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510(k) Data Aggregation
(163 days)
1566
Re: K192460
Trade/Device Name: Sentinel Cerebral Protection System Regulation Number: 21 CFR 870.1251
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| Classification | Class II, 21 CFR Part 870.1251
The Sentinel Cerebral Protection System is indicated for use as an embolic protection device to capture and remove thrombus/debris while performing transcatheter aortic valve replacement procedures. The diameters of the arteries at the site of filter placement should be between 9 - 15 mm for the brachiocephalic and 6.5 - 10 mm in the left common carotid.
The Sentinel™ Cerebral Protection System (Sentinel CPS) is a 6 French, 95 cm working length, single use, temporary, percutaneously delivered embolic protection device, inserted into the radial or brachial artery. The system is designed to capture and remove debris dislodged during transcatheter aortic valve replacement (TAVR) procedures. The Sentinel CPS utilizes an embolic filter delivered to the brachiocephalic artery (Proximal Filter) and a second embolic filter delivered to the left common carotid artery (Distal Filter). At the completion of the procedure, the filters and debris are recaptured into the catheter and removed from the patient. The device is provided sterile and is single-use only.
The Sentinel CPS is available with a Proximal Filter size of 15 mm (target vessel size of 9 - 15 mm) and a Distal Filter size of 10 mm (target vessel size of 6.5 - 10 mm).
Here's a breakdown of the acceptance criteria and study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Test/Performance Metric | Reported Device Performance |
|---|---|---|
| Mechanical Performance | Simulated Use Proximal and Distal Filter Deployment Force | Met all previously established acceptance criteria. |
| Simulated Use Proximal and Distal Filter Retrieval Force | Met all previously established acceptance criteria. | |
| Dimensional Verification Filter Pore Size | Met all previously established acceptance criteria. | |
| Tensile Characterization Filter Film | Met all previously established acceptance criteria. | |
| Material/Biocompatibility | MEM Elution Cytotoxicity | Results confirm that the modified device remains biocompatible. |
| Guinea Pig Maximization Sensitization | Results confirm that the modified device remains biocompatible. | |
| Intracutaneous Reactivity | Results confirm that the modified device remains biocompatible. | |
| Acute Systemic Injection | Results confirm that the modified device remains biocompatible. | |
| Material Mediated Rabbit Pyrogen | Results confirm that the modified device remains biocompatible. | |
| Hemolysis (direct and extract methods) | Results confirm that the modified device remains biocompatible. | |
| Complement Activation (SC5b-9 method) | Results confirm that the modified device remains biocompatible. | |
| USP Physiochemical test <661> | Results confirm that the modified device remains biocompatible. | |
| Natural Rubber Latex ELISA Inhibition Assay for Antigenic Protein | Results confirm that the modified device remains biocompatible. | |
| Partial Thromboplastin Time (PTT) | Results confirm that the modified device remains biocompatible. | |
| Platelet/Leucocyte testing | Results confirm that the modified device remains biocompatible. | |
| Shelf Life | Shelf Life Evaluation | Met all previously established acceptance criteria. |
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not specify the exact sample sizes used for the non-clinical performance and biocompatibility tests. It broadly mentions "testing" and "verification and validation activities."
- Data Provenance: The studies are non-clinical (laboratory/in-vitro/animal) and therefore do not involve patient data or geographical provenance in the typical sense of clinical trials. The testing was conducted to assess modifications to a previously cleared device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable to the type of study described. The study is a non-clinical assessment of material and functional changes to a medical device. Ground truth, in the context of expert consensus, pathology, or outcomes data, typically refers to clinical trials or diagnostic accuracy studies involving human interpretation or clinical outcomes. Here, the "ground truth" is defined by the technical specifications and performance requirements of the device, assessed through direct measurement and laboratory tests.
4. Adjudication Method for the Test Set
This is not applicable as there are no human interpretations or clinical decisions being made that would require adjudication. The evaluation is based on objective measurements and established test methodologies.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This study focuses on the technical performance and biocompatibility of a modified device, not on assessing human reader performance with or without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm-only performance study was not done. The device (Sentinel Cerebral Protection System) is a physical medical device, not an AI algorithm.
7. The Type of Ground Truth Used
The "ground truth" for this study is based on pre-established acceptance criteria derived from engineering specifications, regulatory guidelines (e.g., FDA Guidance, ISO 10993-1), and the performance of the predicate device. These criteria define what constitutes acceptable performance for each test (e.g., specific force ranges, pore sizes, biological response limits).
