Important Information
This Summary of Safety and Clinical Performance (SSCP) is intended
to provide public access to an updated summary of the main aspects
of the safety and clinical performance of the device. This SSCP is
not intended to replace the Instructions for Use as the main
document to ensure the safe use of the device, nor is it intended
to provide diagnostic or therapeutic suggestions to intended users
or patients.
Applicable Documents
| Document Type |
Document Title / Number |
| Design History File (DHF) |
02020, 03006, 03006-A2 |
| ‘MDR Documentation’ File Number |
MDR-007 |
1. Device Identification and General Information
Device Trade Name(s): Split Stream®
Manufacturer Name and Address: Medical
Components, Inc. 1499 Delp Drive Harleysville, PA 19438 USA
Manufacturer Single Registration Number (SRN):
US-MF-000008230
Basic UDI-DI: 00884908249NH
Medical Device Nomenclature: F900202 – Permanent
Hemodialysis Catheter and Kits
Class of Device: III
Date First CE Certificate Issued: 2003
Authorized Representative Name and SRN: European
Regulatory Expert Medical Product Service GmbH (MPS) Borngasse 20
35619 Braunfels, Germany SRN: DE-AR-000005009
Notified Body Name and Single Identification Number:
BSI Netherlands NB2797
Device Grouping and Variants
The devices in scope of this document are all long-term
hemodialysis catheter sets. The device part numbers are organized
into variant categories. These devices are distributed as
procedure trays, in various configurations inclusive of
accessories and adjunctive devices (see section “Accessories
intended for use in combination with the Device”).
Variant Devices:
Variant Devices:
| Variant Description |
Part Number(s) |
Explanation of Multiple Part Numbers |
| 14F x 24cm Split Stream |
10298-824 10028-824 |
No significant clinical, biological, or technical difference
(only difference is pre-loaded stylet)
|
| 14F x 28cm Split Stream |
10298-828 10028-828 |
No significant clinical, biological, or technical difference
(only difference is pre-loaded stylet)
|
| 14F x 32cm Split Stream |
10298-832 10028-832 |
No significant clinical, biological, or technical difference
(only difference is pre-loaded stylet)
|
| 14F x 36cm Split Stream |
10298-836 10028-836 |
No significant clinical, biological, or technical difference
(only difference is pre-loaded stylet)
|
| 14F x 40cm Split Stream |
10298-840 10028-840 |
No significant clinical, biological, or technical difference
(only difference is pre-loaded stylet)
|
| 16F x 24cm Split Stream |
10062-824 |
N/A |
| 16F x 28cm Split Stream |
10062-828 |
N/A |
| 16F x 32cm Split Stream |
10062-832 |
N/A |
| 16F x 36cm Split Stream |
10062-836 |
N/A |
| 16F x 40cm Split Stream |
10062-840 |
N/A |
Variant Devices:
| Variant Description |
Part Number(s) |
Explanation of Multiple Part Numbers |
Procedure Trays:
Procedure Trays:
| Catalog Code |
Part Number |
Description |
| S24SE. |
10298-824 |
14F x 24cm Split Stream® Catheter Sheathless Technique Set
(Cuff 19cm From Tip)
|
| S28SE. |
10298-828 |
14F x 28cm Split Stream® Catheter Sheathless Technique Set
(Cuff 19cm From Tip)
|
| S32SE. |
10298-832 |
14F x 32cm Split Stream® Catheter Sheathless Technique Set
(Cuff 19cm From Tip)
|
| S36SE. |
10298-836 |
14F x 36cm Split Stream® Catheter Sheathless Technique Set
(Cuff 19cm From Tip)
|
| S40SE. |
10298-840 |
14F x 40cm Split Stream® Catheter Sheathless Technique Set
(Cuff 19cm From Tip)
|
| SST24SE. |
10298-824 |
14F x 24cm Split Stream® Catheter w/ Stylet Set (Cuff 19cm
From Tip)
|
| SST28SE. |
10298-828 |
14F x 28cm Split Stream® Catheter w/ Stylet Set (Cuff 23cm
From Tip)
|
| SST32SE. |
10298-832 |
14F x 32cm Split Stream® Catheter w/ Stylet Set (Cuff 27cm
From Tip)
|
| SST36SE. |
10298-836 |
14F x 36cm Split Stream® Catheter w/ Stylet Set (Cuff 31cm
From Tip)
|
| SST40SE. |
10298-840 |
14F x 40cm Split Stream® Catheter w/ Stylet Set (Cuff 35cm
From Tip)
|
| SST24E. |
10028-824 |
14F x 24cm Split Stream® Catheter Set (Cuff 19cm From Tip)
|
| SST28E. |
10028-828 |
14F x 28cm Split Stream® Catheter Set (Cuff 23cm From Tip)
|
| SST32E. |
10028-832 |
14F x 32cm Split Stream® Catheter Set (Cuff 27cm From Tip)
|
| SST36E. |
10028-836 |
14F x 36cm Split Stream® Catheter Set (Cuff 31cm From Tip)
|
| SST40E. |
10028-840 |
14F x 40cm Split Stream® Catheter Set (Cuff 35cm From Tip)
|
| SST2416E. |
10062-824 |
16F x 24cm Split Stream® Catheter Set (Cuff 19cm From Tip)
|
| SST2816E. |
10062-828 |
16F x 28cm Split Stream® Catheter Set (Cuff 23cm From Tip)
|
| SST3216E. |
10062-832 |
16F x 32cm Split Stream® Catheter Set (Cuff 27cm From Tip)
|
| SST3616E. |
10062-836 |
16F x 36cm Split Stream® Catheter Set (Cuff 31cm From Tip)
|
| SST4016E. |
10062-840 |
16F x 40cm Split Stream® Catheter Set (Cuff 35cm From Tip)
