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510(k) Data Aggregation
(220 days)
Penumbra System Penumbra JET 7X
Penumbra Reperfusion Catheters and Separators
As part of the Penumbra System, the Reperfusion Catheters and Separators are indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
Penumbra 3D Revascularization Device
As part of the Penumbra System, the Penumbra 3D Revascularization Device is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
Penumbra Aspiration Tubing
As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
The Penumbra JET 7 with MAX Delivery Device, known as Penumbra JET 7MAX, is an additional configuration being added to the currently available Penumbra System. The MAX Delivery Device is an optional accessory for use with the Penumbra JET 7 Reperfusion Catheter and is removed prior to aspiration. The Reperfusion Catheter Penumbra JET 7 delivers aspiration from the Aspiration Pump directly to the site of occlusion to assist in the removal of thrombus from the neurovasculature. The devices are provided sterile, nonpyrogenic, and intended for single use only.
The provided text describes the 510(k) submission for the Penumbra System® JET™ 7 Reperfusion Catheter with MAX Delivery Device (JET™ 7MAX). The submission primarily relies on non-clinical data (biocompatibility and bench-top testing) and reference to previous animal testing of a predicate device to establish substantial equivalence.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of acceptance criteria and the reported device performance
The document clearly outlines acceptance criteria and results for Biocompatibility Testing and Design Verification (Bench-Top Testing).
Biocompatibility Testing (for MAX Delivery Device only, as Reperfusion Catheter was previously tested):
| Test | Acceptance Criteria | Reported Device Performance (Results) | Conclusion |
|---|---|---|---|
| Cytotoxicity: MEM Elution (10993-5) | Sample extracts must have a cytotoxic reactivity score of grade 2 or lower | Grade = 0 (Reactivity None) | Pass (Non-cytotoxic) |
| Sensitization: Magnusson-Kligman Method (10993-10) | Test Group shall yield Grade 10% in 3 or more animals | No evidence of systemic toxicity from sample extracts (both NaCl and CSO extracts). No deaths, no signs consistent with toxicity, no weight loss > 10% | Pass (Non-toxic) |
| Systemic Toxicity: Material Mediated Pyrogen (10993-11, USP) | Sample extracts must not cause a total rise in body temperature of ≥ 0.5 °C | Non-pyrogenic: no single animal had an individual rise in body temperature ≥ 0.5 °C | Pass (Non-pyrogenic) |
| Hemocompatibility: Prothrombin Time (PT) (10993-4) | Clotting times of test article must be similar to predicate values using analysis of variance. | Test article coagulation times are statistically similar to predicate | Pass (Hemocompatible) |
| Hemocompatibility: Partial Thromboplastin Time (PTT) (10993-4) | Clotting times of test article must be similar to predicate values using analysis of variance | Test article coagulation times are statistically similar to predicate | Pass (Hemocompatible) |
| Hemocompatibility: Complement Activation (10993-4) | The concentration of SC5b-9 of test article must be similar to predicate values using analysis of variance | SC5b-9 Test article concentrations are statistically similar to predicate at all exposure time points: 30min, 60min, 90min | Pass (Hemocompatible) |
| Hemocompatibility: Hemolysis (indirect contact) (10993-4) | Sample extracts must be non-hemolytic (≤ 2% hemolytic index) | Hemolytic Index = 0.22% | Pass (Non-hemolytic) |
| Hemocompatibility: Hemolysis (direct contact) (10993-4) | Sample must be non-hemolytic (≤ 2% hemolytic index) | Hemolytic Index = 0.00% | Pass (Non-hemolytic) |
| Hemocompatibility: In vitro Thrombogenicity (10993-4) | Device must be non-thrombogenic in vtro when compared to predicate device | Test article performed equal or better than predicate in three separate in vitro assays | Pass (Non-thrombogenic) |
Design Verification - Bench-Top Testing:
| Attribute | Specification | Results |
|---|---|---|
| Dimensional/Visual Inspection | Evaluations confirm units meet all product specifications. | Pass |
| Simulated Use [Intracranial Access & Vessel Access Entry Performance, Delivery/Retrieval Forces] | Evaluate effectiveness of device to assist in delivery of Reperfusion Catheter to target site in anatomical neurovasculature model. | Pass |
| Reperfusion Catheter / Access Assist Tool compatibility (Friction Force) | Maximum value per specification | Pass |
| Access Assist Tool / 0.016" Guidewire compatibility (Friction Force) | Maximum value per specification | Pass |
