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) |
16002-A5 |
| ‘MDR Documentation’ File Number |
MDR-033 |
1. Device Identification and General Information
Device Trade Name(s): Symetrex®
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: 00884908307N6
Medical Device Nomenclature: F900202 — Permanent
Hemodialysis Catheter and Kits
Class of Device: III
Date First CE Certificate Issued: 16-Oct
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 |
| 15.5F x 19cm Symetrex w/ sideholes |
10764-819-201 |
|
| 15.5F x 19cm Symetrex w/o sideholes |
10763-819-201 |
|
| 15.5F x 23cm Symetrex w/ sideholes |
10764-823-201 |
|
| 15.5F x 23cm Symetrex w/o sideholes |
10763-823-201 |
|
| 15.5F x 28cm Symetrex w/ sideholes |
10764-828-201 |
|
| 15.5F x 28cm Symetrex w/o sideholes |
10763-828-201 |
|
| 15.5F x 33cm Symetrex w/ sideholes |
10764-833-201 |
|
| 15.5F x 33cm Symetrex w/o sideholes |
10763-833-201 |
|
| 15.5F x 37cm Symetrex w/ sideholes |
10764-837-201 |
|
| 15.5F x 37cm Symetrex w/o sideholes |
10763-837-201 |
|
| 15.5F x 42cm Symetrex w/ sideholes |
10764-842-201 |
|
| 15.5F x 42cm Symetrex w/o sideholes |
10763-842-201 |
|
| Variant Description |
Part Number(s) |
Explanation of Multiple Part Numbers |
Procedure Trays:
Procedure Trays:
| Catalog Code |
Part Number |
Description |
| MBPS019E. |
10763-819-201 |
15.5F X 19CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes w/ Dual Stylet Set
|
| MBPS023E. |
10763-823-201 |
15.5F X 23CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes w/ Dual Stylet Set
|
| MBPS028E. |
10763-828-201 |
15.5F X 28CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes w/ Dual Stylet Set
|
| MBPS033E. |
10763-833-201 |
15.5F X 33CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes w/ Dual Stylet Set
|
| MUPS019E. |
10763-819-201 |
15.5F X 19CM Symetrex® Double Lumen Hemodialysis w/o
Sideholes w/ Dual Stylet Catheter Only Set
|
| MUPS023E. |
10763-823-201 |
15.5F X 23CM Symetrex® Double Lumen Hemodialysis w/o
Sideholes w/ Dual Stylet Catheter Only Set
|
| MUPS028E. |
10763-828-201 |
15.5F X 28CM Symetrex® Double Lumen Hemodialysis w/o
Sideholes w/ Dual Stylet Catheter Only Set
|
| MUPS033E. |
10763-833-201 |
15.5F X 33CM Symetrex® Double Lumen Hemodialysis w/o
Sideholes w/ Dual Stylet Catheter Only Set
|
| MBNS037E. |
10763-837-201 |
15.5F X 37CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes Set
|
| MBNS042E. |
10763-842-201 |
15.5F X 42CM Symetrex® Double Lumen Hemodialysis Catheter
w/o Sideholes Set
|
| MBPS019SE. |
10764-819-201 |
15.5F X 19CM Symetrex® Double Lumen Hemodialysis Catheter w/
Dual Stylet Set
|
| MBPS023SE. |
10764-823-201 |
15.5F X 23CM Symetrex® Double Lumen Hemodialysis Catheter w/
Dual Stylet Set
|
| MBPS028SE. |
10764-828-201 |
15.5F X 28CM Symetrex® Double Lumen Hemodialysis Catheter w/
Dual Stylet Set
|
| MBPS033SE. |
10764-833-201 |
15.5F X 33CM Symetrex® Double Lumen Hemodialysis Catheter w/
Dual Stylet Set
|
| MUPS019SE. |
10764-819-201 |
15.5F X 19CM Symetrex® Double Lumen Hemodialysis w/ Dual
Stylet Catheter Only Set
|
| MUPS023SE. |
10764-823-201 |
15.5F X 23CM Symetrex® Double Lumen Hemodialysis w/ Dual