|
Procedure Trays:
| Catalog Code |
Part Number |
Description |
Configurations of Procedure Trays:
| Configuration Type |
Kit Components |
| 24cm and 28cm length Sets |
(1) Catheter (1) 1.3mm OD x 1.0mm ID x 70mm (18GA)
INTRODUCER NEEDLE (1) 0.97mm x 70cm (.038) GUIDEWIRE J (R
3mm) TIP (1) Advancer (1) 3.3mm OD x 15cm 12° BENT Raulerson
Ring Handled Y Adaptor Tunneler (1) 3.3mm OD x 18cm 12° BENT
TUNNELER (1) Tunneler Sleeve (1) Dilator
|
| 32cm, 36cm, and 40cm length Set |
(1) Catheter (1) 1.3mm OD x 1.0mm ID x 70mm (18GA)
INTRODUCER NEEDLE (2) 0.97mm x 100cm (.038) GUIDEWIRE J (R
3mm) TIP (2) Advancers (1) 3.3mm OD x 15cm 12° BENT
Raulerson Ring Handled Y Adaptor Tunneler (1) 3.3mm OD x
18cm 12° BENT TUNNELER (1) Dilator
|
| Set w/ Stylets |
(1) Catheter (1) Stylet |
| Sheathless Technique Set |
(1) Catheter (1) Stylet |
2. Intended Use of the Device
Intended Purpose: Split Stream® Catheters are
intended for use in adult patients who do not have functional
permanent vascular access or are not candidates for permanent
vascular access for whom central venous vascular access for
hemodialysis is deemed necessary based on the direction of a
qualified, licensed physician. The catheter is intended to be used
under the regular review and assessment of qualified health
professionals. This catheter is for single use only.
Indication(s): Split Stream® Catheters are
indicated for short-term or long-term use where vascular access is
required for 14 days or more for the purpose of hemodialysis.
Target Population(s): Split Stream® Catheters are
intended for use in adult patients who do not have functional
permanent vascular access or are not candidates for permanent
vascular access for whom central venous vascular access for
hemodialysis is deemed necessary based on the direction of a
qualified, licensed physician. The catheter is not intended for
use in pediatric patients.
Contraindications and/or Limitations:
-
Known or suspected allergies to any of the components of the
catheter or the kit.
-
This device is contraindicated for patients exhibiting severe,
uncontrolled coagulopathy or thrombocytopenia.
3. Device Description
Device Name: Split Stream® Catheter
Description of Device: The Split Stream® Catheter
is a long-term double lumen, single access catheter that is used
to remove and return blood through two separate passages (lumens).
The lumens are connected to two extensions by means of detachable
adapter style hubs. Priming volumes are printed on each lumen. A
polyester cuff is placed on the catheter’s lumen for tissue
ingrowth to anchor the catheter. The catheter incorporates Barium
Sulphate to facilitate visualization under fluoroscopy or Xray.
The catheter has been tested at flow rates of up to 500 mL/min.
The catheter is available in a variety of sizes to accommodate
physician preference and clinical needs.
Device Name:
Description of Device:
Materials / Substances in Contact with Patient Tissue:
The percentage ranges in the table below are based on the weights
of the 24cm catheter (7.09g) and the 40cm catheter (11.58g).
14F Split Stream®
| Material |
% Weight (w/w) |
| Polyurethane |
56.22 - 59.41 |
| Acetal co-polymer |
15.01 - 17.33 |
| Silicone |
5.31 - 6.13 |
| Barium sulfate |
6.31 - 8.14 |
| Stainless Steel |
2.65 - 3.06 |
| Nylon |
4.30 - 4.96 |
| Acrylonitrile Butadiene Styrene |
3.52 - 4.07 |
| Polyethylene terephthalate |
1.65 - 1.91 |
The percentage ranges in the table below are based on the weights
of the 24cm catheter (17.25g) and the 40cm catheter (19.92g).
16F Split Stream®
| Material |
% Weight (w/w) |
| Polyurethane |
56.46 - 59.51 |
| Acetal co-polymer |
14.93 - 17.15 |
| Silicone |
5.28 - 6.07 |
| Barium sulfate |
6.45 - 8.20 |
| Stainless Steel |
5.28 - 6.07 |
| Nylon |
4.27 - 4.91 |
| Acrylonitrile Butadiene Styrene |
3.51 - 4.03 |
| Polyethylene terephthalate |
1.65 - 1.90 |
Note: Per the instructions for use, the device is contraindicated
for patients with known or suspected allergies to the above
materials.:
Note: Accessories containing stainless steel may contain up to 4%
weight of the CMR substance cobalt.:
Information on Medicinal Substances in the Device:
N/A
How the Device Achieves its Intended Mode of Action:
Hemodialysis catheters are centrally placed access tubes. A
typical hemodialysis catheter uses a thin, flexible tube. The tube
has two openings. The tube goes into a large vein. The vein is
usually the internal jugular vein. Blood withdraws through one
lumen of the catheter. The blood flows to the dialysis machine
through a separate tubing set. The blood is then processed and
filtered. The blood returns to the patient through the second
lumen. This device is used when dialysis must start at once.
