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510(k) Data Aggregation
(22 days)
Indigo Aspiration System - Lightning Aspiration Tubing
INDIGO Aspiration Catheters and Separators: As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral arterial and venous systems, and for the treatment of pulmonary embolism.
INDIGO Aspiration Tubing: As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump: The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
The INDIGO® Aspiration System is comprised of the several devices:
- · INDIGO Aspiration Catheter
- Penumbra Aspiration Pump
- · INDIGO Aspiration Pump Canister
- · INDIGO Aspiration Tubing
- · INDIGO Separator™
The INDIGO Aspiration System is designed to remove thrombus from the vasculature using mechanical aspiration. The INDIGO Aspiration Catheter targets aspiration from the pump directly to the thrombus. The INDIGO Separator may be used to clear the lumen of the INDIGO Aspiration Catheter should it become blocked with thrombus. The INDIGO Aspiration Catheter is introduced through a guide catheter or vascular sheath into the peripheral vasculature and guided over a guidewire to the primary occlusion. The INDIGO Aspiration Catheter is used with the Penumbra Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, an INDIGO Separator may be deployed from the INDIGO Aspiration Catheter to assist with thrombus removal. The INDIGO Separator is advanced and retracted through the INDIGO Aspiration Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the INDIGO Aspiration Catheter tip. The devices are visible under fluoroscopy. For the aspiration source, the INDIGO Aspiration Catheter is used in conjunction with the Penumbra Aspiration Pump, which is connected using the INDIGO Aspiration Tubing and the INDIGO Aspiration Pump Canister. The INDIGO Aspiration Catheter may be provided with a steam shaping mandrel, rotating hemostasis valve, and introducer. The INDIGO Separator may be provided with an introducer and torque device.
Lightning Aspiration Tubing: The Lightning Aspiration Tubing is a component to the currently available Indigo Aspiration System. The Lightning Aspiration Tubing facilitates the transfer of vacuum between the INDIGO Aspiration Catheter and the Penumbra Aspiration Pump while providing aspiration. Intended users for this device are physicians who have received appropriate training in surgical procedures and/or interventional techniques. The device is provided sterile, non-pyrogenic, and intended for single use only.
This document is a 510(k) premarket notification for the Penumbra, Inc. Indigo® Aspiration System - Lightning™ Aspiration Tubing (K210323). It claims substantial equivalence to a predicate device (K193244).
Here's an analysis of the acceptance criteria and study information provided, structured according to your request:
1. Table of Acceptance Criteria and Reported Device Performance:
The document explicitly states that the subject device "met all specifications and testing requirements under the previously established test methods" for the predicate device. However, it does not provide a specific table of quantitative acceptance criteria or detailed reported device performance values. Instead, it makes general statements about meeting requirements.
Acceptance Criterion Type | Reported Device Performance |
---|---|
Bench-top performance (physical and mechanical properties) | "met all specifications and testing requirements" |
Electrical Safety and Suction Equipment Testing (IEC 60601-1, IEC 60601-1-2 & -6) | "successfully met all applicable requirements" |
Biocompatibility | Equivalent to predicate (due to equivalent materials) |
Sterilization | Maintained from predicate |
Packaging Characteristics | Maintained from predicate |
2. Sample Size Used for the Test Set and Data Provenance:
The document mentions "Bench-top performance (design verification)" and "Electrical Safety and Suction Equipment Testing." However, it does not specify the sample sizes used for these tests. The data provenance is also not explicitly stated in terms of country of origin or whether it's retrospective/prospective, but the nature of the testing (bench-top, electrical safety) implies internal laboratory testing, which is typically prospective for verification.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
This information is not applicable and not provided. The testing described relates to the physical and electrical properties of medical device components, not diagnostic accuracy or clinical outcomes that would require expert ground truth establishment.
4. Adjudication Method for the Test Set:
This information is not applicable and not provided. As with point 3, adjudication methods are relevant for studies involving human interpretation or clinical endpoints, not for bench-top or electrical safety testing of device components.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
No, a MRMC comparative effectiveness study was not done. This type of study is relevant for assessing the impact of AI on human reader performance, and the subject device (Lightning Aspiration Tubing) is a physical component, not an AI or imaging diagnostic tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
No, a standalone algorithm performance study was not done. This is not an AI-powered device. The testing described focuses on the physical and electrical performance of the aspiration tubing.
7. The Type of Ground Truth Used:
For the bench-top performance and electrical safety testing, the "ground truth" would be the established engineering specifications and regulatory standards (e.g., IEC 60601 series). The device's performance was compared against these predefined requirements.
