AQUABOSS ECORO DIA I (HT); AQUABOSS ECORO DIA II (HT)
Applicant
Lauer Membran Wassertechnik GmbH
Product Code
FIP · Gastroenterology, Urology
Decision Date
Mar 25, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5665
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K124059 · Mar 25, 2013
AQUABOSS ECORO DIA I (HT); AQUABOSS ECORO DIA II (HT)
Lauer Membran Wassertechnik GmbH
Performance data from European clinical installations
Retrospective performance data from existing European installations was used to evaluate the long-term microbiological performance of the RO systems, specifically regarding the heat disinfection of the membranes.
Microbiological performance; Long-term evaluation; European installations; Heat disinfection
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Long term evaluation of microbiological performance; Retrospective evaluation of performance data; Follow-up/Duration: Long term
European clinical installations
Not applicable for this study
Microbiological performance (bacterial counts and endotoxins)
Indications for Use
The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are complete water treatment systems centered around reverse osmosis units of varying output which include recommended pretreatment components such as carbon filtration, backwash filters, softeners, and temperature blending valves and recommended post treatment such as final filtration intended for hemodialysis applications. The Aquaboss water treatment systems are to be used at dialysis clinics or hospitals. The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are intended to remove organic and inorganic substances and microbial contaminants from water. The treated water will then be used to prepare and dilute dialysate concentrate to form dialysate and/or rinse dialyzers for multiple uses and/or to prepare dilute solutions for reprocessing procedures in multiple-use dialyzers. The water treatment systems are designed to meet current AAMI/ISO and Federal (U.S.) standards.
Device Story
Water treatment system for hemodialysis; utilizes reverse osmosis (RO) to remove contaminants from tap water. Input: potable water; Output: purified permeate for dialysate preparation. System includes pretreatment (carbon filters, softeners, backwash filters) and post-treatment (ring main distribution). Operation: pressure-driven cross-filtration through semi-permeable polyamide membranes. Features: automatic flushing, impulse backwashing, and optional dual-stage RO for redundancy. Disinfection: chemical (peracetic acid) or heat (HotRinse SMART). Used in clinics/hospitals; operated by trained staff. Performance monitoring: LCD displays conductivity, pressure, flow, and temperature; triggers alarms for poor water quality. Benefits: ensures water meets AAMI/ISO standards; reduces microbial growth via automated flushing and heat sanitization.
Clinical Evidence
Bench testing only. Includes software validation/verification, alarm/error testing, membrane performance (flux/rejection), microbiological stability (bacterial counts/endotoxins per AAMI/ISO standards), leachable/extractable testing, electrical safety (IEC 61010), EMC (IEC 60601-1-2), and functional safety (ISO 14971). Long-term reliability data from European installations provided.
Technological Characteristics
Reverse osmosis system; polyamide thin-film composite spiral-wound membranes. Materials: Stainless steel AISI 316L, PP, EPDM, PTFE, PVDF. Energy: Electric (pumps/controls). Connectivity: Digital display for monitoring. Disinfection: Chemical or heat. Software: Menu-guided control. Standards: AAMI/ANSI/ISO 13959:2009, 23500:2011, IEC 61010, IEC 60601-1-2.
Indications for Use
Indicated for use in dialysis clinics or hospitals to purify water for hemodialysis applications, including dialysate preparation and dialyzer rinsing/reprocessing. Removes organic/inorganic substances and microbial contaminants.
Regulatory Classification
Identification
A water purification system for hemodialysis is a device that is intended for use with a hemodialysis system and that is intended to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This generic type of device may include a water softener, sediment filter, carbon filter, and water distillation system.
Special Controls
*Classification.* Class II (special controls). The device, when it is a water purification subsystem disinfectant, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.
