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510(k) Data Aggregation

    K Number
    K123560
    Date Cleared
    2013-01-25

    (67 days)

    Product Code
    Regulation Number
    882.5950
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Pushable Coils may be used to reduce or block the rate of blood flow in vessels of the peripheral and neurovasculature. They are intended for use in the interventional radiologic management of arteriovenous malformations, arteriovenous fistulas, and other vascular lesions of the brain, spinal cord and spine.

    The TRUFILL DCS ORBIT Detachable Coil System is indicated for embolizing intracranial aneurysms and other vascular malformations such as arteriovenous malformations and arteriovenous fistulae of the neurovasculature. The TRUFILL DCS ORBIT Detachable Coil is also intended for arterial and venous embolization in the peripheral vasculature.

    Device Description

    The intent of endovascular treatment using embolic microcoils is to pack the lumen of the aneurysm with the microcoil mass, thereby eliminating the influx of blood into the aneurysm. As blood flow is disrupted within the aneurysm, intraluminal thrombosis leads to exclusion of blood flow from the parent artery into the aneurysm. Blood flow in the parent artery is then secluded from the aneurysm and the weakened wall of the aneurysm is isolated from arterial pressures. Coil embolization may also be used to treat arteriovenous malformations and fistulas by packing coils into the lumen of the parent vessel feeding into the unwanted arteriovenous structure, resulting in cessation of blood flow. Stagnated blood within the arteriovenous malformation or fistula then thromboses, leading to involution and absorption of the aberrant vessels.

    The TRUFILL Vascular Occlusion System:
    The Vascular Occlusion System consists of the TRUFILL Pushable Coils and TRUPUSH Coil Pusher. The TRUFILL Pushable Coil is loaded into the proximal end of a compatible microcatheter and advanced through the catheter to the desired vessel location. The coil is deployed using the TRUPUSH Coil Pusher which is sold separately. The TRUFILL Pushable Coils are made from platinum/tungsten and synthetic fibers, and are designed for use under fluoroscopy with the TRUPUSH Coil Pusher and microcatheters having a minimum ,021" I.D. (0.5 mm). The TRUFILL Pushable coils are available in straight and shaped configurations.

    The TRUFILL DCS ORBIT Detachable Coil System:
    The TRUFILL DCS ORBIT Detachable Coil System consists of a delivery system (delivery tube and coil introducer) and an embolic coil. The embolic coil is the implantable segment of the device, and is comprised of a vasoocclusion coil wound from a platinum alloy wire into a primary coil and then formed into a secondary helical or complex shape. The embolic coil is detached from the delivery tube via a proprietary hydraulic release mechanism using the TRUFILL DCS Syringe II which is sold separately. The TRUFILL DCS ORBIT Detachable Coil System is designed for use under fluoroscopy with compatible infusion catheters, and is available in Standard and Fill configurations.

    AI/ML Overview

    The provided 510(k) summary (K123560) describes the TRUFILL® Pushable Coils and TRUFILL® DCS ORBIT™ Detachable Coil System.

    Acceptance Criteria and Device Performance:

    The submission aimed to demonstrate substantial equivalence to previously cleared predicate devices. Since no new technological characteristics were introduced, the primary acceptance criteria revolved around demonstrating that the packaging modifications did not negatively impact the device's design, safety, operation, or performance.

    Acceptance Criteria (Bench Testing)Reported Device Performance
    Maintain Package IntegrityDemonstrated that packaging modifications do not impact design, safety, operation, or performance.
    Pass Dye Leak Test (Package Integrity)Passed
    Pass Visual Inspection (Package Integrity)Passed
    Pass Seal Strength Test (Package Integrity)Passed
    Pass Biocompatibility Testing (Cytotoxicity)Passed
    Pass Sterilization Verification Testing (EO/ECH Residuals)Passed
    Maintain Packaging Shelf Life (Dye Leak, Visual Inspection, Seal Strength)Passed
    Maintain Original Intended UseNo change
    Maintain Original Operating PrincipleNo change
    Maintain Original DesignNo change
    Maintain Original Materials (except coating on Tyvek pouch)No change
    Maintain Original Dimensions (except packaging pouch for Detachable Coils)No change
    Maintain Original Manufacturing Process & LocationsNo change
    Maintain Original Sterilization Process & LocationNo change
    Maintain Original Shelf LifeNo change

    Study Details:

    The study described in this 510(k) summary is non-clinical testing, specifically bench testing, to demonstrate substantial equivalence for packaging modifications.

