K083508 · Excelsior Medical Corp. · QBP · Apr 28, 2009 · General Hospital
Device Facts
Record ID
K083508
Device Name
SWABCAP
Applicant
Excelsior Medical Corp.
Product Code
QBP · General Hospital
Decision Date
Apr 28, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5440
Device Class
Class 2
Indications for Use
SwabCap™ is intended for use on swab-able luer access valves as a disinfecting cleaner prior to line access and to act as a physical barrier to contamination between line accesses. SwabCap™ will disinfect the valve five (5) minutes after application and act as a physical barrier to contamination for up to ninety-six (96) hours under normal conditions if not removed.
Device Story
SwabCap is a single-use, sterile cap containing 70% isopropyl alcohol; designed to fit securely onto swab-able luer access valves. Device functions as a disinfecting cleaner and physical barrier; disinfection occurs 5 minutes after application; barrier protection lasts up to 96 hours. Used in clinical settings by healthcare providers to maintain sterility of intravenous access points between line accesses. Benefits include reduced risk of contamination and associated bloodstream infections. Device is latex-free, preservative-free, and DEHP-free.
Clinical Evidence
Bench testing only. No clinical data provided.
Technological Characteristics
Cap containing 70% isopropyl alcohol; sterile; latex-free; preservative-free; DEHP-free. Sterilization via gamma irradiation. Single-use, passive mechanical barrier design.
Indications for Use
Indicated for use on swab-able luer access valves as a disinfecting cleaner and physical barrier to contamination for patients requiring intravenous line access.
Regulatory Classification
Identification
An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.
Special Controls
*Classification.* Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left, and the FDA logo on the right. The FDA logo is in blue and includes the acronym "FDA" followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in a stacked format.
Excelsior Medical Corp. Roshana Ahmed Manager c/o CanReg, Incorporated 4 Innovation Drive Dundas, On, L2H 7P3 Canada
March 11, 2022
Re: K083508
Trade/Device Name: Swabcap Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: QBP
Dear Roshana Ahmed:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated April 28, 2009 and the correction letter dated March 6, 2019. Specifically, FDA is updating this SE Letter because FDA has better categorized your device technology under regulation 880.5440.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Payal Patel, OHT3: Office of GastroRenal, Ob-Gyn, General Hospital and Urology Devices, 240-402-6029, Payal.Patel(@fda.hhs.gov.
Sincerely,
P
Payal Patel Assistant Director for General Hospital Devices DHT3C: Division of Drug Delivery and General Hospital Devices and Human Factors OHT3: Office of GastroRenal, Ob-Gyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Image /page/1/Picture/0 description: The image shows the logo of the U.S. Food & Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the agency's name on the right. The symbol is a stylized representation of a caduceus, a traditional symbol of medicine. The agency's name is written in bold, sans-serif font, with "U.S. FOOD & DRUG" on the top line and "ADMINISTRATION" on the bottom line.
March 6, 2019
Excelsior Medical Corp. Roshana Ahmed Manager 4 Innovation Drive Dundas. Ontario. L2H 7P3 Canada
Re: K083508 Trade/Device Name: SwabCapTM Regulatory Class: Unclassified Product Code: QBP Dated: November 24, 2008 Received: November 26, 2008
#### Dear Roshana Ahmed:
This letter corrects our substantially equivalent letter of April 28, 2009.
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's
U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov
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#### K083508 - Roshana Ahmed
requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801): medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable. the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803). please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Geeta K. Pamidimukkala -S
for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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K083508
Excelsior Medical Corporation Traditional 510(k)
SwabCap™
## Indications for Use
| 510(k) Number: | K083508 |
|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name: | SwabCap <sup>TM</sup> |
| Indication for Use: | SwabCap <sup>TM</sup> is intended for use on swab-able luer access valves as a disinfecting cleaner prior to line access and to act as a physical barrier to contamination between line accesses. |
| | SwabCap <sup>TM</sup> will disinfect the valve five (5) minutes after application and act as a physical barrier to contamination for up to |
ninety-six (96) hours under normal conditions if not removed.
