TERUMO SURGUARD3 SAFETY NEEDLE & HYPODERMIC SYRINGE WITH SAFETY NEEDLE
K122249 · Terumo (Philippines) Corporation · FMI · Aug 28, 2012 · General Hospital
Device Facts
Record ID
K122249
Device Name
TERUMO SURGUARD3 SAFETY NEEDLE & HYPODERMIC SYRINGE WITH SAFETY NEEDLE
Applicant
Terumo (Philippines) Corporation
Product Code
FMI · General Hospital
Decision Date
Aug 28, 2012
Decision
SESE
Submission Type
Special
Regulation
21 CFR 880.5570
Device Class
Class 2
Indications for Use
The TERUMO® SurGuard®3 Safety Needle device is intended for use in the aspiration and injection of fluids for medical purposes. The TERUMO SurGuard®3 Safety Needle is compatible for use with standard luer slip and luer lock syringes. Additionally, after withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.
Device Story
Hypodermic needle with integrated hinged safety sheath; available as standalone needle or pre-attached to syringe (1cc, 3cc, 5cc, 10cc). Operated manually by healthcare practitioners; sheath activated via finger, thumb, or surface pressure post-injection. Locking mechanism (tooth-cannula and sheath-collar) secures needle within sheath to prevent sharps injury. Finger guide area with ramp and stoppers ensures safe activation. Sterilized via electron beam. Used in clinical settings for fluid aspiration/injection. Benefits include reduced risk of accidental needlestick injuries for clinicians.
Clinical Evidence
Bench testing only. Simulated use study conducted in a clinical environment with healthcare workers of varied experience levels confirmed safe and effective activation of the safety feature per instructions. Functional performance testing (sheath activation, deactivation, radial, retraction, puncture, etc.) and shelf-life testing (ASTM F-1980) met all acceptance criteria. Biocompatibility established via predicate (K113422) per ISO 10993.
Technological Characteristics
Hypodermic needle with hinged safety sheath. Materials: Polystyrene (1cc plunger), Polypropylene (3, 5, 10cc plungers). Standards: ISO 23908 (sharps protection), ISO 7886-1 (syringes), ISO 594-1 (fittings), ISO 6009 (color coding), ISO 7864 (needles). Sterilization: Electron beam (SAL 10^-6). Manual operation; no software or electronics.
Indications for Use
Indicated for aspiration and injection of fluids for medical purposes in patients requiring hypodermic needle use. Compatible with standard luer slip and luer lock syringes. Includes integrated safety shield to minimize accidental needlestick risk post-withdrawal.
Regulatory Classification
Identification
A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.
{0}------------------------------------------------
K1224'9
page 1 of 10
AUG 2 8 2012
## 510(k) SUMMARY
| Manufacturer/Owner | : TERUMO (PHILIPPINES) CORPORATION<br>124 East Main Avenue, Laguna Technopark,<br>Biñan, Laguna, Philippines |
|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Prepared by | : Ma. Cristina Faderagao – Supervisor Regulatory Affairs<br>Tel. (+63) 49 541 2111<br>Fax (+63) 49 541 2121 : |
| Date prepared | : June 22, 2012 |
| Contact person | : Phillip Michael Lester<br>Regulatory Affairs Specialist<br>Terumo Medical Corporation<br>950 Elkton Boulevard<br>Elkton, MD 21921<br>Phone #: (410) 392-7321<br>Fax #: (410) 398-6079 |
E-mail: philmichael.lester@terumomedical.com
··
.
・ ・・
.
.
·
14
·
:
{1}------------------------------------------------
K122249
## A. DEVICE NAME
## Proprietary Name
TERUMO® SurGuard®3 Safety Hypodermic Needle TERUMO® SurGuard®3 Hypodermic Syringe with Safety Needle
## Classification Name
Hypodermic Single Lumen Needle (880.5570) with antistick
Product Code: 80FMI / 80MEG
Classification: Class II
## Common Name
Hypodermic Needle with Safety Sheath or Needle with needle protection device.
