K173596 · Teleflex Medical · EZC · Jan 29, 2018 · Gastroenterology, Urology
Device Facts
Record ID
K173596
Device Name
Rusch Intermittent Urethral Catheters
Applicant
Teleflex Medical
Product Code
EZC · Gastroenterology, Urology
Decision Date
Jan 29, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5130
Device Class
Class 2
Indications for Use
The Intermittent Urethral Catheters are indicated for routine drainage of fluids from the bladder. These catheters are not intended or designed for indwelling use.
Device Story
Rusch® Intermittent Urethral Catheters are single-use, sterile, uncoated PVC devices for routine bladder drainage. Available in Tiemann and Nelaton-Robinson tip configurations (sizes 10 Ch. to 24 Ch.). Operated by clinicians or patients; inserted through urethra to drain bladder; withdrawn and disposed after use. Device consists of tubular shaft, funnel, and drainage holes. Benefits include safe, temporary fluid removal. No indwelling use.
Clinical Evidence
Bench testing only. Testing included flow rate, catheter tensile properties, and break strength. Biocompatibility testing performed per ISO 10993-1 (cytotoxicity, sensitization, skin irritation). Results confirm the device is as safe and effective as the predicate.
Technological Characteristics
Materials: PVC shaft and funnel with specific plasticizers. Dimensions: 10 Ch. to 24 Ch. (3.3 mm to 7.9 mm OD), 40 cm length. Configurations: Tiemann and Nelaton-Robinson tips with two drainage holes. Sterilization: Ethylene Oxide. Shelf-life: 5 years. Biocompatibility: ISO 10993-1, 10993-5, 10993-10.
Indications for Use
Indicated for routine bladder fluid drainage in patients requiring intermittent catheterization. Contraindicated in patients with insuperable urethral obstruction. Suitability must be assessed by a physician or qualified personnel.
Regulatory Classification
Identification
A urological catheter and accessories is a flexible tubular device that is inserted through the urethra and used to pass fluids to or from the urinary tract. This generic type of device includes radiopaque urological catheters, ureteral catheters, urethral catheters, coudé catheters, balloon retention type catheters, straight catheters, upper urinary tract catheters, double lumen female urethrographic catheters, disposable ureteral catheters, male urethrographic catheters, and urological catheter accessories including ureteral catheter stylets, ureteral catheter adapters, ureteral catheter holders, ureteral catheter stylets, ureteral catheterization trays, and the gastro-urological irrigation tray (for urological use).
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
January 29, 2018
Teleflex Medical, Inc. Amanda Webb Manager, Regulatory Affairs 3015 Carrington Mill Blvd. Morrisville, NC 27560
Re: K173596
> Trade/Device Name: Rusch® Intermittent Urethral Catheters Regulation Number: 21 CFR§ 876.5130 Regulation Name: Urological catheter and accessories Regulatory Class: II Product Code: EZC, EZD Dated: November 28, 2017 Received: November 29, 2017
Dear Amanda Webb:
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.
{1}------------------------------------------------
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 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.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
#### Name, Address, Phone and Fax Number of Applicant
Teleflex Medical, Incorporated 3015 Carrington Mill Blvd Morrisville, NC 27560 USA Phone: 919-491-8960 Fax: 919-443-4996
# Contact Person
Amanda Webb Manager, Regulatory Affairs
# Date Prepared
1/23/2018
# Device Name
| Trade Name: | Rusch® Intermittent Urethral Catheter |
|--------------------|---------------------------------------------------|
| Common/Usual Name: | Urological Catheter |
| Regulation Number: | 21 CFR 876.5130 |
| Regulation Name: | Urological catheter and accessories |
| Regulation Class: | II |
| Product Code: | EZC - catheter, coude<br>EZD - catheter, straight |
| Panel: | Gastroenterology/Urology |
# Predicate Device Rusch® Intermittent Urethral Catheters -K033023
#### Device Description
The Rusch® Intermittent Urethral Catheters are single use, uncoated, disposable and sterile. The catheter is comprised of a tip, shaft, and funnel. The catheter tube is made of polovviny chiloride (PVC), the tip of a PVC/liquid colored PVC which is cured to the tube and a catheter funnel also made of PVC. The dimensions range from Charrièr (Ch.) Ch. 10 to Ch. 24 which is a range of 3.3 mm to 7.9 mm in Outer Diameter with a length 40 cm. The catheters are produced with two different tips - Tiemann and Nelaton-Robinson. Each catheter size has a color-coded tip.
