The Charter™ Guidewires are intended for use in the coronary and peripheral vasculature. Contraindications: The Charter™ Guidewire is not intended for use in the cerebral vasculature. Patients judged not acceptable for percutaneous intervention (PCI).
Device Story
Charter Guidewire is a single-use, disposable device designed to facilitate navigation of catheters through coronary and peripheral vasculature. The device consists of a stainless steel core wire (140cm or 180cm length; 0.014" or 0.018" diameter) with a centerless-ground tapered distal section for variable stiffness. The distal tip features a platinum-tungsten spring coil for radiopacity and an Estane 88A polymer sleeve. The wire is coated to enhance lubricity. Operated manually by a physician during percutaneous intervention (PCI), the guidewire acts as a track for catheter advancement. The radiopaque tip allows visualization under x-ray, assisting the physician in precise placement within the vasculature. By providing a stable path, the device enables the delivery of therapeutic or diagnostic catheters, potentially improving procedural success and patient outcomes in vascular interventions.
Clinical Evidence
Bench testing only. No clinical data provided. Performance evaluations included tensile strength, torque strength, outer diameter measurement, torque response, catheter compatibility, coating adherence/integrity, and tip flexibility. Biocompatibility testing was conducted in compliance with ISO 10993-1, including cytotoxicity, irritation, acute systemic toxicity, and comprehensive haemocompatibility assays (haemolysis, coagulation, thrombosis, and complement activation).
Technological Characteristics
Materials: Stainless steel core, platinum-tungsten spring coil, Estane 88A radiopaque heat shrink polymer tubing. Dimensions: 140cm/180cm length, 0.014"/0.018" diameter. Principle: Manual guidewire for catheter tracking. Features: PTFE coating, hydrophilic coating, centerless-ground tapered core. Biocompatibility: ISO 10993-1 compliant. Sterilization: Not specified.
Indications for Use
Indicated for use in coronary and peripheral vasculature. Contraindicated for cerebral vasculature and patients ineligible for percutaneous intervention (PCI).
Regulatory Classification
Identification
A catheter guide wire is a coiled wire that is designed to fit inside a percutaneous catheter for the purpose of directing the catheter through a blood vessel.
Special Controls
*Classification.* Class II (special controls). The device, when it is a torque device that is manually operated, non-patient contacting, and intended to manipulate non-cerebral vascular guide wires, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
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# K103377
Navilyst Charter 510(k) Application
## 510(k) Summary
## as required by 21 CFR 807.92(c)
| Device Name | Charter™ Guidewire | | |
|---------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|--------------|
| Submitters<br>name/contact<br>details | Brivant Ltd,<br>Parkmore West Business Park,<br>Galway,<br>Ireland<br><br>Contact Details:<br>Tomas Furey<br>Operations Manager,<br>Tel: +353 91 385037<br>Fax: +353 91 766598 | | |
| Summary<br>Preparation Date | 10th November 2010 | | |
| Device Name &<br>Classification | Trade Name: Charter™ Guidewire<br>Common Name: Guidewire<br>Classification Name: Catheter, Guidewire<br>Device Classification: Class II, 21 CFR §870.1330<br>Product Code: DQX | | |
| Intended Use | Intended Use:<br>The Charter™ Guidewires are intended for use in the coronary and peripheral<br>vasculature.<br><br>Contraindications:<br>The Charter™ Guidewire is not intended for use in the cerebral vasculature.<br>Patients judged not acceptable for percutaneous intervention (PCI) | | |
| Device Description | The Navilyst Medical Guidewire is a disposable medical device designed for<br>single use only. It consists of a PTFE coated 140cm or 180cm, 0.014" or 0.018"<br>diameter stainless steel core wire, one end of which is reduced in diameter over<br>a 43cm approx. segment in a progressive fashion through a centreless grinding<br>operation. The profile of this reduced section affords the product a reduced area<br>of stiffness and can be varied to produce various levels of support.<br><br>The distal part of the reduced section is covered with a 3cm, 0.010" platinum<br>tungsten spring coil. This provides greater visibility on x-ray equipment. A 39cm<br>approx. length of black / grey Estane 88A radiopaque heat shrink polymer tubing<br>is applied over the tapered distal end of the wire and ground to form a constant<br>outer diameter, OD, equivalent in diameter to the main core body.<br>Coatings are placed on the device to improve the lubricity and ease in its<br>advancement through the guide catheter and the blood vessel | | |
| Predicate Devices | Manufacturer | 510k | Date |
| | Brivant Ltd, Brivant Guidewire | K060551 | 07 Jun 2006 |
| | Brivant Ltd, Streamer Guidewire | K083094 | 07 July 2009 |
| | Brivant Ltd, Courier Guidewire | K073082 | 09 Jan 2008 |
| Principle of<br>Operation | The Charter™ Guidewire is operated manually by a manual process | | |
