K103035 · Draeger Medical GmbH · BSZ · Mar 28, 2012 · Anesthesiology
Device Facts
Record ID
K103035
Device Name
SMARTPILOT VIEW MODEL MK04500
Applicant
Draeger Medical GmbH
Product Code
BSZ · Anesthesiology
Decision Date
Mar 28, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5160
Device Class
Class 2
Indications for Use
The SmartPilot View is software which monitors and logs the dosage of intravenous and volatile drugs administered to a human being. Additionally, SmartPilot View displays pharmacokinetic, pharmacodynamic (PK/PD) and interactive PD modeling information. Smart Pilot provides the health care professional with theoretical information about the modeled effect of supported anesthesia pharmaceuticals delivered to the patient. The SmartPilot View is software for use by health care professionals trained in the application of general anaesthesia. The SmartPilot View is intended for use with data from adults only. The demographic ranges for these patient data are as follows: Height 59 in to 79 in (150 cm to 200 cm) Weight 88 lb to 309 lb (40 kg to 140 kg) Age 18 to 90 years
Device Story
SmartPilot View is software running on a dedicated workstation (Draeger C700) that integrates data from anesthesia workstations, IV pumps, and patient monitors. It processes drug dosage data alongside patient parameters (HR, NIBP, etCO2, BIS) to visualize pharmacokinetic and pharmacodynamic effects of intravenous (hypnotics, opioids, muscle relaxants) and volatile anesthetics. The system uses PK/PD models to calculate and display synergetic/additive drug effects in a 2D diagram and computes a novel pharmacodynamic parameter (NSRI). Used by anesthesia professionals in clinical settings, the output provides theoretical modeling information to assist in anesthesia management and retrospective case analysis. It does not control drug delivery but informs clinical decision-making regarding anesthesia depth and drug titration.
Clinical Evidence
No clinical data. Bench testing only, including software validation per IEC 62304 and risk management per ISO 14971.
Technological Characteristics
Software-based PK/PD modeling system. Operates on dedicated patient vicinity workstation (Draeger C700) with Infinity Explorer. Connectivity via RS232/RJ45. Implements pharmacokinetic and pharmacodynamic models for specific intravenous and volatile anesthetics. Complies with IEC 62304 and ISO 14971.
Indications for Use
Indicated for adult patients (age 18-90, height 150-200 cm, weight 40-140 kg) undergoing general anesthesia to monitor/log drug dosage and display PK/PD modeling information.
Regulatory Classification
Identification
A gas machine for anesthesia is a device used to administer to a patient, continuously or intermittently, a general inhalation anesthetic and to maintain a patient's ventilation. The device may include a gas flowmeter, vaporizer, ventilator, breathing circuit with bag, and emergency air supply. A gas machine for analgesia is a device used to administer to a patient an analgesic agent, such as a nitrous oxide-oxygen mixture (maximum concentration of 70 percent nitrous oxide).
{0}------------------------------------------------
MAR 2 8 2012
K103035 Traditional 510(k) SmartPilot View
Dräger
ﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤ
# Premarket Notification 510(k) summary As required per 807.92
### General Company Information
| Submitters Name and Address: | Dräger Medical GmbH<br>Moislinger Allee 53-55,<br>D-23542 Luebeck, Germany | |
|---------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Contact Person: | Mr. Ulrich Schroeder<br>Moislinger Allee 53-55,<br>D-23542 Luebeck, Germany<br>Phone : 49 (451) 882-3648<br>Fax :49 (451) 882-3018<br>Email: Ulich.Schroeder@draeger.com | |
| Alternate | Mrs. Joyce Kilroy, Draeger Medical Systems, Inc., 3135<br>Quarry Road, Telford, PA 18969-1042<br>Phone +1 (215) 660-2626,<br>Fax: +1 (215) 721-5424<br>Email: joyce.kilroy@draeger.com | |
| Versions : | Initial Version : | 2010-10-08 |
| | Change 1 for submission: | 2012-03-28 |
| Device Name | | |
| Common Name: | Software, Information system, anaesthesia | |
| Legally Marketed Device<br>Identification (Trade name): | SmartPilot View | |
| Regulation Number | 868.5160 | |
| Regulation Description | Gas machine for anesthesia | |
| Regulation Medical Specialty | Anesthesiology | |
{1}------------------------------------------------
### K103035 Traditional 510(k) SmartPilot View
| Product Code | BSZ |
|---------------------------|---------|
| Class | 2 |
| 510(k) Number (if known): | K103035 |
### Device description:
The current version of the SmartPilot View is receiving data from a dedicated anesthesia workstation or combination of workstation and other devices.
Image /page/1/Figure/5 description: The image shows a diagram with four boxes. The boxes on the left are labeled M, A, and IV. The box on the right is labeled C700 IT. The boxes on the left are connected to the box on the right by lines labeled RS232 and RJ45/RS232.
- র্ব Anesthesia workstation
- Monitor M
- IV IV pumps
The Software SmartPilot View runs on a dedicated patient vincinity workstation (Draeger C700 for IT) with the installed Infinity Explorer Software.
