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510(k) Data Aggregation

    K Number
    K181237
    Date Cleared
    2018-08-03

    (85 days)

    Product Code
    Regulation Number
    870.1340
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K152173, K111606

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

    The Glidesheath Slender Tibial Pedal Kit is indicated to facilitate placing a catheter through the skin into the lower extremity peripheral vasculature below the knee.

    Device Description

    The Glidesheath Slender Tibial Pedal Kit is used to facilitate placing a catheter through the skin into the lower extremity peripheral vasculature below the knee. It consists of an introducer (sheath and dilator), which are packaged together with a mini guide wire, an entry needle and a guide inserter.

    During a diagnostic or interventional procedure in a cath lab, the stainless steel entry needle (cannula) is used to gain access to the vein or artery for placement of the mini guide wire. The nitinol mini guide wire is inserted through the cannula into the patient's blood vessel. The wire is used for placement of the sheath and dilator into the vein or artery. The Guide Inserter which is attached to the Mini Guide Wire holder is used to assist the placement of the wire into the needle.

    Following guide wire insertion, the cannula is removed and the sheath and dilator are then inserted over the mini guide wire and into the blood vessel. The mini guide wire is then withdrawn from the vessel. The dilator maintains the integrity of the sheath and dilates the blood vessel during insertion. Once the sheath is situated in the vessel, the dilator is removed and an appropriate catheter can then be inserted through the sheath.

    The sheath incorporates a 1-way valve and a 3-way stopcock connected by a side tube. The sheath is coated with hydrophilic coating to minimize frictional resistance when inserting or removing the sheath from the patient's blood vessel. In addition, the sheath and dilator contain bismuth, making these devices visible under fluoroscopy.

    The sheath, dilator, entry needle, mini guide wire and guide inserter are provided in a single package and sterilized together.

    The Glidesheath Slender Tibial Pedal Kit is a disposable, ethylene oxide gas sterilized device intended for single use only.

    AI/ML Overview

    The Glidesheath Slender Tibial Pedal Kit is a medical device, and the provided document is a 510(k) summary for its premarket notification to the FDA. As such, the concept of "acceptance criteria" and "device performance" in this context refers to demonstrating substantial equivalence to a legally marketed predicate device rather than achieving specific quantitative performance metrics typically seen in AI/software medical devices.

    The "study" that proves the device meets the acceptance criteria is a combination of non-clinical tests (packaging, cadaver testing) and a comparison to existing PRIME Registry data, rather than a clinical trial directly evaluating the device's efficacy against a predefined standard.

    Here's an attempt to extract the requested information, understanding that some categories might not be directly applicable or phrased differently for a medical device clearance like this.


