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510(k) Data Aggregation
(181 days)
The Esperance 3+ Aspiration Catheter with the Wallaby Aspiration Tubing set and a compatible aspiration pump is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within internal carotid, middle cerebral – M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
The Esperance® 3+ Aspiration Catheter is a single-use, vascular catheter consisting of a single lumen, variable stiffness, composite catheter. The device has a tapered shaft with tapered inner diameter (ID) from 0.054'' (proximal) to 0.041'' (distal) and tapered outer diameter (OD) from 0.066'' (proximal) to 0.050'' (distal). It has five different working lengths: 120 cm, 133 cm, 145 cm, 153 cm, and 160 cm. The device is supplied as a kit with the Wallaby Aspiration Tubing Set provided with a single catheter. The distal tip of each catheter is visible under fluoroscopy and the distal shaft of each catheter is designed with an external hydrophilic coating to reduce friction during use. The proximal end of each catheter incorporates a strain relief and a standard luer adapter to facilitate the attachment of accessories. Each catheter has a semi-rigid proximal shaft which transitions into a flexible distal shaft to facilitate the advancement of the catheter in tortuous anatomy.
The Esperance 3+ Aspiration Catheter System is a non-active, surgically invasive device intended for short term use within the neurovasculature.
The document provided is a 510(k) premarket notification decision letter from the FDA for a medical device called the "Esperance 3+ Aspiration Catheter System." It primarily focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance data (bench testing and biocompatibility).
Based on the provided text, here's a breakdown of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The document lists various performance tests and their outcomes, all indicating that the device met the acceptance criteria. The specific numerical acceptance criteria themselves are not detailed in this public FDA letter, but the conclusion for each test is consistently "All samples met the acceptance criteria" or similar.
Test Category | Test Name | Test Method Summary | Reported Device Performance/Conclusion |
---|---|---|---|
Biocompatibility | Cytotoxicity (ISO 10993-5) | MTT- L929 Cytotoxicity Study; ISO MEM elution- L929 | No cytotoxic effect. |
Skin Irritation (ISO 10993-10) | ISO Intracutaneous Irritation | No sensitization indicated. | |
Sensitization (ISO 10993-10) | ISO Guinea Pig Maximization Sensitization | No sensitization indicated. | |
Systemic Toxicity (ISO 10993-11) | ISO Acute Systemic Toxicity; ISO Material Mediated Rabbit Pyrogen (GLP); Systemic Toxicity - Acute Systemic Injection | No acute systemic toxicity indicated. Esperance 3+ Aspiration Catheter is deemed non-pyrogenic. Test articles are deemed non-pyrogenic (for Introducer Sheath). RHV is deemed non-pyrogenic (for Rotating Hemostasis Valve). | |
Hemocompatibility (ISO 10993-4) | Hemolysis (ASTM method) Indirect Extract; ASTM Hemolysis - Direct Contact and Extract Method (GLP); Complement Activation; Thromboresistance Evaluation; Partial Thromboplastin Time | No hemolysis indicated. Esperance 3+ Aspiration Catheter is deemed comparable to predicate (for Complement Activation, Thromboresistance Evaluation, Partial Thromboplastin Time). | |
Sterilization | Sterility Assurance Level (SAL) | Sterilization cycle verified to ensure a SAL of 10^-6 per EN ISO 11135:2014 and AAMI TIR28:2009. Validated via the half cycle method. | Met the SAL of 10^-6. |
Shelf Life | Accelerated Aging (AA) | Testing on devices subjected to AA process to represent 1 year of aged units. Aging studies for packaging integrity, seal strength, and device functionality. | Design and performance specification requirements were met after one year shelf life. Catheters and packaging remain functional for the labeled use by date. All acceptance criteria met. |
Non-Clinical Bench | Dimensional Verification | Dimensions of the catheter and introducer sheath are measured. | All samples met the acceptance criteria. |
Navigability | Device tested for its ability to reach target site in an anatomical model in comparison to the predicate. | All samples met the acceptance criteria. | |
