← Product Code [NLH](/submissions/CV/subpart-b%E2%80%94cardiovascular-diagnostic-devices/NLH) · K160242

# Reprocessed Livewire Steerable Diagnostic EP Catheter (K160242)

_Innovative Health, LLC · NLH · May 10, 2016 · Cardiovascular · SESE_

**Canonical URL:** https://fda.innolitics.com/submissions/CV/subpart-b%E2%80%94cardiovascular-diagnostic-devices/NLH/K160242

## Device Facts

- **Applicant:** Innovative Health, LLC
- **Product Code:** [NLH](/submissions/CV/subpart-b%E2%80%94cardiovascular-diagnostic-devices/NLH.md)
- **Decision Date:** May 10, 2016
- **Decision:** SESE
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 870.1220
- **Device Class:** Class 2
- **Review Panel:** Cardiovascular

## Indications for Use

The Reprocessed Livewire Steerable Diagnostic Electrophysiology Catheter can be used in the evaluation of a variety of cardiac arrhythmias from endocardial and intravascular sites.

## Device Story

Flexible electrode catheter; polyurethane shaft; platinum electrodes; steerable tip manipulated via proximal control. Used by physicians in clinical electrophysiology settings for cardiac arrhythmia evaluation. Device captures electrical signals from endocardial/intravascular sites; signals transmitted to external recording equipment for physician analysis. Output assists in diagnosis of cardiac arrhythmias. Reprocessed device; undergoes cleaning, decontamination, inspection, and functional testing to ensure performance equivalent to original device. Single-use reprocessing limit; tracked via marking system.

## Clinical Evidence

Bench testing only. Testing included biocompatibility, cleaning validation, sterilization validation, functional testing (visual, dimensional, electrical continuity/resistance, simulated use, mechanical characteristics), and electrical safety (dielectric and current leakage).

## Technological Characteristics

Polyurethane insulation/shaft; platinum electrodes. Steerable tip mechanism. Dimensions vary by model (French size 5F-7F; length 95-115cm). Connectivity: wired to external recording equipment. Sterilization: validated process. No software/algorithm.

## Regulatory Identification

An electrode recording catheter or an electrode recording probe is a device used to detect an intracardiac electrocardiogram, or to detect cardiac output or left-to-right heart shunts. The device may be unipolar or multipolar for electrocardiogram detection, or may be a platinum-tipped catheter which senses the presence of a special indicator for cardiac output or left-to-right heart shunt determinations.

## Predicate Devices

- Livewire Electrophysiology Catheter ([K102721](/device/K102721.md))
- Livewire Electrophysiology Catheter ([K022380](/device/K022380.md))

## Reference Devices

- Reprocessed Daig Livewire Electrophysiology Catheters ([K052603](/device/K052603.md))

## Submission Summary (Full Text)

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

May 10, 2016

Innovative Health, LLC Rafal Chudzik Director of Engineering 1435 North Hayden Road. Suite 100 Scottsdale, Arizona 85257

Re: K160242

Trade/Device Name: Reprocessed Livewire Steerable Diagnostic EP Catheter Regulation Number: 21 CFR 870.1220 Regulation Name: Electrode Recording Catheter or Electrode Recording Probe Regulatory Class: Class II Product Code: NLH Dated: April 5, 2016 Received: April 6, 2016

Dear Rafal Chudzik:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

FDA

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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# K160242

