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510(k) Data Aggregation
(60 days)
Axium Detachable Coil System
The Axium™ Detachable Coil System is indicated for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The Axium™ Detachable Coils are also indicated for arterial and venous embolizations in the peripheral vasculature.
The Axium™ Detachable Coil System consists of a platinum/tungsten embolization coil attached to a composite implant delivery pusher with a radiopaque positioning marker and a hand-held Axium™ I.D. (Instant Detacher) which, when activated, detaches the coil from the delivery pusher tip. The Axium™ I.D. (Instant Detacher) is sold separately.
This submission expands the size offerings of the Axium™ Detachable Coil (subject device) by adding thirty-five (35) new model numbers to the currently cleared Axium product portfolio (predicate device). These new model numbers are a line extension of the currently sold predicate device and range in size from 1mm diameter x 1cm length to 3.5mm diameter x 10cm length. All thirtv-five (35) new SKUs have a smaller primary wire diameter than the predicate device. This line extension includes six (6) coils having a 1mm diameter which is outside of the currently cleared Axium size range of 1.5mm diameter x 1cm length to 25mm diameter x 50cm length.
The second modification features a change to the Implant Delivery Pusher by replacing the PET material of the Positive Load Indicator (PLI) and Hypotube Break Indicator (BI) with a laser mark.
These modifications to the currently cleared predicate device were made solely to accommodate the new smaller implant coil size of the subject line extension. All other aspects of the subject device (materials of construction of the implant coil, principles of operation, packaging, labeling and indications for use) are identical to the predicate device.
This document describes a 510(k) submission for a medical device called the Axium™ Detachable Coil System. The submission is for a line extension of an already cleared device, introducing new coil sizes and a minor change to the implant delivery pusher.
Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance:
The document summarizes the bench tests performed. The acceptance criteria for each test are implicitly that "All devices met acceptance criteria." The device performance is reported as meeting these criteria.
Test | Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|---|
Visual and Dimensional Inspection (Coil, Sheath, Implant Delivery Pusher) | Dimensions (ID, OD, length) were measured, and key characteristics were inspected of the implant coil, sheath, and coupler tube, within specified tolerances. | All devices met acceptance criteria. |
Softness and Conformability (Coil Deformation) | The first loop of the coil is advanced until it exits the sheath and is compressed to a deformation distance that is a percentage of the coil's loop OD. The peak force is recorded within an acceptable range for proper coil softness and conformability. | All devices met acceptance criteria. |
Ease of Deliverability (Force Transfer, Friction Testing, Fatigue and Knotting) | Force Transfer: Peak delivery force measured through a representative tortuous anatomical model must be within acceptable limits. Friction Testing: The proximal end of the device is advanced until the distal force exceeds a specified value, and the force transfer must be calculated within acceptable limits. Fatigue and Knotting: The device is placed inside the microcatheter and advanced until the coil is deployed completely inside the aneurysm model, then retracted and the cycle repeated for a required number of cycles without evidence of fatigue or knotting upon inspection. | All devices met acceptance criteria. |
Detachment (Coil Tensile – Polypropylene, Coil Tensile – Implant/Weld) | Coil Tensile – Polypropylene: The coil is stretched until the stretch resistant member breaks, and the peak force result is recorded and must be within an acceptable range. Coil Tensile – Implant/Weld: The primary wire of the coil is stretched until the coil-coil shell weld breaks, and the peak force result is recorded and must be within an acceptable range to ensure proper detachment and integrity. | All devices met acceptance criteria. |
Labeling Verification | Text and format of drawings were visually compared to labeling and packaging product specifications and must match. | All devices met acceptance criteria. |
Physician Usability Testing | The device was navigated through a tortuous benchtop model and deployed into a simulated silicone aneurysm to assess coil softness, conformability, ease of delivery, and biomechanical stability according to pre-defined criteria. | All test results met the acceptance criteria. |
Adopted Tests (from predicate device): | ||
Torque Response | The device's response to applied torque must be within acceptable limits to ensure steerability and control. | Passed (implied by adoption from cleared predicate) |
Coil Tensile - Assembly | The tensile strength of the coil assembly (excluding specific weld/fiber breaks, which have individual tests) must meet predefined strength requirements. | Passed (implied by adoption from cleared predicate) |
Pusher Dimensions | Dimensions of the implant delivery pusher must conform to specifications. | Passed (implied by adoption from cleared predicate) |
Marker Radiopacity | The radiopacity of the marker on the device must be sufficient for clear visualization under fluoroscopy. | Passed (implied by adoption from cleared predicate) |