    1. Table of Acceptance Criteria and Reported Device Performance

    Parameter / Acceptance CriteriaReported Device Performance / Evaluation Finding
    Substantial Equivalence (Overall Acceptance Criteria): Demonstrate that the Glidesheath Slender Tibial Pedal Kit is safe and effective and substantially equivalent to legally marketed predicate devices in its intended use/indications for use, technology/principal of operation, materials, and performance.The Glidesheath Slender Tibial Pedal Kit is considered substantially equivalent to the predicate device (K142183 Glidesheath Slender) and reference devices (K152173 Glidesheath, K111606 Pinnacle Precision Access System) based on:
    • Identical materials, formulation, geometry, source, processing, and sterilization method for individual components.
    • Successful packaging verification testing.
    • Demonstrated clinical feasibility in cadaver testing.
    • Favorable comparison to PRIME Registry data. |
      | Packaging Durability: Packaging must ensure the durability of the device throughout distribution. | Packaging verification testing was performed, including Visual Inspection (Post Environmental Conditioning and Distribution Simulation), Detecting Seal Leaks by Dye Penetration (ASTM F1929-15), Seal Strength (ASTM F88/F88M-15), and Climatic Stressing (ASTM F2825-10). The packaging was found to be durable. |
      | Clinical Feasibility (Cadaver Testing): Device compatible with insertion angles and acceptable for use in Below-The-Knee (BTK) access; protocols used by physicians in standard practice are equivalent to the test protocol. | Cadaver testing using lower leg models demonstrated that the Glidesheath Slender sheath is compatible with insertion angles for ultrasound-guided BTK access in four BTK vessels. The kit and components were deemed acceptable for BTK access. A follow-up survey confirmed physician protocols align with the study's access protocol. |
      | Biocompatibility: Meet biological safety requirements for an external communicating device, circulating blood with limited contact (up to 24 hours), per EN ISO 10993-1 and FDA Guidance. | No additional biocompatibility testing was performed as all components are identical to predicate/reference devices in materials, formulation, etc. The device is considered to have substantially equivalent biocompatibility. |
      | Sterilization (SAL 10-6): Achieve a Sterility Assurance Level (SAL) of 10-6 in accordance with ISO 11135:2014. | The device was adopted into an existing ethylene oxide sterilization process validated via the overkill half-cycle approach to achieve an SAL of 10-6. |
      | Sterilant Residuals: Ethylene oxide (EO) and ethylene chlorohydrin (ECH) levels must not exceed average daily doses of 4 mg and 9 mg, respectively, after 24 hours of heated aeration, per EN ISO 10993-7:2008. | Sterilant residual testing demonstrated that EO and ECH levels did not exceed the specified limits after 24 hours of heated aeration. |

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

    • Test Set for Packaging: The document does not specify the exact sample size for each packaging test (Visual Inspection, Seal Leaks, Seal Strength, Climatic Stressing).
    • Test Set for Cadaver Testing: The document mentions "lower leg models" but does not specify the number of cadavers or individual access attempts.
    • Test Set for Clinical Comparison (PRIME Registry): "The first 71 patients treated with the Terumo Glidesheath Slender when undergoing an index endovascular procedure using a tibial access point."
      • Data Provenance: The document states this was compared "to a literature based dataset of procedures using radial and femoral access," implying this data might be a mix of prospective collection (for the 71 patients) and retrospective (for the literature comparison). No country of origin is specified for the PRIME Registry data, but generally, medical device registries can be multinational.

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

    • Packaging Testing: No external experts are mentioned for ground truth establishment; testing was done against established ASTM/ISO standards.
    • Cadaver Testing: The study involved "physicians." A "follow-up survey" was conducted to confirm protocols. The number and specific qualifications of these physicians are not detailed beyond being "physicians" involved in BTK access.
    • Clinical Comparison (PRIME Registry): The PRIME Registry data itself is likely based on clinical outcomes and assessments made by healthcare professionals during actual procedures. The document does not specify experts involved in establishing "ground truth" for comparative purposes, rather, it uses existing clinical data.

    4. Adjudication Method for the Test Set

    • Packaging Testing: Adjudication is inherently built into meeting the criteria of the referenced ASTM/ISO standards. No human adjudication is specified beyond standard quality control procedures.
    • Cadaver Testing: The document implies assessment by physicians performing the procedures. No formal adjudication method (e.g., 2+1, 3+1 consensus) for the cadaver test results is described.
    • Clinical Comparison (PRIME Registry): The document does not describe any specific adjudication method for the PRIME Registry data or the literature-based dataset. Registry data typically relies on established clinical reporting.

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

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This device is a catheter introducer (hardware), not an AI/software device that would typically involve human readers interpreting output with or without AI assistance. The clinical evaluation focused on comparing the device's performance to predicate devices and existing clinical practices using registry data.


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

    No, this question is not applicable. The device is a physical medical instrument (catheter introducer kit), not an algorithm or software. Its performance is tied to its physical characteristics and how it functions during a medical procedure, not an algorithm's output.


