EURO DEFI PADS ADULT; EURO DEFI PADS ADULT RADIOTRANSPARENT: EURO DEFI PADS PEDIATRIC
Applicant
Fiab Spa
Product Code
LDD · Cardiovascular
Decision Date
Jun 16, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.5300
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
EURO DEFI PADS series of disposable multi-function electrodes are indicated for the following clinical applications: - external defibrillation - synchronized cardioversion - cardiac stimulation - ECG monitoring EURO DEFI PADS scries of disposable multi-function electrodes provide the conductive interface between the defibrillator and the patient's skin. These devices are available with different connectors compatible for use with different defibrillators. All devices are non-sterile and for single-use only. The pediatric model of EURO DEFI PADS disposable multi-function electrodes is intended for use on pediatric patient under eight years of age, or weighting less than 25 kg, the device is designed to deliver a maximum of 100 joule. The adult model of EURO DEFI PADS disposable multi-function electrodes is intended for use on adult patients and children older than eight years or greater than 25 kg, the device is designed to deliver a maximum of 360 joule. The radio-transparent adult model EURO DEFI PADS disposable multi-function electrodes for adult patient use only, is well suited for certain clinical applications involving radiographic viewing.
Device Story
Disposable multi-function electrodes; provide conductive interface between defibrillator and patient skin. Components: foam backing, laminated metallic substrate, conductive hydrogel, lead wires, molded connector. Used in hospitals and paramedic settings by medical staff. Facilitates delivery of electrical energy for defibrillation, cardioversion, or pacing; enables ECG signal acquisition. Passive device; no active processing. Benefits: enables life-saving cardiac therapy and monitoring. Single-use, non-sterile.
Clinical Evidence
Bench testing only. Biocompatibility testing per ISO 10993-5 (cytotoxicity) and ISO 10993-10 (irritation/hypersensitivity). Component compatibility testing (connector force, energy delivery, ECG monitoring). Electrical safety testing per ANSI/AAMI DF80:2003. Accelerated aging shelf-life testing (30 months).
Technological Characteristics
Foam backing, laminated metallic substrate, conductive hydrogel. Passive electrode interface. Radiopaque or radiotransparent versions. Single-use, non-sterile. Connectivity via molded connectors compatible with various defibrillator brands. Compliant with 21 CFR 898.12 and ANSI/AAMI DF80:2003.
Indications for Use
Indicated for external defibrillation, synchronized cardioversion, cardiac stimulation, and ECG monitoring. Pediatric model for patients <8 years or <25 kg (max 100J). Adult model for patients >8 years or >25 kg (max 360J). Radiotransparent model for adult use during radiographic imaging.
Regulatory Classification
Identification
Low-energy DC-defibrillator: A device that delivers into a 50 ohm test load an electrical shock of a maximum of 360 joules of energy used for defibrillating (restoring normal heart rhythm) the atria or ventricles of the heart or to terminate other cardiac arrhythmias. This generic type of device includes low energy defibrillators with a maximum electrical output of less than 360 joules of energy that are used in pediatric defibrillation or in cardiac surgery. The device may either synchronize the shock with the proper phase of the electrocardiogram or may operate asynchronously. The device delivers the electrical shock through paddles placed either directly across the heart or on the surface of the body. High-energy DC-defibrillator: A device that delivers into a 50 ohm test load an electrical shock of greater than 360 joules of energy used for defibrillating the atria or ventricles of the heart or to terminate other cardiac arrhythmias. The device may either synchronize the shock with the proper phase of the electrocardiogram or may operate asynchronously. The device delivers the electrical shock through paddles placed either directly across the heart or on the surface of the body.
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Section 05
K103783 - Additional Information
Pad-type electrodes
## Submitter Information
FIAB SpA Via P. Costoli, 4 50039 Vicchio Florence - Italy
Phone: +39 055 8497916 Fax: +39 055 8497987 Contact person: Silvia Calabrò, Official Correspondent E-mail: regulatory@fiab.it
## Device name and classification
Trade name: EURO DEFI PADS series of disposable multi-function electrodes
Common name: defibrillation electrodes
Classification name: Electrode, Electrocardiograph, Multi-Function (21 CFR 870.2360, Product code MLN)
### Predicate device
Lawfully marked devices to which it is claimed equivalence:
| Trade name | 510(K) holder | 510(K) number |
|------------------------------------------------------|----------------|---------------|
| Adult Radiotranslucent Multi-function Electrodes | Heart Sync LLC | K080421 |
| Adult Radiotransparent Multi-function Electrodes | Heart Sync LLC | K080421 |
| Pediatric Radiotranslucent Multi-function Electrodes | Heart Sync LLC | K081442 |
### Device description
FIAB EURO DEFI PADS scries of disposable multi-function electrodes are made by a couple of pre-gelled self-adhesive pad-type clectrodes consisting of foam backing, laminated metallic substrate, conductive hydrogel, cabling and molded connector. The electrodes are passive devices providing the conductive interface between the defibrillator and the patient's skin. Each couple of electrodes is permanently attached with lead wires that join together in a safety connector suitable for direct connection to devices - both monophasic and biphasic of the main defibrillators brands nowadays present on the market.
