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510(k) Data Aggregation

    K Number
    K240746
    Date Cleared
    2024-11-20

    (246 days)

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

    The Neurovascular Access System Family is indicated for the introduction of interventional devices into the peripheral and neuro vasculature. It is not intended for use in coronary arteries.

    Device Description

    The subject Neurovascular Access System Family consists of sterile, single-use catheters and accessories that are used together to facilitate the insertion and guidance of an appropriately sized interventional device into a selected vessel in the peripheral and neurovasculature. The Neurovascular Access System is comprised of the Neurovascular Access Catheter, Access Tool, Peel Away Introducer and Dilator. The Neurovascular Access System Family is offered in various lengths to accommodate physician preferences and anatomical variations. The distal end of the catheter is coated with hydrophilic coating to reduce friction during use and a radiopaque marker on the distal tip that is visible under fluoroscopy.

    AI/ML Overview

    This document is a 510(k) Summary for a medical device called the "Neurovascular Access System Family." It details the device's characteristics, intended use, and compares it to legally marketed predicate devices to demonstrate substantial equivalence.

    Here's a breakdown of the requested information based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    Test NameObjectiveTest Method / Standard or GuidanceAcceptance Criteria (Implied by "Pass")Reported Device Performance
    Visual Surface RequirementsTo demonstrate that the device meets the visual surface requirements.ISO 10555-1 2013, Section 4.4Device meets visual surface requirements.Pass
    Dimensional VerificationTo demonstrate that the device meets the dimensional requirements.ISO 10555-1 2013, Section 4.5Device meets dimensional requirements.Pass
    Liquid Leakage Under PressureTo demonstrate that the device passes the liquid leakage under pressure test.ISO 10555-1 2013, Section 4.7.1, Annex CDevice passes liquid leakage test.Pass
    Hub Aspiration Air LeakageTo demonstrate that the device passes the hub aspiration air leakage test.ISO 10555-1 2013, Section 4.7.2, Annex DDevice passes hub aspiration test.Pass
    Simulated Use and UsabilityTo demonstrate that the device passes testing specified in the simulated use test protocol. Simulated use testing includes usability assessment with multiple physicians.FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions", April 2023Device passes simulated use and usability protocols.Pass
    Flex FatigueTo demonstrate that the device passes the flex fatigue test.FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions", April 2023Device passes flex fatigue test.Pass
    Torque TestTo demonstrate the torque strength of the device.FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023Device demonstrates adequate torque strength.Pass
    Tip DeflectionTo demonstrate that the tip deflection is comparable to the predicate device.FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023Tip deflection is comparable to predicate.Pass
    Device Removal ForcesTo demonstrate that the removal forces are comparable to the predicate device.FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023Removal forces are comparable to predicate.Pass
    Peak Tensile Strength TestingTo demonstrate that the device passes the peak tensile strength testing including all bonds and joints.ISO 10555-1 2013, Section 4.6, Annex BDevice passes peak tensile strength testing.Pass
    Flow RateTo demonstrate that the flow rate is comparable to the predicate device.ISO 10555-1 2013: Section 4.9Flow rate is comparable to predicate.Pass
    Corrosion ResistanceTo demonstrate that the device has no visual evidence of corrosion.ISO 10555-1 2013, Section 4.5, Annex ANo visual evidence of corrosion.Pass
    RadiopacityTo demonstrate that the distal marker band is clearly visible under typical fluoroscopic imaging conditions.ISO 10555-1 2013, Section 4.2; ASTM F640-12Distal marker band is clearly visible.Pass
    Kink ResistanceTo demonstrate that shaft kink resistance is comparable to the predicate device and clinically relevant for the intended anatomical locations for use.FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions"Shaft kink resistance is comparable to predicate and clinically relevant.Pass
    Particulates and Coating IntegrityTo demonstrate the quantity and size of particles generated during simulated use are comparable to the predicates and reference devices.FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions"Particulates and coating integrity are comparable to predicates.Pass
    Dynamic BurstTo demonstrate that the device withstands dynamic burst strength.ISO 10555-1 2103, Annex GDevice withstands dynamic burst strength.Pass
    Static BurstTo demonstrate that the device passes static burst pressure as specified in the test protocol.ISO 10555-1 2013, Section FDevice passes static burst pressure.Pass
    Shelf LifeRepeated bench tests after accelerated aging to demonstrate that the device performance is maintained over the proposed shelf-life (6 months).ASTM D4332-22, ASTM D4169-22, ASTM F1980-21, ASTM F1886 / F1866M-16, ASTM 2096-11 (2019), ASTM F88/F88M:21Device performance maintained over 6-month shelf-life.Pass