Stylet Catheter Only Set
|
| MUPS028SE. |
10764-828-201 |
15.5F X 28CM Symetrex® Double Lumen Hemodialysis w/ Dual
Stylet Catheter Only Set
|
| MUPS033SE. |
10764-833-201 |
15.5F X 33CM Symetrex® Double Lumen Hemodialysis w/ Dual
Stylet Catheter Only Set
|
| MBNS037SE. |
10764-837-201 |
15.5F X 37CM Symetrex® Double Lumen Hemodialysis Catheter
Set
|
| MBNS042SE. |
10764-842-201 |
15.5F X 42CM Symetrex® Double Lumen Hemodialysis Catheter
Set
|
Procedure Trays:
| Catalog Code |
Part Number |
Description |
Configurations of Procedure Trays:
| Configuration Type |
Kit Components |
| Catheter Only |
(1) Catheter (2) End Cap |
| Catheter Only with Stylet |
(1) Catheter (2) Stylet (2) End Cap |
| Catheter Set |
(1) Catheter (1) Guidewire (1) Guidewire Advancer (1) 18ga
Introducer Needles (1) Tunneler (1) 14F Valved Peelable
Introducer (1) 12F Dilator (1) 14F Dilator (2) End Cap
|
| Catheter Set with Stylet |
(1) Catheter (2) Stylet (1) Guidewire (1) Guidewire Advancer
(1) (18GA) Introducer Needle (1) Tunneler (1) 14F Valved
Peelable Introducer (1) 12F Dilator (1) 14F Dilator (2) End
Cap
|
2. Intended Use of the Device
Intended Purpose: As per product IFU (IFU
40818-1BSI), Symetrex® 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): As per product IFU (IFU
40818-1BSI), the Symetrex® Catheter is 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): Symetrex® 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:
3. Device Description
Device Name: Symetrex®
Description of Device: The Symetrex® Catheter is
a 15.5 French, dual lumen, radiopaque catheter made of
polyurethane. It has a polyester retention cuff and two female
luer adapters. The retention cuff promotes tissue ingrowth to
anchor the catheter in the subcutaneous tunnel. The luer adapters
are identical in color to indicate the reversibility of this
catheter. This catheter features symmetrical side channels with a
distal tip configuration designed to separate the intake flow from
the output flow in both directions. The catheter has been tested
at flow rates of up to 500 mL/min. The catheter is available in a
variety of lengths and with or without sideholes to accommodate
physician preference and clinical needs.
Device Name: Symetrex®
Description of Device:
Materials / Substances in Contact with Patient Tissue:
The percentage ranges in the table below are based on the weights
of the 15.5F x 19cm catheter without sideholes (11.88g), 15.5F x
19cm catheter with sideholes (11.87g), 15.5F x 42cm catheter
without sideholes (15.60g) , and 15.5F x 42cm catheter with
sideholes (15.59g).
| Material |
% Weight (w/w) |
| Polyurethane |
35.96 - 46.50 |
| Acetyl Copolymer |
15.82 - 20.79 |
| Isoplast |
20.94 - 27.53 |
| Barium Sulfate |
7.69 - 10.64 |
| Acrylonitrile butadiene styrene |
4.26 - 5.60 |
| Polyester |
1.85 - 2.43 |
| Chloroform |
<1 |
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.
|
| Introducer Needle |
Used for the percutaneous introduction of guidewires.
|
| Stylet |
Assists in catheter insertion |
| Tunneler |
Instrument used to create a subcutaneous tunnel
|
| 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.