    • Sample size used for the test set and the data provenance: The document does not specify the exact sample sizes for each bench test conducted (e.g., number of packages tested for dye leak). It only states that "Codman performed non-clinical testing necessary to demonstrate substantial equivalence to the predicate devices." The data provenance is internal testing performed by Codman & Shurtleff, Inc., as stated in section G. "Summary of Nonclinical Testing" and H. "Summary of Clinical Testing". Given the nature of bench testing, it is prospective for the specific tests performed to evaluate the modified packaging components.

    • 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): Not applicable. This was bench testing of physical properties and packaging, not clinical interpretation requiring expert consensus.

    • Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. This was bench testing of physical properties and packaging, not clinical interpretation.

    • 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: No. This submission is for physical medical devices (catheters and coils) and does not involve AI or human reader interpretation.

    • If a standalone (i.e. algorithm only without human-in-the loop performance) was done: No. This submission is for physical medical devices and does not involve algorithms.

    • The type of ground truth used (expert consensus, pathology, outcomes data, etc): The "ground truth" for this non-clinical testing was defined by established engineering and material science standards for device performance, packaging integrity, biocompatibility, and sterilization, as confirmed through the various bench tests listed.

    • The sample size for the training set: Not applicable. This was non-clinical testing of physical products, not an AI or machine learning model that requires a training set.

    • How the ground truth for the training set was established: Not applicable.

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    K Number
    K071962
    Date Cleared
    2007-09-26

    (72 days)

    Product Code
    Regulation Number
    882.5950
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The intended use of the TRUFILL® Vascular Occlusion System (TRUFILL® Pushable Coils and TRUPUSH® Coil Pusher) is as follows:

    Pushable Coils may be used to reduce or block the rate of blood flow in vessels of the peripheral and neurovasculature. They are intended for use in the interventional radiologic management of arteriovenous malformations, arteriovenous fistulas, and other vascular lesions of the brain, spinal cord, and spine.

    Device Description

    The TRUPUSH® Coil Pusher is used in coil embolization procedures in both the neuro and peripheral vascular systems. An embolic coil is loaded into the proximal end of a compatible microcatheter and the Coil Pusher is used to advance the device through the catheter lumen until it has exited the distal tip of the catheter.

    AI/ML Overview

    This document describes the 510(k) premarket notification for the TRUPUSH® Coil Pusher, a component of the TRUFILL® Vascular Occlusion System. The submission aims to demonstrate substantial equivalence to a predicate device, focusing on process changes, packaging changes, and manufacturing site transfer.

    Here's an analysis of the provided information regarding acceptance criteria and the supporting study:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are not explicitly detailed with quantitative targets in the provided document. Instead, the "Design Verification Testing" and "Design Validation Testing" sections list the types of tests performed. The implication is that the device met the inherent acceptance criteria for each test to support substantial equivalence. Without specific numerical thresholds, we can only infer that the performance was deemed acceptable for regulatory clearance.

