K223386 · Balt USA, LLC · HCG · Dec 6, 2022 · Neurology
Device Facts
Record ID
K223386
Device Name
Optima Coil System
Applicant
Balt USA, LLC
Product Code
HCG · Neurology
Decision Date
Dec 6, 2022
Decision
SESE
Submission Type
Special
Regulation
21 CFR 882.5950
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Optima Coil System is intended for use in the peripheral and neuro-vasculature to endovascularly obstruct or occlude blood flow in vascular abnormalities of the neurovascular and peripheral vessels.
Device Story
Optima Coil System consists of platinum/tungsten embolization coils attached to a delivery pusher; used for endovascular embolization of intracranial aneurysms and other vascular abnormalities. Device inserted into vasculature under angiographic visualization; coils placed into aneurysm to create blood stasis, reduce flow, and induce thrombosis. Detachment from pusher achieved via thermal detachment controller. Used in neurovascular and peripheral vasculature by physicians. System available in various shapes, lengths, and sizes; provides permanent obstruction of blood flow to vascular malformations.
Clinical Evidence
Bench testing only. Testing included visual and dimensional inspection, simulated use in a clinically relevant model, and stretch resistance (tensile strength) testing. All tests passed.
Technological Characteristics
Implant: 92/8 Platinum/Tungsten alloy coil. Delivery system: stainless steel hypotube, PET jacket, polyimide-coated silver lead wires. Detachment: thermal via controller. Dimensions: 3-65 cm length, 1-14 mm secondary diameter. Sterilization: Gamma irradiation (SAL 10^-6). Single-use. Materials include Dymax 1128A-M-VT adhesive and Epoxy 353 ND.
Indications for Use
Indicated for endovascular embolization of intracranial aneurysms, arteriovenous malformations, and arteriovenous fistulae; vascular occlusion of blood vessels within the neurovascular system; and arterial and venous embolizations in the peripheral vasculature.
Regulatory Classification
Identification
A neurovascular embolization device is an intravascular implant intended to permanently occlude blood flow to cerebral aneurysms and cerebral ateriovenous malformations. This does not include cyanoacrylates and other embolic agents, which act by polymerization or precipitation. Embolization devices used in other vascular applications are also not included in this classification, see § 870.3300.
Special Controls
*Classification.* Class II (special controls.) The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Vascular and Neurovascular Embolization Devices.” For availability of this guidance document, see § 882.1(e).
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December 6, 2022
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Balt USA, LLC Kavita Chandrashekar Senior Regulatory Affairs Specialist 29 Parker Irvine, California 92618
Re: K223386
Trade/Device Name: Optima Coil System Regulation Number: 21 CFR 882.5950 Regulation Name: Neurovascular Embolization Device Regulatory Class: Class II Product Code: HCG, KRD Dated: November 4, 2022 Received: November 7, 2022
Dear Kavita Chandrashekar:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Naira Muradyan -S
Naira Muradyan, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K223386
Device Name Optima Coil System
#### Indications for Use (Describe)
The Optima Coil System is intended for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae. The Optima Coil System is also intended for vascular occlusion of blood vessels within the neurovascular system to permanently obstruct blood flow to an aneurysm or other vascular malformation and for arterial and venous embolizations in the peripheral vasculature.
