The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0mm to 7.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
Device Story
Pantheris Catheter performs atherectomy in peripheral vasculature; utilizes OCT-assisted orientation as adjunct to fluoroscopy to guide plaque removal. System includes catheter, flush fixture, syringes, and added accessories (tweezers, 3-way stopcocks). Tweezers facilitate tissue extraction from catheter distal end post-removal; stopcocks facilitate CO2/saline delivery to catheter lumens. Device used by clinicians in clinical settings. Accessories do not contact patient. OCT imaging provides real-time visualization to assist physician in plaque removal, potentially improving procedural precision and patient outcomes.
Clinical Evidence
Bench testing only. Biocompatibility (ISO 10993-1), packaging/shelf-life (ISO 11607-1/2), and sterilization (ISO 11137-1/2) validation performed for added accessories. No clinical data required.
Technological Characteristics
Intraluminal artery stripper; OCT-assisted orientation. Accessories: tweezers, 3-way stopcocks. Sterilization: Electron Beam (Method VDMax25, SAL 10^-6). Complies with ISO 10993-1, ISO 11607-1/2, ISO 11137-1/2.
Indications for Use
Indicated for atherectomy in partially occluded peripheral vessels (3.0-7.0mm diameter). Contraindicated for iliac, coronary, cerebral, renal, or carotid vasculature.
Regulatory Classification
Identification
An intraluminal artery stripper is a device used to perform an endarterectomy (removal of plaque deposits from arterisclerotic arteries.)
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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 seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol of three human profiles facing to the right, stacked on top of each other.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 21, 2016
Avinger, Inc. Ms. Golnaz Moeini Senior Regulatory Affairs Specialist 400 Chesapeake Drive Redwood City, California 94063
Re: K160827
Trade/Device Name: Pantheris Catheter Regulation Number: 21 CFR 870.4875 Regulation Name: Intraluminal Artery Stripper Regulatory Class: Class II Product Code: MCW Dated: March 24, 2016 Received: March 25, 2016
Dear Ms. Moeini:
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 devicerelated 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.
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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 (800) 638-2041 or (301) 796-7100 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 (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Kenneth J. Cavanaugh -S
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) K160827
Device Name Pantheris Catheter
Indications for Use (Describe)
The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0mm to 7.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| X Prescription Use (Part 21 CER 801 Subnart D) | Over-The-Counter Use (21 CFR 801 Subnart C) |
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# 510(k) Summary
## General Information
| 510(k) Sponsor | Avinger, Inc. |
|-------------------------|--------------------------------------------------------------------|
| Address | 400 Chesapeake Drive<br>Redwood City, CA 94063 |
| FDA Registration Number | 3007498664 |
| Correspondence Person | Golnaz Moeini<br>Sr. Regulatory Affairs Specialist<br>Avinger Inc. |
| Contact Information | Email: gmoeini@avinger.com<br>Phone: 408-504-3187 |
| Date Prepared | March 23rd, 2016 |
#### Proposed Device
| Proprietary Name | Avinger Pantheris Accessories |
|---------------------|-------------------------------|
| Common Name | Avinger Pantheris Catheter |
| Classification Name | Intraluminal Artery Stripper |
| Regulation Number | 21 CFR§870.4875 |
| Product Code | MCW |
| Regulatory Class | II |
## Predicate Device
| Proprietary Name | Avinger Pantheris Catheter (K153460) |
|------------------------|--------------------------------------|
| Premarket Notification | K153460 |
| Classification Name | Intraluminal Artery Stripper |
| Regulation Number | 21 CFR§870.4875 |
| Product Code | MCW |
| Regulatory Class | II |
## Device Description
The Pantheris Catheter received clearance under K153460 to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature using OCTassisted orientation. This Special 510(k) submission is intended to add Tweezers and two 3-way Stopcocks to the Pantheris Catheter packaging. The Tweezers are provided to assist in the extraction of tissue that is collected during the atherectomy procedure from the distal end of the catheter once the catheter is removed from the patient. The catheter can then be re-inserted into the vessel to continue plaque removal using the
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same technique. The Tweezers are not intended to come into direct contact with the patient.
The Stopcocks are standard, off the shelf accessories, used to facilitate the delivery of CO2 and saline to the catheter. The Syringes are connected to the Flush and Balloon Inflation Lumens (components on the catheter's handle assembly) via the Stopcocks. The Stopcocks are not intended to come into direct contact with the patient.
Both the Tweezers and the Stopcocks are provided in order to make readily available these commonly used accessories and for user's convenience.
#### Indications for Use
The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0mm to 7.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
## Comparison of Technological Characteristics with the Predicate Device
The cleared Pantheris Catheter package includes the catheter, a flush fixture and 6mL and 10mL Syringes. Avinger is proposing to add Tweezers and two 3-way Stopcocks to the Pantheris Catheter packaging. There are no modifications to the indications for use, intended use, material, design, functionality or performance of the catheter, flush fixture and syringes cleared under K153460. The Tweezers and Stopcocks are provided for user convenience purposes. The performance testing conducted establishes that the addition of Tweezers and Stopcocks does not raise new questions of the safety and efficacy for the Pantheris Catheter cleared under K153460.
## Non-Clinical Test Data
Tweezers and Stopcocks used in conjunction with the Pantheris Catheter has been evaluated in accordance with design specifications and applicable performance standards through biocompatibility assessment, packaging, sterilization and shelf life validation.
The Pantheris Catheter design, performance, material, indications for use and fundamental technology are identical to the cleared Pantheris Catheter (K153460), supporting a determination of substantial equivalence.
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The biocompatability of the Tweezers and Stopcocks were verified per ISO10993-1:2009 Biological evaluation of medical devices — Part 1: Evaluation and testing within a risk management process and related collateral standards for patient contacting materials (see Section 13.3, Biocompatibility).
The packaging and shelf-life validation were performed to test the packaging tray configuration in accordance to ISO 11607-1:2006 Packaging for terminally sterilized medical devices Part 1: Requirements for materials, sterile barrier systems and packaging systems and ISO 11607-2:2006, Packaging for terminally sterilized medical devices- Part 2: Validation requirements for forming, sealing and assembly process
The Pantheris Catheter along with accessories is provided sterile and utilizes the same sterilization process as the cleared device. The sterilization was repeated to verify the product maintain the Sterility Assurance Level of 106 using Electron Beam sterilization per Method VDMax25 in accordance with ISO 11137-1:2006, Sterilization of health care products- Radiation, Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices and ISO 11137-2:2006 Sterilization of health care products – Radiation – Part 2: Establishing the sterilization dose.
The collective results of the non-clinical testing demonstrate that the Pantheris Catheter meets the established specifications necessary for consistent performance for its intended use.
#### Conclusion
Based on the information submitted in this premarket notification, and based on the indications for use, technological characteristics, performance testing and material comparison to the predicate device, the Pantheris accessories raise no new questions of safety and effectiveness and the device is substantially equivalent to the predicate device.
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.