Patients may not have a functioning AV fistula or graft. Catheter
hemodialysis normally happens on a short-term basis. Long-term
access may occur in some cases. For example, when there are
problems supporting an AV fistula or graft.
Sterilization Information: Contents sterile and
non-pyrogenic in unopened, undamaged package. Sterilized by
Ethylene Oxide.
Previous Generations / Variants:
| Name of Previous Generation |
Differences from Current Device |
| N/A |
N/A |
Accessories Intended for Use in Combination with the
Device:
| Name of Accessory |
Description of Accessory |
| Guidewire |
For general intravascular use to facilitate the selective
placement of medical devices in the vessel anatomy.
|
| Guidewire Advancer |
Aid for introduction of guidewire into target vein.
|
| Stylet |
Assist in catheter insertion |
| Introducer Needle |
Used for the percutaneous introduction of guidewires.
|
| Scalpel |
A cutting device during surgical, pathology and minor
medical procedures
|
| Tunneler |
Instrument used to create a subcutaneous tunnel
|
| Tunneler Sleeve |
Sleeve slides down the tunneler and over the catheter tip to
secure the catheter to the tunneler.
|
| Peelable Introducer |
Introducers are intended to obtain central venous access to
facilitate catheter insertion into the central venous
system.
|
| Dilator |
Designed for percutaneous entry into a vessel in order to
enlarge the opening of the vessel for the placement of a
catheter in a vein.
|
| Removable Hub |
The removable hub is intended to provide additional catheter
securement and to minimize movement at the exit site.
|
| End Cap |
To keep clean and protect catheter luer between treatments.
|
Other Devices or Products Intended for Use in Combination with
the Device:
| Name of Device or Product |
Description of Device or Product |
| Tegaderm |
Adhesive wound dressing intended to protect the catheter
from contamination when not in use
|
| Syringe |
Attached to introducer needle to help capture blood return
once introducer needle perforates targeted vein, prevent air
embolism
|
4. Risks and Warnings
Residual Risks and Undesirable Effects: As per
product IFU (IFU 40773BSI), All surgical procedures carry risk.
Medcomp has implemented risk management processes to proactively
find and mitigate these risks as far as possible without adversely
affecting the benefit-risk profile of the device. After
mitigation, residual risks and the possibility of adverse events
from use of this product remain. Medcomp has determined that all
residual risks are acceptable.
| Residual Harm Type |
Possible Adverse Events Associated with Harm
|
| Bleeding |
Bleeding (May be severe)
|
| Cardiac Event |
Cardiac Arrhythmia
|
| Embolism |
Air Embolus
|
| Infection |
Bacteremia
|
| Perforation |
Inferior Vena Cava Puncture
|
| Thrombosis |
Central Venous Thrombosis
|
| Miscellaneous Complications |
Brachial Plexus Injury
|
|
Quantification of Residual Risks
|
|
PMS Complaints 01 January 2016 – 31 March 2025
|
PMCF Events |
|
Units Sold: 112,258 |
Units Studied: 107 |
|
Patient Residual Harm Category
|
% of Devices |
% of Devices |
| Allergic Reaction |
Not Reported |
Not Reported |
| Bleeding |
0.006% |
Not Reported |
| Cardiac Event |
Not Reported |
Not Reported |
| Embolism |
0.001% |
Not Reported |
| Infection |
Not Reported |
Not Reported |
| Perforation |
0.001% |
Not Reported |
| Stenosis |
Not Reported |
Not Reported |
| Tissue Injury |
Not Reported |
Not Reported |
| Thrombosis |
Not Reported |
Not Reported |
Warnings and Precautions:
All warnings have been reviewed against the risk analysis, PMS,
and usability testing to validate consistency between the sources
of information. As per product IFU (IFU 40773BSI), the Split
Stream® Catheters have the following warnings:
-
Do not insert catheter in thrombosed vessels.
-
Do not advance the guidewire or catheter if unusual resistance
is encountered.
-
Do not insert or withdraw the guidewire forcibly from any
component. If the guidewire becomes damaged, guidewire and any
associated componentry must be removed together.
-
Do not resterilize the catheter or accessories by any method.
-
Contents sterile and non-pyrogenic in unopened, undamaged
package. STERILIZED BY ETHYLENE OXIDE
-
Do not re-use catheter or accessories as there may be a failure
to adequately clean and decontaminate the device which may lead
to contamination, catheter degradation, device fatigue, or
endotoxin reaction.
-
Do not use catheter or accessories if package is opened or
damaged.
-
Do not use catheter or accessories if any sign of product damage
is visible or the use-by date has passed.
