K161921 · Merit Medical Systems, Inc. · KRA · Nov 4, 2016 · Cardiovascular
Device Facts
Record ID
K161921
Device Name
SwiftNINJA Microcatheter
Applicant
Merit Medical Systems, Inc.
Product Code
KRA · Cardiovascular
Decision Date
Nov 4, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.1210
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
This microcatheter is intended for general intravascular use, including peripheral and coronary vasculature. Once the sub-selective region has been accessed, the microcatheter can be used for the controlled and selective infusion of diagnostic, embolic, or therapeutic materials into the vasculature. The catheter should not be used in the cerebral vessels.
Device Story
SwiftNINJA Microcatheter is a 2.9 Fr (proximal) / 2.4 Fr (distal) steerable microcatheter. Operator uses a proximal steering dial connected via two internal wires to manipulate the distal tip up to 180 degrees in opposing directions; a dial lock maintains tip orientation. Device features a hydrophilic coating on the distal shaft to facilitate vascular introduction. Used by physicians in clinical settings for sub-selective access and targeted delivery of diagnostic or therapeutic agents. Output is the physical placement of the catheter tip and subsequent infusion of materials. Benefits include enhanced maneuverability for accessing complex vascular anatomy.
Clinical Evidence
No clinical or pre-clinical animal testing was conducted. Substantial equivalence is supported by bench testing, including biocompatibility (ISO 10993), mechanical performance (tensile strength, burst pressure, fatigue, torque, kink resistance), and functional validation (tip articulation, coating effectiveness, radiopacity).
Technological Characteristics
Steerable microcatheter with 2.9 Fr proximal/2.4 Fr distal diameter. Features mechanical steering dial, dual-wire articulation mechanism, and hydrophilic coating. Materials meet ISO 10993 biocompatibility standards. Sterilized via ethylene oxide (ISO 11135). Complies with ISO 594-1/2 for Luer fittings and ASTM standards for packaging and radiopacity.
Indications for Use
Indicated for general intravascular use in peripheral and coronary vasculature for controlled infusion of diagnostic, embolic, or therapeutic materials. Contraindicated for use in cerebral vessels.
Regulatory Classification
Identification
A continuous flush catheter is an attachment to a catheter-transducer system that permits continuous intravascular flushing at a slow infusion rate for the purpose of eliminating clotting, back-leakage, and waveform damping.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 4, 2016
Merit Medical Systems, Inc. Luke Meidell Senior Regulatory Affairs Specialist 1600 West Merit Parkway South Jordan, Utah 84095
Re: K161921
Trade/Device Name: SwiftNINJA Microcatheter Regulation Number: 21 CFR 870.1210 Regulation Name: Continuous Flush Catheter Regulatory Class: Class II Product Code: KRA Dated: September 30, 2016 Received: October 3, 2016
Dear Luke Meidell:
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,
Brian D. Pullin -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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Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below
# Indications for Use
510(k) Number (if known) K161921
#### Device Name
SwiftNINJA Microcatheter
#### Indications (Describe)
This microcatheter is intended for general intravascular use, including peripheral and coronary vasculature. Once the sub-selective region has been accessed, the microcatheter can be used for the controlled and selective infusion of diagnostic, embolic, or therapeutic materials into the vasculature. The catheter should not be used in the cerebral vessels.
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 - K161921
| General<br>Provisions | Submitter Name: Merit Medical Systems, Inc.<br>Address: 1600 West Merit Parkway South Jordan, UT 84095<br>Telephone Number: (801) 208-4623<br>Fax Number: (801) 826-4174<br>Contact Person: Luke Meidell<br>Date Prepared: 09/30/2016<br>Registration Number: 1721504 |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Subject<br>Device | Trade Name: SwiftNINJA® Microcatheter<br>Common/Usual Name: Continuous Flush Catheter<br>Classification Name: Catheter, Continuous Flush<br>Regulatory Class: 2<br>Product Code: KRA<br>21 CFR §: 870.1210<br>Review Panel: Cardiovascular |
| Primary<br>Predicate<br>Device | Trade Name: Merit Microcatheter<br>Classification Name: Continuous Flush Catheter<br>Premarket Notification: K082613<br>Manufacturer: Merit Medical Systems, Inc.<br>This predicate has not been subject to a design-related recall. |
| Secondary<br>Predicate<br>Device | Trade Name: Micrus® Courier Enzo™ Microcatheter<br>Classification Name: Diagnostic intravascular catheter<br>Premarket Notification: K072526, K070456<br>Manufacturer: Micrus Endovascular Corporation |
| Device<br>Description | The SwiftNINJA® Microcatheter is a 2.9 Fr (proximal) / 2.4 Fr<br>(distal) microcatheter with a steerable/articulating distal tip.<br>Articulation is achieved via a steering dial at the proximal handle<br>which allows the operator to manipulate the tip up to 180 degrees<br>in opposing directions. The steering dial and steerable tip are<br>connected via two operating wires. The wires are located on both<br>lateral walls of the catheter shaft with a connection point on the |
| distal catheter. Tension is applied to either one of the wires by<br>turning the steering dial for manipulation of the tip direction.<br>Once the direction of steerable tip is determined, the steering dial<br>lock may be used for maintaining the intended direction.<br><br>The outer surface of the distal segment of the microcatheter shaft<br>is coated with a hydrophilic coating designed to facilitate the<br>introduction of the microcatheter into the vasculature. | |
| Indications for<br>Use | This microcatheter is intended for general intravascular use,<br>including peripheral and coronary vasculature. Once the sub-<br>selective region has been accessed, the microcatheter can be<br>used for the controlled and selective infusion of diagnostic,<br>embolic, or therapeutic materials into the vasculature. The<br>catheter should not be used in the cerebral vessels.<br><br>The Indications for Use statement for the SwiftNINJA<br>Microcatheter is identical to the predicate device. |
| Comparison<br>to Predicate<br>Device | The SwiftNINJA Microcatheter is similar in design and<br>technological characteristics to the Merit Microcatheter (primary<br>predicate) and the Micrus Courier Enzo Microcatheter (secondary<br>predicate).<br><br>The comparison between the subject, primary predicate, and<br>secondary predicate devices is based on the following:<br>Same intended use Same Indications for Use Similar material types that meet ISO 10993 biocompatibility requirements Same sterilization methods Same fundamental technology/principle of operation between the subject and predicate devices. |
| | Performance<br>Data |
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- BS EN 20594-1 1994/ISO 594-1:1986, Conical fittings with a ● 6% (Luer) taper for svringes, 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.
