle 24 Guidewire was a series of comprehensive non-clinical performance tests, including:

    • Biocompatibility Testing: Confirmed the safety of the device's materials by assessing blood compatibility and cytotoxicity. This was supported by the fact that the materials are identical to those used in the cleared predicate device.
    • Sterilization Validation: Demonstrated the effectiveness of the Ethylene Oxide (EO) sterilization process to achieve a required sterility assurance level (SAL).
    • Functional Testing: Evaluated various mechanical and physical properties of the guidewire (e.g., dimensional accuracy, tensile strength, flexibility, torqueability, tip retention, particulate generation, coating lubricity/integrity) in accordance with ISO 11070:2014 and FDA guidance. These tests were stated to "meet testing acceptance criteria," implying successful performance against pre-defined engineering and performance specifications.
    • Simulated Use Model Testing: Used an anatomical model to simulate tortuous neurovasculature for assessing device performance and compatibility during simulated use.
    • Usability Evaluation: Involved physicians evaluating the device in a human cadaver model for performance characteristics.

    The overarching goal of these tests was to demonstrate that the Aristotle 24 Guidewire is substantially equivalent to the predicate Aristotle 18 Guidewire, despite minor technological differences (larger O.D., two centering coils, one bushing). The document explicitly states that these differences "do not result in new materials used or new questions of safety or effectiveness, nor do they result in new risks for the subject device," and that "testing of the subject device has been performed, demonstrating the safety and effectiveness of the device."

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

    The Aristotle 18 Guidewire is intended for general vascular use within the neuro and peripheral vasculatures to introduce and position catheters and other interventional devices. The guidewire is not intended for use in the coronary vasculature.

    Device Description

    The Aristotle 18 Guidewire is a modification of Scientia Vascular's Aristotle 14 Guidewire. It is a 0.018" diameter steerable guidewire with a shapeable tip to aid in accessing vasculature. The guidewire is supplied sterile and is for single use only. It is provided in a range of stiffness profiles: soft, standard, and support. The product is provided in one overall length of 200cm. The distal portion of the guidewire tip includes a radiopaque platinum wire marker coil to facilitate fluoroscopic visualization. The guidewire has a hydrophilic polymer coating on the distal portion and a polytetrafluoroethylene (PTFE) coating on the proximal portion to reduce friction during manipulation in vessels. The guidewire is provided with an introducer (to aid with the insertion of the guidewire into a catheter hub and/or a hemostasis valve) and a torque device (to attach to the proximal portion to facilitate gripping and manipulation of the guidewire during use). The introducer and torque accessory devices are included to facilitate use of the guidewire and are not intended to contact the patient's body.

    AI/ML Overview

    This document describes the safety and performance testing for a medical device called the "Aristotle 18 Guidewire" to demonstrate its substantial equivalence to a predicate device, the "Aristotle 14 Guidewire." This is a 510(k) premarket notification, not a clinical study of an AI/ML device, therefore many of the requested criteria are not applicable.

    Here's an analysis of the provided text in relation to your request:

    Key Takeaway: The provided document is a 510(k) summary for a guidewire, which is a physical medical device, not an AI/ML diagnostic or treatment device. Therefore, many of the questions related to AI/ML device performance (such as MRMC studies, training/test sets, ground truth establishment by experts, and adjudication methods) are not applicable to this submission. The "study" described herein refers to non-clinical performance and biocompatibility testing of a physical product.

    1. A table of acceptance criteria and the reported device performance

    The document provides a table summarizing functional tests and their results. The "acceptance criteria" are implied by the "Results" column, indicating that the device "met," "demonstrated acceptable," or "showed acceptable" performance according to relevant standards (ISO 11070, AAMI TIR 28:2016, ASTM D 4169:16) and internal specifications.