Predicate Devices
Gambro Central Water Treatment System CWP 100 WROH (K974899)
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# K124059 PAGE 1 OF 8
MAR 2 5 2013
# 510(k) Summary
As required by section 807.92( c )
# Aquaboss® EcoRO Dia I + II (HT) Series Water Treatment System for Hemodialysis
Manufacturer: Lauer Membran Wassertechnik GmbH Speichermatt 9 / 79599 Wittlingen (Germany) Organization Number: 187230
> Contact: Stephan Krietemeyer Phone: (+49) 7621 927015 FAX: (+49) 7621 927092
| Date: | 12/12/2012 |
|----------------------|----------------------------------------------------------------------------------------|
| Classification Name: | Water Purification System for Hemodialysis |
| Common Name: | Reverse Osmosis systems with pretreatment and<br>product water distribution components |
| Proprietary Name: | Aquaboss® EcoRO Dia I+II (HT) Series Water<br>Purification System for Hemodialysis |
# Claiming substantial equivalence to:
| Gambro Central Water Treatment System CWP 100 WROH | (K974899) |
|----------------------------------------------------|-----------|
| Gambro WRO 300H | (K093608) |
| Aquaboss EcoRO Dia | (K032004) |
2635
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Image /page/1/Picture/0 description: The image shows the text "K124059 PAGE 2 OF 8". The text appears to be handwritten. The top line contains a series of numbers and letters, while the bottom line indicates the page number.
| | | 510(k) | 5 | page:2 of 8 |
|--|----------------------------|------------|-------|-------------|
| | EcoRO Dia I+II (HT) Series | Author: | RD/Ln | |
| | 510(k) Summary | Approved : | Kr | |
| | | project: | | |
| | | 18.03.2013 | QM | |
# Classification panel:
| Administrative Information | |
|-------------------------------------------|----------------------------------------------------------------------------------------|
| Type of 510(k) submission: | Traditional |
| Medical device type: | Reverse Osmosis EcoRO Dia. |
| 510(k) submitter: | Lauer Membran Wassertechnik GmbH<br>Speichermatt 9<br>79599 Wittlingen<br>Germany |
| Contact person: | Dr. Stephan Krietemeyer<br>Title: Technical Director; VP<br>Phone no. +49 7621 9270 15 |
| Preference for continued confidentiality: | Yes, continued confidentiality |
| Classification regulation: | Water purification system for haemodialysis |
| Class: | II |
| Panel: | Gastroenterology/Urology |
| Product code: | FIP |
| FDA documents: | |
# PART 876--- GASTROENTEROLOGY-UROLOGY DEVICES
[Code of Federal Regulations] [Title 21, Volume 8] [Revised as of April 1, 2002] From the U.S. Government Printing Office via GPO Access [CITE: 21CFR876.5665] [Page 363] TITLE 21--FOOD AND DRUGS CHAPTER I--FOOD AND DRUG ADMINISTRATION, DEPARTMENT OF HEALTH AND HUMAN SERVICES (CONTINUED) PART 876--GASTROENTEROLOGY-UROLOGY DEVICES--Table of Contents Subpart F -- Therapeutic Devices Sec. 876.5665 Water purification system for haemodialysis.
(a) Identification. A water purification system for haemodialysis is a device that is intended for use with a haemodialysis system and that is intended to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This generic type of device may include a water softener, sediment filter, carbon filter, and water distillation system. (b) Classification. Class II (performance standards).
# Product Code:
FIP
2636
Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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Image /page/2/Picture/1 description: The image shows a document with the title "ECORO DIA I+II (HT) SERIES 510(k) Summary". The document includes the author's initials, RD/Ln, and the approval initials, Kr. The document also includes the date 18.03.2013 and the initials QM. The document is labeled as page 3 of 8.
