Indigo Aspiration System - Penumbra Engine Pump, Indigo Aspiration System - Penumbra Engine Pump Canister
Device Facts
| Record ID | K180105 |
|---|---|
| Device Name | Indigo Aspiration System - Penumbra Engine Pump, Indigo Aspiration System - Penumbra Engine Pump Canister |
| Applicant | Penumbra, Inc. |
| Product Code | QEW · Cardiovascular |
| Decision Date | Mar 8, 2018 |
| Decision | SESE |
| Submission Type | Special |
| Regulation | 21 CFR 870.5150 |
| Device Class | Class 2 |
| Attributes | Therapeutic |
Indications for Use
INDIGO Aspiration Catheters and Separators As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral and venous systems. INDIGO Aspiration Tubing As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump. Penumbra Aspiration Pump The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
Device Story
Indigo Aspiration System removes thrombus from peripheral/venous vasculature via continuous aspiration. System components: Aspiration Catheter, Separator, Aspiration Tubing, Penumbra Engine Pump, and Canister. Catheter introduced via guide catheter/sheath to occlusion site; pump provides vacuum pressure; Separator clears catheter lumen if blocked. Engine Pump is electromechanical vacuum source; 1000 mL reservoir Canister with stop-flow filter prevents fluid ingress. Used in OR or interventional labs by physicians. Pump/Canister are non-patient contacting capital equipment. Output is vacuum pressure; clinical benefit is thrombus removal to restore vessel patency.
Clinical Evidence
Bench testing only. No clinical data. Performance verified via electrical safety/EMC testing (IEC 60601-1, IEC 60601-1-2), environmental testing, dimensional inspection, and 500-hour reliability/life testing. All tests met acceptance criteria.
Technological Characteristics
Electromechanical vacuum pump; 100-240 Vac, 50/60 Hz. 1000 mL reservoir canister with stop-flow filter. Compliant with IEC 60601-1, IEC 60601-1-2, and EN ISO 10079-1. Packaging validated per ASTM D4169. Non-sterile capital equipment.
Indications for Use
Indicated for removal of fresh, soft emboli and thrombi from peripheral arterial and venous vessels. Used with Penumbra Aspiration Pump as a vacuum source.
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
- Indigo Aspiration System (K161523)
Reference Devices
- Penumbra Pump MAX (K122756)
Submission Summary (Full Text)
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March 8, 2018
Penumbra, Inc. Mr. Richard Kimura Regulatory Specialist One Penumbra Place Alameda, California 94502
Re: K180105
Trade/Device Name: Indigo Aspiration System - Penumbra Engine Pump and Canister Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy Catheter Regulatory Class: Class II Product Code: DXE Dated: January 15, 2018 Received: January 16, 2018
Dear Mr. Kimura:
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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820);
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# Page 2 - Mr. Richard Kimura
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 medical devices and radiation-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,
# 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) K180105
Device Name
Indigo Aspiration System-Penumbra Engine Pump and Canister
Indications for Use (Describe)
INDIGO Aspiration Catheters and Separators
As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral and venous systems.
INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump.
Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### 1 510(k) Summary
(as required by 21 CFR 807.92)
Pursuant to Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, Penumbra, Inc. is providing the summary of Substantial Equivalence for the Indigo Aspiration System® - Penumbra Engine™ Pump and Canister.
