K113757 · Control Medical Technology, LLC · QEZ · Feb 22, 2012 · Cardiovascular
Device Facts
Record ID
K113757
Device Name
ASPIRE MAX ASPIRATION CATHETER
Applicant
Control Medical Technology, LLC
Product Code
QEZ · Cardiovascular
Decision Date
Feb 22, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.5150
Device Class
Class 2
Attributes
Therapeutic, 3rd-Party Reviewed
Indications for Use
The Aspire MAX 5 and MAX 6 Aspiration Catheters and Aspirator are indicated for the removal of fresh, soft emboli and thrombi from vessels in the peripheral vasculature. Aspire MAX Aspiration Catheters are single-use devices intended for use by physician's experienced and trained in diagnostic and interventional procedures. Techniques for placement of vascular sheaths, catheters, and guidewires may be used.
Device Story
Single-use aspiration catheter system; includes catheter and 30ml manual piston syringe. Used by interventional physicians in clinical settings to remove fresh, soft thrombi/emboli from peripheral vasculature. Device inserted over guidewire through sheath/guide catheter to target site; manual aspiration created via piston syringe. Provides mechanical removal of obstructions; benefits patient by restoring blood flow. Materials include stainless steel braid, Pebax/Vestamid shafts, polycarbonate luer lock, and platinum-iridium radiopaque marker. No electronic or software components.
Clinical Evidence
No clinical data. Bench testing only. Testing included mold validation, tensile strength, leakage (positive pressure/vacuum), vacuum collapse, tracking, torque, kink resistance, radiopaque visibility, and aspiration performance using various viscosity aspirants. Biocompatibility testing performed per ISO 10993.
Technological Characteristics
Intravascular catheter; stainless steel braid, Pebax/Vestamid shafts, polycarbonate luer lock, platinum-iridium radiopaque marker. Manual piston syringe operation. ISO 10555-1, ISO 7886-1, ISO 10993, AAMI/ANSI/ISO 11135 compliance. Ethylene oxide sterilization. No software or electronic components.
Indications for Use
Indicated for removal of fresh, soft emboli and thrombi from peripheral vasculature. Contraindicated for fibrous, adherent, or calcified material (chronic clot/atherosclerotic plaque), neurovascular use, and vessels <2.0mm (MAX 5) or <2.5mm (MAX 6) diameter.
Regulatory Classification
Identification
An embolectomy catheter is a balloon-tipped catheter that is used to remove thromboemboli, i.e., blood clots which have migrated in blood vessels from one site in the vascular tree to another.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
February 8, 2021
Control Medical Technology, LLC % Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1000 Westgate Drive, Saint Paul. Minnesota 55114
Re: K113757
Trade/Device Name: Aspire MAX Aspiration Catheter Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: OEZ
Dear Mark Job:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated February 22, 2012. Specifically, FDA is updating this SE Letter as an administrative correction because FDA has created a new product code to better categorize your device technology.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Gregory O'Connell, OHT2: Office of Cardiovascular Devices, (301) 796-6075, Gregory. Oconnell(@FDA.HHS.gov.
Sincerely,
Digitally signed by Gregory W. Gregory W. O'connell -S O'connell -S Date: 2021.02.08 08:17:06 -05'00'
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/1/Picture/1 description: The image contains the text 'Public Health Service'. The text is written in a simple, sans-serif font. The words are arranged horizontally, with 'Public' on the first line, 'Health' on the second line, and 'Service' on the third line.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
FEB 2 2 2012
Control Medical Technology c/o Mark Job Responsible Third Party Official Regulatory Technical Services LLC 1394 25th Street NW Buffalo, MN 55313
Re: K113757
Trade/Device Name: Aspire MAX Aspiration Catheters (MAX 5 and MAX 6) Regulation Number: 21 CFR 870.5150 · Regulation Name: Embolectomy Catheter Regulatory Class: Class II Product Code: DXE Dated: December 20, 2011 Received: December 21, 2011
Dear Mr. Job:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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#### Page 2 - Mr. Mark Job
Please be advised that FDA's issuance of a substantial equivalence determination does not mean I hat FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must or any I ederal state Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please n you active you.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# 4. Indication for Use Statement
510(k) Number:
113757
Device Name:
Aspire MAX Aspiration Catheter
Indications for Use:
The Aspire MAX 5 and MAX 6 Aspiration Catheters and Aspirator are indicated for the removal of fresh, soft emboli and thrombi from vessels in the peripheral vasculature.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use _ (21 CFR 807 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED
Concurrence of CDRH, Office of Device Evaluation (ODE)
C
(Division Sicin-Off Division of Cardiovascular Devices 510(k) Number
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# 5. 510(k) Summary
In accordance with the Safe Medical Devices Act (SMDA) of 1990 and Title of the Code of Federal Regulations Part 807 (21 CFR §807), and in particular §807.92, the following summary of safety and effectiveness information is provided.