### Classification name:
Water purification system for haemodialysis (21 CFR 876 5665)
### Device trade name:
EcoRO Dia I / EcoRO Dia II central water treatment systems
#### Common name:
Central Reverse Osmosis for Hemodialysis
#### Indications for use
| 510(k) Number (if known): | K124059 |
|---------------------------|---------------------------------------------------------------------------------------|
| Device Name: | Aquaboss® EcoRO I, Aquaboss® EcoRO I HT,<br>Aquaboss® EcoRO II. Aquaboss® EcoRO II HT |
#### Indications for Use:
The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are complete water treatment systems centered around reverse osmosis units of varying output which include recommended pretreatment components such as carbon filtration, backwash filters, softeners, and temperature blending valves and recommended post treatment such as final filtration intended for hemodialysis applications. The Aquaboss water treatment systems are to be used at dialysis clinics or hospitals. The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are intended to remove organic and inorganic substances and microbial contaminants from water. The treated water will then be used to prepare and dilute dialysate concentrate to form dialysate and/or rinse dialyzers for multiple uses and/or to prepare dilute solutions for reprocessing procedures in multiple-use dialyzers. The water treatment systems are designed to meet current AAMI/ISO and Federal (U.S.) standards.
The Aquaboss water treatment systems come in the following configurations:
- (1) EcoRO I: Single-Pass / Single staged; Chemical Disinfection -
| | Catalogue numbers :<br>1106073 - 1106108 - 1106108 - 1106128 - 1106143 - 1106183 - 1106213 - 1106248 - 1106283<br>- 1106363<br>Description:<br>Single staged reverse osmosis with permeate capacity of 700 Vh to 3600 V. |
|-----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Chemical disinfection possible.<br>Pretreatment of potable water with components such as carbon filtration, backwash filters,<br>softeners, and temperature blending valves.<br>Post-treatment: Ringmain with optional final filtration for distribution of permeate to point of use, |
| (2) | EcoRO II Twin-Pass / Double Staged Chemical Disinfection |
| | Cataloque numbers:<br>1107073 - 1107094 - 1107108 - 1107128 - 1107143 - 1107184 - 1107214 - 1107249 - 1107283<br>- 1107363 |
Dual/ Double staged reverse osmosis with permeate capacity of 700 I/h to 3600 1/:
Chemical Disinfection possible.
Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves.
Post-treatment: Ringmain with optional filtration for distribution of permeate to point of use.
Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
510(k) Summary v3
2637
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| L/a/u/e/r<br>Membran Wassertechnik | EcoRO DIA I+II (HT) SERIES | | 510(k) | 5 (page: 4 of 8) |
|------------------------------------|----------------------------|--|------------|------------------|
| | 510(k) Summary | | Author: | RD/Ln |
| | | | Approved: | Kr |
| | | | project: | |
| | | | 18.03.2013 | QM |
(3) EcoRO I HT Single-Pass / Single Staged Heat Disinfection
Catalogue numbers:
1106072 - 1106107 - 1106107 - 1106127 - 1106142 - 1106182 - 1106212 - 1106247 - 1106282 - 1106362
Description:
Single staged reverse osmosis with permeate capacity of 700 Vh to 3600 I/.
- Chemical disinfection possible
Hot water sanitization with Aquaboss® HotRinse SMART 10/ 20/30/40/60.
Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves.
Post-treatment: Ringmain with optional filtration for distribution of permeate to point of use.
- (4) EcoRO II HT Twin-Pass / Double Staged Chemical Disinfection
Catalogue numbers: 1107072 – 1107093 – 1107107 – 1107142 – 1107183 – 1107213 – 1107248 – 1107282 – 1107362 Description: Dual/ Double staged reverse osmosis with permeate capacity of 700 l/h to 3600 V. Chemical disinfection possible Hot water sanitization with Aquaboss® HotRinse SMART 10/ 20/30/40/60. Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves. Post-treatment: Ringmain with optional filtration for distribution of permeate to point of use.
# Directions for use:
The system produces water for diluting hemodialysis concentrates according to AAMI ANSI ISO 13959: 2009 Water for hemodialysis and related therapies and AAMI ANSI ISO 11663:2009 Quality of dialysis fluid for hemodialysis and related therapies
The system output rate is 700Vh to 3600 Vh. The temperature of the supplied water must not drop below 50°F (10°C). The system is designed and built for continuous operation. The selection of water treatment equipment for dialysis is the responsibility of the dialysis physician. Product water should be tested periodically according to the AAMI ANSI ISO 13959: 2009 standard.