    TestTest Method SummaryAcceptance Criteria (Implied)Reported Device Performance
    BiocompatibilityIn vitro blood flow loop thrombogenicity, MEM elution, toxicological risk assessment, ASTM hemolysis (direct/extract), PTT, complement activationEquivalent to predicate deviceEstablished that the biocompatibility profile of the subject device is equivalent to the predicate device due to identical materials and no increased thrombogenic potential from increased surface area. New testing was conducted to specifically address the increased diameter.
    Sterilization100% Ethylene Oxide (EO) to achieve SAL of at least 10^-6, evaluated per AAMI TIR 28:2016SAL of at least 10^-6The device was adopted into an EO sterilization processing group, and review indicates similarity between Aristotle 18 and Aristotle 14 regarding characteristics affecting sterilization.
    Functional TestingPer ISO 11070:2014 & FDA Guidance Document Coronary and Cerebrovascular Guidewire Guidance (Jan 1995)
    Visual InspectionFor extraneous matter, process/surface defects, trauma-causing defects.No defects observedNo extraneous matter, surface defects or visible droplets of coating are present on the Aristotle 18 Guidewires.
    Dimensional VerificationPer engineering drawings.Met dimensional specificationsAll Aristotle 18 guidewires met dimensional specifications.
    Tensile StrengthPer ISO 11070.Met minimum force breakageAll Aristotle 18 guidewires meet minimum force breakage requirements specified in ISO 11070.
    Flexing TestInspection for defects, damage, or flaking of coating after flexing.No defects or damageNo defects or damage / flaking of the coating were observed after flexing.
    FractureInspection for fracture, loosening, or failure after wrapping around mandrel.No fracture, loosening, or failureNo Aristotle 18 guidewires showed signs of fracture, loosening, or failure after wrapping them 8 times around a mandrel.
    TorqueabilityMeasurement of torque response (avg input to output lag) in anatomical model.Acceptable, comparable to predicateAll Aristotle 18 guidewires demonstrated acceptable torque responses. The torque response of the subject device was comparable to that of the predicate device.
    Torque StrengthTorque turns to failure in anatomical model.Acceptable, comparable to predicateAll Aristotle 18 guidewires demonstrated acceptable torque strength. The torque strength of the subject device was comparable to that of the predicate device.
    Tip FlexibilityMeasure force to deflect guidewire tips to 45 & 90 deg at 5mm, 10mm, 20mm.Acceptable, comparable to predicateThe forces required to deflect the Aristotle 18 guidewire tips were acceptable. The flexibility of the tips of all subject devices was comparable to the tip flexibility of the predicate guidewire.
    Tip Shape, RetentionMust be shapeable and retain shaped angle after simulated use.Met requirementsAll tips met shaping and shape retention requirements after simulated use.
    ParticulateParticulates of various size ranges counted after simulated use in tortuous path.Comparable to predicateA comparable number of particulates was recovered from subject and predicate device following simulated use.
    Coating Lubricity & DurabilityFrictional force determined after simulated use in tortuous path.Met specified requirementsAll Aristotle 18 guidewires met specified frictional force requirements.
    Coating IntegrityUniformity/integrity visually examined on dyed samples after simulated use in tortuous path.Acceptable coverageAll Aristotle 18 guidewires showed acceptable coating coverage after simulated use.
    Simulated Use Model Testing & Product CompatibilityAnatomical model (neurovasculature) for simulated use testing.Acceptable performanceAristotle 18 Guidewires and predicate devices were found to perform acceptably in evaluations of: Torqueability in tortuous vasculature, Lubricity, Microcatheter Support & Tracking, Compatibility with Introducer, Compatibility with Torque Device, and Compatibility with Microcatheter.
    Usability EvaluationPhysicians evaluated subject/predicate guidewires for various characteristics in human cadaver.Acceptable performanceSubject and predicate guidewires both exhibited acceptable performance.
    RadiopacityPhysicians evaluated during simulated use in human cadaver.Acceptable radiopacityBoth subject and predicate guidewires exhibited acceptable radiopacity.
    Corrosion ResistancePer ISO 11070, after soaking in typical end-use solutions.No signs of corrosionThere were no signs of corrosion on guidewires after soaking in typical end-use solutions.
    Compatibility with AgentsExposed to saline, contrast agents, DMSO, then examined for degradation.No degradation, corrosion, decomp.All Aristotle 18 guidewires showed no signs of degradation, corrosion or physical decomposition after exposure.
    PackagingSimulated transportation test per ASTM D 4169:16.Product secured, labeling legibleFollowing exposure to typical storage and transportation conditions, product remained secured and labeling remained affixed and legible.

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

    • Sample Size: The document does not specify the exact number of guidewires tested for each functional test. It refers to "All Aristotle 18 guidewires" (e.g., for tensile strength, torqueability, flexibility), implying that the entire batch or lot tested passed. For biocompatibility, it states "new biocompatibility testing was conducted" but does not give sample sizes.
    • Data Provenance: The tests are non-clinical, laboratory-based functional and material tests. There is no "country of origin" for patient data as no patient data was used. These tests are prospective, meaning they were performed specifically for this 510(k) 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. This is a physical device testing summary. "Ground truth" in the context of AI/ML diagnostic studies (where experts typically label images) is not relevant here.
    • However, for usability and radiopacity evaluations, "physicians" were used in a simulated use (cadaver) model. The number and qualifications of these physicians are not specified.