### Date Summary was Prepared
November 4, 2011
### Submitter
Control Medical Technology 136 Heber Avenue, Suite 101 PO Box 681013 Park City, UT 84068 Phone (954) 534-9345
### FDA Establishment Registration Number
3007282893
### Contact
President Control Medical Technology 136 Heber Avenue, Suite 101 PO Box 681013 Park City, UT 84068 Phone (954) 534-9345
### Device Information
| Trade Name: | |
|----------------------|--|
| Common Name: | |
| Classification Name: | |
| Product Code: | |
| Regulation: | |
Aspire MAX Aspiration Catheter Embolectomy or aspiration catheter and piston syringe Embolectomy catheter DXE Class II, 21 CFR 870.5150
### Predicate Devices
Aspire Max Aspiration Catheters are substantially equivalent to the Medtronic Export Aspiration Catheters, Vascular Solutions Pronto Extraction Catheters, Lumen - Volcano Xtract Aspiration Catheters, and other predicate devices.
| Trade Names: | Export XT Aspiration Catheters K061958 September 5, 2006<br>Pronto Short Aspiration Catheter K051193 August 8, 2005<br>Pronto V3 Aspiration Catheter K063371 Mar 30, 2009<br>Xtract Aspiration Catheters K071529 August 10, 2007<br>Xtract Aspiration Catheter K080901 October 2, 2008 |
|----------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Embolectomy or aspiration catheter and piston syringe |
| Classification Name: | Embolectomy catheter |
| Product Code: | DXE |
| Regulation: | Class II, 21 CFR 870.5150 |
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# Device Description
Aspire MAX 5 Aspiration Catheter (MAX 5 Aspiration Catheter and Aspire Aspirator) Aspire MAX 6 Aspiration Catheter (MAX 6 Aspiration Catheter and Aspire Aspirator) Aspire Aspirator 30ml
An Aspire MAX Aspiration Catheter includes (1) Aspire MAX 6 Aspiration Catheter and (1) Aspirator 30ml. Aspire MAX Aspiration Catheters and MAX Aspiration Catheters are single-use, sterile, short-term use, and non-pyrogenic medical devices designed for use with manually operated piston svringes to remove fresh, soft emboli and thrombi from the peripheral and coronary vasculature. The Aspire MAX Aspiration Catheter operating and scientific principle is the same as predicate devices. The catheter is inserted into the body over a guidewire and through a sheath or guide catheter to the target anatomy. A piston syringe is then connected to the catheter and the aspiration is manually created with the piston syringe.
Similar to predicate devices, industry standard intravascular catheter components and materials are used:
- Clear proximal polycarbonate female luer lock, -
- -Stainless steel braid,
- Clear Pebax and Vestamid Shafts, -
- -Embedded platinum iridium radiopaque marker,
- Clear polycarbonate barrel piston syringe. -
Aspire MAX Aspiration Catheters do not add any new materials, manufacturing processes, colorants, or dyes to the manufacturing process.
Same as predicates, all MAX Aspiration Catheters may be connected to piston syringes including the Aspire Aspirator. Aspirators may be connected to other aspiration catheters.
# Indications, Intended Use and Contraindications
Indication: The Aspire MAX 6 Aspiration Catheters and Aspirator are indicated for the removal of fresh, soft emboli and thrombi from vessels in the peripheral vasculature.
Intended Use: Aspire MAX Aspiration Catheters are single-use devices intended for use by physician's experienced and trained in diagnostic and interventional procedures. Techniques for placement of vascular sheaths, catheters, and guidewires may be used.
Contraindications: The removal of fibrous, adherent or calcified material (e.g., chronic clot and atherosclerotic plaque), neurovascular use, and vessels <2.0mm diameter for the Aspire MAX 5 Aspiration Catheter and <2.5mm diameter for the Aspire MAX 6 Aspiration Catheter.
The indication and intended use is substantially equivalent other thrombus aspiration catheters manually actuated by syringes and legally marketed under the DXE product code.
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#### Comparison to Predicate Devices
Aspire MAX Aspiration Catheters and Aspirator are substantially equivalent to predicate catheters used to remove fresh, soft thrombi/emboli. Substantial equivalence is based on equivalence in:
| Science | Mechanism of Use |
|-----------------------------------|----------------------------------|
| Scientific Principle | |
| Device Construction | Manual Use |
| Design & Dimensions | Piston Syringe Driven Aspiration |
| Function | Manufacturing |
| Materials | |
| Device Performance | Bend & Torque |
| Aspiration | Tracking |
| Break strength integrity | Freedom from Leakage Aspiration |
| Freedom of Leakage Injection | |
| Labeling | Contraindications |
| Indication for Use & Intended Use | Instructions for Use |
| Warnings | |
Manufacturing ISO 10993 Biocompatibility
Sterilization
New device is compared to predicate device? Yes, the Aspiration Catheter is compared to the predicates against predetermined metrics and performance test criteria.