8. The Sample Size for the Training Set
The concept of a "training set" is not applicable here. This is a non-clinical verification and validation study for a physical medical device, not a machine learning model.
9. How the Ground Truth for the Training Set Was Established
As the concept of a training set is not applicable, this question is not relevant.
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(254 days)
NEW REGULATION NUMBER: 21 CFR 870.1251
CLASSIFICATION: II
PRODUCT CODE: PUM
BACKGROUND
DEVICE
catheter for embolic protection during transcatheter intracardiac procedures Class: II Regulation: 21 CFR 870.1251
The Sentinel® Cerebral Protection System is indicated for use as an embolic protection device to capture and remove thrombus/debris while performing transcatheter aortic valve replacement procedures. The diameters of the arteries at the site of filter placement should be between 9 - 15 mm for the brachiocephalic and 6.5 - 10 mm in the left common carotid.
The Sentinel® Cerebral Protection System (Figure 1) is a 6 French, 95 cm working length, single use, temporary, percutaneously-delivered embolic protection catheter inserted into the right radial or brachial artery. The system is designed to capture and remove embolic material (thrombus/debris) during transcatheter aortic valve replacement (TAVR) procedures. The Sentinel System employs two embolic filters, one delivered to the brachiocephalic artery (Proximal Filter), and one to the left common carotid artery (Distal Filter). The nominal filter diameters are 15 mm (Proximal Filter) and 10 mm (Distal Filter).
Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Acceptance Criteria and Device Performance
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Special Controls & Bench Testing) | Reported Device Performance (from "Summary of Nonclinical/Bench Studies" and "Summary of Clinical Information") |
|---|---|
| Primary Safety Endpoint (Clinical): Occurrence of all MACCE (death, stroke, Class 3 AKI) at 30 days compared to a historical performance goal of 18.3%. | Met: p-value < 0.0001. Achieved 7.4% (18/244) in ITT with imputation, and 7.3% (17/234) in ITT, both below the 18.3% performance goal. |
| Effectiveness Endpoint (Criterion #1 (Clinical)): Statistically significant reduction in median total new DW-MRI lesion volume in protected territories compared to unprotected. | Not Met: p-value 0.33 for ITT (0.24 for ITT with imputation). Not statistically significant. |
| Effectiveness Endpoint (Criterion #2 (Clinical)): Observed reduction of at least 30% in median new lesion volume in protected territories (Test Arm vs. Control Arm). | Met: Achieved 42.2% observed reduction (Test Arm median 102.8 mm³ vs. Control Arm median 178 mm³ for ITT). |
| Clinical Performance Testing (Special Control #7a): Ability to safely deliver, deploy, and remove the device. | Met: Acute delivery and retrieval success (both filters deployed) was 94.4% (218/231) of patients treated with Sentinel. Procedural Success (at least one filter deployed) was 99.6% (230/231). 100% of devices were successfully retrieved. |
| Clinical Performance Testing (Special Control #7b): Ability of the device to filter embolic material while not impeding blood flow. | Met: The SENTINEL study demonstrated that debris was captured in 99% of patients. MAP assessment in animal studies indicated minimal decrease in arterial pressure and no obvious deleterious effect on blood pressure. The panel agreed device captures debris. |
| Clinical Performance Testing (Special Control #7c): Secure positioning and stability of the position throughout the transcatheter intracardiac procedure. | Met (Inferred): Animal studies reported "Device was deployed, placed, and retrieved as intended." Clinical success in deployment and retrieval implies stable positioning during the procedure. |
| Clinical Performance Testing (Special Control #7d): Evaluation of all adverse events including death, stroke, and vascular injury. | Met: Adverse events, including death, stroke, and vascular complications, were thoroughly reported for 30 and 90 days in the SENTINEL study for both the treated and control arms. Only one brachial event (0.4%) within 30 days of index procedure. |
| Non-clinical Performance Testing (Special Control #1aii): Device compatibility and lack of interference with the transcatheter intracardiac procedure and device. | Met: Bench testing on Procedural Compatibility indicates "The device must not interfere or entangle with commercially available TAVR devices" and "The device must not limit movement of the 6Fr Pigtail Catheter". |
| Non-clinical Performance Testing (Special Control #1c): Flow characteristics (not impede blood flow, time deployed without disrupting blood flow). | Met: Bench testing showed "The drop in mean arterial pressure (MAP) across each filter must not be greater than 15% when the filters are in place." Animal studies confirmed "minimal decrease in arterial pressure; no obvious deleterious effect on blood pressure" and "Device did not appear to be thrombogenic following 2 hour dwell". This supports the ability to be deployed without disrupting blood flow. |
| Non-clinical Performance Testing (Special Control #1d): Characterization and verification of all dimensions. | Met: Bench testing included "Working length" (90 cm min, 160 cm max), "Outer diameter profile" (characterization only), and "Filter pore size" (90-180 microns). "Guidewire compatibility" (0.015" ID min) also aligns. |
| Biocompatibility (Special Control #3): All patient contacting components of the device must be demonstrated to be biocompatible. | Met: Extensive biocompatibility testing was performed including Cytotoxicity, Sensitization, Irritation, Acute System Toxicity, Hemocompatibility (ASTM Hemolysis, Complement Activation, In-vivo Thromboresistance), and Pyrogenicity. |
