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510(k) Data Aggregation

    K Number
    K182512
    Date Cleared
    2018-12-10

    (89 days)

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

    The Route 92 Medical Delivery Catheter is indicated for use with compatible catheters in facilitating the insertion and guidance of catheters into a selected blood vessel in the neurovascular system.

    Device Description

    The Delivery Catheter is a single-lumen, variable stiffness catheter with a flexible, tapered tip delineated by two radiopaque markers. The distal shaft of the Delivery Catheter has a hydrophilic coating. On the proximal end is a hypotube attached to a luer hub for guidewire introduction. This proximal hypotube includes a fluoro-saver marker indicating when the tip of the catheter is about to exit a long femoral sheath/guide. The devices are provided sterile and non-pyrogenic and are intended for single use only. During use, a standard neurovascular guidewire may be inserted through the Delivery Catheter. The Delivery Catheter is inserted through a compatible access catheter. The Delivery Catheter and access catheter are advanced to the targeted location under fluoroscopy using standard endovascular techniques.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Route 92 Medical Delivery Catheter. The submission aims to demonstrate substantial equivalence to a predicate device, not to perform a comparative effectiveness study or validate an AI/ML algorithm. Therefore, many of the requested elements for describing AI-related studies are not applicable.

    Here's an analysis of the provided information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for each test are typically "PASS," meaning the samples met pre-determined criteria. The document states "All samples met the pre-determined acceptance criteria" for nearly all non-clinical performance tests. Specific quantitative acceptance criteria are not provided within this summary for most tests, but they would have been defined in the full test protocols.

    TestAcceptance Criteria (Implied)Reported Device Performance
    Biocompatibility Testing
    Cytotoxicity - ISO MEM ElutionGrade 0Grade 0 at 24, 48, 72 ± 4 hrs (Non-cytotoxic)
    Sensitization - ISO Guinea Pig Maximization Sensitization TestNo sensitization responseNo sensitization response
    Irritation - ISO Intracutaneous ReactivityMean Test-Mean Control < 1.0Mean Test-Mean Control (Normal Saline) = 0; Mean Test-Mean Control (Sesame Oil) = 0.1
    Acute Systemic Toxicity – ISO Acute Systemic InjectionNo clinical signs consistent with toxicity, body weight within acceptable parametersNone observed, within acceptable parameters
    Pyrogen - Material Mediated PyrogenTemperature rise < 0.5℃No temperature rise ≥ 0.5℃
    Hemocompatibility - Complement Activation (C3a & SC5b-9)Minimal increase not expected to result in adverse effects in vivoMinimal increase noted, not expected to result in adverse effects in vivo
    Hemocompatibility - Partial Thromboplastin Time (PTT)PTT of test article = 100% of negative controlPTT of test article was 100% of the negative control
    Hemocompatibility - ASTM HemolysisNon-hemolyticDirect Method: 0.0%; Extract Method: 0.3% (non-hemolytic)
    Hemocompatibility - ThromboresistanceSimilar thromboresistance characteristics as control devicesSimilar thromboresistance characteristics as control devices
    Genotoxicity - ISO Bacterial Mutagenicity Test - Ames AssayNo substantial increases in reversion rates or toxicity interfering with mutagen detectionNo substantial increases in reversion rates, no substantial toxicity
    Genotoxicity - ISO In Vitro Mouse LymphomaNo notable changes in typical growth pattern, cloning efficiencies within normal limitsNo notable changes, cloning efficiencies within normal limits
    Performance Testing - Bench
    Dimensional VerificationConformance to specificationsPASS
    Luer IntegrityMet pre-determined acceptance criteriaPASS
    RHV SealingMet pre-determined acceptance criteriaPASS
    Tensile StrengthMet pre-determined acceptance criteriaPASS
    Kink ResistanceMet pre-determined acceptance criteriaPASS
    Torsion ResistanceMet pre-determined acceptance criteriaPASS
    Tip FlexibilityMet pre-determined acceptance criteriaPASS
    Air LeakageMeets ISO 10555-1:2013 Annex D requirementsPASS
    Liquid LeakageMeets ISO 10555-1:2013 Annex C requirementsPASS
    Hydrophilic Coating IntegrityMet pre-determined acceptance criteriaPASS
    Particulate RecoveryMeets USP <788> requirementsPASS
    Corrosion ResistanceMeets ISO 10555-1:2013 Annex A requirementsPASS
    Catheter Burst Pressure (Static & Dynamic)Meets ISO 10555-1:2013 Annex F requirementsPASS
    Catheter Flow RateMeets ISO 10555-1:2013 Annex E requirementsPASS
    Simulated Use TestingDeliverability and compatibility met pre-determined acceptance criteriaPASS
    Packaging IntegrityMeets ISO 11607-1 Part 1 & ISO 11607-2 Part 2 requirementsPASS
    RadiopacityMet pre-determined acceptance criteriaPASS