-
Do not use sharp instruments near the extension tubing or
catheter lumen.
- Do not use scissors to remove dressing.
-
Do not clamp over guidewire or stylet. Precautions listed in the
Split Stream® Catheter IFU are as follows:
-
Examine catheter lumen and extensions before and after each
treatment for damage.
-
To prevent accidents, ensure the security of all caps and
bloodline connections prior to and between treatments.
-
Use only Luer Lock (threaded) Connectors with this catheter.
-
In the rare event that a hub or connector separates from any
component during insertion or use, take all necessary steps and
precautions to prevent blood loss or air embolism and remove the
catheter.
-
Before attempting catheter insertion, ensure that you are
familiar with the potential complications and their emergency
treatment should any of them occur.
-
Repeated overtightening of bloodlines, syringes, and caps will
reduce connector life and could lead to potential connector
failure.
-
The catheter will be damaged if clamps other than what is
provided with this kit are used.
-
Avoid clamping near the Luer Lock and hub of the catheter.
Clamping of the tubing repeatedly in the same location may
weaken tubing. Additional warnings and cautions listed in the
Split Stream® Catheter IFU are as follows:
-
Physician discretion is strongly advised when inserting this
catheter in patients who are unable to take or hold a deep
breath.
-
Patients requiring ventilator support are at increased risk of
pneumothorax during subclavian vein cannulation, which may cause
complications.
-
Extended use of the subclavian vein may be associated with
subclavian vein stenosis.
-
The incidence of infection may be increased with femoral vein
insertion.
-
Do not pull tunneler out at an angle. Keep tunneler straight to
prevent damage to catheter tip.
-
DO NOT grasp and pull the guidewire prior to releasing the
J-Straightener. Damage to the guidewire may occur if it is
pulled against the restraint of the J-Straightener.
-
The length of the wire inserted is determined by the size of the
patient. Monitor patient for arrhythmia throughout this
procedure. The patient should be placed on a cardiac monitor
during this procedure. Cardiac arrhythmias may result if
guidewire is allowed to pass into the right atrium. The
guidewire should be held securely during this procedure.
-
Insufficient tissue dilation can cause compression of the
catheter lumen against the guidewire causing difficulty in the
insertion and removal of the guidewire from the catheter. This
can lead to bending of the guidewire.
-
The Valved Peelable Introducer is not designed for use in the
arterial system or as a hemostatic device.
-
DO NOT bend the sheath/dilator during insertion as bending will
cause the sheath to prematurely tear. Hold the introducer close
to the tip (approximately 3cm from tip) when initially inserting
through the skin surface. To progress the introducer towards the
vein, regrasp the introducer a few centimeters above the
original grasp location and push down on the introducer. Repeat
procedure until introducer is inserted to appropriate depth
based on patient anatomy and physician’s discretion.
-
Never leave sheath in place as an indwelling catheter. Damage to
the vein will occur.
-
Assure that all air has been aspirated from the catheter and
extensions. Failure to do so may result in air embolism.
-
Failure to verify catheter placement may result in serious
trauma or fatal complications.
-
Care must be taken when using sharp objects or needles in close
proximity to catheter lumen. Contact from sharp objects may
cause catheter failure.
-
Only clamp catheter with in-line clamps provided.
-
Extension clamps should only be open for aspiration, flushing,
and dialysis treatment.
-
Patients must not swim, shower, or soak dressing while bathing.
-
Always review hospital or unit protocol, potential complications
and their treatment, warnings, and precautions prior to
undertaking any type of mechanical or chemical intervention in
response to catheter performance problems.
-
Only a physician familiar with the appropriate techniques should
attempt the following procedures.
-
Due to the risk of exposure to HIV (Human Immunodeficiency
Virus) or other blood borne pathogens, health care professionals
should always use Universal Blood and Body Fluid Precautions in
the care of all patients.
-
Do not pull distal end of catheter through incision as
contamination of wound may occur.
Other Relevant Aspects of Safety: For a period of
01 January 2020 to 31 March 2025 there were 285 complaints for
61,824 units sold, giving an overall complaint rate of 0.46%. No
events resulted in recalls during the review period.
5. Summary of Clinical Evaluation and Post-Market Clinical
Follow-Up (PMCF)
Summary of Clinical Data Related to Subject Device
Specific Case Numbers (Mixed Cohort Case Numbers) Identified and
Used for Clinical Performance Evaluation
| Product Family |
Clinical Literature |
PMCF Data |
Total Cases |
User Survey Responses |
| 179 |
107 |
286 |
0 |
|
Clinical performance was measured using parameters including but
not limited to dwell time, catheter insertion outcomes, and
adverse event rates. Critical clinical parameters extracted from
these studies met standards set forth in the guidelines for the
State of the Art. There were no unforeseen adverse events or other
high occurrences of adverse events detected in any of the clinical
activities. Medcomp® catheters are subjected to, and must pass,
simulated use testing intended to replicate use 3 times per week
for 12 months as part of device development. The Split Stream®
Catheter passed this testing. Although Medcomp® catheters contain
no materials which degrade over time, fully functional catheters
may be removed for other reasons, such as intractable infection,
change of therapy (such as Renal replacement (transplant) or use
of an arterio-venous graft/fistula). Published clinical literature
does not always focus on the physical lifetime of a catheter for
these reasons. In the case of the Split Stream® Catheter, 45, 49,
and 47 catheters had 112, 130.7, and 130.5 day mean durations of
use that has been found in clinical use reported to date. Based on
this information, the Split Stream® Catheter has a 12-month
lifetime; however, the decision to remove and/or replace the
catheter should be based on clinical performance and need, and not
any predetermined point in time.
