K212351 · Rex Medical, L.P. · MCW · Dec 15, 2021 · Cardiovascular
Device Facts
Record ID
K212351
Device Name
Revolution Peripheral Atherectomy System
Applicant
Rex Medical, L.P.
Product Code
MCW · Cardiovascular
Decision Date
Dec 15, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.4875
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Revolution Peripheral Atherectomy System is intended for atherectomy of the peripheral vasculature and to break apart and remove thrombus from the peripheral arteries in patients with occlusive atherosclerotic disease.
Device Story
Revolution Peripheral Atherectomy System is a sterile, single-use rotational atherectomy device. It consists of a flexible drive shaft with a distal diamond-coated spheroid burr, a guidewire, infusion assembly, collection receptacle, and a reusable power supply. Operated by a physician in a clinical setting, the device tracks over a guidewire to the target lesion. The burr rotates at high speeds (up to 140,000 RPM) to ablate occlusive material into fine particles. These particles are mechanically conveyed proximally through the catheter into an external collection receptacle. The system restores luminal patency in peripheral arteries. Benefits include effective plaque removal and thrombus management in peripheral vasculature.
Clinical Evidence
Bench testing only. Performance was evaluated through dimensional verification, plaque removal efficiency, embolization analysis, fatigue, tensile/torsional, stall, heat generation, kink bend radius, corrosion resistance, flow rate, coating integrity, and comparative surface assessment. Electrical/EMC testing (EN 60601-1, EN 60601-1-2) and extensive biocompatibility testing (cytotoxicity, hemolysis, pyrogenicity, systemic toxicity, intracutaneous, sensitization, complement activation, and thromboresistance) were performed to demonstrate safety and equivalence.
Technological Characteristics
Rotational atherectomy system; diamond-coated spheroid burr; flexible drive shaft; mains-powered reusable power supply; available in 60cm, 145cm, and 200cm lengths; burr diameters 1.33mm to 2.33mm; over-the-wire guidewire compatibility (0.014"); mechanical debris conveyance; ethylene oxide sterilization; single-use patient-contact components.
Indications for Use
Indicated for patients with occlusive atherosclerotic disease requiring atherectomy of the peripheral vasculature and removal of thrombus from peripheral arteries.
Regulatory Classification
Identification
An intraluminal artery stripper is a device used to perform an endarterectomy (removal of plaque deposits from arterisclerotic arteries.)
Predicate Devices
Revolution™ Peripheral Atherectomy System (K191419)
Submission Summary (Full Text)
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December 15, 2021
Rex Medical, L.P. Colin Valentis Project Leader and Senior Developement Engineer 555 East North Lane, Suite 5035 Conshohocken, Pennsylvania 19428
Re: K212351
Trade/Device Name: Revolution™ Peripheral Atherectomy System Regulation Number: 21 CFR 870.4875 Regulation Name: Intraluminal Artery Stripper Regulatory Class: Class II Product Code: MCW Dated: November 23, 2021 Received: November 24, 2021
Dear Colin Valentis:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K212351
Device Name Revolution Peripheral Atherectomy System
Indications for Use (Describe)
Atherectory of the peripheral vasculature and to break apart and remove thrombus from the peripheral arteries in patients with occlusive atherosclerotic disease.
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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Image /page/3/Picture/0 description: The image shows the logo for Rex Medical. The logo features the company name in bold, black lettering. A blue swoosh design wraps around the left side of the word "REX".
| Submitter: | Rex Medical, L.P.<br>555 East North Lane, Suite 5035<br>Conshohocken, PA 19428 |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact<br>Person: | Colin Valentis<br>Project Leader and Senior Development Engineer<br>Tel: (610) 940-6051<br>Fax: (610) 940-1590<br>E-mail: cvalentis@rexmedical.com |
| Date Prepared: | July 30th, 2021 |
| Trade Name: | Revolution™ Peripheral Atherectomy System |
| Common<br>Name: | Peripheral Atherectomy Catheter |
| Classification<br>Name: | Intraluminal Artery Stripper (21 CFR 870.4875) |
| Product Code: | MCW |
| Regulatory<br>Class: | Class II |
| Predicate<br>Device: | K191419<br>Revolution™ Peripheral Atherectomy System<br>Rex Medical, L.P. |
| Device<br>Description: | The Revolution Peripheral Atherectomy System is sterile, single-use device designed<br>for atherectomy of the peripheral vasculature and to break apart and remove thrombus<br>from the peripheral arteries in patients with occlusive atherosclerotic disease.<br><br>The Revolution device incorporates a flexible drive shaft designed to track over the<br>Revolution guidewire. Attached to the distal end of the drive shaft is a diamond coated<br>spheroid shaped burr which rotates at high speed to ablate occlusive material and<br>restore luminal patency. Power is derived from a mains source and converted using the<br>reusable power supply. During treatment, the rotating burr ablates material into fine<br>particles. This particulate is conveyed proximally by a mechanical means through the<br>catheter and handle into a collection receptacle that resides outside the patient. The<br>device is available in 145cm, 200cm, and 60cm lengths with burr diameters of 1.33mm,<br>1.66mm, 2.00mm, and 2.33mm.<br><br>The Revolution Peripheral Atherectomy System consists of the following components:<br>1. Single-use Revolution Device (provided sterile)<br>2. Single-use Revolution .014" Guidewire (provided sterile)<br>3. Single-use infusion assembly (provided sterile)<br>4. Single-use collection receptacle (provided sterile)<br>5. Single-use guidewire clip (provided sterile)<br>6. Reusable power supply (provided non-sterile) |
| Indication for<br>Use: | The Revolution Peripheral Atherectomy System is intended for atherectomy of the<br>peripheral vasculature and to break apart and remove thrombus from the peripheral<br>arteries in patients with occlusive atherosclerotic disease. |
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Image /page/4/Picture/0 description: The image shows the logo for Rex Medical. The logo features the text "REX MEDICAL" in a bold, sans-serif font. The word "REX" is slightly larger than "MEDICAL". A blue swoosh design wraps around the left side of the word "REX", adding a dynamic element to the logo. The overall design is clean and professional, conveying a sense of reliability and innovation.