Tip Buckling | The device tip must not buckle under specified forces or conditions. | Passed (implied by adoption from cleared predicate) |
Detachment Zone Stiffness | The stiffness of the detachment zone must be within an acceptable range to ensure reliable detachment while maintaining appropriate flexibility. | Passed (implied by adoption from cleared predicate) |
Kink Resistance | The device must resist kinking when navigated through tortuous paths or under simulated use conditions. | Passed (implied by adoption from cleared predicate) |
Hypotube and Weld Tensile Strength | The tensile strength of the hypotube and its welds must meet specified requirements to prevent breakage during use. | Passed (implied by adoption from cleared predicate) |
Pusher Elongation | The implant delivery pusher must not elongate beyond specified limits under typical forces encountered during use. | Passed (implied by adoption from cleared predicate) |
MRI Compatibility | The device must be demonstrated to be safe for use in an MRI environment according to relevant standards. | Passed (implied by adoption from cleared predicate) |
Sterilization, Biocompatibility, and Aging data (for the new SKUs) | Must demonstrate sterility, biocompatibility, and shelf-life equivalent to the predicate device due to no changes in manufacturing process, packaging, or materials of construction for the implant coil, and reduced mass. For the laser marks, physicochemical and cytotoxicity testing confirmed no impact on safety. | Passed (implied by adoption from cleared predicate, and specific testing for laser marks) |
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set (Bench Testing): The document does not explicitly state the sample sizes for each specific bench test (e.g., "n=X coils"). It states "All devices met acceptance criteria," suggesting that multiple units of each new SKU were tested. The total number of new SKUs is 35.
- Data Provenance: The data is based on bench testing performed by the manufacturer (Micro Therapeutics, Inc. d/b/a ev3 Neurovascular). It is prospective in the sense that the tests were conducted specifically for this 510(k) submission to demonstrate substantial equivalence of the new offerings. There is no mention of geographical origin for the bench testing data; it's assumed to be from the manufacturer's testing facilities.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- This submission relies primarily on engineering and performance bench testing, not clinical data or expert visual assessment in the traditional sense of diagnostic imaging.
- For the "Physician Usability Testing," the document states, "The device was navigated through a tortuous benchtop model and deployed into a simulated silicone aneurysm in order to assess coil softness, conformability, ease of delivery and biomechanical stability." It doesn't specify the number or qualifications of physicians who performed or assessed this usability testing. Given it's a benchtop test, it likely involved internal engineering or R&D personnel with relevant medical device experience, possibly overseen or advised by clinicians. It is not mentioned as a formal clinical study with expert ground truth establishment.
4. Adjudication Method for the Test Set:
- Not applicable in the typical sense of diagnostic performance or clinical outcomes. The bench tests have defined parameters and measurements, with results either meeting or not meeting the acceptance criteria. The "Physician Usability Testing" outcome is reported as "All test results met the acceptance criteria," indicating a singular decision based on the assessment criteria.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical study was performed as there is no change to the indications for use or the fundamental scientific technology for the new model numbers."
6. Standalone (Algorithm Only) Performance Study:
- No, this is a physical medical device (embolization coils), not an AI or software algorithm. Therefore, a standalone algorithm performance study is not applicable.
7. Type of Ground Truth Used:
- Engineering Specifications and Performance Standards: For the bench testing, the "ground truth" is defined by established engineering specifications, performance requirements, and industry standards for medical devices of this type. These standards relate to dimensions, mechanical properties (e.g., force, tensile strength, resistance to deformation), and functional performance (e.g., detachment, deliverability).
- Predicate Device Data: A significant portion of the "ground truth" or basis for comparison comes from the predicate Axium™ Detachable Coil System. The new devices are deemed substantially equivalent by demonstrating similar performance to the already cleared predicate device, and in many cases, adopting the predicate's testing data for aspects where no change occurred or where the change (e.g., smaller size, laser mark) was proven not to negatively impact performance.
8. Sample Size for the Training Set:
- Not applicable. This device does not use machine learning or AI algorithms that would require a 'training set.'
9. How the Ground Truth for the Training Set Was Established:
- Not applicable, as there is no training set for this type of device submission.
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(74 days)
AXIUM DETACHABLE COIL SYSTEM
The Axium ™ Detachable Coil System is indicated for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The Axium™ Detachable Coils are also indicated for arterial and venous embolizations in the peripheral vasculature.