    7. The Type of Ground Truth Used

    • Packaging Testing: Ground truth was based on adherence to established international standards (ASTM and ISO).
    • Cadaver Testing: Ground truth was based on direct observation of the device's performance and compatibility with BTK access in simulated use, assessed by physicians. This can be considered a form of "expert assessment" in a simulated environment.
    • Clinical Comparison (PRIME Registry): Ground truth was established through real-world clinical outcomes and procedural observations recorded in the PRIME Registry and a literature-based dataset. This could be considered a form of "outcomes data" and "clinical assessment."

    8. The Sample Size for the Training Set

    This question is not applicable. This is a hardware medical device, not a machine learning or AI model, thus there is no "training set" in the context of algorithm development.


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

    This question is not applicable as there is no training set for a hardware device.

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    K Number
    K173831
    Date Cleared
    2018-05-08

    (141 days)

    Product Code
    Regulation Number
    870.1340
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K152173

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

    The Glidesheath Slender is indicated to facilitate placing a catheter through the skin into the radial artery.

    Device Description

    The Glidesheath Slender consists of an introducer (sheath and a dilator), which are packaged together with an entry needle, mini guide wire and guide wire inserter. The Glidesheath Slender devices (all sheath sizes) are used to facilitate placing a catheter through the skin into the radial artery. The sheath and dilator contain bismuth, making these devices visible under fluoroscopy. The sheath is coated with hydrophilic coating to minimize frictional resistance when inserting or removing the sheath from the patient's blood vessel.

    The entry needle (cannula) is used to gain access to the radial artery for placement of the mini guide wire. The entry needle is offered in either the stainless steel (SS) entry needle version or the Surflo (SR) IV catheter (which includes a needle). There are two different types of stainless-steel entry needles that are available in various gauges and lengths. The two needle types are referenced in the documentation as TPC and TRI. These initials are only used in internal Terumo documents.

    The mini guide wire is used for placement of the sheath and dilator into the radial artery. The mini guide wire is offered in three versions made out of three materials, either a stainless-steel spring coil model (stainless steel), a nitinol model with palladium tip (nitinol) or a polyurethane plastic model with a nitinol core (plastic).

    During either a diagnostic or interventional catheterization procedure, a physician will perform the following procedure. The mini guide wire is inserted through a cannula placed in the patient's blood vessel. A guide wire inserter is provided to assist in insertion of the mini guide wire into the cannula. Following guide wire insertion, the cannula is removed, and the sheath and dilator are then inserted over the mini guide wire and into the blood vessel. The mini guide wire is then withdrawn from the vessel. The dilator maintains the integrity of the sheath and dilates the blood vessel during insertion. Once the sheath is situated in the vessel, the dilator is removed, and an appropriate catheter can then be inserted through the sheath.

    The entry needle, the mini guide wire and the guide wire inserter are all accessories to the Glidesheath Slender sheath/dilator. The accessories for a given product code are provided with the Glidesheat Slender sheath/dilator in an individual package and sterilized together.

    AI/ML Overview

    The acceptance criteria and study proving the device meets them are detailed for the Glidesheath Slender. The device is a catheter introducer for radial artery access.

    Here's a breakdown of the information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document provides a comprehensive list of performance tests conducted on various components of the Glidesheath Slender. The "Reported Device Performance" column implicitly states that the "Glidesheath Slender tested met the predetermined acceptance criteria and results support a determination of substantial equivalence." This means that for each test item listed, the device's performance fell within the acceptable parameters defined by the cited standards (ISO, ASTM, in-house) or internal requirements.