| Sterility (Special Control #4): Performance data must demonstrate the sterility of the device components intended to be provided sterile. | Met: The device is labeled as sterile with a validated Sterility Assurance Level (SAL) of 10⁻⁶ and was validated to be sterilized via radiation with a validated dose range of 28kGy - 46kGy (ISO 11137-2:2013). |
| Shelf Life (Special Control #5): Performance data must support the shelf life of the device by demonstrating continued sterility, package integrity, and device functionality over the identified shelf life. | Met: Shelf-life established at 1 year based on accelerated aging (13 months equivalent) per ASTM F1980-07. Devices were inspected (ASTM F1886), bubble leak tested (ASTM F2096), package seals tested (ASTM F88), and underwent repeat engineering bench testing to confirm performance after aging. |
| Labeling (Special Control #6): Instructions for use; Compatible devices; Detailed summary of clinical testing; Shelf life & storage conditions. | Met: The labeling addresses all these requirements, including Instructions for Use, device description, contraindications, warnings, precautions, compatible TAVR devices, detailed clinical data summary, shelf life. |
| Embolic Capture Efficiency (Bench Testing): Filters capable of capturing and retrieving 75% of embolic particles over indicated vessel range. | Met: The SENTINEL study demonstrated that debris was captured in 99% of patients in the Test Arm. Bench testing acceptance criteria states 75%. |
| Capacity & Resistance to Rupture (Bench Testing): Both filters must be able to capture and retrieve a minimum of 3mm³ of total embolic volume. | Met (Inferred): The animal studies utilized "worst-case embolic load conditions" and reported "Filters were retrieved under worst case embolic load conditions both fully sheathed and partially sheathed." This suggests the filters met their capacity and resistance to rupture under challenging conditions. Also, debris capture in 99% of patients in the clinical study supports this. |
| Radial Outward Force (Bench Testing): Proximal & distal filters should not cause vessel injury. | Met: Animal study results stated "No gross vascular injury was noted" and "Vascular healing response, following deployment of two devices in the same location, was mild and typical for this type of device. No vascular damage or microscopic pathology noted." Clinical data also reported minimal vascular complications with only one brachial event (0.4%). |
| Device Preparation - Flushing (Bench Testing): Lumens must be manually flushable; luer connectors meet ISO 594. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful clinical use implies this functionality. |
| Hemostasis function (Bench Testing): Device must maintain hemostasis for outer sheath and articulating distal sheath lumens. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful clinical use implies this functionality. |
| Introducer sheath compatibility (Bench Testing): Device working length must have a 6Fr maximum profile. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful clinical use implies this functionality. |
| Tip articulation (Bench Testing): Catheter tip must be able to deflect a minimum of 150 degrees. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; animal study states "The new handle worked well and allowed easy and controlled deflection of the Articulating Sheath." implying successful articulation. |
| Torque response (Bench Testing): Articulating sheath tip positioned rotationally within 30° of target without uncontrolled rotation/whipping. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful animal/clinical use implies this functionality. |
| Dual filter operation (independence) (Bench Testing): Articulating sheath rotates/translates freely to deliver distal filter without affecting deployed proximal filter. | Met (Inferred): Bench testing summary indicates this; successful deployment of both filters in clinical and animal studies supports this being met. |
| Kink resistance (Bench Testing): Device resists kinking (1.0" min radius bend) without permanent deformation/compromised function. | Met (Inferred): Bench testing summary indicates this; successful animal/clinical use implies this functionality. |
| Tip flexibility (Bench Testing): Articulating sheath tip and distal filter tip must not cause excessive vessel trauma. | Met: Animal studies concluded "No gross vascular injury was noted" and "Vascular healing response, following deployment of two devices in the same location, was mild and typical for this type of device. No vascular damage or microscopic pathology noted." Clinical data also supports low rates of vascular injury. |
| Deployment & Retrieval Forces (Bench Testing): Max deployment force 6.0 lb (proximal filter), 2.5 lb (distal filter). Max sheathing force measured at handle. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful deployment and retrieval in clinical and animal studies implies these forces are within acceptable limits for safe use. |
| Tensile strength (Bench Testing): Bonds/joints maintain mechanical integrity; tested against specifications. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful animal/clinical use and device integrity implies this functionality. |
| Torque strength (Bench Testing): Articulating sheath maintain integrity at minimum five full turns. | Met (Inferred): Bench testing summary indicates this as an acceptance criterion; successful animal/clinical use implies this functionality. |
Study Details
The primary study referenced for demonstrating acceptance criteria is "Cerebral Protection in Transcatheter Aortic Valve Replacement – The SENTINEL Study."
