← Product Code [QEZ](/submissions/CV/subpart-f%E2%80%94cardiovascular-therapeutic-devices/QEZ) · K100569 # MERIT EMBOLECTOMY CATHETER MODEL ASAP100 (K100569) _Merit Medical Systems, Inc. · QEZ · Mar 11, 2011 · Cardiovascular · SESE_ **Canonical URL:** https://fda.innolitics.com/submissions/CV/subpart-f%E2%80%94cardiovascular-therapeutic-devices/QEZ/K100569 ## Device Facts - **Applicant:** Merit Medical Systems, Inc. - **Product Code:** [QEZ](/submissions/CV/subpart-f%E2%80%94cardiovascular-therapeutic-devices/QEZ.md) - **Decision Date:** Mar 11, 2011 - **Decision:** SESE - **Submission Type:** Traditional - **Regulation:** 21 CFR 870.5150 - **Device Class:** Class 2 - **Review Panel:** Cardiovascular - **Attributes:** Therapeutic ## Indications for Use The Merit Embolectomy Catheter is intended for use for the removal of fresh, soft emboli and thrombi from vessels of the arterial system. Not for use in cerebral vasculature. ## Device Story Merit Embolectomy Catheter is a dual-lumen rapid-exchange catheter designed for aspiration of fresh, soft emboli and thrombi from arterial vessels. Operated by physicians in clinical settings, the device is compatible with 0.014-inch guidewires. It features a radiopaque marker band for visualization and positioning marks for depth tracking. The device functions via manual aspiration to remove obstructions, facilitating blood flow restoration. It is a single-use, sterile device. ## Clinical Evidence Bench testing only. No clinical data provided. Testing included ISO 10555-1/2 compliance, surface condition, force at break, leakage, dimensional verification, radiodetectability, flow, lubricious coating effectiveness, guide wire compatibility, stiffness, kink resistance, marker band retention, and simulated use in tortuous paths (tracking, crossing stents, and soft emboli aspiration). Biocompatibility testing included cytotoxicity, sensitization, irritation, acute systemic toxicity, pyrogenicity, genotoxicity, and hemocompatibility. Packaging performance was validated via accelerated aging and shipping simulations. ## Technological Characteristics Dual-lumen rapid-exchange catheter; 0.068"/1.73mm max OD; 140cm working length. Compatible with 0.014" guidewires. Features radiopaque marker band and positioning marks. Standards: ISO 10555-1/2 (catheters), ISO 594-2 (Luer fittings), ISO 11135 (EtO sterilization), ISO 10993-1 (biocompatibility). Mechanical design includes lubricious coating. Non-powered, manual aspiration device. ## Regulatory 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 - Pronto V3 Extraction Catheter, Model 5003 ([K063371](/device/K063371.md)) ## Submission Summary (Full Text) > This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com. > > Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [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/). {0}------------------------------------------------ Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA text logo on the right. The FDA text logo is in blue and includes the letters "FDA" stacked on top of the words "U.S. FOOD & DRUG ADMINISTRATION". February 8, 2021 Merit Medical Systems, Inc. Lindsay Martin Regulatory Affairs Specialist 1600 West Merit Pkwy. South Jordan, Utah 84095 Re: K100569 Trade/Device Name: Merit Embolectomy Catheter Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: OEZ Dear Lindsay Martin: The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated March 11, 2011. Specifically, FDA is updating this SE Letter as an administrative correction because FDA has created a new product code to better categorize your device technology. Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Gregory O'Connell, OHT2: Office of Cardiovascular Devices, (301) 796-6075. Gregory. Oconnell(@FDA.HHS.gov. Sincerely, Digitally signed by Gregory W. Gregory W. O'connell -S O'connell -S Date: 2021.02.08 07:54:50 -05'00' 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 {1}------------------------------------------------ Image /page/1/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo features a stylized eagle with three lines representing its wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular pattern around the eagle. Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MI) 20993-0002 Merit Medical Systems, Inc. c/o Ms. Lindsay Martin 1600 West Merit Parkway South Jordan, UT 84095 Re: K100569 Trade Name: Merit Embolectomy Catheter Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: DXE Dated: February 26, 2011 Received: March 1, 2011 MAR 1 1 2011 Dear Ms. Martin: 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. Iisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading. If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical {2}------------------------------------------------ Page 2 - Ms. Linday Martin 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. ff you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR 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 Small Manufacturers, International and Consumer Assistance 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. R. Vachner Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and . Radiological Health Enclosure {3}------------------------------------------------ | 510(k) Number (if known): | K100569 | |---------------------------|----------------------------| | Device