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510(k) Data Aggregation

    K Number
    K143328
    Date Cleared
    2014-12-19

    (29 days)

    Product Code
    Regulation Number
    870.4875
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Phoenix® Atherectomy System is in atherectomy of the peripheral vasculature. It is not intended for use in coronary, carotid, iliac or renal vasculature.

    Device Description

    The Phoenix Atherectomy System is a sterile, single-use device designed for atherectomy of the peripheral vasculature. The Phoenix Atherectomy System has two main components: the Phoenix Catheter and the Phoenix Handle.

    The Phoenix Catheter is a flexible, over-the-wire (OTW), front-cutting Catheter that continuously captures and clears debulked plaque proximally through the Catheter and Handle into a collection reservoir that resides outside the patient. For use, the Phoenix Catheter is inserted into the Phoenix Handle incorporates a self-contained battery-powered motor designed to drive and rotate the cutter of the Phoenix Atherectomy Catheter at its specified rotational speed. The device is activated by an ON/OFF slider switch on the top of the Handle. An optional Wire Support Clip can also be used to clip a guidewire torque device in a fixed position relative to the Handle. The Catheter, Handle, and Wire Support Clip are each packaged separately as sterile, single-use components of the Phoenix Atherectomy System.

    There are multiple models of the Phoenix Catheter. The smaller Phoenix Catheter models track directly over the guidewire with no tip deflection capability. These models are available in 1.8 mm and 2.2 mm tip diameter sizes. The controls for rotation are housed in the Phoenix Handle when the Catheter is inserted into the Handle. All Phoenix Catheter models are compatible with commercially available 0.014" exchange length (260 cm or greater) guidewires, and all use the same Phoenix Handle.

    This 510(k) includes modifications to the 1.8 mm and 2.2 mm tip diameter Phoenix Catheter models to increase the overall working length from 130 cm to 149 cm and thereby create two new longer-length models within the Phoenix Catheter product family.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device (Phoenix® Atherectomy System). These notifications primarily aim to demonstrate substantial equivalence to a predicate device, rather than providing extensive details on novel acceptance criteria and study designs typically found in regulatory submissions for new devices or software.

    Based on the provided text, the device is an updated version of an existing device (the only change being an increased working length of the catheter). Therefore, the "acceptance criteria" discussed relate to demonstrating that the modified device performs equivalently to the predicate device, not to establishing new performance benchmarks for a novel device or AI algorithm. The study described is a series of engineering and performance tests rather than a clinical trial or a study assessing human reader performance.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of "acceptance criteria" in the traditional sense, nor does it provide quantitative performance metrics for each. Instead, it states that the testing "demonstrate[s] that the performance and technological characteristics of the modified Phoenix Atherectomy System meet defined design requirements and that the modified Phoenix Atherectomy System performs in a manner equivalent to the predicate Phoenix Atherectomy System."

    The technological characteristics of the modified device are compared to the predicate device in Table 9-1. The "acceptance" is implied by the "Identical" assessment for most characteristics, and the successful completion of the listed tests.