- ISO 10993-1:2009. Biological Evaluation of Medical Devices -. Part 1: Evaluation and Testing within a risk management process, and FDA quidance Required Biocompatibility Training and Toxicology Profiles for Evaluation of Medical Devices, May 1, 1995
- ISO 10993-3:2014, Biological Evaluation of Medical Devices ● – Part 3: Tests for Genotoxicity, Carcinogenicity and Reproductive Toxicity
- ISO 10993-4:2002 (Amd.1:2006), Biological evaluation of ● medical devices – Part 4: Selection of tests for interaction with blood
- 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
- ISO 10993-11:2006, Biological evaluation of medical devices - Part 11: Tests for systemic toxicity
- ASTM F756-13:2013, Standard practice for assessment of ● hemolytic properties of materials
- . United States Pharmacopeia 38, National Formulary 33, 2015 <151> Pyrogen Test
- ISO 11607-1: 2009/Amd.1:2014, Packaging for terminally . sterilized medical devices - Part 1: Requirements for materials, sterile barrier systems and packaging systems.
- ISO 11607-2: 2006/Amd.1:2014, Packaging for terminally ● sterilized medical devices – Part 2: Validation requirements for forming, sealing and assembly processes.
- . ISO 2233:2000, Packaging - Complete, filled transport packages and unit loads - Conditioning for testing.
- ASTM D4169-14:2014, Standard practice for performance ● testing of shipping containers and systems
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- ASTM F2096-11:2011, Standard Test Method for Detecting ● Gross Leaks in Medical Packaging by Internal Pressurization (Bubble Test)
- ASTM F1929-98:1998 (Reapproved 2004), Standard Test . Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration.
- ASTM F640-12:2012, Standard test methods for determining radiopacity for medical use.
The following performance data were provided in support of the substantial equivalence determination.
# Biocompatibility testing
The biocompatibility evaluation for the SwiftNINJA Microcatheter was conducted in accordance with the FDA Blue Book Memorandum #G95-1 "Use of International Standard ISO-10993. 'Biological Evaluation of Medical Devices Part 1: Evaluation and Testing." May 1, 1995, and 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 ●
- Acute Systemic Toxicity ●
- Pyrogenicity ●
- Genotoxicitv ●
- Hemolysis ●
- Thrombogenicity ●
- Complement Activation ●
The SwiftNINJA Microcatheter is considered tissue contacting for a duration of less than 24 hours.
# Performance Testing-Bench
- Gauging
- Liquid leakage under high static pressure conditions ●
# Performance
- Air leakage ●
### Data cont.
- Separation force
- Unscrewing torque ●
- Ease of assembly .
- Resistance to overriding ●
- Stress cracking ●
- Visual inspection ●
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- Dimensional inspection ●
- Catheter body tensile strength / elongation ●
- Catheter tip tensile strength / elongation
- Catheter body to hub tensile strength ●
- . Catheter burst to failure
- Power injection
- Dead space (priming volume) ●
- Microcatheter quide wire passage ●
- Tip articulation / dial spring functionality / dial lock knob ●
- Multiple articulation (fatique test) ●
- . Radiodetectability
- Freedom from damage under high dynamic pressure ● conditions
- Catheter body fatigue
- Shaft radius of collapse with guide wire ●
- Shaft radius of collapse without quide wire ●
- Kink resistance ●
- Lubricious coating effectiveness ●
- Lubricious coating coverage ●
- Torque to failure
- Design validation ●
- . Neqative pressure collapse
- Embolic Delivery
- Particulate ●
No clinical or pre-clinical testing was conducted to evaluate the substantial equivalence of this device.
#### Summary of Substantial Equivalence
Based on the Indications for Use, design, safety and performance testing, the subject SwiftNINJA Microcathetermeets the requirements that are considered essential for its intended use and is substantially equivalent to the predicate device, the Merit Microcatheter, K082613.
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.