8. The Sample Size for the Training Set:
This information is not applicable and not provided. This is not an AI/machine learning device that requires a training set.
9. How the Ground Truth for the Training Set Was Established:
This information is not applicable and not provided. As mentioned, there is no training set for this type of device.
In summary:
This 510(k) submission focuses on demonstrating substantial equivalence of a medical device component (aspiration tubing) through bench-top and electrical safety testing. The criteria for acceptance are compliance with established engineering specifications and regulatory standards. The document asserts that these criteria were met but does not provide the granular data or specific acceptance thresholds that would be found in a detailed test report. It is not an AI-enabled device, and therefore many of the requested data points (like expert ground truth, MRMC studies, training sets) are not relevant to this submission.
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(28 days)
Indigo Aspiration System Lightning Aspiration Tubing
INDIGO Aspiration Catheters and Separators:
As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral arterial and venous systems, and for the treatment of pulmonary embolism.
INDIGO Aspiration Tubing:
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump: The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
The INDIGO® Aspiration System is comprised of several devices:
- INDIGO Aspiration Catheter ●
- Penumbra Aspiration Pump ●
- INDIGO Aspiration Pump Canister
- INDIGO Aspiration Tubing ●
- . INDIGO SeparatorTM
The INDIGO Aspiration System is designed to remove thrombus from the vasculature using mechanical aspiration. The INDIGO Aspiration Catheter targets aspiration from the pump directly to the thrombus. The INDIGO Separator may be used to clear the lumen of the INDIGO Aspiration Catheter should it become blocked with thrombus. The INDIGO Aspiration Catheter is introduced through a guide catheter or vascular sheath and into the peripheral vasculature and guided over a guidewire to the site of the primary occlusion. The INDIGO Aspiration Catheter is used with the Penumbra Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, an INDIGO Separator may be deployed from the INDIGO Aspiration Catheter to assist with thrombus removal. The INDIGO Separator is advanced and retracted through the INDIGO Aspiration Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the INDIGO Aspiration Catheter tip. The devices are visible under fluoroscopy. For the aspiration source, the INDIGO Aspiration Catheter is used in conjunction with the Penumbra Aspiration Pump, which is connected using the INDIGO Aspiration Tubing and the INDIGO Aspiration Pump Canister. The INDIGO Aspiration Catheter may be provided with a steam shaping mandrel, rotating hemostasis valve, and introducer. The INDIGO Separator may be provided with an introducer and torque device.
This document outlines the substantial equivalence of the "Indigo Aspiration System Lightning Aspiration Tubing" (subject device) to a predicate device (K193244) and a reference device (K192833). The review primarily focuses on demonstrating that the subject device is identical to the predicate device and that prior performance data for similar devices within the Indigo Aspiration System remain applicable.
Here's an analysis of the acceptance criteria and supporting studies based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document states: "The subject and predicate Indigo System devices are identical. Therefore, previous device performance data regarding substantial equivalence described below remain unchanged." This implies that the acceptance criteria for the subject device are met by virtue of it being identical to a previously cleared predicate device that had already satisfied those criteria.
Acceptance Criteria Category | Reported Device Performance (Subject Device) | Supporting Evidence |
---|---|---|
Biocompatibility | No changes to previously provided biocompatibility data from K193244 (predicate device). | Implicitly, the subject device meets the biocompatibility criteria established for K193244. |
Bench-Top Performance | No changes to previously provided bench-top data from K193244 (predicate device). | Implicitly, the subject device meets the bench-top performance criteria established for K193244. |
Clinical Performance | No additional clinical data required or performed for these devices. Met by the EXTRACT-PE trial (from K192833, reference device) which demonstrated substantial equivalence for acute PE. Primary efficacy and safety endpoints were met. | Clinical study EXTRACT-PE, associated with reference device K192833. |
Shelf-Life | No changes to previously provided shelf-life data from K193244 (predicate device). The shelf-life for the subject device is "SAME as Predicate Device (K193244)", which is 12 Months. | Implicitly, the subject device meets the shelf-life criteria established for K193244. |
Packaging | No changes to the packaging material listing or the packaging process for the devices cleared in K193244 (predicate device). | Implicitly, the subject device meets the packaging integrity criteria established for K193244. |
2. Sample Size Used for the Test Set and Data Provenance
- Biocompatibility & Bench-Top Performance: Not explicitly stated for the subject device, as these tests were not re-performed. The document refers to data from the predicate device (K193244). The specific sample sizes and provenance for those original tests are not detailed in this document.