Summary of Clinical Data Related to the Equivalent Device
Clinical evidence from published literature and PMCF activities
has been generated specific to known and unknown variants of the
subject device. The equivalency rationale in the updated clinical
evaluation report will demonstrate that the clinical evidence
available for these variants is representative of the range of
device variants in the device family. There are no clinical or
biological differences between variants within the subject device
family, and the potential impact of the technical differences will
be rationalized in the updated clinical evaluation report.
Summary of Clinical Data from Pre-Market Investigations (if
applicable)
No pre-market clinical devices were used for the device’s clinical
evaluation.
Summary of Clinical Data from Other Sources
Source:Summary of Published Literature
Clinical evidence literature searches have found three published
literature articles representing 179 Split Stream® device family
specific cases. The articles include one randomized controlled
trial (Silva et al., 2008), one retrospective study (Leou et al.,
2013), and one case study (Ogawa et al., 2021). Bibliography: Leou
S, Garnier F, Testevuide P, et al. Évaluation des complications
infectieuses liées aux cathéters veineux centraux d’hémodialyse en
Polynésie française. Néphrologie & Thérapeutique.
2013;9(3):137-42. Ogawa, Tomonari; Inamura, Megumi; Kawai,
Yuichiro; Yamamoto, Ryo; Yasuda, Kunihiko; Shimizu, Taisuke;
Tamaru, Jun-ichi; Hasegawa, Hajime; (2021). Difficulty removing
dialysis cuff catheter after its adhesion to the right atrium
#journal#, (#issue#), 1129729821993981 Silva J, Teixeira e C,
Baptista A, Ramos A, Ponce P. Catheter-related bacteremia in
hemodialysis: which preventive measures to take? Nephron Clinical
practice. 2008;110(4):c251-257.
Source:LTHD Data Collection Survey Report
The Long-Term Hemodialysis Catheter Data Collection Survey was
intended to gather safety and performance outcome information from
sites that purchase Medcomp long-term hemodialysis catheters for
use in EU MDR clinical evaluation. Responses were requested to be
completed by physicians or other site employees with oversight and
direction from a physician. The surveys were distributed globally
to existing Medcomp customers. Responses were collected from
twenty-one sites, spanning nine countries (Colombia, Croatia, El
Salvador, Greece, Italy, Netherlands, Panama, Uruguay, and USA)
across North America, South/Latin America, and Europe. At least
partial data was collected on 56 Split Stream® catheter product
family cases. Of these 56 cases, all were described as 14F, with
29 catheters of 24cm length, 18 catheters of 28cm length, and 9
catheters of 32cm length. Information was collected on Insertion
Success (100%, n=56), but no dwell time information was provided.
Due to the absence of dwell time information, rate information
could not be derived, and only insertion success was concluded to
be within State of the Art safety and performance outcome measures
from published literature.
• Source:PMCF_Infusion_211
The Infusion Product Line Data Collection Survey aimed to assess
safety and performance outcome information for all variants of
Medcomp Infusion Ports, PICCs, Midlines, and CVCs. 70 survey
responses were collected from 17 countries representing 471 device
cases. 7 Split Stream® cases, all described as 14F, inclusive of
several variant devices across length (28cm, 32cm, 40cm) were
collected. The following outcome measures were collected for
Medcomp Split Stream® devices:
Procedural Outcomes – 100%
Catheter Related Blood Stream Infection – No Events Reported
Catheter Associated Venous Thrombus – No Events Reported
Exit Site Infection – No Events Reported
• Source:PMCF_Medcomp_211
The Medcomp User Survey acquired responses from healthcare
personnel familiar with any number of Medcomp’s product offerings.
28 respondents responded that they or their facility have used
Medcomp long-term hemodialysis catheters; there were no
respondents that have used the Split Stream® device. There were no
differences in mean user sentiments within long-term hemodialysis
catheters across State of the Art Performance and Safety Outcome
Measures or between device types relating to safety or
performance. The following data points were collected from users
of Medcomp long-term hemodialysis catheters (n=28):
(Mean Likert Scale Response) Catheters function as intended – 4.8
/ 5
(Mean Likert Scale Response) Packaging allows for aseptic
presentation – 4.8 / 5
(Mean Likert Scale Response) Benefit outweighs the risk – 4.7 / 5
Dwell Time (n=26) – 167 days (95%CI: 130 – 203)
• Source:PMCF_LTHD_242
The Long-Term Hemodialysis (LTHD) Truveta data analysis assessed
safety and performance outcome information for Medcomp® and
competitor devices present in Truveta Studio. Truveta data comes
from a growing collective of more than 30 health systems that
provide 17% of the daily clinical care across all 50 U.S. states
from 800 hospitals and 20,000 clinics, representing the full
diversity of the United States. The population used for data
analysis was derived utilizing Truveta Studio’s proprietary coding
language (Prose) and unique device identifier (UDI) codes
representing all saleable Medcomp® LTHD devices and LTHD devices
distributed and/or manufactured by other companies. 44 Split
Stream® cases inclusive of several variant devices were collected.
