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510(k) Data Aggregation

    K Number
    K200083
    Date Cleared
    2020-02-14

    (30 days)

    Product Code
    Regulation Number
    870.3300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    EMBA Hourglass Peripheral Embolization Device (PED)

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

    The EMBA Hourglass® Peripheral Embolization Device (PED) is indicated to obstruct or reduce the rate of blood flow in the peripheral vasculature in 6-8mm blood vessels. The device is not indicated for use in blood vessels subject to repetitive motion, such as extremity or pulmonary vessels.

    Device Description

    The Hourglass® Peripheral Embolization Device (PED) consists of a covered, implantable, self-expanding hourglass-shaped structure (Embolic Device) preloaded in a catheter-based Delivery System. The Embolic Device is intended to be deployed to the target site in the vasculature under fluoroscopic guidance. The product is shipped sterile and labeled for single use only.

    AI/ML Overview

    This FDA 510(k) summary (K200083) indicates that the device, EMBA Hourglass® Peripheral Embolization Device (PED), is substantially equivalent to a predicate device (K171845). The submission explicitly states that "no additional testing is required" for the current device because it is considered substantially equivalent to its predicate.

    Therefore, based on the provided document, there are no specific acceptance criteria or details of a study performed specifically for this device (K200083). Instead, the justification for substantial equivalence relies on the testing of the predicate device.

    However, I can extract the information regarding the comparison between the subject device and the predicate device, and the general statement about performance testing.

    Here's a breakdown of the requested information, where applicable:

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

    Since the document states that "no additional testing is required" for the subject device (K200083), there are no new acceptance criteria or reported performance unique to this submission. The substantial equivalence is based on the predicate device's performance.

    Acceptance Criteria (for Predicate Device)Reported Device Performance (for Predicate Device)
    Not explicitly stated in this document (refers to predicate's testing)Not explicitly stated for the subject device (relies on predicate's performance)
    Implied Acceptance (for K200083 based on K171845)
    Device functions as intended to obstruct or reduce blood flow in 6-8mm peripheral vessels.Maintains functionality for obstructing/reducing blood flow in 6-8mm peripheral vessels.
    Material and manufacturing process consistency with predicate.Same materials and manufacturing processes as predicate.
    BiocompatibilityPassed biocompatibility testing (of predicate device per ISO 10993-1).

    2. Sample size used for the test set and the data provenance:

    • Sample Size: Not applicable. No new test set for K200083. The document states that "bench, animal, and clinical testing performed for the predicate device are adequate."
    • Data Provenance: Not applicable for K200083. The origin of data for the predicate device's testing is not mentioned in this document.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. No new test set and no ground truth establishment for K200083.

    4. Adjudication method for the test set:

    • Not applicable. No new test set for K200083.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • Not applicable. This device is a physical embolization device, not an AI-assisted diagnostic tool.

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

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

    7. The type of ground truth used:

    • Not applicable for K200083. The "ground truth" for the predicate device's performance would likely have involved direct observation of embolization effectiveness in animal models, and clinical outcomes if clinical studies were part of its submission.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/machine learning device.

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

    • Not applicable. This is not an AI/machine learning device.

    Key takeaway from the document:

    The regulatory strategy for K200083 is based on substantial equivalence to a predicate device (K171845). The primary difference noted is the Delivery System length (80cm vs. 120cm). All other design and material characteristics, as well as manufacturing processes, are stated to be identical. Due to these similarities and a risk analysis concluding no new or modified risks, the prior performance testing (bench, animal, clinical) and biocompatibility testing of the predicate device are deemed sufficient for this new submission.

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    K Number
    K171845
    Date Cleared
    2017-08-18

    (59 days)

    Product Code
    Regulation Number
    870.3300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    EMBA Hourglass Peripheral Embolization Device

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

    The EMBA Peripheral Embolization Device (PED) is indicated to obstruct or reduce the rate of blood flow in the peripheral vasculature in 6-8mm blood vessels. The device is not indicated for use in blood vessels subject to repetitive motion, such as extremity or pulmonary vessels.

    Device Description

    The EMBA™ HOURGLASS™ Peripheral Embolization Device (PED) consists of a covered, implantable, self-expanding structure (Embolic Device) preloaded in a catheter-based Delivery System. The Embolic Device is intended to be deployed to the target site in the vasculature under fluoroscopic guidance. The product is shipped sterile and labeled for single use only.

    AI/ML Overview

    This document describes the EMBA™ HOURGLASS™ Peripheral Embolization Device (PED). The information provided focuses on the device's substantial equivalence to predicate devices rather than a detailed study proving it meets specific quantitative acceptance criteria for performance metrics in a clinical setting.

