K121532 · Hemosphere, Inc. · DSY · Jun 22, 2012 · Cardiovascular
Device Facts
Record ID
K121532
Device Name
HERO GRAFT
Applicant
Hemosphere, Inc.
Product Code
DSY · Cardiovascular
Decision Date
Jun 22, 2012
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.3450
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The HeRO Graft is intended for use in maintaining long-term vascular access for chronic hemodialysis patients who have exhausted peripheral venous access sites suitable for fistulas or grafts.
Device Story
HeRO Graft is a synthetic vascular access prosthesis for chronic hemodialysis; consists of three components: Arterial Graft Component (ePTFE graft with titanium connector), Venous Outflow Component (radiopaque silicone with braided reinforcing filaments), and Accessory Component Kit. During surgery, surgeon sizes Venous Outflow Component by cutting to length and sliding over connector barbs. Device provides long-term access for patients who have exhausted peripheral venous sites. Implanted by surgeons; provides durable outflow to maintain hemodialysis access; benefits patients by reducing reliance on catheters and improving dialysis clearance.
Clinical Evidence
No clinical data was required to support this modification. Substantial equivalence is supported by design verification testing.
Indicated for end stage renal disease patients on hemodialysis who have exhausted all other access options, including those who are catheter-dependent or approaching catheter-dependency, are not candidates for upper extremity fistulas/grafts due to poor venous outflow, are failing existing fistulas/grafts, have poor remaining venous access sites, have compromised central venous systems or central venous stenosis, or are receiving inadequate dialysis clearance via catheters.
Regulatory Classification
Identification
A vascular graft prosthesis is an implanted device intended to repair, replace, or bypass sections of native or artificial vessels, excluding coronary or cerebral vasculature, and to provide vascular access. It is commonly constructed of materials such as polyethylene terephthalate and polytetrafluoroethylene, and it may be coated with a biological coating, such as albumin or collagen, or a synthetic coating, such as silicone. The graft structure itself is not made of materials of animal origin, including human umbilical cords.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Guidance Document for Vascular Prostheses 510(k) Submissions.”
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K121532
# 510(k) Summary · (per 21 CFR 807.87(h))
JUN 2 2 2012
| Common/Usual Name: | Vascular Graft Prosthesis |
|----------------------|------------------------------------------------------------------------------------|
| Product Trade Name: | HeRO® Graft |
| Classification Name: | 21 CFR 870.3450; Vascular graft prosthesis; Class<br>II; DSY, LJS, MSD, Cardiology |
| Predicate Device: | K071778, K091491 HeRO™ Vascular Access Device<br>K120006 HeRO® Graft |
| Manufacturer: | Hemosphere, Inc.<br>6545 City West Parkway<br>Eden Prairie, MN 55344 |
Contact:
Laurie E. Lynch, Ph.D. Director QA/RA/R&D
Date Prepared:
May 11, 2012
## Device Description:
The HeRO Graft is a non-autogenous (i.e., synthetic) vascular graft prosthesis composed of three components: Arterial Graft Component, Venous Outflow Component and Accessory Component Kit. The Venous Outflow Component is made of radiopaque silicone and contains reinforcing braided filaments that impart kink and crush resistance. During surgery, the Venous Outflow Component is sized to fit the patient by cutting it to the proper length and sliding it over the barbs of the connector on the Arterial Graft Component. The Arterial Graft Component is a conventional ePTFE hemodialysis graft that has been attached to a titanium connector. The Accessory Component Kit (a convenience kit) contains instruments that assist in the implantation of the HeRO Graft.
#### Intended Use:
The HeRO Graft is intended for use in maintaining long-term vascular access for chronic hemodialysis patients who have exhausted peripheral venous access sites suitable for fistulas or grafts.
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## Indications for Use:
The HeRO Graft is indicated for end stage renal disease patients on hemodialysis who have exhausted all other access options. These catheter-dependent patients are readily identified using the KDOQI guidelines' as patients who:
- . Have become catheter-dependent or who are approaching catheter-dependency (i.e.. have exhausted all other access options, such as arteriovenous fistulas and grafts).
- Are not candidates for upper extremity fistulas or grafts due to poor venous outflow as . determined by a history of previous access failures or venography.
- Are failing fistulas or grafts due to poor venous outflow as determined by access failure . or venography (e.g. fistula/graft salvage).
- Have poor remaining venous access sites for creation of a fistula or graft as determined . by ultrasound or venography.
- Have a compromised central venous system or central venous stenosis (CVS) as . determined by history or previous access failures, symptomatic CVS (i.e., via arm, neck, or face swelling) or venography.
- . Are receiving inadequate dialysis clearance (i.e., low Kt/V) via catheters. KDOQI guidelines recommend a minimum Kt/V of 1.4.2
### Substantial Equivalence Comparison:
The predicate device is the GRAFTcath, Inc. HeRO Vascular Access Device, K071778, K091491 and K120006. The company name has been changed from GRAFTcath, Inc. to Hemosphere, Inc. and the product name has been changed from HeRO Vascular Access Device to HeRO Graft.