Prescription Use _ X (21 CFR Part 801 Subpart D) And/Or
Over the Counter Use (21 CFR Part 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE; CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
H. Ol
for
Division Sign-Off . Office of Device Evaluation
510(k)
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
KO83508 510(k) Number: __
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# 510(k) Summary of Safety and Effectiveness
| Manufacture Name: | Excelsior Medical Corporation |
|------------------------------|-------------------------------------|
| Contact Name: | John Linfante |
| Title | VP Regulatory and Quality Assurance |
| Postal Address: | 1933 Heck Avenue |
| | Neptune, NJ 07753 |
| Phone Number: | 732-643-6088 |
| Fax: | 732-776-7600 |
| Date: | February 12, 2009 |
| Device Proprietary Names: | SwabCap™ |
| Device Common or Usual Name: | Alcohol pad |
| Classification Name: | Pad, Alcohol, Device Disinfectant |
| Classification Code | LKB |
| Classification Panel | General Hospital |
| Regulation Number | N/A |
#### Predicate Device:
Substantial equivalence is claimed to the following devices as related to intended use and design characteristics:
- Effectiv™ Cap, Hospira, Inc., K080579 .
- . Curos Port Protector, Ivera Medical, K080466
- Alcohol Prep Pad, Professional Disposables Inc. 510(k) Number: Unknown .
#### Description of the Device
The SwabCap™ is designed to securely fit on swab-able luer access valves. The cap contains 70% isopropyl alcohol. The product is intended for single-use and is provided sterile, latex free, preservative free and DEHP free.
#### Intended Use of the Device
SwabCap" is intended for use on swab-able luer access valves as a disinfecting cleaner prior to line access and to act as a physical barrier to contamination between line accesses.
SwabCap" will disinfect the valve five (5) minutes after application and act as a physical barrier to contamination for up to ninety-six (96) hours under normal conditions if not removed.
#### Substantial Equivalence
The SwabCap " is similar to the predicate devices based on the intended use, design, technology, antimicrobial agent and performance.
#### Conclusion
Based on the information provided in this 510(k) premarket notification, the SwabCap" is substantially equivalent in terms of safety and effectiveness to the predicate devices identified above.
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K083505
2 of 3
SwabCap™
### Section J - Substantial Equivalence
Table J-1 compares the SwabCap™ to the predicate devices.
| 510(k) Number | K083508 | K080579 | K080466 | Unknown |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | SwabCap™ | Effectiv™ Cap | Curos™ Port<br>Protector | Alcohol Prep<br>Pad |
| Manufacturer | Excelsior<br>Medical Corp. | Hospira, Inc. | Ivera Medical<br>Corporation | Professional<br>Disposables Inc. |
| Intended Use | SwabCap™ is<br>intended for use<br>on swab-able<br>luer access<br>valves as a<br>disinfecting<br>cleaner prior to<br>line access and<br>to act as a<br>physical barrier<br>to contamination<br>between line<br>accesses. | The Effectiv™<br>Cap is a device<br>containing 70%<br>IPA. When left<br>in place for 5 to<br>10 minutes the<br>cap<br>decontaminates<br>the injection<br>port; thereafter<br>the cap provides<br>a physical barrier<br>during intended<br>use. | The Curos™ Port<br>Protector is a<br>device<br>containing 70%<br>Isopropyl<br>alcohol. When<br>left in<br>place for 5 to 15<br>minutes the<br>Curos™ Port<br>Protector<br>decontaminates<br>the injection<br>port; thereafter<br>the Curos™ Port<br>Protector<br>provides a<br>physical barrier<br>during the<br>intended use. | For topical<br>cleansing prior<br>to injections or<br>venipuncture.<br>Each soft pad is<br>saturated with<br>70% isopropyl<br>alcohol.<br><br>For professional<br>and hospital use. |
| Additional<br>Claims | DEHP, Latex<br>and Preservative<br>Free | DEHP and Latex<br>Free | unknown | unknown |
| Antimicrobial<br>Agent | 70% Isopropyl<br>Alcohol | 70% Isopropyl<br>Alcohol | 70% Isopropyl<br>Alcohol | 70% Isopropyl<br>Alcohol |
| Sterilization | Gamma<br>Irradiated | Unknown | Non-sterile | Gamma<br>irradiated |
| Packaging | Individually<br>wrapped with<br>peel off foil lid | Individually<br>wrapped with<br>peel off foil lid | Individually<br>wrapped. | Individually<br>packaged in<br>packets. |
Table J-1: Comparison to Predicates for SwabCap"
349
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Image /page/6/Picture/1 description: The image shows the word "SwabCap" in a stylized font, with the letters slightly spaced apart. Above the word "SwabCap", there are two lines of text that appear to be handwritten. The first line of text is "K08352", and the second line of text is "3df3".
#### Discussion:
The SwabCap™ device is similar to the predicate devices in terms of intended use, design and material characteristics.
### Conclusion:
It is concluded that the SwabCap™ device is substantially equivalent to the predicate devices.
i
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.