AtriClip LAA Exclusion System with preloaded Gillinov-Cosgrove Clip

K160454 · AtriCure, Inc. · FZP · Mar 18, 2016 · General, Plastic Surgery

Device Facts

• Record ID: K160454
• Device Name: AtriClip LAA Exclusion System with preloaded Gillinov-Cosgrove Clip
• Applicant: AtriCure, Inc.
• Product Code: FZP · General, Plastic Surgery
• Decision Date: Mar 18, 2016
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 878.4300
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The AtriClip® LAA Exclusion System is indicated for the occlusion of the heart's left atrial appendage, under direct visualization, in conjunction with other open cardiac surgical procedures. Direct visualization, in this context, requires that the surgeon is able to see the heart directly, without assistance from a camera, endoscope, etc., or any other viewing technology. This includes performed by sternotomy (full or partial) as well as thoracotomy (single or multiple).

Device Story

The AtriClip LAA Exclusion System is a sterile, single-use implantable device designed for permanent occlusion of the left atrial appendage (LAA). It consists of a self-closing Gillinov-Cosgrove clip preloaded onto a disposable applier. The system is used by surgeons during open cardiac procedures (sternotomy or thoracotomy) under direct visualization. The applier features a handle, shaft, and deployment loop; the PRO2 version introduces active articulation controls to facilitate clip positioning and deployment. The surgeon manually positions the clip over the LAA; upon deployment, the clip provides uniform pressure to ensure secure occlusion. The device remains as a permanent implant. Benefits include consistent, reproducible LAA exclusion, which may reduce the risk of thromboembolic events. No electronic or software components are involved.

Clinical Evidence

Bench testing only. Evidence includes mechanical testing, reliability testing, MR compatibility testing per FDA guidance, and animal model bench testing. Biocompatibility testing was performed in accordance with ISO 10993-1 for an external communicating device with tissue/bone contact < 24 hours, including cytotoxicity, sensitization, irritation, systemic toxicity, and material-mediated pyrogenicity.

Technological Characteristics

Implantable clip and applier system. Materials: medical-grade metals and plastics. Principle: mechanical self-closing clip providing uniform pressure for LAA occlusion. Features: active articulation controls, disposable handle/shaft/deployment loop. Sterilization: sterile. Connectivity: none. Software: none.

Indications for Use

Indicated for occlusion of the left atrial appendage in patients undergoing open cardiac surgical procedures requiring direct visualization (sternotomy or thoracotomy).

Regulatory Classification

Identification

An implantable clip is a clip-like device intended to connect internal tissues to aid healing. It is not absorbable.

Predicate Devices

• AtriClip LAA Exclusion System (K122276)

Reference Devices

• AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip (K093679)
• AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip (K131107)
• AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip (K142120)
• AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip (K150996)
• AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove PRO-V Clip (K153500)

Submission Summary (Full Text)

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

March 18, 2016

AtriCure, Inc. Mr. Jonathan McElwee Senior Regulatory Specialist 6217 Centre Park Drive West Chester, Ohio 45069

Re: K160454

Trade/Device Name: AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip

Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable Clip Regulatory Class: Class II Product Code: FZP Dated: February 17, 2016 Received: February 18, 2016

Dear Mr. McElwee:

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 of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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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" (21 CFR 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
for

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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# Indications for Use

510(k) Number (if known) K160454

Device Name

AtriClip® LAA Exclusion System with Gillinov-Cosgrove® Clip

Indications for Use (Describe)

The AtriClip® LAA Exclusion System is indicated for the occlusion of the heart's left atrial appendage, under direct visualization, in conjunction with other open cardiac surgical procedures.

Direct visualization, in this context, requires that the surgeon is able to see the heart directly, without assistance from a camera, endoscope, etc., or any other viewing technology. This includes performed by sternotomy (full or partial) as well as thoracotomy (single or multiple).

| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|
| <span style="font-size:12px">☒</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-size:12px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |

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Image /page/3/Picture/0 description: The image shows the AtriCure logo. The logo is in two colors, blue and orange. The word "Atri" is in blue, and the word "Cure" is in orange. There is a blue dot in the middle of the "C" in "Cure". There is a registered trademark symbol next to the "e" in "Cure".

