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510(k) Data Aggregation

    K Number
    K230957
    Date Cleared
    2023-05-02

    (28 days)

    Product Code
    Regulation Number
    870.1210
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    TriSalus TriNav**®** LV Infusion System

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

    The TriSalus TriNav® LV Infusion System is intended for use in angiographic procedures. It delivers radiopaque media and therapeutic agents to selected sites in the peripheral vascular system.

    Device Description

    The TriSalus® TriNav® LV Infusion System is a 0.025" lumen microcatheter, a self-expanding tip at the distal end. The TriNav® LV serves as the conduit for physician-specified agents such as contrast agents, flush solutions, and embolic beads. It is compatible with standard guide wires with outer diameter up to 0.018" (0.46 mm), guiding catheters with inner diameter at least 0.048" (1.22 mm), embolic hydrogel particles 500 um or less in size and glass microspheres 110 um or less in size. The TriNav® LV has a PTFE inner liner to provide a lubricious surface for passage of physician-specified agents and other accessory devices. The device is hydrophilically coated. The soft, pliable, self-expanding tip is sized for use in vessels 3.0 mm to 5.0 mm in diameter. An optional, commercially available hemostasis valve (HV) is included. There are two radiopaque markers located at the distal end of the TriNav® LV device to aid in positioning of the self-expanding tip. When in correct position, the self-expanding tip is designed to improve infusion efficiency of compatible embolic agents while maintaining antegrade flow in various size vessels. The TriSalus® TriNav® LV Infusion System is provided sterile (EtO) for single patient use.

    AI/ML Overview

    The TriSalus® TriNav® LV Infusion System is explicitly stated as not having undergone clinical testing to demonstrate substantial equivalence. Instead, the submission relies on animal and bench performance test data. Therefore, the request for details on acceptance criteria and study proving the device meets them in the context of human clinical performance cannot be fully answered from the provided text.

    However, based on the provided text, we can describe the performance testing conducted and the general acceptance criteria used:

    The document states that the TriSalus® TriNav® LV Infusion System meets the same performance specifications and acceptance criteria as the predicate device. This implies that the acceptance criteria are tied to demonstrating equivalence or non-inferiority to the predicate device across various performance aspects.

    Here's an attempt to extract relevant information based on the provided text, focusing on the type of studies conducted and what constitutes "performance" in this context for the device's clearance:

    Device Performance Study (Bench and Animal Testing for Substantial Equivalence)

    The performance of the TriSalus® TriNav® LV Infusion System was demonstrated through a series of bench testing and an animal study to show substantial equivalence to a predicate device (Surefire Spark Infusion System (rebranded as TriNav) K180677).

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally "meets the same performance specifications" and "acceptable/comparable" to the predicate device.
    Since this document is a 510(k) summary, specific numerical acceptance thresholds and detailed performance results are not typically disclosed. However, the categories of performance evaluated are provided.

    Acceptance Criteria (Inferred)Reported Device Performance (Summary from Text)
    Visual and DimensionalMeets specifications; comparable to predicate.
    Tensile (Pull) StrengthsMeets specifications; comparable to predicate.
    Kink RadiusMeets specifications; comparable to predicate.
    Torque ResistanceMeets specifications; comparable to predicate.
    Burst PressureMeets specifications; comparable to predicate.
    Hub AspirationMeets specifications; comparable to predicate.
    Hub Solvent CompatibilityMeets specifications; comparable to predicate.
    Coating Durability and UniformityMeets specifications; comparable to predicate.
    EtO ResidualsMeets specifications; comparable to predicate.
    Coating Frictional ForceMeets specifications; comparable to predicate.
    Base Catheter Insertion/Retraction ForceMeets specifications; comparable to predicate.
    Diagnostic Agent CompatibilityMeets specifications; comparable to predicate.
    Embolic Agent CompatibilityMeets specifications; comparable to predicate.
    Infusion EfficiencyMeets specifications; comparable to predicate.
    Antegrade FlowMeets specifications; comparable to predicate.
    ParticulatesMeets specifications; comparable to predicate.
    Pouch IntegrityMeets specifications; comparable to predicate.
    Pouch Seal StrengthMeets specifications; comparable to predicate.
    Biocompatibility (various tests per ISO 10993)No significant biological reaction; acceptable through GLP testing.
    Acute performance in simulated clinical environment (Animal Study)Acceptable in all evaluated categories, met defined user needs, performed comparably to predicate.

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

    • Test Set (Bench Testing): Not specified.
    • Test Set (Animal Study): Not specified. The text only states "An animal study was performed."
    • Data Provenance: Not specified, but generally, bench testing would be conducted in a lab and animal studies in a vivarium. The studies are prospective in nature for device validation.

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

    • Bench Testing: Not applicable in the context of human expert ground truth.
    • Animal Study: The study assessed performance "as defined by physicians in a simulated clinical environment." The number and qualifications of these physicians are not specified.

    4. Adjudication Method for the Test Set

    • Not specified. This is less relevant for bench and animal studies compared to human reader studies.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    • No, an MRMC study was NOT done. The document explicitly states: "No clinical testing was required to demonstrate the substantial equivalence of the subject device to its predicates. Therefore, no pre-market clinical testing was performed nor is any included within this 510(k) submission."

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

    • Not applicable as this is a physical medical device, not an AI algorithm.

    7. The Type of Ground Truth Used

    • Bench Testing: Engineering specifications, material standards, and comparisons against predicate device performance data (presumably internal data or published specifications for the predicate).
    • Animal Study: Direct observation by "physicians" in a "simulated clinical environment" and relevant biological/physiological measurements. The "ground truth" for success was defined by "defined user needs" and "comparability to the predicate device."

    8. The Sample Size for the Training Set

    • Not applicable as this is a physical medical device, not a machine learning model.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable.
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