MEDCOMP SPLIT-CATH II

K040318 · Medcomp · MSD · Feb 3, 2005 · Gastroenterology, Urology

Device Facts

• Record ID: K040318
• Device Name: MEDCOMP SPLIT-CATH II
• Applicant: Medcomp
• Product Code: MSD · Gastroenterology, Urology
• Decision Date: Feb 3, 2005
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 876.5540
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Medcomp Split-Cath II is indicated for use in attaining long-term vascular access for hemodialysis and apheresis. It may be inserted percutaneously and is primarily placed in the internal jugular vein. Alternate insertion site is the subclavian vein.

Device Story

Medcomp Split-Cath II is a double-lumen, long-term hemodialysis and apheresis catheter. Device features two segregated 'D'-shaped lumens, tapered distal tip with eight side holes for 360-degree blood uptake/return, and a fixed polyester cuff for tissue ingrowth. Lumens are designed to be split/peeled apart prior to insertion for free-floating placement within the vessel. Extensions include color-coded luer connectors and clamps. Device is placed by a physician via percutaneous insertion, primarily in the internal jugular vein. It facilitates blood removal and return for extracorporeal therapy, providing long-term vascular access.

Clinical Evidence

No clinical data provided. Substantial equivalence established via bench testing (tensile strength, joint strength, leakage, recirculation, flow performance, flexural, and lumen peel) and biocompatibility testing per USP XXII standards.

Technological Characteristics

Polycarbonate/polyurethane double-lumen catheter; polyester cuff for tissue ingrowth. Sensing/actuation: mechanical blood flow. Dimensions: tapered distal tip with eight side holes. Sterilization: not specified. Software: none.

Indications for Use

Indicated for long-term vascular access for hemodialysis and apheresis in adult patients. Inserted percutaneously, primarily in the internal jugular vein, with the subclavian vein as an alternate site.

Regulatory Classification

Identification

A blood access device and accessories is a device intended to provide access to a patient's blood for hemodialysis or other chronic uses. When used in hemodialysis, it is part of an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and provides access to a patient's blood for hemodialysis. The device includes implanted blood access devices, nonimplanted blood access devices, and accessories for both the implanted and nonimplanted blood access devices.(1) The implanted blood access device is a prescription device and consists of various flexible or rigid tubes, such as catheters, or cannulae, which are surgically implanted in appropriate blood vessels, may come through the skin, and are intended to remain in the body for 30 days or more. This generic type of device includes various catheters, shunts, and connectors specifically designed to provide access to blood. Examples include single and double lumen catheters with cuff(s), fully subcutaneous port-catheter systems, and A-V shunt cannulae (with vessel tips). The implanted blood access device may also contain coatings or additives which may provide additional functionality to the device. (2) The nonimplanted blood access device consists of various flexible or rigid tubes, such as catheters, cannulae or hollow needles, which are inserted into appropriate blood vessels or a vascular graft prosthesis (§§ 870.3450 and 870.3460), and are intended to remain in the body for less than 30 days. This generic type of device includes fistula needles, the single needle dialysis set (coaxial flow needle), and the single needle dialysis set (alternating flow needle). (3) Accessories common to either type include the shunt adaptor, cannula clamp, shunt connector, shunt stabilizer, vessel dilator, disconnect forceps, shunt guard, crimp plier, tube plier, crimp ring, joint ring, fistula adaptor, and declotting tray (including contents).