Name: | Merit Embolectomy Catheter | **Indications for Use:** The Merit Embolectomy Catheter is intended for use for the removal of fresh, soft emboli and thrombi from vessels of the arterial system. Not for use in cerebral vasculature. | Prescription Use | X | AND/OR | Over-The-Counter Use | _________________ | |-----------------------------|----------|--------|------------------------|-------------------| | (Part 21 CFR 801 Subpart D) | | | (21 CFR 801 Subpart C) | | (PLEASE DO NOT WRITE BELOW THIS LINE—CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE) } Anna R. Vahmen (Division Sign-Off) Division of Čardiovascular Devices 510(k) Number_K1 0 0569 {4}------------------------------------------------ # Section 5 510(k) Summary for K100569 ## General Provisions | Submitter Name: | Merit Medical Systems, Inc. | |----------------------|-------------------------------------------------| | Address: | 1600 West Merit Parkway, South Jordan, UT 84095 | | Telephone Number: | (801) 208-4187 | | Fax Number: | (801) 253-6905 | | Contact Person: | Lindsay Martin | | Date of Preparation: | February 26, 2010 | | Registration Number: | 1721504 | #### Subject Device Trade Name: ASAP Catheter Common/Usual Name: Merit ASAP Embolectomy Catheter Classification Name: Catheter, Embolectomy ## Predicate Device | Trade Name: | Pronto V3 Extraction Catheter, Model 5003 | |-------------------------|-------------------------------------------| | Classification Name: | Catheter, Embolectomy | | Premarket Notification: | K063371 | | Manufacturer: | Vascular Solutions, Inc. | ### Classification Class II per 21 CFR § 870.5150 DXE Product Code: Division of Cardiovascular Devices Review Branch: #### Intended Use The intended use of the Merit Embolectomy Catheter is to remove or aspirate fresh, soft emboli and thrombi from vessels of the arterial system. Not for use in cerebral vasculature. #### Device Description The Merit Embolectomy Catheter is a dual lumen rapid exchange catheter, compatible with 0.014"/0.36 mm guide wires with related accessories. The catheter has a maximum outer diameter of 0.068"/1.73mm and a working length of 140 cm. The catheter has a radiopaque marker band located approximately 2 mm proximal to the distal tip. The catheter has three (3) non-radiopaque positioning marks located approximately 90cm, 100 cm, and 110 cm proximal of the distal tip. #### Safety & Performance Tests No performance standards have been established under Section 514 of the Food, Drug and Cosmetic Act for these devices. However, a battery of tests was performed according to protocols based on the requirements of the following documents, and were shown to meet the {5}------------------------------------------------ acceptance criteria that were determined to be applicable to the safety and efficacy of the device: @ ISO 10555-1, Sterile, single-use intravascular catheters, Part 1. General requirements. @ ISO 10555-2, Sterile, single-use intravascular catheters, Part 2. Angiographic catheters @ ISO 594-2, Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment - Part 2: Lock fittings @ ISO 11135, Medical Devices - Validation and Routine Control of Ethylene Oxide Sterilization @ ISO 10993-1, Biological Evaluation of medical Devices Part 1: Evaluation and Testing, and the FDA Modified ISO 10993 Test Profile [The following is a list of all significant testing that was successfully completed: Surface Condition Force at Break Freedom from Leakage 1 - Leak under Pressure Freedom from Leakage 2- Aspiration Leak Dimensional Verification . Outside Diameter - . Effective Length - . Usable Length - . Depth Marks - . Tip Angle Radio-detectability Visual Aspiration Flow Lubricious Coating Effectiveness - Coating Lubricity and Durability Test and Accelerated Aging Assessment Coating Integrity- Dye Test Lubricious Coating Length Guide Wire Compatibility Stiffness- Proximal, Mid, Distal Section Kink Test- Proximal, Mid, Distal Section Marker Band Retention Rapid Exchange Lumen Attachment Simulated Use Testing: Tortuous Path- Tracking Tortuous Path- Guide Wire Tortuous Path- Crossing a deployed stent Tortuous Path- Soft emboli aspiration Biocompatibility Tests - . Cytotoxicity - Sensitization - . Irritation - Acute Systemic Toxicity - . Pyrogenicity - . Genotoxicity - Hemocompatibility . {6}------------------------------------------------ Packaging performance before and after exposure to accelerated aging and simulated shipping and handling conditions - . bubble emission - . dye penetration - . seal peel tensile strength - . burst strength - . visual inspection # Summary of Substantial Equivalence Based on the indications for use, design, and safety and performance test results, the subject Merit Embolectomy Catheter meets the requirements that are considered essential for its intended use and is substantially equivalent to the predicate device, the Pronto V3 Embolectomy Catheter manufactured by Vascular Solutions, Inc. --- **Source:** [https://fda.innolitics.com/submissions/CV/subpart-f%E2%80%94cardiovascular-therapeutic-devices/QEZ/K100569](https://fda.innolitics.com/submissions/CV/subpart-f%E2%80%94cardiovascular-therapeutic-devices/QEZ/K100569) **Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. 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