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

    • Not Applicable. This concept is for resolving discrepancies in expert labeling or diagnoses in AI/ML performance studies. It is not relevant to the functional testing of a physical guidewire.

    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 specific to AI/ML software. The submission describes a physical medical device.

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

    • Not Applicable. This is specific to AI/ML software.

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

    • Ground Truth (for this type of device): The "ground truth" for a physical medical device like a guidewire is established by adherence to engineering specifications, validated test methods (e.g., ISO, ASTM standards), and risk assessments. For biocompatibility, the "ground truth" is that the materials are safe for human contact and do not induce adverse biological responses, often confirmed through standardized in vitro and in vivo tests. For functional performance, the "ground truth" is that the device performs reliably according to its design parameters and intended use.
    • For the usability and radiopacity assessments, the "ground truth" was physician evaluation in a simulated (cadaver) environment, where they determined "acceptable performance" and "acceptable radiopacity."

    8. The sample size for the training set

    • Not Applicable. This device is not an AI/ML algorithm that requires a "training set."

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

    • Not Applicable. As above, no training set was used.
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    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Volo 14 Guidewire is intended for general vascular use within the neuro and peripheral vasculatures to introduce and position catheters and other interventional devices. The guidewire is not intended for use in the coronary vasculature.

    Device Description

    The Volo 14 Guidewire is a modification of Scientia Vascular's Aristotle 14 Guidewire. It is a 0.014" diameter steerable guidewire with a shapeable tip to aid in accessing vasculature. The guidewire is supplied sterile and is for single use only. It is provided in a range of stiffness profiles, from soft to standard. The product is provided in 200cm and 300cm lengths.

    The distal portion of the guidewire tip includes a radiopaque platinum wire marker coil to facilitate fluoroscopic visualization. The guidewire has a hydrophilic polymer coating on the distal portion and a polytetrafluoroethylene (PTFE) coating on the proximal portion to reduce friction during manipulation in vessels.

    The guidewire is provided with an introducer (to aid with the insertion of the guidewire into a catheter hub and/or a hemostasis valve) and a torque device (to attach to the proximal portion to facilitate gripping and manipulation of the guidewire during use). The introducer and torque accessory devices are included to facilitate use of the guidewire and are not intended to contact the patient's body.

    AI/ML Overview

    The provided text is a 510(k) summary for the Volo 14 Guidewire, and it details the device's characteristics, indications for use, and a comparison to a predicate device (Aristotle 14 Guidewire). This document focuses on demonstrating substantial equivalence to an already cleared predicate device, rather than proving a device meets specific performance acceptance criteria for a novel AI/ML device.

    Therefore, the information required to answer your request (acceptance criteria, study details for AI/ML device performance, sample sizes, expert ground truth establishment, MRMC studies, etc.) is not present in the provided text. The document describes functional testing for a medical device (guidewire), not the performance of an AI/ML algorithm.

    The testing described in the document is for the physical and functional aspects of the guidewire, such as:

    • Biocompatibility: Assessed by material equivalence to the predicate device.
    • Sterilization: Confirmed by method and process equivalence to the predicate.
    • Functional Testing: This includes:
      • Tip Shape/Retention
      • Torqueability
      • Torque Strength
      • Tip Flexibility
      • Simulated Use Model Testing and Product Compatibility (e.g., torqueability in tortuous vasculature, lubricity, microcatheter support & tracking, compatibility with introducer, torque device, and microcatheter).

    These tests are standard for a guidewire to demonstrate its physical and operational safety and efficacy, and its comparability to a predicate device. They do not involve AI/ML performance evaluation.

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

    The Aristotle 14 Guidewire is intended for general vascular use within the neuro and peripheral vasculatures to introduce and position catheters and other interventional devices. The guidewire is not intended for use in the coronary vasculature.

    Device Description

    The Scientia Vascular Aristotle 14 Guidewire is a 0.014" diameter steerable guidewire with a shapeable tip to aid in accessing vasculature. The guidewire is supplied sterile and is for single use only. It is provided in a range of stiffness profiles, from soft to support, The product is provided in 200cm and 300cm lengths. The distal portion of the guidewire tip includes a radiopaque platinum wire marker coil to facilitate fluoroscopic visualization. The guidewire has a hydrophilic polymer coating on the distal portion and a polytetrafluoroethylene (PTFE) coating on the proximal portion to reduce friction during manipulation in vessels. The guidewire is provided with an introducer (to aid with the insertion of the guidewire into a catheter hub and/or a hemostasis valve) and a torque device (to attach to the proximal portion to facilitate gripping and manipulation of the guidewire during use). The introducer and torque accessory devices are included to facilitate use of the guidewire and are not intended to contact the patient's body.