Type of Use (Select one or both, as applicable)
| <label>Prescription Use (Part 21 CFR 801 Subpart D)</label> | <label>Over-The-Counter Use (21 CFR 801 Subpart C)</label> |
|--------------------------------------------------------------|--------------------------------------------------------------|
| <div style="display:inline-block; margin-right:5px;">☑</div> | <div style="display:inline-block; margin-right:5px;">☐</div> |
X Prescription Use (Part 21 CFR 801 Subpart D)
] Over-The-Counter Use (21 CFR 801 Subpart C)
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### 510(k) Summarv K223386
| Applicant: | Balt USA, LLC<br>29 Parker<br>Irvine, CA 92618<br>Registration No.: 3014162263 |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
| Primary Contact Person: | Kavita Chandrashekar<br>Senior Regulatory Affairs Specialist<br>Telephone: (858) 405-1276<br>Email : kavita.chandrashekar@baltgroup.com |
| Secondary Contact | Brandon Shepard<br>Director, Regulatory Affairs<br>Telephone: (949) 788-1443<br>Email : brandon.shepard@baltgroup.com |
| Date Summary Prepared: | December 02, 2022 |
|------------------------|-------------------------------------------------------------------------------------|
| Trade Name: | Optima Coil System |
| Common Name: | Neurovascular embolization device; Vascular embolization device |
| Review Panel: | Neurology; Cardiovascular |
| Product Code: | HCG, KRD |
| Regulation Number: | 21 CFR 882.5950 (HCG), 21 CFR 870.3300 (KRD) |
| Regulation Name: | Device, Neurovascular Embolization;<br>Device, Vascular, for Promoting Embolization |
| Device Classification: | Class II |
| Predicate Device: | Optima Coil System, 510(k): K200030 |
### Device Description:
The Optima Coil System is a series of specialized coils that are inserted into the vasculature under angiographic visualization to embolize intracranial aneurysms and other vascular anomalies. The system consists of an embolization coil implant comprised of platinum and tungsten, affixed to a delivery pusher to facilitate insertion into the hub of a microcatheter. The system is available in various shapes, lengths and sizes. The devices are to be placed into aneurysms to create blood stasis, reducing flow into the aneurysm and thrombosing the aneurysm. Upon positioning coils into the aneurysm, the coils are detached from the delivery pusher in a serial manner until the aneurysm is occluded.
#### Indications for Use:
The Optima Coil System is intended for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities such as arteriovenous malformations and arteriovenous fistulae. The Optima Coil System is also intended for vascular occlusion of blood vessels within the neurovascular system to permanently obstruct blood flow to an aneurysm or other vascular malformation and for arterial and venous embolizations in the peripheral vasculature.
#### Intended Use:
The Optima Coil System is intended for use in the peripheral and neuro-vasculature to endovascularly obstruct or occlude blood flow in vascular abnormalities of the neurovascular and peripheral vessels.
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### Comparison of Technological Characteristics:
| Table I Device Comparison | | | | |
|--------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------|
| Category | Optima Coil System (predicate device K200030) | Modified Optima Coil<br>System (subject device<br>K223386) | | |
| Intended Use | The Optima Coil System is intended for use in the<br>peripheral and neuro-vasculature to endovascularly<br>obstruct or occlude blood flow in vascular abnormalities<br>of the neurovascular and peripheral vessels. | Same | | |
| Indications for Use | The Optima Coil System is intended for the endovascular<br>embolization of intracranial aneurysms and other<br>neurovascular abnormalities such as arteriovenous<br>malformations and arteriovenous fistulae. The Optima<br>Coil System is also intended for vascular occlusion of<br>blood vessels within the neurovascular system to<br>permanently obstruct blood flow to an aneurysm or other<br>vascular malformation and for arterial and venous<br>embolizations in the peripheral vasculature. | Same | | |
| Risk Class | Class II | Same | | |
| Product Code | HCG, KRD | Same | | |
| Common Name | Neurovascular Embolization Device | Same | | |
| Anatomical Location | Neuro Vasculature and Peripheral Vasculature | Same | | |
