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510(k) Data Aggregation

    K Number
    K051916
    Date Cleared
    2005-08-05

    (21 days)

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

    The PolarCath Peripheral Dilatation System is indicated to dilate stenoses in the peripheral vasculature (iliac, femoral, popliteal, infrapopliteal, renal and subclavian arteries) and for the treatment of obstructive lesions of polytetrafluoroethylene (PTFE) access grafts or arteriovenous dialysis fistulae. The PolarCath Peripheral Dilatation System is also indicated for post-deployed stent expansion of self-expanding peripheral vascular stents.

    Device Description

    The PolarCath Peripheral Dilatation System consists of a Catheter, Inflation Unit, connecting cable and a rechargeable battery pack with recharging unit and battery receptacle. The inflation medium (liquid nitrous oxide) is provided in a disposable 14 gram cartridge.

    AI/ML Overview

    This submission (K051916) by CryoVascular Systems, Inc. for the PolarCath™ Peripheral Dilatation System does not include detailed acceptance criteria or a dedicated study report proving the device meets specific performance criteria in the way typically seen for a new or significantly modified device requiring extensive clinical trials.

    Instead, the submission relies heavily on substantial equivalence to a predicate device. This is a common pathway for 510(k) clearances where the new device is "as safe and effective as" an already legally marketed device.

    Here's an analysis based on the provided documents:


    1. Table of Acceptance Criteria and Reported Device Performance:

    Based on the provided documents, there isn't a table of specific acceptance criteria (e.g., specific lumens, burst pressures, deployment times) and corresponding reported performance from a formal study. The primary statement regarding performance is:

    Acceptance CriteriaReported Device Performance
    Safety and Effectiveness demonstratedDemonstrated with design control activities and bench testing on file at CryoVascular Systems, Inc. (Specific metrics not provided in this summary)
    Substantially Equivalent to predicate deviceDesign, materials, manufacturing process, and intended use are substantially equivalent to the predicate device and other marketed PTA catheters.

    Explanation: In a substantial equivalence submission like this, the "acceptance criteria" are implicitly met if the device can demonstrate it is as safe and effective as a legally marketed predicate device, often through a combination of design controls, bench testing data, and sometimes animal or clinical data if the differences are significant. This summary explicitly states that the safety and effectiveness are demonstrated with design control activities and bench testing, but the specifics of those findings are "on file" and not detailed in the provided K document.

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

    • Test Set Sample Size: Not specified in the provided documents. The filing mentions "bench testing" but doesn't detail the number of units tested or specific parameters.
    • Data Provenance: The data provenance is internal, originating from CryoVascular Systems, Inc. It appears to be primarily retrospective in the sense that it relies on existing design controls and bench testing, rather than a prospective clinical trial designed to collect specific performance data for this submission. The origin is the USA (California, based on the sponsor's address).

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

    This information is not applicable and not provided in the context of this 510(k) summary. For a device like a angioplasty catheter primarily relying on bench testing and substantial equivalence, there isn't an "expert" review of a clinical test set to establish ground truth in the way there would be for an AI diagnostic device. The "ground truth" here relates to engineering specifications and performance against those specifications, which are typically evaluated by internal engineers and quality control personnel.

    4. Adjudication Method for the Test Set:

    This information is not applicable and not provided. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies where multiple human readers interpret medical images or data against a reference standard. For a device primarily cleared based on bench testing and substantial equivalence, this type of adjudication is not relevant.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size of Human Reader Improvement:

    No, a MRMC comparative effectiveness study was not done according to the provided documents. This type of study is common for AI systems that assist human readers in diagnosing or detecting conditions on medical images. This 510(k) is for a medical device (catheter), not an AI-powered diagnostic tool.

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

    No, a standalone study was not done. This is not an AI algorithm. The device is a physical medical device (catheter) used by a human operator, making the concept of a "standalone" algorithm study irrelevant.

    7. The Type of Ground Truth Used:

    The "ground truth" for this device, as implied by the submission, would be based on:

    • Engineering Specifications: The design and performance parameters the catheter is intended to meet (e.g., catheter dimensions, inflation pressure, burst pressure, material integrity).
    • Bench Test Results: Direct measurements and observations from laboratory testing verifying these specifications.
    • Predicate Device Performance: The known safety and effectiveness profile of the legally marketed predicate device, which the PolarCath is demonstrated to be substantially equivalent to.

    8. The Sample Size for the Training Set:

    This information is not applicable and not provided. "Training set" refers to data used to train machine learning models. This 510(k) is for a physical medical device and does not involve AI or machine learning.

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

    This information is not applicable and not provided, as there is no training set for an AI algorithm in this context.


    Summary of the K051916 Submission Approach:

    The K051916 submission primarily relies on the substantial equivalence pathway. This means the applicant demonstrated that the PolarCath™ Peripheral Dilatation System is "as safe and as effective" as a legally marketed predicate device. This demonstration is typically achieved through:

    • Comparison of Device Characteristics: Showing that the design, materials, manufacturing process, and intended use are similar to the predicate.
    • Bench Testing: Laboratory tests to ensure the device meets its own engineering specifications and performs comparably to the predicate for critical parameters (e.g., burst pressure, inflation/deflation times, guidewire compatibility).
    • Risk Analysis and Design Controls: Ensuring that potential risks have been identified and mitigated through the design and manufacturing process.

    The provided documents explicitly state: "The safety and effectiveness of the modified PolarCath Peripheral Dilatation System is demonstrated with design control activities and bench testing on file at CryoVascular Systems, Inc." This indicates that studies were conducted, but the detailed results and specific acceptance criteria used in those studies are retained by the manufacturer and summarized in this high-level document. They are not typically elaborated in the public 510(k) summary if substantial equivalence is the primary basis for clearance.

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