← Product Code [KPM](/submissions/GU/subpart-f%E2%80%94therapeutic-devices/KPM) · K170405

# BD Curve Ascites Shunt (K170405)

_Care Fusion · KPM · Nov 2, 2017 · Gastroenterology, Urology · SESK_

**Canonical URL:** https://fda.innolitics.com/submissions/GU/subpart-f%E2%80%94therapeutic-devices/KPM/K170405

## Device Facts

- **Applicant:** Care Fusion
- **Product Code:** [KPM](/submissions/GU/subpart-f%E2%80%94therapeutic-devices/KPM.md)
- **Decision Date:** Nov 2, 2017
- **Decision:** SESK
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 876.5955
- **Device Class:** Class 2
- **Review Panel:** Gastroenterology, Urology
- **Attributes:** Therapeutic

## Indications for Use

Peritoneovenous shunting is indicated for patients with malignant or non-malignant intractable ascites (including patients with chylous ascites, hepatorenal syndrome, and idiopathic ascites), not responding to standard medical management, and not considered candidates for portal-venous shunting. The 17Fr valved peel-away introducer is intended for use in the percutaneous insertion of catheters in the peritoneal space. The 15.5Fr Pigtail Revision Catheter is indicated for revising the peritoneal catheter of a BD Curve Ascites Shunt.

## Device Story

Fully implantable peritoneovenous shunt; transfers ascitic fluid from peritoneal space to circulatory system for symptom relief. System includes pump chamber (single or double valved), venous catheter, and peritoneal catheter. Placed percutaneously via Seldinger technique. 17Fr valved peel-away introducer facilitates catheter insertion while minimizing air/fluid leakage. 15.5Fr Pigtail Revision Catheter used to replace occluded peritoneal limbs. Used in clinical settings by physicians. Provides palliative management for intractable ascites.

## Clinical Evidence

No clinical tests were conducted for this submission. Substantial equivalence is supported by bench-level performance testing, including biocompatibility, sterilization, and mechanical integrity evaluations.

## Technological Characteristics

Materials: Silicone tubing with barium sulfate stripe and silique surface treatment. Pump chamber: Silicone with silique surface treatment. Design: Fully implantable shunt with single/double valved pump chamber. Introducer: Peel-away sheath with integral valve seal and dilator. Standards: ISO 10993 (biocompatibility), ISO 11135 (EO sterilization), ISO 11607 (packaging), EN ISO 14630 (surgical implants), BS EN 1617/1618 (catheters).

## Regulatory Identification

A peritoneo-venous shunt is an implanted device that consists of a catheter and a pressure activated one-way valve. The catheter is implanted with one end in the peritoneal cavity and the other in a large vein. This device enables ascitic fluid in the peritoneal cavity to flow into the venous system for the treatment of intractable ascites.

## Special Controls

*Classification.* Class II. The special controls for this device are FDA's:(1) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(2) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),” and
(3) Backflow specification and testing to prevent reflux of blood into the shunt.

## Predicate Devices

- Denver Ascites Shunt And Percutaneous Access Kit With Ascites Shunt ([K011862](/device/K011862.md))
- Medcomp, Inc. - Valved Tearaway Introducer Generation II ([K132498](/device/K132498.md))
- CareFusion – Valved Peelable Introducers ([K122422](/device/K122422.md))

## Submission Summary (Full Text)

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>
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November 2, 2017

CareFusion Tamara Brev Regulatory Affairs Advisor 75 North Fairway Drive Vernon Hills, IL 60061

Re: K170405

> Trade/Device Name: BD Curve Ascites Shunt Regulation Number: 21 CFR§ 876.5955 Regulation Name: Peritoneo-Venous Shunt Regulatory Class: II Product Code: KPM, DYB Dated: September 29, 2017 Received: October 2, 2017

Dear Tamara Brey:

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. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unfinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit. 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.

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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); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 (DICE) 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,

Benjamin R. Fisher -S

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

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## Indications for Use

510(k) Number (if known) K170405

Device Name

BD Curve Ascites Shunt

#### Indications for Use (Describe)

Peritoneovenous shunting is indicated for patients with malignant intractable ascites (including patients with chylous ascites, hepatorenal syndrome, and idiopathic ascites), not responding to standard medical management, and not considered candidates for portal-venous shunting

The 17Fr valved peel-away introducer is intended for use in the percutaneous insertion of catheters in the peritoneal space.