    AI/ML Overview

    The provided text is a 510(k) summary for the "Aristotle 14 Guidewire". This document summarizes non-clinical performance tests to demonstrate substantial equivalence to a predicate device, rather than a study proving the device meets specific performance acceptance criteria for a new clinical claim or an AI algorithm.

    Therefore, many of the requested elements for an AI algorithm study (like sample size for test/training sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, or standalone algorithm performance) are not applicable to this submission.

    However, I can extract the acceptance criteria and reported device performance from the Non-Clinical Performance Tests section, focusing on the functional and biocompatibility tests.


    Acceptance Criteria and Reported Device Performance for the Aristotle 14 Guidewire

    The provided document details non-clinical performance tests for the Aristotle 14 Guidewire to demonstrate substantial equivalence to a predicate device (PVS 1300 Synchro® 0.014" Guidewire, K032146). The study is based on a series of laboratory and simulated use tests rather than a clinical trial with human subjects or an AI algorithm performance evaluation.

    Here's a summary of the acceptance criteria (implied by the test objective and relevant standards) and the reported device performance.

    1. Table of Acceptance Criteria and Reported Device Performance

    Biocompatibility Tests

    TestAcceptance Criteria (Implied)Reported Device Performance
    Cytotoxicity (L-929 MEM Elution)No reactivity (Grade 0)Cell culture treated with test sample exhibited no reactivity (Grade 0). Conclusion: Non-cytotoxic.
    Sensitization (Magnusson-Kligman)No erythema or edema (Grade 0) at challenge sitesChallenge sites treated with test sample exhibited no erythema or edema (Grade 0). Conclusion: Negative for dermal sensitization.
    Irritation (Intracutaneous Toxicity)Low mean test score (e.g., ≤1 for 0.9% Normal Saline and Sesame Oil extracts)The mean test score in 0.9% Normal Saline extract was 0, and in Sesame Oil was 0.1. Conclusion: Non-irritating.
    Systemic Toxicity (Acute)No abnormal clinical signs indicative of toxicity during the 72-hour test periodNo study animals were observed with abnormal clinical signs indicative of toxicity during the 72-hour test period. Conclusion: Non-toxic.
    Material Mediated Pyrogenicity (Rabbit)Temperature increases for all test animals not exceeding acceptable test limit for maximum individual temperature riseTemperature increases for all test animals did not exceed the acceptable test limit for maximum individual temperature rise. Conclusion: Non-pyrogenic.
    Hemolysis (Direct Contact and Extract)Difference between hemolytic indices of test article and negative control within acceptable limits (e.g., ≤2% for non-hemolytic)The difference between the hemolytic indices of the test article and the negative control was 0.00% for both direct and indirect hemolysis. Conclusion: Non-hemolytic.
    Partial Thromboplastin Time (PTT)Same thrombogenicity category as predicate device (minimal activator)Both the subject device and predicate device fell within the same thrombogenicity category (minimal activator). Conclusion: Subject and predicate devices showed similar thrombogenicity.
    Complement Activation (SC5b-9)Amounts of SC5b-9 generated comparable to predicate deviceAmounts of SC5b-9 generated by the test article and predicate device after exposure times of 30 and 60 minutes were not statistically different. The amount of SC5b-9 generated by the test article was statistically lower than that released by the predicate after 90 minutes exposure. Conclusion: Subject and predicate devices showed similar complement system activation.
    Thrombogenicity (Dog Model)Average thrombus score comparable to predicate deviceThe average thrombus score was the same for both the subject and predicate device. Conclusion: Subject and predicate devices showed similar thrombogenic potential.
    Latex Antigenic Protein Content (LEAP)No detectable Latex Antigenic ProteinsNo Latex Antigenic Proteins were detected. Conclusion: Contains no detectable traces of latex.

