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510(k) Data Aggregation
(267 days)
The Millipede 088 Access Catheter is indicated for use in facilitating the insertion and guidance of microcatheters into a selected blood vessel in the neurovasculature.
The Millipede 088 Access Catheter consists of the catheter, a rotating hemostasis valve (RHV) and a valve crossing tool. The catheter, RHV and valve crossing tool are provided sterile. They are sterilized by ethylene oxide (EO).
The Millipede 088 Access Catheter is a single lumen, coil-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 valve crossing tool is used to open the valve of the access sheath and to facilitate insertion of the Millipede 088 Access Catheter through the access sheath without damage. The RHV is assembled onto the hub of the Millipede 088 Access Catheter and is used to maintain hemostasis during infusion of saline and contrast agent and insertion of other devices through the Millipede 088 Access Catheter.
The provided document is a 510(k) summary for the Millipede 088 Access Catheter. This type of regulatory submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than providing detailed acceptance criteria and a standalone clinical study to prove the device meets those criteria.
Therefore, the document does not contain the information requested in points 2, 3, 4, 5, 8, and 9, and only partially addresses points 1, 6, and 7.
Here's a breakdown of what can be extracted:
1. Acceptance Criteria and Reported Device Performance
The document lists various performance tests and their conclusions, indicating that the device met "established specifications" or was "suitable for its intended use." However, the specific quantitative acceptance criteria for each test are not provided. The reported device performance is qualitative rather than quantitative in most cases.
Test | Test Method | Reported Device Performance (Conclusions) |
---|---|---|
Dimensional Inspection | Device dimensions were measured to confirm conformance to the specifications. | The device met established specifications. |
Tip Stiffness | Test specimens were tested for tip flexibility and compared to predicate and reference devices. | The device met established specifications. |
Visual Inspection | Device surface characteristics were assessed to confirm freedom from defects. | The device surface characteristics are suitable for its intended use. |
Simulated Use Testing | Deliverability and compatibility with accessory devices were evaluated in a neurovascular model. | The device performs as intended under simulated use conditions. |
Hydrophilic Coating Integrity | The integrity of the hydrophilic coating was evaluated after multiple insertion and withdrawal cycles. | The hydrophilic coating integrity is suitable for its intended use. |
Particulate Recovery | Quantify the particulate size and count generated by simulated use of the test article. | The particulate size and count were similar to control devices. |
Tensile Strength | The tensile strength was evaluated for the bonds between sections of the catheter. | The device met established specifications. |
Air Leakage | Tested per ISO 10555-1:2013 Annex D. | The device integrity is suitable for its intended use. |
Liquid Leakage | Tested per ISO 10555-1:2013 Annex C. | The device integrity is suitable for its intended use. |
Static Burst | Tested per ISO 10555-1:2013 Annex F. | The device integrity is suitable for its intended use. |
Luer Integrity | The luers were evaluated for compliance to relevant standards. | The luers on the device are suitable for their intended use. |
Kink Resistance | Test specimen segments were formed into a defined bend diameter to evaluate kink resistance. | The device met established specifications. |
Torque Strength | The test specimens were rotated in a simulated use model to evaluate integrity after rotation. | The device met established specifications. |
Flow Rate Characterization | The flow rate of saline and a contrast-saline solution was characterized when injected through the catheter. | The flow rate was characterized. |
Radiopacity | Radiopacity of the device was evaluated in an animal model under fluoroscopy. | The radiopacity of the Millipede 088 Access Catheter was similar to a control device. |
Biocompatibility (various tests) | ISO 10993-1, 10993-4 (Hemocompatibility), 10993-5 (Cytotoxicity), 10993-10 (Irritation, Sensitization), 10993-11 (Systemic Toxicity, Pyrogenicity) | Non-cytotoxic, no sensitization response, met intracutaneous reactivity, met acute systemic injection, non-pyrogenic, not a complement activator, not an intrinsic coagulation pathway activator, non-hemolytic, similar thromboresistance to controls. |
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 does not specify the sample sizes for the individual performance tests beyond implicitly suggesting multiple samples were tested (e.g., "test specimens," "test articles"). For the Animal Testing, it states "two studies in a porcine model."
The data provenance for the in vitro and animal studies isn't explicitly stated beyond "Good Laboratory Practices" for the animal studies, which is a standard of conduct rather than a geographic origin. No human data is presented.
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)
This information is not provided as the submission relies on objective performance testing, biocompatibility studies, and animal studies rather than expert-derived ground truth from human data for this type of device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. The evaluation methods described are objective performance tests and animal studies, not human data requiring expert adjudication.
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 device is an access catheter, not an AI-powered diagnostic tool. Therefore, an MRMC study or AI assistance is not relevant to its evaluation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, the performance testing described (mechanical, dimensional, coating integrity, etc.) and the animal studies represent "standalone" evaluations of the device's physical and functional properties without human interpretation of data in a clinical context.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the performance and biocompatibility tests, the "ground truth" is defined by the established specifications, relevant ISO standards, and comparison to control devices or predicate devices. For example:
- "The device met established specifications."
- "The test article is non-cytotoxic."
- "The particulate size and count were similar to control devices."
- "The radiopacity of the Millipede 088 Access Catheter was similar to a control device."
- For animal testing, "Usability, radiopacity, thromboresistance, and vessel injury were assessed," and "The results for the subject device were comparable to a control device."
8. The sample size for the training set
Not applicable. This device is a medical catheter and does not involve a "training set" in the context of machine learning or AI. Its performance is evaluated through engineering and biological testing.
9. How the ground truth for the training set was established
Not applicable (as above).
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(129 days)
The Riptide™ Aspiration System is intended 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 Riptide™ Aspiration System is designed to restore blood flow in patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease. The Riptide™ Aspiration System is designed for use within the internal carotid, middle cerebral – M1 and M2 segments, basilar, and vertebral arteries. The Riptide™ Aspiration System is composed of the following components:
- Arc™ Catheter .
- Riptide™ Aspiration Tubing .
- Riptide™ Aspiration Pump ●
- Riptide™ Collection Canister with Intermediate Tubing .
