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510(k) Data Aggregation

    K Number
    K232524
    Manufacturer
    Date Cleared
    2023-10-18

    (61 days)

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

    The Millipede 070 Aspiration Catheter, with the Perfuze Aspiration Tube Set and a compatible aspiration pump, is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

    The Perfuze Aspiration Tube Set is indicated to connect the Millipede 070 Aspiration Catheter to a compatible aspiration pump.

    Device Description

    The Millipede 070 Aspiration Catheter is a sterile single-use device. It consists of the catheter and a rotating hemostasis valve (RHV). The catheter is a single lumen, reinforced, variable stiffness catheter. The distal segment has a hydrophilic coating for navigation through the vasculature. The catheter has a radiopaque marker located at its distal end for visualization under fluoroscopy. The RHV is assembled onto the hub of the catheter and is used to maintain hemostasis during infusion of saline and contrast agent and insertion of devices into the Millipede 070 Aspiration Catheter.

    The Perfuze Aspiration Tube Set is a sterile, single-use device consisting of a single flexible braided tube. The tube has a rotating male luer-lock connector on the distal end and a suction connector on the proximal end. The rotating male luer-lock connects to the hub of a Millipede 070 Aspiration Catheter. The suction connects to the canister of an aspiration pump. A pinch clamp provides the user with the ability to apply vacuum to the catheter.

    For the aspiration source, the Millipede 070 Aspiration Catheter is used in conjunction with a compatible aspiration pump with prespecified performance parameters that is connected using the Perfuze Aspiration Tube Set along with a legally marketed canister and accessories kit.

    AI/ML Overview

    The document you provided is a 510(k) premarket notification for a medical device (Millipede 070 Aspiration Catheter and Perfuze Aspiration Tube Set). This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than providing the detailed clinical study data often seen for novel devices that might require a PMA (Premarket Approval) or de novo classification.

    Therefore, the information typically requested in your prompt (e.g., number of experts for ground truth, adjudication methods, MRMC studies, effect sizes, training set size for AI, etc.) is not present in this document because it is not a study assessing the performance of an AI/ML-driven device or an imaging diagnostic tool. Instead, this is a clearance for a physical medical catheter and tubing set.

    The "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to engineering and biological performance testing, not AI/ML model validation.

    Here's a breakdown based on the document, addressing what is present and explaining why other points are absent:


    Device: Millipede 070 Aspiration Catheter; Perfuze Aspiration Tube Set

    Regulatory Classification: Class II Percutaneous Catheter (Product Code: NRY)

    Purpose of Submission: Demonstrate substantial equivalence to the SOFIA Plus Aspiration Catheter (K173200).


    1. Table of Acceptance Criteria and Reported Device Performance

    The document describes various performance tests and their conclusions, acting as the "acceptance criteria" and "reported device performance." Since this is not an AI/ML device, the criteria are physical and functional, rather than diagnostic accuracy metrics.

