On June 14, 2023, FDA issued a guidance titled Content of Premarket Submissions for Device 
Software Functions.1 This final guidance supersedes the Guidance for the Content of Premarket 
Submissions for Software Contained in Medical Devices, issued on May 11, 2005. The final 
guidance issued on June 14, 2023, provides information regarding the recommended 
documentation sponsors should include in premarket submissions for FDAs evaluation of the 
safety and effectiveness of device software functions. In particular, the final guidance includes 
information to help determine a devices Documentation Level (formerly known as Level of 
Concern). The purpose of the Documentation Level is to help identify the minimum amount of 
information that would support a premarket submission that includes device software functions.
Within the framework of the superseded guidance, peripheral vascular atherectomy devices were 
considered a device with a Moderate Level of Concern. Based on the devices risk in the context 
of the devices intended use, as discussed in the final guidance Content of Premarket 
Submissions for Device Software Functions, peripheral vascular atherectomy devices should 
generally address the recommendations for a Basic Documentation Level. The actual 
Documentation Level for your device may vary based on the specifics of your device. Certain 
novel or unusual indications, applications, or technological characteristics (e.g., atherectomy 
devices with software to control the devices cutting/lasing functions) may warrant a higher 
Documentation Level. If you are uncertain what Documentation Level may be appropriate given 
the devices indications, applications, or technological characteristics, sponsors should discuss 
with the responsible review division as an Enhanced Documentation Level may be more 
appropriate.   For more information about Documentation Level and recommended 
documentation for a premarket submission, sponsors are encouraged to review the guidance 
Content of Premarket Submissions for Device Software Functions. 
 
1 Available at https://www.fda.gov/regulatory-information/search-fda-guidance-documents/content-premarket-
submissions-device-software-functions. Contains Nonbinding Recommendations
Peripheral Vascular Atherectomy 
Devices - Premarket Notification 
[510(k)] Submissions 
Guidance for Industry and
Food and Drug Administration Staff
Document issued on May 20, 2021.
A draft select update to this document was issued on July 13, 2020.
This document supersedes Peripheral Vascular Atherectomy Devices - 
Premarket Notification [510(k)] Submissions: Guidance for Industry and Food 
and Drug Administration Staff issued February 13, 2020
For questions about this document, contact OHT2: Office of Cardiovascular Devices/Division C: 
Division of Coronary and Peripheral Interventional Devices/Plaque Modifications Team at (301) 
796-2520.
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Devices and Radiological Health Contains Nonbinding Recommendations
Preface
Public Comment 
You may submit electronic comments and suggestions at any time for Agency consideration to 
https://www.regulations.gov. Submit written comments to the Dockets Management Staff, Food 
and Drug Administration, 5630 Fishers Lane, Room 1061, (HFA-305), Rockville, MD 20852. 
Identify all comments with the docket number FDA-2018-D-2494. Comments may not be acted 
upon by the Agency until the document is next revised or updated. 
Additional Copies
Additional copies are available from the Internet. You may also send an e-mail request to 
CDRH-Guidance@fda.hhs.gov to receive a copy of the guidance. Please include the document 
number 16013 and complete title of the guidance in the request. Contains Nonbinding Recommendations
Table of Contents
I. Introduction ............................................................................................................................. 1 
II. Background ............................................................................................................................. 2
III. Scope ....................................................................................................................................... 3
IV. Premarket Submission Recommendations .............................................................................. 3
A. Device Description .............................................................................................................. 3
B. Predicate Device Comparison ............................................................................................. 4
C. Software .............................................................................................................................. 5
D. Biocompatibility ................................................................................................................. 6
E. Sterility ................................................................................................................................ 7
F. Pyrogenicity ........................................................................................................................ 8
G. Shelf Life and Packaging .................................................................................................... 8
H. Electrical Safety and Electromagnetic Compatibility (EMC) ............................................ 9
I. Battery Testing .................................................................................................................. 10
(1) Risk Management ....................................................................................................... 10
(2) Qualification Testing .................................................................................................. 10
(3) Performance Testing Considerations .......................................................................... 10
J. Non-Clinical Performance Testing ................................................................................... 11
(1) Risk Management ....................................................................................................... 12
(2) Test Sample Selection ................................................................................................. 12
(3) Test Sample Preparation: Pre-Conditioning ............................................................... 12
(4) Simulated-Use Model ................................................................................................. 12
(5) Engineering Testing .................................................................................................... 13
(6) Additional Engineering Testing for Devices Intended to Treat In-stent Restenosis .. 20
K. Animal Testing.................................................................................................................. 21
(1) Animal Model ............................................................................................................. 22
(2) Study Endpoint Considerations................................................................................... 23
L. Clinical Performance Testing ........................................................................................... 24
(1) Considerations for the Level of Clinical Evidence ..................................................... 25
(2) Study Endpoint Considerations................................................................................... 26
M. Labeling ............................................................................................................................ 26
V. Modifications ......................................................................................................................... 27 Contains Nonbinding Recommendations
Peripheral Vascular Atherectomy 
Devices - Premarket Notification 
[510(k)] Submissions 
Guidance for Industry and
Food and Drug Administration Staff
This guidance represents the current thinking of the Food and Drug Administration (FDA or 
we) on this topic. It does not establish any rights for any person and is not binding on FDA or 
the public. You can use an alternative approach if it satisfies the requirements of the 
applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff 
or Office responsible for this guidance as listed on the title page.
I.  Introduction
This guidance document provides recommendations for 510(k) submissions for peripheral 
vascular atherectomy devices. The recommendations reflect current review practices and are 
intended to promote consistency and facilitate efficient review of peripheral vascular 
atherectomy submissions.
For the current edition of the FDA-recognized consensus standards referenced in this document, 
see the FDA Recognized Consensus Standards Database Web site at 
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/search.cfm. For more 
information regarding use of consensus standards in regulatory submissions, please refer to FDA 
guidance, Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for 
Medical Devices - Guidance for Industry and Food and Drug Administration Staff.1
The contents of this document do not have the force and effect of law and are not meant to bind 
the public in any way, unless specifically incorporated into a contract. This document is intended 
only to provide clarity to the public regarding existing requirements under the law. FDA 
guidance documents, including this guidance, should be viewed only as recommendations, unless 
specific regulatory or statutory requirements are cited. The use of the word should in FDA 
guidances means that something is suggested or recommended, but not required.
1 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/appropriate-use-voluntary-consensus-
standards-premarket-submissions-medical-devices. 
1 Contains Nonbinding Recommendations
II.  Background
Atherectomy is an interventional procedure performed to remove atherosclerotic plaque from 
diseased arteries. The mechanism of plaque removal ranges from cutting, shaving, sanding, or 
vaporizing.2,3Atherectomy devices vary in design and complexity and there are currently four 
main categories of atherectomy devices:4,5
1.  Directional: Directional atherectomy involves the resection of atherosclerotic plaque with 
a cutting device in the longitudinal plane. Directional atherectomy typically removes 
plaque in a single plane with multiple passes.
2.  Rotational: Rotational atherectomy devices typically employ a high-speed concentrically 
rotating cutting blade or burr coated with abrasive material. These devices use differential 
and circumferential cutting blades to debulk plaque.
3.  Orbital: Although similar to rotational atherectomy devices, orbital atherectomy devices 
employ a 360 rotational coil with a rough burr that sands off plaque. The orbital 
motion allows the burr to remove plaque as it moves through the lesion. Unlike rotational 
atherectomy, the orbit of this type of atherectomy device changes with rotational speed.
4.  Laser: Laser atherectomy systems use a high-energy light beam to vaporize plaque. The 
device typically consists of a fiber-optic catheter that attaches to a laser generator. 
The choice of atherectomy device depends on plaque location, vessel characteristics, length of 
disease segment, plaque quantity, plaque texture, and physician experience. 
We encourage members of industry to engage the Office of Product Evaluation and Quality 
(OPEQ) via the Q-Submission Program to obtain feedback on specific device indications and 
operation characteristics. For more information on Q-Submissions, please see the FDA guidance, 
Requests for Feedback and Meetings for Medical Device Submissions: The Q-Submission 
Program;6 here in after, Q-Submission Guidance).
Atherectomy devices used in the peripheral vasculature require a premarket notification [510(k)] 
submission before marketing (see 21 CFR part 807). This document supplements other FDA 
documents regarding the specific content requirements and recommendations of a premarket 
2 Mustapha, Jihad A. Atherectomy Today: Go Slow to Finish Fast. Endovascular Today, October 2011, pp. 56- 
66.
3 Akkus, Nuri I., Abdulrahman Abdulbaki, Enrique Jimenez, and Neeraj Tandon. Atherectomy Devices: 
Technology Update. Medical Devices: Evidence and Research, vol. 8, 2015, pp. 1-10.
