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  FDA 2007
 

I)EC 2 2 2004

Preparation Date: August 28, 2003

1.0

510(K) SummarySubmitter Name and Address

Matt Longson, VP Product Development

NeoSci Medical Inc.

1192 E. Draper Parkway

Suite #442

Draper, Utah 84020

2.0 Contact Person/ Prepared By

Phil Triolo, PhD

Phil Triolo and Associates LC

148 S. 1200 E.

Salt Lake City, UT 84102-1643

801.328.1996 phone / 801.328.2399 fax

philtaphilt.com

3.0

Trade Name

Device IdentificationEndoluminal Brush

Common Name

Central Venous Catheter Biopsy Brush

Endoluminal Brush

Classification Name

4.0

Predicate Device Manufacturer / Name

Intravascular Catheter AccessoryPredicate Device(s)

FAS Endoluminal Brush

Digene Cervical Brush

Guidant Hi-Torque Floppy Guide Wire with Hydrocoat Hydrophilic Coating

AngioDynamics Continuous Flush Catheter of its Pulse Spray Infusion

System

Gait Medical Guide Wire

5.0

Device Description

The NeoSci Medical (NSM) Endoluminal Brush (EB) is a device similar to a very

small diameter bottlebrush that can be inserted into the lumen of partially

obstructed central venous catheters to collect a sample. The distal end of the

device consists of a flexible tip equivalent to that of a floppy guide wire tip.

Immediately proximal to the flexible tip is a segment of bristles wound into flexible,

twisted (braided) stainless steel wires. The outer diameter of the bristle profile is

selected by the user. Instructions for use recommend that the EB size be 1.2 to

2.0 times the inner diameter of the lumen to be sampled. The stainless steel wires

are bonded to a nitinol shaft that extends to the proximal end of the device. The

proximal nitinol shaft is encased in a polvtetrafluoroethylene sheath with a

hydrophhilic coating applied to reduce friction.

6.0 Intended Use

The NeoSci Medical Endoluminal brush is intended to collect a sample, which is suitable

for microbiological analysis, from the inner lumen surface of an indwelling central venous

catheter.

The device is contraindicated for patients with known, or suspected allergies to nitinol,

PTFE Teflon®, Nylon, stainless steel, gold or hydrophilic coatings.

7.0

Device(s)

Device NeoSci Medical EB FAS Endoluminal

Component Brush

Summary of Technological Characteristics in relation to Predicate

Distal Tip Gold-coated tungsten wire Twisted stainless steel

wrapped around a central wire loop

nitinol core

Brush Segment Nylon bristles wound into Same design, with different

twisted stainless steel wires diameter Nylon bristles

Proximal Shaft Nitinol encased in sheath with Twisted stainless steel

hydrophilic coating wire

Proximal End Same as proximal shaft Stainless steel tube

bonded to the twisted

stainless steel wire, with

a loop at the end

Sterile Sheath None Clear polymer with PVC

Luer lock hubs

8.0

Results indicate that NSM EB Tensile Strength, Torque Strength, Torqueability, Tip

Assessment of Performance Data used to justify Substantial Equivalence Claim

Flexibility,

Coating Adherence / Integrity, Catheter Compatibility, Biocompatibility,

Fracture

intended use. Tests were carried out according to protocols based on those identified in

ISO 11070, where applicable.

9.0

and Flex Resistance, and Effectiveness of Sampling are suitable for the EB'sConclusion

Performance and safety of the NSM EB meets the relevant requirements for guide wires

identified in ISO 11070, and / or are substantially equivalent to the safety and efficacy of

the predicate endoluminal brush, and no new issues of safety and efficacy are raised by

use of the NSM EB.

DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service

Food and Drug Administration

9200 Corporate Boulevard

Rockville MD 20850

DEC

2 2 2004

Mr. Matt Longson

Vice President Research and Development

NeoSci Medical, Incorporated

1192 E. Draper Parkway

Draper, Utah 84020

Re: K030400

Trade/Device Name: NeoSci Medical Endoluminal Brush

Regulation Number: 880.5970

Regulation Name: Percutaneous, Implanted, Long-Term Intravascular Catheter

Regulatory Class: II

Product Code: LJS

Dated: December 8, 2004

Received: December 9, 2004

Dear Mr. Longson:

We have reviewed your Section 510(k) premarket notification of intent to market the device

referenced above and have determined the device is substantially equivalent (for the

indications for use stated in the enclosure) to legally marketed predicate devices marketed in

interstate commerce prior to May 28, 1976, the enactment date of the Medical Device

Amendments, or to devices that have been reclassified in accordance with the provisions of

the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket

approval application (PMA). You may, therefore, market the device, subject to the general

controls provisions of the Act. The general controls provisions of the Act include

requirements for annual registration, listing of devices, good manufacturing practice,

labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III

(PMA), it may be subject to such 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.

Page 2 - Mr. Triolo

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); 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.

This letter will allow you to begin marketing your device as described in your Section 510(k)

premarket notification. The FDA finding of substantial equivalence of your device to a

legally marketed predicate device results in a classification for your device and thus, permits

your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801),

please contact the Office of Compliance at (240) 276-0115. 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

Division of Small Manufacturers, International and Consumer Assistance at its toll-free

number (800) 638-2041 or (301) 443-6597 or at its Internet address

http://www.fda.gov/cdrh/dsma/dsmamain.htrnl

Sincerely yours,

Chiu Lin, Ph.D.

Director

Division of Anesthesiology, General Hospital,

Infection Control and Dental Devices

Office of Device Evaluation

Center for Devices and

Radiological Health

Enclosure

Indications for Use

510(k) Number (if known): K030400

Device Name: NeoSci Medical Endoluminal Brush

Indications for Use:

The NeoSci Medical Endoluminal Brush is intended to collect a sample, which is

suitable for microbiological analysis, from the inner lumen surface of an

indwelling central venous catheter. The proximal nitinol shaft is encased in a

polytetrafluoroethylene sheath with a hydrophilic coating applied to reduce

friction.

The device is contraindicated for patients with known, or suspected, allergies to

nitinol, PTFE Teflon®, Nylon, stainless steel, gold, or hydrophilic coatings.

Prescription Use

-,~- ' 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)

( 2vision Stgn-lbff)

Division of Anesthesiology, General Hospital,

Infection Control, Dental Devices

0(k

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