|
| 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 |
| Syringe |
Attached to introducer needle to help capture blood return
once introducer needle perforates targeted vein, prevent air
embolism
|
| Scalpel |
A cutting device during surgical, pathology and minor
medical procedures
|
| Suture |
Used to close the insertion site and exit site
|
| Adhesive Wound Dressing |
Used to protect the catheter from contamination when not in
use
|
4. Risks and Warnings
Residual Risks and Undesirable Effects: As per
product IFU (IFU 40818-1BSI), 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
|
| Allergic Reaction |
Allergic Reaction
|
| Bleeding |
Bleeding (May be Severe)
|
| Cardiac Event |
Cardiac Arrhythmia
|
| Embolism |
Air Embolus
|
| Infection |
Bacteremia
|
| Perforation |
Arterial Puncture
|
| Thrombosis |
Dissection or Occlusion of the Carotid Artery
|
| Tissue Injury |
Brachial Plexus Injury
|
| Miscellaneous Complications |
Death
|
|
Quantification of Residual Risks
|
|
PMS Complaints 01 January 2019 – 31 March 2025
|
PMCF Events |
|
Units Sold: 31,093 |
Units Studied: 65 |
|
Patient Residual Harm Category
|
% of Devices |
% of Devices |
| Allergic Reaction |
Not Reported |
Not Reported |
| Bleeding |
0.02% |
Not Reported |
| Cardiac Event |
Not Reported |
Not Reported |
| Embolism |
Not Reported |
Not Reported |
| Infection |
Not Reported |
Not Reported |
| Perforation |
Not Reported |
Not Reported |
| Stenosis |
Not Reported |
Not Reported |
| Tissue Injury |
Not Reported |
Not Reported |
| Thrombosis |
0.01% |
12.3% |
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 40818-1BSI), the Symetrex®
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 clamp
the shaft of the catheter. Use only the line extension clamps
which have been provided with the catheter. • Do not insert the
valved pull-apart sheath/introducer further than necessary.
Depending upon patient size and access site, it may not be
necessary to insert the entire length of the introducer into the
vessel. • 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 lines or catheter lumen. • Do not use scissors to
remove dressing. • Do not suture through any part of the
catheter. There is a danger of tearing the catheter tubing or
damaging the suture wing from the bifurcate if excessive force
is applied to the catheter. • Do not use excessive force to
flush obstructed lumen. Precautions listed in the Symetrex®
Catheter IFU are as follows: • Before attempting procedure,
ensure that you are familiar with the potential complications
and their emergency treatment should any of them occur. • 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. • 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
catheter. • To minimize the risk of air embolism or
extravasation, keep the catheter clamps closed at all times when
not in use or when attached to a syringe, IV tubing, or
bloodlines. • Before attempting catheter insertion, ensure that
you are familiar with the potential complications and their
emergency treatment should any of them occur. • To help avoid
air embolism, fill (prime) the device with sterile,
anticoagulant lock solution or normal saline solution prior to
catheter insertion. • Avoid sharp or acute angles that could
compromise the opening of the catheter lumens. • 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. • Health care
professionals should always use universal blood and body fluid
precautions in the care of all patients to minimize the risk of
exposure to HIV (Human Immunodeficiency Virus) or other blood
borne pathogens. Sterile technique must be strictly adhered to
during any handling of the device. • Peel-away introducer must
only be advanced over a guidewire. • The valved pull-apart
sheath/introducer is designed to reduce blood loss and the risk
of air intake. • The valved pull-apart sheath/introducer is not
intended for arterial use. • Discard biohazard according to
facility protocol. • Examine the device after it is removed from
the patient to ensure no foreign material remains inside the
patient.
Other Relevant Aspects of Safety: For a period of
01 January 2020 to 31 March 2025 there were 34 complaints for
27,900 units sold, giving an overall complaint rate of 0.122%.
There were no death-related events. 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 |
| 0 |
65 |
65 |
38 |
|
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 12 months use as part
of device development. The Symetrex® Catheter passed this testing.
Although Medcomp® catheters materials contain non-degradable
polymers, fully functional catheters may be removed for other
reasons, such as intractable infection or change of therapy.
Published clinical literature does not always focus on the
physical lifetime of a catheter for these reasons. In the case of
the Symetrex® Catheter, 46 catheters had a 87 day [95%CI: 61.7 –
112.3 days] duration of use that has been found in clinical use
reported to date. Based on this information, the Symetrex®
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 clinical
evaluation report demonstrates 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 is
rationalized in the 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: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 64 Symetrex® catheter product family
cases totalling 4,004 catheter days. Of these 64 cases, 55
described as with sideholes and 13 described as without sideholes.
There were 26 catheters of 19cm length, 31 catheters of 23cm
length, 6 catheters of 28cm length, and 1 catheters of 33cm.
Information was collected on Insertion Success (98.4%, n=64) and
dwell time (mean 87 days, 95% CI: 61.7 112.3, n=46). There were
eight reports of catheter associated venous thrombus (2 per 1,000
catheter days), and no reports of tunnel infection, exit site
infection, or catheter related blood stream infection. These
outcomes, aside from catheter associated venous thrombus, were
concluded to be within State of the Art safety and performance
outcome measures from published literature. This is likely
attributable to the limited catheter days available for
statistical testing, as the sample rate (2 per 1,000 catheter
days) is better than the potential acceptance criteria of 3.04 per
1,000 catheter days.