The 15.5Fr Pigtail Revision Catheter is indicated for revising the peritoneal catheter of an BD Curve Ascites Shunt.

| Type of Use (Select one or both, as applicable)                               |                                                                              |
|-------------------------------------------------------------------------------|------------------------------------------------------------------------------|
| <div> <span> </span>    Prescription Use (Part 21 CFR 801 Subpart D)   </div> | <div> <span> </span>    Over-The-Counter Use (21 CFR 801 Subpart C)   </div> |

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# 510(k) SUMMARY- K170405

# A summary of 510(k) safety and effectiveness information in accordance with 21 CFR 807.92.

| SUBMITTER INFORMATION                                                                                    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                                                 |
|----------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Name                                                                                                     | CareFusion                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                                                                                 |
| Address                                                                                                  | 75 North Fairway Drive, Vernon Hills, IL 60061 USA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                                                                                                                                 |
| Phone number                                                                                             | (847) 362-9485                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                 |
| Fax number                                                                                               | (312) 949-9245                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                 |
| Establishment Registration<br>Number                                                                     | 1423507                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                 |
| Name of contact person                                                                                   | Tamara Brey                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                 |
| Date prepared                                                                                            | November 1, 2017                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                                                                                                                                 |
| DESCRIPTION OF DEVICE                                                                                    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                                                 |
| Trade or proprietary name                                                                                | BD Curve Ascites Shunt                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                                                                                                                                                 |
| Device name                                                                                              | Ascites Shunt                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                                                                                                                                 |
| Classification name                                                                                      | Peritoneo-Venous Shunt                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                                                                                                                                                 |
| Classification panel                                                                                     | Gastroenterology/Urology                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                 |
| Regulation                                                                                               | Class II per 21CFR §876.5955                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                                                                                 |
| Product Code(s)                                                                                          | KPM, DYB                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                 |
| Legally marketed device(s) to<br>which equivalence is claimed                                            | Denver Ascites Shunt And Percutaneous Access Kit With Ascites Shunt:<br>K011862<br>Medcomp, Inc. - Valved Tearaway Introducer Generation II: K132498<br>CareFusion – Valved Peelable Introducers: K122422                                                                                                                                                                                                                                                                                                                                                                          |                                                                                                                                                                                 |
| Reason for 510(k) submission                                                                             | This 510(k) submission is for minor design modifications to the Ascites<br>Shunt pump chamber and the peritoneal catheter. A minor design<br>modifications to the peritoneal revision catheter design and addition of a<br>new placement accessory. Updates to labeling include a revision of<br>placement techniques and updated patient selection considerations.                                                                                                                                                                                                                |                                                                                                                                                                                 |
| Device description                                                                                       | The Ascites Shunt is a fully implantable device that transfers fluid from the<br>peritoneal space to the circulatory system to provide symptom relief for<br>patients with malignant or non-malignant intractable ascites.                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                                                                                 |
| Intended use of the device                                                                               | Peritoneovenous shunting is indicated for patients with malignant or non-<br>malignant intractable ascites (including patients with chylous ascites,<br>hepatorenal syndrome, and idiopathic ascites), not responding to standard<br>medical management, and not considered candidates for portal-venous<br>shunting.<br>The 17Fr valved peel-away introducer is intended for use in the<br>percutaneous insertion of catheters in the peritoneal space.<br>The 15.5Fr Pigtail Revision Catheter is indicated for revising the peritoneal<br>catheter of a BD Curve Ascites Shunt. |                                                                                                                                                                                 |
| Characteristic                                                                                           | New Device                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Predicates:                                                                                                                                                                     |
|                                                                                                          |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | CareFusion Denver Ascites Shunt PAK:<br>K011862<br>Medcomp, Inc. - Valved Tearaway<br>Introducer Generation II: K132498<br>CareFusion - Valved Peelable Introducers:<br>K122422 |
| Ascites Shunt Overall<br>Design                                                                          | Shunt with pump chamber<br>(Single Valved and Double<br>Valved) with venous and<br>peritoneal catheters                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Same as predicate: CareFusion Denver<br>Ascites Shunt PAK: K011862                                                                                                              |
| Ascites Shunt Materials<br>of Construction                                                               | Tubing: Silicone with a barium<br>sulfate stripe and silique surface<br>treatment.<br>Pump Chamber Material:<br>Silicone with silique surface<br>treatment                                                                                                                                                                                                                                                                                                                                                                                                                         | Same as predicate: CareFusion Denver<br>Ascites Shunt PAK: K011862                                                                                                              |
| Ascites Shunt Placement<br>Technique                                                                     | Minimally invasive (Seldinger<br>technique) for all shunts                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Same as predicate: CareFusion Denver<br>Ascites Shunt PAK: K011862                                                                                                              |
| Ascites Shunt<br>Design Intent                                                                           | Placed percutaneously to<br>manage ascites by recirculating<br>ascitic fluid from the peritoneal<br>space to the circulatory system                                                                                                                                                                                                                                                                                                                                                                                                                                                | Same as predicate: CareFusion Denver<br>Ascites Shunt PAK: K011862                                                                                                              |
| Valved Peelable<br>Introducer Overall Design                                                             | Peel-away introducer sheath<br>which contains an integral valve<br>seal and dilator comprised of a<br>cylindrical tube with a locking<br>hub                                                                                                                                                                                                                                                                                                                                                                                                                                       | Same as predicate: Medcomp, Inc. -<br>Valved Tearaway Introducer Generation II:<br>K132498                                                                                      |
| Valved Peelable<br>Introducer Design Intent                                                              | To obtain peritoneal access and<br>facilitate catheter insertion while<br>minimizing air/fluid leakage.                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Same as predicate: CareFusion - Valved<br>Peelable Introducers: K12242                                                                                                          |
| Pigtail Revision Catheter<br>Design Intent                                                               | Placed percutaneously to<br>replace occluded peritoneal limb<br>of Ascites shunt.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Same as predicate: CareFusion Denver<br>Ascites Shunt PAK: K011862                                                                                                              |
| CONCLUSION OF DEVICE COMPARISON                                                                          |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                                                 |
| The technological characteristics of the proposed devices are substantially equivalent to the predicates |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                                                 |

