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510(k) Data Aggregation

    K Number
    K173614
    Manufacturer
    Date Cleared
    2018-04-17

    (146 days)

    Product Code
    Regulation Number
    882.5950
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Penumbra Coil 400, Ruby Coil System, POD System

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

    Penumbra Coil 400:

    • Intracranial aneurysms.
    • Other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae.
    • Arterial and venous embolizations in the peripheral vasculature.

    Ruby Coil System:

    • Arterial and venous embolizations in the peripheral vasculature.

    POD System (For POD Coils with nominal sizes ≤ 6 mm):

    • Intracranial aneurysms.
    • Other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae.
    • Arterial and venous embolizations in the peripheral vasculature.

    POD System (For POD Coils with nominal sizes > 6 mm):

    • Arterial and venous embolizations in the peripheral vasculature.
    Device Description

    The subject devices (Penumbra Coil System and POD System) are designed for embolization in the neuro and/or peripheral vasculature. This is achieved by using coils to exclude the intended treatment area from blood flow, thus creating stasis and allowing thrombosis to occur. The subject devices consist of a bare platinum embolization coil for the treatment of aneurysms or other vascular abnormalities. The devices should only be used by physicians who have received appropriate training in interventional techniques.

    The subject devices consist of the following components:

    • Coil: The Coil is attached to a Delivery Pusher both contained within an Introducer Sheath. The Coil is an implantable medical device intended to exclude the treatment area from blood flow, thus creating stasis and allowing thrombosis to occur.
    • Delivery Pusher: The Delivery Pusher is composed of a shaft with a radiopaque positioning marker, a Distal Detachment Tip (DDT) and a pull wire. The Delivery Pusher may also be referred to as the Detachment Pusher.
    • Introducer Sheath: The Introducer Sheath is intended to cover the entire length of the Coil and the distal flexible segment of the Delivery Pusher. The Introducer Sheath is secured onto the Delivery Pusher with a friction lock to prevent unsheathing until use.
    • Detachment Handle: The Detachment Handle is packaged separately. It is intended for use in multiple coil detachments performed during a single procedure.
    AI/ML Overview

    This document, a 510(k) Premarket Notification for the Penumbra Coil System and POD System, focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study proving a device meets specific acceptance criteria for performance, especially concerning Artificial Intelligence (AI) or software-based diagnostics.

    Therefore, many of the requested details about acceptance criteria, clinical study design (sample size, data provenance, expert ground truth, adjudication, MRMC study, standalone performance), and training set information are not applicable to this type of submission. This document describes a medical device (embolization coils) that is a physical product, not an AI/software device.

    Here's an attempt to extract relevant information and note where the requested information is not present:

    Device: Penumbra Coil System (Penumbra Coil 400 and Ruby Coil System); POD System
    Device Type: Neurovascular Embolization Device


    Acceptance Criteria and Reported Device Performance (Non-AI/Software Context)

    For this physical device, "acceptance criteria" are typically defined by engineering specifications and performance benchmarks, proven through bench-top (laboratory) and biocompatibility testing. The "performance" is the passing of these tests, demonstrating that the device functions as intended and is safe.

    Here's a table based on the provided "Bench-Top Testing" and "Biocompatibility Testing" sections:

    Feature/Test CategoryAcceptance Criteria (Specification)Reported Device Performance (Results)
    Bench-Top Testing
    Dimensional/Visual InspectionMeet all product specificationsPass
    Fatigue ResistanceCoil retains secondary shape after cycling into/out of 0.025 in. ID microcatheterPass
    Torsional ResistanceMinimum value per specificationPass
    Friction (Pull & Push)Maximum value per specificationPass
    Simulated Use Flow Model TestingEffectiveness to embolize targeted vasculature in anatomical modelPass
    Distal System Tensile TestMinimum per specificationPass
    Stiffness TestingMaximum value per specificationPass
    Biocompatibility Testing
    In Vitro CytotoxicityNon-ToxicNon-Toxic
    SensitizationNon-SensitizingNon-Sensitizing
    Irritation (Intracutaneous Reactivity)Non-IrritantNon-Irritant
    Implant studyNon-IrritantNon-Irritant
    Systemic Toxicity (Acute)Non-ToxicNon-Toxic
    Material Mediated PyrogenNon-PyrogenicNon-Pyrogenic
    Sub-Chronic Toxicity (Sub-Acute Toxicity)Non-ToxicNon-Toxic
    In Vitro HemolysisNon-HemolyticNon-Hemolytic
    Dog Thrombogenicity CoagulationNon-ThrombogenicNon-Thrombogenic
    Complement ActivationNo greater biological response than corresponding controlNo greater biological response than corresponding control
    Genotoxicity (Mouse Lymphoma)Non-MutagenicNon-Mutagenic
    Genotoxicity (Ames Mutagenicity)Non-MutagenicNon-Mutagenic
    Genotoxicity (In Vivo Mouse Micronucleus)Non-MutagenicNon-Mutagenic
    MR Compatibility TestingCompliant with ASTM F2182-11, F2052-15, F2213-06 (R-11), F2119-07 (R-13) for 1.5T & 3T MR environmentsTesting performed; advises MR conditional statement in IFU
    MRA TestingMaximum artifact distance beyond implant of 2 mm using clinical MRA sequenceMaximum artifact distance was 2 mm

    Information Not Applicable or Not Provided for This Type of Submission (AI/Software-Specific Questions)

    1. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):

      • N/A. This is a physical device, and the "test set" here refers to the number of units or biological samples used in bench-top and biocompatibility testing, not a clinical data set for an AI model. The document does not specify the number of units tested for each bench-top criterion. Biocompatibility tests followed ISO and CFR guidelines.
    2. 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):

      • N/A. Ground truth establishment by experts is relevant for AI/diagnostic software. For a physical device, ground truth is established by objective measurements against engineering specifications and biological material reactions.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • N/A. Adjudication is for resolving discrepancies in expert interpretations, not for physical device testing.
    4. 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:

      • N/A. This applies to AI-assisted diagnostic tools, not physical embolization coils.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • N/A. This applies to AI/software.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For this device, "ground truth" related to performance is based on engineering specifications, direct physical measurements, and well-established biological response criteria (e.g., cell viability, immune response markers) in a laboratory setting, as well as adherence to recognized standards like ASTM and ISO. There is no "expert consensus" on ground truth for the physical and biological properties being tested here in the way there would be for a diagnostic image.
    7. The sample size for the training set:

      • N/A. There is no "training set" as this is not an AI/machine learning device.
    8. How the ground truth for the training set was established:

      • N/A. There is no "training set" or AI model.
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