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) |
1504 |
| ‘MDR Documentation’ File Number |
TD-031 |
1. Device Identification and General Information
Device Trade Name(s): Duo-Flow® 400XL® Catheter
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: 00884908305N2
Medical Device Nomenclature: F900201 – Temporary
Hemodialysis Catheters and Kits
Class of Device: III
Date First CE Certificate Issued: Mar-01
Authorized Representative Name and SRN: Gerhard
Frömel 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 short-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 12cm Pre-Curved Duo-Flow 400XL |
1583G |
|
| 14F x 12cm Straight Duo-Flow 400XL |
1539G |
|
| 14F x 15cm Pre-Curved Duo-Flow 400XL |
1584G |
|
| 14F x 15cm Straight Duo-Flow 400XL |
1504G |
|
|
14F x 20cm Curved Extensions Duo-Flow 400XL
|
1505-C |
|
| 14F x 20cm Pre-Curved Duo-Flow 400XL |
1585G |
|
| 14F x 20cm Straight Duo-Flow 400XL |
1505G |
|
| 14F x 24cm Pre-Curved Duo-Flow 400XL |
1586G |
|
| 14F x 24cm Straight Duo-Flow 400XL |
1540G |
|
Variant Devices:
| Variant Description |
Part Number(s) |
Explanation of Multiple Part Numbers |
| 14F x 12cm Pre-Curved Duo-Flow 400XL |
1583G |
|
| 14F x 12cm Straight Duo-Flow 400XL |
1539G |
|
| 14F x 15cm Pre-Curved Duo-Flow 400XL |
1584G |
|
| 14F x 15cm Straight Duo-Flow 400XL |
1504G |
|
|
14F x 20cm Curved Extensions Duo-Flow 400XL
|
1505-C |
|
| 14F x 20cm Pre-Curved Duo-Flow 400XL |
1585G |
|
| 14F x 20cm Straight Duo-Flow 400XL |
1505G |
|
| 14F x 24cm Pre-Curved Duo-Flow 400XL |
1586G |
|
| 14F x 24cm Straight Duo-Flow 400XL |
1540G |
|
Procedure Trays:
Procedure Trays:
| Catalog Code |
Part Number |
Description |
| DFXL144IJSE |
1583G |
14F x 12cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL144MT |
1539G |
14F x 12cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL146IJSE |
1584G |
14F x 15cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL146MTB |
1504G |
14F x 15cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL146MTE |
1504G |
14F x 15cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL148CES |
1505-C |
14F x 20cm Duo-Flow® 400XL® Double Lumen Curved Extension
Hemodialysis Catheter Basic Set
|
| DFXL148IJSE |
1585G |
14F x 20cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL148MTB |
1505G |
14F x 20cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL148MTE |
1505G |
14F x 20cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL149IJSE |
1586G |
14F x 24cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL149MTB |
1540G |
14F x 24cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL149MTE |
1540G |
14F x 24cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
Procedure Trays:
| Catalog Code |
Part Number |
Description |
| DFXL144IJSE |
1583G |
14F x 12cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL144MT |
1539G |
14F x 12cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL146IJSE |
1584G |
14F x 15cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL146MTB |
1504G |
14F x 15cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL146MTE |
1504G |
14F x 15cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL148CES |
1505-C |
14F x 20cm Duo-Flow® 400XL® Double Lumen Curved Extension
Hemodialysis Catheter Basic Set
|
| DFXL148IJSE |
1585G |
14F x 20cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL148MTB |
1505G |
14F x 20cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL148MTE |
1505G |
14F x 20cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
| DFXL149IJSE |
1586G |
14F x 24cm Duo-Flow® 400XL® Double Lumen Pre-Curved
Hemodialysis Catheter Basic Set
|
| DFXL149MTB |
1540G |
14F x 24cm Nikkiso Duo-Flow® 400XL® Double Lumen
Hemodialysis Catheter Basic Set
|
| DFXL149MTE |
1540G |
14F x 24cm Duo-Flow® 400XL® Double Lumen Hemodialysis
Catheter Basic Set
|
Configurations of Procedure Trays:
| Configuration Type |
Kit Components |
| Duo-Flow® 400XL Basic Set |
(1) Catheter (1) Guidewire (1) Guidewire Advancer (1) Needle
(1) Scalpel (1) Dilator (2) End Cap
|
2. Intended Use of the Device
Intended Purpose: Duo-Flow® 400XL® Catheters are
intended for use in adult patients with Acute Kidney Injury (AKI)
or Chronic Kidney Disease (CKD) for whom immediate central venous
vascular access for short-term 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): The Duo-Flow® 400XL® Catheter is
indicated for short-term use where vascular access is required for
less than 14 days for the purpose of hemodialysis.
