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510(k) Data Aggregation

    K Number
    K211990
    Date Cleared
    2021-07-27

    (29 days)

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

    K191551

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

    The Rist™ 071 Radial Access Guide Catheter is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

    Device Description

    The Rist™ 071 Radial Access Guide Catheter is a single lumen, variable stiffness catheter with a stainless steel and nitinol reinforced shaft to provide support. The embedded stainless-steel flat wire cross coil is in the proximal section of the catheter, which transitions to a nitinol round wire single coil in the distal end. The catheter has a radiopaque platinum/iridium marker band on the distal end to aid in visualization. The distal 25 cm of the Rist™ 071 Radial Access Guide Catheter has a hydrophilic coating which reduces the insertion force and allows the catheter to traverse the vasculature more easily. The catheter has a nominal outer diameter of 0.084 inches and a nominal inner diameter of 0.071 inches. It is available in three working lengths: 95 cm, 100 cm, and 105 cm. The Rist™ 071 Radial Access Guide Catheter has a PTFE-lined lumen to reduce friction with other devices introduced through the lumen. It is intended to provide access to the target site via transradial access and, once in place, provides a reinforcing conduit for other intravascular devices. A radial access dilator is included as an accessory. The Rist™ 071 Radial Access Guide Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    The Rist™ 071 Radial Access Guide Catheter is a medical device intended for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature. The acceptance criteria and supporting studies are detailed below.

    1. Table of Acceptance Criteria and Reported Device Performance

    The device underwent extensive testing, and the results consistently indicated that "All units met the acceptance criteria" or similar statements. Specific numerical acceptance criteria were not explicitly provided in the document for most tests, but the qualitative statement of meeting criteria is present.

    Test PerformedAcceptance Criteria (Explicit or Qualitative)Reported Device Performance
    Biocompatibility
    CytotoxicityNon-cytotoxicity, no abnormal events (pH change, debris)The test article is considered non-cytotoxic... No abnormal events such as pH change or debris were noted.
    SensitizationNo sensitization responseThe test article did not elicit a sensitization response.
    IrritationNo significant dermal reactionsNo significant dermal reactions were observed.
    Acute Systemic ToxicityNo abnormal clinical signs indicative of toxicityNone of the study subjects were observed with abnormal clinical signs indicative of toxicity.
    PyrogenicityNo pyrogenic response; all validity criteria metThe test article extracts did not cause a pyrogenic response and all validity criteria were met.
    Hemocompatibility (Complement Activation)Not statistically significant (p>0.05) to reference material/comparison articleThe test article results... were not statistically significant (p>0.05).
    Hemocompatibility (Hemolysis)Blank corrected percent hemolysis above negative control of 0.0%The test article returned a blank corrected percent hemolysis above the negative control of 0.0%.
    Hemocompatibility (Platelet & Leukocyte Count)Platelet count within specificationThe platelet count was within specification.
    Hemocompatibility (Partial Thromboplastin Time)No more material mediated coagulation abnormalities than predicate in intrinsic pathwayThe test article did not create any more material mediated coagulation abnormalities... when compared to the predicate.
    Sterilization ValidationProduct sterility per ANSI/AAMI/ISO 11135:2014 and AAMI TIR 28:2016Product was sterile.
    PackagingSterile barrier not compromisedAll units met all the packaging acceptance criteria.
    Catheter and Dilator Tensile StrengthMet tensile strength acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the tensile strength acceptance criteria.
    Catheter PTFE DelaminationMet PTFE delamination acceptance criteriaAll units met the catheter PTFE delamination acceptance criteria.
    TorqueMet torque acceptance criteriaAll units met the torque acceptance criteria.
    Catheter Burst PressureMet burst pressure acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the catheter burst pressure acceptance criteria.
    Particulate TestingMet particulate acceptance criteria per USPAll units met the particulate testing acceptance criteria.
    Coating IntegrityMet coating integrity acceptance criteria (no surface irregularities after conditioning and tortuous path)All units met the coating integrity acceptance criteria.
    Leak (Liquid)No leakage per ISO 10555-1:2013/Amd. 1:2017(E)All units met the liquid leak test acceptance criteria.
    Leak (Air)No air leaks per ISO 10555-1:2013/Amd. 1:2017(E)All units met the air leak test acceptance criteria.
    Catheter Dimensional InspectionID, OD, and working length met acceptance criteriaAll units met the catheter dimensional inspection acceptance criteria.
    Dilator Dimensional InspectionID and OD met acceptance criteriaAll units met the dilator dimensional inspection acceptance criteria.
    Chemical CompatibilityNo signs of degradation, no obstruction of ID after exposure to saline, dextrose, heparin, radiocontrastAll units met the chemical compatibility acceptance criteria.
    Visual Inspection of Catheter and DilatorSmooth tip transition points, no surface defectsAll units met the visual inspection acceptance criteria.
    Catheter Coating LengthLength of hydrophilic coating met specificationAll units met the catheter coating length acceptance criteria.
    Kink ResistanceMet kink resistance acceptance criteriaAll units met the kink resistance acceptance criteria.
    In vitro Simulated Use StudyProduct performance verified by physiciansAll acceptance criteria were met.
    Corrosion (from predicate)Met corrosion acceptance criteria per ISO 10555-1:2013/Amd. 1:2017(E)All units met the corrosion acceptance criteria.
    Hub Compatibility (from predicate)Met hub compatibility acceptance criteria per ISO 594-1:1986 and ISO 594-2:1998All units met the hub compatibility acceptance criteria.
    Radiopacity (from predicate)Physicians identified distal tip location, catheter shape, and curve locations on fluoroscopic imagesAll acceptance criteria were met.
    Label Content (from predicate)Information included is accurateAll units met the acceptance criteria for label content.
    Label Legibility (from predicate)Labeling remained legible after transportation and conditioningAll units met the acceptance criteria for label legibility.
    Barcode (from predicate)Scanned barcode matched appropriate informationAll units met the acceptance criteria for barcode.
    Dilator Working Length (from predicate)Dilator length met specificationAll units met the acceptance criteria for dilator working length.
    Useability (from predicate)Evaluators confirmed usability as per Instructions for UseAll acceptance criteria were met.
    Shelf-Life TestingProduct and packaging met all acceptance criteria for 6-month shelf lifeAll acceptance criteria were met.