The Arc™ Catheter is introduced into the vasculature through the Split-Y Introducer Sheath. A lubricous, tapered liner is used to create a structure that has both proximal stiffness and distal flexibility. The Arc™ Catheter has a radiopaque marker band encapsulated at the distal tip for visualization under fluoroscopy. The Arc™ Catheter is navigated to the intended treatment site and positioned proximal to the site of occlusion. The Arc™ Catheter is the only component of the Riptide™ Aspiration System that is used intravascularly.
The Riptide™ Aspiration Tubing serves as a conduit to supply vacuum from the Riptide™ Aspiration Pump to the distal tip of the Arc™ Catheter. The Riptide™ Aspiration Tubing provides a connection between the sterile and non-sterile environments. The proximal end of the Riptide™ Aspiration Tubing is connected to the Riptide™ Collection Canister (outside of the sterile environment) while the distal end of the Riptide™ Aspiration Tubing is connected to the Arc™ Catheter (inside the sterile environment). The Riptide™ Collection Canister is connected to the Riptide™ Aspiration Pump (also outside of the sterile environment) via the Intermediate Tubing.
The Riptide™ Aspiration Pump is designed to generate vacuum for the Riptide™ Aspiration System. The vacuum pressure of the Riptide™ Aspiration Pump is set by turning the vacuum control valve until the vacuum gauge reads a minimum of 20inHg but not exceeding 25inHg. The Riptide™ Aspiration Pump is reusable, non-sterile, and intended to be utilized outside of the sterile environment.
The Riptide™ Collection Canister is provided non-sterile and is pre-assembled with the Intermediate Tubing. The Riptide™ Collection Canister with Intermediate Tubing is single-use and the repository for aspirated material. The Riptide™ Collection Canister is placed into the receptacle of the Riptide™ Aspiration Pump while the Intermediate Tubing is connected to the vacuum inlet port.
The provided text describes the acceptance criteria and the studies conducted to demonstrate the substantial equivalence of the Riptide™ Aspiration System to its predicate device, the Penumbra System® and Penumbra Pump MAX™.
Here's the breakdown of the information requested:
1. Table of Acceptance Criteria and Reported Device Performance
The document lists numerous tests conducted on various components of the Riptide™ Aspiration System, with an explicit statement that the device met the acceptance criteria for each. The specific acceptance criteria values are generally not quantified in the "Results" column, but rather stated qualitatively (e.g., "met the acceptance criteria").
Table 1: Acceptance Criteria and Reported Device Performance (Summary)
Component | Test Category | Individual Test | Acceptance Criteria Statement (from document) |
---|---|---|---|
Arc™ Catheter | Biocompatibility | USP Physicochemical | Meets USP Physicochemical (Pass) |
ISO MEM Elution Using L-929 Mouse Fibroblast Cells | Non-cytotoxic | ||
ISO Guinea Pig Maximization Sensitization Test | Non-sensitizer | ||
ISO Intracutaneous Irritation Test | Non-irritant | ||
ISO Acute Systemic Injection Test | Non-cytotoxic | ||
ISO Materials Mediated Rabbit Pyrogen | Non-pyrogenic | ||
ASTM Hemolysis Assay – Direct Contact and Extract Method | Non-hemolytic | ||
Complement activation C3a and SC5b-9 Assay | The compliment activation of the C3a and SC5b assays were similar for test and comparison articles. | ||
Thromboresistance Evaluation | The test and control articles exhibited similar thromboresistant characteristics. | ||
ISO Bacterial Mutagenicity Test - Ames Assay | Non-mutagenic | ||
ISO in vitro Mouse Lymphoma with Extended Treatment | Non-mutagenic (non-genotoxic and non-clastogenic) | ||
ISO in vivo Mouse Micronucleus Assay | Non-mutagenic | ||
Partial Thromboplastin Time | Non-activator (of intrinsic coagulation pathway) | ||
in vitro Hemocompatibility Assay | No adverse effect on leukocyte or platelet counts. | ||
Arc™ Catheter | Bench - Microbial | Ethylene Oxide (EO) Residual | Met the acceptance criteria for EO Residual. |
Ethylene Chlorohydrin (ECH) | Met the acceptance criteria for ECH. | ||
Bacterial Endotoxin | Met the acceptance criteria for Bacterial Endotoxin. | ||
Bench - Packaging | Visual Inspection | Met the acceptance criteria for Visual Inspection. | |
Bubble Leak | Met the acceptance criteria for Bubble Leak. | ||
Seal Strength | Met the acceptance criteria for Seal Strength. | ||
Bench - Performance | Lumen Patency | Met the acceptance criteria for Lumen Patency. | |
Dimensional Inspection | Met the acceptance criteria for Dimensional Inspection. | ||
Tip Buckling | Met the acceptance criteria for Tip Buckling. | ||
Injection Flow Rate | Met the acceptance criteria for Injection Flow Rate. | ||
Suction Flow Rate | Met the acceptance criteria for Suction Flow Rate. | ||
Vacuum Resistance | Met the acceptance criteria for Vacuum Resistance. | ||
Air Aspiration Leak | Met the acceptance criteria for Air Aspiration Leak. | ||
Hub/Shaft Peak Tensile Force | Met the acceptance criteria for Hub/Shaft Peak Tensile Force. | ||
Coating Integrity | Characterization only. | ||
Coating Lubricity/Durability | Met the acceptance criteria for Coating Lubricity/Durability. | ||
Particulate | Met the acceptance criteria for Particulate. | ||
Kink Resistance | Met the acceptance criteria for Kink Resistance. | ||
Liquid Leak | Met the acceptance criteria for Liquid Leak. | ||
Static/Dynamic Burst | Met the acceptance criteria for Static/Dynamic Burst. | ||
Corrosion Resistance | Met the acceptance criteria for Corrosion Resistance. | ||
Torque to Failure | Characterization only. | ||
Riptide™ Aspiration Tubing | Bench - Microbial | Ethylene Oxide (EO) Residual | Met the acceptance criteria for EO Residual. |
Ethylene Chlorohydrin (ECH) | Met the acceptance criteria for ECH. | ||
Bioburden Recovery | Met the acceptance criteria for Bioburden Recovery. | ||
Bioburden | Met the acceptance criteria for Bioburden. | ||
Bacterial Endotoxin | Met the acceptance criteria for Bacterial Endotoxin. | ||
Bench - Packaging | Aseptic Presentation | Met the acceptance criteria for Aseptic Presentation. | |
Seal Width | Met the acceptance criteria for Seal Width. | ||
Dye Leak | Met the acceptance criteria for Dye Leak. | ||
Visual Inspection | Met the acceptance criteria for Visual Inspection. | ||
Bubble Leak | Met the acceptance criteria for Bubble Leak. | ||
Legibility | Met the acceptance criteria for Legibility. | ||