    ComponentTest ItemReferenceAcceptance CriteriaReported Device Performance
    SheathFluoroscopyISO 11070:2014, Section 4.5
    ASTM F640-12(Implicit: Device must be visible under fluoroscopy as per standards)Met predetermined acceptance criteria.
    Sheath visual inspectionIn-house standard(Implicit: Visual quality meets internal specifications)Met predetermined acceptance criteria.
    Sheath Effective LengthIn-house standard(Implicit: Length within specified tolerances)Met predetermined acceptance criteria.
    Side Tube LengthIn-house standard(Implicit: Length within specified tolerances)Met predetermined acceptance criteria.
    Sheath Tip IDIn-house standard(Implicit: Inner diameter at tip within specified tolerances)Met predetermined acceptance criteria.
    Sheath, Hemostatic Valve LeakISO 11070:2014, Annex E(Implicit: Hemostatic valve must prevent leakage as per standard)Met predetermined acceptance criteria.
    Sheath Pressure TestISO 11070:2014, Annex D
    ISO 11070:2013, Annex C(Implicit: Withstands specified pressure without failure as per standards)Met predetermined acceptance criteria.
    Sheath PenetrationIn-house standard(Implicit: Achieves appropriate penetration characteristics)Met predetermined acceptance criteria.
    Visual inspection after penetration testingISO 11070:2014 - Annex A section A3(Implicit: No significant damage or alteration after penetration as per standard)Met predetermined acceptance criteria.
    Sheath Tip Rollback TestISO 11070:2014 - Annex A section A3(Implicit: Tip integrity maintained during rollback as per standard)Met predetermined acceptance criteria.
    Dilator Hub to Sheath Hub Snap Fit StrengthIn-house standard(Implicit: Connection strength meets internal specifications)Met predetermined acceptance criteria.
    Valve Mobility ResistanceIn-house standard(Implicit: Valve operates smoothly within specified resistance)Met predetermined acceptance criteria.
    Sheath Kink resistanceISO 11070:2014 Annex A section A.1(Implicit: Resists kinking under specified conditions as per standard)Met predetermined acceptance criteria.
    Sheath Tubing/Housing Joint StrengthISO 11070:2014, Section 7.6(Implicit: Joint strength meets specified requirements as per standard)Met predetermined acceptance criteria.
    Cap to Housing Joint StrengthIn-house standard(Implicit: Connection strength meets internal specifications)Met predetermined acceptance criteria.
    Sheath Support to Housing StrengthIn-house standard(Implicit: Support strength meets internal specifications)Met predetermined acceptance criteria.
    Sheath Tubing Tensile StrengthISO 11070:2014, Section 7.6(Implicit: Tensile strength meets specified requirements as per standard)Met predetermined acceptance criteria.
    Sheath Lubricity and DurabilityIn-house standard(Implicit: Maintains lubricity and durability over intended use)Met predetermined acceptance criteria.
    Particle capture during simulated useFDA PTCA Guidance(Implicit: Particle generation during simulated use is within acceptable limits as per FDA guidance)Met predetermined acceptance criteria.
    Coating integrity after simulated useIn-house standard(Implicit: Hydrophilic coating maintains integrity after simulated use)Met predetermined acceptance criteria.
    DilatorFluoroscopyISO 11070:2014, Section 4.5
    ASTM F640-12(Implicit: Device must be visible under fluoroscopy as per standards)Met predetermined acceptance criteria.
    Dilator visual inspectionIn-house standard(Implicit: Visual quality meets internal specifications)Met predetermined acceptance criteria.
    Dilator Useable LengthIn-house standard(Implicit: Length within specified tolerances)Met predetermined acceptance criteria.
    Dilator Tip IDIn-house standard(Implicit: Inner diameter at tip within specified tolerances)Met predetermined acceptance criteria.
    Dilator OD at Sheath TipIn-house standard(Implicit: Outer diameter at sheath tip within specified tolerances)Met predetermined acceptance criteria.
    Dilator PenetrationIn-house standard(Implicit: Achieves appropriate penetration characteristics)Met predetermined acceptance criteria.
    Visual inspection after penetration testingISO 11070:2014 - Annex A section A3(Implicit: No significant damage or alteration after penetration as per standard)Met predetermined acceptance criteria.
    Dilator Tip Rollback TestISO 11070:2014 - Annex A section A3(Implicit: Tip integrity maintained during rollback as per standard)Met predetermined acceptance criteria.
    Dilator to Hub TensileISO 11070:2014, Annex C
    ISO 11070:2013, Annex B(Implicit: Tensile strength of dilator to hub connection meets specified requirements as per standards)Met predetermined acceptance criteria.
    Dilator Hub to Sheath Hub Snap Fit StrengthIn-house standard(Implicit: Connection strength meets internal specifications)Met predetermined acceptance criteria.
    Particle capture during simulated useFDA PTCA Guidance(Implicit: Particle generation during simulated use is within acceptable limits as per FDA guidance)Met predetermined acceptance criteria.
    BiocompatibilityCytotoxicityEN ISO 10993-1, FDA Guidance(Implicit: No cytotoxic effects detected)Met predetermined acceptance criteria.
    SensitizationEN ISO 10993-1, FDA Guidance(Implicit: No sensitization detected)Met predetermined acceptance criteria.
    Intracutaneous ReactivityEN ISO 10993-1, FDA Guidance(Implicit: No significant intracutaneous reaction)Met predetermined acceptance criteria.
    Systemic Toxicity (Acute)EN ISO 10993-1, FDA Guidance(Implicit: No acute systemic toxicity)Met predetermined acceptance criteria.
    PyrogenicityEN ISO 10993-1, FDA Guidance(Implicit: No pyrogenic response)Met predetermined acceptance criteria.
    HemocompatibilityEN ISO 10993-1, FDA Guidance(Implicit: Compatible with blood, does not cause adverse hematological effects)Met predetermined acceptance criteria.
    SterilizationSterility AssayISO 11135:2014Sterility Assurance Level (SAL) of 10-6Achieved SAL of 10-6.
    Residual Ethylene Oxide (EO)EN ISO 10993-7:2008Not exceeding an average daily dose of 4 mg after 24 hours of heated aerationMet predetermined acceptance criteria.
    Residual Ethylene Chlorohydrin (ECH)EN ISO 10993-7:2008Not exceeding an average daily dose of 9 mg after 24 hours of heated aerationMet predetermined acceptance criteria.
    Shelf LifeShelf life validation(Implied in submission)(Implicit: Device maintains performance and safety for 30 months)Demonstrated 30 months shelf life, with performance maintained throughout.