# 510(k) Summary

#### l. Submitter

| Manufacturer: | AtriCure, Inc.<br>6217 Centre Park Drive<br>West Chester, OH 45069<br>P: 513-755-4100<br>F: 513-755-4108 |
|----------------------|----------------------------------------------------------------------------------------------------------|
| Contact Person: | Jonathan McElwee<br>Senior Regulatory Affairs Specialist |
| Alternate Contact: | Jim Taufen<br>Sr. Manager of Regulatory Affairs |
| Date Prepared: | 2/17/2016 |
| II.<br>Device | |
| Name of Device: | AtriClip® LAA Exclusion System with preloaded Gillinov-Cosgrove® Clip (PRO2) |
| Common Name: | Implantable Clip and Clip Applier |
| Classification Name: | Implantable Clip and Clip Applier (21 CFR 878.4300) |
| Regulatory Class: | Class II |
| Product Code: | FZP |

#### lll. Predicate Device

The device proposed for modification in this submission is the AtriClip LAA Exclusion System cleared via K122276 on August 29, 2012.

The predicate device has not been subject to a design-related recall.

The following reference devices were also used in this submission:

- K093679 AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip ●
- K131107 AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip ●
- K142120 AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip
- K150996 AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip
- K153500 AtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove PRO-V Clip .

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### IV. Device Description

The AtriClip PRO2 LAA Exclusion System consists of a single use, sterile, self-closing, implantable Clip preloaded on a Single Use Clip Applier along with a selection guide. When closed, the Clip applies uniform pressure over the length of the Clip to ensure consistent, reproducible, and secure occlusion of the left atrial appendage (LAA). The clip is then deployed and is left as a permanent implant. The Clip is available in the following lengths to accommodate different sizes of LAA: 35 mm, 40 mm, 45 mm, and 50 mm.

The Clip Applier is a disposable device with a handle, shaft, suture anchors, and deployment loop which contains the Clip. This Special 510(k) contains design modifications to the predicate AtriClip LAA Exclusion System (PRO1) intended to eliminate the End Effector Hoop configuration, allow for active articulation via articulation controls, and increase ease of deployment of the clip.

#### V. Indications For Use

The AtriClip LAA Exclusion System is indicated for the left atrial appendage, under direct visualization, in conjunction with other open cardiac surgical procedures.

Direct visualization, in this context, requires that the surgeon is able to see the heart directly, without assistance from a camera, endoscope, etc., or any other viewing technology. This includes procedures performed by sternotomy (full or partial) as well as thoracotomy (single or multiple).

### VI. Comparison Of Technological Characteristics With The Predicate Device

- . The devices have the same intended use, and;
- No changes were made in operating principle, or specifications of performance, and;
- Both the PRO1 and PRO2 Appliers use the Gillinov-Cosgrove Clip, and;
- . Both the predicate and proposed device are made of similar patient contacting materials (medical grade metals and plastics) with long and safe histories of use.
- . The results of the verification and validation testing:
- Demonstrated equivalency in performance o
- o Device biocompatibility remains unchanged
- Did not raise any new issues of safety O

The modifications to the proposed AtriClip LAA Exclusion System are intended to eliminate the existing End Effector Hoop configuration, allow for active articulation controls, and to increase ease of deployment.

#### VII. Performance Data

Non-clinical Bench Testing

- Mechanical Testing ●
- Reliability Testing ●
- Magnetic Resonance Testing Per FDA Guidance (December 11, 2014) Establishing Safety and ● Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment
- . Bench Testing on an Animal Model

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# Biocompatibility Testing

The biocompatibility evaluation for the PRO2 clip applier was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process" as recognized by FDA. The battery of testing included the following tests:

- Cytotoxicity .
- . Sensitization
- Irritation
- . Systemic Toxicity
- Material Mediated Pyrogen .

The PRO2 clip applier is categorized as an "External Communicating Device," contact for "Tissue/Bone" and contact duration for "under 24 hours."

#### VIII. Conclusions

The modified AtriClip LAA Exclusion System (PRO2) is equivalent to the previously cleared AtriClip LAA Exclusion System (PRO1) as there is no change to intended use, operating principals, or function of the device.