4 Akkus, Nuri I., Abdulrahman Abdulbaki, Enrique Jimenez, and Neeraj Tandon. Atherectomy Devices: 
Technology Update. Medical Devices: Evidence and Research, vol. 8, 2015, pp. 1-10.
5 Quevedo, Henry C., Salman A. Arain, Gholam Ali, and Nidal Abi Rafeh. A Critical View of the Peripheral 
Atherectomy Data in the Treatment of Infrainguinal Arterial Disease. Journal of Invasive Cardiology, vol. 26, no. 
1, 2014, pp. 22-29.
6 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/requests-feedback-and-meetings-
medical-device-submissions-q-submission-program. 
2 Contains Nonbinding Recommendations
notification (510(k)) submission. You should also refer to 21 CFR 807.87 and FDAs guidance, 
Format for Traditional and Abbreviated 510(k)s.7
III.  Scope
The scope of this document is limited to atherectomy devices used in the peripheral vasculature, 
regulated under 21 CFR 870.4875 and with the product code listed in the table below: 
Product Code Regulation Number Name
MCW 870.4875 Intraluminal Artery Stripper
Because of the higher-risk anatomical location, atherectomy devices used in the coronary 
vasculature are class III devices, which require a premarket approval (PMA) application before 
marketing. (see sections 513(a)(1)(C) and 515 of the Federal Food, Drug, and Cosmetic Act (the 
FD&C Act) (21 U.S.C. 360c(a)(1)(C) and 360e) and 21 CFR part 814). Atherectomy devices 
indicated for use in the coronary vasculature are outside the scope of this guidance document; 
however, some of the information provided in this guidance document may be applicable to 
atherectomy devices with coronary indications. For more information on FDAs 
recommendations for review of coronary atherectomy devices, please contact the Plaque 
Modification Devices Team, Division of Health Technology 2C, within the Office of Health 
Technology 2.
Peripheral atherectomy devices are used to establish significant luminal gain in stenotic 
peripheral plaque by removing plaque as the devices primary function. A new peripheral 
atherectomy device might not strictly fall into one of the four categories listed in the Background 
Section above; however, the information provided in this guidance may still be helpful in 
developing a risk analysis and performance testing strategy. 
Medical devices used to facilitate passage of a guidewire through or around chronic total 
occlusions or devices used for plaque modification via reshaping, compression, and cracking of 
the plaque to change the plaque volume, but do not intentionally remove plaque (such as devices 
that primarily achieve luminal gain through balloon angioplasty or cutting/scoring), are not 
considered atherectomy devices and are outside the scope of this guidance document. 
IV.  Premarket Submission Recommendations
A.  Device Description
We recommend that you identify your device by regulation and product code as described in 
Section III above, and include the information described below. As part of the device 
description, we also recommend that you identify all accessories and describe their function(s). 
7 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/format-traditional-and-abbreviated-
510ks.
3 Contains Nonbinding Recommendations
In addition, we recommend that you provide the following information, if applicable to your 
device:
 description of the mechanism of operation;
 description of technological characteristics;
 identification of configurations and models;
 listing of materials;
 identification of coatings; and images or engineering drawings.
We recommend that you describe the technical and performance specifications of the device and 
include a brief description of the device design in this section. This should include, as applicable, 
details about how your atherectomy device achieves its desired rotational speed. We recommend 
the specifications identify applicable dimensional characteristics, operating limitations (e.g., 
rotational speed, energy output, wavelength, orbital lumen diameter) and any other functional, 
physical, and environmental considerations of the device. If your submission includes multiple 
device models, we recommend that you identify all device models and configurations. You 
should also provide images or engineering drawings of the device and accessories that include 
dimensions and tolerances to fully describe and characterize the device and describe any unique 
device features. Please also identify if your device uses software and if so, the extent of software 
control on your device. 
As part of your device description, we recommend that you provide a list of all device 
components, their respective materials, and their contact duration. We recommend identifying 
both the generic material(s) of construction and the unique material identifier(s). You should also 
provide the level of blood contact (i.e., direct, indirect, or no contact) for each component.
B.  Predicate Device Comparison
For devices reviewed under the 510(k) process, manufacturers must compare their new device to 
a similar legally marketed predicate device to support its substantial equivalence (21 U.S.C. 
360c(i); and 21 CFR 807.87(f)). This comparison should provide information to show how your 
device is similar to and different from the predicate. Side by side comparisons, whenever 
possible, are desirable. See Table 1 below for an example of how this information may be 
organized. This table is not intended to represent an exhaustive list of comparative parameters; 
you should provide all relevant device descriptive characteristics as outlined in the Device 
Description section, above. 
Table 1: Predicate Device Comparison.
Description Subject Device Predicate Device (Kxxxxxx)
Indications for Use 
Mechanism of Operation
Materials
Dimensional Characteristics
Rotational Speed
Energy Wavelength
Other Relevant Characteristics
4 Contains Nonbinding Recommendations
As part of your comparison, we recommend that you clearly explain the intended clinical 
environment and intended use of the device, including target vasculature.
C.  Software
Significance: Software in atherectomy devices may include a variety of functions ranging from 
ensuring that malfunctions that could be hazardous do not occur (e.g., cause injury, erroneous 
diagnosis, or delay in delivery) to directly controlling device cutting/lasing output. Adequate 
software performance testing provides assurance that the device is safe for the user, operator, and 
the patient.
Recommendation: Refer to the FDA software guidance, Guidance for the Content of Premarket 
Submissions for Software Contained in Medical Devices8 for a discussion of the software 
documentation that you should provide in your submission. The software guidance outlines the 
type of documentation to be provided based on the level of concern (LOC) associated with the 
device. We generally consider the software of atherectomy devices to present a moderate LOC. 
However, new or unusual indications, applications, or technological characteristics (e.g., 
atherectomy devices with software to control the devices cutting/lasing functions) may result in 
a higher level of concern. If you believe that the software in your device presents either a 
minor or a moderate LOC as defined in the software guidance, you should provide a 
scientific justification that supports your rationale of the LOC based on the possible 
consequences of software failure. 
We recommend that you provide a full description of the software/firmware supporting the 
operation of the subject device in accordance with the Software Guidance, commensurate with 
the appropriate level of concern. This recommendation applies to original device/systems as well 
as to any software/firmware changes made to already-marketed devices. Changes to software 
must be revalidated and reverified in accordance with Design Controls (21 CFR 820.30(g)(i)) 
and documented in the Design History File (21 CFR 820.30(j)). Some software changes may 
warrant the submission of a new 510(k). For further information on this topic, please refer to 
Deciding When to Submit a 510(k) for a Software Change to an Existing Device.9
As appropriate, you should also provide information on the Cybersecurity aspects of your device. 
For more information on this topic, please see the FDA guidance, Content of Premarket 
Submissions for Management of Cybersecurity in Medical Devices.10
If the device includes off-the-shelf software, you should provide the additional information as 
recommended in the FDA documents titled, Off-the-Shelf Software Use in Medical Devices11
8 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-content-premarket-
submissions-software-contained-medical-devices 
9 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/deciding-when-submit-510k-
software-change-existing-device 
10 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/content-premarket-submissions-
management-cybersecurity-medical-devices-0 
11 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/shelf-software-use-medical-devices 
5 Contains Nonbinding Recommendations
and Cybersecurity for Networked Medical Devices Containing Off-The-Shelf (OTS) 
Software,12 which provide additional information regarding medical devices using off-the-shelf 
software. 
FDA has recognized various voluntary consensus standards that support medical device 
interoperability which is one way to ensure appropriate functional, performance, and interface 
requirements of these devices. If your device has the ability to exchange and use information 
through an electronic interface with another medical/nonmedical product, system, or device, you 
should provide the additional information as recommended in the FDA guidance, Design 
Considerations and Pre-market Submission Recommendations for Interoperable Medical 
Devices.13
Overall, the documentation related to the software contained in the medical device should 
provide sufficient evidence to describe the role of the software included in the device and 
performance testing to demonstrate that the software functions as designed.
D.  Biocompatibility
Significance: Peripheral vascular atherectomy devices contain patient-contacting materials, 
which, when used for their intended purpose, may induce a harmful biological response.
Recommendation: You should determine the biocompatibility of all patient-contacting materials 
present in your device. If your device is identical in composition and processing methods to 
atherectomy devices with a history of successful use, you may reference previous testing 
experience or the literature, if appropriate. For some device materials, it may be appropriate to 
reference a recognized consensus standard or provide a Letter of Authorization (LOA) for a 
device Master File (MAF).
If you are unable to identify a legally marketed predicate device with similar location/duration of 
contact and intended use that uses the same materials and manufacturing (including sterilization 
and packaging) as used in your device, we recommend you conduct and provide a 
biocompatibility risk assessment. The assessment should explain the relationship between the 
identified biocompatibility risks, discuss the information available to mitigate the identified 
risks, and identify any knowledge gaps that remain. You should then identify any 
biocompatibility testing or other evaluations that were conducted to mitigate any remaining risks.
