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510(k) Data Aggregation

    K Number
    K172980
    Manufacturer
    Date Cleared
    2018-05-03

    (218 days)

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

    K171999

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

    This device is intended to introduce up to an 0.038" wire guide into the peripheral vasculature. It is also used to introduce diagnostic and/or interventional devices able to pass through the ID of the introducer.

    Device Description

    The device is utilized to gain access to the peripheral vasculature using the Seldinger technique. These introducer sets are comprised of either 4.0 French or 5.0 French outer introducer and 3.0 French inner dilator coaxial pair, a 21 gauge percutaneous entry needle, an 0.018 inch mandril wire guide with a distal coil tip, and a Check-Flo® Hemostasis Valve. These sets are supplied sterile and are intended for one-time use.

    AI/ML Overview

    The provided text describes the Cook Incorporated Micropuncture® Pedal Access Set (K172980). It details the device's indications for use, its comparison to a predicate device, and the non-clinical testing performed to establish its substantial equivalence.

    Here's an analysis of the acceptance criteria and study information provided, structured as requested:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance CriteriaReported Device Performance
    Biocompatibility testingPredetermined acceptance criteria (per ANSI AAMI ISO 10993-1:2009(R)2013) were met.Device is biocompatible (cytotoxicity, sensitization, intracutaneous reactivity, systemic toxicity, pyrogenicity, hemocompatibility, complement activation, and partial thromboplastin time).
    Tensile Testing of the Hub to Shaft BondHub of outer introducer and inner dilator would not loosen or separate from the shaft (per BS EN ISO 11070:2014).Predetermined acceptance criteria were met.
    Tensile Testing of Check-Flo® Valve BondsConnection bonds withstand peak load values under proper clinical use.Predetermined acceptance criterion was met.
    Liquid Leakage TestingNo liquid leakage under proper clinical use of the hemostasis valve (per BS EN ISO 11070:2014 - Sections 7.3 and 7.4).Predetermined acceptance criterion was met.
    Dimensional Verification TestingComponents meet specified dimensional requirements.Predetermined acceptance criteria were met.
    Wire Guide Fracture TestNo signs of fracture (per BS EN ISO 11070:2014 - Section 8.4 and Annex H).Predetermined acceptance criterion was met.
    Wire Guide Tensile TestDistal tip of wire guide would not separate under clinically relevant conditions (per BS EN ISO 11070:2014 - Section 8.6 and Annex H).Predetermined acceptance criterion was met.
    Radiopacity TestingWire guide detectable under fluoroscopy.Predetermined acceptance criterion was met.
    Resistance to Damage by Flex TestingWire guide show no damage or defects when subjected to repeated flexing (per BS EN ISO 11070:2014 - Section 8.5 and Annex G).Predetermined acceptance criterion was met.

    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 primarily details non-clinical laboratory testing. For these tests, specific sample sizes are not explicitly stated, but the results indicate that the "predetermined acceptance criteria were met" for all tests. There is no information regarding country of origin or retrospective/prospective nature for these non-clinical tests.

    The document does reference clinical literature to support the indications for use, stating:

    • "These articles describe successful use of the subject device for pedal access in a total of 220 patients..."
    • The articles listed are from the Journal of Endovascular Therapy, Fortschr Röntgenstr, and Annals of Vascular Surgery, suggesting an international (likely multi-country) provenance, and they are retrospective or prospective observational studies/case series rather than controlled trials focused specifically on this device's performance against pre-defined criteria. The specific nature (retrospective/prospective) would need to be gleaned from the individual articles, which are only referenced.

    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 primary evidence presented for substantial equivalence is based on non-clinical performance testing against established engineering standards (e.g., ISO standards), not on expert-adjudicated test sets or ground truth established by experts. The clinical literature cited involves patient outcomes from medical procedures, where the "ground truth" would be the clinical success or complications observed by the treating physicians, but this is used as supportive evidence for the indications for use, not as a test set for device performance itself.

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

    Not applicable. This is for non-clinical testing against engineering standards.

    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 not an AI-powered diagnostic or assistive tool for human readers. It is a physical medical device (catheter introducer set).

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

    Not applicable. This is a physical medical device, not an algorithm.

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

    For the non-clinical tests, the "ground truth" is defined by the specific performance requirements outlined in the referenced ISO and other engineering standards. For instance, the "ground truth" for the tensile test is "no loosening or separation."

    For the clinical literature cited, the "ground truth" is implicitly the outcomes data from the patient cases described in those publications (e.g., successful revascularization, complications, etc.), which support the general utility of pedal access.

    8. The sample size for the training set

    Not applicable. This is a physical medical device and does not involve AI or machine learning models that require training sets.

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

    Not applicable. This is a physical medical device and does not involve AI or machine learning models.

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