The Axium™ Detachable Coil System consists of a platinum coil secured to a composite delivery wire and is compatible with a 2-marker band micro catheter and a mechanical detachment system. The Axium™ Detachable Coil System consists of three (3) components: 1 -- Implantable Coil, 2 - Implant Delivery Pusher, 3 - Instant Detacher. The Instant Detacher is packaged and sold separately. Axium™ coil configurations include bare platinum, PGLA enlaced platinum and Nylon enlaced platinum coils. Bare configuration coils are non-fiber-enlaced, whereas PGLA and Nylon are enlaced with PGLA and Nylon fibers respectively. This submission expands the size offerings of the Axium™ Detachable Coil System by adding one (1) new model number to the Axium bare product portfolio with a new diameter and coil length combination (SKU QC-1.5-1-Helix). Currently cleared sizes for Axium™ bare under K081465 already include a coil diameter of 1.5mm and a coil length of 1cm; however, not in combination.
This document describes a 510(k) submission for the Axium™ Detachable Coil System, which is a neurovascular embolization device. The submission is for expanding the size offerings of an already cleared device.
Here's an analysis of the provided information concerning acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The provided document describes the performance data in textual form, stating that "The following test(s) was performed to support the addition of the new size offering" and then lists several categories of bench testing. It does not explicitly present a table of acceptance criteria with corresponding reported device performance values. Instead, it states that these tests were "adopted from existing test data for currently cleared Axium™ coil sizes" and that the conclusion is based on "successful completion of non-clinical testing; a thorough assessment of existing test data; as well as identical principles of operation, materials of construction, dimensions, packaging, and indications for use."
Therefore, the acceptance criteria are implicitly that the new size offering (SKU QC-1.5-1-Helix) performs comparably to the previously cleared Axium™ coils in the listed bench tests. The reported device performance is that it did successfully meet these implied criteria.
Implied Acceptance Criteria and Reported Performance:
Acceptance Criteria Category | Reported Device Performance |
---|---|
Dimensions - 1st Loop Outer Diameter | Successfully met (implied by "successful completion of non-clinical testing") |
Dimensions - Length | Successfully met (implied by "successful completion of non-clinical testing") |
Coil Deformation | Successfully met (implied by "successful completion of non-clinical testing") |
Friction | Successfully met (implied by "successful completion of non-clinical testing") |
Fatigue After Knotting and Reliability Detachment | Successfully met (implied by "successful completion of non-clinical testing") |
Torque Response | Successfully met (implied by "successful completion of non-clinical testing") |
Force Transfer - Implant | Successfully met (implied by "successful completion of non-clinical testing") |
Coil Tensile - Polypropylene | Successfully met (implied by "successful completion of non-clinical testing") |
Coil Tensile - Implant/Weld (Implant Coil to Coil Shell Weld) | Successfully met (implied by "successful completion of non-clinical testing") |
Coil Tensile - Assembly | Successfully met (implied by "successful completion of non-clinical testing") |
Particulate | Successfully met (implied by "successful completion of non-clinical testing") |
Pusher Dimensions | Successfully met (implied by "successful completion of non-clinical testing") |
Marker Radiopacity | Successfully met (implied by "successful completion of non-clinical testing") |
Tip Buckling | Successfully met (implied by "successful completion of non-clinical testing") |
Detachment Zone Stiffness | Successfully met (implied by "successful completion of non-clinical testing") |
Kink Resistance | Successfully met (implied by "successful completion of non-clinical testing") |
Hypotube and Weld Tensile Strength | Successfully met (implied by "successful completion of non-clinical testing") |
Force Transfer - Pusher | Successfully met (implied by "successful completion of non-clinical testing") |
Pusher Elongation | Successfully met (implied by "successful completion of non-clinical testing") |
MRI Compatibility | Successfully met (implied by "successful completion of non-clinical testing") |
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 primarily refers to "bench testing" and "existing test data" for currently cleared devices. It does not specify the sample size for the new SKU (QC-1.5-1-Helix) or the provenance (country of origin, retrospective/prospective) of the data. Given it's a 510(k) for an additional size, it's highly likely this is internal R&D data from the company, likely prospective for the new SKU but leveraging retrospective data for comparison to the predicate devices.