#### B. INTENDED USE
The Terumo SurGuard®3 Safety Hypodermic Needle device is intended for use in the aspiration and injection of fluids for medical purposes. The Terumo SurGuard 3 Safety Needle is compatible for use with standard luer slip and luer lock syringes.
Additionally, after withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.
Note: This is the same intended use as the predicate device, Terumo SurGuard®3 Safety Hypodermic Needle.
## C. DEVICE DESCRIPTION
The Terumo SurGuard 3 Safety Hypodermic Needle consists of a hypodermic needle with a hinged safety sheath attached to the connector hub with or without an attached hypodermic syringe. This device features a hinged safety sheath attached to the needle hub. The safety sheath contains two locking mechanisms, the tooth-cannula and sheath-collar which are simultaneously activated when
{2}------------------------------------------------
K12249
> manually pressed over the needle immediately after use and just prior to disposal to minimize the possibility of sharps injury. The safety sheath is activated with a one-handed operation by pressing the sheath either by finger, thumb or surface activation.
> The safety sheath has a finger guide area consisting of a circular dent (for thumb activation) and ramp (for finger activation) which gives the user a concrete confirmation that the user's finger is in the appropriate position in performing the activation. The ramp has steps to provide strong grasp when activating the sheath, There are two stoppers located at the end of the circular dent and ramp which prevent the user's finger from going towards the cannula during activation. Another method of activation is by manually pressing the safety sheath over the needle using a firm surface.
> The locking mechanisms are positioned within the center and proximal end of the sheath. The hinge feature allows the medical practitioner to flexibly adjust the sheath to its desired position for use.
> The Terumo SurGuard 3 Safety Hypodermic Needle will be individually packaged and sterilized by electron beam as a safety needle only or as a safety needle with attached Terumo syringe.
#### D. SUBSTANTIAL EQUIVALENCE
The Terumo SurGuard®3 Safety Hypodermic Needle and with attached syringe submitted in this 510(k) and manufactured by Terumo (Philippines) Corporation is substantially equivalent to:
- 1. K113422 TERUMO® SurGuard® 3 Safety Hypodermic Needle with or without syringe manufactured by Terumo (Philippines) Corporation.
## E. SUMMARY OF TECHNOLOGICAL CHARACTERISTICS
### Principle of Operation and Technology
The Terumo SurGuard 3 Safety Hypodermic Needle device with and without syringe manufactured by Terumo (Philippines) Corporation, subject of this 510(k), and the predicate devices covered under K113422 are operated manually.
ા ર
{3}------------------------------------------------
K122249
page 4 of 10
#### Materials
All materials for the Terumo SurGuard®3 Safety Hypodermic Needle and with attached syringe are the same as the materials of the SurGuard3 as submitted in the 510(k), K113422. The 1 cc/ml syringe plunger is made up of polystyrene, while the 3, 5, and 10 cc/ml syringes utilize polypropylene for the plunger; however, both polystyrene and polypropylene were cleared for use in the plunger under K113422.
#### Specifications
The new needle gauge sizes to be added under this 510(k) are 26G, 27G, 30G and the new needle lengths are 3/8", 5/8", and 1/2". The syringe size to be added is 1cc/ml, as K113422 only provided for 3, 5, and 10 cc/ml syringe and needle combinations. This submission also provides for new needle gauge and length combinations for 23G and 25G needles and 1" needle length which were cleared under K113422. Finally, this submission includes the shorter safety sheath with modified design for all new gauge and needle length combinations.
The proposed Terumo SurGuard®3 Safety Hypodermic Needle comes with a shorter safety sheath. The inside rib design of the sheath was modified, specifically extending rib 2 towards the inside wall of the sheath and modifying rib 3 to be symmetrical. This design allows the cannula to slide towards the center of the sheath during the activation.
