K121832 · Merit Medical Systems, Inc. · FGE · Jul 17, 2012 · Gastroenterology, Urology
Device Facts
Record ID
K121832
Device Name
RESOLVE BILIARY LOCKING DRAINAGE CATHETER
Applicant
Merit Medical Systems, Inc.
Product Code
FGE · Gastroenterology, Urology
Decision Date
Jul 17, 2012
Decision
SESE
Submission Type
Special
Regulation
21 CFR 876.5010
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The ReSolve® Biliary Locking Drainage Catheter with locking pigtail and hydrophilic coating is used for drainage of bile within the biliary system.
Device Story
Single lumen thermoplastic biliary drainage catheter; features locking pigtail mechanism and hydrophilic coating. Includes metal/flexible stiffening cannulas, straightener, and repositioning tool for over-the-wire placement. Distal end contains 17-18 drainage holes; radiopaque marker band assists placement. Suture loop from hub to tip forms pigtail; hub locking mechanism secures shape. Repositioning tool allows unlocking for adjustment or replacement. Used by clinicians for biliary drainage; facilitates bile flow; reduces risk of catheter migration via locking pigtail.
Clinical Evidence
Bench testing only. No clinical data. Testing included dimensional analysis, drainage hole orientation, marker band location, tip penetration, hub leak, vacuum test, tubing kink test, hub/tubing tensile testing, material durability, bile exposure, and stiffening cannula friction. Biocompatibility testing performed per ISO 10993 standards (cytotoxicity, irritation, systemic toxicity, pyrogenicity, chemical characterization).
Technological Characteristics
Biocompatible thermoplastic catheter; single lumen; hydrophilic coating. Includes metal/flexible stiffening cannulas, straightener, and repositioning tool. Radiopaque marker band. Sterilized via ethylene oxide (ISO 11135-1). Complies with ISO 10993 (biocompatibility), EN 1617 (drainage catheters), ASTM D4169 (shipping), and ASTM F1980 (accelerated aging).
Indications for Use
Indicated for drainage of bile within the biliary system in patients requiring biliary drainage.
Regulatory Classification
Identification
A biliary catheter and accessories is a tubular flexible device used for temporary or prolonged drainage of the biliary tract, for splinting of the bile duct during healing, or for preventing stricture of the bile duct. This generic type of device may include a bile collecting bag that is attached to the biliary catheter by a connector and fastened to the patient with a strap.
Special Controls
*Classification.* Class II (special controls). The device, when it is a bile collecting bag or a surgical biliary catheter that does not include a balloon component, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.
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ReSolve® Biliary Locking Drainage Catheter
Section 5, 510(k) Summary Special Premarket Notification 510(k)
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K121832
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| Section 5 | | | JUL 17 |
|-----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|
| 510(k) Summary | | | |
| General<br>Provisions | Submitter Name:<br>Address:<br>Telephone Number:<br>Fax Number:<br>Contact Person:<br>Date of Preparation:<br>Registration Number: | Merit Medical Systems, Inc.<br>1600 West Merit Parkway<br>South Jordan, UT 84095<br>(801) 316-4932<br>(801) 316-4860<br>Casey Hughes<br>06/18/2012<br>1721504 | |
| Subject<br>Device | Trade Name:<br>Common/Usual Name:<br>Classification Name: | ReSolve® Biliary Locking Drainage Catheter<br>Biliary Drainage Catheter<br>Catheter, Biliary, Diagnostic | |
| Predicate<br>Device | Trade Name:<br>Common/Usual Name:<br>Classification Name:<br>Premarket Notification:<br>Manufacturer: | ReSolve® Biliary Drainage Catheter<br>Biliary Drainage Catheter<br>Catheter, Biliary, Diagnostic<br>K063733<br>Merit Medical Systems, Inc. | |
| Classification | | Class II<br>21 CFR § 876.5010<br>Gastroenterology/Urology | |
| Intended Use | The ReSolve® Biliary Locking Drainage Catheter with locking pigtail<br>and hydrophilic coating is used for drainage of bile within the biliary<br>system. | | |
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ReSolve® Biliary Locking Drainage Catheter Section 5, 510(k) Summary Special Premarket Notification 510(k)
Device Description The ReSolve® Biliary Locking Drainage Catheter consists of single lumen tubing with two suture holes and 17 to 18 drainage holes in the distal curve region. It is made from a biocompatible thermoplastic. A hydrophilic coating reduces entry site/catheter friction during placement. The components of the catheter allow initial placement using an over-the-wire technique. These include a metal stiffening cannula, flexible stiffening cannula, straightener, and repositioning tool. The pigtail straightener is provided to assist in feeding the guide wire through the catheter. Once the catheter position is established in the area to be drained, the pigtail is formed by retracting a suture which is looped from the hub, to the catheter tip and back to the hub. The hub incorporates a suture locking mechanism to retain the distal pigtail shape. It may be unlocked using the repositioning tool to allow repositioning or replacement of the catheter. A single radiopaque marker band is located proximal to the most proximal drainage hole to assist in accurate placement of the drainage holes in the biliary duct.
