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510(k) Data Aggregation

    K Number
    K170852
    Device Name
    POD Packing Coil
    Manufacturer
    Date Cleared
    2017-07-19

    (119 days)

    Product Code
    Regulation Number
    882.5950
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K160832

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

    POD is indicated for the endovascular embolization of:

    • Intracranial aneurysms
    • · Other neurovascular abnormalities such as arteriovenous malformations and arterioyenous fistulae
    • · Arterial and venous embolizations in the peripheral vasculature
    Device Description

    The Penumbra Occlusion Device (POD), including the subject device, is a bare platinum embolization coil for the treatment of aneurysms or other vascular abnormalities. It is intended for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities such as arteriovenous fistulae. It is also intended for arterial and venous embolization in the peripheral vasculature. The POD System should only be used by physicians who have received appropriate training in interventional techniques.

    The POD System consists of the following components:

    • Coil: The Coil is attached to a Delivery Pusher both contained within an Introducer . Sheath. The Coil is an implantable medical device intended to exclude the treatment area from blood flow, thus creating stasis and allowing thrombosis to occur.
    • . Delivery Pusher: The Delivery Pusher is composed of a shaft with a radiopaque positioning marker, a Distal Detachment Tip (DDT) and a pull wire. The Delivery Pusher may also be referred to as the Detachment Pusher.
    • . Introducer Sheath: The Introducer Sheath is intended to cover the entire length of the Coil and the distal flexible segment of the Delivery Pusher. The Introducer Sheath is secured onto the Delivery Pusher with a friction lock to prevent unsheathing until use.
    • . Detachment Handle: The Detachment Handle is packaged separately. It is intended for use in multiple coil detachments performed during a single procedure
    AI/ML Overview

    The Penumbra, Inc. POD Packing Coil is a Class II neurovascular embolization device. The testing described for this device is primarily "bench-top testing" and biocompatibility testing designed to demonstrate substantial equivalence to a predicate device, the POD System (K141134). No clinical studies or AI/ML components are mentioned in the provided text.

    Here's an analysis based on the given information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document primarily shows specifications for various physical and mechanical properties, and the results confirm that these specifications were met (100% Pass).

    AttributeAcceptance Criteria (Specification)Reported Device Performance (Results)
    Dimensional/Visual InspectionConfirm the dimensions of the units meet all product specifications.100% Pass
    Fatigue ResistanceThe Coil retains its secondary shape after being cycled into / out of the 0.025 in. ID microcatheter.100% Pass
    Torsional ResistanceMinimum value per specification100% Pass
    Friction through a 0.025 in. ID microcatheter – Pull & PushMaximum value per specification100% Pass
    Simulated Use Flow Model TestingSimulated use testing of POD Packing Coil with accessory devices in an anatomical model which simulated the tortuosity of the neurovasculature. Devices were delivered through the model to evaluate the effectiveness of the devices to embolize targeted vasculature.100% Pass
    Distal System Tensile TestMinimum per specification100% Pass

    In addition, biocompatibility tests were performed on the predicate and reference devices, with the following results:

    TestAcceptance Criteria (Method)Reported Device Performance (Results)
    In Vitro CytotoxicityISO Elution Test (MEM Extract)Non-Toxic
    SensitizationMagnusson-Kligman MethodNon-Sensitizing
    Irritation (Intracutaneous Reactivity)ISO Intracutaneous (Intradermal) Injection TestNon-Irritant
    Implant studyIntramuscular Implant TestNon-Irritant
    Acute Systemic ToxicityISO Acute Systemic Injection TestNon-Toxic
    Material Mediated PyrogenUSP Material-Mediated Rabbit Pyrogen TestNon-pyrogenic
    Sub-Chronic/Sub-Acute Toxicity14 day / 14 dose Repeat Dose studyNon-Toxic
    In Vitro HemolysisASTM Method (Extraction & Direct Contact)Non-Hemolytic
    Dog ThrombogenicityThrombogenicity Study in Dogs - ISONon-Thrombogenic
    CoagulationPT and PTT TestNon-Thrombogenic
    Complement ActivationC3a and SC5b-9 through Enzyme AssayNo greater biological response than corresponding control
    Mouse LymphomaISO In Vitro Mouse LymphomaNon-Mutagenic
    Ames MutagenicitySalmonella typhimurium Reverse Mutation Assay (Ames Test)Non-Mutagenic
    In Vivo Mouse MicronucleusISO In Vivo Mouse Micronucleus AssayNon-Mutagenic

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

    • Bench-top testing: The sample size for the bench-top tests is not explicitly stated as a number. For "Dimensional/Visual Inspection," "Fatigue Resistance," "Torsional Resistance," "Friction," and "Distal System Tensile Test," the result is "100% Pass," which implies all units tested passed, but the number of units is not given. For "Simulated Use Flow Model Testing," the result is also "100% Pass," but again, the number of simulations/devices tested is not specified.
    • Biocompatibility testing: The biocompatibility testing was performed on the predicate and reference devices. The sample sizes for these tests are not provided in this summary.
    • Data provenance: Not explicitly stated, but bench-top testing is typically conducted in a laboratory setting, and biocompatibility studies adhere to GLP (Good Laboratory Practices), implying controlled experimental conditions rather than patient-derived data directly.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. This device is a physical medical device, and its performance evaluation relies on objective measurements and established engineering and biocompatibility standards, not expert-derived ground truth from interpreting medical images or clinical outcomes in the context of an AI/ML study.

    4. Adjudication method for the test set:

    • Not applicable. As noted above, this involves objective measurements and standard test protocols for a physical device, not subjective interpretation requiring adjudication among experts.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and its effect size:

    • No. The document describes bench-top and biocompatibility testing for a physical device. There is no mention of an AI component or a comparative effectiveness study involving human readers.

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

    • No. This is a physical medical device, not an algorithm or AI model.

    7. The type of ground truth used:

    • Bench-top testing: The "ground truth" here is defined by established engineering specifications and performance standards for medical devices (e.g., dimensional tolerances, mechanical strength, resistance to fatigue).
    • Biocompatibility testing: The "ground truth" is determined by well-established international standards and guidelines for biological evaluation of medical devices (EN ISO 10993-1) and specific test methodologies (e.g., ISO Elution Test, Magnusson-Kligman Method, ASTM methods, USP tests) that define what constitutes "non-toxic," "non-irritant," etc. These are objective scientific measurements and observations.

    8. The sample size for the training set:

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

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

    • Not applicable. This is not an AI/ML device.
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