    Test CategorySpecific Test (Acceptance Criteria Implicitly Met)Reported Device Performance/Outcome
    Design VerificationTotal Product LengthImplied to meet specified dimensional requirements.
    Taper LengthImplied to meet specified dimensional requirements.
    OD of the Proximal JointImplied to meet specified dimensional requirements.
    OD of the Distal JointImplied to meet specified dimensional requirements.
    OD of the Proximal End of the PTFE SleeveImplied to meet specified dimensional requirements.
    Proximal Marker PositionImplied to meet specified positional requirements.
    Distal Placement of the PTFE SleeveImplied to meet specified positional requirements.
    PTFE Sleeve Visual InspectionImplied to pass visual inspection for defects.
    Distal End of PTFE Sleeve Visual InspectionImplied to pass visual inspection for defects.
    Overall Visual InspectionImplied to pass overall visual inspection for defects.
    Distance from the Proximal End of the PTFE Sleeve to the Corewire TaperImplied to meet specified dimensional requirements.
    Distal Solder Joint LengthImplied to meet specified dimensional requirements.
    Distal Solder Joint VisualsImplied to pass visual inspection for defects and proper formation.
    Turns to FailureImplied to demonstrate sufficient torsional strength/durability for intended use.
    Distal Joint StrengthImplied to demonstrate sufficient strength at the distal joint for intended use.
    Package IntegrityImplied to pass tests ensuring package integrity (e.g., preventing microbial ingress).
    Package ChallengeImplied to pass tests challenging package robustness or performance.
    Seal Integrity Test (Dye Penetration)Implied to pass, indicating no dye penetration and thus a sterile barrier.
    Packaging-Seal Strength (Pull Test)Implied to meet specified pull strength requirements for package seals.
    Product MigrationImplied to demonstrate that the product does not migrate within the package unexpectedly or detrimentally.
    Design Validation3-cavity torque device clipImplied to perform as intended with a 3-cavity torque device clip, likely related to securement or deployment.
    PushabilityImplied to demonstrate acceptable ease of advancement through a microcatheter.
    RetractabilityImplied to demonstrate acceptable ease of withdrawal from a microcatheter.

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

    The document does not explicitly state the sample sizes used for each of the "Design Verification Testing" or "Design Validation Testing" items. It also does not specify the provenance of the data (e.g., country of origin).

    The document mentions "in-vitro and in-vivo testing." In-vitro testing typically refers to tests conducted in a controlled environment, such as a lab bench, using bench models or simulators. In-vivo testing often involves animal models or human subjects. Given the context of a 510(k) for a device like a coil pusher, in-vivo testing likely refers to animal studies to simulate real-world use conditions, as human clinical trials are typically not required for 510(k) unless there are significant performance or safety questions not addressed by bench testing or animal studies. The text does not specify sample sizes or details of these studies.

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

    This information is not applicable and not provided in the document. The studies conducted are engineering and performance tests (e.g., dimensional measurements, mechanical strength, pushability, retractability, package integrity), not diagnostic or interpretative tasks requiring human expert ground truth.

    4. Adjudication Method for the Test Set

    This information is not applicable. The tests described are objective engineering and performance measurements, not subjective evaluations requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is typically performed for diagnostic imaging devices or algorithms where human readers interpret medical images, and the AI's impact on their performance is assessed. The TRUPUSH® Coil Pusher is a physical medical device, not an AI or diagnostic tool.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    No, a standalone study (in the context of an algorithm's performance) was not done. The device is a physical medical instrument, not an algorithm. The "standalone" performance here refers to the physical device's function as designed, which is what the design verification and validation tests aim to assess.

    7. Type of Ground Truth Used

    The "ground truth" for the tests described are engineering specifications, measurement standards, and functional performance requirements for mechanical and material properties, as well as operational characteristics like pushability and retractability. For example, the ground truth for "Total Product Length" would be the engineering drawing's specified length with its permissible tolerance range. The ground truth for "Seal Integrity Test (Dye Penetration)" would be the absence of dye penetration under specified conditions.

    8. Sample Size for the Training Set

    This information is not applicable. The TRUPUSH® Coil Pusher is a physical medical device, not a machine learning model, so there is no "training set."

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

    This information is not applicable, as there is no training set for a machine learning model.