The Nelaton-Robinson catheters have a size range from 10 Ch. to 24 Ch. and have two drainage holes. The Tiemann catheters have a size range from 12 Ch. and also have two drainage holes. Additionally the Tiemann and Nelaton-Robinson catheters also contain funnel adhesive solution to which the funnel is adhered to the shaft and hot embossing film or tint for printing text on the catheter.
#### Indications for Use
The Intermittent Urethral Catheters are indicated for routine drainage of fluids from the bladder. These catheters are not intended or designed for indwelling use.
{3}------------------------------------------------
#### Contraindications
Insuperable obstruction of the urethra. However, the suitability of each patient must be individually assessed by a physician or other suitably qualified personnel.
# Substantial Equivalence
The subject device is substantially equivalent to the predicate device:
| Features | Teleflex Medical<br>Rusch<br>Intermittent<br>Urethral<br>Catheters (Subject<br>Device) | Rusch Urethral<br>Intermittent<br>Catheters<br>(Predicate Device-<br>K033023) | Comparison | |
|---------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | | | Similarities | Differences |
| Classification<br>Name | Catheter,<br>Urological | Catheter,<br>Urological | Devices are the<br>same | None |
| Regulation<br>Number | 876.5130 | 876.5130 | Devices are the<br>same | None |
| Class | II | II | Devices are the<br>same | None |
| Device<br>Description | The Intermittent<br>Urethral Catheters<br>consists of a<br>tubular shaft with<br>attached funnel<br>as connecting<br>device. PVC<br>material used in<br>the catheter.<br>The product sizes<br>range from 10<br>Ch. to 24 Ch.<br>The device shaft is<br>uncoated. | The Intermittent<br>Urethral Catheters<br>consists of a<br>tubular shaft with<br>attached funnel<br>as connecting<br>device. The PVC<br>material used in<br>the catheter.<br>The product sizes<br>range from 6 Ch.<br>to 24 Ch.<br>The device shaft<br>may be uncoated<br>or hydrophilic<br>coated. | Both devices are<br>intended for<br>intermittent<br>catheterization. | The<br>predicate,<br>Intermittent<br>Urethral<br>Catheters,<br>are offered<br>with or<br>without<br>hydrophilic<br>coating and<br>have a wide<br>range of<br>sizes.<br>The subject<br>device shaft<br>does not<br>have a<br>hydrophilic<br>coating, it is<br>uncoated. |
| Indication for Use | The Intermittent<br>Urethral<br>Catheters are<br>indicated for<br>routine drainage<br>of fluids from the<br>bladder. These<br>catheters are not<br>intended or<br>designed for<br>indwelling use. | The Intermittent<br>Urethral Catheters<br>are sterile, single-<br>use, flexible tubular<br>devices that are<br>inserted through the<br>urethra and used to<br>pass fluids to or<br>from urinary tracts. | Both the<br>predicates and<br>subject catheters<br>are sterile, single-<br>use devices that<br>pass fluids from<br>the<br>bladder/urinary<br>tract. | The predicate<br>devices<br>intended use<br>includes<br>passage of<br>fluids to or<br>from the<br>urinary tract.<br>The subject<br>Intermittent<br>Urethral<br>Catheters do<br>not include<br>the intended<br>use of<br>administration<br>of fluids to the<br>urinary tract. |
| Contraindications | Insuperable<br>obstruction of the<br>urethra. However,<br>the suitability of<br>each patient must<br>be individually<br>assessed by a<br>physician or other<br>suitably qualified<br>personnel. | None known | There are no<br>known<br>contraindications<br>for the predicate<br>devices. | The subject<br>Intermittent<br>Urethral<br>Catheters has<br>a<br>contraindicatio<br>n. |
| Single Use | Yes | Yes | Devices are the<br>same | None |
| Size Range | 10 Ch. - 24 Ch. | 6 Ch. - 24 Ch. | The subject<br>Intermittent<br>Urethral catheters<br>sizes are included<br>within the range<br>of the predicate<br>devices. | The predicate<br>devices have a<br>larger size<br>range. |