# ITEM NUMBERS IN SCOPE

| Item<br>Number | Device                      | Electrodes | Spacing (mm)                                      | Curve Type             | French<br>Size | Usable<br>Length (cm) |
|----------------|-----------------------------|------------|---------------------------------------------------|------------------------|----------------|-----------------------|
| 401582         | Livewire Steerable Catheter | 10         | 2-5-2                                             | Med Sweep              | 7F             | 115                   |
| 401932         | Livewire Steerable Catheter | 20         | 2-8-2-(60)-2-8-2                                  | Super Lrg Curl         | 7F             | 95                    |
| 401918         | Livewire Steerable Catheter | 20         | 2-20-2-2-2-2-2-2-<br>2-2-2-2-2-25-2-25-<br>2-25-2 | Super Lrg Curl         | 7F             | 95                    |
| 401580         | Livewire Steerable Catheter | 6          | 2-5-2                                             | Med Sweep              | 7F             | 115                   |
| 401581         | Livewire Steerable Catheter | 8          | 2-5-2                                             | Med Sweep              | 7F             | 115                   |
| 401938         | Livewire Steerable Catheter | 10         | 5-5-5                                             | Med Sweep              | 5F             | 115                   |
| 401939         | Livewire Steerable Catheter | 10         | 2-2-2                                             | Med Sweep              | 5F             | 115                   |
| 401940         | Livewire Steerable Catheter | 10         | 2-5-2                                             | Med Sweep              | 5F             | 115                   |
| 401941         | Livewire Steerable Catheter | 10         | 2-8-2                                             | Extra Lrg Curl         | 5F             | 115                   |
| 401990         | Livewire Steerable Catheter | 10         | 2-2-2                                             | Extra Lrg Curl         | 5F             | 115                   |
| 401991         | Livewire Steerable Catheter | 10         | 2-5-2                                             | Extra Lrg Curl         | 5F             | 115                   |
| 401575         | Livewire Steerable Catheter | 10         | 2-5-2                                             | Med Sweep              | 6F             | 115                   |
| 401915         | Livewire Steerable Catheter | 10         | 2-5-2                                             | Extra Lrg Curl         | 6F             | 115                   |
| 401923         | Livewire Steerable Catheter | 10         | 2-2-2                                             | Extra Lrg Curl         | 6F             | 115                   |
| 401926         | Livewire Steerable Catheter | 10         | 2-8-2                                             | Extra Lrg<br>Sweep CSL | 6F             | 115                   |
| 401904         | Livewire Steerable Catheter | 20         | 2-10-2                                            | Super Lrg Curl         | 7F             | 95                    |
| 401905         | Livewire Steerable Catheter | 20         | 5-5-5                                             | Super Lrg Curl         | 7F             | 95                    |
| 401914         | Livewire Steerable Catheter | 20         | 2-5-2                                             | Super Lrg Curl         | 7F             | 95                    |
| 401908         | Livewire Steerable Catheter | 20         | 2-2-2                                             | Med Curl               | 7F             | 115                   |
| 401917         | Livewire Steerable Catheter | 8          | 2-2-2                                             | Med Sweep              | 6F             | 115                   |
| 401949         | Livewire Steerable Catheter | 8          | 2-2-2                                             | Lrg Sweep              | 6F             | 115                   |
| 401600         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Med Sweep              | 6F             | 115                   |
| 401603         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Med Curl               | 6F             | 115                   |
| 401572         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Med Sweep              | 6F             | 115                   |
| 401606         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Lrg Sweep              | 6F             | 115                   |
| 401933         | Livewire Steerable Catheter | 4          | 5-5-5                                             | Med Sweep              | 6F             | 115                   |
| 401934         | Livewire Steerable Catheter | 4          | 5-5-5                                             | Lrg Sweep              | 6F             | 115                   |
| 401576         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Sml Sweep              | 7F             | 115                   |
| 401577         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Med Sweep              | 7F             | 115                   |
| 401578         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Lrg Sweep              | 7F             | 115                   |
| 401586         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Sml Curl               | 7F             | 115                   |
| 401587         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Med Curl               | 7F             | 115                   |
| 401588         | Livewire Steerable Catheter | 4          | 2-5-2                                             | Lrg Curl               | 7F             | 115                   |

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# Indications for Use

510(k) Number (if known) K160242

#### Device Name

Reprocessed Livewire Steerable Diagnostic Electrophysiology Catheter

Indications for Use (Describe)

The Reprocessed Livewire Steerable Diagnostic Electrophysiology Catheter can be used in the evaluation of a variety of cardiac arrhythmias from endocardial and intravascular sites.

