Medtronic 96530-121 Addendum

Model Numbers
Device Description
FDA-Cleared Indications for Use
96820-108
Bio-Medicus™
These devices are to be used by a trained physician only.
Supplement: Temporary modification to indications for use for cannulae
96820-108, 96820-110, 96820-112, 96820-114 96830-108, 96830-110, 96830-112, 96830-114 96570-115, 96570-117, 96570-119, 96570-121, 96570-123, 96570-125 96670-115, 96670-117, 96670-119, 96670-121, 96670-123, 96670-125, 96670-127, 96670-129 96530-115, 96530-117, 96530-119, 96530-121, 96530-123, 96530-125 96600-115, 96600-117, 96600-119, 96600-121, 96600-123, 96600-125, 96600-127, 96600-129
Background
On April 6, 2020 the United States Food and Drug Administration (FDA) published the following guidance:
Devices during the Coronavirus Disease 2019 (COVID-19) Pubic Health Emergency.”
Under this guidance, the FDA is allowing temporary, limited modifications to the indications of certain FDA-cleared or FDA-approved cardiopulmonary devices without prior submission of premarket notification. These modifications are allowed, due to the public health emergency related to COVID-19, when they do not create an undue risk. This indication modification is in effect for the duration of the public health emergency related to COVID-19, as declared by the Department of Health and Human Services (HHS).
Indications for use
“Enforcement Policy for Extracorporeal Membrane Oxygenation and Cardiopulmonary Bypass
In accordance with the FDA guidance, the devices listed below have a modified indication for use during the COVID-19 public health emergency. This indication modification has not been cleared or approved by the FDA, but shall apply temporarily to the device models listed in this supplement:
The device can be used for longer than 6 hours in an extracorporeal membrane oxygenation (ECMO) circuit to treat patients who are experiencing acute respiratory or acute cardiopulmonary failure.
The table below shows the part numbers, device descriptions, and FDA-cleared indications for use for the various cannulae granted the above modified indication.
96820-110 96820-112 96820-114 96830-108 96830-110
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Pediatric Femoral Cannulae and Introducers
Cannulae are used to cannulate vessels, perfuse vessels or organs, and/or connect with accessory extracorporeal equipment. The cannula introducer is intended to facilitate proper insertion and placement of the appropriately-sized cannula within the vessel for
Model Numbers
Device Description
FDA-Cleared Indications for Use
96830-112 96830-114
cardiopulmonary bypass. These products are intended
for use up to 6 hours.
96570-115
96670-129
Bio-Medicus Adult
These devices are to be used by a trained physician only.
96530-115
96600-129
Bio-Medicus
These devices are to be used by a trained physician only.
96570-117 96570-119 96570-121 96570-123 96570-125 96670-115 96670-117 96670-119 96670-121 96670-123 96670-125 96670-127
96530-117 96530-119 96530-121 96530-123 96530-125 96600-115 96600-117 96600-119 96600-121 96600-123 96600-125 96600-127
Femoral Cannulae and Introducers
Cannula Kits
Cannulae are used to cannulate vessels, perfuse vessels or organs, and/or connect with accessory extracorporeal equipment. The cannula introducer is intended to facilitate proper insertion and placement of the appropriately-sized cannula within the vessel for cardiopulmonary bypass. The Bio-Medicus cannula (18 cm (7.09 in) tip length models) may be used in either the femoral position as an arterial delivery cannula or in the jugular position as a venous return cannula. These products are intended for use up to 6 hours.
Cannulae are used to cannulate vessels, perfuse vessels or organs, and/or connect with accessory extracorporeal equipment. The cannula introducer is intended to facilitate proper insertion and placement of the appropriately-sized cannula within the vessel for cardiopulmonary bypass. The Bio-Medicus cannula (18 cm (7.09 in) tip length models) may be used in either the femoral position as an arterial delivery cannula or in the jugular position as a venous return cannula. These products are intended for use up to 6 hours.
Device performance
There are no changes to device performance as described in the instructions for use for these devices.
Summary of durability testing
Medtronic conducted in vitro testing and reliability and life testing on these devices. The testing showed no failures.
Medtronic also conducted functional testing to demonstrate product reliability using worst case pediatric and adult cannulae models, following environmental conditioning, aging, and simulated use conditioning at maximum flow rates for up to 6 hours of use. All devices met the performance requirements with no failures.
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Summary of clinical performance
A literature search and review1 were conducted to assess the published evidence specific to the use of Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers in ECMO or extracorporeal life support (ECLS) since the first CE mark in 2014. Nine articles reported on case studies of 44 patients using Bio-Medicus cannulae in an ECMO/ECLS setting. The length of time these patients were on ECMO ranged from days to months. Nineteen of the 44 ECMO-treated patients were COVID-19 patients. Erik Osborn et al their experience with 15 COVID-19 patients demonstrates that ECMO can be successfully employed as a support modality for COVID-19 related acute respiratory distress syndrome. Loforte A. et al from 4 COVID-19 patient experiences that if the conservative treatment is not effective, veno-venous ECMO support might be considered. The evidence from these 9 case reports confirmed that ECMO use is beneficial and no performance or safety issues due to the use of Medtronic Bio-Medicus cannulae were reported.
