EN Snare Endovascular Snare System

K151497 · Merit Medical Systems, Inc. · MMX · Jul 1, 2015 · Cardiovascular

Device Facts

• Record ID: K151497
• Device Name: EN Snare Endovascular Snare System
• Applicant: Merit Medical Systems, Inc.
• Product Code: MMX · Cardiovascular
• Decision Date: Jul 1, 2015
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 870.5150
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The EN Snare® Endovascular Snare System is intended for use in the coronary and peripheral vascular system or hollow viscous to retrieve and manipulate foreign objects. Retrieval and manipulation procedures include, indwelling venous catheter repositioning, indwelling venous catheter fibrin sheath stripping, and central venous access veupuncture procedure assistance.

Device Story

Endovascular snare system for retrieval/manipulation of foreign objects in coronary/peripheral vasculature or hollow viscous. Components: snare (3 interlaced platinum/nitinol cables forming 3 loops), catheter (Pebax/PTFE), insertion tool (polypropylene), and external torque device. Snare inserted into intravascular catheter; manipulated via torque device. Used by clinicians in clinical settings. Enables repositioning of indwelling venous catheters, stripping of fibrin sheaths, and assistance during central venous access. Benefits patient by facilitating removal of foreign bodies and management of venous access devices.

Clinical Evidence

No clinical data. Bench testing only. Testing included mechanical performance (torque strength, kink/buckling resistance, leak/air testing, force at break, snare loop resistance), dimensional verification, and biocompatibility (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity, genotoxicity, hemolysis, thrombogenicity, complement activation).

Technological Characteristics

Snare: 3 interlaced stranded cables of platinum and super-elastic nitinol. Catheter: Pebax outer layer, PTFE inner layer, iridium/platinum markerband, Pebax hub, polycarbonate luer. Insertion tool: polypropylene. Sizes: 2mm to 45mm snare; 3.2F, 6F, 7F catheters. Sterilization: Ethylene oxide (ISO 11135:2014). Standards: ISO 10555-1, ISO 594-1/2, ASTM F1980-07, ISO 2233, ISO 10993-1.

Indications for Use

Indicated for use in coronary and peripheral vascular systems or hollow viscous to retrieve and manipulate foreign objects, including indwelling venous catheter repositioning, fibrin sheath stripping, and central venous access venipuncture assistance.

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.

Predicate Devices

• EN Snare Endovascular Snare System (K092343)

Reference Devices

• ONE Snare System (K122088)

Submission Summary (Full Text)

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with the profiles overlapping each other.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

July 1, 2015

Merit Medical Systems, Inc. Siobhan King Senior Regulatory Affairs Specialist Parkmore Business Park West Galway, Ireland

Re: K151497

Trade/Device Name: EN Snare Endovascular Snare System Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: MMX Dated: June 2, 2015 Received: June 4, 2015

Dear Siobhan King:

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.

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

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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 contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

M.A. Hillebrand

R

for Bram Zuckerman, MD
Director, Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

## Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K151497

Device Name EN Snare Endovascular Snare System

### Indications for Use (Describe)

The EN Snare® Endovascular Snare System is intended for use in the coronary and peripheral vascular system or hollow viscous to retrieve and manipulate foreign objects. Retrieval and manipulation procedures include, indwelling venous catheter repositioning, indwelling venous catheter fibrin sheath stripping, and central venous access veupuncture procedure assistance.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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#### 510(k) Summary Submitter Name: Merit Medical Systems, Inc. Address: 1600 West Merit Parkway South Jordan, UT 84095 Telephone Number: ([phone] (3061) Fax Number: ([phone] Contact Person: Mark Mullaney Registration Number: 1721504 General Correspondent Name: Merit Medical Ireland Ltd. Provisions Address: Parkmore Business Park West Galway, Ireland Telephone Number: ([phone] (3052) Fax Number: ([phone] Contact Person: Siobhan King Date of Preparation: 17 June 2015 Registration Number: 9616662 Trade Name: EN Snare Endovascular Snare System Subject Common/Usual Name: Device, Percutaneous Retrieval Device Classification Name: Device, Percutaneous Retrieval Primary Predicate Device #1: Trade Name: EN Snare Endovascular Snare System Classification Name: Device, Percutaneous Retrieval Premarket Notification: K092343 Manufacturer: Merit Medical Systems, Inc. Predicate Device Reference Device #2: ONE Snare System Trade Name: Classification Name: Percutaneous retrieval device Premarket Notification: K122088 Manufacturer: Merit Medical Systems, Inc. Class II 21 CFR 870.5150 Classification Device, Percutaneous Retrieval FDA Product Code: MMX Review Panel: Division of Cardiovascular Devices The EN Snare Endovascular Snare System is intended for use in the coronary and peripheral vascular system or hollow viscous to retrieve and manipulate Intended Use foreign objects. Retrieval and manipulation procedures include, indwelling venous catheter repositioning, indwelling venous catheter fibrin sheath stripping, and central venous access venipuncture procedure assistance.