Special Controls

*Classification.* (1) Class II (special controls) for the implanted blood access device. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible. Material names and specific designation numbers must be provided. (ii) Performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested: (A) Pressure versus flow rates for both arterial and venous lumens, from the minimum flow rate to the maximum flow rate in 100 milliliter per minute increments, must be established. The fluid and its viscosity used during testing must be stated. (B) Recirculation rates for both forward and reverse flow configurations must be established, along with the protocol used to perform the assay, which must be provided. (C) Priming volumes must be established. (D) Tensile testing of joints and materials must be conducted. The minimum acceptance criteria must be adequate for its intended use. (E) Air leakage testing and liquid leakage testing must be conducted. (F) Testing of the repeated clamping of the extensions of the catheter that simulates use over the life of the device must be conducted, and retested for leakage. (G) Mechanical hemolysis testing must be conducted for new or altered device designs that affect the blood flow pattern. (H) Chemical tolerance of the device to repeated exposure to commonly used disinfection agents must be established. (iii) Performance data must demonstrate the sterility of the device. (iv) Performance data must support the shelf life of the device for continued sterility, package integrity, and functionality over the requested shelf life that must include tensile, repeated clamping, and leakage testing. (v) Labeling of implanted blood access devices for hemodialysis must include the following: (A) Labeling must provide arterial and venous pressure versus flow rates, either in tabular or graphical format. The fluid and its viscosity used during testing must be stated. (B) Labeling must specify the forward and reverse recirculation rates. (C) Labeling must provide the arterial and venous priming volumes. (D) Labeling must specify an expiration date. (E) Labeling must identify any disinfecting agents that cannot be used to clean any components of the device. (F) Any contraindicated disinfecting agents due to material incompatibility must be identified by printing a warning on the catheter. Alternatively, contraindicated disinfecting agents must be identified by a label affixed to the patient's medical record and with written instructions provided directly to the patient. (G) Labeling must include a patient implant card. (H) The labeling must contain comprehensive instructions for the following: ( *1* ) Preparation and insertion of the device, including recommended site of insertion, method of insertion, and a reference on the proper location for tip placement;( *2* ) Proper care and maintenance of the device and device exit site;( *3* ) Removal of the device;( *4* ) Anticoagulation;( *5* ) Management of obstruction and thrombus formation; and( *6* ) Qualifications for clinical providers performing the insertion, maintenance, and removal of the devices.(vi) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices that include subcutaneous ports must include the following: (A) Labeling must include the recommended type of needle for access as well as detailed instructions for care and maintenance of the port, subcutaneous pocket, and skin overlying the port. (B) Performance testing must include results on repeated use of the ports that simulates use over the intended life of the device. (C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use. (vii) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices with coatings or additives must include the following: (A) A description and material characterization of the coating or additive material, the purpose of the coating or additive, duration of effectiveness, and how and where the coating is applied. (B) An identification in the labeling of any coatings or additives and a summary of the results of performance testing for any coating or material with special characteristics, such as decreased thrombus formation or antimicrobial properties. (C) A Warning Statement in the labeling for potential allergic reactions including anaphylaxis if the coating or additive contains known allergens. (D) Performance data must demonstrate efficacy of the coating or additive and the duration of effectiveness. (viii) The following must be included for A-V shunt cannulae (with vessel tips): (A) The device must comply with Special Controls in paragraphs (b)(1)(i) through (v) of this section with the exception of paragraphs (b)(1)(ii)(B), (b)(1)(ii)(C), (b)(1)(v)(B), and (b)(1)(v)(C), which do not apply. (B) Labeling must include Warning Statements to address the potential for vascular access steal syndrome, arterial stenosis, arterial thrombosis, and hemorrhage including exsanguination given that the device accesses the arterial circulation. (C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use. (2) Class II (performance standards) for the nonimplanted blood access device. (3) Class II (performance standards) for accessories for both the implanted and the nonimplanted blood access devices not listed in paragraph (b)(4) of this section. (4) Class I for the cannula clamp, disconnect forceps, crimp plier, tube plier, crimp ring, and joint ring, accessories for both the implanted and nonimplanted blood access device. The devices subject to this paragraph (b)(4) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.

Predicate Devices

• Medcomp Ash Split-Cath II (K020465)
• Medcomp Bio-Flex CS Cath with Adjustable Cuff (K971925)
• Medcomp Split-Stream SC4 (K022678)

Submission Summary (Full Text)

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K040318 Page 1 of 2

# FEB - 3 2005 510(k) SUMMARY

## Submitter Information: A.

MEDCOMP® Submitter: 1499 Delp Drive Harleysville, PA 19438 [phone] Telephone [phone] Fax Contact: Jean Callow February 2, 2004 Date Prepared: Medcomp Split-Cath® II Trade Name: Hemodialysis Catheter, Implanted Common Name: Classification: MSD

- K020465 Medcomp Ash Split-C. Predicate Device: Cath II, K971925 Medcomp Bio-Flex CS Cath with Adjustable Cuff and K022678 Medcomp Split-Stream SC4
876.5540

### D. Device Description:

C.F.R. Section:

B.