| Visualization | Visible under radiographic imaging | Same | | |
| Method of Supply | Sterile; single-use | Same | | |
| Coil Delivery Mechanism | Pusher assembly | Same | | |
| System Components | Coil (implant)<br>Delivery System<br>Detachment Controller | Same | | |
| Main Coil Material | 92/8 Platinum/Tungsten (Pt/W) Alloy | Same | | |
| Coil Length | 1 cm - 65 cm | 3 cm - 65 cm | | |
| Coil Secondary Diameter | 1 mm – 24 mm | 1 mm – 14 mm | | |
| Coil Wire Diameter | 0.00125" - 0.0035" | Same | | |
| Primary Coil Wind Diameter | 0.010" - 0.014" | 0.012" - 0.014" | | |
| Category | Optima Coil System (predicate device K200030) | | Modified Optima Coil System<br>(subject device K223386) | |
| No. & Size of Helical Loops<br>on Distalmost End<br>(Complex only) | 1.5 loops of 70% nominal diameter | | 3 loops of 70% nominal secondary diameter<br>3 loops of 100% nominal secondary diameter (with gaps of 0.0015") | |
| Primary Wind and Filar<br>Combinations | Complex | Helical | Complex | Helical |
| | .010" x .00125"<br>.011" x .0015"<br>.010" x .0015"<br>.011" x .00175"<br>.012" x .002"<br>.013" x .00225"<br>.014" x .003"<br>.014" x .0035"<br>.012" x .00125"<br>.014" x .0015"<br>.014" x .00175"<br>.014" x .002" | .012" x .002"<br>.011" x .0015"<br>.010" x .00125"<br>.012" x .00125"<br>.014" x .0015"<br>.014" x .00175"<br>.014" x .002" | .012" x .00125"<br>.014" x .0015"<br>.014" x .0020"<br>.014" x .0025"<br>.014" x .00275"<br>(gap)<br>.014" x .0030"<br>.014" x .0030"<br>(gap) | There are no new dimensions that are subject to this submission. |
| No. of sizes offered | 209 | | 239 (30 additional models as part of this line extension, all new sizes fall within existing ranges) | |
| Detachment | Thermal via Detachment Controller | | Same | |
| Pouch | Tyvek® | | Same | |
| Shelf Life | 5 Years | | Same | |
| Sterilization Method,<br>Sterility Assurance Level<br>(SAL) | Gamma irradiation, 10-6 | | Same | |
| Delivery System (pusher) | | | | |
| Construction/Design | Body coil laser welded to hypotube | | Same | |
| Body coil | 4-part coil:<br>A. Heater Coil (92/8 Pt/W)<br>B. Distal Coil (SSTL) | | Same | |
#### Table 1 Device Co .
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| | C. Radio-opaque (RO, 92/8 Pt/W) Coil | |
|-----------------------|--------------------------------------|------|
| | D. Proximal Coil (SSTL) | |
| Hypotube | SSTL Hypotube | Same |
| Connector | Gold plated, SSTL hypotube | Same |
| Adhesive | Dymax 1128A-M-VT | Same |
| Jacket | PET | Same |
| Fluoro safe markers | Pad Printed PET Shrink tube | Same |
| Epoxy | Epoxy 353 ND | Same |
| Lead wires | Polyimide coated silver lead wires | Same |
| Detachment Controller | | |
| Coil detachment | Thermal via detachment controller | Same |
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The modified Optima Coil System and the predicate Optimal Coil System differ in the following:
- Addition of new sizes of the coil implant. ●
- Addition of new combinations of coil OD, filar diameter, secondary shape diameter and ● lengths.
The differences between the subject and predicate devices do not raise new questions of safety and effectiveness.
#### Performance Data - Bench:
The following non-clinical bench testing was performed to evaluate the device changes and to demonstrate substantial equivalence of the modified Optima Coil System to the predicate device:
| Test | Acceptance Criteria | Results |
|--------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Visual Inspection, Dimensional<br>Inspection, and Resistance Check | The test samples shall meet established test<br>acceptance criteria for visual physical<br>damage and secondary diameter and length. | Pass |
| Simulated Use | The test samples shall be prepared in<br>accordance with the instructions for use and<br>meet established test acceptance criteria for<br>device performance in a clinically relevant<br>model. | Pass |
| Stretch Resistance | The samples shall meet established test<br>acceptance criteria for tensile strength. | Pass |
#### Conclusion:
There is no change to the intended use, materials, principles of operation or performance requirements of the modified Optima Coil System in comparison to the predicate device (K200030). The successful completion of non-clinical bench testing demonstrates that the modified Optima Coil System is substantially equivalent to the predicate device.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.