AMSCO V-PRO 1 LOW/PLUS/MAX TEMPERATURE STERILIZATION SYSTEM
K120632 · STERIS Corporation · MLR · Jun 26, 2012 · General Hospital
Device Facts
Record ID
K120632
Device Name
AMSCO V-PRO 1 LOW/PLUS/MAX TEMPERATURE STERILIZATION SYSTEM
Applicant
STERIS Corporation
Product Code
MLR · General Hospital
Decision Date
Jun 26, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.6860
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K120632 · Jun 26, 2012
AMSCO V-PRO 1 LOW/PLUS/MAX TEMPERATURE STERILIZATION SYSTEM
STERIS Corporation
Clinically cleaned, patient-soiled medical instruments
An 'In Use Test' was conducted using instruments retrieved from clinical settings to verify the sterilization efficacy of the V-PRO Lumen Cycle on representative patient-soiled devices.
Clinically cleaned, patient-soiled medical instruments
Not applicable for this study
Sterilization efficacy of the V-PRO Lumen Cycle
Indications for Use
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems, with VAPROX® HC Sterilant, are vaporized hydrogen peroxide sterilizers intended for use in the terminal sterilization of cleaned, rinsed and dried reusable metal and nonmetal medical devices used in healthcare facilities. The pre-programmed sterilization cycles (Lumen Cycle, Non Lumen Cycle, and Flexible Cycle) operate at low pressure and low temperature and are thus suitable for processing medical devices sensitive to heat and moisture.
Device Story
Vaporized hydrogen peroxide (VHP) sterilizer; uses VAPROX HC Sterilant to process heat/moisture-sensitive medical devices. Operates via pre-programmed cycles (Lumen, Non Lumen, Flexible) involving conditioning, sterilization, and aeration phases. Used in healthcare facilities; operated by trained personnel. Input: cleaned, rinsed, dried medical instruments in validated trays/pouches. Output: terminally sterilized devices ready for immediate use. No cool-down required. Clinical benefit: enables safe, rapid sterilization of complex, heat-sensitive surgical instruments, including endoscopes and hinged tools, without damaging materials.
Clinical Evidence
No clinical data. Evidence consists of bench testing: 1/2 cycle modified total kill endpoint verification, sterilization verification of lumen claims, double-pouch configuration testing, simulated use testing, and in-use testing with patient-soiled instruments. Biocompatibility residue analysis performed. All tests passed.
Technological Characteristics
Vaporized hydrogen peroxide sterilizer; low pressure/temperature operation. Materials: stainless steel lumen compatibility. Connectivity: standalone. Standards: EN 61010-1 (safety), EN 60601-1-2 (EMC). Sterilization: VAPROX HC Sterilant. Software: pre-programmed cycles (Lumen, Non Lumen, Flexible).
Indications for Use
Indicated for terminal sterilization of cleaned, rinsed, and dried reusable metal and nonmetal medical devices in healthcare facilities. Includes lumened/non-lumened instruments, hinged instruments (forceps/scissors), and rigid/semi-rigid/flexible endoscopes (single, dual, triple channeled) with specific lumen ID/length configurations. Contraindicated for devices not cleaned, rinsed, or dried, or those exceeding validated lumen dimensions or load weights.
Regulatory Classification
Identification
An ethylene gas sterilizer is a nonportable device intended for use by a health care provider that uses ethylene oxide (ETO) to sterilize medical products.
Amsco V-PRO® 1 Plus Low Temperature Sterilization System (K083097, K102394, K111810)
Amsco® V-PRO® maX Low Temperature Sterilization System (K102330, K112760)
Submission Summary (Full Text)
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### K120632/S001 STERIS Response to 5/10/12 Request for Additional Information Amsco® V-PRO 1 Plus and V-PRO max Low Temperature Sterilization Systems
Image /page/0/Picture/10 description: The image shows the logo for STERIS. The logo consists of the word "STERIS" in all capital letters, with a registered trademark symbol to the right of the S. Below the word STERIS is a graphic of several horizontal wavy lines stacked on top of each other.