| Markercoil Visibility | The markercoil is fluoroscopically visible | Pass |
| Torsion | Number of turns will be recorded for informational purposes only [FIPO]. | FIPO |
| Corrosion | No visible corrosion immediately after Corrosion Testing procedure | Pass |
| Particulate Testing (≥ 10 um) | ≤ 6000 particles | Pass |
| Particulate Testing (≥ 25 um) | ≤ 600 particles | Pass |
| Particulate Testing (≥ 75 um) | Recorded for informational purposes only [FIPO] | FIPO |
| Particulate Testing (≥ 125 um) | Recorded for informational purposes only [FIPO] | FIPO |
| Coating Integrity (Pre-Inspection) | Coating has not delaminated, peeled, or flaked prior to simulated use particulate testing | Pass |
| Coating Integrity (Post-Inspection) | Coating has not delaminated, peeled, or flaked after simulated use particulate testing | Pass |
| Hub/Air Aspiration | When negative pressure is pulled, no air may leak into hub | Pass |
| Bond Strength Distal Joint 1 | Minimum value per specification | Pass |
| Bond Strength Distal Joint 2 | Minimum value per specification | Pass |
| Bond Strength Midjoint 1 | Minimum value per specification | Pass |
| Bond Strength Midjoint 2 | Minimum value per specification | Pass |
| Proximal Joint | Minimum value per specification | Pass |
| Hub to Shaft Bond Strength | Minimum value per specification | Pass |
| Elongation to Failure - Access Assist Tool | Meets value per specification | Pass |
| Pressure Test | Minimum value per specification | Pass |
2. Sample size used for the test set and the data provenance
- Test set sample size: Not explicitly stated for each test, but implied to be sufficient for the "Pass" results, particularly for biocompatibility (e.g., "no single animal," "2 or more animals" in acceptance criteria implies a small animal sample). For bench testing, it refers to "the units used in this Design Verification testing." No human subjects were involved in the testing for this specific submission.
- Data Provenance: The data is non-clinical (biocompatibility and bench testing), conducted by the manufacturer, Penumbra, Inc. The biocompatibility studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices (GLP). The animal testing for the predicate device (Penumbra JET 7) was performed using a "porcine model" (K173761). The document does not specify the country of origin for the data other than the manufacturer being based in Alameda, California, USA. The studies are prospective in the sense of being planned tests to demonstrate compliance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This submission relies on objective physical and chemical testing (biocompatibility, bench testing) and animal study results rather than expert interpretation of patient data to establish ground truth for the device's performance. The ground truth for these tests is based on pre-defined scientific and engineering specifications and established biological responses.
4. Adjudication method for the test set
Not applicable. As the testing involves objective measurement of physical and biological properties against set specifications, expert adjudication (like in clinical trial image reading) is not required.
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 mechanical medical device (catheter system), not an AI/imaging diagnostic device. Therefore, MRMC studies and AI assistance for human readers are not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an AI/algorithm-based device. Its performance is evaluated through physical, mechanical, and biological testing.
7. The type of ground truth used
The ground truth for this submission is based on:
- Pre-defined quantitative specifications: For bench-top testing (e.g., minimum bond strength, maximum friction force, particulate counts, dimensional measurements).
- Biological response criteria: For biocompatibility testing, based on ISO standards (e.g., cytotoxicity grade, irritation difference, systemic toxicity signs, pyrogenicity temperature rise, hemolytic index, statistical similarity to predicate for clotting times and complement activation).
- Physiological/anatomical models: For simulated use in bench testing and animal models for previous evaluations of the predicate device.
8. The sample size for the training set
Not applicable. This is a medical device approval based on non-clinical performance data and substantial equivalence to a predicate, not an AI/ML model trained on a dataset.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for an AI/ML model in this submission.
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