Does the new device have the same indication for use as predicate device? Yes.
Do the differences between the new device and predicate alter the intended therapeutic or diagnostic effect as predicate device? No, the differences between the Aspire MAX Aspiration Catheter and predicates do not alter the intended use of the device.
Does the new device have the same technical characteristics, manufacturing processes as predicate? Yes, the Aspiration Catheter's manually operated aspiration principle of operation and technical characteristics are the same as predicates. Aspire MAX Aspiration Catheters and piston syringe materials including but not limited to Pebax and Vestamid shafts; 304 stainless steel wire braiding; luer lock hubs; and polycarbonate piston syringe barrels the same as predicates. Manufacturing extrusion, molding, and assembly in ISO 14644 Class 8 certified clean room is the same as predicates. No new materials or manufacturing processes.
### Could the new characteristics affect safety? No.
Do new characteristics raise new types of safety and effectiveness questions? No.
### Do accepted scientific methods exist for assessing effects of new characteristics? Yes, testing was based on FDA recognized standards and guidance including but not limited to:
- ISO 10555-1:1997 Sterile, Single-Use, Intravascular Catheters.
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- ISO 7886-1:1993(E) Sterile Hypodermic Syringe s for Single Use. رت
- -AAMI/ANSI/ISO 11135:1994 Medical Devices - Validation and Routine Control of Ethylene Oxide Sterilization.
- ISO 10993 Biological Evaluation of Medical Devices. 集
- FDA's Required Biocompatibility Training and Toxicology Profiles for Evaluation of Medical 1 Device, May 1, 1995 (G95-1)," U.S. Food and Drug Administration, Center for Devices and Radiological Health, May 1995, attachment C Biocompatibility Flow Chart for the Selection of Toxicity Test for 510(k)s.
# Non-Clinical Testing
Non-clinical testing confirms the Aspiration Catheters and Aspirator passes all testing and meets specifications. Specific tests confirm functionality in the intended use, safety, demonstration of claims, and equivalence to predicate devices plus compliance with ISO recognized standards.
- A. General:
- -Mold validation.
- -Visual inspection pre-packaging,
- Package sealer validation, .
- Tyvek seal test. .
- Packaging and shipping test, -
- Packaging visual appearance. .
- Label integrity and legibility, .
- B. Integrity and compatibility:
- Particulate testing, -
- -Catheter corrosion resistance,
- Catheter body tensile strength integrity, =
- Catheter body to hub tensile strength integrity, _
- -Catheter tip attachment strength,
- Catheter leakage at hub integrity positive pressure, -
- Catheter leakage at hub integrity vacuum, .
- Catheter vacuum collapse integrity, .
- Catheter tracking test, .
- . Catheter torque,
- Catheter kink resistance, -
- Catheter radiopaque visibility. -
- Guidewire interface, .
- Guidecath interface, =
- Sheath interface, .
- Pulsed aspiration integrity tests, .
- . Aspiration fatigue integrity,
- C. Aspiration:
- MAX Aspiration Catheters and predicates with standard syringes and aspirators . with low viscosity aspirants,
- MAX Aspiration Catheters and predicates with standard syringes and aspirators س with high viscosity Newtonian aspirants,
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- MAX Aspiration Catheters and predicates with standard syringes and aspirators . with high viscosity Non-Newtonian aspirants,
- = Thrombus aspiration,
- In-vivo aspiration. -
- Biocompatibility: Compliance with "Required Biocompatibility Training and Toxicology Profiles for Evaluation of Medical Device, May 1, 1995 (G95-1)," U.S. Food and Drug Administration, Center for Devices and Radiological Health. May 1995, attachment C Biocompatibility Flow Chart for the Selection of Toxicity Test for 510(k)s and ISO 10993. Subject devices passed all biocompatible tests performed by Ethox and Nelson Labs.
- Particulate testing include validated light obscuration method and direct visualization tests. Subject = devices passed with scores significantly below an established minimum national standard.
#### Clinical testing
Not applicable.
### Statement of Equivalence
Aspire MAX Aspiration Catheters are substantially equivalent to the currently marketed Pronto, Export, and Xtract aspiration systems based on comparison of the device classification, basic operating principle, indication for use, intended use, technical characteristics, packaging, and sterilization methods.
#### Conclusion
Aspire MAX Aspiration Catheters are substantially equivalent to the currently marketed Pronto, Export, and Xtract catheters based on comparison of the device classification, basic operating principle, indication for use, intended use, technical characteristics, packaging, and sterilization methods. Testing confirms the suitability of Aspire MAX Aspiration Catheters and Aspirator for its intended use.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.