    Test CategorySpecific TestAcceptance Criteria (Implicit)Reported Device Performance (Conclusion)
    BiocompatibilityCytotoxicityNon-cytotoxicThe test article is non-cytotoxic.
    SensitizationNo sensitization responseThe test article did not elicit a sensitization response.
    Irritation (Intracutaneous Reactivity)Requirements metRequirements of the ISO intracutaneous reactivity test were met for the test article.
    Acute Systemic ToxicityRequirements metRequirements of the ISO acute systemic injection test were met for the test article.
    Material-Mediated PyrogenicityNon-pyrogenicThe test article is non-pyrogenic.
    Hemocompatibility (Complement Act.)Not a potential activator of complement systemThe test article is not considered to be a potential activator of the complement system.
    Hemocompatibility (Partial Thrombo.)Not an activator of intrinsic coagulation pathwayThe test article is not considered to be an activator of the intrinsic coagulation pathway.
    Hemocompatibility (Hemolysis)Non-hemolyticThe test article is considered non-hemolytic.
    Hemocompatibility (Thromboresistance)Similar to control devicesThe test articles have similar thromboresistance characteristics as the control devices.
    Millipede Catheter PerformanceDimensional InspectionConformance to specificationsThe device met established specifications.
    Tip StiffnessConformance to specificationsThe device met established specifications.
    Visual InspectionFreedom from defects, suitable surface characteristicsThe device surface characteristics are suitable for its intended use.
    Simulated Use TestingPerforms as intended under simulated use conditionsThe device performs as intended under simulated use conditions.
    Stent-retriever CompatibilityDurability maintained after deployment/retrievalThe device met established specifications.
    Hydrophilic Coating IntegrityIntegrity maintained after multiple cycles, suitable for useThe hydrophilic coating integrity is suitable for its intended use.
    Particulate RecoverySimilar particulate generation to control devicesThe particulate generation was similar to control devices.
    Tensile Strength (bonds)Conformance to specificationsThe device met established specifications.
    Air LeakageIntegrity suitable for intended useThe device integrity is suitable for its intended use.
    Liquid LeakageIntegrity suitable for intended useThe device integrity is suitable for its intended use.
    Static BurstIntegrity suitable for intended useThe device integrity is suitable for its intended use.
    Luer IntegrityCompliance to relevant standards, suitable for intended useThe luers on the device are suitable for their intended use.
    Kink ResistanceConformance to specificationsThe device met established specifications.
    Torque StrengthConformance to specificationsThe device met established specifications.
    Flow Rate CharacterizationCharacterized flow rate data available (implied acceptable)The flow rate was characterized.
    RadiopacitySimilar to control deviceThe radiopacity was similar to a control device.
    Clot Retrieval TestingConformance to specificationsThe device met established specifications.
    Perfuze Tube Set PerformanceVisual InspectionFreedom from defects, suitable surface characteristicsThe device surface characteristics are suitable for its intended use.
    Dimensional InspectionConformance to specificationsThe device met established specifications.
    Luer & Suction Connectors Comp.Conformance to specificationsThe device met established specifications.
    Luer IntegrityCompliance to relevant standards, suitable for intended useThe luer on the device is suitable for its intended use.
    Kink Resistance & CollapseNo kinks/visible collapse under vacuum pressure, Conformance to specsThe device met established specifications.
    Vacuum DecayConformance to specificationsThe device met established specifications.
    Pinch Clamp FunctionalityAbility to enable/disable suction, Conformance to specsThe device met established specifications.
    Tensile Testing (bonds)Conformance to specificationsThe device met established specifications.
    Animal StudyPerformance vs. ControlsComparable results to controls (Penumbra, AXS Vecta)Wedge assessment and clot aspiration assessment results were comparable between the test and control systems. Angiographic and histological evaluations concluded the devices were comparable at all time points.

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

    • Test Set Sample Size: The document does not specify exact sample sizes for each bench test (e.g., number of catheters tested for kink resistance). However, for the animal study, it mentions "two comparative animal studies conducted under Good Laboratory Practices in a porcine model." The exact number of animals is not provided.
    • Data Provenance:
      • Country of Origin: Not explicitly stated for bench testing, but Perfuze Ltd. is based in Galway, Ireland, suggesting testing likely occurred there or at contracted labs.
      • Retrospective/Prospective: All described tests and the animal study are prospective design, as they were specifically conducted to support this premarket notification.

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

    • Not applicable for this type of device. This device is a physical catheter and tube set, not a diagnostic AI/ML system. There is no "ground truth" to be established by human experts in the context of image interpretation or disease diagnosis. The "ground truth" here is the physical measurement, functional performance (e.g., flow rate), or biological response (e.g., non-cytotoxic).

    4. Adjudication Method for the Test Set

    • Not applicable. As there are no human expert readers establishing a diagnostic "ground truth," there is no need for an adjudication method. The test results are objective measurements or observations during laboratory testing.

    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 not an AI-assisted diagnostic device. Its function is direct mechanical aspiration. No MRMC study was conducted or is relevant.

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

    • Not applicable. This is not an algorithm or software device. Its performance is evaluated through bench testing and animal studies as described.

    7. The Type of Ground Truth Used:

    • For Biocompatibility: Laboratory assays and histological/pathological evaluation (e.g., for pyrogenicity, cytotoxicity, systemic toxicity, sensitization, irritation, hemocompatibility in vitro/in vivo, and animal tissue analysis).
    • For Performance Testing: Objective measurements (e.g., dimensions, flow rates, tensile strength), functional assessments (e.g., kink resistance, leakage), and simulated use observations against pre-defined engineering specifications.
    • For Animal Study: Angiographic and histological evaluations of the porcine model.

    8. The Sample Size for the Training Set

    • Not applicable. This device does not involve an AI/ML model that requires a training set.

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

    • Not applicable. No training set for an AI/ML model is involved.

    Summary regarding AI/ML related questions: The questions about experts, adjudication, MRMC studies, standalone algorithms, and training sets are relevant for submissions of Artificial Intelligence / Machine Learning (AI/ML) enabled diagnostic devices or software as a medical device (SaMD). The provided document is for a traditional, physical interventional device (catheter and tube set), and therefore, the testing described focuses on its physical, mechanical, and biological properties, as well as its functional similarity to predicate devices.

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