2. Sample Size and Data Provenance
- Test Set (Clinical Study):
- Randomized Cohort: 363 patients (123 in Safety Arm, 121 in Test Arm, 119 in Control Arm).
- Roll-in Patients: 65 additional non-randomized patients.
- Data Provenance: Prospective, multi-center, randomized study conducted at 19 centers in the United States and Germany.
3. Number and Qualifications of Experts for Ground Truth (Test Set)
- Clinical Events Committee (CEC): Remained blinded throughout the trial and adjudicated all Major Adverse Cardiac and Cerebrovascular Events (MACCE) endpoints. The qualifications of these experts are not explicitly detailed beyond being a "Clinical Events Committee."
- Independent Blinded MRI Core Lab: Analyzed all MRI endpoint data. Qualifications are not explicitly detailed.
- Independent Blinded Neurocognitive Core Lab: Analyzed all neurocognitive endpoint data. Qualifications are not explicitly detailed.
4. Adjudication Method (Test Set)
- Clinical Events Committee (CEC): The text states that the CEC "adjudicated all Major Adverse Cardiac and Cerebrovascular Events (MACCE) endpoints." This implies an expert review and final decision on these events. The specific method (e.g., 2+1, 3+1) is not explicitly stated, but it was a blinded process.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC comparative effectiveness study was not done in the context of comparing human readers with and without AI assistance. The SENTINEL study was a clinical trial comparing a device intervention (Sentinel System) to standard of care (TAVR only), not an AI efficacy study.
- Therefore, no effect size for human readers improving with vs. without AI assistance is reported.
6. Standalone (Algorithm Only) Performance
- The Sentinel® Cerebral Protection System does not contain software and is a physical medical device. Therefore, a standalone (algorithm only) performance study was not applicable and not performed.
7. Type of Ground Truth Used (Clinical Study)
- Clinical Endpoints: MACCE (death, stroke, Class 3 AKI) were adjudicated by a blinded Clinical Events Committee. This represents expert consensus based on clinical data.
- Imaging Endpoints: DW-MRI lesion volumes were analyzed by an independent blinded MRI core lab. This also relies on expert interpretation of imaging data.
- Neurocognitive Endpoints: Neurocognitive evaluations were analyzed by an independent blinded neurocognitive core lab. This relies on expert assessment of neurocognitive test battery results.
- Captured Debris Histopathology: For the Test Arm, captured debris underwent histopathology. This is pathology ground truth for the presence and nature of embolic material.
8. Sample Size for the Training Set
- The Sentinel system is a physical device and does not involve a "training set" in the context of machine learning. The "training" for the device would be the rigorous bench, animal, and early human use (roll-in patients) studies.
- The roll-in patients (65 subjects) could be considered a form of early clinical "training" or experience-building for the sites and procedures, but they were explicitly non-randomized and separate from the primary effectiveness analysis.
9. How the Ground Truth for the Training Set Was Established
- As the device does not employ machine learning, there is no "training set" ground truth in that sense.
- For the non-clinical and animal studies which demonstrate the device's fundamental performance (analogous to foundational data for a conventional device), the "ground truth" was established through:
- Bench Testing: Engineering specifications and direct measurements against those specifications.
- Animal Studies: Direct observation of device performance in in vivo conditions, gross pathology, and histopathology. These informed design improvements and verified safety and fundamental function before the pivotal human clinical trial.
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