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

    The document describes non-clinical performance testing, which typically involves testing of device units according to engineering standards rather than a "test set" of patient data. The specific number of units tested for each performance test item is not provided in this summary. The data provenance is internal to the manufacturer (Terumo Medical Corporation) and follows recognized international and in-house standards. This is not patient data, so "country of origin" and "retrospective/prospective" are not applicable in the usual sense for clinical studies.

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

    This information is not applicable as the document explicitly states: "This 510(k) does not include data from clinical tests." The performance testing described is engineering and biocompatibility testing, where "ground truth" is established by adherence to specified physical and chemical properties and compliance with recognized standards.

    4. Adjudication Method for the Test Set:

    This information is not applicable as clinical data or expert review of cases is not part of this 510(k) summary.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    No, an MRMC comparative effectiveness study was not done. The document explicitly states: "This 510(k) does not include data from clinical tests." Therefore, there is no information on how much human readers improve with AI vs. without AI assistance.

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

    This is not applicable as the device is a physical medical instrument (catheter introducer), not an AI algorithm or software.

    7. The Type of Ground Truth Used:

    For the performance testing, the "ground truth" is established by:

    • International Standards: ISO 11070:2014, ASTM F640-12, ISO 11135:2014, EN ISO 10993-1, EN ISO 10993-7:2008.
    • FDA Guidance: FDA PTCA Guidance, FDA Guidance on Use of International Standard ISO 10993-1.
    • In-house standards: Internal specifications developed by Terumo Medical Corporation.

    These standards and guidances define acceptable physical, mechanical, chemical, and biological properties for device components.

    8. The Sample Size for the Training Set:

    This is not applicable as the device is a physical medical instrument and does not involve a "training set" in the context of machine learning or AI.

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

    This is not applicable for the same reason as above.

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