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510(k) Data Aggregation

    K Number
    K140307
    Date Cleared
    2014-04-21

    (73 days)

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

    The ENVOY® Guiding Catheter is intended for use in the peripheral, coronary, and neurovasculature for the intravascular introduction of interventional/diagnostic devices.

    Device Description

    The ENVOY® Guiding Catheter is a single lumen, braided catheter with a large non-tapered lumen that facilitates the intravascular passage of interventional/diagnostic devices. The guiding catheter is pre-shaped to facilitate positioning.

    AI/ML Overview

    The provided document, K140307, describes a 510(k) submission for a line extension of the ENVOY® Guiding Catheter to include a new 7 French (Fr) diameter size. The submission asserts substantial equivalence to the predicate ENVOY® 6 French (Fr) Guiding Catheter (K093184).

    Here's an analysis based on the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device is a medical catheter. For such devices, acceptance criteria are typically defined by compliance with recognized performance standards and successful execution of specific bench tests designed to ensure safety and effectiveness. The document lists the tests performed, which inherently serve as the performance criteria. The "reported device performance" in this context is the successful completion of these tests, demonstrating that the 7Fr Guiding Catheter meets the design requirements and is substantially equivalent to the predicate.

    Acceptance Criteria (Test Performed)Reported Device Performance
    Visual InspectionPassed
    Catheter ShapePassed
    Catheter Dimensional VerificationPassed
    Tensile Strength TestingPassed
    System Liquid Leakage TestingPassed
    Lateral Stiffness TestingPassed
    Linear Stiffness TestingPassed
    Back-Up SupportPassed
    Track TestingPassed
    Sheath Introducer CompatibilityPassed
    Multiple In-dwelling devicePassed
    Cytotoxicity (MEM Elution)Passed
    Hemocompatibility (In vitro Hemolysis)Passed
    USP Physicochemical Aqueous Extraction TestPassed
    Compliance with BS EN ISO 11607-1Documented Compliance
    Compliance with BS EN ISO 11135-1Documented Compliance
    Compliance with BS EN ISO 10993-7Documented Compliance
    Compliance with BS EN ISO 10555-1Documented Compliance
    Compliance with ISO 594-1Documented Compliance
    Compliance with ISO 594-2Documented Compliance
    Compliance with AAMI / ANSI HE75Documented Compliance
    Compliance with BS EN ISO 10993-1Documented Compliance
    Compliance with BS EN ISO 10993-5Documented Compliance
    Compliance with BS EN ISO 10993-4Documented Compliance
    Compliance with USP <661>Documented Compliance
    Compliance with ISO 14971Documented Compliance
    Compliance with BS EN ISO 15223-1Documented Compliance

    Study Proving Acceptance Criteria Met:

    The study that proves the device meets the acceptance criteria is a non-clinical bench testing program combined with biocompatibility testing.

    The document states: "Results of verification and validation testing that was conducted on the proposed ENVOY® Guiding Catheter demonstrates that it performs as designed, is suitable for its intended use, is substantially equivalent to the predicate device and therefore, does not raise any new questions of safety and effectiveness."

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

    The document does not specify the sample sizes used for each of the performed bench tests. It only lists the types of tests.

    Regarding data provenance, the testing was conducted by Codman & Shurtleff, Inc., the device submitter. The document does not explicitly state the country of origin for the testing, but the submitter's address is in Raynham, MA, USA, suggesting the testing was likely conducted in the US. The study is retrospective in the sense that the testing was performed on manufactured devices after their design, as part of the verification and validation process for regulatory submission.

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

    This information is not applicable to this type of submission. This 510(k) is for a medical device (catheter) based on substantial equivalence to an existing predicate. The "ground truth" for these types of submissions is established through engineering specifications, recognized standards, and the performance characteristics of the predicate device. Expert human interpretation of data for "ground truth" (like in AI/diagnostic device studies) is not relevant here.

    4. Adjudication Method for the Test Set

    This information is not applicable. Adjudication methods are typically relevant for studies involving human interpretation or subjective assessments, such as clinical trials or studies establishing ground truth from multiple expert opinions. The testing described here is objective bench testing and standard compliance.

    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

    No, an MRMC comparative effectiveness study was not done. This device is a guiding catheter, not an AI-assisted diagnostic tool or an imaging device requiring human reader interpretation with or without AI.

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

    No, a standalone algorithm performance study was not done. This refers to AI algorithm performance without human intervention, which is not relevant for a physical medical catheter.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" for this device is based on engineering specifications, recognized national and international performance standards (e.g., ISO, AAMI, USP), and the established performance and safety profile of the predicate device. The tests conducted (e.g., dimensional verification, tensile strength, leakage, biocompatibility) are designed to verify that the device meets these pre-defined, objectively measurable criteria.

    8. The Sample Size for the Training Set

    This information is not applicable as this is not an AI/machine learning device. There is no "training set."

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

    This information is not applicable as this is not an AI/machine learning device.

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