We recommend that you follow the FDA guidance, Use of International Standard ISO 10993-1, 
Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk 
management process,14 which identifies the types of biocompatibility assessments that should 
be considered and recommendations regarding how to conduct related tests.
12 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/cybersecurity-networked-medical-
devices-containing-shelf-ots-software 
13 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/design-considerations-and-pre-
market-submission-recommendations-interoperable-medical-devices 
14 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/use-international-standard-iso-
10993-1-biological-evaluation-medical-devices-part-1-evaluation-and.
6 Contains Nonbinding Recommendations
Per ISO 10993-1: Biological evaluation of medical devices  Part 1: Evaluation and testing 
within a risk management process and Attachment A of FDAs guidance on ISO-10993-1, 
atherectomy devices are external-communicating devices in contact with circulating blood for a 
limited contact duration. Therefore, the following endpoints should be addressed in your 
biocompatibility evaluation:
 Cytotoxicity.
 Sensitization.
 Irritation or intracutaneous reactivity.
 Acute systemic toxicity.
 Material mediated pyrogenicity.
 Hemocompatibility (i.e., hemolysis, complement activation, and thrombogenicity).
Please note that genotoxicity assessment may be requested if the atherectomy device contains 
novel patient-contacting materials that have not been previously evaluated for use in contact with 
circulating blood in legally marketed medical devices.
The following additional considerations are recommended regarding sample preparation for 
atherectomy devices. For biocompatibility testing conducted using extraction samples, we 
recommend the following:
 Determine the appropriate amount of test material, as outlined in ISO-10993-12: 
Biological evaluation of medical devices  Part 12: Sample preparation and 
reference materials or an equivalent method, using surface area to extractant volume 
ratios (mass to extractant volume ratios should only be used if use of mass may result 
in a test article with a larger surface area to extract volume ratio than what is 
recommended by ISO 10993-12.
 Use both polar and nonpolar extractants, where applicable.
 Explain any changes in the post-extraction vehicle (compared to pre-extraction), 
including color, presence of any particulates, etc.
 Describe the details of storage conditions (e.g., storage time, temperature), if 
applicable.
E.  Sterility
Significance: Peripheral vascular atherectomy devices come in contact with blood and should be 
adequately sterilized to minimize infections and related complications.
Recommendation: For atherectomy devices labeled as sterile, we recommend that you provide 
information for the final, sterilized device in accordance with the FDA guidance, Submission 
and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices 
Labeled as Sterile15 (subsequently referred to as Sterility Guidance). 
15 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/submission-and-review-sterility-
information-premarket-notification-510k-submissions-devices-labeled.
7 Contains Nonbinding Recommendations
F.  Pyrogenicity
Significance: Pyrogenicity testing is used to help protect patients from the risk of febrile reaction 
caused by gram-negative bacterial endotoxins and chemicals that can leach from a medical 
device (e.g., material-mediated pyrogens).
Recommendation: To address the risks associated with the presence of bacterial endotoxins, 
atherectomy devices should meet pyrogen limit specifications by following the recommendations 
outlined in the FDA Guidance, Submission and Review of Sterility Information in Premarket 
Notification (510(k)) Submissions for Devices Labeled as Sterile. You should also follow the 
recommendations in Guidance for Industry Pyrogen and Endotoxins Testing: Questions and 
Answers.16 To address the risks associated with material-mediated endotoxins, follow the 
recommendations in FDAs guidance Use of International Standard ISO-10993-1, 'Biological 
Evaluation of Medical Devices Part 1: Evaluation and Testing.17
Peripheral vascular atherectomy devices should be labeled as non-pyrogenic as they come into 
contact with circulating blood. We recommend that both bacterial endotoxins and material-
mediated pyrogenicity be addressed. Devices in contact with the cardiovascular system should 
meet pyrogen limit specifications discussed in the FDA guidance, Submission and Review of 
Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as 
Sterile.18
G.  Shelf Life and Packaging
Significance: Shelf life testing is conducted to support the proposed expiration date through 
evaluation of the package integrity for maintaining device sterility and/or evaluation of any 
changes to device performance or functionality.
Recommendation: With respect to package integrity for maintaining device sterility, you should 
provide a description of the packaging, including how it will maintain the devices sterility, and a 
description of the package integrity test methods and a summary of the results, but not the 
package test data. We recommend that package integrity test methods include simulated 
distribution and associated package integrity testing, as well as simulated (and/or real-time) 
aging and associated seal strength testing to validate package integrity and shelf-life claims. We 
recommend you follow the methods described in the FDA-recognized series of consensus 
standards, AAMI/ANSI/ISO 11607-1: Packaging for terminally sterilized medical devices  Part 
1: Requirements for materials, sterile barrier systems and packaging and AAMI/ANSI/ISO 
11607-2: Packaging for terminally sterilized medical devices  Part 2: Validation requirements 
for forming, sealing and assembly processes.
16 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-pyrogen-and-
endotoxins-testing-questions-and-answers
17 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/use-international-standard-iso-
10993-1-biological-evaluation-medical-devices-part-1-evaluation-and 
18 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/submission-and-review-sterility-
information-premarket-notification-510k-submissions-devices-labeled 
8 Contains Nonbinding Recommendations
With respect to evaluating the effects of aging on device performance or functionality, shelf-life 
studies should evaluate critical device properties to ensure that it continues to perform 
adequately and consistently during the entire proposed shelf life. To evaluate device 
functionality, we recommend you assess each of the bench tests described in Section IV.I and 
IV.J and repeat all tests that evaluate design characteristics that are potentially affected by aging.
We recommend that you provide a summary of the test methods used for your shelf life testing, 
results and the conclusions drawn from your results. If you use devices subjected to accelerated 
aging for shelf life testing, we recommend that you specify the way in which the devices were 
aged and provide a rationale to explain how the results of shelf life testing based on accelerated 
aging are representative of the results if the device were aged in real time. We recommend that 
you age your devices per ASTM F1980: Standard guide for accelerated aging of sterile barrier 
systems for medical devices and specify the environmental parameters established to attain the 
expiration age. For devices or accessories containing polymeric materials, you should plan to 
conduct testing on real-time aged samples to confirm that the accelerated aging is reflective of 
real-time aging. This testing should be conducted in parallel with 510(k) review and clearance 
with results documented to file in the design history file (i.e., complete test reports do not need to 
be submitted to FDA).
H.  Electrical Safety and Electromagnetic Compatibility 
(EMC)
Significance: Most atherectomy devices are medical electrical equipment and therefore may 
expose the operator and patient to hazards associated with the use of electrical energy or may fail 
to operate properly in the presence of electromagnetic disturbance. If your atherectomy device 
includes a laser radiation source, laser safety conditions and standard safety considerations apply 
as there is a risk for ocular and skin tissue damage.
Recommendation: Peripheral vascular atherectomy devices should be tested to demonstrate that 
they perform as anticipated in their intended use environment. We recommend that this testing 
be performed as described in the currently FDA-recognized versions of the following standards 
for medical electrical equipment safety and electromagnetic compatibility:
 ANSI/AAMI/ES 60601-1: Medical electrical equipment  Part 1: General 
requirements for basic safety and essential performance.
 ANSI/AAMI/IEC 60601-1-2: Medical electrical equipment  Part 1-2: General 
requirements for basic safety and essential performance  Collateral standard: 
Electromagnetic disturbances  Requirements and tests.
If submitting a declaration of conformity to the above standards, we recommend that appropriate 
supporting test data and analysis be provided because this series of standards includes general 
methods with multiple options and, in some cases, does not include specific acceptance criteria 
or address assessment of results. For additional information on providing EMC information in a 
9 Contains Nonbinding Recommendations
premarket submission, please see the FDA guidance, Information to Support a Claim of 
Electromagnetic Compatibility (EMC) of Electrically-Powered Medical Devices.19
When a laser atherectomy device has the potential laser radiation hazards to the eyes and skin of 
the patient and operator, safety measures such as the use of personal protective equipment (laser 
protective eyewear) and/or skin contact sensors should be included to mitigate the risk.
I.  Battery Testing
Significance: If your device is battery-operated, it is important to confirm that the battery is 
capable of performing effectively in a clinical setting. Inadequate battery operation could 
lengthen the time of procedure, which could impact patient safety and treatment effectiveness.
Recommendation: We recommend that you describe all batteries used in the system. Your 
description should include performance characteristics (e.g., usable battery amp-hour capacity, 
shelf-life, and life testing under worst-case usage). For evaluation of battery safety and 
performance, we recommend providing the following:
(1)  Risk Management
We recommend you include in your risk analysis any risks related to the battery and its function 
in the system and the systems associated risks (e.g., premature battery depletion leading to 
excessive battery replacement or even replacement of the atherectomy catheter, itself, to 
complete a procedure). 