    2. Sample Size for the Test Set and Data Provenance

    The document does not explicitly state the sample sizes used for each specific test in the "Test Set." However, it repeatedly mentions "All units" or "All units met" indicating that a sufficient number of samples were tested to achieve statistical significance or to demonstrate compliance.

    The data provenance is not specified in terms of country of origin. The studies are described as "Design verification and validation" (in-house testing) and based on applicable ISO/ASTM/USP standards, suggesting a laboratory-based, prospective testing approach. No mention of retrospective or prospective clinical data for the test set is present, as this is a pre-market submission focused on device performance rather than clinical outcomes.

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

    For the "In vitro Simulated Use Study," it states that "A simulated interventional procedure was performed by physicians." The exact number of physicians or their specific qualifications (e.g., "radiologist with 10 years of experience") are not provided.

    For the "Radiopacity" test (from the predicate device), "Physicians were shown fluoroscopic images." Again, the specific number and qualifications of these physicians are not detailed.

    4. Adjudication Method for the Test Set

    The document does not describe any formal adjudication method (e.g., 2+1, 3+1) for the tests. The results indicate a direct pass/fail or "met acceptance criteria" outcome, implying consensus on the directly measurable or observable results rather than a subjective assessment requiring adjudication. For physician-evaluated tests, the document indicates a general 'acceptance criteria met' without detailing disagreement resolution.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study was mentioned. The studies focused on device performance characteristics rather than comparing human reader performance with or without AI assistance. The device itself is a physical catheter, not an AI-powered diagnostic tool.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    No standalone algorithm performance study was done. This is consistent with the nature of the device as a physical medical instrument, not a software algorithm.

    7. Type of Ground Truth Used

    The ground truth for most performance tests was established by adherence to recognized international standards (ISO, ASTM, USP) and predefined internal specifications for various physical, chemical, and biological properties. This includes:

    • Physical Measurements: Dimensional accuracy (ID, OD, length), tensile strength metrics, burst pressure values, torque limits, kink resistance thresholds.
    • Chemical/Biological Properties: Biocompatibility assays (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity, hemocompatibility), chemical compatibility.
    • Functional Performance: Leak testing, coating integrity, particulate count, simulated use performance, radiopacity (as confirmed by physicians).
    • Sterility and Packaging Integrity: Demonstrated through sterilization validation and packaging tests.

    8. Sample Size for the Training Set

    No training set is applicable or mentioned. This device is a physical medical device, not a machine learning model that requires a training set.

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

    Not applicable as there is no training set for a physical device.