    Functional Testing

    TestTest Method & Acceptance Criteria (Implied / Explicit)Reported Device Performance
    Visual InspectionISO 11070: Absence of extraneous matter, process/surface defects, or defects that may cause trauma to vessels.No extraneous matter, surface defects, or visible droplets of coating were present on the Aristotle 14 Guidewires.
    Dimensional VerificationISO 11070: All guidewires meet dimensional specifications per engineering drawings.All guidewires met dimensional specifications.
    Flexing TestISO 11070: No defects or damage / flaking of the coating after flexing.No defects or damage / flaking of the coating were observed after flexing.
    Tensile StrengthISO 11070: All guidewires meet minimum force breakage requirements.All guidewires met minimum force breakage requirements specified in ISO 11070.
    Tip Shape, RetentionGuidewires must be shapeable and must retain shaped angle after simulated use.All tips met shaping and shape retention requirements after simulated use.
    TorqueabilityMeasurement of torque response (average input to output lag) in an anatomical model; acceptable torque responses, comparable to predicate device.All guidewires demonstrated acceptable torque responses. The torque response of the subject device was comparable to that of the predicate device.
    Torque StrengthTorque turns to failure in an anatomical model; acceptable torque strength, comparable to predicate device.All guidewires demonstrated acceptable torque strength. The torque strength of the subject device was comparable to that of the predicate device.
    Tip FlexibilityMeasure force to deflect guidewire tips to 45 and 90 degrees at 5mm, 10mm, and 20mm test lengths; acceptable forces & comparable flexibility to predicate.The forces required to deflect the guidewire tips were acceptable. The flexibility of the tips of all subject devices was comparable to the tip flexibility of the predicate guidewire.
    FractureISO 11070: No signs of fracture, loosening, or failure after wrapping around mandrel.No guidewires showed signs of fracture, loosening, or failure after wrapping them 8 times around a mandrel.
    Coating Lubricity and DurabilityFrictional force of coated guidewires determined after simulated use in a tortuous path; meet specified frictional force requirements.All guidewires met specified frictional force requirements.
    Coating IntegrityCoating uniformity and integrity visually examined on dyed samples after simulated use in a tortuous path; acceptable coating coverage.All samples showed acceptable coating coverage after simulated use.
    ParticulatesParticulates of various size ranges counted after simulated use in a tortuous path; comparable number of particulates to predicate.A comparable number of particulates was recovered from subject and predicate devices following simulated use.
    Torque Device - Introducer TestingISO 11070: Acceptance criteria for biocompatibility, visual inspection, corrosion resistance, tensile testing, luer taper dimensions, pouch seal strength.Acceptance criteria of all tests were met.
    Simulated Use Model Testing & Product CompatibilityAnatomical model to simulate neurovasculature; acceptable performance in evaluations of: Torqueability, Lubricity, Microcatheter Support & Tracking, Compatibility with accessories.Guidewires and predicate devices were found to perform acceptably in evaluations of: Torqueability in tortuous vasculature, Lubricity, Microcatheter Support & Tracking, Compatibility with Introducer, Compatibility with Torque Device, and Compatibility with Microcatheter.
    Cadaver TestingPhysician evaluation of subject and predicate guidewires for performance characteristics; acceptable performance.Subject and predicate guidewires both exhibited acceptable performance.
    RadiopacityPhysician evaluation in human cadaver; acceptable radiopacity.Both subject and predicate guidewires exhibited acceptable radiopacity.
    Corrosion ResistanceISO 11070: No signs of corrosion on guidewires after soaking in typical end-use solutions.There were no signs of corrosion on guidewires after soaking in typical end-use solutions.
    Chemical CompatibilityNo degradation, corrosion, or physical decomposition after exposure to saline and contrast agent/saline solutions.All guidewires showed no signs of degradation, corrosion or physical decomposition after exposure.
    MRI Compatibility(N/A, indicated as "MRI Unsafe")No testing performed. Aristotle Guidewires are labeled “MRI Unsafe.”
    LatexASTM D6499-07: No detectable traces of latex proteins.No detectable traces of latex were found.
    Package IntegrityASTM D 4169:16, ASTM F 88-15, ASTM F 2096-11: Maintenance of integrity, affixation/legibility of labeling after transport simulation.Following exposure to typical storage and transportation conditions, all sterile barrier pouches maintained their integrity and labeling remained affixed and legible.
    Shelf LifeASTM F1980: All device performance acceptance criteria met after accelerated aging conditions simulating 6 months real-time storage.After exposure to accelerated aging conditions simulating real-time storage under ambient conditions for 6 months, all device performance acceptance criteria were met, justifying labeling the devices with a 6-month shelf life.
    Sterilization ValidationAAMI TIR 28:2009, ISO11135:2007 Annex B: Justification for adoption into EO sterilization processing group, PCDs more difficult to sterilize than devices, bioburden enumeration performed, bacteriostasis/fungistasis tests demonstrate no inhibition of growth.Results justified adoption into the EO sterilization processing group: Comparative and Bioburden Resistance study results demonstrated that PCDs are more difficult to sterilize than devices; Bioburden Enumeration and Extraction Efficiency tests were used to enumerate the CFUs present on devices; and Bacteriostasis/Fungistasis test results demonstrated that the product does not inhibit the growth of organisms.
    Sterilization Validation: EO and ECH ResidualsAAMI/ANSI/ISO 10993-7: Residual traces of EO and ECH well below limits.The residual traces of EO and ECH remaining in the Aristotle 14 Guidewire after exposure to the EO sterilization process are well below the limits specified in ISO 10993-7.
    Sterilization Validation: Bacterial Endotoxin LevelsANSI/AAMI ST72:2011/(R)2016, USP <161>, and USP <85>: LAL testing; Endotoxin levels below specified limit (e.g., < 2.15 EU/device).< 2.15 EU/device.