(2)  Qualification Testing
We recommend evaluating the suitability and performance of the battery for the intended use. 
The tests should reflect the risks identified in the risk analysis and should also assess the 
characteristics and general reliability of the battery when subjected to stresses anticipated under 
normal usage and worst-case condition. For qualification testing, we recommend referencing the 
standards listed below:
 IEC 62133: Secondary cells and batteries containing alkaline or other non-acid 
electrolytes  Safety requirements for pore sealed secondary cells, and for batteries 
made from them, for use in portable applications;
 IEC 60086-4: Primary batteries  Part 4: Safety of lithium batteries;
 UL 2054: Standard for household and commercial batteries; and
 UL 1642: Standard for lithium batteries.
(3)  Performance Testing Considerations
When conducting the qualification testing, we recommend taking the following into 
consideration if your device is battery-powered:
19 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/information-support-claim-
electromagnetic-compatibility-emc-electrically-powered-medical-devices.
10 Contains Nonbinding Recommendations
 If a battery is pre-installed in the device (e.g., in the atherectomy catheter handle), it 
is important to note that a battery may self-discharge, even if the device is not turned 
on; this could limit the shelf-life of the device. We recommend that you evaluate the 
device at the proposed shelf-life. Specifically, the atherectomy catheter should have 
an expiration date consistent with the shelf-life of the battery and the catheters 
sterility.
 If a battery is part of the sterile device system, sterilization of the battery at extreme 
conditions (e.g., high temperatures) could affect the batterys properties and limit 
performance. We recommend taking the conditions into consideration during your 
qualification testing.
 If a replacement battery is needed to complete a full procedure, we recommend that 
you ensure that replacing a worn-out battery with a new (or fully charged) battery 
does not compromise device sterility.
 If the battery drives a motor connected to a rotating device, we recommend ensuring 
that the battery and/or the motor does not overheat during long operations. We 
recommend that you provide information on how the risk of overheating is mitigated 
(e.g., vent holes in the battery housing). If the battery necessitates venting (e.g., if 
over-discharged)20 and the battery housing includes vent holes to allow the battery to 
safely vent, we recommend that you provide information regarding how the risk of 
water ingress into the battery is mitigated. 
 For testing an atherectomy device for an increase in shelf life, the battery should be 
periodically recharged to keep the battery voltage at an acceptable level for the 
duration of the shelf life test. 
J.  Non-Clinical Performance Testing
The purpose of the non-clinical bench testing is to ensure that the device performs as intended 
under the specified conditions of use at baseline (time zero) and after aging to support the 
proposed shelf life and that the device demonstrates substantial equivalence to the predicate 
device. The non-clinical performance testing recommended may vary based on the respective 
risk profile associated with the intended target vasculature as well as the design characteristics of 
your device. FDA recommends that you provide the information below to evaluate the material 
and performance characteristics of your final, sterilized device. If a test that is applicable to your 
device and listed in Section J.5 is excluded from your submission, we recommend that you 
provide a clinical and risk-based justification for its omission. For information on the 
recommended content and format of test reports for the testing described in this section, refer to 
FDA guidance, Recommended Content and Format of Non-Clinical Bench Performance 
Testing Information in Premarket Submissions.21
20 Venting is defined as the release of excessive internal pressure from a cell/battery in a manner intended by design 
to preclude rupture or explosion per IEC 62133, clause 3.10.
21 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/recommended-content-and-format-
non-clinical-bench-performance-testing-information-premarket.
11 Contains Nonbinding Recommendations
(1)  Risk Management
We recommend that you apply accepted risk management principles, such as those described in 
the currently recognized version of ISO 14971: Medical devices  Application of risk 
management to medical devices, while conducting the risk analysis required in 21 CFR 820 
during the development of your device. We recommend you submit risk management 
information that identifies hazardous situations, estimates the risks (e.g., risks of device 
malfunction, adverse tissue reaction, infection, use error, extravasation), describes risk control 
measures and overall residual risk specific to your device.
The risk profile of your device depends upon its intended use. In your submission, we 
recommend that you provide a summary of your risk analysis. If you decide not to perform a 
particular test for evaluation of your device performance and/or safety profile, you should 
provide a clinical or scientific rationale based on your risk analysis.
(2)  Test Sample Selection
If your device is available in more than one size or model, the device that is deemed the worst-
case should be evaluated for each respective test. In this case, you should identify the worst-case 
size and provide a rationale on how the selected size is representative of your size range and 
models.
(3)  Test Sample Preparation: Pre-Conditioning
As previously mentioned, testing should be conducted on the final sterilized device. Before 
and/or during bench testing, you should apply clinically relevant pre-conditioning to the device 
(e.g., pre-soaking in 37C water bath and tracking through a simulated-use model). Pre-
conditioning of the device should simulate the worst-case clinical and physiological conditions 
that the device is expected to experience.
(4)  Simulated-Use Model 
Significance: The simulated-use model should adequately mimic the anatomy for which the 
device is intended. The use of a valid simulated use model for evaluation of device functionality 
helps to create a better understanding of how a device is expected to perform in vivo in a clinical 
setting.
Recommendation: Functional tests and pre-conditioning should be performed using a simulated-
use model. We recommend providing the following information pertaining to your simulated-use 
model:
 Your simulated-use model should be rigorous enough to represent the majority of the 
patient population intended to be treated. Considering atherectomy devices are 
intended to remove plaque, we recommend incorporating simulated 
atherosclerotic/rigid calcified plaque in your model to represent the worst-case 
clinical scenario and provide a clinical/scientific rationale (i.e., based on literature or 
experience) for your plaque model. If the anatomical model does not contain 
12 Contains Nonbinding Recommendations
simulated plaque, we recommend evaluating the ability to remove plaque in a cadaver 
model.
 We recommend that you use a three-dimensional model to best represent the human 
anatomy. Furthermore, it should appropriately model the various curvatures expected 
to be encountered from all the proposed access sites.
 We recommend that you include detailed engineering drawings and/or photos of your 
anatomical model(s), including measurements for the different lengths, tubing 
diameters, and radii of curvatures (in millimeters) and information about the 
material/rigidity of your simulated use model You should also provide a clinical 
rationale to support the selection of the anatomical model parameters.
(5)  Engineering Testing
The following are recommended engineering tests for evaluating substantial equivalence of 
peripheral vascular atherectomy devices. Note that the tests are not all-inclusive. Thus, it is 
important to ensure that unique attributes specific to your device are adequately evaluated for 
substantial equivalence. For catheter testing, we also recommend referencing FDAs Class II 
Special Controls Guidance Document for Certain Percutaneous Transluminal Coronary 
Angioplasty (PTCA) Catheters22 (hereinafter, PTCA Catheters Guidance).
a.  Dimensional Verification
Significance: Accurate device dimensions are important to aid the physician in selecting the 
appropriate product size. The dimensions should meet the established specification for each 
device size.
Recommendation: We recommend that you provide dimensional specifications and tolerances 
for your device as manufactured. We recommend that the specified tolerances should be based 
on your risk analysis. To provide accurate and consistent measurements, we recommend the use 
of a calibrated tool.
The following should be evaluated for any atherectomy device:
 crossing profile;
 inner diameter;
 working length; and
 effective length;
For directional devices:
 cutter length; and
 cutter diameter;
For rotational and orbital devices:
22 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/class-ii-special-controls-guidance-
document-certain-percutaneous-transluminal-coronary-angioplasty.
13 Contains Nonbinding Recommendations
 rotating component length; and
 rotating component diameter.
b.  Simulated-Use Testing
Significance: Use of the device in a simulated use model, in combination with other 
interventional devices, as appropriate, can provide more clinically relevant information about its 
performance than isolated bench top performance testing. Furthermore, the device should 
perform safely and reliably when used as intended or according to the recommended Instructions 
for Use, including techniques for preparation, delivery, use, retraction, and removal. Failure to 
perform as expected may lead to prolonged procedure times, device damage, or patient injury.
Recommendation: The following attributes should be evaluated during simulated-use testing:
 The device integrity and performance are unaffected when used in combination with 
applicable ancillary devices (e.g., introducer, guiding catheter, embolic protection 
device). 
 The device is deliverable via the intended access point (e.g., femoral access) without 
vascular damage.
 The device is compatible with materials and accessories expected to be used with 
your device (e.g., guidewire, sheath).
 The device can be appropriately prepared before use.
 The device is able to track smoothly through the tortuous path and lesions to verify 
ease of use. The device should be appropriately flexible to traverse the simulated-use 
model (with plaque) without kinking or damage.
