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510(k) Data Aggregation

    K Number
    K162563
    Date Cleared
    2017-01-05

    (113 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K092702, K112828, K021591

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The YOGA Microcatheter is intended for use in the peripheral, coronary, and neuro vasculature for the intravascular introduction of interventional/diagnostic devices.

    Device Description

    The YOGA Microcatheter is a variable stiffness, end to end braided single lumen catheter designed to access small, tortuous vasculature. The microcatheter has an outer hydrophilic coating that provides lubricity during navigation of vessels. The lubricious PTFE lined inner lumen is designed to facilitate movement of guide wires and other devices. A radiopaque marker band is provided at the catheter tip to aid fluoroscopic visualization. A luer fitting located on the proximal end of the catheter hub is used to attach accessories. A steam shaping mandrel is provided in the package.

    AI/ML Overview

    The provided document describes the substantial equivalence determination for the YOGA Microcatheter (K162563) based on its comparison to a predicate device, the ENVOY DA Guiding Catheter (K140080), and other reference devices. The focus of the provided text is on demonstrating the device's functional integrity and biological compatibility through various performance tests, rather than clinical efficacy as would be seen with an AI/ML device.

    Here's an analysis of the "acceptance criteria and the study that proves the device meets the acceptance criteria" based on the provided text, structured to address your specific points:

    Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the YOGA Microcatheter are implicitly defined by the "PASS" results for each of the performance tests listed. The device is deemed to meet these criteria if its performance matches or is equivalent to established standards or those of the predicate device.

    Test TitleAcceptance Criteria (Implicit)Reported Device Performance
    Visual InspectionSamples meet established acceptance criteria (e.g., no defects)PASS
    Catheter IDCatheter ID verified to pass requirementsPASS
    Catheter ODCatheter OD measured within established specificationsPASS
    Catheter Working LengthCatheter working length measured within established specificationsPASS
    Distal Tip LengthDistal Tip Length measured within established specificationsPASS
    Catheter Tensile StrengthWithstands specified tensile forcesPASS
    Hub Luer TaperComplies with ISO 594-1 and ISO 594-2PASS
    Air Leak testingNo air leakage observedPASS
    Flow Rate (static)Complies with ISO 10555-1 specified flow ratesPASS
    System Liquid LeakageNo liquid leakage under specified pressurePASS
    Flow Rate (dynamic)Meets dynamic flow rate specifications at 100/300 psiPASS
    Burst Pressure (static)Withstands specified burst pressurePASS
    Lumen flushMeets particulate count requirements per USPPASS
    Coating IntegrityMeets particulate count requirements per USP after simulated usePASS
    Delamination of PTFE LinerNo delamination of PTFE liner observedPASS
    Aseptic RemovalFacilitates aseptic removal per procedurePASS
    Steam ShapingSuccessful shaping per Instructions for UsePASS
    Linear Stiffness TestMeets linear stiffness specificationsPASS
    Lateral Stiffness TestMeets lateral stiffness specificationsPASS
    Track TestingForce required to track through anatomical model within limitsPASS
    Radiopacity (Animal Model)Distal end of catheter visible under fluoroscopyPASS
    Biocompatibility (various tests)Complies with ISO 10993 series and FDA Bluebook Memorandum G95-1PASS
    Sterilization Assurance Level (SAL)Achieves SAL of 10^-6PASS
    Shelf-Life (3 years)Demonstrated shelf-life equivalent to predicate devicesPASS

    Study Details

    The provided document describes physical and biological performance testing for a medical device (microcatheter), not an AI/ML device. Therefore, many of your specific questions regarding AI/ML studies (like ground truth, experts, MRMC, standalone performance) are not applicable to this submission. However, I will answer the relevant points based on the provided text.

    1. Sample size used for the test set and the data provenance:

      • Sample Size: The document states that "All testing was conducted using sampling methods as required by Codman & Shurtleff, Inc. Design Control procedures." However, specific sample sizes for each test are not provided in this document.
      • Data Provenance: The tests are "bench" (in vitro) and "animal" (in vivo) tests conducted by the manufacturer, Codman & Shurtleff, Inc. The document does not specify the country of origin for the animal studies, but the manufacturer is based in Raynham, Massachusetts, USA. The studies are prospective as they were conducted to support the 510(k) submission.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This question is not applicable as the document describes performance testing for a physical medical device, not an AI/ML algorithm requiring expert ground truth for classification or diagnosis. The "ground truth" for these tests is based on established engineering and biological standards (e.g., ISO, ASTM, USP).
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • This is not applicable. Adjudication methods are typically relevant for human review of AI/ML outputs or clinical endpoints with subjective interpretation. For the physical and biological tests described, the determination of "PASS" or "FAIL" would be based on objective measurements against pre-defined acceptance criteria, not an adjudication process involving multiple human reviewers.
    4. 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:

      • This is not applicable. This document describes the clearance of a physical medical device and does not involve AI or human readers.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • This is not applicable. The device is a microcatheter, a physical instrument, not an algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • The "ground truth" for the device's performance is based on established engineering standards, international standards (ISO, ASTM, USP), and validated internal design control procedures. For example, tensile strength is measured against engineering specifications, biocompatibility against ISO 10993 standards, and flow rates against ISO 10555-1. For radiopacity, the ground truth is the visual confirmation by a qualified individual (presumably a radiologist or veterinarian during the animal study) that the catheter is visible under fluoroscopy.
    7. The sample size for the training set:

      • This is not applicable. There is no "training set" as this is not an AI/ML device.
    8. How the ground truth for the training set was established:

      • This is not applicable. There is no "training set" for this physical device.
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