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    K Number
    K200417
    Date Cleared
    2020-05-02

    (72 days)

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

    K191551

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

    The RIST Radial Access Catheter is indicated for the introduction of interventional devices into the peripheral, coronary, and neuro vasculature.

    Device Description

    The RIST Radial Access Catheter is a flexible, single lumen catheter compatible with 0.035 inch and 0.038-inch guidewires. It is designed to deliver interventional devices into the peripheral, coronary, and neuro vasculature and is intended to provide access to the target site via transradial access. The RIST Radial Access Catheter consists of a radiopaque catheter shaft reinforced with stainless steel and has a luer connector at its proximal end for the attachment of accessories and the infusion of fluids. The distal tip of the catheter is shaped to have a smooth, rounded tip and is offered in two different distal segment shapes, namely Simmons 2 (SIM2) and Berenstein (BER). The catheter has a nominal outer diameter of 0.070 inches and a nominal inner diameter of 0.040 inches. It is available in two working lengths: 120 cm and 130 cm. The RIST Radial Access Catheter is compatible with the RIST Cath Radial Access Long Sheath (K191551) and off-theshelf accessories. The RIST Radial Access Catheter is supplied sterile, non-pyrogenic, and intended for single use only.

    AI/ML Overview

    The provided text is a 510(k) Summary for the RIST Radial Access Catheter. This document details the engineering and performance tests conducted to demonstrate the device's substantial equivalence to a predicate device, rather than the evaluation of an AI/ML medical device.

    Therefore, many of the typical acceptance criteria and study design elements requested in the prompt, such as:

    • A table of acceptance criteria and reported device performance related to AI/ML metrics (e.g., sensitivity, specificity, AUC)
    • Sample size for the test set and data provenance (e.g., country, retrospective/prospective) related to clinical data for AI/ML performance
    • Number of experts and their qualifications for establishing ground truth for AI/ML
    • Adjudication method for the test set for AI/ML
    • Multi-Reader Multi-Case (MRMC) comparative effectiveness study for human readers with and without AI
    • Standalone (algorithm-only) performance
    • Type of ground truth used (expert consensus, pathology, outcome data) for AI/ML
    • Sample size for the training set and how ground truth was established for training

    cannot be extracted from this document. The document describes a traditional medical device (catheter) and its physical and functional performance testing, not an AI or machine learning algorithm.

    The document focuses on establishing substantial equivalence based on:

    1. Indications for Use: Identical to the predicate device.
    2. Technological Characteristics: Comparison of materials, dimensions, and operational principles.
    3. Performance Data: A series of design verification and validation tests, and biocompatibility tests directly on the catheter itself.

    However, I can provide the acceptance criteria and reported performance for the physical device based on the available information:


    Acceptance Criteria and Device Performance (for a physical catheter; not an AI/ML device)