JUN 2 6 2012
# 510(k) Summary For Amsco® V-PRO® 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems
STERIS Corporation 5960 Heisley Road Mentor, OH 44060 Phone: (440) 354-2600 Fax No: (440) 357-9198
Contact: Bill Brodbeck Senior Manager, Regulatory Affairs
Telephone: (440) 392-7690 Fax No: (440) 357-9198
Summary Date: June 5, 2012
STERIS Corporation ■ 5960 Heisley Road ■ Mentor, OH 44060-1834 USA ■ 440-354-2600
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#### 1. Device Name
| Trade Name: | Amsco® V-PRO® 1, V-PRO 1 Plus and V-PRO<br>maX Low Temperature Sterilization Systems |
|----------------------|--------------------------------------------------------------------------------------|
| Common/usual Name: | Vapor Phase Hydrogen Peroxide Sterilizer |
| Classification Name: | Sterilizer, Ethylene Oxide Gas<br>21-CFR 880.6860<br>Product Code MLR |
#### 2. Predicate Devices
Amsco® V-PRO® 1 Low Temperature Sterilization System (K062297, K102394, and K111810) Amsco V-PRO ®1 Plus Low Temperature Sterilization System (K083097, K102394, and K111810) Amsco® V-PRO® maX Low Temperature Sterilization System (K102330, K112760)
#### 3. Description of Device
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems are vaporized hydrogen peroxide sterilizers. The V-PRO Sterilizers use VAPROX® HC Sterilant to sterilize the intended devices through exposure to vaporized hydrogen peroxide (VHP). The pre-programmed V-PRO cycles all utilize a conditioning phase, a sterilization phase and an aeration phase. The packaged sterilized devices are ready for use at the completion of the cycle; no cool down or aeration period is required.
. The three V-PRO Sterilizers share common cycles as outlined in Table 5-1.
| Cycle | V-PRO 1 | V-PRO 1 Plus | V-PRO maX |
|-----------------|---------|--------------|-----------|
| Lumen Cycle | X | X | X |
| Non Lumen Cycle | * | X | X |
| Flexible Cycle | | | X |
Table 5-1: V-PRO Cvcles Provided in the V-PRO Family of Sterilizers
* Shaded cell indicates that the V-PRO Sterilizer does not include the identified cycle.
All three sterilizers contain the Lumen Cycle. The purpose of this submission is to modify the V-PRO Lumen Cycle stainless steel lumen claims. No modifications were made to the Sterilizers' hardware or software for the proposed modification to the Lumen Cycle stainless steel lumen claims.
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The accessories that have been validated for use in the three V-PRO Cvcles and the Premarket Notification submission references under which the accessories were cleared for the cycles are listed in Table 5-2.
| Accessory | Submission Reference | | |
|-------------------------------------------------|-------------------------------|-----------------------|----------------------|
| | V-PRO Lumen Cycle | V-PRO Non Lumen Cycle | V-PRO Flexible Cycle |
| Verify V24 SCBIs | K073244,<br>K090514 | K083097 | K102330 |
| Verify Vaporized<br>VH2O2 Process<br>Indicators | K091174 | K091174 | K102330 |
| V-PRO<br>Sterilization Trays | K070769,<br>K103226 | K083097,<br>K103226 | K102330,<br>K103226 |
| Vis-U-All Tyvek<br>Pouches | K070765<br>K071087<br>K090371 | K083097<br>K090371 | K102330 |
Table 5-2. Accessories Validated for Use in the V-PRO Sterilizers
#### 4. Intended Use
The purpose of this submission is to modify the V-PRO Lumen Cycle stainless steel lumen claims. No modifications are being made to the V-PRO Sterilizers' intended use with respect to the Non Lumen and Flexible Cycles.