Foreign Material | Met the acceptance criteria for Foreign Material. | ||
Seal Strength | Met the acceptance criteria for Seal Strength. | ||
Bench - Performance | Dimensional Inspection | Met the acceptance criteria for Dimensional Inspection. | |
Identification of Heat Shrink Bands | Met the acceptance criteria for Identification of the Heat Shrink Bands. | ||
Identification of Flow Switch | Met the acceptance criteria for Identification of the Flow Switch. | ||
Joint Tensile Strength | Met the acceptance criteria for Joint Tensile Strength. | ||
Leak (Vacuum and Pressure Decay) | Met the acceptance criteria for Leak. | ||
Degree of Collapse | Met the acceptance criteria for Degree of Collapse. | ||
Compatibility (Arc™ Catheter & Collection Canister) | Met the acceptance criteria for Compatibility to the Arc™ Catheter and Riptide™ Collection Canister. | ||
Riptide™ Aspiration Pump | Bench - Performance | Degrees of Tilt | Met the acceptance criteria for Degrees of Tilt. |
Durability | Met the acceptance criteria for Durability. | ||
Maximum Vacuum | Met the acceptance criteria for Maximum Vacuum. | ||
Flow Capacity | Met the acceptance criteria for Flow Capacity. | ||
Electrical Safety | Met the acceptance criteria for Electrical Safety. | ||
Electromagnetic Compatibility | Met the acceptance criteria for Electromagnetic Compatibility. | ||
Riptide™ Collection Canister with Intermediate Tubing | Bench - Packaging | Packaging Integrity | Met the acceptance criteria for Packaging Integrity. |
Packaging Labeling | Met the acceptance criteria for Packaging Labeling. | ||
Bench - Performance | Volume Capacity | Met the acceptance criteria for Volume Capacity. | |
Volume Marking | Met the acceptance criteria for Volume Marking. | ||
Canister Strength | Met the acceptance criteria for Canister Strength. | ||
Overfill Protection | Met the acceptance criteria for Overfill Protection. | ||
Dimensional Inspection | Met the acceptance criteria for Dimensional Inspection. | ||
Degree of Collapse | Met the acceptance criteria for Degree of Collapse. | ||
Port Identification | Met the acceptance criteria for Port Identification. | ||
Compatibility (Riptide™ Aspiration Pump) | Met the acceptance criteria for Compatibility. | ||
Riptide™ Aspiration System | Bench - System Performance | Simulated Clot Retrieval | Met the acceptance criteria for Simulated Clot Retrieval. |
Vacuum Pressure | Met the acceptance criteria for Vacuum Pressure. | ||
Flow Rate | Met the acceptance criteria for Flow Rate. | ||
Lumen Collapse | The Arc™ Catheter is resistant to Lumen Collapse. | ||
Usability | Met the acceptance criteria for Usability. |
Study Information:
The provided document describes non-clinical bench testing and non-clinical animal testing. It explicitly states "Not Applicable" for clinical performance data. Therefore, questions related to human reader studies, ground truth establishment for a test set of clinical images, and training set details are not directly addressed in this document.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Test Set Sample Size:
- Bench Testing: The document does not specify the exact sample sizes (number of units tested) for each individual bench test. The nature of these tests often involves a batch of devices or components.
- Animal Testing: The document mentions "a porcine model" but does not specify the number of animals used for the animal testing.
- Data Provenance:
- Bench Testing: Conducted by the manufacturer, Micro Therapeutics, Inc. d/b/a ev3 Neurovascular, as part of their R&D and regulatory submission process. Location not specified, but the company is based in Irvine, California, USA.
- Animal Testing: Conducted "in a porcine model." Location not specified.
- Retrospective/Prospective: These are non-clinical studies (bench and animal), so the terms retrospective/prospective in the context of human data acquisition do not directly apply. They are inherently prospective in the sense that the tests were designed and executed to evaluate this specific device for its regulatory submission.
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)
- Not Applicable. The studies described are non-clinical (bench and animal). There is no mention of human expert-established ground truth for a test set of clinical images or data. The "ground truth" for these tests comes from objective measurements against defined standards (e.g., ISO, ASTM, USP standards, or internal specifications) and observations in animal models.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. As no human expert evaluation of clinical data for ground truth establishment is described, adjudication methods are not relevant to this submission.
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
- No. The document explicitly states "Performance Data - Clinical: Not Applicable." This means no human reader studies (MRMC or otherwise) were conducted or submitted as part of this 510(k). The device is not an AI-powered system that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- No. This device is a medical instrument (aspiration system for stroke), not an AI algorithm. Therefore, a standalone algorithm performance study is not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Bench Testing: Ground truth is established by objective measurements against pre-defined engineering specifications, international standards (ISO, ASTM, USP), and validated test methods. For example, "The Arc™ Catheter met the acceptance criteria for EO Residual" means the measured residual levels were below the established safe limits per ISO 10993-7.
- Animal Testing: Ground truth is established through direct observation and measurement in a controlled porcine model, in accordance with "21 CFR Part 58 for Good Laboratory Practice (GLP) for Non-Clinical Laboratory Studies". The goal was to evaluate "safety, efficacy, and usability" and compare it to the predicate device.
8. The sample size for the training set
- Not Applicable. No AI/machine learning component is described for this device, so there is no concept of a "training set" in the context of algorithm development.
9. How the ground truth for the training set was established
- Not Applicable. As there is no training set for an AI algorithm mentioned, this question is not relevant.
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(117 days)
Penumbra Aspiration Catheters and Separators: As part of the Penumbra Aspiration System, the Penumbra Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels in the coronary and peripheral vasculature.