The products are packaged in pairs inside water-vapor proof, heat scaled, non-transparent, aluminum/PE pouches.
FIAB EURO DEFI PADS scries of disposable multi-function clectrodes are available in the following versions: adult, adult radiotransparent, pediatric.
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Section 05
K103783 - Additional Information
Pad-type electrodes
All products are intended to be used by mcdical staff only in not-sterile environment. All disposable devices are not-sterile and for single patient use only.
## Intended use
EURO DEFI PADS series of disposable multi-function electrodes are indicated for the following clinical applications:
- external defibrillation -
- synchronized cardioversion +
- cardiac stimulation
- ﺳ ECG monitoring
EURO DEFI PADS scries of disposable multi-function electrodes provide the conductive interface between the defibrillator and the patient's skin.
These devices are available with different connectors compatible for use with different defibrillators. All devices are non-sterile and for single-use only.
The pediatric model of EURO DEFI PADS disposable multi-function electrodes is intended for use on pediatric patient under eight years of age, or weighting less than 25 kg, the device is designed to deliver a maximum of 100 joule.
The adult model of EURO DEFI PADS disposable multi-function electrodes is intended for use on adult patients and children older than eight years or greater than 25 kg, the device is designed to deliver a maximum of 360 joule.
The radio-transparcnt adult model EURO DEFI PADS disposable multi-function electrodes for adult patient use only, is well suited for certain clinical applications involving radiographic viewing.
## Comparison to predicate
Safety and effectiveness of adult version:
| COMPARISON | HEART SYNC Adult Radiotranslucent | FIAB EURO DEFI PADS |
|---------------------------------|----------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| AREAS | Electrodes (K080421) | Adult Electrodes |
| Indication for | For use as disposable electrodes on<br>external defibrillators for monitoring,<br>pacing, cardioversion and defibrillation | SAME |
| use | | |
| Where used | Hospitals and paramedic situation | SAME |
| Basic features | Radiotranslucent, non sterile, latex free,<br>single use, self adhesive, in sealed foil<br>pouch | Radiopaque, non sterile, latex<br>free, single use, self adhesive,<br>in sealed foil pouch |
| Target<br>population | Adult patients | SAME |
| Energy used<br>and/or delivered | For use on defibrillators whose output is<br>classified as low power (360 joule<br>maximum) | SAME |
| Standard met | 21 CFR 898.12 performance standard;<br>ANSI/AAMI DF80:2003 standard | SAME |
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FIAB spa - Via P. Costoli, 4 - 50039 VICCHIO - FLORENCE - ITALY ☏ +39 0558497999 - 룸 +39 0558497979 - www.fiab.it
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Section 05
K103783 - Additional Information
Pad-type electrodes
Safety and effectiveness of adult radiotransparent version:
| COMPARISON<br>AREAS | HEART SYNC Adult<br>Radiotransparent Electrodes<br>(K080421) | FIAB EURO DEFI PADS<br>Adult Radiotransparent<br>Electrodes |
|---------------------------------|----------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| Indication for<br>use | For use as disposable electrodes on<br>external defibrillators for monitoring,<br>pacing, cardioversion and defibrillation | SAME |
| Where used | Hospitals and paramedic situation | SAME |
| Basic features | Radiotransparent, non sterile, latex free,<br>single use, self adhesive, in sealed foil<br>pouch | Radiotransparent except for wire-<br>pad connection, non sterile, latex<br>free, single use, self adhesive, in<br>sealed foil pouch |
| Target<br>population | Adult patients | SAME |
| Energy used<br>and/or delivered | For use on defibrillators whose output is<br>classified as low power (360 joule<br>maximum) | SAME |
| Standard met | 21 CFR 898.12 performance standard;<br>ANSI/AAMI DF80:2003 standard | SAME |
Safety and effectiveness of pediatric version:
| COMPARISON<br>AREAS | HEART SYNC Pediatric<br>Radiotranslucent Electrodes (K081442) | FIAB EURO DEFI PADS<br>Pediatric Electrodes |
|---------------------------------|----------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| Indication for<br>use | For use as disposable electrodes on<br>external defibrillators for monitoring,<br>pacing, cardioversion and defibrillation | SAME |
| Where used | Hospitals and paramedic situation | SAME |
| Basic features | Radiotranslucent, non sterile, latex free,<br>single use, self adhesive, in sealed foil<br>pouch | Radiopaque, non sterile, latex<br>free, single use, self adhesive,<br>in sealed foil pouch |
| Target<br>population | Pediatric patients whose weight is less than<br>25 kg | SAME |
| Energy used<br>and/or delivered | Do not exceed a settings of 100 joules<br>while defibrillating | SAME |
| Standard met | 21 CFR 898.12 performance standard;<br>ANSI/AAMI DF80:2003 standard | SAME |
The products covered by this submission are substantially equivalent to other disposable multi-function electrodes, that are legally marked for this purpose. Specifically FIAB EURO DEFI PADS series of disposable multi-function electrodes are substantially equivalent to HEART SYNC clectrodes.