| 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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# SECTION 5: 510(k) SUMMARY

As required by 21 CFR 807.92(c)

# Submitter's Name and Address:

Innovative Health, LLC. 1435 N. Hayden Road, Suite 100 Scottsdale, AZ 85257

### Contact Name and Information:

Rafal Chudzik Director of Engineering (602) 326-7716 (cell) (480) 525-6006 (office) (844) 965-9359 (fax) rchudzik@innovative-health.com

#### Date prepared:

January 28, 2016

### Device Information:

| Trade/Proprietary Name: | Reprocessed Livewire Steerable Diagnostic<br>Electrophysiology Catheters |
|-------------------------|--------------------------------------------------------------------------|
| Common Name:            | Diagnostic Electrophysiology Catheter                                    |
| Classification Name:    | Catheter, Recording, Electrode, Reprocessed                              |
| Classification Number:  | Class II, 21 CFR 870.1220                                                |
| Product Code:           | NLH                                                                      |

#### Predicate Device:

| 510(k) Number | 510(k) Title                        | Manufacturer     |
|---------------|-------------------------------------|------------------|
| K102721       | Livewire Electrophysiology Catheter | St. Jude Medical |
| K022380       | Livewire Electrophysiology Catheter | St. Jude Medical |

#### Reference Device:

| 510(k) Number | 510(k) Title                                             | Reprocessor            |
|---------------|----------------------------------------------------------|------------------------|
| K052603       | Reprocessed Daig Livewire<br>Electrophysiology Catheters | Alliance Medical Corp. |

### Device Description:

The Reprocessed Livewire Steerable Diagnostic Electrophysiology Catheter is a flexible electrode catheter constructed of a polyurethane insulation/shaft and incorporates platinum electrodes. The active tip may be manipulated by remote means located at the proximal end of the catheter.

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# Indications for Use:

The Reprocessed Livewire Steerable Diagnostic Electrophysiology Catheter can be used in the evaluation of a variety of cardiac arrhythmias from endocardial and intravascular sites.

# Technological Characteristics:

The purpose, design, materials, function, and intended use of the Reprocessed Livewire Steerable Diagnostic Electrophysiology (EP) Catheters are identical to the predicate devices. There are no changes to the claims, clinical applications, patient population, performance specifications, or method of operation. In addition, Innovative Health's reprocessing of these devices includes removal of visible soil and decontamination. Each device is inspected and function tested prior to packaging and labeling.

# Functional and Safety Testing:

Bench and laboratory testing was conducted to demonstrate performance (safety and effectiveness) of the Reprocessed Livewire Steerable Diagnostic EP Catheter. This included the following:

- Biocompatibility ●
- Cleaning Validation .
- Sterilization Validation ●
- Functional Testing ●
	- . Visual Inspection
	- Dimensional Verification .
	- Electrical Continuity and Resistance .
	- Simulated Use .
	- Mechanical Characteristics
- Electrical Safety Testing
	- . Dielectric and Current Leakage
- Packaging Validation ●

The Reprocessed Livewire Steerable Diagnostic EP Catheters are reprocessed no more than one (1) time. Each device is marked and tracked. After the device has reached the maximum number of reprocessing cycles, the device is rejected from further reprocessing. Reprocessing is performed only by Innovative Health. Innovative Health restricts its reprocessing to exclude devices previously reprocessed by other reprocessors.

# Conclusion:

Innovative Health concludes that the Reprocessed Livewire Steerable Diagnostic EP Catheters are as safe and effective as the predicate devices described herein.

---

**Source:** [https://fda.innolitics.com/submissions/CV/subpart-b%E2%80%94cardiovascular-diagnostic-devices/NLH/K160242](https://fda.innolitics.com/submissions/CV/subpart-b%E2%80%94cardiovascular-diagnostic-devices/NLH/K160242)

**Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. If you're preparing [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/), [get in touch](https://innolitics.com/contact).

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