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

    The document does not explicitly state a single "test set" sample size in the context of an AI algorithm, or detailed provenance for each test (e.g., country of origin, retrospective/prospective). Instead, it describes various non-clinical tests.

    • Sample Size: For each functional and biocompatibility test, "All guidewires" or "All samples" or "All test animals" met the criteria, suggesting that a sufficient number of devices/samples were tested according to relevant standards (e.g., ISO 11070, ISO 10993-1). Specific sample numbers for each test are not provided but are implied to be adequate for conformity to the referenced standards.
    • Data Provenance: This is not applicable in the context of an AI evaluation. The tests are laboratory-based, simulating use conditions or evaluating material properties. The cadaver testing involved "human cadaver" generally, without specifying origin.

    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)

    • Number of Experts: For the "Cadaver Testing" and "Radiopacity" tests, "Physicians" evaluated the guidewires. The specific number of physicians is not stated.
    • Qualifications of Experts: The specific qualifications (e.g., specialty, years of experience) of the "Physicians" involved in cadaver testing are not provided.

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

    • Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or expert-driven evaluations where there's a need to resolve discrepancies in independent assessments. This is not applicable to the non-clinical, objective laboratory tests described in this 510(k) summary. For the cadaver studies, the method of aggregation or adjudication among physicians, if more than one, is not described.

    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 document describes non-clinical performance and substantial equivalence tests for a medical device (guidewire), not an AI algorithm. Therefore, an MRMC study related to AI assistance was not performed.

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

    • Not applicable. As stated above, this document concerns a medical device, not an AI algorithm.

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

    • For the non-clinical tests, "ground truth" is established by:
      • Referenced Standards: Adherence to international and FDA-recognized standards (e.g., ISO 10993-1, ISO 11070) for material properties and functional performance.
      • Laboratory Measurements: Objective measurements (e.g., dimensions, force, torque, particulate counts, chemical analysis).
      • Qualitative Assessments by Trained Personnel: Visual inspections, qualitative assessments in simulated use.
      • Physician Evaluation: For cadaver testing and radiopacity, physician opinion served as the "ground truth" for acceptable performance.
      • Comparison to Predicate Device: Many tests establish equivalence by showing comparable performance to the legally marketed predicate device.

    8. The sample size for the training set

    • Not applicable. This document is for a physical medical device and does not involve an AI algorithm training set.

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

    • Not applicable. This document is for a physical medical device and does not involve an AI algorithm training set.
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    K Number
    K170406
    Date Cleared
    2017-04-18

    (67 days)

    Product Code
    Regulation Number
    870.1200
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Plato MICROCATH 27B Microcatheter is intended for the introduction of interventional devices and infusion of diagnostic agents to the peripheral and neurovascular systems. The catheter is also intended for the introduction of therapeutic agents to the peripheral system. The catheter is not intended for use in the coronary vasculature.

    Device Description

    The Plato MICROCATH® 27B Microcatheter is a single lumen microcatheter with a flexible polymer shaft of varying stiffness to aid in navigation of the neurovasculature. The catheter is designed to be used with a guide catheter and a steerable guidewire. The proximal end of the catheter has a diameter of 3.4F tapering to a distal OD of 3.2F. The catheter can be inserted into a 5F guide catheter. The inner diameter is constant over the entire length of the catheter shaft and accommodates guidewires up to 0.025" in diameter. The catheter is 150 cm in length with a straight tip configuration which can be shaped, using steam heat and the provided mandrels, to the users' preferred shapes. A steam shaping mandrel is included in the packaging. The microcatheter has a hydrophilic coating on the outer distal shaft to reduce friction during catheter manipulation in the vasculature and has one radiopaque tip marker at its distal tip to facilitate fluoroscopic visualization.