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, with 2 of those
respondents using the Symetrex® 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) The following
data points were collected from users of Medcomp Symetrex®
catheters (n=2): • (Mean Likert Scale Response) Catheters function
as intended – 5 / 5 • (Mean Likert Scale Response) Packaging
allows for aseptic presentation – 5 / 5 • (Mean Likert Scale
Response) Benefit outweighs the risk – 5 / 5 • Dwell Time – 198
days (Range: 1-2 Months Approximately 1 Year)
Source:Symetrex® Survey Report
The Symetrex® Catheter Survey Report was intended to review and
tabulate responses to ensure the device remains safe and effective
when used as intended. Symetrex Survey Protocol was finalized on
08 February 2019. The Symetrex® Catheter Survey was provided
electronically to clinicians who use the product worldwide by the
product distributors. The survey received responses from 36
clinicians. Symetrex Survey Report was finalized on 30 March 2019.
The survey report concluded that the Medcomp® Symetrex® catheter
is safe and effective when used as directed, that the features
incorporated within the design of the Symetrex® catheter have
aided clinicians in its use, and few complications were reported.
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. 1 Symetrex®
case inclusive of several variant devices were collected. The case
was described as 15.5F and Straight Case, configurations
(straight), and length (42cm), representation of 42cm length
catheters. The following State of the Art safety and performance
outcome measures were observed for Medcomp Symetrex® devices: •
Catheter Related Blood Stream Infection – 0 per 1,000 catheter
days (95%CI: 0 – 40.99) • Catheter Associated Venous Thrombus – 0
per 1,000 catheter days (95%CI: 0 – 40.99) • Exit Site Infection –
0 per 1,000 catheter days (95%CI: 0 – 40.99) • Tunnel Infection –
0 per 1,000 catheter days (95%CI: 0 – 40.99) • Dwell Time – No
Days Reported 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 |
+
|
ND**
|
87 days (LTHD Data Collection Survey Report) 198 days
(PMCF_Medcomp_211) Likert Scale Response 5 / 5
(PMCF_Medcomp_211)*
|
| Procedural Outcomes |
Greater than 93.3% |
+
|
ND**
|
98.4% (LTHD Data Collection Survey Report) Likert Scale
Response 5 / 5 (PMCF_Medcomp_211)*
|
| Safety Outcomes |
|
Catheter Related Blood Stream Infection (CRBSI)
|
Less than 4.8 incidents of CRBSI per 1,000 catheter days
|
-
|
ND**
|
No Events Reported (LTHD Data Collection Survey Report)
Likert Scale Response 5 / 5 (PMCF_Medcomp_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
|
-
|
ND**
|
No Events Reported (LTHD Data Collection Survey Report)
Likert Scale Response 5 / 5 (PMCF_Medcomp_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
|
-
|
ND**
|
No Events Reported (LTHD Data Collection Survey Report)
Likert Scale Response 5 / 5 (PMCF_Medcomp_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
|
-
|
ND**
|
2 per 1,000 catheter days (LTHD Data Collection Survey
Report) Likert Scale Response 5 / 5 (PMCF_Medcomp_211)* 0
per 1,000 catheter days (PMCF_LTHD_242)
|
*PMCF_Medcomp_211 asked respondents, if they agreed on a scale of
1-5, that their experience in relation to each outcome was the
same or better than the benefit/risk acceptability criteria.:
**ND = No Data on Parameter:
| 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 Symetrex®
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 13485 |
2016 + A11:2021 |
Medical Devices – Quality Management system – Requirements
for Regulatory Purposes
|
Full |
| EN ISO 14971 |
2019+A11:2021 |
Medical devices. Application of risk management to medical
devices
|
Full |
| EN ISO 11607-1 |
2020 |
Packaging for terminally sterilized medical devices.
Requirements for materials, sterile barrier systems and
packaging systems
|
Full |
| EN ISO 11607-2 |
2020 |
Packaging for terminally sterilized medical devices.
