Penumbra System 110 Aspiration Tubing (K151623): indications, design and recorded evidence

Computed exact-code research

This decision beside its recorded product-code cohort

The 2021–2025 complete-year cohort contains 43 selected decisions under primary code NRY. 43 have valid reported receipt/decision pairs; 0 pairs are missing or invalid.

Calendar elapsed days: lower quartile 55.5, median 122.0, upper quartile 178.5. These are recorded calendar differences, not active FDA review time.

The table shows the named decision and up to four latest exact-code research records through 2026-09-27. It can include partial-year records outside the complete-year cohort. The quartiles above use the full stated cohort, not this displayed selection.

Use this comparison: select a record to investigate, read its actual indications and design, and document differences. A shared code or elapsed period cannot establish its relevance to your device.

Calendar elapsed days are not active FDA review time, a promised schedule or a success probability. The selection includes only the stated recorded decisions, not all applications. Latest records can postdate the named historical decision and are contextual research, not its predicates. Shared codes, summaries and observed records do not prove equivalence, current market availability, buyer applicability or predicate suitability.

Historical references beside dated FDA recognition metadata

Read each mention in the linked original summary, including statements that testing was not performed. Recognition metadata does not determine your testing needs, chosen edition or transition eligibility.

Prepare for your provider: the proposed protocol/report edition, its justification for your device and the complete current FDA recognition sheet. In particular, inspect exclusions for partial recognition. An edition difference does not automatically make the historical evidence unusable.

Known facts and deciding inputs

Known context: US. Confirm the organisation’s role, relevant activities and markets against the cited criteria.

Prepare a differences and evidence worksheet

Use this checklist to gather your business or product details before speaking with a specialist. The items below explain what to record and suggest useful supporting documents. You can add your own answers in the editable project brief.

1. Indications and users — what differs in our product?

   Compare the recorded indication, population, body site and use environment with your proposed label. Record each change instead of assuming the primary code settles intended use.

   Useful evidence: Our proposed indication, user/population and use environment beside this exact recorded indication.

2. Design and operating principle — what differs in our product?

   Compare physical design, materials, energy, accessories and operating principle with your design. Ask which documented differences change the evidence scope.

   Useful evidence: Design description, materials/components, accessory list and a differences matrix.

3. Performance evidence actually described — what differs in our product?

   The source labels this section as performance data. Determine which described evidence is bench, software, biological or clinical from the actual narrative and original tables; the section label alone does not settle that distinction or prescribe your testing.

   Useful evidence: The cited narrative and full tables, underlying protocols/results and a reviewed comparison with the proposed product.

4. Which edition and recognition limits would our provider rely on?

   Compare each historical reference below with the dated FDA metadata. Ask the specialist to justify the applicable scope and selected edition, read the complete supplementary sheet for partial-recognition exclusions, and investigate any recorded transition conditions. A difference in editions does not automatically make the earlier study unusable.

   Useful evidence: Proposed protocol/report edition, dated FDA recognition sheet with scope/exclusions, and a documented edition/transition rationale for the actual device.

Work packages and dependencies

• Conditional: Indication, design and evidence-gap comparison — Compare the named summary and underlying official records with the proposed product; document the differences, applicable route questions and evidence gaps before agreeing submission or testing deliverables.
• Optional: Biological evaluation and material/contact differences — The recorded source mentions this evidence topic, including possible negative statements. Discuss this package only if the proposed product’s design/use, source differences and current requirements justify it; the recorded case is not a mandatory testing checklist.

What needs to happen first

• FDA 510(k) Submission Services → Biocompatibility Testing (ISO 10993 Program): Define the proposed indication/design and compare the original source context; commission this optional work only after its separate evidence need is justified.

Questions for providers

• Which specific differences from the cited indication, design and operating principle change our proposed evidence work?
• What source limitations or missing protocols/results must be resolved before treating this recorded evidence as comparable?
• Which additional records and current guidance support the proposed route, and how will the comparison avoid assuming predicate suitability?
• Which exact standard edition and FDA recognition scope would your proposed work use, and how would you justify differences from the historical references shown?