 The device (e.g., distal component, catheter shaft, cutting component) is able to 
maintain structural integrity prior to delivery, during use (at all labeled rotational 
speeds by using all mechanisms of achieving the desired rotational speed(s) and 
functional modes), and during retraction.
 The catheter distal component (e.g., catheter tip) can withstand constant impact on 
plaque under the expected number of clinical cycles as evidenced by appropriate 
visual assessment. If your distal component also serves as a flushing tool, the number 
of tissue removal cycles the distal component can withstand should be determined. 
The catheter should also be evaluated for possible distal component detachment. 
 The device should be visualized with appropriate imaging guidance. You should 
address any device changes (e.g., defects, kinks, debris) on your device before and 
after testing. 
 If your device contains a coating, we recommend that you provide images of 
sufficient magnification to fully characterize the coating coverage and potential 
defects. Apart from standard visual inspection (e.g., 2.5X), please also conduct 
coating inspection at higher magnifications (e.g., 40-500X)) to clearly identify and 
characterize any defects in the coating. Any changes in the coating (e.g., decreased 
uniformity, delamination, cracks) should be addressed. Please refer to Section q 
below for further details.
 If your device contains software, we recommend that you validate use of the software 
component during simulated-use testing. Please see Section C above.
14 Contains Nonbinding Recommendations
c.  Kink Resistance
Significance: Inability to withstand bending forces that are typical of clinical use (e.g., when the 
distal tip is not free to rotate, tracking the device through tortuous vascular regions) could lead to 
device failure or vessel damage.
Recommendation: We recommend evaluating kink resistance of the device under the worst-case 
radius of curvature expected during clinical use. For example, we recommend that you consider 
wrapping the catheter around a series of mandrels with successively smaller radii until the 
catheter kinks or the lumen collapses. We also recommend you provide the clinical basis for your 
acceptance criteria. 
d.  Corrosion Resistance
Significance: Corrosion of components fabricated from metal may lead to device failure or 
patient risk (e.g., toxicity, embolization). Visible signs of corrosion may lead to degradation of 
performance characteristics, even if corrosion of metallic components after exposure to corrosive 
environment does not lead to potential toxicity or embolization.
Recommendation: We recommend that any metallic component of the device be  
 examined for visual signs of corrosion after an immersion test (e.g., exposure of the device to a 
series of saline baths at room temperature, boiling, and 37 C beyond the maximum expected 
clinical use duration). For more information regarding recommendations of methodology for this 
testing, please refer to the currently recognized version of ISO 10555-1:2013 Intravascular 
catheters  Sterile and single-use catheters  Part 1: General requirements, Annex A. Although 
the scope of this standard is limited to intravascular catheters, the method used to evaluate 
corrosion resistance is applicable to atherectomy devices. Refer to the test sample conditioning 
methods in ISO 10555-1:2013 Intravascular catheters  Sterile and single-use catheters  Part 
1: General requirements, Annex A for further details.
e.  Heat Generation
Significance: Rotation of the device can cause heat generation caused by friction between device 
parts and between the rotating tip and tissues (especially if there are rigid calcified areas). 
Similarly, energy from the laser can also generate heat. Increased heat may lead to tissue injury 
or necrosis.
Recommendation: We recommend evaluating the maximum temperature rise of your device 
during simulated use. A clinical and/or scientific rationale for the acceptance criteria should be 
supported by literature (i.e., why an increase in temperature within a specific range does not 
impart tissue/vessel damage). If you have multiple device sizes, you should evaluate the worst-
case model. For example, the largest tip at the fastest recommended rotation is expected to 
generate the most heat for rotational atherectomy devices.
15 Contains Nonbinding Recommendations
f.  Torsional Strength
Significance: Inability to withstand torsional forces that are typical of clinical use (e.g., when the 
distal tip is not free to rotate) could lead to device failure or vessel damage.
Recommendation: We recommend that you measure the torque strength of the atherectomy 
device when the distal tip is not free to rotate by rotating the proximal end of the catheter until 
failure. We recommend that you pre-condition the atherectomy system before evaluating torque 
strength by tracking through a tortuous path fixture, as described in Section (4). We recommend 
that you report the number of rotations to failure and the failure mode for each sample tested. 
Additionally, we recommend that you test the delivery system in a fixture that simulates worst-
case expected anatomy. We also recommend you provide the clinical and/or scientific basis for 
your acceptance criteria.
g.  Tensile Strength
Significance: Failure of bonds in the catheter could lead to device failure, vessel damage, and/or 
embolic risk caused by device remnants within the vasculature.
Recommendation: We recommend evaluating the tensile force of all the joints on your device 
after pre-conditioning (i.e., tracking through a simulated-use model in a water bath at 37C). We 
recommend providing an image or engineering drawing with all the joints labeled. If you choose 
to reference standards (e.g., ISO 10555-1: Intravascular catheters  Sterile and single-use 
catheters  Part 1: General requirements) for establishing your test method, we still recommend 
inclusion of a clinical and/or scientific rationale to support your acceptance criteria for your 
device in the intended anatomy.
h.  Rotational Speed
Significance: Inappropriate or non-stable rotational speed could lead to device failure or vessel 
damage.
Recommendation: We recommend specifying how the device achieves its labeled speed(s) (e.g., 
rotational speed ramps up until the desired level is reached or rotational speed is achieved 
instantaneously) in your test report and device description. We also recommend evaluating the 
rotational speed specified in your labeling and the speed stability over the proposed treatment 
time. It is beneficial to include the rotational speed of the predicate device for comparison. If the 
rotational speed is higher than that of the predicate and other FDA-cleared atherectomy devices, 
a discussion should be included to confirm that the proposed speed is not a safety concern. This 
speed should be supported with an animal study and/or clinical data (i.e., clinical study or 
cadavers). 
i.  Plaque Removal Efficiency
Significance: Inadequate plaque removal may lead to increased procedural time. This test is 
intended to characterize the debulking capability under simulated conditions.
16 Contains Nonbinding Recommendations
Recommendation: We recommend characterizing the plaque removal efficiency in terms of 
percentage of plaque removed, luminal gain, or mass of tissue removed per pass. This test can be 
conducted either in a simulated-use model or cadaver model. For devices with multiple models 
or settings (e.g., speeds), we recommend evaluating the plaque removal efficiency at the 
minimum and maximum specified settings.
j.  Infusion Flow Rate
Significance: Inability to achieve acceptable flow rates could lead to user error, increased 
procedural time, device overheating, and/or tissue damage.
Recommendation: For atherectomy devices intended to infuse saline or contrast agents, the 
appropriate flow-rate range should be established to ensure that the flow rate is consistent and 
safe. Thus, we recommend validating the device flow rate and providing a clinical/scientific 
rationale for why the flow rate is acceptable.
k.  Aspiration Rate
Significance: Inadequate aspiration rate could lead to vessel damage or build-up of debris, 
resulting in device failure and/or debris embolization.
Recommendation: If applicable, we recommend evaluating both the infusion and 
aspiration/suction rate and confirming that the selected rate is adequate to remove emboli but not 
excessive enough to cause vessel collapse or injury. This acceptance criterion should be 
supported by a clinical rationale. The test should be conducted in a simulated-use model and 
supported with animal study data.
l.  Debris Removal and Collection
Significance: Inadequate debris removal could lead to build-up of debris, resulting in device 
failure and/or debris embolization.
Recommendation: If applicable, we recommend evaluating the effectiveness of the removal 
mechanism in a diseased model (i.e., benchtop model, animal model, or cadaver model) via 
quantitative and qualitative methodologies.
m. Embolization Analysis
Significance: Distal embolization is an inherent risk with treatment of peripheral artery disease 
with atherectomy. Migration of large emboli could result in patient injury. 
Recommendation: We recommend capturing and evaluating downstream emboli content post-
atherectomy and quantifying the particulates using a bench and/or animal model. Your analysis 
should determine whether the type, size, and quantity of emboli are clinically acceptable. If a 
downstream filter is used during this test, the type, size, and quantity of the embolic contents 
present in the filter should be evaluated.
17 Contains Nonbinding Recommendations
n.  Life Cycle/Fatigue
Significance: Atherectomy systems are operated through multiple cycles (or passes) during one 
procedure. Failure of the atherectomy device to withstand multiple cycles could lead to device 
failure or vessel damage.
Recommendation: We recommend that you evaluate your device under the worst-case expected 
number of insertions and runtime. We recommend that you provide clinical rationales to support 
the number of insertions and runtime tested. Any changes or deformations to the atherectomy 
device after testing should be reported.
If your device contains an inflatable balloon that assists with cutter or tip apposition, we 
recommend evaluating balloon fatigue, rated burst pressure, balloon compliance, and inflation 
and deflation time. Please refer to the PTCA Catheters Guidance or Non-Clinical Engineering 
Tests and Recommended Labeling for Intravascular Stents and Associated Delivery Systems 
Guidance23 for details.