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems, with VAPROX HC Sterilant, are vaporized hydrogen peroxide sterilizers intended for use in the terminal sterilization of cleaned, rinsed and dried reusable metal and nonmetal medical devices used in healthcare facilities. The pre-programmed sterilization cycles (Lumen Cycle, Non Lumen Cycle, and Flexible Cycle) operate at low pressure and low temperature and are thus suitable for processing medical devices sensitive to heat and moisture.
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems' Lumen Cycle, the subject of this submission, can sterilize:2
- Lumened and non-lumened instruments with diffusion-restricted spaces . such as the hinged portion of forceps and scissors
- . Medical devices, including single, dual and triple channeled rigid and semi-rigid endoscopes, with the following configurations: 4
- o single channeled devices with a stainless lumen that is ≥ 0.77 mm internal diameter (ID) and ≤ 500 mm in length
- dual channeled devices with stainless steel lumens that are ≥ 0.77 O mm ID and ≤ 527 mm in length
{3}------------------------------------------------
### K120632/S001 STERIS Response to 5/10/12 Request for Additional Information Amsco® V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems
- triple channeled devices with stainless steel lumens that are either o ■ > 1.2 mm ID and < 310 mm in length
or
- ≥ 2.8 mm ID and ≤ 317 mm in length
- a The validation studies were conducted using a maximum of twenty (20) lumens per load. Hospital loads should not exceed the maximum number of lumens validated by this testing. The validation studies were performed using a validation load consisting of two instrument trays and two pouches for a total weight of 19.65 lbs.
The Amsco V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems' Non Lumen Cycle, cleared under K083097, K102394 and K111810, can sterilize:b
Non-lumened instruments including non-lumened rigid, semi-rigid and flexible endoscopes and non-lumened instruments with stainless steel diffusion-restricted areas such as the hinged portion of forceps or scissors.
- The validation studies were conducted using a validation load consisting of two instrument trays and two pouches for a total weight of 19.65 Ibs.
The Amsco V-PRO maX Low Temperature Sterilization System's Flexible Cycle, cleared under K102330 and K112760, can sterilize single or dual lumen surgical' flexible endoscopes (such as those used in ENT, Urology and Surgical Care) and bronchoscopes in either of two load configurations:
- l . Two flexible endoscopes with a light cord (if not integral to endoscope) and mat with no additional load. 6
The flexible endoscopes may contain either:
- · a single lumen that is > 1 mm ID and < 1050 mm in length
- · or two lumens with:
- o one lumen that is > 1 mm ID and < 998 mm in length
- o and the other lumen that is ≥ 1 mm ID and ≤ 850 mm in length
- C The validation studies were conducted with two flexible endoscopes, each packaged into a tray with silicone mat and light cord (if not integral to endoscope).
- 2. One flexible endoscope with a light cord (if not integral to endoscope) and mat and additional non-lumened instruments including instruments with diffusion-restricted areas such as the hinged portion of forceps or · scissors. "
The flexible endoscope can contain either:
- · a single lumen that is ≥ 1 mm ID and ≤ 1050 mm in length
- or two lumens with:
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- o one lumen that is ≥ 1 mm ID and ≤ 998 mm in length o and the other lumen that is > 1 mm and < 850 mm in length
-
- d The validation studies were conducted with a flexible endoscope in a tray with silicone mat and light cord (if not integral to endoscope). Also included in the load were an additional instrument tray and one pouch for a total load weight of 24.0 Ibs.
#### 5. Summary of Nonclinical Tests
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems have the same or similar intended use and the same technological characteristics as compared to the predicate devices. Performance testing to assess and demonstrate substantial equivalence to the predicates is summarized below.
