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510(k) Data Aggregation

    K Number
    K182097
    Date Cleared
    2018-11-14

    (103 days)

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

    The React™ 71 Catheter is indicated for the introduction of interventional devices into the peripheral and neuro vasculature.

    Device Description

    The React™ 71 Catheter is a single lumen, flexible, variable stiffness composite catheter with a nitinol structure that is jacketed with various durable polymer outer layers. A lubricious, polytetrafluoroethylene liner and Engage™ inner layer is used to create a structure that has both proximal stiffness and distal flexibility. The React™ 71 Catheter is also designed with an encapsulated radiopaque distal platinum-iridium marker band which is used for visualization under fluoroscopy. The React™ 71 Catheter is introduced into the vasculature through the Split-Y Introducer Sheath. The proximal end of the React™ 71 Catheter is designed with a green thermoplastic elastomer strain relief and a clear hub. The distal end of the React™ 71 Catheter is coated with a Surmodics Serene™ Coating.

    AI/ML Overview

    The provided document describes the React™ 71 Catheter. Based on the content, here's a breakdown of the acceptance criteria and the study performed:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document lists various tests, their methods, and states that the React™ 71 Catheter "met the acceptance criteria" or similar statements for each. Specific quantitative acceptance criteria are generally not provided in this summary, but the results confirm compliance.

    Test DescriptionTest Method SummaryAcceptance Criteria (Implicit)Reported Device Performance
    Biocompatibility
    Cytotoxicity (Elution Method)The test article extract showed no evidence of causing cell lysis or toxicity and had a Grade 0 (No Reactivity).Grade < 2 (Mild Reactivity)Met (Grade 0: No Reactivity), considered non-cytotoxic.
    Sensitization (Guinea Pig Maximization Test)The test article extracts showed no evidence of causing delayed dermal contact sensitization in the guinea pig.No evidence of sensitizationMet, does not elicit a sensitization response.
    Irritation (Intracutaneous Reactivity)The test article met the requirements of the test since the difference between each test article extract overall mean score and corresponding control extract overall mean score was 0.0 and 0.2 for the Sodium Chloride and Sesame Oil test article extracts, respectively.Difference in mean score ≤ a specified threshold (implied to be low)Met, considered a non-irritant.
    Acute Systemic Toxicity (Systemic Toxicity)There was no mortality or evidence of systemic toxicity from the extracts injected into mice.No mortality or systemic toxicityMet, does not indicate signs of toxicity.
    Hemocompatibility (Hemolysis)The hemolytic index for the test article in direct contact with blood was 0.8%, and the hemolytic index for the test article extract was 0.0%.Hemolytic index below a specified thresholdMet (0.8% and 0.0%), considered non-hemolytic.
    Hemocompatibility (Complement Activation)The concentration of SC5b-9 in the test article was not statistically higher than the activated normal human serum control or the negative control.SC5b-9 concentration not statistically higher than controlsMet, not considered a potential activator of the complement system.
    Hemocompatibility (Thrombogenicity – Canine Model)The control article had a mean score of 2.0. The test article had a mean score of 1.7 after four (4) hours (±30 minutes) without systemic anticoagulation.Lower thrombogenic potential than predicate/controlMet, demonstrates lower thrombogenic potential compared to ACE 68 Reperfusion Catheter.
    Pyrogenicity (Material Mediated)Not a single animal showed a temperature rise of 0.5°C or more above its baseline temperature. The total rise of the rabbits' temperature during the three (3) hours was 0.0°C.Temperature rise < 0.5°C above baselineMet, considered non-pyrogenic.
    Bench Performance (Leveraged Testing)
    Ethylene Oxide ResidualEvaluated per ISO 10993-7.Met acceptance criteria for residualsMet the acceptance criteria.
    Ethylene Chlorohydrin ResidualEvaluated per ISO 10993-7.Met acceptance criteria for residualsMet the acceptance criteria.
    Bioburden RecoveryEvaluated per ISO 11737-1.Met acceptance criteria for recoveryMet the acceptance criteria.
    Bacterial EndotoxinEvaluated per ANSI/AAMI ST72 and USP <161>.Met acceptance criteria for endotoxin levelsMet the acceptance criteria.
    Packaging Visual InspectionEvaluated per ASTM F1886.Met acceptance criteria for visual integrityMet the acceptance criteria.
    Bubble LeakEvaluated per ASTM F2096.Met acceptance criteria for leak integrityMet the acceptance criteria.
    Seal StrengthEvaluated per ASTM F88.Met acceptance criteria for seal strengthMet the acceptance criteria.
    Bench Performance (Conducted Testing)
    BioburdenEvaluated per ISO 11737-1.Met acceptance criteria for bioburdenMet the acceptance criteria.
    Visual InspectionInspected under x2.5 magnification.Met acceptance criteria for visual integrityMet the acceptance criteria.
    Dimensional MeasurementsProximal ID, distal ID, proximal OD, distal OD, usable length, total length, coating length, and distal tip length measured.Met acceptance criteria for specified dimensionsMet the acceptance criteria.
    Tip BucklingEvaluated for maximum compressive force.Met acceptance criteria for tip buckling forceMet the acceptance criteria.
    Kink ResistanceEvaluated for maximum kink diameter.Met acceptance criteria for kink diameterMet the acceptance criteria.
    ParticulateEvaluated per USP <788>.Met acceptance criteria for particulate levelsMet the acceptance criteria.
    Coating LubricityEvaluated for average frictional forces.Met acceptance criteria for frictional forcesMet the acceptance criteria.
    Tensile StrengthEvaluated per ISO 10555-1. Annex B.Met acceptance criteria for tensile strengthMet the acceptance criteria.
    Liquid LeakEvaluated per ISO 10555-1. Annex C.Met acceptance criteria for liquid leakMet the acceptance criteria.
    Corrosion ResistanceEvaluated per ISO 10555-1. Annex A.Met acceptance criteria for corrosionMet the acceptance criteria.
    Hub Aspiration ResistanceEvaluated per ISO 10555-1. Annex D.Met acceptance criteria for hub air aspirationMet the acceptance criteria.
    RadiopacityMarkerband length and wall thickness measured; confirmed via fluoroscopy.Met acceptance criteria for radiopacityMet the acceptance criteria.
    Luer StandardsEvaluated per ISO 594-1 and ISO 80369-7.Met acceptance criteria for luer standardsMet the acceptance criteria.
    CompatibilityInspected for visual damage when delivering and retrieving interventional devices.Met acceptance criteria for no visual damage/functionalityMet the acceptance criteria.
    Torque to FailureEvaluated for transmission of proximal torque to the distal tip.Withstood typical clinical torsional forcesWas able to withstand torsional forces typical of clinical use.
    Dynamic PressureEvaluated for the amount of pressure it can withstand.Withstood typical clinical pressuresWas able to withstand pressures typical of clinical use.
    Coating IntegrityEvaluated for coating coverage and lubricity.Remained coated and lubriciousRemained coated and lubricious.
    UsabilityEvaluated for maneuverability and flexibility against a predicate device.Met acceptance criteria for maneuverability and flexibility.Met the acceptance criteria.