If your device has an automated handle, we recommend that you verify that device operation 
under user control can withstand the maximum number of cycles expected during clinical use. 
Please also refer to the Automated Handle Functionality Section below for additional testing 
considerations.
o.  Orbit Testing
Significance: For an orbital atherectomy system, the maximum orbital diameter is dependent on 
plaque rigidity, diameter of the rotating component, rotational speed (rpm), and the number of 
passes through the lesion. Inadequate speeds may lead to device failure, increased treatment 
times, and/or vessel damage.
Recommendation: We recommend orbit testing at speeds specified in your labeling in a 
simulated-use model containing a plaque model. We also recommend that you provide a 
clinical/scientific rationale for your acceptance criteria and confirm that the orbits created at your 
pre-determined speeds during your specified intended run time of the device are not expected to 
impart vessel damage. We also recommend that you include orbit performance data in your 
device instructions for use (IFU) (e.g., reference graphs depicting typical orbit diameter versus 
duration of operation (as measured in simulated lesions) for each device size and speed).
p.  Automated Handle Functionality
Significance: Devices may contain an automated handle component with control buttons (e.g., 
for rotational direction), rather than a handle that is physically maneuvered by hand. The 
automated handle should function as intended. Inadequate control of the atherectomy system by 
the automated handle could lead to device failure, increased treatment time, and patient injury.
23 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/non-clinical-engineering-tests-and-
recommended-labeling-intravascular-stents-and-associated-delivery.
18 Contains Nonbinding Recommendations
Recommendation: If your device contains an automated handle, you should evaluate its 
functionality as part of bench or animal testing. We recommend verifying that the catheter distal 
end (e.g., distal tip, cutter) orientation/torque capability operates as expected in worst-case 
simulated anatomy. Additionally, evaluate the rotational response of the atherectomy system 
upon activation by the automated handle and verify that the device does not rotate unexpectedly 
upon activation.
q.  Coating Integrity
Significance: Coating separation (i.e., peeling, flaking, shedding, delamination and/or sloughing 
off) or degradation may result in embolized particulates that could cause clinical complications.
Recommendation: If a coating is present on your device, you should provide the following:
 Name of the coating.
 A description of the physical structure of the coating.
 Location of the coating.
 Length of the coating.
 Representative images using scanning electron microscopy (SEM) and/or optical 
microscopy of the coated surface before and after simulated-use testing at baseline 
(time zero) and post-aging. Images should be of sufficient magnification to fully 
characterize the coating coverage and potential defects. If your coating is clear, it may 
be beneficial to dye the coating before simulated use to allow for proper visualization. 
Apart from standard visual inspection (e.g., 2.5x), please also conduct coating 
inspection at higher magnifications (e.g., 40-500x)) to clearly identify and 
characterize any defects in the coating.
 A summary of your results should be provided. If coating delamination or defects are 
observed, the coating reduction or particulates should be quantified, and a clinical 
rationale for why the results are clinically acceptable should be provided.
r.  Particulate Evaluation
Significance: Particulate generation from the device during clinical use may result in serious 
adverse events. If your coating integrity evaluation identified coating defects that may raise 
additional clinical concerns, particulate evaluation may be needed to address potential safety 
concerns.
Recommendation: If your device has a coating, to accurately account for particulates generated 
during the use of your device, the particles should be characterized and data should be 
interpreted after simulated use. 
Test Samples
You should conduct all testing on the finished product subject to all manufacturing processes 
including sterilization. You should provide a scientific or statistical justification for the sample 
size you plan to test. We recommend that you implement a sampling plan to examine multiple 
lots of product (3) to assess both inter- and intra-lot variability. You should perform testing on 
the extremes and an appropriate intermediate size for the entire product matrix proposed. 
19 Contains Nonbinding Recommendations
Test Methods
We recommend that you evaluate particulate generated by the entire atherectomy system, 
including accessory devices expected to be used during a clinical procedure. Catheters should be 
tracked through a tortuous path fixture (as described above in Sections J(4) Simulated Use Model 
and J(5)b Simulated-Use Testing). When delivered to the site of interest, the device should be in 
direct contact with the simulated vessel without the use of other coatings, lubricants, sheaths, or 
protective wraps between the device and the simulated vessel. To ensure measurement of the 
total number of particles that could be potentially introduced into the bloodstream, the catheter 
should be inserted into the test fixture to the extent at which it would be inserted in clinical use. 
We recommend that the number of particulates generated at each evaluation be quantified and 
characterized by size and count using a validated method (e.g., light obscuration, light refraction) 
under continuous flow conditions to simulate blood flow. Specifically, we recommend that the 
total number of particulates be reported in the following size ranges:  10m, 25m, and at the 
largest size for which validation yields  75% recovery. At a minimum, the largest size should be 
 50m. 
Appropriate precautions should also be implemented to ensure that the particles are suspended 
during particle counting and sizing to minimize aggregation and other artifacts from the test 
system. We recommend that you measure the total quantity and size of the particulates generated 
during the simulated use of your device. We recommend you perform particulate evaluation 
under the worst-case conditions of use. For example, for devices intended for in-stent restenosis 
(ISR), we recommend that you evaluate the quantity and sizes of particulate generated from 
tracking the device through the tortuous path fixture and placement within a stent which has been 
deployed in the mock vessel.
Method Validation
You should describe and validate particle counting and sizing methods. We recommend that you 
introduce a known amount of various particle sizes into the test setup and quantify the amount of 
particles recovered. The number of particles recovered should closely approximate the number 
you artificially introduced into the system. For a system to be considered validated, 90% 
recovery should be demonstrated for the 10m and 25m size ranges.
You should provide a clinical discussion explaining why the results of the particulate evaluation 
and the associated coating integrity assessments do not raise any safety concerns. If the 
particulate evaluation raises safety concerns, then chemical characterization may be appropriate 
to identify the particulate source(s).
(6)  Additional Engineering Testing for Devices Intended to 
Treat In-stent Restenosis
If your atherectomy device is also intended for treatment of in-stent restenosis (ISR), we 
recommend conducting the bench tests specified below in addition to conducting a thorough risk 
analysis to evaluate the risks caused by stent and atherectomy device interaction. If applicable, 
20 Contains Nonbinding Recommendations
the risk analysis should include an evaluation of the stent interaction with the atherectomy device 
(e.g., metal exposure, stent fatigue, post-fatigue corrosion). If you decide to omit any of the tests 
specified below, we recommend providing a rationale based on your risk analysis.
a.  Simulated-Use of Atherectomy Device in a Stent
Significance: Interaction with the stent could lead to device failure, stent fracture, and vessel 
damage.
Recommendation: We recommend evaluating the atherectomy system in an in vitro or in vivo 
model containing both a stent and plaque analog (e.g., using a diseased model or overstretch 
model). Visual inspection should be conducted with the naked eye and under SEM of both the 
stent and atherectomy device pre- and post-testing. The vessel should be assessed for damage. 
See Section IV.K for additional information regarding animal testing.
b.  Heat Generation
Significance: High heat generation caused by interaction between the atherectomy system and 
stent could lead to device failure and tissue damage.
Recommendation: We recommend evaluating heat generation under in vitro simulated-use 
conditions. The acceptable limit of heat generation, if any, should be supported by literature 
and/or clinical data. The acceptance criterion should include the upper heat limit (considering 
both the heat generated by the atherectomy device and heat generated from the interaction of the 
atherectomy device and stent), which could influence vessel safety.
c.  Embolization Analysis
Significance: For ISR treatment, migration of metallic particles downstream as a result of stent 
and atherectomy device interaction could also result in patient injury.
Recommendation: For atherectomy devices intended for ISR treatment, the quantity, identity, 
and size of metallic particulates should also be evaluated. Your analysis should determine 
whether the type and quantity of emboli are clinically acceptable. If a downstream filter is used 
during this test, the quantity, identity, and size of the embolic contents present in the filter should 
be evaluated.
K.  Animal Testing
Significance: Animal testing is generally recommended to evaluate the in vivo safety of 
peripheral vascular atherectomy devices, particularly for new designs, significant device 
modifications, new indications (e.g., ISR), and/or specific anatomies.
Recommendation: Animal testing of atherectomy devices should address factors that cannot be 
evaluated through bench tests or in a clinical study. The study design and endpoints should be 
based upon the mechanism of action of the device and mitigation of associated risks.
21 Contains Nonbinding Recommendations
FDA supports the principles of the 3Rs, to reduce, refine, and replace animal use in testing 
when feasible. You should consider the best practices for the development, conduct, and 
presentation of these animal studies while incorporating modern animal care and use strategies. 