- Clinical Performance (EXTRACT-PE Trial): The sample size for the clinical study (EXTRACT-PE) is not specified in this document. The data provenance is also not specified (e.g., country of origin). It is stated as a "clinical study" and "trial," suggesting it was prospective. The document refers to the data from the reference device (K192833).
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not available in the provided document. The document refers to previous clearances (K193244 and K192833) for performance data, but does not detail how ground truth was established for those studies.
4. Adjudication Method for the Test Set
This information is not available in the provided document.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
An MRMC study was not mentioned or implied. The clinical data cited (EXTRACT-PE) appears to focus on device efficacy and safety outcomes rather than reader performance with or without AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device (Indigo Aspiration System Lightning Aspiration Tubing) is a physical medical device, not an algorithm or AI system. Therefore, standalone performance in the context of AI is not relevant here.
7. The Type of Ground Truth Used
For the clinical study (EXTRACT-PE) related to the reference device, the document states it "demonstrated that the Indigo Aspiration System showed substantially equivalent safety and effectiveness outcomes for acute PE. The primary efficacy and safety endpoints were met." This implies that the ground truth was based on clinical outcomes data related to the efficacy of thrombus removal and patient safety in acute pulmonary embolism settings. Specific methods for establishing definitive "ground truth" for patient outcomes (e.g., imaging confirmation, pathology reports, adjudicated clinical events) are not detailed.
8. The Sample Size for the Training Set
This is not applicable. The device is a physical medical device, not an AI model that requires a training set.
9. How the Ground Truth for the Training Set was Established
This is not applicable. The device is a physical medical device, not an AI model.
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(109 days)
Indigo Aspiration System Lightning Aspiration Tubing
INDIGO Aspiration Catheters and Separators: As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral arterial and venous systems.
INDIGO Aspiration Tubing: As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump: The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
The Indigo Aspiration System ("Indigo System") is intended for the removal of fresh, soft emboli and thrombi from vessels of the peripheral arterial and venous systems using the Indigo Aspiration Catheter, Indigo Separator, Indigo Aspiration Tubing, and Penumbra Aspiration Pump. The Indigo System was most recently cleared under K180939.
The INDIGO® Aspiration System is comprised of the several devices:
- · INDIGO Aspiration Catheter
- Penumbra Aspiration Pump
- INDIGO Pump/Canister Tubing
- INDIGO Aspiration Tubing
- INDIGO Separator
The INDIGO Aspiration System is designed to remove thrombus from the vasculature using mechanical aspiration. The INDIGO Aspiration Catheter targets aspiration from the pump directly to the thrombus. The INDIGO Separator may be used to clear the lumen of the INDIGO Aspiration Catheter should it become blocked with thrombus. The INDIGO Aspiration Catheter is introduced through a guide catheter or vascular sheath into the peripheral vasculature and guided over a guidewire to the site of the primary occlusion. The INDIGO Aspiration Catheter is used with the Penumbra Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, an INDIGO Separator may be deployed from the INDIGO Aspiration Catheter to assist with thrombus removal. The INDIGO Separator is advanced and retracted through the INDIGO Aspiration Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the INDIGO Aspiration Catheter tip. The devices are visible under fluoroscopy. For the aspiration source, the INDIGO Aspiration Catheter is used in conjunction with the Penumbra Aspiration Pump, which is connected using the INDIGO Aspiration Tubing and the INDIGO Aspiration Pump Canister. The INDIGO Aspiration Catheter may be provided with a steam shaping mandrel, rotating hemostasis valve, and introducer. The INDIGO Separator may be provided with an introducer and torque device.
Lightning Aspiration Tubing: The Lightning Aspiration Tubing is a component to the currently available Indigo Aspiration System. The Lightning Aspiration Tubing facilitates the transfer of vacuum between the INDIGO Aspiration Catheter and the Penumbra Aspiration Pump while providing aspiration.
This document is a 510(k) Pre-market Notification for a medical device (Indigo Aspiration System - Lightning Aspiration Tubing) and as such, it focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving the device meets acceptance criteria through a comparative effectiveness study with human readers assisting AI or an AI standalone system. The concepts of AI assistance, multi-reader multi-case studies, and specific performance metrics like sensitivity/specificity for AI are not applicable here.
The "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to the engineering and performance testing conducted to ensure the new device functions as intended and is equivalent to the predicate device. The prompt's request for information largely aligns with the type of evaluation performed for an AI-powered diagnostic device, which is not what this document describes.