    The subject microcatheter is identical with respect to its technological characteristics, design and materials to Scientia's currently marketed Plato MICROCATH 27B Microcatheters cleared under K143398. This 510k was prepared to expand the indications for use of the device to include its use in the neurovasculature.

    AI/ML Overview

    The provided document describes the acceptance criteria and a study demonstrating that the Plato MICROCATH® 27B Microcatheter meets these criteria.

    Here's a breakdown of the requested information:

    1. Table of acceptance criteria and the reported device performance

    TestTest Method SummaryAcceptance Criteria (Implied from Preamendment status / Predicate) & Results
    Tensile StrengthTensile testing performed per ISO 10555-1 on distal, medial and proximal catheter sections after simulated use.Acceptance Criteria: Meet minimum force breakage requirements specified in ISO 10555-1.Results: All catheters meet minimum force breakage requirements specified in ISO 10555-1.
    Coating Lubricity and DurabilityFrictional force of uncoated and coated catheters was determined.Acceptance Criteria: Meet specified frictional force requirements.Results: All catheters met specified frictional force requirements.
    Coating IntegrityCoating uniformity and integrity visually examined on dyed samples after simulated use in a tortuous path.Acceptance Criteria: Acceptable coating coverage and no defects post simulated use.Results: All samples showed acceptable coating coverage and no defects were identified post simulated use.
    ParticulatesParticulates of various size ranges counted after inserting a guidewire and advancing the Microcatheter through a guide catheter multiple times.Acceptance Criteria: Comparable number of particles in each size range to the predicate.Results: The test and predicate catheters had comparable numbers of particles in each size range.
    Torque to FailureTorque turns to failure in an anatomical model to provide a 4-fold safety factor.Acceptance Criteria: No signs of breakage, twists or collapsed lumens after specified number of torque turns.Results: All catheters showed no signs of breakage, twists or collapsed lumens after specified number of torque turns.
    Plato 27B Neurovascular Model EvaluationEvaluate ability to deliver and withdraw interventional devices through catheter in a model designed to simulate the tortuous anatomy of the neurovasculature.Acceptance Criteria: Successful delivery and withdrawal of interventional devices.Results: Interventional devices were successfully delivered into and withdrawn from the 27B Microcatheter while it was located in the model simulating the tortuous anatomy of the neurovasculature.
    Liquid Leakage under Pressure/Leakage at HubTest for leakage at 300-320 kPa per ISO 10555-1.Acceptance Criteria: No leakage from hub or catheter body.Results: No leakage from hub or catheter body.
    Static Burst PressureBurst pressure tested per ISO 10555-1.Acceptance Criteria: Maximum peak pressures all exceeded 300 psi.Results: Maximum peak pressures all exceeded 300 psi.
    Air Ingress/Negative CollapseTests per ISO 10555.Acceptance Criteria: Hub fittings do not allow air ingress and no evidence of lumen collapse.Results: Hub fittings do not allow air ingress and no evidence of lumen collapse.
    Kink ResistanceTests for kinks after distal tip of catheter is wrapped around cylindrical forms.Acceptance Criteria: Device resistant to kinking around small diameter turns per specification.Results: Device was resistant to kinking around small diameter turns per specification.
    Tip StiffnessTest for stiffness per ASTM D747-10.Acceptance Criteria: Tip stiffness comparable to predicate devices.Results: Tip stiffness was comparable that of the predicate devices.
    Flexural Fatigue and ProfileWorst case bend of 90° with an 8-fold safety factor for repetitions per ASTM D747-10.Acceptance Criteria: No signs of cracks or breakage after worst case simulated use.Results: All catheters showed no signs of cracks or breakage after worst case simulated use.
    Tip Shape RetentionCatheters must retain angle shaped by steam and meet tensile strength specifications after conditioning and simulated use.Acceptance Criteria: All tips formed by steam meet shape and tensile requirements after conditioning and simulated use.Results: All tips formed by steam met shape and tensile requirements after conditioning and simulated use.
    Simulated UseAnatomical model designed to simulate the tortuous anatomy of the neurovasculature used for simulated use testing.Acceptance Criteria: Perform acceptably in evaluations of guidewire tracking and guide catheter movement, and interventional devices successfully deployed/withdrawn.Results: Catheters and predicate devices were found to perform acceptably in evaluations of guidewire tracking and guide catheter movement. Interventional devices were successfully deployed and withdrawn.
    Visual/Dimensional InspectionVisual inspection for extraneous matter, process and surface defects or defects that may cause trauma to vessels. Dimensional inspection per drawings.Acceptance Criteria: No surface defects or visible droplets of coating; meet dimensional specifications; no clinically significant hydration.Results: No surface defects or visible droplets of coating on catheters. All catheters met dimensional specifications. Plato MICROCATH 27B Microcatheters do not exhibit clinically significant hydration as defined in ISO 10555-1:2013.
    Pressure vs. Flow CharacterizationFlow rates measured at two typical injection pressures per ISO 10555-1.Acceptance Criteria: Flow rates reported in Instructions for Use at 100 and 300 psi.Results: Flow rates reported in Instructions for Use at 100 and 300 psi.
    Dynamic FlowProduct used with power injector at pressure-limited setting to 700 psi.Acceptance Criteria: No leaks, breaks or occluded lumens at 700 psi.Results: No leaks, breaks or occluded lumens at 700 psi.
    Packaging TestingPouch evaluated for seal strength per ASTM F 88-00 and leak tests (bubble test) per ASTM F 2096-04.Acceptance Criteria: Meet minimum seal strength and release no bubbles under leak test conditions.Results: All sterile barrier pouches met minimum seal strength and released no bubbles under leak test conditions.
    Cadaver TestingHuman cadaver used to evaluate catheter and predicate devices by physicians for performance, access time, and ability to deploy and retrieve.Acceptance Criteria: Comparable performance with similar access time to the designated target compared to predicate.Results: Test and predicate devices both exhibited comparable performance with similar access time to the designated target.
    RadiopacityCatheters and predicate devices evaluated by physicians in human cadaver model.Acceptance Criteria: Acceptable radiopacity.Results: Both test and predicate catheters exhibited acceptable radiopacity.
    MRI CompatibilityCatheters contain metallic materials and should not be exposed to MRI procedures.Acceptance Criteria: Labeled MRI Unsafe in IFU.Results: Catheters are labeled MRI Unsafe in IFU.
    Chemical compatibilityCatheters were exposed to saline and contrast agent/saline solutions and examined for degradation.Acceptance Criteria: No signs of degradation, corrosion or physical decomposition.Results: All catheters showed no signs of degradation, corrosion or physical decomposition.
    Latex ContentTested for trace latex proteins per ASTM D6499-07.Acceptance Criteria: No detectable traces of latex.Results: No detectable traces of latex were found.
    Corrosion ResistanceTest for corrosion resistance per ISO 10555-1.Acceptance Criteria: No signs of corrosion on metallic components.Results: No signs of corrosion on metallic components of catheters.