# Technological Characteristics
The technological characteristics of the subject ReSolve Biliary Locking Drainage Catheter are substantially equivalent to those of the predicate device, the ReSolve Biliary Drainage Catheter, 510(k) K063733.
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K121832
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No performance standards have been established under Section 514 of the Food, Drug and Cosmetic Act for these devices. Performance testing of the ReSolve Biliary Locking Drainage Catheter was conducted based on a risk analysis and based on the requirements of the following international standards:
- ISO 11135-1:2007, Sterilization of health care products -. Ethylene oxide - Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices
- ISO 10993-1:2009, Biological Evaluation of Medical Devices ● Part-1: Evaluation and Testing within a risk management process, and the FDA Modified ISO 10993 Test Profile
- ISO 10993-5:2009. Biological evaluation of medical devices -. Part 5: Tests for in vitro cytotoxicity
- ISO 10993-7:2008, Biological Evaluation of Medical Devices -. Part 7: Ethylene Oxide Sterilization Residuals
- ISO 10993-10:2010. Biological evaluation of medical devices -Part 10: Tests for irritation and skin sensitization
### Safety & Performance Tests
- ISO 10993-11:2006, Biological evaluation of medical devices -. Part 11: Tests for systemic toxicity
- ISO 10993-17:2002, Biological Evaluation of Medical Devices -. Part 17: Methods for the Establishment of Allowable Limits for Leachable Substances
- ISO 10993-18:2005, Biological Evaluation of Medical Devices -� Part 18: Chemical Characterization of Materials
- USP 34 <151>:2011, United States Pharmacopeia 34, National ● Formulary 29, 2011. <151> Pyrogen Test.
- EN 1617:1997, Sterile Drainage Catheters and Accessory . Devices for Single Use
- ASTM D4169-09:2009, Standard Practice for Performance . Testing of Shipping Containers and Systems
- ASTM F 1980-07:2007, Standard Guide for Accelerated Aging ● of Sterile Barrier Systems for Medical Devices
- ISO 2233:2000, Packaging Complete, Filled Transport . Packages and Unit Loads - Conditioning for Testing
The following is a list of all significant testing that was successfully completed:
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ReSolve® Biliary Locking Drainage Catheter Section 5, 510(k) Summary Special Premarket Notification 510(k)
Design Verification Conditioning Dimensional Drainage Hole Orientation Marker Band/Hole Location Tip Penetration Hub Leak Vacuum Test Tubing Kink Test Safety & Marker Band Adhesion Performance Hub Tensile Testing Tests cont. Tubing Tensile Testing Material Durability Testing Bile Exposure Testing Stiffening Cannula Friction Test Biocompatibility Tests Cytotoxicity Irritation Acute Systemic Toxicity Pvrogenicitv Chemical Characterization Safety & The results of the testing demonstrated that the subject ReSolve Performance Biliary Locking Drainage Catheter met the pre-determined acceptance criteria applicable to the safety and efficacy of the Tests cont. device. Based on the indications for use, design, and safety and performance testing, the subject ReSolve Biliary Locking Drainage Summary of Catheter meets the requirements that are considered essential for Substantial its intended use and is substantially equivalent to the predicate Equivalence device, the ReSolve Biliary Drainage Catheter, manufactured by
Merit Medical Systems. Inc.
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## DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three tail feathers, representing the department's mission to protect the health of all Americans and provide essential human services. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular fashion around the eagle.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room-WO66-G609 Silver Spring, MD 20993-0002
Ms. Casey Hughes Manager, Regulatory Affairs Merit Medical Systems, Inc. 1600 West Merit Parkway SOUTH JORDAN UT 84095
# JUL 1 7 2012
K121832 Re:
Trade/Device Name: Resolve® Biliary Locking Drainage Catheter Regulation Number: 21 CFR§ 876.5010 Regulation Name: Biliary catheter and accessories Regulatory Class: II Product Code: FGE Dated: June 18, 2012 Received: June 22, 2012
Dear Ms. Hughes:
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 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). You may, therefore, market the device, subject to the general controls provisions of the Act. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unfinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, and labeling, and prohibitions against misbranding and adulteration.
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 - Ms.Casey Hughes
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that 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 comply with all the 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 go to http://www.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/ReportalProblem/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/Resourcesfor You/Industry/default.htm.
Sincerely vours.
Hubert Demerino
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
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ReSolve® Biliary Locking Drainage Catheter Section 4, Indications for Use Special Premarket Notification 510(k)
## Section 4
### Indications for Use
K121832
510(k) Number (if known):
Device Name: ReSolve® Biliary Locking Drainage Catheter
Indications for Use:
The ReSolve® Biliary Locking Drainage Catheter with locking pigtail and hydrophilic coating is used for drainage of bile within the biliary system.
Prescription Use × (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Hulut Leen
Division Sign-Off) Division of Reproductive, Gastro-Renal, and Jrological Devices 121832 510(k) Number
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.