All cases were described as 14F and Straight Cases, configurations
(straight), and lengths (24cm, 32cm), representation of 24cm and
32cm length catheters. The following State of the Art safety and
performance outcome measures were observed for Medcomp Split
Stream® devices:
Catheter Related Blood Stream Infection – 0 per 1,000 catheter
days (95%CI: 0 – 0.93)
Catheter Associated Venous Thrombus – 0 per 1,000 catheter days
(95%CI: 0 – 0.93)
Exit Site Infection – 0 per 1,000 catheter days (95%CI: 0 – 0.93)
Tunnel Infection – 0 per 1,000 catheter days (95%CI: 0 – 0.93)
Dwell Time – 82.5 days (95%CI: 0 – 199.04) The catheter brand
logistic regression model did not find that any Medcomp® catheter
brands were statistically significantly associated with an
increase of the incidence of CRBSI. The brand agnostic logistic
regression found that pediatric age group (0–19 years), femoral
vein insertion site, catheters that were the fourth or beyond in
sequence for a given patient, split-tip designs, and pre-curved
configurations were statistically significantly associated with
the incidence of CRBSI. The Split Cath® III was associated with a
statistically significant decrease in CRBSI incidence in the brand
model (OR: 0.46 95%CI: 0.33 - 0.63), and both shorter catheter
length (<=24cm) and smaller French size (<14.5F) in the
brand agnostic model.
Overall Summary of Clinical Safety and Performance
| Outcome |
Benefit/Risk Acceptability Criteria |
Desired Trend |
Clinical Literature (Subject Device) |
PMCF Data (Subject Device) |
| Performance Outcomes |
| Dwell Time |
Greater than 40 days |
+
|
105.4 days - 130.7 days (Summary of Published Literature)
|
82.5 days (PMCF_LTHD_242)
|
| Procedural Outcomes |
Greater than 93.3% |
+
|
ND*
|
100% (LTHD Data Collection Survey Report &
PMCF_Infusion_211)
|
| Safety Outcomes |
|
Catheter Related Blood Stream Infection (CRBSI)
|
Less than 4.8 incidents of CRBSI per 1,000 catheter days
|
-
|
0.16 – 1.78 per 1,000 catheter days (Summary of Published
Literature)
|
No Events Reported (LTHD Data Collection Survey Report &
PMCF_Infusion_211) 0 per 1,000 catheter days
(PMCF_LTHD_242)
|
| Tunnel Infection Rate |
Less than 2.8 incidents of tunnel infection per 1,000
catheter days
|
-
|
0.25** - 0.59** per 1,000 catheter days (Summary of
Published Literature)
|
No Events Reported (LTHD Data Collection Survey Report &
PMCF_Infusion_211) 0 per 1,000 catheter days
(PMCF_LTHD_242)
|
| Exit Site Infection Rate |
Less than 3.2 incidents of exit site infection per 1,000
catheter days
|
-
|
0.25** - 0.59** per 1,000 catheter days (Summary of
Published Literature)
|
No Events Reported (LTHD Data Collection Survey Report &
PMCF_Infusion_211) 0 per 1,000 catheter days
(PMCF_LTHD_242)
|
|
Catheter Associated Venous Thrombus (CAVT)
|
Less than 3.04 incidents of CAVT per 1,000 catheter days
|
-
|
2.13*** - 3.2*** per 1,000 catheter days (Summary of
Published Literature)
|
No Events Reported (LTHD Data Collection Survey Report &
PMCF_Infusion_211) 0 per 1,000 catheter days
(PMCF_LTHD_242)
|
*ND:= No data on the clinical parameter
**Silva et al., 2008 and Leou et al., 2013:do not differentiate
between exit site and tunnel infection
***Obstruction episodes from Silva et al., 2008:is used to
approximate the rate of CAVT
| Outcome |
Benefit/Risk Acceptability Criteria |
Desired Trend |
Clinical Literature (Subject Device) |
PMCF Data (Subject Device) |
| Performance Outcomes |
| Safety Outcomes |
On-going or Planned Post-Market Clinical Follow-Up (PMCF)
| Activity |
Description |
Reference |
Timeline |
|
Multi-center Patient-Level Case Series
|
Collect additional clinical data on the device by acquiring
case data healthcare personnel familiar with the device.
|
PMCF_LTHD_241 |
Q4 2025 |
| State of the Art Literature Search |
Identify risks and trends with use of similar devices by
reviewing applicable standards, published literature,
conference abstracts, guidance documents and
recommendations; information relating to the medical
condition managed by the device and medical alternatives
available for the same target treated population.
|
SAP-HD |
Q2 2026 |
| Clinical Evidence Literature Search |
Identify risks and trends with use of the device by
reviewing any clinical data relevant to the device from
published literature.
|
LRP-HD |
Q2 2026 |
| Global Trial Database Search |
Identify ongoing clinical trials involving Split Stream®
catheters.
|
N/A |
Q2 2026 |
No emerging risks, complications or unexpected device failures
have been detected from PMCF activities.