#### 1.1 Sponsor/Applicant Name and Address
Penumbra, Inc. One Penumbra Place Alameda, CA 94502 USA
#### 1.2 Sponsor Contact Information
Richard Kimura Regulatory Affairs Specialist Phone: (510) 995-2034 FAX: (510) 217-6414 Email: rkimura@penumbrainc.com
#### 1.3 Date of Preparation of 510(k) Summary
January 12, 2018
#### 1.4 Device Trade or Proprietary Name
Indigo Aspiration System® - Penumbra Engine™ Pump and Canister
#### 1.5 Device Classification
| Regulatory Class: | II |
|-----------------------|-----------------------|
| Classification Panel: | Cardiovascular |
| Classification Name: | Catheter, Embolectomy |
| Regulation Number: | 21 CFR §870.5150 |
| Product Code: | DXE |
#### 1.6 Predicate and Reference Devices
| 510(k) Number / Clearance Date | Name of Device | Name of Manufacturer |
|------------------------------------|--------------------------|---------------------------------------------------------------|
| Predicate Device | | |
| K161523 cleared on July 1, 2016 | Indigo Aspiration System | Penumbra, Inc.<br>One Penumbra Place<br>Alameda, CA 94502 USA |
| Reference Device | | |
| K122756 cleared on October 2, 2012 | Penumbra Pump MAX | Penumbra, Inc.<br>One Penumbra Place<br>Alameda, CA 94502 USA |
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#### Predicate Comparison 1.7
| | Predicate Device | Subject Device |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------|
| Trade Name | Indigo System (with Penumbra Pump MAX<br>and Canister) | Indigo System (with Penumbra Engine<br>Pump and Canister) |
| 510(k) No. | K161523 | To Be Determined |
| Classification | Class II, DXE | SAME |
| Indication for Use | INDIGO Aspiration Catheters and<br>Separators<br>As part of the INDIGO Aspiration System,<br>the INDIGO Aspiration Catheters and<br>Separators are indicated for the removal of<br>fresh, soft emboli and thrombi from vessels<br>of the peripheral arterial and venous<br>systems.<br><br>INDIGO Aspiration Tubing<br>As part of the INDIGO Aspiration System,<br>the INDIGO Sterile Aspiration Tubing is<br>indicated to connect the INDIGO Aspiration<br>Catheters to the Penumbra Aspiration<br>Pump.<br><br>Penumbra Aspiration Pump<br>The Penumbra Aspiration Pump is indicated<br>as a vacuum source for Penumbra<br>Aspiration Systems. | SAME |
| Aspiration Pump | | |
| Trade Name | Penumbra Pump MAX and Canister | Penumbra Engine Pump and Canister |
| IEC 60601-1<br>Compliance | Yes | SAME |
| IEC 60601-1-2<br>Compliance | Yes | SAME |
| Voltage | 100-115 Vac/230 Vac | 100-240 Vac |
| Frequency | 50 Hz/60 Hz | SAME |
| Sterilization | Non sterile | SAME |
| Shelf Life | N/A | SAME |
| The Aspiration Catheters, Separators, and Aspiration Tubings are unchanged and remain identical to<br>those of the currently cleared Indigo System (K161523). | | |
#### 1.8 Device Description
The Indigo Aspiration System ("Indigo System") is intended for the removal of fresh, soft emboli and thrombi from vessels of the peripheral and venous systems using the Indigo Aspiration Catheter, Indigo Separator, Indigo Aspiration Tubing, and Penumbra
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Aspiration Pump. The Indigo System was most recently cleared under K161523.
The Indigo System is designed to remove thrombus from the vasculature using continuous aspiration. The Aspiration Catheter targets aspiration from the Aspiration Pump directly to the thrombus. The Separator may be used to clear the lumen of the Aspiration Catheter should it become blocked with thrombus. The use of the Separator may not be necessary when using an Aspiration Catheter with an I.D. of 0.054in or larger. The Aspiration Catheter is introduced through a guide catheter or long femoral sheath and into the site of the primary occlusion. The Aspiration Catheter is used with the Aspiration Pump to aspirate thrombus from an occluded vessel. As needed, a Separator may be deployed from the Aspiration Catheter to assist with thrombus removal. The Separator is advanced and retracted through the Aspiration Catheter at the proximal margin of the primary occlusion to facilitate clearing of the thrombus from the Aspiration Catheter tip. For the aspiration source, the Aspiration Catheter is used in conjunction with the Aspiration Pump, which is connected using the Aspiration Tubing and Canister. The Aspiration Catheter is provided with a steam shaping mandrel and rotating hemostasis valve, and a peelable sheath. The Separator is provided with an introducer and torque device. The Aspiration Catheters and Separators are visible under fluoroscopy.