The data is taken from dedicated anesthesia workstation A (Draeger Primus US "Apollo") or combination of the workstation and other devices like IV Pumps (B.Braun Perfusor Space pump) and patient monitors M (Draeger Delta/Delta XL, Kappa, Omega S).
The software visualizes the drug effect based on pharmacokinetic models and the drug interaction based on pharmacodynamic models known from scientific literature.
The software visualizes the synergetic and additive drug effect on a screen in a specially developed 2D pharmacodynamic diagram. Furthermore a new pharmacodynamic parameter (NSRI) is calculated based on the synergetic drug effects.
The software monitors and calculates data for the use during the anesthesia case. The software also logs data during the anesthesia case for a retrospective analysis.
Supported drugs:
Intravenous hypnotics – Propofol
Volatile hypnotics
- Isoflurane
- Sevoflurane
- Desflurane
- Enflurane
{2}------------------------------------------------
Image /page/2/Picture/1 description: The image shows the word "Dräger" in a bold, sans-serif font. The "a" in the word has an umlaut, which is a diacritical mark consisting of two dots above the letter. The text is black and appears to be slightly pixelated, suggesting it may be a scanned image or a low-resolution graphic. The background is plain white.
Intravenous opioids
### - Fentanyl
- Remifentanil
- Sufentanil
- Alfentanil
Intravenous muscle relaxants
- Pancuronium
- Rocuronium
### Parameters provided by the basic device (monitor and anaesthesia machine)
- Heart rate HR in 1/min
- Mean non-invasive blood pressure NIBP M or mean arterial pressure ART M in mmHg or kPa.
- ~ End-expiratory CO2 concentration etCO2 in mmHg, Vol.% or kPa.
- Bispectral index BIS
- BIS signal quality index SQI in % ।
### Statement of Indications / Intended Use:
The SmartPilot View is software which monitors and logs the dosage of intravenous and volatile drugs administered to a human being. Additionally, SmartPilot View displays pharmacokinetic, pharmacodynamic (PK/PD) and interactive PD modeling information.
Smart Pilot provides the health care professional with theoretical information about the modeled effect of supported anesthesia pharmaceuticals delivered to the patient.
The SmartPilot View is software for use by health care professionals trained in the application of general anaesthesia.
The SmartPilot View is intended for use with data from adults only. The demographic ranges for these patient data are as follows:
Height 59 in to 79 in (150 cm to 200 cm) Weight 88 lb to 309 lb (40 kg to 140 kg) Age 18 to 90 years
### Substantial Equivalence (identification of the legally marketed Predicate):
With respect to the pharmacokinetic and pharmacodynamic calculation and display of data the Smart Pilot View is equivalent to the Navigator Applications Suite (K071097, K081941, K083098, K102389) from GE Healthcare Finland Oy.
The display of the monitoring data is equivalent to the Software Infinity Explorer (K013515, K022889, K030615, K040945, K060254) from Draeger Medical Systems, Inc..
{3}------------------------------------------------
### Assessment of non-clinical testing:
The SmartPilot View has been tested according to its specifications, including software validation.
The following standards and guidelines were used to support the safe use of the Software:
ISO 14971 :2007 Medical devices - Application of risk management to medical devices
IEC 62304 :2006 Medical device software - Software life-cycle processes
FDA CDRH Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (Document issued on: May 11, 2005)
### Clinical performance data:
Not applicable
### Biocompatibility:
Not applicable
### Sterilization:
Not applicable
{4}------------------------------------------------
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or a stylized human figure with outstretched arms.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room-WO66-G609 Silver Spring, MD 20993-0002
Draeger Medical GmbH C/O Ms. Royce Kilroy Vice President Draeger Medical System. Incorporated 3135 Quarry Road Telford, Pennsylvania 18969
MAR 2 8 2012
Re: K103035
Trade/Device Name: SmartPilot View Regulation Number: 21 CFR 868.5160 Regulation Name: Gas Machine for Anesthesia or Analgesia Regulatory Class: II Product Code: BSZ Dated: March 22, 2012 Received: March 23, 2012
Dear Ms. Kilroy:
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 (for the indications for use stated in the enclosure) 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. 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.
{5}------------------------------------------------
### Page 2- Ms. Kilroy
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices /ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely vours.
Nh for
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
### Enclosure
{6}------------------------------------------------
# Indications for Use Statement
510(k) Number (if known): K103035
Device Name: SmartPilot View
Indications for Use:
The SmartPilot View is software which monitors and logs the dosage of intravenous and volatile drugs administered to a human being. Additionally, SmartPilot View displays pharmacokinetic, pharmacodynamic (PK/PD) and interactive PD modeling information. Smart Pilot provides the health care professional with theoretical information about the modeled effect of supported anesthesia pharmaceuticals delivered to the patient.
The SmartPilot View is software for use by health care professionals trained in the application of general anaesthesia.
The SmartPilot View is intended for use with data from adults only. The demographic ranges for these patient data are as follows:
Height 59 in to 79 in (150 cm to 200 cm) Weight 88 lb to 309 lb (40 kg to 140 kg) Age 18 to 90 years
Schultheis
(Division Sign-Off) vision of Anesthesiology, General Hospital rection Control. Dental Devices
1103035 i10(k) Number:
X Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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.