6. Possible Therapeutic Alternatives
The Kidney Disease Outcomes Quality Initiative (KDOQI) 2019
clinical practice guidelines have been used to support the below
recommendations for treatments.
| Therapy |
Benefits |
Disadvantages |
Key Risks |
| • AV Fistula |
-
Permanent vascular access solution
-
Lower complication rate than hemodialysis via catheter
|
- Requires time to mature
-
Patients must sometimes self-cannulate
|
- Stenosis
- Thrombosis
- Aneurysm
- Pulmonary hypertension
- Steal Syndrome
- Septicemia
|
| • Hemodialysis Catheter |
-
Useful for quick vascular access without AV Fistula in
place
-
Can be used as a bridge dialysis method between other
therapies
|
- Not a permanent solution
-
Catheter dysfunction can disrupt regular treatment
-
Benefit is not equal for all patient populations
|
- Post-procedural bleeding
- Infection
- Thrombosis
-
Decreased blood flow in dysfunctional catheter
- Cardiovascular events
-
Fibrin sheath formation around catheter
- Septicemia
|
| • Peritoneal Dialysis |
-
Less restrictive diet than hemodialysis
-
Does not require hospitalization, can be done in any
clean place
|
-
Clearance of impurities is limited by dialysate flow and
peritoneal area
|
- Peritonitis
- Septicemia
- Fluid overload
|
| • Kidney Transplant |
-
Better quality of life compared to HD
-
Lower risk of death compared to HD
-
Fewer dietary restrictions compared to HD
|
-
Requires a donor which can take time
-
More risky for certain groups (aged, diabetics, etc.)
-
Patient must take rejection medication for life
-
Rejection medication has side effects
|
- Thrombosis
- Hemorrhage
- Ureteral blockage
- Infection
- Organ rejection
- Death
- Myocardial infarction
- Stroke
|
| • Comprehensive Conservative Care |
-
Less imposed symptom burden than dialysis
- Preserves life satisfaction
|
- May aggravate clinical condition
-
Not designed to treat, but to minimize adverse events
|
-
Treatment may not actually minimize risks associated
with CKD
|
7. Suggested Profile and Training for Users
The catheter should be inserted, manipulated, and removed by a
qualified, licensed physician or other qualified health care
professional under the direction of a physician. In certain
circumstances, patients who may be suitable for home hemodialysis
may manipulate the external connections of the catheter. As per
guidelines stated from the International Society of Hemodialysis,
if home dialysis is recommended, each patient will undergo a
thorough training in order to obtain optimal results from home
dialysis treatments. The objectives of the training program are to
(1) provide the appropriate amount of information to ensure that
the patient will be able to dialyze safely at home; (2) enable the
patient to monitor and manage other elements of his or her chronic
kidney disease, such as obtaining samples for lab work and
maintaining appropriate nutrition and diet; and (3) help the
patient and his or her care partner(s) cope with barriers and
fears associated with home HD During training, the patient will
also receive technical education on the operations and maintenance
of the water treatment system. During training, the ideal nurse
trainer-to-patient ratio is typically 1:1. An idealized schedule
of training is created, with weekly areas of focus and training
objectives. In practice, however, training is individualized to
address any identified learning barriers or risks for failure.
8. Reference to Any Harmonized Standards and Common Specifications
(CS) Applied
| Harmonized Standard or CS |
Revision |
Title or Description |
Level of Compliance |
| EN ISO 14971 |
2019 |
Medical devices. Application of risk management to medical
devices
|
Full |
| EN ISO 10555-1 |
2023 |
Intravascular catheters. Sterile and single-use catheters.
General requirements
|
Full |
| ISO 10555-3 |
2013 |
Intravascular catheters. Sterile and single-use catheters.
Central venous catheters
|
Full |
| EN ISO 11607-1 |
2020+A1:2023 |
Packaging for terminally sterilized medical devices.
Requirements for materials, sterile barrier systems and
packaging systems
|
Full |
| EN ISO 11607-2 |
2020+A1:2023 |
Packaging for terminally sterilized medical devices.
