The Polyethylene Catheter is intended for use in angiographic procedures.
Device Story
Polyethylene Catheter is a sterile, single-use diagnostic intravascular catheter. It features a single-lumen shaft and Luer lock adapter. Used by clinicians during angiographic procedures to facilitate contrast media delivery or diagnostic imaging. The device is inserted into the vasculature; its radiopaque properties allow visualization under fluoroscopy. It functions as a conduit for diagnostic access. Benefits include reliable performance in angiographic imaging and procedural utility. No complex electronics or software are involved.
Clinical Evidence
Bench testing only. Testing included biocompatibility (ISO 10993-1), air leakage, liquid leakage, dimensional verification, tensile testing (shaft, hub-to-shaft, sideported area), and radiopacity. All tests met predetermined acceptance criteria per BS EN ISO 10555-1 standards.
Technological Characteristics
Single-lumen polyethylene catheter with Luer lock adapter. Available in 3.0 Fr diameter and lengths of 35-65 cm. Radiopaque. Tested per BS EN ISO 10555-1:2013 (leakage, tensile strength) and ANSI AAMI ISO 10993-1:2009(R)2013 (biocompatibility). Sterile, single-use.
Indications for Use
Indicated for use in angiographic procedures. Prescription use only.
Regulatory Classification
Identification
An intravascular diagnostic catheter is a device used to record intracardiac pressures, to sample blood, and to introduce substances into the heart and vessels. Included in this generic device are right-heart catheters, left-heart catheters, and angiographic catheters, among others.
Predicate Devices
Cook Incorporated Slip-Cath® Beacon® Tip Catheter (K122937)
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March 22, 2019
Cook, Inc. Reuben Lidster Regulatory Affairs Specialist P.O. Box 489, 750 Daniels Way Bloomington, IN 47402
Re: K181722
Trade/Device Name: Polyethylene Catheter Regulation Number: 21 CFR 870.1200 Regulation Name: Diagnostic Intravascular Catheter Regulatory Class: Class II Product Code: DQO Dated: February 21, 2019 Received: February 22, 2019
Dear Mr. Lidster:
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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice
(https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
| For | Gregory O'Connell |
|-----|--------------------------------------------|
| | 2019.03.22 |
| | 11:48:35 -04'00' |
| | Bram D. 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
510(k) Number (if known) K181722
Device Name Polyethylene Catheter
| Indications for Use (Describe) | The Polyethylene Catheter is intended for use in angiographic procedures. |
|--------------------------------|---------------------------------------------------------------------------|
|--------------------------------|---------------------------------------------------------------------------|
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
|X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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K181722
Image /page/3/Picture/1 description: The image shows the logo for Cook Medical. The logo is set against a red background. The word "COOK" is written in large, white, sans-serif letters at the top of the logo. Below "COOK", the word "MEDICAL" is written in smaller, white, sans-serif letters.
COOK INCORPORATED 750 Daniels Way BLOOMINGTON, IN 47404 USA 39.2235 TOLL FREE: 800.457.4500 www.cookmedical.com
# Polyethylene Catheter Traditional 510(k) Summary 21 CFR §807.92
### Submitter Information
| Applicant: | Cook Incorporated |
|-----------------------|--------------------------------|
| Address: | 750 Daniels Way |
| | Bloomington, IN 47404 |
| Contact: | Reuben G. Lidster |
| Email: | RegSubmissions@CookMedical.com |
| Contact Phone Number: | 812-335-3575 ext. 104866 |
| Contact Fax Number: | 812-332-0281 |
| Date Prepared: | 28 June 2018 |
#### Device Information
| Trade Name: | Polyethylene Catheter |
|----------------------|---------------------------------------------------------------|
| Common Name: | Diagnostic intravascular catheter |
| Classification Name: | Catheter, Intravascular, Diagnostic<br>DQO (21 CFR §870.1200) |
#### Predicate Device
The predicate device is the Cook Incorporated Slip-Cath® Beacon® Tip Catheter cleared under 510(k) number K122937 (part number prefix SCBR). The predicate device is manufactured in diameters of 4.0 to 6.5 French and in lengths of 60 to 150 centimeters. The catheter is compatible with a 0.035 or 0.038 inch wire guide. These catheters are manufactured in a variety of distal tip configurations.