| Overall Length | Nominal 40 cm | Nominal 40 cm | Devices are the<br>same | None |
| Shaft | Tubular | Tubular | Devices are the<br>same | None |
| Shaft Material | | | Both devices are | The subject |
| | PVC | PVC | made with PVC | device is made with different plasticizer |
| Funnel Material | PVC | PVC | Both devices are made with PVC | The subject device is made with different plasticizer |
| Coating | Uncoated | Uncoated or Hydrophilic Coated | Both the predicate and subject Intermittent Urethral Catheters have uncoated catheters. | The predicate, Intermittent Urethral Catheters, also has coated catheters. |
| Biocompatibility | Evaluation and testing within the risk management process ISO 10993-1 | Evaluation and testing within the risk management process ISO 10993-1 | Biocompatibility studies of the devices conclude that the materials are safe for the intended use | None |
| Principal of Operation - Short Description of Use | Peel package open Insert catheter Empty bladder Withdraw catheter Dispose device | Peel package open Insert catheter Empty bladder Withdraw catheter Dispose device | Devices are the same | None |
| Catheter Tip Configurations | Tiemann and Nelaton- Robinson | Tiemann, Nelaton-Robinson, and Olive | The Tiemann and Nelaton-Robison configurations are offered for the predicate and subject devices. | The Olive tip configuration is offered for the predicate device. |
| Eyelets | Yes | Yes | Devices are the same | None |
| Primary Packaging | Paper and film peel back | Paper and film peel back | Devices are the same | None |
| Secondary Packaging | Corrugated box, quantity 50 | Corrugated box, quantity 100 | | The unit quantities in the secondary |
| | | | Secondary<br>packaging<br>material is the<br>same | packaging are<br>different for<br>the predicate<br>than for the<br>subject device. |
| Shipper Case | Corrugated board | Corrugated board | Devices are the<br>same | None |
| Sterile | Yes | Yes | Devices are the<br>same | None |
| Sterilization<br>Method | Ethylene Oxide | Ethylene Oxide | Devices are the<br>same | None |
| Shelf-life | 5 Years | 3 Years | Both devices<br>have a shelf-life<br>of at least 3 years | The subject<br>device,<br>Intermittent<br>Urethral<br>Catheters,<br>have a shelf-<br>life of 5 years. |
{4}------------------------------------------------
{5}------------------------------------------------
{6}------------------------------------------------
# Non-clinical Performance testing
The bench testing performed verifies that the performance of the subject Intermittent Urethral Catheters are substantially equivalent in terms of critical performance characteristics to the predicate device. These tests include:
- Flow Rate
- Catheter Tensile properties
- . Break Strength
- Cytotoxicity ISO 10993-5 ●
- Sensitization ISO 10993-10
- Skin Irritation ISO 10993-10
#### Conclusion
The Intermittent Urethral Catheters have demonstrated through comparison of design features and performance testing that the proposed device and the predicate device are substantially equivalent. Performance test results demonstrate that the subject device meets its intended use and is as safe, as effective, and performs as well as or better than the legally marketed predicate device. It is for these reasons that the subject device can be found substantially equivalent.
{7}------------------------------------------------
# Please wait...
If this message is not eventually replaced by the proper contents of the document, your PDF viewer may not be able to display this type of document.
You can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by visiting http://www.adobe.com/go/reader_download.
For more assistance with Adobe Reader visit http://www.adobe.com/go/acrreader.
Windows is either a registered trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark of Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other countries.
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.