Clot Removal | Subject device tested for its ability to aspirate clots in an anatomical model in comparison to the predicate. | All samples met the acceptance criteria. | |
Kink Resistance | Catheter tested at different locations for its ability to bend to clinically relevant radii without kinking in comparison to predicate. | All samples met the acceptance criteria. | |
Lubricity | Catheter's hydrophilic coating lubricity tested by applying force to the coated section and measuring frictional force in comparison to the predicate. | All samples met the acceptance criteria. | |
Coating Integrity | Coated length of the catheter inspected for defects post simulated use in comparison to the predicate. | All samples met the acceptance criteria. | |
Torque Strength | Catheter and predicate evaluated for torque strength by rotating the test sample within an anatomical model until failure while the distal tip was not free to rotate. | All samples met the acceptance criteria. | |
Delivery and Retrieval Force | Subject device tested for its ability to reach and be retracted from a target site in an anatomical model with application of force below a specified value. Compared to predicate device. | All samples met the acceptance criteria. | |
Vacuum Resistance | Device tested for its ability to withstand a specified vacuum pressure for a specified time without damage, lumen collapse, or kink. | All samples met the acceptance criteria. | |
Aspiration Flow Rate | Aspiration flow rate of the subject device at a specified vacuum pressure measured in comparison to the predicate. | All samples met the acceptance criteria. | |
Elongation to Failure | Catheter elongation at break obtained from the shaft tensile testing data. | All samples met the acceptance criteria. | |
Tip Stiffness | Catheter tip tested by bending in a test fixture and measuring the maximum load that caused deflection. Compared to the predicate. | All samples met the acceptance criteria. | |
Atraumatic Distal Tip | Catheter tip inspected for smoothness. | All samples met the acceptance criteria. | |
Tip Shaping Ability | Distal tip shaped using the shaping mandrel supplied and assessed for damage and ability to hold tip shape. | All samples met the acceptance criteria. | |
Introducer Sheath Compatibility | Supplied introducer sheath tested for compatibility with the Esperance 3+ Aspiration Catheter System. | All samples met the acceptance criteria. | |
Device Compatibility | Appropriately sized guidewire delivered and retrieved through the catheter. Catheter delivered and retrieved through an appropriately sized sheath. | All samples met the acceptance criteria. | |
Surface Defects | Catheter and introducer sheath examined under magnification for extraneous matter. | All samples met the acceptance criteria. | |
Tensile Force | Peak tensile force of the subject catheter measured at different locations in comparison to the predicate. | All samples met the acceptance criteria. | |
Liquid Leakage | Subject catheter tested for leakage per ISO 10555-1 and compared to the reference device. | All samples met the acceptance criteria. | |
Air Leak | Subject catheter tested for air leakage per ISO 10555-1 and compared to the reference device. | All samples met the acceptance criteria. | |
Static Burst | Subject catheter tested to withstand a specified static pressure. | All samples met the acceptance criteria. | |
Power Injection | Distal tip of the catheter blocked, and fluid injected into the lumen using a power injector until the catheter burst. | All samples met the acceptance criteria. | |
Corrosion | Subject device visually inspected for signs of corrosion post exposure to required conditions per ISO 10555-1. | All samples met the acceptance criteria. | |
Particulate Testing | Size and number of particulates generated during simulated use of the device in a neurovascular model were measured and calculated. Particulate generation compared to the reference device. | Particulate generation was similar between the subject and reference device. | |
Hub/Luer Fitting | Catheter hub tested as per ISO 80369-7. | All samples met the acceptance criteria. |
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 dedicates a section to "PERFORMANCE TESTING - BENCH" and concludes most tests with "All samples met the acceptance criteria." However, it does not specify the sample size used for each of these non-clinical tests.