Penumbra Aspiration Tubing: As part of the Penumbra Aspiration System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump: The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
The Penumbra Aspiration System is indicated for the removal of fresh, soft emboli and thrombi from vessels of the coronary and peripheral vasculature. The Aspiration Catheter and Separator are available in multiple configurations. The devices are provided sterile, non-pyrogenic, and intended for single use only. Intended users for this device are physicians who have received appropriate training in interventional radiology. The Penumbra Aspiration System is designed to remove thrombus from the coronary and peripheral vasculature using continuous aspiration. The Aspiration Catheter targets aspiration from the pump directly to the thrombus. The Separator may be used to clear the lumen of the Aspiration Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using an Aspiration Catheter with an I.D. of 0.054 in or larger. The Aspiration Catheter is introduced through a guide catheter or long introducer sheath and into the coronary or peripheral vasculature and guided over a guidewire to the site of the primary occlusion. The Aspiration Catheter is used with the Penumbra Pump MAX to aspirate thrombus from an occluded vessel. As needed, the Separator may be deployed from the Aspiration Catheter to assist with thrombus removal. The Separator is advanced and retracted through the Aspiration Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Aspiration Catheter tip. For the aspiration source, the Aspiration Catheter is used in conjunction with the Penumbra Pump MAX, which is connected using the Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Separator is provided with an introducer and torque device. The Aspiration Catheter may be provided with a steam shaping mandrel, rotating hemostasis valve, and a peelable sheath. The Separator is provided with an introducer and torque device. The Aspiration Catheter and Separator are visible under fluoroscopy. The Penumbra Pump MAX is the aspiration source for the Penumbra Aspiration System. The Penumbra Pump MAX operates using AC power and is designed to be portable if needed. The Penumbra Pump MAX provides vacuum of up to 29 inHg. The pump is available in both 110Vac and 230Vac versions. The front face of the pump has a display panel with a vacuum gauge, vacuum regulator dial, and power switch. The pump connects to the canister reservoir with a tubing assembly (Penumbra Pump/Canister Tubing), which is provided as an accessory. The Penumbra Pump/Canister Tubing consists of a short tubing segment with an inline filter and connectors on each end to facilitate attachment to the pump's vacuum port. The tubing is provided pre-attached to the canister reservoir lid. The Penumbra Pump/Canister Tubing is provided non-sterile and is used outside the sterile field.
The provided document is a 510(k) premarket notification for the Penumbra Aspiration System. It details the device's indications for use, its classification, and a comparison to predicate and reference devices. However, the document primarily focuses on demonstrating substantial equivalence through non-clinical (benchtop) and animal study data, largely leveraging existing data from previously cleared similar devices.
Crucially, this document does NOT contain information about specific "acceptance criteria" or "device performance" in terms of clinical outcomes, nor does it describe a study involving human subjects or experts for establishing ground truth for AI/algorithm performance.
Therefore, I cannot fulfill the request to describe the acceptance criteria and the study that proves the device meets the acceptance criteria, along with the specified sub-points (table of acceptance criteria/performance, sample size, experts, adjudication, MRMC study, standalone performance, type of ground truth, training set details) because this information is not present in the provided text.
The document discusses:
- Leveraged Non-Clinical Data (Section 1.10): This section lists benchtop tests (Friction, Visual & Dimensional, Pouch Seal Strength, Flow Rate, Tensile, Elongation, Bond Strength, Hub Air Aspiration, Torsion, Burst, Simulated Use, Particulate, Flexibility, Packaging, Corrosion). It states that "all established requirements and acceptance criteria were met," but it does not specify what those acceptance criteria were in measurable terms (e.g., "flow rate X L/min," "tensile strength Y N"). It also does not define "device performance" in the way requested (e.g., diagnostic accuracy, sensitivity, specificity).
- Leveraged Animal Studies (Section 1.11): This section summarizes findings from design validation in GLP animal testing, noting "No vessel injury," "No abnormal gross or histology findings," and "no significant vascular response." This is performance data in an animal model, but not clinical performance in humans, nor does it relate to acceptance criteria for an AI/algorithm-driven device.
In summary, the provided text describes the regulatory clearance process for a medical device (an aspiration system) based on substantial equivalence to existing devices, supported by benchtop testing and animal studies. It does not contain the kind of information typically found in a study proving an AI/algorithm-driven device meets specific clinical acceptance criteria, which would involve human data, expert review, and metrics like accuracy, sensitivity, or specificity.
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(97 days)
Penumbra Reperfusion Catheters and Separators: As part of the Penumbra System, the Reperfusion Catheters and Separators are 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.
Penumbra Aspiration Tubing: As part of the Penumbra System, the Penumbra Sterile Aspiration Tubing is indicated to connect the Penumbra Reperfusion Catheters to the Penumbra Pump MAX.
Penumbra Pump MAX: The Penumbra Pump MAX is indicated as a vacuum source for Penumbra Aspiration Systems.
The Penumbra System is designed to remove thrombus from the neurovasculature using continuous aspiration. The Reperfusion Catheter targets aspiration from the pump directly to the thrombus. The Separator may be used to clear the lumen of the Reperfusion Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using a Reperfusion Catheter with an I.D. of 0.054in [1.37mm] or larger. The Reperfusion Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire to the site of the primary occlusion. The Penumbra Reperfusion Catheter is used with the Penumbra Pump MAX to aspirate thrombus from an occluded vessel. As needed, a Penumbra Separator may be deployed from the Reperfusion Catheter to assist with thrombus removal. The Penumbra Separator is advanced and retracted through the Penumbra Reperfusion Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Reperfusion Catheter tip. For the aspiration source, the Penumbra Reperfusion Catheter is used in conjunction with the Penumbra Pump MAX, which is connected using the Penumbra Aspiration Tubing and the Penumbra Pump/Canister Tubing. The Penumbra Reperfusion Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Penumbra Separator is provided with an introducer and torque device. The devices are visible under fluoroscopy. The Penumbra Reperfusion Catheter, Separator, and Aspiration Tubing are provided sterile, non-pyrogenic, and intended for single use only. Additionally, a pre-packaged configuration (KIT packaging) for all Penumbra System Reperfusion Catheters with Aspiration Tubing is available.
The Penumbra Pump MAX is designed to provide aspiration for the Penumbra System. The Penumbra Pump MAX operates using AC power. The Penumbra Pump MAX provides vacuum of up to 29 inHg and is available in both 110Vac and 230Vac versions. The Penumbra Pump MAX and Pump/Canister Tubing are provided non-sterile and is used outside the sterile field.