Target Population(s): Duo-Flow® 400XL® Catheters
are intended for use in adult patients with Acute Kidney Injury
(AKI) or Chronic Kidney Disease (CKD) for whom immediate central
venous vascular access for short-term 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: Duo-Flow® 400XL® Catheter
Description of Device: Duo-Flow® 400XL®
Catheter:The Duo-Flow® 400XL® Catheter removes and returns blood
through two segregated lumen passages. Each lumen is connected to
an extension line with color-coded female luer connectors. The
transition between lumen and extension is housed within a molded
hub. Both arterial and venous lumens contain side holes. The
catheter incorporates Barium Sulphate to facilitate visualization
under fluoroscopy or Xray. The catheter is available in straight
or pre-curved configurations with straight or curved extensions in
a variety of lengths to accommodate physician preference and
clinical needs.
Device Name: Nikkiso Duo-Flow® 400XL Catheter
Description of Device: Nikkiso Duo-Flow® 400XL
Catheter:The Nikkiso Duo-Flow® 400XL® Catheter removes and returns
blood through two segregated lumen passages. Each lumen is
connected to an extension line with color-coded female luer
connectors. The transition between lumen and extension is housed
within a molded hub. Both arterial and venous lumens contain side
holes. The catheter incorporates Barium Sulphate to facilitate
visualization under fluoroscopy or Xray. The catheter is available
in a variety of lengths to accommodate physician preference and
clinical needs.
Materials / Substances in Contact with Patient Tissue:
The percentage ranges in the table below are based on the weights
of the 12cm catheter (10.35g) and the 24cm catheter (12.97g).
Duo-Flow® 400XL® Catheter
| Material |
% Weight (w/w) |
| Polyurethane |
49.10 - 53.93 |
| Acetal co-polymer |
18.05 - 22.60 |
| Polyvinyl chloride |
14.55 - 18.22 |
| Acrylonitrile Butadiene Styrene |
5.67 - 7.10 |
| Barium sulfate |
2.97 - 6.06 |
| Vythene |
0 - 1.97 |
The percentage ranges in the table below are based on the weights
of the 12cm catheter (10.35g) and the 24cm catheter (12.97g).
Nikkiso Duo-Flow® 400XL Catheter
| Material |
% Weight (w/w) |
| Polyurethane |
49.10 - 53.93 |
| Acetal co-polymer |
18.05 - 22.60 |
| Polyvinyl chloride |
14.55 - 18.22 |
| Acrylonitrile Butadiene Styrene |
5.67 - 7.10 |
| Barium sulfate |
2.97 - 6.06 |
| Vythene |
0 - 1.97 |
Note:Per the instructions for use, the device is contraindicated
for patients with known or suspected allergies to the above
materials.
Information on Medicinal Substances in the Device:
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.
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.
|
| Scalpel |
A cutting device during surgical, pathology and minor
medical procedures
|
| 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
|
4. Risks and Warnings
Residual Risks and Undesirable Effects: 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
when considered with respect to the expected clinical benefits of
the Duo-Flow® 400XL® Catheter and the benefits of other similar
hemodialysis devices.
| Residual Harm Type |
Possible Adverse Events Associated with Harm
|
| Allergic Reaction |
Allergic Reaction Intolerance Reaction to Implanted
Device
|
| Bleeding |
Bleeding (May be severe) Exsanguination Femoral Artery Bleed
Hematoma Hemorrhage Retroperitoneal Bleed
|
| Cardiac Event |
Cardiac Arrhythmia Cardiac Tamponade
|
| Embolism |
Air Embolus
|
| Infection |
Bacteremia Endocarditis Exit Site Infection Septicemia
|
| Perforation |
Inferior Vena Cava Puncture Laceration of the Vessel
Perforation of the Vessel Pneumothorax Right Atrial Puncture
Subclavian Artery Puncture Superior Vena Cava Puncture
|
| Stenosis |
Venous Stenosis
|
| Tissue Injury |
Brachial Plexus Injury Exit Site Necrosis Mediastinal Injury
Pleural Injury
|
| Thrombosis |
Central Venous Thrombosis Lumen Thrombosis Subclavian Vein
Thrombosis Vascular Thrombosis
|
| Miscellaneous Complications |
Catheter Dysfunction Femoral Nerve Damage Hemothorax
Malposition Thoracic Duct Laceration
|
|
Quantification of Residual Risks
|
|
PMS Complaints 01 January 2017 – 31 December 2023
|
PMCF Events |
|
Units Sold: 68,603 |
Units Studied: 9 |
|
Patient Residual Harm Category
|
% of Devices |
% of Devices |
| Allergic Reaction |
Not Reported |
Not Reported |
| Bleeding |
Not Reported |
Not Reported |
| Cardiac Event |
Not Reported |
Not Reported |
| Embolism |
Not Reported |
11.11% |
| Infection |
Not Reported |
22.22% |
| Perforation |
Not Reported |
Not Reported |
| Stenosis |
Not Reported |
Not Reported |
| Tissue Injury |
Not Reported |
Not Reported |
| Thrombosis |
Not Reported |
11.11% |
Warnings and Precautions:
Warnings listed for the Duo-Flow® 400XL® Catheter are as follows:
-
Warnings listed for the Duo-Flow® 400XL® Catheter are as
follows:
-
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. Precautions listed for
Duo-Flow® 400XL® Catheter 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.