For further clarification of the reason for this submission and differences from the previous 510(k), Tables 1 and 2 on the following page are included here. Table 1 shows the needle gauges x needle length combinations both new for this submission and those cleared under previous 510(k), K113422. Table 2 demonstrates gauge and needle length combinations and the syringe size specific to each needle gauge x needle length. "X" demonstrates clearance under previous 510(k), K113422, while items new for this submission are denoted by "New."
{4}------------------------------------------------
K122244
page
ਸਿੰ
. .
.
ా
്ര
Terumo (Philippines) Corporation
SurGiaard3 Safety Needle
Special 510k
Section II 510k
Section II 510(k) Summary
| TABLE 1 | | Needle Length | | | | | |
|---------|-----|---------------|--------|--------|--------|--------|--------|
| | | 3/8" | יי2/1 | 5/8" | ] ** | 1 1/2" | 2" |
| | | (9mm) | (13mm) | (16mm) | (25mm) | (38mm) | (51mm) |
| | 18G | | | | X | X | |
| | 19G | | | | X | X | |
| | 20G | | | | X | X | X |
| | 21G | | | | X | X | |
| Gauge | 22G | | | | X | X | |
| Size | 23G | | | | New | X | |
| | 25G | | | New | New | X | |
| | 26G | New | New | | | | |
| | 27G | | New | | | | |
| | 30G | | New | | | | |
## Table 1 – Needle Gauges x Needle Length
## Table 2 - Needle Length and Gauge x Syringe
| TABLE 2 | | | Syringe Size | | | |
|---------------------------------|------------|---------|--------------|---------|----------|--|
| | | 1 cc/ml | 3 cc/ml | 5 cc/ml | 10 cc/ml | |
| Needle Gauge x<br>Needle Length | 18G x 1" | | | | | |
| | 18G x 1 ½" | | | | | |
| | 19G x 1" | | | | | |
| | 19G x 1 ½" | | | | | |
| | 20G x 1" | | X | X | X | |
| | 20G x 1 ½" | | X | X | X | |
| | 20G x 2" | | | | | |
| | 21G x 1" | | X | | X | |
| | 21G x 1 ½" | | X | X | | |
| | 22G x 1" | | X | | | |
| | 22G x 1 ½" | | X | | | |
| | 23G x 1" | | New | | | |
| | 23G x 1 ½" | | | | | |
| | 25G x 5/8" | New | New | | | |
| | 25G x 1" | | New | | | |
| | 25G x 1 ½" | | | | | |
| | 26G x 3/8" | New | | | | |
.
{5}------------------------------------------------
| TABLE 2 | | Syringe Size | | | |
|---------------------------------|----------|--------------|---------|---------|----------|
| | | 1 cc/ml | 3 cc/ml | 5 cc/ml | 10 cc/ml |
| Needle Gauge x<br>Needle Length | 26G x ½" | | | | |
| | 27G x ½" | New | | | |
| | 30G x ½" | | | | |
1777499
ਹੰਦਿ
IO
The above cleared devices (indicated as "X") serve as predicate for the devices that are subject of this 510(k). '
| Product Code | Description |
|--------------|------------------------------------------------------------------------|
| SG3-2325 | 23gauge x 1" (25mm) safety hypodermic needle |
| SG3-2516 | 25gauge x 5/8" (16mm) safety hypodermic<br>needle |
| SG3-2525 | 25gauge x 1" (25mm) safety hypodermic needle |
| SG3-2609 | 26gauge x 3/8" (9mm) safety hypodermic needle |
| SG3-2613 | 26gauge x 1/2" (13mm) safety hypodermic<br>needle |
| SG3-2713 | 27gauge x 1/2" (13mm) safety hypodermic<br>needle |
| SG3-3013 | 30 gauge x 1/2" (13mm) safety hypodermic<br>needle |
| SG3-01T2516 | 25gauge x 5/8" (16mm) safety hypodermic<br>needle, with 1cc/ml syringe |
| SG3-01T2609 | 26gauge x 3/8" (9mm) safety hypodermic needle,<br>with 1cc/ml syringe |
| SG3-01T2713 | 27gauge x 1/2" (13mm) safety hypodermic<br>needle, with 1cc/ml syringe |
| SG3-03L2325 | 23gauge x 1" (25mm) safety hypodermic needle,<br>with 3cc/ml syringe |
| SG3-03L2516 | 25gauge x 5/8" (16mm) safety hypodermic<br>needle with 3cc/ml syringe |
| SG3-03L2525 | 25gauge x 1" (25mm) safety hypodermic needle<br>with 3cc/ml syringe |
## Specifications for product proposed in this 510(k)
{6}------------------------------------------------
#### Performance
The following tests were performed on the Terumo SurGuard®3 Safety Hypodermic Needle and with attached syringe.