The data provenance is through non-clinical bench testing performed by the manufacturer, Wallaby Medical. There's no information about the country of origin of the data within the document, beyond the sterilization facility being in "Suzhou) Ltd., Jiangsu, China." The nature of the tests (bench testing, biocompatibility, sterilization, shelf life) indicates these are prospective tests performed specifically for this submission, rather than retrospective analysis of existing data.
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)
This section is not applicable as the document describes non-clinical bench performance testing, not a clinical study involving human or image-based data that would require expert ground truth labeling. The "ground truth" for these tests is based on objective measurements and established engineering standards (e.g., ISO, ASTM).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable as the document describes non-clinical bench performance testing where adjudication methods typical for clinical or image-based studies are not relevant.
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
No MRMC comparative effectiveness study was done or reported. The device is a medical catheter and not an AI/imaging algorithm that would typically involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device is a physical medical catheter, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical tests described, the "ground truth" is based on:
- Engineering specifications and standards: Adherence to ISO standards (e.g., ISO 10993 for biocompatibility, ISO 11135 for sterilization, ISO 10555-1 and 80369 for bench tests) and relevant FDA guidance documents.
- Objective measurements: Dimensional verification, force measurements, flow rates, visual inspections for defects, etc.
- Comparison to predicate/reference device: Many tests involved comparing the subject device's performance (e.g., navigability, clot removal, lubricity, particulate generation) to the predicate or reference device to establish similarity and ensure similar safety and effectiveness profiles.
8. The sample size for the training set
This is not applicable. The document describes the testing of a physical medical device, not an AI or machine learning model that would require a training set.
9. How the ground truth for the training set was established
This is not applicable for the same reason as point 8.
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(330 days)
The Esperance Distal Access Catheter is indicated for the introduction of interventional devices into the peripheral and neuro vasculature.
The Esperance® Distal Access Catheter is a single-use, single lumen, variable stiffness, composite catheter. The device includes 5F and 6F catheters with inner diameters of 0.055" and 0.071", respectively, designed with three different working lengths for both sizes: 115 cm, and 131 cm. The device is supplied with a peelable introducer and shaping mandrel. The distal tip of each catheter is visible under fluoroscopy and the distal shaft of each catheter is designed with an external hydrophilic coating to reduce friction during use. The proximal end of each catheter incorporates a strain relief and a standard Luer adapter to facilitate the attachment of accessories. Each catheter has a semi-rigid proximal shaft which transitions into a flexible distal shaft to facilitate the advancement of the catheter in tortuous anatomy.
The Esperance® Distal Access Catheter is a non-active, surgically invasive device intended for short term use within the vasculature.
The provided document is a 510(k) Substantial Equivalence Determination letter from the FDA for a medical device called the "Esperance Distal Access Catheter." It details non-clinical performance testing but does not include information about a study proving device performance against acceptance criteria in the context of an AI/ML-driven device or human-in-the-loop performance.
Specifically, the document states:
- "Animal data were not deemed necessary as substantial equivalence was established based upon successful completion of non-clinical bench testing."
- "A clinical study was not deemed necessary as substantial equivalence was established based upon successful completion of non-clinical bench testing."
Therefore, I cannot extract the requested information points related to a study proving the device meets acceptance criteria for an AI/ML device, as such a study was not performed or detailed in this submission. The tests listed are primarily engineering bench tests for a physical catheter, not AI model validation.
However, I can extract the acceptance criteria for the physical device's performance from the "NON-CLINICAL PERFORMANCE DATA" section.