Here's a breakdown of the acceptance criteria and study information based on the provided text, focused on the KIT configuration, as that's where new testing was performed:
1. Table of Acceptance Criteria and Reported Device Performance (KIT Configuration)
Attribute | Specification | Acceptance Criteria | Reported Performance |
---|---|---|---|
Visual Inspection | These evaluations confirm that the units used in this Design Verification testing meet all inspection criteria for release of finished goods (clinically acceptable) product. | Products meet all inspection criteria. | Pass |
Simulated Use (Intracranial Access, Vessel Access Entry Performance & Clot Removal) | Simulated use testing of the Catheter and Separator was performed with accessory devices in an anatomical model which simulated the tortuosity of the neurovasculature. Devices were delivered through the tortuous anatomical model to evaluate the effectiveness of the devices to remove clots and that the Reperfusion Catheter does not collapse under vacuum. | Devices effectively remove clots and catheters do not collapse under vacuum. | 100% Pass |
Catheter Coating | Coating has not delaminated, peeled, or flaked after simulated use. | Coating remains intact (not delaminated, peeled, or flaked). | 100% Pass |
Gross Leak | Pouch seals, pouch front, and pouch back material do not leak. | No leaks in pouch seals, front, or back material. | 100% Pass |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the numerical sample size for the "Design Verification testing" for the KIT configuration. It only mentions "units used in this Design Verification testing" for Visual Inspection, and implicitly for Simulated Use, Catheter Coating, and Gross Leak tests as they all report 100% Pass
.
- Sample Size: Not explicitly stated as a number, but all tested units passed.
- Data Provenance: The tests are described as "additional testing performed for the KIT configuration packaging," suggesting these are prospective, benchtop tests conducted by Penumbra, Inc. The country of origin for the data generation would logically be the USA, given the company's location.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
There is no mention of experts or clinicians being used to establish a ground truth for these non-clinical tests. The tests are focused on physical and mechanical properties and simulated use in anatomical models.
4. Adjudication Method for the Test Set
Not applicable, as these are non-clinical, objective tests and not based on expert review or consensus.
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 document describes a medical device (Penumbra System and Penumbra Pump MAX) for treating acute ischemic stroke, not an AI-based diagnostic or treatment guidance system that would involve human readers or AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This is a medical device, not an algorithm.
7. The Type of Ground Truth Used
The ground truth for these non-clinical tests is based on:
* Defined specifications and performance expectations: For Visual Inspection, Catheter Coating, and Gross Leak, the "ground truth" is adherence to predefined quality and integrity standards.
* Simulated physiological conditions and objective performance: For Simulated Use, the "ground truth" is the effective removal of clots and prevention of catheter collapse in an anatomical model that mimics neurovasculature.
8. The Sample Size for the Training Set
Not applicable. This is a medical device, not a machine learning model requiring a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable.
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(262 days)
The Penumbra System is intended 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. The Reperfusion Catheters ACE 64 and ACE 68 are intended for use in revascularization within the Internal Carotid Artery (ICA) within 8 hours of symptom onset.
The Penumbra System ACE components are additional components to the currently available Penumbra System / Penumbra System MAX. The Penumbra System ACE components provide a larger lumen to assist in the removal of thrombus from the neurovasculature. The devices are provided sterile, non-pyrogenic, and intended for single use only.
Here's an analysis of the provided text regarding the acceptance criteria and study for the Penumbra System ACE 64 and ACE 68 Reperfusion Catheters:
1. Table of Acceptance Criteria and Reported Device Performance
Test | Acceptance Criteria | Reported Device Performance | Pass / Fail |
---|---|---|---|
Biocompatibility Testing | |||
In Vitro Cytotoxicity | Sample extracts must yield cell lysis grade 2 or lower | Grade 1: Slight | Pass |
Sensitization | Test Group shall yield Grade 10% weight loss in 3 or more test animals, Mortality of 2 or more test animals, Abnormal behavior in 2 or more test animals | No evidence of systemic toxicity from sample extracts: No weight loss (all gained weight), No death, All test animals appeared normal | Pass |
Rabbit Pyrogen Study | Sample Extracts must not cause a total rise in body temperature of ≥ 0.5°C | Non-pyrogenic: No evidence of material-mediated pyrogenicity; no single animal had a total body temperature rise of ≥ 0.5°C | Pass |
Hemocompatibility In Vitro Hemolysis | Sample extracts must be non-hemolytic (≤ 2% hemolytic index) | Non-hemolytic: Hemolytic Index = 0.70%, Corrected Hemolytic index = 0.00% | Pass |
Complement Activation | The concentrations of C3a and SC5b-9 in the test samples are statistically similar to the predicate (Exposure Control & Ref Material) control and statistically lower than the positive control for all exposure times | The test sample concentrations of C3a and SC5b-9 were statistically similar or lower than the predicate control sample concentrations, and statistically lower than the positive control sample concentrations at all three exposure times | Pass |
Dog Thrombogenicity | The device must be non-thrombogenic after 4 hours in vivo when compared to a control device (Boston Scientific Excelsior SL-10 microcatheter) | No significant thrombosis with a Grade of 0 was observed in 2 out 2 test site and 2 out of 2 control sites. Based on the evaluation criteria, the amount of thrombosis was not considered significant | Pass |
Bench-top Testing | |||
Dimensional/Visual Inspection | Units meet all inspection criteria for release of finished goods (clinically acceptable) product. | Pass | Pass |
Simulated Use (Intracranial Access, Vessel Access Entry Performance & Clot Removal) | Effectiveness of devices to remove clots and that Reperfusion Catheter does not collapse under vacuum. | 100% Pass | Pass |
Coating Integrity | Coating has not delaminated, peeled, or flaked after simulated use. | 100% Pass | Pass |
Particulate Testing (Hydrophilic Coating) | Max particles: ≥ 10 um ≤ 6000 particles; ≥ 25 um ≤ 600 particles. | 10um 100% Pass; 25 um 100% Pass | Pass |
Particulate Testing (Catheter/Separator) | Max particles: ≥ 10 um ≤ 6000 particles; ≥ 25 um ≤ 600 particles. | 10μm 100% Pass; 25 um 100% Pass | Pass |