Other Relevant Aspects of Safety: For a period of
01 January 2019 to 31 December 2023 there were 7 complaints for
68,603 units sold, giving an overall complaint rate of 0.010%.
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 |
| Clinical Literature |
120 (& 10 Mixed Cohort Cases) |
|
|
|
| PMCF Data |
9 |
|
|
|
| Total Cases |
129 (& 10 Mixed Cohort Cases) |
|
|
|
| User Survey Responses |
4 |
|
|
|
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® STHD catheters are subjected to, and must
pass, simulated use testing intended to replicate 30 days use as
part of device development. The Duo-Flow® 400XL Catheter passed
this testing. Clinical guidelines recommend to limit the use of
temporary, noncuffed, nontunneled dialysis catheters to a maximum
of 2 weeks (KDOQI 2019), however, duration of use of these
catheters has varied in available clinical evidence identified by
the manufacturer to date. 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 Duo-Flow® 400XL Catheter, 19 catheters had a mean 5.6 day
[Range: 2 – 10 days] duration of use (Mol et al., 2008) that has
been found in clinical use reported to date. Based on this
information, the Duo-Flow® 400XL catheters have a 30 day 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
Previous clinical evidence literature searches found seven
published literature articles representing 120 Duo-Flow® 400XL®
device family specific cases, and an additional 10 mixed cohort
cases inclusive of Duo-Flow® 400XL devices. The most recent
clinical evidence search found no additional articles relating to
the Duo-Flow® 400XL® device family. The articles included one
non-randomized controlled trial (de Pont et al.), four
uncontrolled studies (Mol et al., Bouman et al., Vidal et al., and
Scherer et al.), one case series (de Pont et al.), and one
abstract (Lopez et al.). Bibliography: de Pont A-CJM, Hofstra
J-JH, Pik DR, Meijers JCM, Schultz MJ. Pharmacokinetics and
pharmacodynamics of danaparoid during continuous venovenous
hemofiltration: a pilot study. Critical Care. 2007;11(5):R102.
López R, Pérez-Araos R, Salazar Á, et al. Targeted high volume
hemofiltration could avoid extracorporeal membrane oxygenation in
some patients with severe Hantavirus cardiopulmonary syndrome.
Journal of medical virology. 2021;93(8):4738-4747. Mol M, van Kan
HJM, Schultz MJ, de Jonge E. Systemic tobramycin concentrations
during selective decontamination of the digestive tract in
intensive care unit patients on continuous venovenous
hemofiltration. Intensive Care Medicine. 2008;34(5):903-906.
Scherer PF, Iizuka IJ, Ammirati AL, et al. Intermittent
hemodiafiltration as a down-step transition therapy in patients
with acute kidney injury admitted to intensive care unit who
initially underwent continuous venovenous hemodiafiltration. The
International journal of artificial organs. 2021;44(4):223-228. de
Pont AC, Bouman CS, Bakhtiari K, et al. Predilution versus
postdilution during continuous venovenous hemofiltration: a
comparison of circuit thrombogenesis. ASAIO journal (American
Society for Artificial Internal Organs : 1992).
2006;52(4):416-422. Bouman CSC, de Pont ACJM, Meijers JCM, et al.
The effects of continuous venovenous hemofiltration on coagulation
activation. Critical Care. 2006;10(5). Vidal S, Richebé P,
Barandon L, et al. Evaluation of continuous veno-venous
hemofiltration for the treatment of cardiogenic shock in
conjunction with acute renal failure after cardiac surgery.