Validation requirements for forming, sealing and assembly
processes
|
Full |
| EN ISO 10555-1 |
2013+A1:2017 |
Intravascular catheters. Sterile and single-use catheters.
General requirements
|
Full |
| EN ISO 10555-3 |
2013 |
Intravascular catheters. Sterile and single-use catheters.
Central venous catheters
|
Full |
| EN ISO 10993-1 |
2020 |
Biological evaluation of medical devices — Part 1:
Evaluation and testing within a risk management process
|
Full |
| EN ISO 10993-18 |
2020 |
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 |
| EN ISO 14644-1 |
2015 |
Cleanrooms and associated controlled environments — Part 1:
Classification of air cleanliness by particle concentration
|
Full |
| EN 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 |
| BS ISO 11737-3 |
2023 |
Sterilization of health care products. Microbiological
methods Bacterial endotoxin 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 |
| ISO 7000 |
2019 |
Graphical symbols for use on equipment. Registered symbols
|
Partial |
| EN 62366-1 |
2015 + A1: 2020 |
Medical devices — Part 1: Application of usability
engineering to medical devices
|
Full |
| BS EN ISO 80369-7 |
2021 |
Small-bore connectors for liquids and gases in healthcare
applications — Connectors for intravascular or hypodermic
applications
|
Full |
| ASTM D4332 |
2014 |
Standard Practice for Conditioning Containers, Packages, or
Packaging Components for Testing
|
Full |
| ASTM D4169 |
2022 |
Standard Practice for Performance Testing of Shipping
Containers and Systems
|
Full |
| ASTM F2503 |
2023e1 |
Standard Practice for Marking Medical Devices and Other
Items for Safety in the Magnetic Resonance Environment
|
Full |
| ASTM F1140/F1140M-13 |
2020 |
Standard Test Methods for Internal Pressurization Failure
Resistance of Unrestrained Packages
|
Full |
| ASTM F2096-11 |
2019 |
Standard Test Method for Detecting Gross Leaks in Packaging
by Internal Pressurization (Bubble Test)
|
Full |
| ASTM F88/F88M |
2023 |
Standard Test Method for Seal Strength of Flexible Barrier
Materials
|
Full |
| ASTM F1980 |
2021 |
Standard Guide for Accelerated Aging of Sterile Barrier
Systems and Medical Devices
|
Full |
| ASTM F640 |
2020 |
Standard Test Methods for determining Radiopacity for
Medical Use
|
Full |
| EN ISO 11070 |
2014+A1:2018 |
Sterile single-use intravascular introducers, dilators and
guidewires
|
Full |
| PD CEN ISO/TR 20416 |
2020 |
Medical devices — post-market surveillance for manufacturers
|
Full |
| Regulation (EU) 2017/745 |
2017 |
Regulation (EU) 2017/745 of the European Parliament and of
the Council
|
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 |
| 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 |
| 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 2019-9 |
2022 |
Summary of safety and clinical performance
|
Full |
| MDCG 2018-1 |
Rev. 4 |
Guidance on BASIC UDI-DI and changes to UDI-DI
|
Full |
| EN 17141 |
2020 |
Cleanrooms and associated controlled environments.
Biocontamination control
|
Full |
| EN ISO 11140-1 |
2014 |
Sterilization of health care products — Chemical indicators
Part 1: General requirements
|
Full |
| EN ISO 14155 |
2020 |
Clinical investigation of medical devices for human subjects
— Good clinical practice
|
Full |
Revision History
| Revision |
Date |
CR# |
Author |
Description of Changes |
Validated |
| 1 |
15AUG2022 |
27212 |
KO |
Implementation of SSCP |
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 2 |
10JUL2023 |
28290 |
GM |
Periodic Update; Updated in Accordance with CER-033,
Revision B
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 3 |
08NOV2023 |
28592 |
GM |
Correcting date of first CE certificate, list of
accessories, and harmonized standardized
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 4 |
13DEC2023 |
28714 |
GM |
Including variants in equivalency rationale
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 5 |
01JUL2024 |
29461 |
GM |
Periodic Update; Updated in Accordance with CER-033,
Revision C
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 6 |
05SEP2025 |
25-0172 |
GM |
Periodic Update; Updated in Accordance with CER-033,
Revision D
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|