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510(k) Data Aggregation

    K Number
    K170373
    Date Cleared
    2017-02-27

    (20 days)

    Product Code
    Regulation Number
    870.1340
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Flextra Steerable Introducer

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

    The Flextra™ Steerable Introducer is introducing various cardiovascular catheters into the heart, including the left side of the heart through the interatrial septum.

    Device Description

    The Flextra Steerable Introducer set contains a steerable introducer, integrated vessel dilator/transseptal needle (component branded as Lancer"), guidewire, and ECG adapter cable. The set is designed to facilitate vascular access to the heart and then provide variable catheter positioning within the cardiac anatomy. The Flextra introducer is an elongated shaft with central lumen capable of accepting the Lancer dilator/needle as well as various cardiac catheters. The shaft has a proximal handle with a rotating actuator that allows the user to change the degree of curvature on the distal tip of the shaft (referred to as steerable tip, deflectable tip, or dynamic tip). Rotating the actuator can deflect the tip, in a planar fashion, +/- 180°. The handle is also fitted with a hemostasis valve to minimize blood loss during catheter introduction, and/or exchange, as well as a sideport with 3way stopcock to allow blood aspiration, fluid infusion, and pressure monitoring. The introducer shaft features distal side holes to facilitate aspiration and prevent cavitation plus an embedded platinum radiopaque tip marker to facilitate fluoroscopic visualization. The Lancer integrated dilator/needle combines the dilator and transseptal needle into a single component. The needle is used to puncture the interatrial septum to gain access to the left atrium. The Lancer consists of an elongated shaft with a tapered tip and central lumen to track over a guidewire in a similar fashion to conventional dilators. The lumen of the Lancer is fitted with a hollow stainless steel transseptal needle and both the shaft and needle are connected to the same proximal handle. The needle lumen will accept guidewire sizes up to 0.032 inches in diameter. Inside the Lancer handle, the needle is affixed to a spring-tensioned actuator that prevents needle extension until the operator purposely advances the needle via a slider button located on the outer surface of the handle. The proximal handle is fitted with a Luer connector to gain access to the central lumen of the needle. The handle is also fitted with an electrical connector to monitor an ECG from the needle while in the heart, utilizing the ECG adapter cable. The guidewire included in the kit is manufactured by Lake Region Medical (K935170) and is supplied in a polypropylene retainer coil with a J-straightener and Luer fitting. The ECG adapter cable included is manufactured by Bioconnect (RF Industries, Inc.), is one (1) meter long, and has male/female DIN 0.080 inch touchproof connectors on the ends.

    AI/ML Overview

    The provided document describes the predicate device and the new device being submitted for 510(k) clearance, the Flextra Steerable Introducer. It focuses on demonstrating substantial equivalence to the predicate device through various non-clinical tests.

    Since this document describes a medical device undergoing premarket notification (510(k)) for substantial equivalence, the "acceptance criteria" are generally established regulatory standards and the "study that proves the device meets the acceptance criteria" refers to the comprehensive non-clinical testing performed to show the device functions as intended and is safe, effective, and performs as well as or better than the predicate device.

    Here's a breakdown of the requested information based on the provided text, recognizing that it pertains to a device, not an AI algorithm:

    1. Table of Acceptance Criteria and Reported Device Performance

    For a medical device, "acceptance criteria" are typically defined by recognized standards and performance specifications derived from these standards or from the predicate device's performance. The "reported device performance" are the results of tests against these criteria.