In addition, we encourage you to consult with FDA if you wish to use a non-animal testing 
method that you believe is suitable, adequate, validated, and feasible. We will consider if such an 
alternative method could be assessed for equivalency to an animal test method. 
We encourage manufacturers to take advantage of the Q-Submission Program to ensure that the 
animal study protocol addresses safety concerns and contains elements which are appropriate for 
a regulatory submission (i.e., the study should be performed under Good Laboratory Practice 
(GLP) regulations as stated in 21 CFR part 58 at an animal study facility with appropriate 
licensure and accreditations). In addition, if you are proposing to use a non-animal testing 
method that you believe is suitable, adequate, validated, and feasible, we recommend that you 
discuss the proposal using the Q-Submission Program. We will consider if such an alternative 
method could be assessed for equivalency to an animal test method. For details on the Q-
Submission Program, please refer to the guidance Requests for Feedback and Meetings for 
Medical Device Submissions: The Q-Submission Program.24
(1)  Animal Model 
An ideal animal model should be representative of the human atherosclerotic disease. 
Unfortunately, there are currently no animal models that completely mimic the human 
pathology.25,26Despite this limitation, animal models can provide safety information that cannot 
be obtained through other assessments. Therefore, we recommend the use of a porcine or ovine 
large animal model because of the similarities in cardiovascular system size and anatomy, which 
have demonstrated suitability for translation to humans. For details on animal study 
recommendations, please refer the FDA guidance, General Considerations for Animal Studies 
for Cardiovascular Devices.27
Although experimental animal models of atherosclerosis do exist (i.e., swine diet-induced 
atherosclerotic model or simulated plaque), the cost and time involved with developing the test 
systems with intravascular lesions often make these models prohibitive to yield robust data for 
regulatory safety studies. Healthy native vessel models are therefore typically employed and 
represent the worst-case scenario caused by direct contact of the debulking portion of the device 
with the intima versus a hard-atherosclerotic lesion, as is intended for clinical use. This factor 
and species-related differences are taken into consideration when interpreting the data for the 
premarket submission. Additional animal models may be applicable to evaluate specific intended 
24 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/requests-feedback-and-meetings-
medical-device-submissions-q-submission-program.
25 Kapourchali, Fatemeh Ramezani, Gangadaran Surendiran, Li Chen, Elisabeth Uitz, Babak Bahadori, and 
Mohammed H. Moghadasian. Animal Models of Atherosclerosis. World Journal of Clinical Cases, vol. 2, no. 5, 
2014, pp. 126-132.
26 Li, Xiangdong, Yuanwu Liu, Hua Zhang, Liming Ren, Qiuyan Li, and Ning Li. Animal Models for the 
Atherosclerosis Research: A Review. Protein & Cell, vol. 2, no. 3, 2011, pp. 189-201.
27 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/general-considerations-animal-
studies-cardiovascular-devices-guidance-industry-and-fda-staff.
22 Contains Nonbinding Recommendations
uses or anatomies. For example, as noted above, an overstretch model may be employed to 
generate stenosis in a stent for evaluating atherectomy systems in ISR. 28,29
(2)  Study Endpoint Considerations
When defining your study endpoint, we recommend that animal safety studies for atherectomy 
devices should contain both acute and chronic testing elements that use the specified predicate 
device(s) as the control article. The elements we generally recommend evaluating in animal 
studies for atherectomy devices are as follows:
a.  Acute Testing (Day 0)
Acute testing should capture:
  user data (as rated by qualified independent interventionalists), including:
 ease of use/usability;
 catheter trackability in vascular anatomy;
 visibility on standard imaging; and
 compatibility with accessory devices;
 major adverse events;
 acute procedural vascular safety via angiography for overall vessel integrity, 
including:
 dissection;
 filling defects; 
 stenosis; 
 thrombosis; and/or 
 other abnormalities;
 acute procedural evaluation, including hemolysis and downstream emboli (size and 
type); and
 examination of device for thrombus-acute thrombogenicity.
b.  Chronic Study Data (Days 28+)
Duration of testing and evaluation timepoints should be based upon mechanism of action, 
identified risks, expected resolution of the inflammatory response, and vascular healing. We 
generally recommend a 28- to 30-day observation period following treatment. However, longer 
studies may be warranted if healing is not observed at 30 days. In your submission, we 
recommend providing a justification for the chosen timepoints based upon device design and 
mechanism of action. If unsure, we recommend using the Q-Submission Program to obtain 
feedback on your study protocol; please refer to the Q-Submission Guidance. The chronic study 
endpoints should include:
28 Schwartz, Robert S., Joseph G. Murphy, William D. Edwards, Allan R. Camrud, Ronald E. Vlietstra, and David 
R. Holmes. Restenosis after Balloon Angioplasty. A Practical Proliferative Model in Porcine Coronary Arteries. 
Circulation, vol. 82, 1990, pp. 2190-2200.
29 Touchard, Arturo G., and Robert S. Schwartz. Preclinical Restenosis Models: Challenges and Successes. 
Toxicologic Pathology, vol. 34, 2006, pp. 1118.
23 Contains Nonbinding Recommendations
 major adverse events;
 in-life clinical observations;
 imaging of vascular treatment site by angiography or other imaging modalities for 
vascular integrity/patency, filling defects, and stenosis at baseline, interim timepoints, 
and at sacrifice;
 clinical pathology at baseline and at time of sacrifice;
 complete necropsy with focus on vascular treatment sites, major organ systems and 
downstream tissue beds for thromboembolic events;
 histopathology of vascular treatment sites for injury (external elastic lamina 
(EEL)/internal elastic lamina (IEL) integrity), intimal thrombi, inflammation, 
endothelialization, hemorrhage, and mineralization; and
 histomorphometric evaluation of vascular treatment sites for stenosis, as appropriate.
L.  Clinical Performance Testing
Significance: Non-clinical evaluation does not fully characterize all relevant clinical experience, 
outcomes, and risks needed to demonstrate substantial equivalence. As previously noted, a 
diseased animal model with clinically relevant challenging anatomy and lesions does not 
currently exist. We believe a clinical study evaluating multiple operators, patient demographics, 
and lesion characteristics represents the least burdensome approach to demonstrate substantial 
equivalence. Therefore, we recommend that you conduct in vivo (i.e., clinical) studies to evaluate 
device safety and effectiveness for new and modified peripheral vascular atherectomy devices.
Recommendation: Clinical data are typically expected for new devices, devices modified in 
design and/or functionality (e.g., modification to the debulking portion of the atherectomy 
device), and new indications for use or labeling changes associated with device benefit or 
improved clinical outcomes. Because of the multivariable considerations for establishing the 
need for clinical data, FDA recommends having a discussion via the Q-Submission Program 
early in device development or when modifications are proposed; please refer to the Q-
Submission Guidance.
If a clinical study is needed to demonstrate substantial equivalence, i.e., conducted before 
obtaining 510(k) clearance of the device, the study must be conducted under the Investigational 
Device Exemption (IDE) regulation, 21 CFR part 812.Generally, FDA believes that atherectomy 
devices addressed by this guidance are significant risk devices subject to requirements set forth 
in 21 CFR 812.please see the FDA guidance, Significant Risk and Nonsignificant Risk Medical 
Device Studies.30 In addition to the requirements of 21 CFR part 812, sponsors of such trials 
must comply with the regulations governing institutional review boards (21 CFR part 56) and 
informed consent (21 CFR part 50).
In some cases, real-world data (RWD) may be used to support expansion of the indication for a 
device for which 510(k) clearance has already been obtained. Whether the collection of RWD for 
30 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/significant-risk-and-nonsignificant-
risk-medical-device-studies.
24 Contains Nonbinding Recommendations
a legally-marketed device requires an Investigational Drug Exemption (IDE) depends on the 
situation. Specifically, if a cleared device is being used in the normal course of medical practice, 
an IDE would likely not be required. For additional information regarding this topic, please refer 
to the FDA guidance, Use of Real-World Evidence to Support Regulatory Decision-Making for 
Medical Devices.31
(1)  Considerations for the Level of Clinical Evidence
The level of clinical evidence depends on several factors, including but not limited to the 
following:
a.  Proposed Indications for Use
If the device is intended to be used as the primary treatment (e.g., in lieu of percutaneous 
transluminal angioplasty (PTA)), clinical evidence should be provided to demonstrate that the 
device has equivalent safety and performance compared to PTA or another atherectomy device 
with regards to meaningful clinical outcome measures (e.g., major adverse events, patency, 
target lesion revascularization measured at six months).
b.  Use with Other Endovascular Therapies
If you propose to label the atherectomy device to be used in conjunction with PTA, stenting, or 
other endovascular therapies, the contribution of the atherectomy device itself should be 
demonstrated in a clinically meaningful way. Clinical data may be appropriate to support 
labeling of the devices when used in combination with other endovascular therapies. Your 
labeling should accurately reflect the outcome of your clinical study.
c.  Novelty of Design
For new or modified designs and technologies, clinical data may be expected to be provided to 
support a substantial equivalence determination. FDA recommends that you assess the need for 
additional clinical testing based on your device operational characteristics via the Q-Submission 
Program; please refer to the Q-Submission Guidance.
d.  Use in Specific Lesion Types
Clinical data should be provided if your device is intended to treat specific anatomies or lesion 
types (e.g., below-the-knee, ISR lesions, long lesions) and should be noted in your indications 
for use and/or labeling. For example, patients with ISR lesions should be independently studied 
(e.g., separate arm, separate study) given the unique characteristics of these lesions as well as the 
potential for interactions between devices that may impact clinical outcomes.