| Comparison of<br>Technological<br>Characteristics | The Charter™ wire has minor differences in construction to the approved Brivant<br>Guidewire. These include Same diameter range as predicate devices Same basic construction technology as the predicate devices. Different polymer and hydrophilic coating materials to the predicate devices providing improved radiopacity. Slightly shorter overall length than predicate devices. Minor differences in profiles of the distal tip area of the guidewire changes to meet customer performance requirements. These changes are within ranges of the predicate devices. | | |
| | In vitro bench testing was performed to support a determination of substantial equivalence (refer to performance testing below) between the Charter™ Guidewires (in its various configurations) and the predicate devices.<br>The results of these tests provide reasonable assurance that the proposed device has been designed and tested to assure conformance to the requirements for its intended use and performs comparably to the predicate devices. The differences in construction between the Charter™ wire and the predicate devices raise no new issues of safety and effectiveness such that the Charter™ Guidewire is considered substantially equivalent to the predicate devices. | | |
| Performance<br>Testing (non-clinical) | In vitro bench tests were carried out to demonstrate equivalence with reference to the FDAs guidance document "Coronary and Cerebrovascular Guidewire Guidance, Jan 1995".<br>The following bench tests were performed: Tensile Strength Torque Strength Outer Diameter measurement Torque Response Catheter Compatibility Coating Adherence/Coating Integrity Tip Flexibility The results from these performance evaluations demonstrated that the Charter™ Guidewire met the acceptance criteria defined in the product specification and performed comparably to the predicate device. | | |
| | Biological Safety of the device has been established through biocompatibility testing carried out in compliance with ISO 10993-1 under VP-0427<br>The following biocompatibility tests were performed | | |
| | <b>Test Description</b> | <b>Test Method</b> | |
| | Cytotoxicity Study | Qualitative Evaluation – Dye Exclusion &<br>Microscopial Evaluation | |
| | Cytotoxicity Study | Quantitative Evaluation - MTT or XTT Assay | |
| | Irritation Test | Intracutaneous Injection (ISO10993-10) | |
| | Acute Systemic Toxicity Test | Systemic Injection<br>ISO10993-11 | |
| | Acute Systemic Toxicity Test | ISO-Rabbit-Pyrogen | |
| | Haemocompatibility Test | Haematology: Haemolysis - rabbit blood- Direct<br>(Complete ASTM Method) | |
| | Haemocompatibility Test | Haematology:<br>In-vitro Haemocompatiblity Assay | |
| | Haemocompatibility Test | Coagulation: The Prothrombin Time Assay (PT) | |
| | Haemocompatibility Test | Coagulation: The Unactivated Partial<br>Thromboplastin Time Assay (UPTT) | |
| | Haemocompatibility Test | Thrombosis: In Vivo Thrombogenicity in Dogs | |
| | Haemocompatibility Test | Complement Activation | |
| | Haemocompatibility Test | Lee& White Coagulation Assay | |
| Conclusions | Based on safety and performance testing, technological characteristics and the | | |
| | indications for use for the device, the Charter™ Guidewire has been | | |
| | demonstrated to be appropriate for its intended use and is considered to be<br>substantially equivalent to the predicate devices. | | |
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Navilyst Charter 510(k) Application
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#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Brivant, LTD. c/o Mr. Tomas Furey Operations Manager Parkmore West Business Park Galway Ireland
MAY 18 2011
Re: K103377
Trade/Device Name: Charter Guidewire Model 45-281, 45-282, 45-283 Regulation Number: 21 CFR 870.1330 Regulation Name: Catheter, Guidewire Regulatory Class: Class II Product Code: DQX Dated: April 14, 2011 Received: April 18, 2011
Dear Mr. Furey:
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. 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
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Page 2 - Mr. Tomas Furey
comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical 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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH0ffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
C. Tom Zuckerman, M.D.
Bram Zuckerman, M.D Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
K103377 510(k) Number (if known):
Charter Guidewire Device Name:
Indications For Use: Charter Guidewires are intended for use in the coronary and peripheral vasculature.
Contraindications: The Charter Guidewire is not intended for use in the cerebral vasculature. Patients judged not acceptable for percutaneous intervention (PCI).
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of Cardiovascular Devices
510(K) number K103377
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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.
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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
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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.
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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.
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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.
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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.