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    K Number
    K983483
    Date Cleared
    1999-03-24

    (170 days)

    Product Code
    Regulation Number
    882.5950
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Cordis Endovascular Systems, Inc. Vascular Occlusion System may be used to reduce or block the rate of blood flow in vessels of the peripheral and neurovasculature. They are intended for the interventional radiologic management of arteriovenous malformations, arteriovenous fistulas, and other vascular lesions of the brain, spinal cord, and spine.

    Device Description

    The Vascular Occlusion System consists of straight and shaped TRUFILL Pushable Coils (made from platinum allow and synthetic fibers) and the TRUPUSH Coil Pusher (with 1 or 2 radiopaque markers). The pushable coils are designed for use under fluoroscopy with microcatheters having a minimum 0.21" inner diameter.

    AI/ML Overview

    This document, K983483, is a 510(k) premarket notification for the Cordis Endovascular Systems, Inc. Vascular Occlusion System. It focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific acceptance criteria through a dedicated study.

    Therefore, many of the requested details about acceptance criteria, specific study design, sample sizes, expert involvement, and ground truth establishment are not applicable or not provided in this type of regulatory document. 510(k) submissions primarily rely on comparison to previously cleared devices.

    Here's a breakdown of what is and is not present based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    BiocompatibilityAll applicable biocompatibility testing was successfully performed for the Vascular Occlusion System. (Implied acceptance criterion is successful performance)
    Substantial EquivalenceThe Vascular Occlusion System is substantially equivalent in design, materials, sterilization, and indications for use as other commercially available occlusion devices, specifically: - Hilal Embolization Microcoil (Cook, Inc., K901337) - Helix Shaped Coils with Dacron Fibers (Target Therapeutics, K901721) - Vascular Occlusion System (Cordis Endovascular Systems, Inc., K964367, K972881) (The core acceptance criterion for a 510(k) is demonstrating substantial equivalence.)
    Performance StandardsThe FDA has not established performance standards under Section 514 of the Food, Drug and Cosmetic Act for this device type. (No specific performance acceptance criteria are mentioned beyond biocompatibility and equivalence).

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

    • Not applicable / Not provided. This document does not describe a clinical or performance study with a "test set" in the context of an algorithm or device performance study. The "testing" referred to is biocompatibility, which typically involves laboratory assays, not human subject data sets in the way implied by the question. The substantial equivalence argument relies on comparison to existing devices, not a new performance study.

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

    • Not applicable / Not provided. As no "test set" for performance evaluation is described, there's no mention of experts establishing ground truth for such a set.
      • The "experts" involved are the FDA reviewers and the manufacturer's regulatory affairs personnel.

    4. Adjudication Method for the Test Set:

    • Not applicable / Not provided. No test set requiring adjudication in the context of performance metrics is described.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    • No. An MRMC study was not done or described in this 510(k) premarket notification. These studies are typically for evaluating the impact of AI on human reader performance, which is not the focus of this device (a physical embolization coil system).

    6. Standalone (Algorithm Only) Performance Study:

    • No. This is a physical medical device (embolization coils), not an algorithm or software device. Therefore, a standalone algorithm performance study is not applicable.

    7. Type of Ground Truth Used:

    • Not applicable / Not provided directly. For biocompatibility, the "ground truth" would be the established safety profiles and recognized standards for biological compatibility. For substantial equivalence, the "ground truth" is the established regulatory clearance and safety/effectiveness of the predicate devices. There's no clinical "ground truth" (e.g., pathology, outcomes data) presented from a de novo study.

    8. Sample Size for the Training Set:

    • Not applicable / Not provided. This is not an AI/ML device where a "training set" would be used.

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

    • Not applicable / Not provided. As this is not an AI/ML device, there's no training set or ground truth establishment for such a set.

    In summary: This 510(k) submission primarily focuses on demonstrating that the "Vascular Occlusion System" is "substantially equivalent" to predicate devices already on the market, as opposed to presenting novel clinical study data against defined acceptance criteria. The only performance detail provided is the successful completion of biocompatibility testing.

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