European Journal of Cardio-thoracic Surgery. 2009;36(3):572-579.
• Source:PMCF_Medcomp_211
The Medcomp User Survey acquired responses from healthcare
personnel familiar with any number of Medcomp’s product offerings.
20 respondents responded that they or their facility have used
Medcomp short-term hemodialysis catheters, with 4 of those
respondents using the Duo-Flow® 400XL® device. There were no
differences in mean user sentiments within short-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 short-term hemodialysis catheters (n=20):
(Mean Likert Scale Response) Catheters function as intended – 4.8
/ 5
(Mean Likert Scale Response) Packaging allows for aseptic
presentation – 4.9 / 5
(Mean Likert Scale Response) Benefit outweighs the risk – 4.7 / 5
Dwell Time (n=19) – 15.74 days (95%CI: 6.3 – 25.1) The following
data points were collected from users of Medcomp Duo-Flow® 400XL®
catheters (n=4):
(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 – 4.7 / 5
Dwell Time (n=3) – 10.3 days (95%CI: 1.61 – 19)
• Source:PMCF_STHD_242
The Short-Term Hemodialysis (STHD) Truveta data analysis aimed to
assess 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. Truveta data encompasses the
complete medical record across all care settings. Comprehensive
agreements with healthcare providers ensure ethical approval and
publication rights, aligning with the highest standards of
clinical research. 9 Duo-Flow® 400XL® cases inclusive of several
variant devices were collected. Cases were described as 14F and
Pre-Curved and Straight Cases, configurations (straight,
pre-curved), and lengths (15cm, 20cm), representation of 15cm and
20cm length catheters. The following State of the Art safety and
performance outcome measures were observed for Medcomp Duo-Flow®
400XL® devices:
Catheter Related Blood Stream Infection – 31.75 per 1,000 catheter
days (95%CI: 8.65 – 81.28)
Catheter Associated Venous Thrombus – 0 per 1,000 catheter days
(95%CI: 0 – 29.28)
Exit Site Infection – 0 per 1,000 catheter days (95%CI: 0 – 29.28)
Overall Summary of Clinical Safety and Performance
Upon review of the Duo-Flow® 400XL® catheter data across all
sources, it is possible to conclude that the benefits of the
subject device outweigh the overall and individual risks when the
device is used as intended by the manufacturer. It is the
manufacturer’s and clinical expert evaluator’s opinion that
activities both complete and ongoing are sufficient to support the
safety, efficacy, and acceptable benefit/risk profile of the
subject devices.
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 8 days |
+
|
5.6 days (Range
|
2 – 10 days) (Summary of Published Literature)
|
| Procedural Outcomes |
Greater than 95% |
+
|
No Complications Reported (Summary of Published
Literature)
|
Likert Scale Response 4.7 / 5 (PMCF_Medcomp_211)**
|
| Safety Outcomes |
|
Catheter Related Blood Stream Infection (CRBSI)
|
Less than 7.8 incidents of CRBSI per 1,000 catheter days
|
-
|
No Events Reported (Summary of Published Literature)
|
Likert Scale Response 4.5 / 5 (PMCF_Medcomp_211)** 4 Events
Reported (PMCF_STHD_242)
|
| Exit Site Infection Rate |
Less than 3.5 incidents of exit site infection per 1,000
catheter days
|
-
|
ND*
|
Likert Scale Response 4.5 / 5 (PMCF_Medcomp_211)** No Events
Reported (PMCF_STHD_242)
|
|
Catheter Associated Venous Thrombus (CAVT)
|
Less than 11.4 incidents of CAVT per 1,000 catheter days
|
-
|
ND*
|
Likert Scale Response 4.5 / 5 (PMCF_Medcomp_211)** No Events
Reported (PMCF_STHD_242)
|
*ND:indicates no data on the clinical data parameter
**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.
On-going or planned Post-Market Clinical Follow-up (PMCF)
| Outcome |
Benefit/Risk Acceptability Criteria |
Desired Trend |
Clinical Literature (Subject Device) |
PMCF Data (Subject Device) |
| Performance Outcomes |
| Multicenter Patient-Level Case Series |
Collect additional clinical data on the device
|
PMCF_STHD_241
|
Q4 2025
|
|
| State of the Art Literature Search |
Identify risks and trends with use of dialysis catheters
|
SAP-HD
|
Q1 2025
|
|
| Clinical Evidence Literature Search |
Identify risks and trends with use of the device
|
LRP-STHD
|
Q3 2025
|
|
| Global Trial Database Search |
Identify ongoing clinical trials involving the devices
|
N/A
|
Q3 2025
|
|
| Safety Outcomes |
| N/A |
N/A |
?
