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510(k) Data Aggregation

    K Number
    K192439
    Manufacturer
    Date Cleared
    2019-12-09

    (94 days)

    Product Code
    Regulation Number
    870.5150
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The JETi Peripheral Thrombectomy System is intended to:

    • remove/aspirate fluid and break-up soft emboli and thrombus from the peripheral vasculature, and
    • subselectively infuse/deliver diagnostics or therapeutics with or without vessel occlusion.
    Device Description

    The JETi Peripheral Thrombectomy System consists of one aspiration catheter, which is connected to the JETi Pump Set, one JETi Peripheral Saline Drive Unit (SDU), one Peristaltic Pump, and an Accessory Stand. A Sterile Accessory Kit and Non-Sterile Accessory Device are supplied. In use, thrombus enters the distal catheter tip via the suction force provided by the peristaltic pump. The peripheral SDU and pump set deliver a stream of sterile saline through the secondary lumen to break up and dilute the thrombus within the catheter. The diluted thrombus and saline are drawn back through the primary lumen and deposited into the peristaltic pump receptacle. No saline is injected into the patient during normal operation. The peripheral SDU, peristaltic pump, an adjustable mounting arm, an accessory basket, and an IV pole are contained on an accessory stand.

    The peripheral catheter is a multi-lumen device that allows for simultaneous hydro-mechanical thrombus disruption and thrombus aspiration. It is designed to simultaneously deliver a stream of saline via a displacement pump within the distal tip of the catheter, while aspirating thrombotic material macerated by the saline stream.

    The peripheral catheter has the ability to infuse fluid through the aspiration lumen and saline lumen.

    For infusion through the aspiration lumen, an appropriate sized syringe filled with fluid is infused to the treatment area by passing through the side arm of the rotating hemostasis valve (RHV) that is attached to the catheter.

    For infusion through the saline lumen, a clamp is used on the suction tubing to cut off aspirate flow.

    The proximal end of the pump set consists of a spike and an in-line drip chamber that is used to pierce the saline bag and connect the pump set to the saline source. The cassette contains a piston pump and is mounted onto the peripheral SDU. The cassette is powered by the motor contained in the peripheral SDU. The distal end of the pump set has a connector, which mounts to the proximal end of the multi-port Luer adapter of the peripheral catheter and delivers the saline to the peripheral catheter.

    The peripheral SDU is a reusable device. The fork drive of the peripheral SDU is designed to run the piston pump contained in the pump set to deliver the stream of saline to the peripheral catheter, when activated by the foot pedal. Aspiration is achieved with a peristaltic pump that is connected to the SDU and is also turned on/off with the foot pedal. The pressure sensor is connected to the suction tubing, which is connected to the multi-port connector of the peripheral catheter. The peripheral SDU contains a microprocessor controlled circuit and firmware that monitors various functions of the motor and pressure to assure that the device is functioning as expected. Various colored LED lights on the front panel indicate to the user what the current status is of the SDU. Energy is provided by a 24 volt external power supply, which is connected to mains power.

    AI/ML Overview

    The provided text describes the JETi Peripheral Thrombectomy System and its 510(k) premarket notification (K192439) to the FDA. The document primarily focuses on demonstrating substantial equivalence to a predicate device (JETi 88 Peripheral Thrombectomy System, K183403) through non-clinical performance data.

    Here's an analysis based on your requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that "All data met the acceptance criteria and fell within pre-determined product specifications and external standard requirements." However, it does not explicitly list the quantitative acceptance criteria for each test. It only lists the tests performed and mentions that the results were compliant.

    The table below presents the functional specifications of the device that can be inferred from the comparison table between the predicate and subject device, along with the implied "acceptance criteria" (i.e., that the new device met these specifications, often matching the predicate or a new measured value).

    Design Feature (Performance Aspect)Predicate JETi 88 Peripheral Thrombectomy System (Implied Acceptance Criteria)Subject JETi Peripheral Thrombectomy System (Reported Performance)
    Aspiration Flow Rate650 mL/min (Predicate Value)450 mL/min
    Pressure – Free Flow-23.6 inHg (Predicate Value)-12.9 inHg
    Pressure - Engaged in Clot< -27 inHg (Predicate Value)< -27 inHg (Same as predicate)
    Catheter Working Length100 cm (Predicate Value)100 cm (Same as predicate)
    Saline Input Tube Length6 feet (Predicate Value)6 feet (Same as predicate)
    IEC 60601-1-2 Edition4th (Predicate Value)4th (Same as predicate)
    On/off ControlFoot pedal (Predicate Value)Foot pedal (Same as predicate)
    Method to Stop FlowPinch valve (Predicate Value)Peristaltic pump (Change from predicate)
    Pinch Valve ControlMode button (Predicate Value)N/A (Change from predicate due to different method)
    Location (SDU)Mounted on cart outside sterile field (Predicate Value)Mounted on cart outside sterile field (Same as predicate)
    Vacuum Sensor ConnectorStandard RJ45 (Predicate Value)Standard RJ45 (Same as predicate)

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

    • Sample Size: The document does not specify the sample sizes for any of the in vitro tests (e.g., clot removal, aspiration source comparison). It simply states that "in vitro testing" was performed.
    • Data Provenance: The data is non-clinical/in vitro testing, meaning it was generated in a lab setting, likely by the manufacturer (Walk Vascular, LLC). The country of origin is not explicitly stated, but the company is based in Irvine, CA, USA. The data is prospective in the sense that it was conducted for the purpose of this 510(k) submission, not collected from prior clinical use.

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

    • This device is a physical medical device (thrombectomy system), not an AI/software device that requires expert-established ground truth from images or other diagnostic data. The "acceptance criteria" here refers to engineering specifications and performance metrics tested in a lab, not diagnostic accuracy against expert consensus. Therefore, this information is not applicable to this submission.

    4. Adjudication Method for the Test Set

    • Not applicable. As this is not a diagnostic AI system, there is no need for expert adjudication of results. Performance was evaluated against predetermined specifications.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done

    • No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No pre-clinical or clinical data were generated to establish substantial equivalence. Bench data are considered adequate to support a determination of substantial equivalence." This type of study would involve human readers (likely clinicians) evaluating cases, which was not performed.

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

    • Not applicable. This device is a physical medical instrument, not a standalone algorithm/AI for diagnosis or treatment planning. Its function involves a human operator.

    7. The Type of Ground Truth Used

    • The "ground truth" for the non-clinical performance studies would be the objective measurement of the device's physical and functional characteristics against defined engineering specifications and, in some cases, comparison to the performance of the predicate device (e.g., flow rates, pressure, software functionality, electrical safety, clot removal in an in vitro model). It is not expert consensus, pathology, or outcomes data in the typical sense of diagnostic devices. For "clot removal," it would likely involve quantified removal of a simulated clot in a controlled in vitro environment.

    8. The Sample Size for the Training Set

    • Not applicable. This is not an AI/machine learning device that requires a "training set."

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

    • Not applicable, as there is no training set for this type of device.
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