The Penumbra Engine Pump and Canister
The Penumbra Engine Pump ("Engine Pump") is an electromechanical device designed to create vacuum pressure for use with the Indigo System. The Engine Pump maintains vacuum pressure for 3 hours of continuous use and has an operating life of ≥ 500 hours. The pump can be used in environments with 100 - 240 Vac and 50/60 Hz. The Engine Pump is intended for use in operating rooms or interventional catheterizations laboratories. The Engine Pump and Canister do not come into contact with the patient. The Engine Pump Canister is a 1000 mL minimum volume reservoir which is an accessory to the Engine Pump. The Canister has a lid with a stop-flow filter to prevent excess fluid from entering the pump. The patient port on the lid is sized to accept the Suction Connector on the Indigo Aspiration Tubing.
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Image /page/6/Picture/1 description: The image shows the Penumbra company logo. The logo consists of the word "Penumbra" in red font, followed by a red circle with a white "P" inside. The "P" is stylized with a horizontal line extending beyond the circle.
#### 1.9 Indications for Use
# INDIGO Aspiration Catheters and Separators
As part of the INDIGO Aspiration System, the INDIGO Aspiration Catheters and Separators are indicated for the removal of fresh, soft emboli and thrombi from vessels of the peripheral arterial and venous systems.
### INDIGO Aspiration Tubing
As part of the INDIGO Aspiration System, the INDIGO Sterile Aspiration Tubing is indicated to connect the INDIGO Aspiration Catheters to the Penumbra Aspiration Pump.
### Penumbra Aspiration Pump
The Penumbra Aspiration Pump is indicated as a vacuum source for Penumbra Aspiration Systems.
### 1.10 Summary of Non-Clinical Data
As required under Section 12, Part (a)(i)(3A) of the Safe Medical Devices Act of 1990, a summary of any information regarding substantial equivalence of the device follows.
Included in this section are summary descriptions of the testing (or rationale for not testing if not applicable to the Engine Pump and Canister) which substantiates the performance of the subject Indigo System with Engine Pump and Canister as well as its substantial equivalence to the predicate device:
- Biocompatibility .
- Design Verification (Bench-Top Testing and Electrical Safety/EMC Testing) .
- Shelf Life ●
- Sterilization .
- Packaging
The subject Indigo System with Engine Pump and Canister met all established requirements.
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### 1.10.1 Biocompatibility
The subject and predicate Indigo System sterile devices are identical. There are no changes to the previously provided biocompatibility data of the Indigo System materials sterile devices, which were reviewed and cleared under K161523. No additional biocompatibility testing is required or was performed for the Indigo System sterile devices.
The Indigo System Engine Pump is a non-sterile reusable piece of capital equipment. The pump does not contact the patient, nor is it introduced into the sterile field. As such, biocompatibility testing is not required and was not performed for the pump. The Indigo System Engine Pump Canister also does not contact the patient, nor is it introduced into the sterile field. Furthermore, blood or body fluids collected in the canister are not reintroduced to the patient. As such, biocompatibility testing is not required and was not performed for the Canister.
### 1.10.2 Design Verification (Bench-top Testing and Electrical Safety/EMC Testing)
The subject and predicate Indigo System sterile devices are identical. There are no changes to the design specifications and performance characteristics of the Indigo System sterile devices. Therefore, all previous bench-top testing data which were reviewed and cleared under K161523 continue to support the subject Indigo System sterile devices. No additional bench-top testing is required or was performed for the Indigo System sterile devices.
Bench-top testing was conducted to evaluate the physical and mechanical properties of the subject Indigo System Engine Pump and Canister. All bench-top studies were conducted using good scientific practices and statistical sampling methods as required by the Penumbra Design Control procedures. Performance testing was based on the design specifications, risk analysis, performance standards, and guidance documents.
The Indigo System Engine Pump and Canister also underwent electrical safety and EMC testing in accordance with the requirements of IEC 60601-1 and IEC 60601-1-2. Testing was performed by Intertek, a nationally recognized test laboratory. The Engine Pump and Canister passed all tests and met all acceptance criteria.