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Cook Incorporated Polyethylene Catheter Traditional 510(k) 28 June 2018
#### Reference Device
Cook has utilized the Angiodynamics AngiOptic® Catheter (K964033) as a reference device, which is available in the 3.0 Fr diameter only, to support the 3.0 Fr diameter size of the subject device, the Polyethylene Catheter.
Cook has utilized the Angiodynamics Soft-Vu® Angiographic Catheter (K161596) as a reference device, which is available in lengths of 25 to 140 centimeters, to support the shorter length (35 centimeters) of the subject device, the Polyethylene Catheter.
#### Comparison to Predicate Device
The subject device, Polyethylene Catheter has similar indications for use, duration of use, principles of operation, fundamental technological characteristics, and insertion method as the predicate device. Minor differences between the subject device and the predicate device include wording of intended use, material, and dimension. The differences between the subject device and the predicate device do not raise new questions of safety and effectiveness as demonstrated by performance and biocompatibility testing.
#### Device Description
The Polyethylene Catheter, the subject of this submission, is a sterile, single use device designed for use in angiographic procedures. The Polyethylene Catheter is available in the 3.0 Fr size and is manufactured in lengths of 35, 40, 50, 55 and 65 centimeters. Each configuration includes a Luer lock adapter and a single lumen shaft.
#### Intended Use
The Polyethylene Catheter is intended for use in angiographic procedures.
#### Test Data
The Polyethylene Catheter was subjected to the applicable testing listed below to assure reliable design and performance under the testing parameters. Performance and biocompatibility testing were conducted in accordance with applicable FDA guidance documents to confirm the reliable performance of critical device characteristics. Simulated use preconditioning was performed. Packaging integrity and sterility data were leveraged from similar devices manufactured by Cook based on a technical analysis.
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Cook Incorporated Polyethylene Catheter Traditional 510(k) 28 June 2018
- Biocompatibility testing Testing (i.e., cytotoxicity, sensitization, intracutaneous . reactivity, systemic toxicity, pyrogenicity, hemocompatibility, complement activation, in vivo thrombogenicity, and partial thromboplastin time) demonstrated that the device is biocompatible for the intended use. In conformance with the applicable sections of ANSI AAMI ISO 10993-1:2009(R)2013, the predetermined acceptance criteria were met.
- Air Leakage Testing Testing verified that, under proper clinical use of the . catheter, there will be no air leakage when tested in accordance with the methods described in BS EN ISO 10555-1:2013, Annex D. The predetermined acceptance criterion was met.
- Dimensional Verification Testing Testing verified that the dimensional . requirements of the subject device are within a specified tolerance. The predetermined acceptance criteria were met.
- Liquid Leakage Testing Testing verified that, under proper clinical use of the . catheter, there will be no liquid leakage when tested in accordance with the methods described in BS EN ISO 10555-1:2013, Annex C. The predetermined acceptance criterion was met.
- . Tensile Testing of the Catheter Shaft - Testing verified that, under proper clinical used of the catheter, the catheter meets the requirements of the methods described in BS EN ISO 10555-1. Annex B. The predetermined acceptance criterion was met.
- Tensile Testing of the Hub-to-Shaft Bond Testing verified that, under proper . clinical use of the catheter, the peak load value of the hub-to-shaft connection is in accordance with the methods of BS EN ISO 10555-1:2013, Annex B. The predetermined acceptance criterion was met.
- Tensile Testing of the Sideported Area Testing verified that, under proper . clinical use of the catheter, the peak load value of the sideported area of the shaft is in accordance with the methods of BS EN ISO 10555-1:2013, Annex B. The predetermined acceptance criterion was met.
- . Radiopacity Testing - The results verified, under the proper clinical use of the subject device, the test articles were visible when imaged under fluoroscopy. The predetermined acceptance criterion was met.
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Cook Incorporated Polyethylene Catheter Traditional 510(k) 28 June 2018
### Conclusions
The results of testing provide reasonable assurance that the Polyethylene Catheter has been designed so that it conforms to the requirements of its intended use. The evidence demonstrates that the subject device is substantially equivalent to the predicate device, the Cook Incorporated Slip-Cath® Beacon® Tip Catheter (K122937), and does not raise new questions of safety or effectiveness.
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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 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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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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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.