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### SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE COMPARED TO THE PREDICATE DEVICE

## PERFORMANCE DATA

### SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE

Bench-level testing was carried out on Ascites Shunt to demonstrate substantial equivalence. The performance testing requirements were determined by the predicate devices and further defined by the standards listed below. The testing and evaluation conducted includes displacement volume, resealing capacity, interface testing, declogging, aging, biocompatibility, sterilization, and EO residuals.

Performance Test Summary

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| Biocompatibility                                                                                                   | ISO 10993-1: Part 1, Biological Evaluation of Medical Devices: Evaluation and<br>Testing within a Risk Management Process.                                                                                           |
|--------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Biocompatibility                                                                                                   | ISO 10993-5:2009/(R) 2014: Part 5, Biological Evaluation of Medical Devices --<br>Tests For In Vitro Cytotoxicity                                                                                                    |
| Biocompatibility                                                                                                   | ISO 10993-7 Second Edition 2008-10-15: Part 7, Biological Evaluation Of Medical<br>Devices - Ethylene Oxide Sterilization Residuals [Including: Technical Corrigendum<br>1 (2009)]                                   |
| Biocompatibility                                                                                                   | ISO 10993-12, 2012 Biological Evaluation Of Medical Devices - Part 12: Sample<br>Preparation and Reference Materials.                                                                                                |
| Biocompatibility                                                                                                   | ISO 10993-17:2002: Part 17, Biological evaluation of medical devices -<br>Establishment of allowable limits for leachable substances                                                                                 |
| Biocompatibility                                                                                                   | ISO 10993-18:2005: Part 18, Biological evaluation of medical devices - Chemical<br>characterization of materials                                                                                                     |
| Sterilization                                                                                                      | ISO 11135 2nd Ed: Sterilization of Health-Care Products -Ethylene Oxide -<br>Requirements for the Development, Validation and Routine Control of a Sterilization<br>Process for Medical Devices                      |
| Sterilization                                                                                                      | ISO 11138-1 2nd Ed: Sterilization of Health Care Products - Biological Indicators -<br>Part 1: General Requirements                                                                                                  |
| Sterilization                                                                                                      | ISO 11737-1 2nd Ed: Sterilization of Medical Devices – Microbiological Methods<br>Part 1                                                                                                                             |
| Sterilization                                                                                                      | AAMI TIR28:2009(R) 2013: Product Adoption and Process Equivalency for Ethylene<br>Oxide Sterilization                                                                                                                |
| Sterilization                                                                                                      | ANSI/AAMI ST72:2011: Bacterial endotoxins - Test methods, routine monitoring,<br>and alternatives to batch testing                                                                                                   |
| Packaging                                                                                                          | AAMI / ANSI / ISO 11607-1:2006/(R)2010: Packaging For Terminally Sterilized<br>Medical Devices - Part 1:Requirements For Materials, Sterile Barrier Systems And<br>Packaging Systems [Including: Amendment 1 (2014)] |
| Packaging                                                                                                          | AAMI/ANSI/ISO 11607-2:2006/(R)2010: Packaging For Terminally Sterilized Medical<br>Devices - Part 2: Validation Requirements For Forming, Sealing And Assembly<br>Processes [Including: Amendment 1 (2014)]          |
| Risk Management                                                                                                    | BS EN ISO 14971: 2012 Medical Devices. Application of Risk Management to<br>Medical Devices.                                                                                                                         |
| Performance                                                                                                        | EN ISO 14630: Non-active Surgical Implants - General Requirements                                                                                                                                                    |
| Performance                                                                                                        | BS EN 1617: 1997 Sterile Drainage Catheters and Accessory Devices for Single Use                                                                                                                                     |
| Performance                                                                                                        | BS EN 1618: 1997 Catheters other than Intravascular Catheters - Test Methods for<br>Common Properties                                                                                                                |
| SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL<br>EQUIVALENCE AND/OR OF CLINICAL INFORMATION |                                                                                                                                                                                                                      |
|                                                                                                                    | N/A - No clinical tests were conducted for this submission.                                                                                                                                                          |

## CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA

The results of the non-clinical tests show that the CareFusion Ascites Shunt is as safe, as effective, and performs as well as the legally marketed predicate devices.

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**Source:** [https://fda.innolitics.com/submissions/GU/subpart-f%E2%80%94therapeutic-devices/KPM/K170405](https://fda.innolitics.com/submissions/GU/subpart-f%E2%80%94therapeutic-devices/KPM/K170405)

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