Coating Integrity (after particulate testing) | Coating is not grossly damaged after undergoing particulate testing. | 100% Pass | Pass |
Hub/Catheter Air Aspiration | When negative pressure is pulled, no air may leak into hub. | 100% Pass | Pass |
Pressure Test | 45 psi for 30 sec MIN | 100% Pass | Pass |
Reperfusion Catheter/Sheath or 8F Guide & 0.014" Guidewire compatibility (Friction Force) | Maximum value per specification. | 100% Pass | Pass |
Markerband Section Bond Strength | Minimum value per specification. | 100% Pass | Pass |
Joint Sections Bond Strength | Minimum value per specification. | 100% Pass | Pass |
Hub to Shaft & Hub to Hypotube Bond Strength | Minimum value per specification. | 100% Pass | Pass |
Steam-Shaped Distal Tip Tensile | Minimum value per specification. | 100% Pass | Pass |
Elongation to Failure | % Elongation ≥ 5% | 100% Pass | Pass |
Kink Resistance | No kinking when formed in a defined radius. | 100% Pass | Pass |
Corrosion | No visible corrosion on Reperfusion Catheter immediately after Corrosion Testing procedure. | 100% Pass | Pass |
Animal Study | |||
Vessel Injury | No vessel injury on final angiograms. | No vessel injury was noted. | Pass |
Gross/Histology Findings | No abnormal gross or histology findings in test vessel segments. | No abnormal gross or histology findings were noted. | Pass |
Vascular Response | No significant vascular response. | No significant vascular response. | Pass |
2. Sample Size and Data Provenance (for test sets, where applicable)
-
Biocompatibility Testing:
- In Vitro Cytotoxicity: Not specified in terms of sample size for the test itself, but implies multiple samples for extract testing.
- Sensitization: "Test Group" - size not specified.
- Acute Intracutaneous Reactivity: "mean test article and mean control score" - implies multiple samples, size not specified.
- Acute Systemic Toxicity: "3 or more test animals" (for weight loss criteria), "2 or more test animals" (for morality/behavior) - implies at least 3 animals for each extract/test (likely mice or rats, as common for this test).
- Rabbit Pyrogen Study: "No single animal" suggests multiple rabbits, specific number not stated.
- Hemocompatibility In Vitro Hemolysis: Sample extracts, size not specified.
- Complement Activation: "test samples" compared to "predicate (Exposure Control & Ref Material) control" and "positive control" at "all three exposure times." Specific number of samples not stated.
- Dog Thrombogenicity: "2 out of 2 test site and 2 out of 2 control sites" - suggests at least two test animals (dogs) for the in-vivo evaluation.
- Data Provenance: Retrospective, conducted by the manufacturer, or by external labs following GLP. Country of origin not specified, but following EN ISO 10993 guidelines.
-
Bench-top Testing:
- Sample sizes are not explicitly stated for all individual tests, but most indicate "100% Pass," which suggests the testing was performed on a sample of devices and all met the criteria. For particulate testing, the maximum number suggests a specific measurement from a sample.
- Data Provenance: Retrospective, conducted by the manufacturer.
-
Animal Study:
- Sample Size: A "swine model" was used. The number of individual animals (swine) is not explicitly stated, but the conclusions "No vessel injury was noted on the final angiograms following the vessel response procedure," "No abnormal gross or histology findings were noted in test vessel segments," and "The use of the Penumbra System ACE devices resulted in no significant vascular response in these experimental conditions," suggest sufficient animal subjects were used to support the claim.
- Data Provenance: Prospective, animal study (GLP Animal Testing).
3. Number of Experts Used and Qualifications (for ground truth establishment)
- Biocompatibility Testing: Experts in toxicology, microbiology, and animal studies would have been involved in the design and interpretation of these studies. Their specific number and qualifications are not detailed in this summary.
- Bench-top Testing: Engineers and material scientists within the manufacturer's R&D and Quality departments would have developed the specifications and assessed the results.
- Animal Study: Veterinarians, interventionalists (to perform the procedures), pathologists (for gross and histology findings), and researchers expert in animal models for vascular devices.
- Note: This document does not pertain to AI/ML or image data, so the concept of experts establishing ground truth for a test set (e.g., radiologist for image interpretation) as typically understood in AI studies is not directly applicable here. The "ground truth" here is physical/biological measurements and observations.
4. Adjudication Method (for the test set)
- Not applicable in the context of this device's non-clinical testing. Adjudication methods (like 2+1 or 3+1) are typically used for medical image interpretation where there is subjective assessment by multiple human readers (e.g., radiologists) that needs to be reconciled to establish a ground truth. The tests described are objective physical, chemical, or biological measurements.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, a MRMC comparative effectiveness study was not done. This document describes the pre-market non-clinical testing of a physical medical device (catheter), not an AI/ML algorithm for diagnostic imaging or similar applications where human reader performance is augmented.
6. Standalone (Algorithm Only) Performance Study
- No, this is not an AI/ML device. Therefore, a standalone algorithm performance study was not performed.
7. Type of Ground Truth Used
- Biocompatibility Testing: The ground truth is objective biological and chemical reactions/measurements (e.g., cell lysis grade, inflammation scores, weight changes, temperature changes, hemolytic index, C3a/SC5b-9 concentrations, histopathology for thrombogenicity).
- Bench-top Testing: The ground truth is objective physical and mechanical measurements against technical specifications (e.g., dimensions, force measurements, flow rates, visual integrity, particulate counts).
- Animal Study: The ground truth is direct in-vivo observation and pathological assessment (e.g., angiographic evidence of injury, gross pathology findings, histological examination of vessel segments).
8. Sample Size for the Training Set
- Not applicable. This is a physical medical device, not an AI/ML algorithm that requires a training set. The "training" for such devices involves engineering design, material selection, and iterative prototyping based on established engineering principles and prior knowledge.
9. How the Ground Truth for the Training Set Was Established
- Not applicable, as there is no "training set" in the AI/ML sense for this device. The development process relies on engineering specifications, material science data, and established test methods, rather than a labeled dataset for algorithm training.
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(28 days)
The Penumbra System is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.