    Acceptance Criteria (Test Performed)Reported Device Performance (Results)
    Design Verification Testing
    Tensile StrengthAll units met the Tensile Strength acceptance criteria.
    Torque StrengthAll units met the Torque Strength acceptance criteria.
    Particulates (per USP )The acceptance criteria for Particulate testing was met.
    Dimensional Verification - IDThe acceptance criteria for ID Dimensional Verification was met.
    Dimensional Verification - ODThe acceptance criteria for OD Dimensional Verification was met.
    Dimensional Verification - Working LengthThe acceptance criteria for Working Length Dimensional Verification was met.
    Dimensional Verification - Tip LengthThe acceptance criteria for Tip Length Dimensional Verification were met.
    Kink ResistanceAll units met the Kink Resistance acceptance criteria.
    Visual Inspection (Tip Taper/Transitions)All units met the Tip Taper/Transition Visual Inspection acceptance criteria.
    Shape Retention (Catheter Tip Shape)All units met the Shape Retention Acceptance criteria.
    Burst Test (per ISO 10555-1)All units met the Catheter Burst acceptance criteria.
    Liquid Leak Test (per ISO 10555-1)All units met the Liquid Leak acceptance criteria.
    Air Leak Test (per ISO 80369-7)All units met the Air Leak Test acceptance criteria.
    Chemical Compatibility (with saline, dextrose, heparin, radiocontrast)All units met the Chemical Compatibility acceptance criteria.
    Corrosion (per ISO 10555-1 Annex A)All units met the Corrosion acceptance criteria.
    Packaging - Visual InspectionAll units met the Packaging Visual Inspection.
    Packaging - Pouch Leak (per ASTM F-1929-15)All units met the Pouch Leak test.
    Packaging - Pouch Peel (per ASTM F-88/F88M-15)All units met the Pouch Peel test.
    Packaging - Seal WidthAll seals met the acceptance criteria for Seal Width.
    Comparative Testing
    Friction Force (in simulated-use anatomical model)The RIST Radial Access Catheter and predicate device had comparable friction forces.
    Design Validation Testing
    In vitro Simulated Use Study - Bench (performance by physicians in simulated procedure, compared to competitive device)All acceptance criteria were met. The performance was found to be substantially equivalent.
    Radiopacity (physician identification of distal tip, shape, curves from fluoroscopic images)All acceptance criteria were met. The performance was found to be substantially equivalent.
    In vitro Simulated Use Study - Usability (evaluators representative of intended user population, per IFU)All acceptance criteria were met. The catheter was able to be used as per the Instruction for Use.
    Leveraged Testing (from previous submissions)
    Hub Compatibility (Catheter luers per ISO 594)All units met the Hub Compatibility acceptance criteria.
    Labeling Legibility - LabelThe acceptance criteria for Labeling Legibility was met.
    BarcodeThe acceptance criteria for Barcode was met.
    Labeling Legibility - IFUThe acceptance criteria for IFU Legibility was met.
    Sterilization (per ANSI/AAMI/ISO 11135:2014 and AAMI TIR 28:2016)Product was sterile (achieved SAL of at least 10⁻⁶).
    Biocompatibility Testing (per EN ISO 10993-1)
    Cytotoxicity (ISO MEM Elution)The test article is considered non-cytotoxic.
    Sensitization (ISO Guinea Pig Maximization Sensitization)The test article did not elicit a sensitization response; classified as non-sensitizer.
    Irritation (ISO Intracutaneous Irritation)No significant dermal reactions observed; non-irritant.
    Systemic Toxicity (ISO Acute Systemic Injection)No abnormal clinical signs indicative of toxicity; non-cytotoxic (conclusion oddly repeats cytotoxicity).
    Complement Activation, SC5b-9 AssaySC5b-9 assay results not statistically significant when compared to reference material and comparison.
    Hemocompatibility (ASTM Hemolysis - Direct Contact and Extract Method)Test article returned a blank corrected percent hemolysis above the negative control of 0.0% (interpreted as non-hemolytic based on conclusion).
    Pyrogenicity (Materials Mediated Rabbit Pyrogen)Test article extracts did not cause a pyrogenic response; non-pyrogenic.

    Study Details (for a physical catheter, not AI/ML):

    1. Sample sizes used for the test set and the data provenance: The document generally states "All units" or "Samples" without specifying the exact number of units tested for each criterion. The data provenance is internal RIST Neurovascular testing, leveraging some data from previously cleared devices (K152202, K161262, K152876). The studies are evidently prospective, laboratory/benchtop tests, not clinical studies on human subjects, hence "country of origin of the data" in a clinical sense is not applicable.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: For the In vitro Simulated Use Study - Bench and Radiopacity tests, "physicians" were used. For the In vitro Simulated Use Study - Usability, "evaluators representative of the intended user population" were used. No specific number or qualifications (e.g., years of experience, specialty) of these experts are provided in the summary.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable and not mentioned, as these are primarily objective engineering performance tests rather than subjective human assessments requiring adjudication. For the tests involving physicians/evaluators, specific adjudication methods are not detailed.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done: No, an MRMC study was not done, as this is a physical medical device (catheter), not an AI/ML system being evaluated for diagnostic accuracy improvement.
    5. If a standalone performance was done: Yes, the described performance tests (e.g., tensile strength, torque strength, dimensional verification, kink resistance, burst, leak tests, biocompatibility, sterilization) were performed directly on the RIST Radial Access Catheter in a standalone manner to demonstrate its inherent properties and safety.
    6. The type of ground truth used: For most engineering tests, the ground truth is established by the specified ISO/ASTM standards and internal acceptance criteria (e.g., a specific pressure for burst test, a specific force for tensile strength). For the simulated use and radiopacity tests, the 'ground truth' is the observable, functional performance and perception by the evaluating physicians/users, often compared to the predicate device. Biocompatibility used standard biological test methods.
    7. The sample size for the training set: Not applicable. This is a physical device submission, not an AI/ML algorithm that requires a training set.
    8. How the ground truth for the training set was established: Not applicable, as there is no training set for a physical device.
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