    Biocompatibility Tests:

    Test NameObjective (Implied)Test Method / Standard or GuidanceAcceptance Criteria (Implied by "Results")Reported Device Performance
    CytotoxicityAssess cell toxicity.ISO 10993-5No reactivity observed.Non-cytotoxic
    SensitizationAssess potential for allergic reactions.ISO10993-10No evidence of delayed dermal contact sensitization.Non-sensitizing
    Intracutaneous ReactivityAssess localized irritation.ISO 10993-23Scores from test article extracts were acceptable (<1.0 for sesame seed oil).Non-irritant
    Acute Systemic ToxicityAssess systemic toxic effects.ISO 10993-11No mortality or evidence of systemic toxicity.Non-toxic
    Material Mediated PyrogenicityAssess fever-inducing substances.ISO 10993-11No rabbit temperature rise ≥ 0.5 °C.Non-pyrogenic
    Hemolysis - Direct Contact and Extract MethodAssess red blood cell damage.ISO 10993-4Mean blank corrected % hemolysis < 2%.Non-hemolytic
    Complement ActivationAssess immune system activation.ISO 10993-4Results within acceptable range compared to controls.Not a Sc5b-9 complement activator
    ThrombogenicityAssess potential for blood clot formation.ISO 10993-4No adverse effects/clinical signs, no thrombus score ≥ 2, similar to comparator/negative controls in PTT and platelet/leukocyte counts.Non-thrombogenic

    Sterility Testing:

    Test NameObjective (Implied)Test Method / Standard or GuidanceAcceptance CriteriaReported Device Performance
    Sterilization ValidationEnsure device is sterile.ISO 11135:2014Sterility Assurance Level (SAL) of 1x10⁻⁶ achieved.Pass
    EO and ECH ResidualsEnsure residuals are below toxic levels.ISO 10993-7:2008Residuals below specified limits.Pass
    Bacterial Endotoxin LevelsEnsure endotoxin levels are safe.FDA's sterility guidanceLevels below 2.15 EU/device.Pass
    Shelf-Life (Sterility)Maintain sterility over proposed shelf-life.(Implicitly part of validation)Sterility maintained over 6 months.Pass

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document lists "Performance Data" in Section VII and "Biocompatibility" in Section VIII.

    • Performance Data: The specific sample sizes for each performance test (e.g., visual, dimensional, burst, fatigue) are not explicitly stated in this summary table. The document only indicates "Pass" for each test. The methods refer to ISO standards and FDA guidance documents, which typically define appropriate sample sizes for such tests.
    • Biocompatibility Data: Similarly, the sample sizes for the various biocompatibility tests (e.g., number of cells, animals for in vivo tests) are not explicitly stated.
    • Data Provenance: The document does not provide information on the country of origin of the data or whether the studies were retrospective or prospective. These are typically bench and laboratory tests performed by the manufacturer or contract labs.

    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)

    • For the "Simulated Use and Usability" test, the objective states an "usability assessment with multiple physicians." The exact number of physicians and their specific qualifications are not provided in this summary.
    • For all other tests, ground truth is established by objective measurements against specified standards (ISO, ASTM, FDA guidance), rather than expert consensus on images or outcomes. Therefore, "experts" in the sense of clinical reviewers establishing ground truth for diagnostic accuracy are not applicable here.

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

    Not applicable. This device is an access catheter, and the performance criteria are based on engineering, mechanical, and biological testing, not on interpretation of clinical data requiring adjudication by experts.

    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 medical device (catheter), not an AI diagnostic algorithm. Therefore, MRMC studies and the concept of human readers improving with AI assistance are not relevant to this submission.

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

    Not applicable. This is a medical device (catheter), not an algorithm or AI system.

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

    The ground truth for this device's performance testing is based on:

    • Established Industry Standards: ISO 10555-1, ISO 10993 series, ASTM standards.
    • FDA Guidance Documents: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions."
    • Objective Measurements: Such as dimensional measurements, pressure thresholds, tensile strength, flow rates, visual inspection for corrosion or particulates, and biological responses in biocompatibility tests.
    • Simulated Use: Involving usability assessment (implied to be clinical feedback from physicians during simulated use).

    Essentially, the ground truth is adherence to predefined physical, chemical, mechanical, and biological specifications and performance metrics.

    8. The sample size for the training set

    Not applicable. This is a medical device, not a machine learning model that requires training data.

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

    Not applicable. There is no training set for this type of medical device submission.

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