Validation requirements for forming, sealing and assembly
processes
|
Full |
| MEDDEV 2.7/1 |
Rev 4 |
Clinical Evaluation: A Guide for Manufacturers and Notified
Bodies Under Directives 93/42/EEC and 90/385/EEC
|
Full |
| MEDDEV 2.12/2 |
Rev. 2 |
GUIDELINES ON MEDICAL DEVICES POST MARKET CLINICAL FOLLOW-UP
STUDIES A GUIDE FOR MANUFACTURERS AND NOTIFIED BODIES
|
Full |
| EN ISO 14155 |
2020 |
Clinical investigation of medical devices for human subjects
— Good clinical practice
|
Full |
| MDCG 2020-6 |
2020 |
Clinical evidence needed for medical devices previously CE
marked under Directives 93/42/EEC or 90/385/EEC
|
Full |
| MDCG 2020‑7 |
2020 |
Post-market clinical follow-up (PMCF) Plan Template A guide
for manufacturers and notified bodies
|
Full |
| MDCG 2020‑8 |
2020 |
Post-market clinical follow-up (PMCF) Evaluation Report
Template A guide for manufacturers and notified bodies
|
Full |
| MDCG 2022-9 |
2022 |
Summary of safety and clinical performance
|
Full |
| MDCG 2022-21 |
2022 |
Guidance on Periodic Safety Update Report (PSUR) According
to Regulation EU 2017/745 (MDR)
|
Full |
| ISO 10993-1 |
2020 |
Biological evaluation of medical devices — Part 1:
Evaluation and testing within a risk management process
|
Full |
| ISO 10993-18 |
2020+A1:2023 |
Biological evaluation of medical devices — Part 18: Chemical
characterization of medical device materials within a risk
management process
|
Full |
| EN ISO 10993-7 |
2008 + A1: 2022 |
Biological evaluation of medical devices — Part 7: Ethylene
oxide sterilization residuals — Amendment 1: Applicability
of allowable limits for neonates and infants
|
Full |
| EN ISO 11135 |
2014 + A1: 2019 |
Sterilization of health-care products. Ethylene oxide.
Requirements for the development, validation and routine
control of a sterilization process for medical devices
|
Full |
| ISO 14644-1 |
2015 |
Cleanrooms and associated controlled environments — Part 1:
Classification of air cleanliness by particle concentration
|
Full |
| ISO 14644-2 |
2015 |
Cleanrooms and associated controlled environments — Part 2:
Monitoring to provide evidence of cleanroom performance
related to air cleanliness by particle concentration
|
Full |
| EN 556-1 |
2024 |
Sterilization of medical devices. Requirements for medical
devices to be designated "STERILE". Requirements for
terminally sterilized medical devices
|
Full |
| EN ISO 11737-1 |
2018 + A1: 2021 |
Sterilization of health care products. Microbiological
methods. Determination of a population of microorganisms on
products
|
Full |
| EN 11737-3 |
2023 |
Sterilization of health care products. Microbiological
methods — Bacterial endotoxin testing
|
Full |
| ANSI/AAMI ST72 |
2019 |
Bacterial endotoxins-Test methods, routine monitoring, and
alternatives to batch testing
|
Full |
| EN ISO 20417 |
2021 |
Medical Devices - Information supplied by the manufacturer
|
Full |
| EN ISO 15223-1 |
2021 |
Medical devices — Symbols to be used with medical device
labels, labelling and information to be supplied — Part 1:
General requirements
|
Full |
| EN 62366-1 |
2015 + A1: 2020 |
Medical devices — Part 1: Application of usability
engineering to medical devices
|
Full |
| ASTM D4332 |
2022 |
Standard Practice for Conditioning Containers, Packages, or
Packaging Components for Testing
|
Full |
| ASTM F2503 |
2023e1 |
Standard Practice for Marking Medical Devices and Other
Items for Safety in the Magnetic Resonance Environment
|
Full |
| EN ISO 11070 |
2014+A1:2018 |
Sterile single-use intravascular introducers, dilators and
guidewires
|
Full |
| ISO 594-1 |
1986 |
Conical fittings with a 6 % (Luer) taper for syringes,
needles and certain other medical equipment — Part 1:
General requirements
|
Full |
| ISO 594-2 |
1998 |
Conical fittings with a 6 % (Luer) taper for syringes,
needles and certain other medical equipment — Part 2: Lock
Fittings
|
Full |
| ASTM D4169 |
2023e1 |
Standard Practice for Performance Testing of Shipping
Containers and Systems
|
Full |
| EN ISO 13485 |
2016 + A11: 2021 |
Medical Devices – Quality Management system – Requirements
for Regulatory Purposes
|
Full |
| PD CEN ISO/TR 20416 |
2020 |
Medical devices — Post-market surveillance for manufacturers
|
Full |
| EN ISO 80369-7 |
2021 |
Small-bore connectors for liquids and gases in healthcare
applications Part 7: Connectors for intravascular or
hypodermic applications
|
Full |
| MDCG 2018-1 |
Rev. 4 |
Guidance on BASIC UDI-DI and changes to UDI-DI
|
Full |
| EN ISO 11140-1 |
2014 |
Sterilization of health care products — Chemical indicators
Part 1: General requirements
|
Full |
| EN ISO/IEC 17025 |
2017 |
General requirements for the competence of testing and
calibration laboratories
|
Full |
| Regulation (EU) 2017/745 |
2017 |
Regulation (EU) 2017/745 of the European Parliament and of
the Council
|
Full |
Revision History
| Revision |
Date |
CR# |
Author |
Description of Changes |
Validated |
| 1 |
04OCT2021 |
26535 |
RS |
Implementation of SSCP |
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 2 |
28JUN2022 |
27030 |
RS |
Scheduled Update |
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 3 |
26JUN2023 |
28249 |
GM |
Periodic Update; Updated in Accordance with CER-007,
Revision D
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 4 |
21JUN2024 |
29455 |
GM |
Periodic Update; Updated in Accordance with CER-007,
Revision E
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 5 |
05SEP2025 |
25-0166 |
GM |
Periodic Update; Updated in Accordance with CER-007,
Revision F
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|