31https://www.fda.gov/regulatory-information/search-fda-guidance-documents/use-real-world-evidence-support-
regulatory-decision-making-medical-devices.
25 Contains Nonbinding Recommendations
(2)  Study Endpoint Considerations
We recommend that you conduct a multi-center, prospective study designed to collect data to 
support the safety and effectiveness of your device. As previously noted, a diseased animal 
model with clinically relevant challenging anatomy and lesions does not currently exist. 
Therefore, we believe a clinical study represents the least burdensome approach to demonstrate 
substantial equivalence while evaluating multiple operators, patient demographics, and lesion 
characteristics. The sample size should be determined based on sound clinical and statistical 
principles. The study endpoints and results should be compared to known outcomes for 
alternative atherectomy therapies. Patient selection should include both clinical and anatomical 
criteria (e.g., Rutherford categorization, lesion diameter/length, lesion location). We recommend 
considering the following safety and effectiveness evaluations:
a.  Safety Assessment
For all planned studies, data regarding a composite of Major Adverse Events (MAEs) 
adjudicated by an independent Clinical Events Committee (CEC) should be captured. MAE may 
be defined as the composite of the occurrence through 30-day follow-up of all-cause death, 
unplanned major amputation, and target lesion revascularization (TLR).
b.  Performance Assessment
Demonstrating performance of an atherectomy device generally includes: (1) a measure of acute 
technical success (e.g., residual diameter stenosis after treatment) and (2) a measure of clinical 
success (e.g., target lesion revascularization at six months).
We may consider alternatives to clinical testing when the proposed alternatives are supported by 
an adequate scientific rationale. We suggest that you contact FDA to discuss clinical study 
planning early in your device development process using the Q-Submission Program.
M.  Labeling
The premarket notification must include proposed labeling in sufficient detail to satisfy the 
requirements of 21 CFR 807.87(e). Proposed labels and labeling, sufficient to describe the 
peripheral vascular atherectomy device, its intended use, and the directions for use, must be 
provided. As noted previously for specific non-clinical tests in Section IV.J, your labeling should 
include relevant attributes (e.g., rotational speed(s), duration of treatment, aspiration 
characteristics) of your device. Your labeling should also include a description of how long your 
device takes to achieve its labeled speed (e.g., ramped up to desired rotational speed or rotational 
speed achieved instantaneously) and orbit performance data, if applicable, for each device size 
and speed. 
As prescription devices, peripheral vascular atherectomy devices are exempt from having 
adequate directions for non-prescription use under section 502(f) of the FD&C Act (21 U.S.C. 
352(f)) as long as the conditions in 21 CFR 801.109 are met. For instance, labeling must include 
adequate information for practitioner use of the device, including indications, effects, routes, 
methods, frequency and duration of administration, and any relevant hazards, contraindications, 
side effects, and precautions (21 CFR 801.109(d)). 
26 Contains Nonbinding Recommendations
V.  Modifications
In accordance with 21 CFR 807.81(a)(3), a device change or modification that could 
significantly affect the safety or effectiveness of the device or represents a major change or 
modification in the intended use of the device requires a new 510(k). The changes or 
modifications listed below would likely require submission of a new 510(k). Note that the lists 
provided below are not exhaustive but provide examples of modifications that generally require 
submission of a new 510(k). For additional details, please see FDA guidances 
Deciding When to Submit a 510(k) for a Change to an Existing Device32 and Deciding When 
to Submit a 510(k) for a Software Change to an Existing Device.33
Such changes or modifications that generally require a new 510(k) submission include:
 Significant change in device dimensions: FDA considers this change to be a 
modification in design that could alter the device performance, which in turn could 
impact the safety and effectiveness of the device. Thus, if dimensional changes are 
not in the range previously cleared, test data reports should be provided for FDA 
review to support the change.
 Change to the debulking component or mechanism (e.g., change from directional to 
orbital): FDA considers this change to be a modification in design. FDA has 
determined that this change could significantly affect safety and effectiveness of the 
device as it could change how the device operates and interacts with blood vessels. 
More specifically, changes in the debulking component could also impact the extent 
of vessel trauma, which could pose a safety risk.
 Supplier or material change to a critical component (e.g., rotation component, 
catheter coating): FDA considers this change to be a modification in material. FDA 
has determined that this change could significantly affect safety and effectiveness of 
the device as a change in supplier and/or material may affect performance and/or 
introduce different types or quantities of residual chemicals, which could result in a 
toxic response, corrosion, or device failure.
 Change in the laser component specifications: FDA considers this change to be a 
modification in design. FDA has determined that a change in the laser component 
specifications (e.g., laser generator type, optical fiber density, laser modes, device 
crossing profile, device working length) could significantly affect safety and 
effectiveness of the device by potentially influencing laser output parameters (e.g., 
pulse duration, output energy, repetition rate), which would ultimately influence how 
the device effectively targets and ablates lesions. To support a change in laser 
component specifications, new testing should be provided to demonstrate that the 
device does not ablate lesions outside the expected range of use such that it would 
pose a safety risk or affect ablation effectiveness.
32 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/deciding-when-submit-510k-change-
existing-device.
33 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/deciding-when-submit-510k-
software-change-existing-device.
27 Contains Nonbinding Recommendations
 Change in sterilization technique: FDA considers this change to be a significant 
change. FDA has determined that this change could affect the safety and effectiveness 
of the device as it could impact device sterility and biocompatibility. For example, 
changes to an ethylene oxide sterilization process may leave increased ethylene oxide 
residuals. Additionally, changes in sterilization may unintentionally affect device 
materials, which could consequently affect the safety and effectiveness of the device.
 Significantly altered user technique (e.g., change from manual to automatic feature): 
FDA considers this change to be a significant change. FDA has determined that this 
change could significantly affect safety and effectiveness of the device by altering the 
extent of user control, which could significantly impact how the device interacts with 
the patient.
 Change in power source: FDA considers this change to be a modification in energy 
source. FDA has determined that his change could significantly affect the safety and 
effectiveness of the device by introducing new risks that were not previously 
considered or evaluated in a prior 510(k) submission. For example, a change from AC 
power to DC power in the form of a rechargeable battery may alter the failure modes. 
For example, a battery can fail due to over-charge or over-discharge, while AC power 
usually does not have this failure mode. Alternately, if a non-rechargeable battery is 
used to power the catheter, then the capacity of the battery would limit the device use-
time while AC power would allow for potentially limitless device use time. Thus, it is 
important for FDA to evaluate changes in the power source to ensure safe and 
effective use of the device.
Changes or modifications in the indications for use or labeling could significantly affect both the 
safety and effectiveness of the device. The following changes are examples that would require a 
new 510(k) submission:
 Change in specific lesion characteristics (e.g., ISR) or a change in specific 
vasculature (e.g., below the knee, upper extremities)
 Labeling changes to capture improvement of outcomes in combination with other 
technologies (e.g., pre-treatment with atherectomy improves outcomes of angioplasty 
or drug-coated balloon). This type of labeling change should be supported with bench 
and/or clinical data because utilization of atherectomy in combination with other 
therapies could impact patient safety when considering the extent or level of 
treatment the patient is expected to receive.
Conversely, FDA believes that the following changes or modifications, generally, do not require 
the submission of a new 510(k):
 Minor change in packaging: A minor change in packaging (e.g., removal of hardcopy 
Instructions for Use from the box and replacement with an electronic version, update 
to the expiration date) is not expected to impact device safety and performance.
 Increase in shelf-life: An increase in device shelf-life is not expected to impact device 
safety and performance as long as the testing protocols and acceptance criteria have 
been previously reviewed and accepted (e.g., in the original 510(k)). Additionally, the 
28 Contains Nonbinding Recommendations
test results should fall within the acceptance criteria previously found to be 
acceptable.
The following list provides a history of revisions to this guidance document from July 2020 to 
present:
  Select Updates for Peripheral Vascular Atherectomy Devices - Premarket Notification 
[510(k)] Submissions: Draft Guidance for Industry and Food and Drug Administration 
Staff issued July 13, 2020
29