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)
This submission does not involve clinical studies with human expert evaluation for establishing ground truth in the traditional sense of a diagnostic or AI device. The testing is bench-based and focuses on physical and mechanical properties. Therefore, these questions are not applicable to this type of submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as this is bench testing, not a clinical study requiring adjudication of expert opinions.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No. This submission is for a physical medical device (detachable coil system) and does not involve AI or a multi-reader, multi-case study. This question is not applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No. This submission is for a physical medical device and does not involve an algorithm or standalone performance testing in this context. This question is not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the bench testing, the "ground truth" would be the established engineering and materials specifications and performance characteristics derived from recognized standards and internal quality control protocols for the predicate devices. These are quantitative and measurable physical properties.
8. The sample size for the training set
This is not an AI/machine learning device; therefore, there is no training set in the conventional sense. The "training data" equivalent in this context would be the extensive manufacturing specifications, material properties, and performance data accumulated from the predicate devices' development and testing.
9. How the ground truth for the training set was established
As there is no training set for an AI algorithm, this question is not applicable. The "ground truth" for the overall device's performance is established through rigorous engineering design, material science characterization, and comprehensive bench testing against established industry standards and internal acceptance criteria for medical devices.
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(84 days)
AXIUM DETACHABLE COIL SYSTEM
The AXIUM™ DETACHABLE COIL SYSTEM is indicated for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The AXIUM™ DETACHABLE COILS are also indicated for arterial and venous embolizations in the peripheral vasculature.
The AXIUM™ DETACHABLE COIL SYSTEM consists of a platinum coil secured to a composite delivery wire and is compatible with a 2-marker band micro catheter and a mechanical detachment system. The AXIUM™ coil configurations include bare platinum, PGLA laced platinum and Nylon laced platinum coils. The AXIUM™ DETACHABLE COIL SYSTEM consists of three components: 1- Implantable Coil, 2- Implant Delivery Pusher, 3- Instant Detacher (called the LRS (Linear Release System) actuator in K060747). The Instant Detacher is packaged and sold separately.
The provided text describes a medical device, the AXIUM™ DETACHABLE COIL SYSTEM, and its regulatory clearance process, focusing on an expanded indication for use. However, it does not include detailed acceptance criteria or a specific study proving the device meets acceptance criteria in the way typically required for AI/algorithm performance.
The document is a 510(k) summary for a medical device (a coil system for embolization), which focuses on demonstrating substantial equivalence to predicate devices rather than proving performance against specific quantitative metrics through a clinical trial or algorithm validation study.
Therefore, many of the requested bullet points regarding acceptance criteria, sample sizes for test/training sets, expert involvement, and comparative effectiveness studies are not applicable or cannot be extracted from this document, as it pertains to a physical medical device, not an AI or algorithmic medical device.
Here's a breakdown of what can and cannot be answered based on the provided text:
1. A table of acceptance criteria and the reported device performance
- Not applicable / Cannot be extracted from this document. This document is for a physical medical device's 510(k) clearance, not an AI or algorithmic device. It does not provide quantitative acceptance criteria or performance metrics in the context of an algorithm's output (e.g., sensitivity, specificity, accuracy). The "Performance Data" section refers to bench and animal testing for the physical device, not for an algorithm.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable / Cannot be extracted from this document. This document does not discuss a "test set" in the context of validating an algorithm. The performance data mentioned (bench and animal testing) relates to the physical device. The information about sample sizes or data provenance for such studies is not detailed here.
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 / Cannot be extracted from this document. This document does not describe the establishment of ground truth for an algorithmic test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable / Cannot be extracted from this document. This document does not involve an algorithmic test set or adjudication.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not applicable / Cannot be extracted from this document. This device is a physical embolization coil system, not an AI-assisted diagnostic or treatment planning system. Therefore, an MRMC study comparing human readers with and without AI assistance is irrelevant to this device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable / Cannot be extracted from this document. This device is a physical medical implant, not a standalone algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable / Cannot be extracted from this document. As there's no algorithm involved, there's no "ground truth" to establish for an algorithm's performance. The "performance data" refers to the physical characteristics and safety of the implant itself, likely validated through engineering tests, animal studies, and comparison to predicate devices, rather than a diagnostic ground truth.
8. The sample size for the training set
- Not applicable / Cannot be extracted from this document. There is no "training set" as this is not an AI/ML device.
9. How the ground truth for the training set was established
- Not applicable / Cannot be extracted from this document. There is no "training set" or corresponding ground truth for an algorithm.
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