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Section 05
K 103783 - Additional Information
Pad-type electrodes
FIAB EURO DEFI PAD clectrodes have the same intended use as the predicate device. There are no technical differences in the design, materials, packaging, and labeling compared to the predicate. The defibrillation pads meet the standards referenced above. They are produced and tested according to all requirements to guarantee safety and effectiveness (as shown in section 17 and 18 of the submission). According to the riskbenefit analysis (ISO 14971 standards), the risk has been decemed acceptable. The performance is expected to be the same as the predicate device (see section 12 of the submission). In addition to the descriptive characteristics the following tests were performed to establish substantial equivalence:
Biocompatibility - Biocompatibility testing of all patient contacting material was performed according to ISO10993-5 for cytotoxicity and 10993-10 for irritation and delayed-type hypersensitivity. The results were reported as passing by the NAMSA organization and are congruent with the predicate device.
Component Compatibility - Compatibility testing was conducted to ensure interoperability between the FIAB Euro Defi Pads and the listed defibrillators, pacers, and monitors. This included testing of the insertion and extraction forces of the physical connectors, amount of energy delivered through the pads, and the monitoring of a simulated heartbeat
Electrical Standards - Testing was conducted to mect AAMI/ANSI standard DF80:2003. The FIAB Euro Defi Pads passed the tests related to defibrillation pads
Shelf-Life Testing - Accolerated age testing was conducted to assure a shelf life of 30 months.
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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" arranged around the perimeter. Inside the circle is a stylized image of three human figures, represented by flowing lines, suggesting a sense of unity and support.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
FIAB SpA c/o Mr. Francesco Batistini Counsellor of the Board Via Costoli, 4 50039 Vicchio Florence - Italy
JUN 1 6 291
Re: K103783
Trade Name: FIAB Euro Defi Pads Regulation Number: 21 CFR 870.5300 Regulation Name: DC-Defibrillator Regulatory Class: Class II (two) Product Code: LDD Dated: May 10, 2011 Received: May 13, 2011
Dear Mr. Batistini:
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.
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Page 2 -- Mr. Francesco Batistini
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.
W.g. Hellebaum
- Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications For Use Statement K103783 - Additional Information
Section 04
I. Life, Liberty, Happiness
Pad-type clectrodes
Indications for Use
510(K) Number: K103783
Device Name: EURO DEFI PADS series of disposable multi-function electrodes
Indications For Use:
EURO DEFI PADS series of disposable multi-function electrodes are indicated for the following clinical applications:
- external defibrillation -
- synchronized cardioversion
- cardiac stimulation
- ECG monitoring -
EURO DEFI PADS scries of disposable multi-function electrodes provide the conductive interface between the defibrillator and the patient's skin. These devices are available with different connectors compatible for use with different defibrillators. All devices are non-sterile and for single-use only.
The pediatric model of EURO DEFI PADS disposable multi-function electrodes is intended for use on pediatric patient under eight years of age, or weighting less than 25 kg, the device is designed to deliver a maximum of 100 joule.
The adult model of EURO DEFI PADS disposable multi-function electrodes is intended for use on adult patients and children older than eight years or greater than 25 kg, the device is designed to deliver a maximum of 360 joule.
The radio-transparent adult model EURO DEFI PADS disposable multi-function electrodes for adult patient use only, is well suited for certain clinical applications involving radiographic viewing.
______________________________________________________________________________________________________________________________________________________________________________ Prescription Use AND /OR (Part 21 CFR 801 Subpart D)
Over-the-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
W. A. Kilbourne
(Division Sign-Off)
Division of Cardiovascular Devices
K103783 510(k) Number
2011/05/10
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FIAB spa - Via P. Costoli, 4 - 50039 VICCHIO - FLORENCE - ITALY 密 +39 0558497999 - 黒 +39 0558497979 - www.fiab.it
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.