The Medcomp Split-Cath II is a polycarbonate/polyurethane, double lumen catheter used to remove and return blood through two-segregated lumen passages. Both lumens are "D" shaped, tapered at the distal tip, with eight side holes. The distal venous lumen extends beyond the arterial lumen to reduce recirculation. The fixed polyester cuff allows for tissue ingrowth for long term placement.

The arterial and venous lumens are designed to be split, or peeled apart, prior to insertion to provide two free-floating lumens within the vessel. The side holes are orientated to allow 360-degree arterial uptake and venous return. The lumens are connected to the extensions via a soft pliable hub with suture wing. Red and blue luer connectors and clamps identify the arterial and venous extensions. Priming volume information is printed an identification ring housed within the extension line clamp.

# E. Intended Use:

The Medcomp Split-Cath II is indicated for use in attaining long-term vascular access for hemodialysis and apheresis. It may be inserted percutaneously and is primarily placed in the internal jugular vein. Alternate insertion site is the subclavian vein.

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KOH0318 Page 2 of 2

#### Comparison to Predicate Device: F.

The technological characteristics of the Split-Cath II are substantially equivalent to the predicate devices in terms of intended use, insertion method, anatomical location, design, performance, labeling, manufacturing process and method of sterilization.

The design specifications are identical to that of the Ash Split- Cath II predicate device. The difference between the proposed device and the predicate is the addition of a second vendor for the lumen material. The proposed device and predicate device lumens are manufactured from polyurethane, the material formulations are the same.

#### G. Performance Data:

In Vitro performance data for the Medcomp Split Cath II, including tensile strength, joint strength, leakage, recirculation, flow performance, flexural and lumen peel demonstrate that this device is substantially equivalent to the legally marketed Ash Split-Cath II catheter.

Biocompatibility testing on the Split-Cath II demonstrates the lumen materials meet the requirements of USP XXII for a permanent contact device.

Clinical data was not deemed necessary since substantial equivalence is addressed by way of comparison to a legally marketed device.

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three curved lines representing its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

Public Health Service

FEB - 3 2005

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Ms. Jean Callow Regulatory Specialist Medcomp® 1499 Delp Drive HARLEYSVILLE PA 19438

Re: K040318

Trade/Device Name: Medcomp® Split Cath® II Regulation Number: 21 CFR §876.5540 Regulation Name: Blood access device and accessories Regulatory Class: III Product Code: 78 MSD Dated: January 20, 2005 Received: January 25, 2005

Dear Jean Callow:

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). 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 tray 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 tray. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, and labeling, and prohibitions against misbranding and adulteration.

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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Page 2 - Ms. Jean Callow

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 or uny I vith all the Act's requirements, including, but not limited to: registration (21 CFR Part 807); listing (21 CFR Part 807), labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if requirements as bet fortif in als quady bon control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

This letter will allow you to begin marketing your device as described in your Section 510(k) I mis letter will and w yourse Finding of substantial equivalence of your device to a legally premation houried.com "results in a classification for your device and thus, permits your marketed proceed to the market. If you desire specific advice for your device on the labeling aceries to probeed to me the Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification"(21 CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Tou may oount other gener generational and Consumer Assistance at its toll free number [phone] or [phone], or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

David G. Lyman


Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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K04 03/8

# INDICATIONS FOR USE

510(k) Number:

Device Name: Medcomp® Split Cath® II

Indications for use:

The Medcomp® Split-Cath® II is indicated for use in attaining chronic (Iongthe wousehip access for hemodialysis and apheresis. It may be inserted tonni/ vaceusly and is ideally placed in the internal jugular vein of an adult patient. Alternate insertion site includes the subclavian vein as required.

(Please DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

| Prescription Use | <div>✓</div> | OR | Over-The-Counter |
|----------------------|--------------|----|------------------|
| (Per 21 CFR 801.109) | | | |

David A.

(Optional Format 1(Division Sign-Off) 1 Division of Reproductive, Abdominal, and Radiological Devices 510(k) Number.

al Format 1-2-96)