    Here's an analysis based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not provide a table of quantitative acceptance criteria for performance metrics (e.g., specific thresholds for occlusion rates, migration rates, etc.) that the device was evaluated against in a clinical study. Instead, it lists various comparative performance tests conducted to demonstrate substantial equivalence to predicate devices. These tests focused on design and functional characteristics to show that technological differences do not raise new safety or effectiveness concerns.

    Performance CharacteristicAcceptance Criteria (Implicit)Reported Device Performance
    Mechanical/Physical
    Kink RadiusDemonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit in "Comparative performance testing was conducted to demonstrate that the technological differences... do not raise concerns of substantial equivalence").
    TrackabilityDemonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit).
    Partial Deployment &Demonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit).
    Retraction
    Deployment AccuracyDemonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit).
    Chronic Outward ForceDemonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit).
    Embolic Device Length &Within specified design ranges and comparable to predicate devices.Conducted; passed (implicit). Device dimensions are provided in the DEVICE DESCRIPTION section (e.g., 10mm diameter, 20mm length).
    Diameter
    ForeshorteningDemonstrates performance comparable to predicate devices and does not introduce new safety concerns.Conducted; passed (implicit).
    Contrast FlowDemonstrates performance comparable to predicate devices and does not introduce new safety concerns (e.g., allows for adequate visualization).Conducted; passed (implicit).
    Migration ResistanceDemonstrates performance comparable to predicate devices and does not introduce new safety concerns (e.g., device stays in intended location).Conducted; passed (implicit).
    Occlusion EffectivenessDemonstrates performance comparable to predicate devices and does not introduce new safety concerns (e.g., obstructs blood flow as intended).Conducted; passed (implicit). The fundamental purpose of the device is to obstruct or reduce blood flow.
    CorrosionDemonstrates biocompatibility and structural integrity.Conducted; passed (implicit).
    Fatigue TestingDemonstrates durability and structural integrity over time.Conducted; passed (implicit).
    Delivery System IntegrityDemonstrates safe and effective delivery of the device.Conducted; passed (implicit).
    BiocompatibilityBiocompatible in accordance with ISO 10993."The subject device... passed appropriate ISO 10993 testing to demonstrate biocompatibility."
    SterilityTerminally sterilized by ethylene oxide (EtO)."All of the devices are terminally sterilized by ethylene oxide (EtO)."
    MR CompatibilitySafe for use in an MR environment.Conducted; passed (implicit).
    Shelf LifeMaintains performance and sterility over its stated shelf life.Conducted; passed (implicit).
    Clinical Safety &Demonstrated safety and effectiveness endpoints."Human Use Clinical Testing has been conducted on the EMBA™ HOURGLASS™ Peripheral Embolization Device (PED) (n=51) to evaluate safety and effectiveness endpoints." (No specific metrics or results are provided in this summary, just that it was evaluated.)
    Effectiveness (Human Use)

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

    • Sample Size: Human Use Clinical Testing was conducted on n=51.
    • Data Provenance: The document does not specify the country of origin. The study appears to be a prospective human use clinical study, although full details are not provided in this summary.

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

    • The document does not mention the number of experts used to establish ground truth for the clinical test set or their specific qualifications. It only states that human use clinical testing was conducted to evaluate "safety and effectiveness endpoints," implying clinical assessment by medical professionals.

    4. Adjudication Method for the Test Set:

    • The document does not specify the adjudication method used for the clinical test set.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    • No, this was not an MRMC comparative effectiveness study. The text discusses comparative performance testing against predicate devices, but this refers to bench testing and animal testing, and for the human use study, it was to evaluate safety and effectiveness endpoints of the EMBA device itself, not to compare human readers with and without AI assistance. The device is a physical medical implant, not an AI diagnostic tool.

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

    • This question is not applicable as the EMBA™ HOURGLASS™ Peripheral Embolization Device is a physical medical device, not a software algorithm. Its "standalone" performance would typically refer to its mechanical and functional performance in in-vitro or animal models, which was indeed performed as "comparative performance testing."

    7. The Type of Ground Truth Used:

    • For the human use clinical testing, the "ground truth" would implicitly be clinical outcomes data assessed by medical professionals, related to the safety and effectiveness of the device's embolization. For the non-clinical performance tests (Kink Radius, Trackability, Migration Resistance, Occlusion Effectiveness, etc.), the "ground truth" was established by engineering and scientific measurements against predefined specifications or comparison with predicate device performance.

    8. The Sample Size for the Training Set:

    • This question is not applicable as the device is a physical medical implant, not an AI algorithm that requires a "training set" in the context of machine learning.

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

    • This question is not applicable for the same reason as point 8.
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