| Test | Result | Conclusion |
|------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| 1/2 Cycle Modified<br>Total Kill Endpoint<br>Verification | Modified total kill end point analysis was<br>demonstrated. The standard injection weight of 2.1<br>g and a lower injection weight of 1.457 g resulted<br>in all sterile results for the Lumen Cycle modified<br>stainless steel lumen claims. All survival results<br>were shown at the lowest weight evaluated<br>(0.121 g). Partial positives results were seen at the<br>intermediate injection weights. | PASS |
| 1/2 Cycle Sterilization<br>Verification of<br>Lumen Claims | The V-PRO Lumen Cycle reproducibly sterilizes<br>the modified stainless steel lumen claims under<br>worst case conditions in a V-PRO Lumen 1/2 Cycle. | PASS |
| 1/2 Cycle Sterilization<br>Verification of<br>Double Pouched<br>Lumens | The V-PRO Lumen Cycle reproducibly sterilizes<br>the modified stainless steel lumen claims under<br>worst case conditions in a V-PRO Lumen 1/2 Cycle<br>in a double pouched configuration. | PASS |
| Simulated Use Test | Simulated use testing verified the ability of the<br>V-PRO Lumen Cycle to sterilize the modified<br>stainless steel lumen claims under worst case<br>processing conditions. | PASS |
| In Use Test | The in use investigation demonstrated the ability of<br>the V-PRO Lumen Cycle to sterilize clinically<br>cleaned, patient-soiled medical instruments<br>representative of the modified stainless steel lumen<br>claims. | PASS |
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### K120632/S001 STERIS Response to 5/10/12 Request for Additional Information Amsco V-PRO 1 Plus and V-PRO max Low Temperature Sterilization Systems
| Test | Result | Conclusion |
|---------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Biocompatibility | Residue analysis evaluation has demonstrated<br>biocompatibility after processing in the V-PRO<br>Lumen Cycle. | PASS |
| Validation of Accessories for use with the V-PRO Lumen Cycle Modified Lumen<br>Claims | | |
| V-PRO Sterilization<br>Trays | The modified stainless lumens claims were<br>successfully sterilized in the V-PRO Sterilization<br>Trays under Lumen ½ cycle worst case conditions. | PASS |
| Vis-U-All Tyvek<br>Pouches | The modified stainless lumens claims were<br>successfully sterilized in the Vis-U-All Tyvek<br>Pouches under ½ cycle worst case conditions. | PASS |
The Amsco V-PRO Low Temperature Sterilization Systems have been tested for conformity and are certified to the following standards:
- . EN 61010-1:2001 Safety requirements for electrical equipment for measurement, control and laboratory use. General requirements; Part 1: General Requirements
- EN 60601-1-2:2002 Medical electrical equipment. General requirements for safety. Collateral standard. Electromagnetic compatibility. Requirements and tests. . .
#### 6. Conclusion
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems have been validated to meet the established performance criteria. The results of the Amsco V-PRO Low Temperature Sterilization System verification studies demonstrate that the Lumen Cycle performs as intended and the proposed device is substantially equivalent to the predicate devices.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/6/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three stripes representing the department's three main goals: health, human services, and well-being. The eagle is encircled by the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" in a circular arrangement.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Bill Brodbeck, Ph.D. Senior Manager, Regulatory Affairs STERIS Corporation 5960 Heisley Road Mentor, Ohio 44060
JUN 2 6 2012
Re: K120632
Trade/Device Name: Amsco® V-PRO® 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems Regulation Number: 21 CFR 880.6860 Regulation Name: Ethylene Oxide Gas Sterilizer Regulatory Class: II Product Code: MLR Dated: June 5, 2012 Received: June 6, 2012
Dear Dr. Brodbeck:
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.
{7}------------------------------------------------
### Page 2 - Dr. Brodbeck
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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
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
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# Indications for Use
510(k) Number (if known): K120632
Device Name:
### Amsco® V-PRO® 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems
Indications For Use:
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems, with VAPROX® HC Sterilant, are vaporized hydrogen peroxide sterilizers intended for use in the terminal sterilization of cleaned, rinsed and dried reusable metal and nonmetal medical devices used in healthcare facilities. The pre-programmed sterilization cycles (Lumen Cycle, Non Lumen Cycle, and Flexible Cycle) operate at low pressure and low temperature and are thus suitable for processing medical devices sensitive to heat and moisture.