    2. Sample Size for Test Set and Data Provenance

    This submission is for a medical device (catheter) and relies on non-clinical (bench and biocompatibility) testing, not a clinical study involving human patient data or a "test set" in the context of an AI/ML algorithm.

    • Sample Size (Test Set): The specific number of samples for each bench test is not provided in this summary. For biocompatibility, animal testing (Guinea Pig Maximization, Acute Systemic Injection, Pyrogen, Thromboresistance in animal model) was performed, but the exact number of animals per test is not detailed.
    • Data Provenance (e.g., country of origin, retrospective/prospective): Not applicable for bench and biocompatibility testing of a physical device. Biocompatibility data was leveraged from the predicate device (K180201), indicating it was previously generated.

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

    Not applicable. Ground truth, in the context of expert consensus, is typically used for AI/ML image analysis or diagnostic devices. This submission involves physical device performance and safety testing.

    4. Adjudication Method for the Test Set

    Not applicable, as there is no "test set" requiring adjudication by experts.

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

    Not applicable. This is not a diagnostic device or an AI/ML algorithm being compared to human readers. It is a delivery catheter.

    6. Standalone (Algorithm Only) Performance Study

    Not applicable. This is not an AI/ML algorithm.

    7. Type of Ground Truth Used

    The "ground truth" for this device's performance is established by:

    • Pre-defined technical specifications and engineering requirements.
    • International standards (e.g., ISO 10993-1, ISO 80369-7, ISO 10555-1, ISO 11607-1/2, USP <788>).
    • Laboratory measurements and observations during bench testing.
    • Biological responses observed in animal models (for biocompatibility).

    8. Sample Size for the Training Set

    Not applicable. This is a physical medical device, not an AI/ML algorithm requiring a training set.

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

    Not applicable. There is no training set for this device.

    Study Proving Device Meets Acceptance Criteria:

    The study that proves the device meets the acceptance criteria is a combination of Biocompatibility Testing and Performance Testing - Bench.

    • Biocompatibility Testing: Evaluated the biological safety of the device materials. These tests were leveraged from the predicate device (Route 92 Medical Access System, K180201) because the subject device is identical in materials, design, and manufacturing processes. The tests included Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Pyrogen, Hemocompatibility (Complement Activation, PTT, Hemolysis, Thromboresistance), and Genotoxicity (Bacterial Mutagenicity, In Vitro Mouse Lymphoma). All tests reported "PASS" or conclusions indicating the device is safe and biocompatible within accepted medical device standards.
    • Performance Testing - Bench: Evaluated the physical and mechanical performance characteristics of the catheter. Most of these tests were also leveraged from the predicate device (K180201) due to identical design. Tests included Dimensional Verification, Luer Integrity, RHV Sealing, Tensile Strength, Kink Resistance, Torsion Resistance, Tip Flexibility, Air Leakage, Liquid Leakage, Hydrophilic Coating Integrity, Particulate Recovery, Corrosion Resistance, Catheter Burst Pressure, Catheter Flow Rate, Simulated Use Testing, Packaging Integrity, and Radiopacity. All tests reported "PASS," indicating that the samples met their pre-determined acceptance criteria.

    The summary concludes that: "The successful completion of the performance testing listed in the following table demonstrates that the Route 92 Medical Delivery Catheter is suitable for its intended use." And "based on the identical design and materials of construction between the subject and predicate devices and the completed non-clinical testing, the subject Route 92 Medical Delivery Catheter is substantially equivalent to the predicate Route 92 Medical Access System (K180201)."

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