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

    The document does not specify exact sample sizes for each test. For the biocompatibility study on thrombogenicity, it mentions a "Canine Model" with "four (4) hours (±30 minutes) without systemic anticoagulation," and comparing a "control article" to the "test article." This implies a very small comparative animal study, rather than a large test set for AI evaluation.

    The provenance of data (e.g., country of origin, retrospective/prospective) is not provided as the tests are primarily bench and animal studies (biocompatibility) conducted in controlled laboratory settings for device performance and safety.

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

    Not applicable. This is a medical device submission based on product performance and biocompatibility testing, not an AI/software submission requiring expert ground truth for classification or diagnosis.

    4. Adjudication Method for the Test Set

    Not applicable. As this is not an AI/software submission involving human interpretation or adjudication for ground truth, this information is not relevant.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size

    No. This is a medical device submission for a catheter, not an AI system that would typically undergo MRMC studies.

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

    Not applicable. This is a physical medical device, not an algorithm. The "standalone" performance here refers to the device's physical and biological performance in bench and animal tests.

    7. The Type of Ground Truth Used

    The "ground truth" for the tests performed is based on established scientific and engineering standards and methods. For example:

    • Biocompatibility: In vitro and in vivo testing (e.g., cell cultures, guinea pigs, mice, canine model) following ISO 10993 standards.
    • Performance Data – Bench: Standardized laboratory tests (e.g., ISO, ASTM, USP) for physical, mechanical, and material properties.

    8. The Sample Size for the Training Set

    Not applicable. This is a physical medical device. There is no concept of a "training set" as understood in AI/machine learning. The device design and manufacturing processes are refined through engineering development, not machine learning training.

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

    Not applicable, as there is no training set for an AI model. For the device itself, the "ground truth" for its design and performance requirements is established through regulatory standards, predicate device characteristics, and engineering specifications.

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