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

    The document does not explicitly state the sample sizes for each test in a numerical format (e.g., "n=X catheters"). Instead, it generally refers to "all catheters," "all samples," or "test and predicate catheters." The provenance of the data is primarily non-clinical, involving in-vitro testing and simulated use in anatomical models and human cadavers.

    • Data Provenance: Predominantly non-clinical laboratory testing (in-vitro) and human cadaver studies.
    • Country of Origin: Not specified, but generally assumed to be carried out by the manufacturer (Scientia Vascular LLC) or their contracted labs.
    • Retrospective or Prospective: All tests described are prospective, conducted specifically to demonstrate substantial equivalence for this 510(k) 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)

    For the human cadaver testing and radiopacity evaluation, "physicians" were used to evaluate the devices. No specific number or qualifications (e.g., years of experience, specialization) of these physicians are provided in the document.

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

    The document does not describe any formal adjudication method (like 2+1 or 3+1) for establishing ground truth or evaluating performance, beyond "physicians" performing evaluations in the cadaver study. The non-clinical tests rely on meeting specified standards (e.g., ISO, ASTM, internal specifications).

    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

    There is no MRMC comparative effectiveness study and no AI component mentioned in this document. This is a traditional medical device (microcatheter) and the testing is purely for physical and functional performance, not diagnostic accuracy with AI.

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

    There is no standalone algorithm performance study as this device does not involve any algorithm or AI.

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

    For most functional and biocompatibility tests, the ground truth is defined by established industry standards (ISO, ASTM), FDA guidance documents, and internal engineering specifications which are based on acceptable performance limits for medical devices. For the cadaver studies, the "ground truth" for performance was based on physician evaluation and comparison to a predicate device's performance in a similar setting. There is no pathology or patient outcomes data as it's a pre-market submission for a physical device.

    8. The sample size for the training set

    There is no training set as this device does not incorporate machine learning or AI.

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

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

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