Summary of Safety and Clinical Performance

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

1. Device Identification and General Information

Device Trade Name(s): T-3® CT Catheter

Manufacturer Name and Address: Medical Components, Inc. (dba Medcomp®) 1499 Delp Drive Harleysville, PA 19438 USA

Manufacturer Single Registration Number (SRN): US-MF-000008230

Basic UDI-DI: 00884908300MQ

Medical Device Nomenclature: F900201 – Temporary Hemodialysis Catheters and Kits

Class of Device: III

Date First CE Certificate Issued: 11-Aug

Authorized Representative Name and SRN: Gerhard Frömel European Regulatory Expert Medical Product Service GmbH (MPS) Borngasse 20 35619 Braunfels, Germany SRN: US-MF-000008230

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:

Procedure Trays:

Configurations of Procedure Trays:

2. Intended Use of the Device

Intended Purpose: T-3® CT 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, intravenous administration of fluids or medications, and power injection of contrast media 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 T-3® CT Catheter is indicated for short-term use where vascular access is required for less than 14 days for the purpose of hemodialysis. The third internal lumen is indicated for intravenous administration of fluids or medications and power injection of contrast media.

Target Population(s): T-3® CT 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, intravenous administration of fluids or medications, and power injection of contrast media 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: T-3® CT Catheter

Description of Device: T-3® CT Catheter:The T-3® Catheter is a short-term dialysis catheter made of thermosensitive polyurethane. The catheter has three separate lumens allowing continuous blood flow. The venous (blue) and arterial (red) lumens may be used for hemodialysis treatments. The middle (purple) lumen is independent from the two dialysis lumens, and may be used for administration of fluids or medications and power injection of contrast media. The catheter is available in a variety of lengths to accommodate physician preference and clinical needs.

Device Name: T-3® CT Catheter

Description of Device: T-3® CT Catheter:The T-3® Catheter is a short-term dialysis catheter made of thermosensitive polyurethane. The catheter has three separate lumens allowing continuous blood flow. The venous (blue) and arterial (red) lumens may be used for hemodialysis treatments. The middle (purple) lumen is independent from the two dialysis lumens, and may be used for administration of fluids or medications and power injection of contrast media. 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 15cm catheter (15.15g) and the 32cm catheter (17.91g).

The percentage ranges in the table below are based on the weights of the 15cm catheter (15.15g) and the 32cm catheter (17.91g).

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:

Accessories Intended for Use in Combination with the Device:

Other Devices or Products Intended for Use in Combination with the Device:

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 T-3® CT Catheter and the benefits of other similar hemodialysis devices.

Warnings and Precautions:

Warnings listed for the T-3® CT 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 T-3® CT 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.
• The third lumen of the catheter allows for intravenous administration of fluids or medications and power injection of contrast media. Refer to standards of practice and institutional policies for compatible infusion agents for central venous access.
• Follow all contraindications, warnings, precautions, and instructions for all infusates including contrast media as specified by their manufacturer.
• The red arterial and blue venous lumens should not be used for infusion of any infusates or contrast media as patient injury may occur.
• The center (distal) infusion lumen should not be used for hemodialysis as insufficient treatment may occur.

Other Relevant Aspects of Safety: For a period of 01 January 2019 to 31 December 2023 there was 1 complaint for 9,842 units sold, giving an overall complaint rate of 0.01%. 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

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 T-3® CT 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 T-3® Catheter, 77 catheters had a mean dwell time of 11.3 days [95%CI: 9.04 – 13.61 days] duration of use that has been found in clinical use reported to date. Based on this information The T-3® CT Catheter has 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 two published literature articles representing 1 T-3® CT device family specific case, and an additional 10 mixed cohort cases inclusive of the T-3® CT device family. The most recent clinical evidence search found no additional articles relating to the T-3® CT device family. The articles included a case report (Boullata et al.) and a prospective study (Scherer et al.). Bibliography: 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. Boullata JI, Stefankiewicz PM, Gallagher P, Gutsche J. Hemofilter Obstruction with Intravenous Lipid Administration. Journal of Parenteral and Enteral Nutrition. 2020;44(2):370-373.

• Source:PMCF_STHD_221

The dataset was provided by Scott O. Trerotola, MD an Interventional Radiologist at the Hospital of the University of Pennsylvania. Dr. Trerotola is also Stanley Baum Professor of Radiology, Professor of Radiology in Surgery, Vice Chair for Quality, Radiology, Associate Chair and Chief, Interventional Radiology, and Director, Penn HHT Center of Excellence at the Perelman School of Medicine at the University of Pennsylvania. The dataset includes information on 77 T-3® CT Catheter cases with dates of insertion ranging from 01 October 2009 to 14 September 2020 and dates of removal (or last known follow-up) ranging from 13 October 2009 to 23 September 2020. All insertion data is from the Interventional Radiology department at the University of Pennsylvania Hospital. 77 T-3® CT cases inclusive of several variant devices across catheter length (15cm, 20cm, 24cm) were collected. The following outcome measures were confirmed to be within State of the Art safety and performance outcome measures from published literature for Medcomp T-3® CT catheters.

• 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 2 of those respondents using the T-3® CT 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):

• Source:Dr Trerotola Data Report

The dataset was provided by Scott O. Trerotola, MD an Interventional Radiologist at the Hospital of the University of Pennsylvania. Dr. Trerotola is also Stanley Baum Professor of Radiology, Professor of Radiology in Surgery, Vice Chair for Quality, Radiology, Associate Chair and Chief, Interventional Radiology, and Director, Penn HHT Center of Excellence at the Perelman School of Medicine at the University of Pennsylvania. The dataset is consecutive, comprehensive, and includes catheter placements by interventional radiology Attending and Fellowship Physicians, as well as Residents under Attending supervision. This database was updated daily during the data collection period 02Jul2001-01Jul2019. 4 T-3® CT cases, including 24cm and 32cm length variants, were collected. The following outcome measures were collected for Medcomp T-3® CT devices:

Source:T-3® CT Catheter Survey Report

The T-3 Catheter Survey Report was intended to review and tabulate responses to ensure the device remains safe and effective when used as intended. Both survey reports concluded that the Medcomp® T-3® CT catheter is safe and effective when used as directed. One complication was reported in the first iteration of the survey, relating to bleeding. The second iteration of the survey indicated 3 of 4 respondents used the T-3® CT catheter for hemodialysis, 1 of 4 respondents used the T-3® CT catheter for apheresis, 4 of 4 respondents used the third internal lumen of the T-3® CT catheter for infusion therapy, and 3 of 4 respondents used the third internal lumen of the T-3® CT catheter for power injection of contrast media.

Overall Summary of Clinical Safety and Performance

T-3® CT Catheters facilitate hemodialysis, delivery of fluids and medications for treatments, and power injection of contrast media for CT examinations in patients in whom immediate central venous vascular access for short-term hemodialysis is deemed necessary based on the direction of a qualified, licensed physician. Upon review of the T-3® CT 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.

On-going or Planned Post-Market Clinical Follow-Up (PMCF)

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.

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

Revision History