#### Performance Testing
These tests were performed on both predicate device K113422 and the proposed device:
- . Sheath Activation
- Sheath Deactivation .
- Sheath Removal �
- Sheath Radial .
- Sheath Retraction .
- Protector Fitting .
- Collar removal .
- Sheath Puncture �
- Adhesive Hold .
- Needle Penetration �
- Manual Sheath Activation
- -Finger Activation
- Thumb Activation -
- Surface Activation .
- Measurement Testing .
- Manual Sheath Activation by analytical balance .
- . Simulated Use Study
This study was performed to confirm that the safety feature of the proposed device can be safely activated by following the Instructions For Use of the device. The study was conducted in a simulated clinical environment and the safety feature activation was performed by healthcare workers with varied amounts of experience. It was concluded that the proposed Terumo SurGuard 3 Safety Hypodermic Needle met its intended use, and the Instructions for Use were adequate for safe and effective activation of the safety feature.
Results of the verification testing performed on both the predicate device and the proposed device met the acceptance criteria of the functional performance tests of both devices.
20
{7}------------------------------------------------
## Shelf Life Testing
Shelf life tests both on the predicate device (K113422) and the proposed Terumo SurGuard 3 Safety Hypodermic Needle and with attached syringe (1cc/ml) were performed using accelerated aged samples to simulate a 5-year (60 months) shelf life for this 510(k) submission. The accelerated aging condition was performed in accordance with ASTM F-1980.
- Sheath Activation .
- Sheath Deactivation .
- Sheath Removal .
- . Sheath Radial
- . Sheath Retraction
- Protector Fitting .
- . Collar removal
- Sheath Puncture .
- Adhesive Hold .
- Needle Penetration .
- Manual Sheath Activation
- Finger Activation -
- Thumb Activation
- Surface Activation -
- . Package Seal Strength
Results of verification testing indicated that the functional performance of the proposed Terumo SurGuard®3 Safety Hypodermic Needle and with attached syringe (1cc/ml) is acceptable throughout a 5-year (60months) shelf life. The shelf-life will be confirmed with real time testing.
## Biocompatibility Testing
Biocompatibility was established for the Terumo SurGuard®3 Safety Hypodermic Needle manufactured by Terumo (Philippines) Corporation (K113422) which is comprised of blood contacting materials identical to the Terumo SurGuard®3 Safety Hypodermic Needle (26G, 27G and 30G) and with attached syringe (1cc/ml) device. No changes have been made since 510(k) clearance that would require re-testing; therefore, biocompatibility established under K113422 is still applicable.
{8}------------------------------------------------
> The Terumo SurGuard®3 Safety Hypodermic Needle is classified as Externally Communicating Device, Circulating Blood, Limited Duration of Contact (≤24hr.). The device's blood contacting materials were tested in accordance with the tests recommended in the FDA General Program Memorandum #G95-1 (5/1/95): Use of International Standard ISO - 10993, "Biological Evaluation of Medical Devices part 1: Evaluation and Testing". Results of the testing demonstrate that the blood contacting materials are biocompatible.
None of the data raises any new issues of safety and effectiveness.
#### Product Risk Analysis
Additionally a product risk analysis was conducted and there were no new issues of safety and effectiveness.
Conclusion: The performance of the TERUMO SurGuard®3 Safety Needle submitted in this 510(k) is substantially equivalent in intended use, design, technology/principles of operation, materials and performance to the legally marketed predicate devices. The proposed devices perform as well as the predicate devices.