The Amsco V-PRO 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems' Lumen Cycle, the subject of this submission, can sterilize:4
- Lumened and non-lumened instruments with diffusion-restricted spaces . such as the hinged portion of forceps and scissors
- Medical devices, including single, dual and triple channeled rigid and . semi-rigid endoscopes, with the following configurations: 4
- single channeled devices with a stainless lumen that is ≥ 0.77 mm 0 internal diameter (ID) and ≤ 500 mm in length
- dual channeled devices with stainless steel lumens that are ≥ 0.77 0 mm ID and ≤ 527 mm in length
- triple channeled devices with stainless steel lumens that are either o
- ≥ 1.2 mm ID and ≤ 310 mm in length
or
- ≥2.8 mm ID and ≤ 317 mm in length
- a The validation studies were conducted using a maximum of twenty (20) lumens per load. Hospital loads should not exceed the maximum number of lumens validated by this testing. The validation studies were performed using a validation load consisting of two instrument trays and two pouches for a total weight of 19.65 Ibs.
Page 1 of 3
{9}------------------------------------------------
The Amsco V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems' Non Lumen Cycle, cleared under K083097, K102394, and K111810, can sterilize: 8
Non-lumened instruments including non-lumened rigid, semi-rigid and flexible endoscopes and non-lumened instruments with stainless steel diffusion-restricted areas such as the hinged portion of forceps or scissors.
- b The validation studies were conducted using a validation load consisting of two instrument trays and two pouches for a total weight of 19.65 lbs.
The Amsco V-PRO maX Low Temperature Sterilization System's Flexible Cycle, cleared under K102330 and K112760, can sterilize single or dual lumen surgical flexible endoscopes (such as those used in ENT, Urology and Surgical Care) and bronchoscopes in either of two load configurations:
- 1. Two flexible endoscopes with a light cord (if not integral to endoscope) and mat with no additional load.6
The flexible endoscopes may contain either:
- . a single lumen that is ≥ 1 mm ID and ≤ 1050 mm in length
- or two lumens with: .
- . one lumen that is ≥ 1 mm ID and ≤ 998 mm in length
- and the other lumen that is > 1 mm ID and < 850 mm in length .
- C The validation studies were conducted with two flexible endoscopes, each packaged into a tray with silicone mat and light cord (if not integral to endoscope).
- 2. One flexible endoscope with a light cord (if not integral to endoscope) and mat and additional non-lumened instruments including instruments with diffusion-restricted areas such as the hinged portion of forceps or scissors. 9
The flexible endoscope can contain either:
- a single lumen that is > 1 mm ID and < 1050 mm in length .
- . or two lumens with:
- one lumen that is ≥ 1 mm ID and ≤ 998 mm in length .
- and the other lumen that is > 1 mm and < 850 mm in length .
- d The validation studies were conducted with a flexible endoscope in a tray with silicone mat and light cord (if not integral to endoscope). Also included in the load were an additional instrument tray and one pouch for a total load weight of 24.0 lbs.
Page 2 of 3
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### K120632/S001 STERIS Response to 5/10/12 Request for Additional Information Amsco® V-PRO® 1, V-PRO 1 Plus and V-PRO maX Low Temperature Sterilization Systems
| Sterilization<br>Cycle | Sterilant<br>injection<br>(g) | # of<br>Injections | Sterilant<br>Exposure<br>Time (min) | Chamber<br>Pressure<br>Prior to<br>Injection<br>(Torr) | Chamber/<br>Vaporizer<br>Temperature<br>(°C) |
|------------------------|-------------------------------|--------------------|-------------------------------------|--------------------------------------------------------|----------------------------------------------|
| Lumen | 2.1 | 4 | 32 | 0.4 | 50/60 |
| Non Lumen | 2.1 | 4 | 12 | 1 | 50/60 |
| Flexible | 2.1 | 4 | 12 | 0.4 | 50/60 |
The parameters for the three V-PRO Cycles are as follows:
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use X (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)
La ocw
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
. .
510(k) Number: K120632
Page 3 of 3
. .
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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.