510(k) Summa Per 21 CFR 807.
Technological The proposed Revolution Peripheral Atherectomy System is substantially equivalent to Characteristics the currently marketed Revolution Peripheral Atherectomy System (K191419). The Comparison: subject and predicate devices share the following technological characteristics:
- . Intended Use
- . Fundamental Cutting Mechanism
- Fundamental Scientific Technology .
- Principles of Operation ●
- Conditions of Use ●
- . Sterilization Method
The differences between the subject and predicate device include the addition of several product codes and modifications to the construction and materials of certain components.
Changes in catheter material and drive wire construction were implemented in order to reduce the total stiffness of the system to improve performance in highly tortuous anatomy.
The additional product code offerings include a 2.33mm bit, a 200cm length, and lowprofile sheath options for the 1.66mm and 2.00mm bits which reduces the sheath compatibility to 6F.
| Description | Revolution Peripheral<br>Atherectomy System<br>(Predicate) | Revolution Peripheral<br>Atherectomy System<br>(Subject) |
|-------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------|
| 510(k) Number | K191419 | K212351 |
| Indications for Use | Atherectomy of the peripheral<br>vasculature and to break apart<br>and remove thrombus from<br>the peripheral arteries in<br>patients with occlusive<br>atherosclerotic disease. | Unchanged |
| Cutting Mechanism | Spheroid diamond coated burr | Unchanged |
| Device Type | Rotational | Unchanged |
| Burr Advancement | Direct-Push Type | Unchanged |
| Debris Collection | Continuous collection and<br>removal of excised debris via<br>mechanical conveyance | Unchanged |
| Max. Rotational Speed | 140,000 RPM | Unchanged |
| Guidewire Exchange | Over-the-Wire | Unchanged |
| Guidewire Compatibility | 0.014" x 335cm | 0.014" x 335cm<br>0.014" x 445cm |
| Sheath Compatibility | 4F - 7F | Unchanged |
| Catheter Working Length | 60cm<br>145cm | 60cm<br>145cm<br>200cm |
| Crossing Profile | 1.33mm<br>1.66mm<br>2.00mm | 1.33mm<br>1.66mm<br>2.00mm<br>2.33mm |
| Capital Equipment | No | Unchanged |
| Rotation Profile | Axial, Rotational | Unchanged |
| Infusion | Yes, Saline | Unchanged |
| Sterilization | Ethylene Oxide | Unchanged |
| Single-Use | Yes | Unchanged |
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Image /page/5/Picture/0 description: The image shows the logo for Rex Medical. The logo features the text "REX MEDICAL" in a bold, sans-serif font. A blue crescent shape is above and to the left of the text, adding a visual element to the logo. The overall design is clean and professional.
**510(k) Summary**
(Per 21 CFR 807.92)
1 CFR 807.92)
K212351
| Non-Clinical<br>Performance<br>Data: | To demonstrate the substantial equivalence of the Revolution™ Peripheral Atherectomy<br>System to the selected predicate device, the performance and technological<br>characteristics will be evaluated in an anatomically correct model and under simulated<br>biological conditions, when necessary, in the following tests:<br><br>Dimensional Verification Testing Testing in Simulated Lesion Plaque Removal Efficiency and Embolization Analysis Fatigue Testing Tensile & Torsional Testing Stall Testing |
|--------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|--------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
- Heat Generation Testing
- Kink Bend Radius Testing
- Corrosion Resistance Testing .
- Flow Rate Testing ●
- Coating Integrity Testing
- Comparative Surface Assessment ●
- . Guidewire Testing
- Corrosion, Tensile, Flex, Fracture, and Fatigue O
- . Sterilization Validation
- Shelf Life
- Simulated Distribution ●
- Electrical and EMC Testing ●
- EN 60601-1 O
- o EN 60601-1-2
- Biocompatibility Testing ●
- Cytotoxicity Study Using the ISO Elution Method o
- O ASTM Hemolysis Study
- USP Rabbit Pyrogen Study, Material Mediated O
- ISO Systemic Toxicity Study in Mice O
- ISO Intracutaneous Study in Rabbits O
- ISO Maximization Sensitization Study Extract o
- C3a Complement Activation Assay O
- SC5b-9 Complement Activation Assay O
- In Vivo Thromboresistance Study O
- Partial Thromboplastin Time O
- Heparinized Blood Platelet and Leukocyte Count o
- Conclusion: Rex Medical, L.P. considers the proposed Revolution Peripheral Atherectomy System to be substantially equivalent to the currently marketed Revolution Peripheral Atherectomy System (K191419) based on the intended use, technological characteristics, and performance testing included in this submission.
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.