|
|
|
N/A:N/A
On-going or Planned Post-Market Clinical Follow-Up (PMCF)
| Activity |
Description |
Reference |
Timeline |
| Multicenter Patient-Level Case Series |
Collect additional clinical data on the device
|
PMCF_STHD_241 |
Q4 2025 |
| State of the Art Literature Search |
Identify risks and trends with use of dialysis catheters
|
SAP-HD |
Q1 2025 |
| Clinical Evidence Literature Search |
Identify risks and trends with use of the device
|
LRP-STHD |
Q3 2025 |
| Global Trial Database Search |
Identify ongoing clinical trials involving the devices
|
N/A |
Q3 2025 |
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.
8. Reference to Any Harmonized Standards and Common Specifications
(CS) Applied
| Harmonized Standard or CS |
Revision |
Title or Description |
Level of Compliance |
| EN 556-1 |
2001 |
Sterilization of medical devices. Requirements for medical
devices to be designated "STERILE". Requirements for
terminally sterilized medical devices
|
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 10993-7 |
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 10993-18 |
2020 |
Biological evaluation of medical devices — Part 18: Chemical
characterization of medical device materials within a risk
management process
|
Full |
| EN ISO 11070 |
2014+A1:2018 |
Sterile single-use intravascular introducers, dilators and
guidewires
|
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 11138-1 |
2017 |
Sterilization of health care products — Biological
indicators Part 1: General requirements
|
Full |
| EN ISO 11138-2 |
2017 |
Sterilization of health care products—Biological
indicators—Part 2: Biological indicators for ethylene oxide
sterilization processes
|
Full |
| EN ISO 11138-7 |
2019 |
Sterilization of health care products. Biological indicators
- Guidance for the selection, use and interpretation of
results
|
Full |
| EN ISO 11140-1 |
2014 |
Sterilization of health care products — Chemical indicators
Part 1: General requirements
|
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 11737-1 |
2018 + A1: 2021 |
Sterilization of health care products. Microbiological
methods. Determination of a population of microorganisms on
products
|
Full |
| EN ISO 13485 |
2016 + A11: 2021 |
Medical Devices – Quality Management system – Requirements
for Regulatory Purposes
|
Full |
| EN ISO 14155 |
2020 |
Clinical investigation of medical devices for human subjects
— Good clinical practice
|
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 ISO 14971 |
2019+A11:2021 |
Medical devices. Application of risk management to medical
devices
|
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 ISO/IEC 17025 |
2017 |
General requirements for the competence of testing and
calibration laboratories
|
Full |
| PD CEN ISO/TR 20416 |
2020 |
Medical devices — post-market surveillance for manufacturers
|
Full |
| EN ISO 20417 |
2021 |
Medical devices - Information to be supplied by the
manufacturer.
|
Full |
| EN 62366-1 |
2015 + A1: 2020 |
Medical devices — Part 1: Application of usability
engineering to medical devices
|
Full |
| ISO 7000 |
2019 |
Graphical symbols for use on equipment. Registered symbols
|
Partial |
| 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 |
| 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 |
| 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 2018-1 |
Rev. 4 |
Guidance on BASIC UDI-DI and changes to UDI-DI
|
Full |
| MDCG 2019-9 |
2022 |
Summary of safety and clinical performance
|
Full |
| ASTM D 4169-22 |
2022 |
Standard Practices for Performance Testing of Shipping
Containers and Systems.
|
Full |
| ASTM F2096-11 |
2019 |
Standard Test Method for Detecting Gross Leaks in Packaging
by Internal Pressurization (Bubble Test)
|
Full |
| ASTM F2503-20 |
2020 |
Standard Practice for Marking Medical Devices and Other
Items for Safety in the Magnetic Resonance Environment
|
Full |
| ASTM F640-20 |
2020 |
Standard Test Methods for determining Radiopacity for
Medical Use
|
Full |
| ASTM D4332-14 |
2014 |
Standard Practice for Conditioning Containers, Packages, or
Packaging Components for Testing
|
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 |
07NOV2022 |
27445 |
KO |
Initial Implementation of SSCP |
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 2 |
27JUL2023 |
28324 |
GM |
Update in accordance with CER-023 Revision C.2
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|
| 3 |
16SEP2024 |
29353 |
GM |
Update in accordance with CER-023 Revision D
|
No, this version was not validated by the Notified Body as
this is a Class IIa or IIb implantable device
|