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| Attribute | Sample<br>Size | Specification | Acceptance Criteria | Results |
|------------------------------------------------------------|----------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|-----------|
| Pump - Electrical<br>Safety | N=1 | The Pump conforms to IEC 60601-1<br>and IEC 60601-1-2 requirements<br>including international worldwide<br>variants (CB Scheme). The Pump is<br>compliant with EN ISO 10079-1. | 100% Pass | 100% Pass |
| Pump - Environmental<br>Testing | N=5 | Pump performance specifications<br>under environmental conditions | 100% Pass | 100% Pass |
| Pump - Dimensional<br>Inspection | N=5 | Dimensional specifications per<br>Product Specification | 100% Pass | 100% Pass |
| Pump - Inspection of<br>Design Features | N=5 | Design specifications per Product<br>Specification | 100% Pass | 100% Pass |
| Pump - Performance | N=5 | Performance specifications per<br>Product Specification | 100% Pass | 100% Pass |
| Pump - Performance at<br>variable voltage and<br>frequency | N=5 | Performance specifications per<br>Product Specification | 100% Pass | 100% Pass |
| Pump and Canister -<br>500 hour Use Testing | N=5 | Performance specifications after 500<br>hour use | 100% Pass | 100% Pass |
| Pump Canister -<br>Inspection of Design<br>Features | N=5 | Design specifications per Product<br>Specification | 100% Pass | 100% Pass |
| Pump Canister -<br>Performance | N=5 | Performance specifications per<br>Product Specification | 100% Pass | 100% Pass |
| Pump and Canister -<br>Simulated Use | N=5 | Pump and Canister use<br>specifications | 100% Pass | 100% Pass |
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Image /page/9/Picture/1 description: The image shows the Penumbra company logo. The word "Penumbra" is written in a red, sans-serif font. To the right of the word is a red circle with a white "P" inside. The logo is simple and modern.
### 1.10.3 Shelf Life
The subject and predicate Indigo System sterile devices are identical. There are no changes to the previously provided shelf life data for the sterile devices which were reviewed and cleared under K161523. No additional shelf life testing is required or was performed for the Indigo System sterile devices.
The proposed Indigo System Engine Pump is a reusable piece of capital equipment that is provided non-sterile. Therefore, shelf life testing is not applicable to the Engine Pump and shelf life testing was not performed. The Engine Pump is established for 500 hours of use based on completed life (reliability) testing. The Engine Pump Canister does not have an established shelf life.
### 1.10.4 Sterilization
The subject and predicate Indigo System sterile devices are identical. There are no changes to the previously provided sterilization data of the devices, which were reviewed and cleared under K161523. No additional sterilization testing is required or was performed for these devices.
Sterilization testing is not applicable to the proposed Indigo System Engine Pump and Canister. Both are supplied non-sterile and are not intended to be sterilized.
### 1.10.5 Packaging
The packaging materials and process of the subject and predicate Indigo System sterile devices are identical. There are no changes to the previously provided packaging material listing or the packaging process for these devices, which were reviewed and cleared under K161523. No additional packaging testing is required or was performed for the Indigo System sterile devices.
The packaging materials for the proposed Indigo System Engine Pump and Canister are similar to those used for the predicate Indigo System Penumbra Pump MAX and Canister. The Engine Pump and Canister are packaged to ensure that damage does not occur during shipping. The Engine Pump is packaged in a protective, corrugated, cardboard 275 B/C Flute Double Wall RSC shipping container with custom shaped foam inserts. Pumps used for Design Verification and Packaging Validation testing first underwent transportation conditioning per ASTM D4169, Distribution Cycle 3,
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Image /page/10/Picture/1 description: The image shows the logo for Penumbra, Inc., a global healthcare company focused on innovative therapies. The logo features the word "Penumbra" in a bold, red font. To the right of the name is a stylized "P" inside a red circle, with a white line bisecting the "P" and extending beyond the circle's edge.
Assurance Level 3 to ensure packaging integrity. The Canister is packaged individual in 200 pound E-Flute container product boxes. The Canister box is then packaged in protective, corrugated, cardboard 275 B/C Flute Double Wall RSC shipping containers (8 canister boxes per shipper).
# 1.11 Summary of Substantial Equivalence
The subject Indigo System disposable devices are unchanged and remain identical to those of the predicate Indigo System with regard to indications, function, design, materials, biocompatibility, packaging, and sterilization. The subject Indigo System Engine Pump and Canister are substantially equivalent to the predicate device with regard to intended use, operating principle, design concept, materials, and packaging processes.