    Test TypeTest NameAcceptance Criteria (Implicit from "Pass" result and standards)Reported Device Performance (Result)
    BiocompatibilityHemolysis Test (ASTM F756)Non-HemolyticPass, Non-Hemolytic
    Complement Activation (C3a Assay, SC5b-9 Assay)Non-ReactivePass, Non-Reactive
    Platelet and LeukocyteAcceptable levelsPass
    Partial Thromboplastin Time (PTT)Non-ActivatorPass, Non-Activator
    Prothrombin Time Assay (PT)Acceptable levelsPass
    Cytotoxicity (MEM Elution: L-929 Mouse Fibroblast Cells)Non-CytotoxicPass, Non-Cytotoxic
    Sensitization (Guinea Pig Maximization)Non-SensitizerPass, Non-Sensitizer
    Irritation (Intracutaneous Reactivity Test)Non-IrritantPass, Non-Irritant
    Pyrogenicity (Materials Mediated Pyrogenicity Test)Non-PyrogenicPass, Non-Pyrogenic
    Acute Systemic Toxicity Test (Aqueous and Non-Aqueous Extract)Non-ToxicPass, Non-Toxic
    4-hour Thrombogenicity (2 canines)Non-ThrombogenicPass, Non-Thrombogenic
    SterilizationBiological Indicator Population Enumeration TestingMeeting SAL requirements (ANSVA AMI/ISO 11135 overkill approach)Protocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    Bioburden TestingMeeting SAL requirementsProtocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    Product Sterility TestingMeeting SAL requirementsProtocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    Bacteriostasis/Fungistasis TestingMeeting SAL requirementsProtocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    Biological Indicator Sterility TestingMeeting SAL requirementsProtocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    EO Residuals TestingAcceptable levels (ISO 10993-7)Protocol for EO sterilization provided in submission, status "pending sterilization" at time of summary, but implied successful validation by "Results" section.
    PackagingEnvironmental ConditioningMaintain integrity after environmental conditionsPassed
    Distribution Simulation (ASTM D 4169-09, Cycle 13; ISTA 2A)Maintain integrity after distribution simulationPassed
    Visual EvaluationNo damage/defectsPassed
    Bubble Test (ASTM F2096-11)Maintain seal integrityPassed
    Seal Strength (ASTM F88/F88M-15)Maintain seal strengthPassed
    Shelf Life12 Month Accelerated Aging (ASTM F 1980-07)Device function and sterile barrier maintainedPassed at 12 months accelerated aging
    12 Month Real Time AgingDevice function and sterile barrier maintainedOn-going at time of submission, but implies positive initial results.
    Performance TestingProduct Inspection/Dimensional VerificationConform to specificationsAll protocol requirements/specifications met
    Surface InspectionNo defectsAll protocol requirements/specifications met
    Label Legibility & AdhesionLegible and adheredAll protocol requirements/specifications met
    Sheath Compatibility (Insertion/Withdrawal)Acceptable forceAll protocol requirements/specifications met
    Pushability/TrackabilityAcceptable performanceAll protocol requirements/specifications met
    Tip DeflectionMeet specified deflection rangeAll protocol requirements/specifications met
    Tip Curve RetentionMaintain curveAll protocol requirements/specifications met
    System Leak (Liquid, Hemostasis, Luer, Aspiration)No leaksAll protocol requirements/specifications met
    Coating Integrity (Particulate, Friction)Acceptable integrityAll protocol requirements/specifications met
    Kink ResistanceResist kinkingAll protocol requirements/specifications met
    Torque ResistanceResist twistingAll protocol requirements/specifications met
    Tip/Markerband TensileWithstand tensile forcesAll protocol requirements/specifications met
    Sheath to Hemostasis Valve TensileWithstand tensile forcesAll protocol requirements/specifications met
    Shaft to Handle TensileWithstand tensile forcesAll protocol requirements/specifications met
    Needle to Button TensileWithstand tensile forcesAll protocol requirements/specifications met
    Luer to Hypotube TensileWithstand tensile forcesAll protocol requirements/specifications met
    Needle ActuationProper functionAll protocol requirements/specifications met
    Flush Tubing to Stopcock TensileWithstand tensile forcesAll protocol requirements/specifications met
    Flush Tubing to Hemostasis Valve TensileWithstand tensile forcesAll protocol requirements/specifications met
    Electrical Safety (IEC 60601)Meet safety standardsAll protocol requirements/specifications met
    Electrical Continuity Pin-NeedleMaintain continuityAll protocol requirements/specifications met
    Corrosion ResistanceResist corrosionAll protocol requirements/specifications met
    Package Integrity - Bubble LeakMaintain integrityAll protocol requirements/specifications met
    Package Integrity Peel StrengthMaintain strengthAll protocol requirements/specifications met
    Radiopacity (ASTM F640-12)Visible under fluoroscopyAll protocol requirements/specifications met
    Animal StudyPerformance (compared to predicate)Substantially equivalent performance for selected parametersPerformed substantially equivalent to SJM Agilis NxT Steerable Catheter Introducer (K061363)

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

    • Biocompatibility: Various numbers per test, e.g., "2 canines" for thrombogenicity.
    • Sterilization, Packaging, Shelf Life, Performance Testing: The document refers to "samples" or "test devices" but does not specify the exact number of units used for each test. For accelerated aging, it mentions "test devices."
    • Animal Study: "A single animal study was performed that combined the evaluation of another device... to limit the number of animals required." The thrombogenicity test also used "2 canines."
    • Data Provenance: The tests were conducted by various vendors and labs primarily in the USA (Minneapolis, MN; Salt Lake City, UT; Franklin, WI; Eden Prairie, MN). The studies are prospective evaluations of the manufactured device.

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

    Not applicable to this type of device submission. The "ground truth" for device performance is established by objective measurements against engineering specifications and validated test methods (e.g., ASTM, ISO standards), or by comparison to a predicate device in an animal model. There is no mention of human experts establishing ground truth in the context of diagnostic performance or image interpretation.

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

    Not applicable. Adjudication methods like 2+1 (two readers, one adjudicator if disagreement) are typically used in clinical studies or diagnostic performance evaluations for subjective assessments. This document describes objective engineering tests and an animal study.

    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 steerable introducer catheter, not an AI algorithm for diagnostic interpretation. Therefore, no MRMC study or AI-assisted human reader improvement assessment was performed.

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

    Not applicable. The device is a physical medical instrument, not an AI algorithm.

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

    The "ground truth" for this device's performance is established by:

    • Compliance with recognized international and national standards (e.g., ISO, ASTM IEC) for physical, mechanical, chemical, and biological properties.
    • Direct measurement and verification against pre-defined engineering specifications.
    • Comparison to a legally marketed predicate device (SJM Agilis™ NxT Steerable Introducer, K061363) in an animal model for functional and performance aspects, demonstrating substantial equivalence.

    8. The sample size for the training set

    Not applicable. This is a physical medical device, not an AI algorithm that requires a training set.

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

    Not applicable. See point 8.

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