## F. COMPARISON TO STANDARDS
The Terumo SurGuard®3 Safety Hypodermic Needle complies with the requirements specified in the following standards:
- ISO 23908:2011 Sharps Injury Protection, requirements and test methods . - sharps protection features for single hypodermic needles, introducers for catheters, and needles used for blood sampling
- ISO 7886-1:1993 Sterile Hypodermic Syringes for Single Use .
- ISO 594-1:1986 Conical Fittings with a 6% taper on syringes, needles, . and certain other medical equipment
- ISO 6009:1992/Cor:1:2008 Hypodermic Needles for Single Use color . coding for identification
The Terumo SurGuard 3 Safety Hypodermic Needle also complies with the requirements specified in ISO 7864:1993 - Sterile Hypodermic Needles for Single
{9}------------------------------------------------
K122249
page 10 of 10
Use, with the exception of:
Section 13.2a Patency of Lumen: no specifications are given for 26G, 27G and 30G having an ultra thin wall cannula. As a result, these needles cannot be compared to this requirement.
## G. ADDITIONAL SAFETY INFORMATION
Manufacturing controls include visual, functional and sterility tests.
The sterility of the device is assured using a sterilization method validated in accordance with ANSI/AAMI/ISO 11137 - Medical Devices - Validation and Routine Control of Radiation Sterilization. The Terumo SurGuard®3 Safety Hypodermic Needle is sterilized to provide a Sterility Assurance Level (SAL) of 10-6.
A specific sterilization dose to provide Sterility Assurance Level (SAL) of 100 is set using bioburden information obtained.
## H. CONCLUSION
The performance of the TERUMO® SurGuard®3 Safety Needle submitted in this 510(k) is substantially equivalent in intended use, design, technology/principles of operation, materials and performance to the legally marketed predicate device which is:
- 1. K113422 TERUMO® SurGuard®3 Safety Hypodermic Needle with or without syringe manufactured by Terumo (Philippines) Corporation.
Differences among the devices do not raise any significant issues of safety or effectiveness.
Terumo's statement of substantial equivalence is done solely to comply with the requirements of the Federal Food, Drug and Cosmetic Act and is not intended whatsoever to be the basis for a patent infringement action.
{10}------------------------------------------------
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/10/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 lines representing its body and wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring. MD 20993-0002
Terumo (Philippines) Corporation C/O Mr. Phillip Michael Lester Regulatory Affairs Specialist Terumo Medical Corporation 950 Elkton Boulevard Elkton, Maryland 21921
AUG 28 2012
Re: K122249
Trade/Device Names: TERUMO® SurGuard®3 Safety Needle, 23G, 25G, 26G, 27G and 30G; TERUMO® SurGuard® 3 Hypodermic Syringe with Safety Needle, Icc/mL Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: II Product Code: FMI, MEG Dated: July 25, 2012 Received: July 30, 2012
Dear Mr. Lester:
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.
{11}------------------------------------------------
## Page 2- Mr. Lester
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. S. Smith D.
Anthony B. Watson, BS, MS, MBA Director Division of Anesthesiology, General Hospital, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
{12}------------------------------------------------
# 22249
## Indications for Use
510(k) Number (if known):
Device Name: TERUMO® SurGuard®3 Safety Needle, 23G, 25G, 26G, 27G and 30G TERUMO® SurGuard®3 Hypodermic Syringe with Safety Needle, 1cc/mL
Indications for Use:
The TERUMO® SurGuard®3 Safety Needle device is intended for use in the aspiration and injection of fluids for medical purposes. The TERUMO SurGuard®3 Safety Needle is compatible for use with standard luer slip and luer lock syringes.
Additionally, after withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.
Prescription Use X (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)
Alid Chapman 8/27/12
(Division Sign-Off) (Division of Anesthesiology, General Hospital nfection Control, Dental Devices
510(k) Number: K122249
Page 1 of 1
4
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.