Therefore, providing a direct answer to all points of the prompt as though the document describes an AI diagnostic or assistive device study would be factually incorrect and misleading.
However, I can extract the relevant information regarding the engineering/performance acceptance criteria and the supporting studies from the provided document as it pertains to the device's substantial equivalence.
Here's how the information can be broken down based on the document's content, focusing on what is present:
Device: Indigo Aspiration System - Lightning Aspiration Tubing
Regulatory Class: Class II
Product Code: QEW (Embolectomy Catheter)
Purpose of Submission: Demonstrate substantial equivalence to a predicate device (K180939, 110 Aspiration Tubing, modified).
1. Table of Acceptance Criteria and Reported Device Performance
The document details various non-clinical tests performed to demonstrate the device meets its design specifications and is substantially equivalent to the predicate. These are more akin to engineering and material acceptance criteria rather than diagnostic performance metrics.
Acceptance Criteria (Attribute/Specification) | Reported Device Performance (Results) |
---|---|
Biocompatibility: | |
In Vitro Cytotoxicity (ISO Elution Test) - Non-Toxic | Pass - Non-Toxic |
Sensitization (ISO Maximization Test) - Non-Sensitizing | Pass - Non-Sensitizing |
Irritation (ISO Intracutaneous Reactivity) - Non-Irritant | Pass - Non-Irritant |
Design Verification (Bench-Top Testing): | |
Dimensional/Visual Inspection (Units meet all product specifications) | Pass |
Simulated Use (Units meet specifications) | Pass |
Tensile Strength (Minimum value per specification) | Pass |
Indigo Aspiration System Compatibility (Must meet specification) | Pass |
Lightning Aspiration Tubing Valve Sense Testing (Must meet specification) | Pass |
Shelf Life: | |
Support a 12-month shelf life (based on accelerated aging) | Shelf life supported |
Sterilization: | |
Ethylene Oxide (EO) gas exposure in accordance with BS EN ISO 11135 | Device provided sterile |
Packaging: | |
Packaging Validation Testing - Met all acceptance criteria | Met all acceptance criteria |
Software Verification and Validation: | |
Complies with FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (Minor Level of Concern) | Complies |
Electrical Safety/EMC Testing: | |
Complies with IEC/EN 60601-1, IEC/EN 60601-1-2, IEC 60601-1-6, and IEC/EN 62366-1 | Complies |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not explicitly stated as a single "test set" in the context of an AI study. The "test sets" for each specific engineering/performance test (e.g., biocompatibility, tensile strength, simulated use) would vary, but the document does not provide the exact sample sizes for each. It generally states that "units" or "the subject device" were tested.
- Data Provenance: The tests are non-clinical (bench-top, laboratory testing) and focused on device performance, not clinical patient data. The provenance is internal to Penumbra, Inc. (Alameda, CA, USA). The document does not specify if any retrospective or prospective patient data was used, as it explicitly states "Clinical Testing was not required".
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This concept is not applicable to this 510(k) submission. "Ground truth" in the context of AI diagnostic performance is typically established by medical experts (e.g., radiologists, pathologists). Here, the "ground truth" for each test is its defined engineering specification or a generally accepted laboratory standard (e.g., ISO guidelines for biocompatibility). The experts would be engineers, chemists, and quality control professionals, but their number and specific qualifications are not detailed in this regulatory summary.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods (like 2+1 or 3+1 consensus) are used for resolving disagreements among human readers or between human readers and AI outputs in diagnostic studies. For engineering tests, results are typically binary (pass/fail) based on objective measurements against pre-defined 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
Not applicable. This device is not an AI-powered diagnostic or assistive tool for human readers. It's a medical device (aspiration tubing) used in a non-AI surgical/interventional procedure. Therefore, no MRMC study with human readers and AI assistance was conducted or described.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device does not involve an algorithm or AI.
7. The Type of Ground Truth Used
The "ground truth" for the various non-clinical tests were:
- Pre-defined engineering specifications (e.g., dimensional requirements, tensile strength minimums).
- International and national standards (e.g., ISO 10993-1 for biocompatibility, IEC/EN 60601 series for electrical safety).
- Results from previously cleared predicate devices for comparison.
8. The Sample Size for the Training Set
Not applicable. This device does not use machine learning or AI, so there is no "training set."
9. How the Ground Truth for the Training Set was Established
Not applicable, as no training set exists for this device.
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