Here's what I can provide based on the document:
1. A table of acceptance criteria and the reported device performance (for non-clinical bench tests):
Test | Acceptance Criteria (Implied / Stated) | Reported Device Performance |
---|---|---|
Visual Inspection* | Requirements were met. | The device met all pre-defined acceptance criteria. |
Dimensional Inspection* (ID, OD, Overall Length, Working Length, Coating Length, Distal Tip to Marker Band, Hub/Strain Relief Length) | Requirements were met. | The device met all pre-defined acceptance criteria. |
Simulated Use | Performs as intended, meets pre-defined acceptance criteria for: preparation/ease of assembly, introducer sheath interaction, introducer peel away, compatibility with guidewire/microcatheter, lubricity and durability of hydrophilic coating, and kink resistance. | Device performs as intended and met all pre-defined acceptance criteria under simulated use conditions. (Supplemented by additional testing beyond reference device, K211697) |
Physician Validation* | Performs as intended under simulated use conditions. | Device performs as intended under simulated use conditions. |
Delivery and Retrieval Forces | Meets pre-defined acceptance criteria in a vascular model under simulated use conditions. | Met all pre-defined acceptance criteria. (Supplemented by additional testing beyond reference device, K211697) |
Tip Stiffness* | Meets acceptance criteria when deflected on a universal testing machine. | Met acceptance criteria. |
Tip Shaping* | Meets pre-defined acceptance criteria when shaped with shaping mandrel and steam. | Met the pre-defined acceptance criteria. |
System Tensile* (Hub, Shaft, Tip) | Meets the minimum tensile requirement. | The device met all predefined acceptance criteria. |
Elongation to Failure* | Met all pre-defined acceptance criteria, obtained from shaft tensile testing data. | The device met all pre-defined acceptance criteria. |
Torque Strength* | Meets the predefined acceptance criteria in a vascular model. | Met the predefined acceptance criteria. |
Coating Integrity (after particulate testing) | Meets all pre-defined acceptance criteria (inspected pre- and post-insertion and retrieval through a vascular model). | The device coating integrity was inspected pre- and post-insertion and retrieval through a vascular model and met all pre-defined acceptance criteria. (Supplemented by additional testing beyond reference device, K211697) |
Coating Lubricity* | Meets all pre-defined acceptance criteria from frictional forces on a universal testing machine. | Met all pre-defined acceptance criteria. |
Catheter Burst, Leak (Liquid and Air) | Does not leak, burst, and is compatible with accessories per ISO 10555-1 and meets acceptance criteria. | Met acceptance criteria. (Supplemented by additional testing beyond reference device, K211697) |
Kink Resistance* | Meets acceptance criteria for resistance to kinking around bends with clinically relevant radii. | Met acceptance criteria. |
Particulate | Any particulate generated is comparable to cleared comparator devices and meets acceptance criteria. | The device met acceptance criteria. (Supplemented by additional testing beyond reference device, K211697) |
Corrosion Resistance* | Is corrosion resistant per ISO 10555-1. | The catheter is corrosion resistant per ISO 10555-1. |
Radiopacity* | Meets the pre-defined acceptance criteria for marker band visibility under fluoroscopy. | Met the pre-defined acceptance criteria. |
Luer Hub Testing* | Meets the pre-defined specifications per ISO 80369-7 and ISO 80369-20. | Met the pre-defined specifications. |
For the remaining points, the document explicitly states that clinical or animal studies were not deemed necessary beyond the non-clinical bench testing for this specific device (a physical catheter). Therefore, the following information cannot be provided from the given text:
- Sample sized used for the test set and the data provenance: Not applicable for an AI/ML context, as no such test set was described. Bench tests were performed on physical units, but specific sample sizes for each test are not listed.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI/ML system is not relevant to this physical device's non-clinical bench testing. "Physician Validation" was mentioned, but no details on the number or qualifications of physicians, nor their role in establishing a ground truth for an AI system.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
- 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, as this is not an AI-assisted device.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable, as this is not an algorithm.
- The type of ground truth used (expert concensus, pathology, outcomes data, etc): Not applicable for an AI/ML system. Ground truth in this context would refer to the reference standards for the physical tests (e.g., precise measurements, material specifications, functional performance during simulated use).
- The sample size for the training set: Not applicable, as there is no AI/ML training set.
- How the ground truth for the training set was established: Not applicable, as there is no AI/ML training set.
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