Results of design verification testing demonstrate that the device system as modified is as safe as the predicate device. The risk assessment results, together with the results of design verification testing presented in this submission, confirm that the HeRO Graft, as modified, raises no new questions of safety or effectiveness compared to the predicate device. The HeRO Graft has been shown to be substantially equivalent to the legally marketed device for the purpose of 510(k) clearance.
## Summary of Non-Clinical & Clinical Performance Data:
No changes were made to the previously cleared packaging verification and sterilization validation. Additional clinical performance data was not required to support the modification of the device.
<sup>1</sup> Vascular Access Work Group. National Kidney Foundation KDOQI clinical practice quidelines for vascular access. Guideline 1: patient preparation for permanent hemodialysis access. Am J Kidney Dis 2006,48(1Suppl1):S188-91. 4 Hemodialysis Adequacy 2006 Work Group. National Kidney Foundation KDOQI clinical practice quidelines for hemodialysis adequacy, update 2006. Am J Kidney Dis 2006:48(Suppl 1):S2-S90.
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Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo features a stylized eagle with three swooping lines representing its wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Hemosphere, Inc. c/o Laurie E. Lynch, Ph.D. Director, QA/RA/R&D 6545 City West Parkway Eden Prairie, MN 55344
JUN 2 2 2012
Re: K121532
Trade/Device Name: HeRO® Graft Regulation Number: 21 CFR 870.3450 Regulation Name: Vascular Graft Prosthesis Regulatory Class: Class II Product Code: DSY Dated: May 23, 2012 Received: May 24, 2012
Dear Dr. Lynch:
We have reviewed your Section 510(k) premarket notification of intent to market the indication We have reviewed your Section 310(k) prematic is substantially equivalent (for the indications
referenced above and have determined the device is substanterled in interstate referenced above and have determined the devices marketed in interstate
for use stated in the enclosure) to legally marketed president Device, mendments. for use stated in the enclosure) to regary market of the Medical Device Amendments, or to
commerce prior to May 28, 1976, the enactment of the Medical Device American Food. D commerce prior to May 28, 1976, the elacultien and of the Federal Food. Drug, devices that have been reclassified in accordance was assessmoval application (PMA).
and Cosmetic Act (Act) that do not require approval assuresisions of the Act. The and Cosmetic Act (Act) that do not require approvate of the general controls provisions of the Act. The Act. The You may, therefore, market the device, subject of the general or annual registration, listing of
general controls provisions of the Act include requirements for annual regist general controls provisions of the Accurations against misbranding and devices, good manufacturing practice, rademig, and promonone related to contract liability.
adulteration. Please note: CDRH doesh or evaluate information related to adulteration. Please note: CDKFI does not evaluate international
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
and be If your device is classified (see and on into cince of (spinss affecting your device can be
may be subject to additional controls. Existing major regulations affecting your may be subject to additional controls. Exismig major regarators and man and more of the may
found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In additio found in the Code of Federal Regulations, This Beyone in the Federal Register.
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
ts of the Active that the start of the complies with other requirements of the Please be advised that FDA's issuance of a substance of the requirements of the Act
that FDA has made a determination that your device complies with of the Act that FDA has made a determination una your areas by other Federal agencies. You must
or any Federal statutes and regulations administered by other Federal on and listin or any Federal statutes and regulations and limited to: registration and listing (21
comply with all the Act's requirements, including, but not limited to registration of med comply with all the Act's requirements, micruding, out not minted on region
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical
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Page 2 - Laurie E. Lynch, Ph.D.
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/CDRH0ffices/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 youns.
Sincerely yours,
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
Current 510(k) Number: K121532
Device Name:
HeRO® Graft
#### Indications for Use:
The HeRO® Graft is indicated for end stage renal disease patients on hemodialysis who have exhausted all other access options. These catheter-dependent patients are readily identified using the KDOQI guidelines1 as patients who:
- Have become catheter-dependent or who are approaching catheter-dependency (i.e., have exhausted all other access options, such as arteriovenous fistulas and grafts).
- Are not candidates for upper extremity fistulas or grafts due to poor venous outflow as determined by a history of previous access failures or venography.
- Are failing fistulas or grafts due to poor venous outflow as determined by access failure or venography (e.g. fistula/graft salvage).
- Have poor remaining venous access sites for creation of a fistula or graft as determined . by ultrasound or venography.
- Have a compromised central venous system or central venous stenosis (CVS) as . determined by history or previous access failures, symptomatic CVS (i.e., via arm, neck, or face swelling) or venography.
- Are receiving inadequate dialysis clearance (i.e., low Kt/V) via catheters. KDOQI . guidelines recommend a minimum Kt/V of 1.4.2
Vascular Access Work Group. National Kidney Foundation KDOQ! clinical practice guidelines for vascular access. Guideline 1: patient preparation for permanent hemodialysis access. Am J Kidney Dis 2006;48(1Suppl1):S188-91. 2 Hemodialysis Adequacy 2006 Work Group. National Kidney Foundation KDOQI clinical practice guidelines for hemodialysis adequacy, update 2006. Am J Kidney Dis 2006;48(Suppl 1):S2-S90.
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 IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Divi
Division cardioprcular Devices
510(k) Number K121532
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.