# Section 5

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The EN Snare Endovascular Snare System consists of four individual components: snare: catheter: insertion tool and torque device. Systems are available in various sizes and lengths. The snare is comprised of 3 interlaced stranded cables of platinum and super-elastic nitinol that form 3 loops and are mechanically secured with a crimp collar to a nitinol shaft wire. The superelastic nitinol construction enables the loops of the snare to be introduced through a catheter without the risk of deformation. The catheter is manufactured with a Pebax outer layer and a PTFE inner layer with an embedded iridium/platinum markerband at the distal end, a Pebax hub and a polycarbonate luer. A snare insertion tool is also included for optional back-end loading of the snare into a preplaced catheter. The snare insertion tool is manufactured from polypropylene. The snare is inserted into an intravascular catheter and manipulated by use of an external torque device. The snare is offered in sizes ranging from 2mm to 45mm, with catheter sizes of 3.2F, 6F, and 7F.

The technological characteristics of the subject Merit EN Snare Endovascular Snare System are substantially equivalent to the Primary Predicate Device#1 Merit EN Snare Endovascular Snare System (K092343), and the Reference Device#2, Merit ONE Snare System, 510(k), K122088, for the following performance data - Corrosion Testing, Luer Testing and Packaging Testing, The Comparison to difference between the subject Merit EN Snare Endovascular Snare System and Predicate the Primary Predicate Device#1 Merit EN Snare Endovascular Snare System (K092343) relates to a modification to the catheter and insertion tool design and materials only. The snare device and the torque device remain unchanged. While the intended use remains unchanged the indications for use are being clarified.

> No performance standards have been established under section 514 of the Food, Drug and Cosmetic Act for these devices. Performance testing of the subject Merit EN Snare Endovascular Snare System was conducted based on risk analysis. A battery of testing was conducted in accordance with protocols based on requirements outlined in quidance's and industry standards and these were shown to meet the acceptance criteria that were determined to demonstrate substantial equivalence.

> Where appropriate, the tests were based on the requirements of the following documents:

- FDA guidance Coronary and Cerebrovascular Guide Wire Guidance . January 1995.
Safety & Performance Tests

Device

Description

- ISO 10555-1 2013 Intravascular catheters Sterile and single use ● catheters - Part 1: General Requirements.
- ISO 594-1:1986 Conical fittings with a 6% (Luer) taper for syringes, ● needles and certain other medical equipment - Part 1: General requirements
- ISO 594-2:1998 Conical fittings with 6% (Luer) taper for syringes, . needles and certain other medical equipment - part 2: Lock fittings
- . ISO 11135:2014 Sterilization of health care products-Ethylene oxide-Requirements for the development, validation and routine control of a sterilization process for medical devices.
- ASTM F1980-07 Standard Guide for Accelerated Aging of Sterile Barrier ● Systems for Medical Devices

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- ISO 2233:2000 Packaging complete, filled transport packages and unit ● loads - conditioning for testing . 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 FDA Memo G95-1. The following is a list of all significant testing that was successfully completed: Catheter and Insertion Tool Surface: external surface ● Radiodetectability of catheter/marker bands ● Dimensions: Catheter Markeband length ● Dimensions: Catheter Markerband placement ● Surface: Catheter PTFE Liner Inspection ● Dimensions: Catheter Tip Angle ● ● Dimensions: Catheter Tip Length Dimensions: Length, Diameter (ID/OD) ● Atraumatic Catheter Tip ● Markerband retention ● ● Torque Strength ● Kink resistance Buckling resistance ● Freedom from Liquid Leakage ● Freedom from Air Leakage ● Force at break(junction between catheter hub and tube) ● ●
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## System

- Snare Loop Resistance
- Guiding Catheter Resistance ●
- . Snare insertion tool fitment
- Snare insertion ●
- Insertion Tool tear away force from the snare ●
- . Snare inspection after insertion tool removal
- Snare loop protrusion

## Biocompatibility testing included

- Cytotoxicity ●
- Sensitization ●
- Irritation ●
- Acute Systemic Toxicity ●
- Pyrogenicity ●
- Genotoxicity ●
- Hemolysis ●
- Thrombogenicity .
- Complement Activation
- Chemical Tests

The subject Merit EN Snare Endovascular Snare System met the acceptance criteria applicable to the safety and effectiveness of the device. This has demonstrated the subject device Merit EN Snare Endovascular Snare System is substantially equivalent to the Primary Predicate Device#1 EN Snare Endovascular Snare System, K092343.

Safety & Performance

Tests

## continued

- Force at break(junction between insertion tool hub and tube)
- Catheter hub with female luer ●
- . Corrosion resistance

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| Summary of | Based on the Indications for Use, design, safety and performance testing, the |
|-------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Substantial | subject Merit EN Snare Endovascular Snare System is substantially equivalent |
| Equivalence | to the Primary Predicate Device#1 Merit EN Snare Endovascular Snare System,<br>K092343 and the Reference Device#2, Merit ONE Snare System, 510(k),<br>K122088 for Performance data. |