The Penumbra System MAX components are additional components of the currently available Penumbra System. The Penumbra System MAX components provide a larger lumen to assist in the efficient removal of thrombus from the brain. The devices are provided sterile, non-pyrogenic, and intended for single use only.
The Penumbra System® MAX components are additional components of the currently available Penumbra System. The summary of non-clinical data details the testing that substantiates the safe and effective performance of the Neuron MAX System and its substantial equivalence to predicate devices. This includes Biocompatibility testing, Design Verification (Bench-Top Testing), and an Animal study.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and the Reported Device Performance
The acceptance criteria for each test were "Pass," meaning the device met the established requirements for each attribute.
Test / Test Subject | Attribute | Reported Device Performance (Result) |
---|---|---|
Biocompatibility Testing | ||
In Vitro Cytotoxicity | No evidence of cell lysis or toxicity | No evidence of cell lysis or toxicity |
Acute Intracutaneous Reactivity (Irritation) | No evidence of irritation | No evidence of irritation |
Acute Systemic Toxicity | No evidence of systemic toxicity | No evidence of systemic toxicity |
Rabbit Pyrogen Study | No evidence of material-mediated pyrogenicity | No evidence of material-mediated pyrogenicity |
Sensitization | Non-Sensitizing | Non-Sensitizing |
Hemo-compatibility - In Vitro Hemolysis | Non-hemolytic | Non-hemolytic |
Hemo-compatibility - In Vitro Coagulation (PT, PTT) | Coagulation times are within the normal range; Non-Thrombogenic | Within normal range; Non-Thrombogenic |
Hemo-compatibility - Complement Activation | No greater biological response than corresponding control | No greater biological response than corresponding control |
Bench-top Testing (Reperfusion Catheters) | ||
Pouch Seal | Pouch Seal Strength | Pass |
Dimensional / Visual Inspection | Units meet all inspection criteria for release of finished goods (clinically acceptable) product. | Pass |
Simulated Use [Intracranial Access & Thrombus Removal] | Units meet all inspection criteria for release of finished goods (clinically acceptable) product. | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Hub /Shaft & Hub / HypotubeTensile Strength | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Joint Tensile Strength | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Hub Air Aspiration | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Burst Test | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Particulate Testing (Hydrophilic Coating) | Pass |
Reperfusion Catheter4MAX / Sheath or 8F Guide compatibility (Friction Force) | Pass | |
Reperfusion Catheter 4MAX / 0.014" Guidewire compatibility (Friction Force) | Pass | |
Reperfusion Catheter 3MAX / Reperfusion Catheter 054 (Friction Force) | Friction Force | Pass |
Reperfusion Catheter 3MAX / 0.014" Guide wire compatibility (Friction Force) | Pass | |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Flow Rate | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Elongation to Failure | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Corrosion | Pass |
Reperfusion Catheter 3MAX / Reperfusion Catheter 4MAX | Torsion | Pass |
Bench-top Testing (Separator 3MAX) | ||
Dimensional / Visual Inspection (all sizes) | Units meet all inspection criteria for release of finished goods (clinically acceptable) product. | Pass |
Simulated Use: Hub Transition | Pass | |
Reperfusion Catheter 3MAX / Separator 3MAX / Aspiration Tubing Assembly Performance | Tracking | Pass |
Reperfusion Catheter 3MAX / Separator 3MAX / Aspiration Tubing Assembly Performance | Separator 3MAX & Reperfusion Catheter Compatible | Pass |
Reperfusion Catheter 3MAX / Separator 3MAX / Aspiration Tubing Assembly Performance | Separator 3MAX / Reperfusion Catheter / Pump and accessories / Aspiration Tubing (Aspiration Remove Clot) | Pass |
Reperfusion Catheter 3MAX / Separator 3MAX / Aspiration Tubing Assembly Performance | Separator 3MAX and Reperfusion Catheter Compatibility (Separator Advance / Retract) | Pass |
Separator Bond Joint Test | Separator 054 and Wire Joint Break Force | Pass |
Separator Bond Joint Test | Separator 041 and Wire Joint Break Force | Pass |
Separator Bond Joint Test | Separator 032 and Wire Joint Break Force | Pass |
Separator Bond Joint Test | Separator 026 and Wire Joint Break Force | Pass |
Separator Bond Joint Test | Separator 3MAX and Wire Joint Break Force | Pass |
Animal Study | ||
Safe use of Penumbra System MAX in swine model | No vessel injury noted on final angiograms following the vessel response procedure. No abnormal gross or histology findings in test vessel segments. No significant vascular response. | No vessel injury; No abnormal findings; No significant vascular response |
2. Sample Size Used for the Test Set and the Data Provenance
- Bench-top Testing: Sample sizes for individual tests ranged from 3 to 30 units (e.g., N=30 for Pouch Seal Strength, N=10 for Particulate Testing, N=3 for Flow Rate). The data provenance is internal laboratory testing ("All studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. All testing was performed using units which were 2x sterilized and met finished goods release requirements."). This is considered retrospective data from a manufacturing/design verification process.
- Biocompatibility Testing: The document does not specify exact sample sizes for each biocompatibility test but states that "All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices," which implies standard laboratory animal testing where applicable (e.g., Rabbit Pyrogen Study, Acute Intracutaneous Reactivity, Acute Systemic Toxicity, Sensitization). This data is from controlled laboratory experiments.
- Animal Study: The document mentions "An animal study was conducted to evaluate the safe use of the Penumbra System MAX in a swine model." The exact sample size for the animal study is not explicitly provided in the summary, but it refers to "experimental conditions" and "test vessel segments," suggesting a controlled study within a lab setting. This is prospective animal data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of those Experts
Not applicable. The studies described are non-clinical (bench-top, biocompatibility, animal studies) and do not involve human diagnostic or treatment decision-making where expert consensus would establish ground truth for a test set. The "ground truth" here is determined by objective physical, mechanical, biological, or physiological measurements against predefined engineering and biological safety standards.