    Technological CharacteristicPredicate Phoenix Atherectomy System (K140944) - 130 cm lengthModified Phoenix Atherectomy System (Subject Device) - 149 cm lengthImplied Acceptance Criteria (Demonstrate Equivalence to Predicate)Reported Device Performance (Result of Testing)
    Rotational Speed10,000-12,000 RPMIdenticalAchieve 10,000-12,000 RPMIdentical
    Guidewire ExchangeOver-the-wireIdenticalMaintain over-the-wire exchange capabilityIdentical
    Guidewire Compatibility0.014"IdenticalCompatible with 0.014" guidewireIdentical
    Sheath Compatibility5F - 6FIdenticalCompatible with 5F - 6F sheathIdentical
    Catheter Working Length130 cm149 cmAchieve 149 cm working length149 cm
    Catheter Torque ShaftMulti-Strand Stainless Steel (SS)IdenticalMaintain Multi-Strand SS torque shaftIdentical
    Catheter Outer ShaftStainless Steel Outer Shaft and Teflon sheathIdenticalMaintain SS Outer Shaft and Teflon sheathIdentical
    Catheter Shaft Diameter1.7mmIdenticalMaintain 1.7mm shaft diameterIdentical
    Distal Cutter Flute Maximum Diameter1.8mm (FG1847) / 2.2mm (FG1984)Identical (FG2160) / Identical (FG2162)Maintain 1.8mm/2.2mm distal cutter flute max diameterIdentical
    Tip Diameter and Crossing Profile1.8mm (FG1847) / 2.2mm (FG1984)Identical (FG2160) / Identical (FG2162)Maintain 1.8mm/2.2mm tip diameter and crossing profileIdentical
    Cutting Tip PortSingle exit port conveys excised debris from inner guidewire lumen into Distal Cutting Flute channelIdenticalMaintain single exit port design and debris conveyanceIdentical
    Second Stage Maceration within HousingYesIdenticalMaintain second stage macerationIdentical
    Cutter Housing CoatingNo CoatingIdenticalMaintain no coating on cutter housingIdentical
    Distal Tip Assembly CoatingCoatedIdenticalMaintain coating on distal tip assemblyIdentical
    Minimum Vessel Size for Device Use2.5mm (FG1847) / 3.0mm (FG1984)Identical (FG2160) / Identical (FG2162)Maintain minimum vessel size for useIdentical
    Debris Collection & RemovalContinuous collection and removal of excised debris by mechanical conveyanceIdenticalMaintain continuous debris collection and removalIdentical
    Steering (Directional) mechanismRotation of knob on handle steers distal tip and cutter by torqueing catheter shaftIdenticalMaintain existing steering mechanismIdentical
    Catheter CoatingNoIdenticalMaintain no catheter coatingIdentical
    SterilizationEthylene OxideIdenticalMaintain Ethylene Oxide sterilizationIdentical
    Single-use onlyYesIdenticalMaintain single-use only designIdentical

    The "study" that proves the device meets these criteria consists of the following tests:

    • Dimensional and Visual Inspection
    • Simulated Use
    • Cutter Torque Chain Torque-to-Failure Test
    • Functional Outer Shaft Torque Test
    • Knob to Shaft Testing
    • Catheter Drive Train Stress Test
    • Cutter Stall Test
    • Temperature Rise of Catheter During Simulated Use
    • Kink Bend Radius Test
    • Guidewire Compatibility
    • Catheter Trackability in Below-the-Knee Anatomy

    2. Sample size used for the test set and the data provenance

    The document does not specify a "test set" in the context of clinical data or patient outcomes. The testing described is bench testing and simulated use. Therefore, there is no information on a sample size of patients or data provenance (country of origin, retrospective/prospective). The "samples" would be the catheters themselves used in the engineering tests.

    3. 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 is not a study involving expert review of medical images or patient data to establish ground truth. The "ground truth" for these engineering tests would be the established design specifications and performance characteristics of the predicate device.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable, as this is not a study requiring expert adjudication of clinical outcomes or interpretations.

    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 is a premarket notification for a mechanical atherectomy system, not an AI software device.

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

    Not applicable. This is a premarket notification for a mechanical atherectomy system, not an AI software device.

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

    The "ground truth" for the equivalence demonstration is the established performance and specifications of the legally marketed predicate device (K140944 Phoenix Atherectomy System). The objective of the testing was to show that the modified device's performance, despite an increased length, did not deviate in a way that would alter its safety or effectiveness compared to the predicate.

    8. The sample size for the training set

    Not applicable. This is not a machine learning or AI device that would involve a "training set."

    9. How the ground truth for the training set was established

    Not applicable. This is not a machine learning or AI device that would involve a "training set."

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