The clinical performance and safety data of Bio-Medicus cannulae derived from Medtronic field experience data (including Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers) and published scientific literature (including all Bio-Medicus adult and pediatric cannulae and not limited to these models) were evaluated and
4
documented in a Clinical Evaluation Report (CER)
. The CER confirms the performance and safety of Bio­Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers.
No new or increased risks or other clinical concerns were identified in this clinical evidence review for the Medtronic Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers.
Medtronic conducted blood trauma testing comparing a reference catheter, which is qualified for ECMO/ECLS long-term use, to the Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers. The design, geometry, flow rate performance, and manufacturing methods used for the Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers are the same as the reference device. The results of the blood trauma testing demonstrate that the Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers have equivalent hemocompatibility as the reference device.
Medtronic also conducted biocompatibility testing of the blood-contacting materials used in the Bio­Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers for prolonged use. The results of the biocompatibility testing demonstrate that the Bio-Medicus Adult Femoral Cannulae and Introducers and Cannula Kits, and Bio-Medicus Pediatric Femoral Cannulae and Introducers meet ISO 10993-1 as recommended by FDA guidance
2
reported that
3
concluded
1
The literature search and review were conducted to access the products in scope of this documentation only.
2
Data on file
3
Data on file
4
Data on file
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document “Use of International Standard ISO 10993-1, ‘Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process.’”
Potential risks
Possible complications include those normally associated with ECMO, ECLS, anticoagulation, and large­bore venous and arterial catheterization.
The following potential adverse effects are associated with the use of the devices: abrasion, air embolism, anaphylaxis, bleeding or hematoma at the cannulation site, death, delayed procedure, dissection, exsanguination, foreign-material embolism, hemolysis, hypercarbia, hypervolemia, hypotension, hypovolemia, hypoxia, infection, irritation, ischemia or lower limb ischemia, major blood loss, minor blood loss, neurological dysfunction, organ dysfunction, perforation, sensitization, thromboembolism, thrombus formation, tissue damage, toxicity, vessel damage. Vessel damage and complications at the puncture site may occur if the instructions for use are not followed.
Clinical signs or observations that suggest device changeout is necessary
These clinical observations may necessitate or predict the need for device replacement throughout the duration of use:
Decreased blood flow due to a clot, obstruction, or other factor that cannot be managed by
catheter repositioning Significant or uncontrolled blood loss from the catheter
Entrained air in the catheter or connectors
Mechanical injury to access vessels (perforation, tearing, dissection), injury at or above the site
of insertion, and tissue damage during the insertion and placement of the catheter Mechanical failure due to kinking of the catheter, or material failure due to incorrect suturing
Hemorrhage related to bleeding, catheter malposition, or dislodgement around the insertion
site Heart, vessel, or lung damage; anemia; liver or kidney failure; and stroke
Note: The benefits of catheterization for extracorporeal circulation must be weighed against the risk of systemic anticoagulation and subsequent propensity for hemorrhage.
Warning: Only physicians with previous training and experience in cannulation, Seldinger technique and extracorporeal life support should replace these devices. It is the responsibility of the physician to determine the proper steps to follow based on the patient’s individual clinical need.
Use conditions
The intended patient population are those experiencing acute respiratory failure or acute cardiopulmonary failure. The duration of use is likely to extend beyond the labeled 6-hour indication when used in an ECMO circuit. There are no other changes to the intended use as described in the instructions for use for these devices. There are no changes to the contraindications as described in the instructions for use for these devices.
There are no changes to the recommended catheters by flow index as shown in Table 1 and Table 2.
2
Table 1. Recommended catheter for flow index 2.5 L/min/m
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Body surface area (m2)
Index matched flow requirements (L/min)
Return
Drainage
0.2
0.5
96820-108
96830-110
0.6
1.5
96820-112
96830-114
1.0
2.5
96820-014
96570-119
1.4
3.6
96570-117
96670-123
1.8
4.6
96570-119
96670-125
2.2
5.6
96570-121
96670-127
2.6
6.5
96570-123
96670-129
Body surface area (m2)
Index matched flow requirements (L/min)
Return
Drainage
0.2
0.3
96820-108
96830-108
0.6
0.9
96820-110
96830-112
1.0
1.5
96820-112
96830-114
1.4
2.2
96820-114
96570-117
1.8
2.8
96570-115
96570-119
2.2
3.4
96570-117
96670-121
2.6
3.9
96570-117
96670-123
Table 2. Recommended catheter for flow index 1.5 L/min/m
2
Medtronic, Inc.
710 Medtronic Parkway Minneapolis, MN 55432 USA
M013394C001 B © 2021 Medtronic
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