4. Adjudication Method for the Test Set
Not applicable. As noted above, these are non-clinical studies. The results are objective measurements/observations (e.g., "Pass," "No evidence of toxicity," "No vessel injury") rather than interpretations requiring adjudication among human 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 document describes the safety and effectiveness testing of a physical medical device (catheter system) for mechanical thrombus removal, not an AI or imaging-based diagnostic device that would involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This document describes a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The ground truth for these non-clinical studies was established by:
- Predefined engineering specifications and performance parameters for mechanical and physical properties.
- Established international and national standards for biocompatibility (e.g., ISO 10993, USP, ASTM, 21 CFR Part 58).
- Physiological observations, angiographic evaluations, gross pathology, and histology in the animal model.
8. The Sample Size for the Training Set
Not applicable. This document refers to the testing of a physical medical device. There is no "training set" in the context of machine learning or AI. The design verification and biocompatibility testing involved various "test units" or "samples" for specific tests, as detailed in the table, to ensure the device met its design specifications.
9. How the Ground Truth for the Training Set was Established
Not applicable, for the same reason as #8. Ground truth in this context refers to the defined specifications and standards the device was designed to meet and was tested against.
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(64 days)
The Penumbra System is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (in the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset.
The Penumbra System Separator Flex (026, 032, 041, and 054) is an alternative to the current Penumbra System Separators. The Separator Flex utilizes a Nitinol core wire in place of the current stainless steel corewire. The Flex utilizes a Nitinol core wire in all four current sizes (026, 032, 041, and 054). Both the existing Separators and the subject Separator Flex models will be available to address Physician preference of stainless steel and nitinol. The device is provided sterile, nonpyrogenic, and intended for single use only.
The Penumbra System® Separator™ Flex (K100769) is a medical device intended for the revascularization of patients with acute ischemic stroke. The acceptance criteria and the study proving the device meets these criteria are detailed below.
1. Table of Acceptance Criteria and Reported Device Performance
Test | Acceptance Criteria | Reported Device Performance |
---|---|---|
Biocompatibility | ||
In Vitro Cytotoxicity | No evidence of cell lysis or toxicity | No evidence of cell lysis or toxicity |
Acute Intracutaneous Reactivity (Irritation) | No evidence of irritation | No evidence of irritation |
Acute Systemic Toxicity | No evidence of systemic toxicity | No evidence of systemic toxicity |
Rabbit Pyrogen Study | No evidence of material-mediated pyrogenicity | No evidence of material-mediated pyrogenicity |
Sensitization | Non-sensitizing | Non-sensitizing |
In Vitro Hemolysis | Non-hemolytic | Non-hemolytic |
In Vitro Coagulation (PT, PTT) | Coagulation times within normal range, non-thrombogenic | Coagulation times within normal range, non-thrombogenic |
Complement Activation | No greater biological response than corresponding control | No greater biological response than corresponding control |
Design Verification (Bench-Top Testing) | ||
Dimensional / Visual Inspection | Met established requirements | All sizes passed successfully |
Simulated Use (Reperfusion Catheter / Separator Flex / Aspiration Tubing Assembly Performance) | Met established requirements | All sizes passed successfully |
Separator Flexibility Test | Met established requirements | All sizes passed successfully |
Separator Flex Bond Joint Test | Met established requirements | Passed successfully |
2. Sample Size and Data Provenance
The provided document does not specify the exact sample sizes for each non-clinical test (biocompatibility and bench-top testing). However, it states that "All studies were conducted pursuant to 21 CFR, Part 58, Good Laboratory Practices" for biocompatibility, and for design verification, "All testing was performed using units which met applicable Design Control processed goods release requirements." This indicates that standard laboratory testing practices were followed to ensure sufficient sample sizes for statistically valid results, even if the explicit numbers are not given.
The data provenance is from non-clinical studies conducted by Penumbra, Inc. in the USA (Alameda, CA), as indicated by the sponsor's address and the regulatory context of a 510(k) submission to the FDA. The testing can be considered prospective in the sense that it was specifically designed and executed to support the regulatory submission for this new device.
3. Number of Experts and Qualifications for Ground Truth
This submission pertains to a medical device (catheter/separator) and relies on non-clinical data (biocompatibility and bench-top testing) rather than clinical data requiring expert review of medical images or patient outcomes. Therefore, the concept of "ground truth" derived from experts, as typically understood in studies involving diagnostic devices or AI algorithms, does not apply in this context. The "ground truth" for these tests is based on established scientific methods and pass/fail criteria.
4. Adjudication Method for the Test Set
As the studies are non-clinical (biocompatibility and bench-top testing), an adjudication method in the context of expert review (e.g., 2+1, 3+1) is not applicable. The results are determined by objective measurements and analyses performed according to established scientific protocols.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not conducted. This is a medical device (catheter) and not a diagnostic imaging AI algorithm, so such a study design is generally not relevant. The effectiveness is demonstrated through pre-clinical performance testing.
6. Standalone Performance Study
Yes, a standalone performance study was done in the form of the "Design Verification (Bench-Top Testing)". This section evaluates the physical, mechanical, and performance characteristics of the Penumbra System Separator Flex on its own, without human intervention during the actual tests (after the device is assembled and prepared for testing). The tests included:
- Dimensional / Visual Inspection
- Simulated Use (Reperfusion Catheter / Separator Flex / Aspiration Tubing Assembly Performance)
- Separator Flexibility Test
- Separator Flex Bond Joint Test
These tests demonstrate the intrinsic performance of the device against predefined specifications.
7. Type of Ground Truth Used
The "ground truth" for the non-clinical studies is based on established scientific and engineering standards and methods.
- For biocompatibility, the ground truth is defined by the accepted criteria outlined in ISO-10993 - I (Biological Evaluation of Medical Devices) for various biological responses (cytotoxicity, irritation, systemic toxicity, pyrogenicity, sensitization, hemolysis, coagulation, complement activation).
- For design verification (bench-top testing), the ground truth is based on engineering specifications, physical measurements, and functional performance criteria defined by the manufacturer to ensure the device operates as intended and meets safety and performance requirements.
8. Sample Size for the Training Set
Not applicable. This submission describes a physical medical device (catheter/separator), not an AI algorithm that requires a training set. The performance is assessed through bench-top testing and biocompatibility studies.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As a physical medical device, there is no "training set" in the context of machine learning. The ground truth for its performance is established through adherence to engineering design specifications, international standards (like ISO-10993), and good laboratory practices.
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