Ambient air temperature for Aquaboss EcoRO Dia I + II (HT) is in the range of 5-40°C/41... 104°F, max 75% relative humidity, non condensing
# Device Description:
The Aquaboss® EcoRO Dia I + II (HT) Series Water Treatment System for Hemodialysis is a complete water purification system and consists of a reverse osmosis (RO) and pro-treatment. This product is an accessory device that is intended for use within the Hemodialysis facility to remove organic and inorganic substances and microbial contaminants from tap water used to dilute Dialysate concentrate to form Dialysate. This system has been designed to produce purified water as prescribed by AAMI ANSI ISO 13959: 2009 Water for hemodialysis and related therapies and provide adequate flow of the feed (tap) water and compliance with the existing drinking water standards. In order to optimize the performance of the RO system, the following items for pre-treatment can be utilized:
- Softeners 1)
- Backwash filters 2)
- 3) Organic Bed Service Carbon
· Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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| | L/a/u/e/r | |
|--|-----------------------|--|
| | Membran Wassertechnik | |
| 510(k) | 5 page:5 of 8 |
|----------------------------|---------------|
| EcoRO DIA I+II (HT) SERIES | Author: RD/Ln |
| 510(k) Summary | Approved : Kr |
| | project: |
| 18.03.2013 | QM |
#### 4) Raw Water Temperature Blending Value
Aquaboss® EcoRO Dia I + II (HT) operates on the reverse osmosis principle. Reverse Osmosis describes a process involving a pressure operated cross filtration system. The water high pressure tangentially to a semi permeable membrane. As it is the case with normal filtration the system is cleaned by allowing one component (water) of the mixture to be separated to pass through the membrane with almost no hindrance whereas the other components (dissolved and non-dissolved water contents) are held back to leave the fitration unit in the concentrate flow. This is a separation process in the molecular sector which does not change the components being separated either chemically, biologically or thermally.
In order to ensure the microbiological quality of the permeate, this system has:
- . A dead space free stainless steel pressure vessel for the RO membrane.
- . A hygienic design with smooth surfaces
- . Automatic flushing program to remove impurities from the membrane surface (impulse backwashing)
- . Automatic flushing during standby periods to exchange stagnant water
- . Dead space free connection between Reverse osmosis and the Dialysis machine's via continuous flow distribution loop.
- . The implementation of a secondary distribution loop which reduces dead space and pressure fluctuations.
#### Performance Monitoring:
The conductivity of the Permeate and the operating mode is continuously displayed on the LCD on the operator's panel. Alarm and error messages are displayed on the LCD. All readings for conductivities (raw water, permeate), flow (permeate, concentrate) system pressure, temperature are presented on the display on the operator's panel on request.
#### Impulse backwash
After the system has been switched on or after switchover from standby operation to dialysis operation the membrane and the complete system can be pre flushed for 2 - 45 minutes. In this state the system carries out repeated backwashing operations and flushes concentrate down the drain.
#### Cleaning & Disinfection:
Aquaboss® EcoRO Dia I + II (HT) Series has a menu-guided cleaning and disinfection program. By following the displayed messages disinfection with peracetic acid disinfection products or heat can easily be carried out by the operator.
#### Standby operation
During standby the EcoRO Dia Series flushes automatically to reduce microbial growth in the system.
#### Material used
Pipework, pressure vessels: Break Tank: Membranes, plugs/adapter Polyamide (PA) Seals/O-rings
Stainless steel AISI 316L (1.4404/1.4571) Polypropylene (PP) Ethylene Propylene Diene Monomer (EPDM) Polytetrafluoroethylene (PTFE) Polyvinylidene fluoride (PVDF)
Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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| <img alt="Logo" src="image"/> | EcoRO D <sub>IA</sub> I+II (HT) SERIES | 510(k) | 5 page:6 of 8 |
|-------------------------------|----------------------------------------|------------|---------------|
| | 510(k) Summary | Author: | RD/Ln |
| | | Approved: | Kr |
| | | project: | |
| | | 18.03.2013 | QM |
### Predicate Devices
The Aquaboss EcoRO Dia I + II (HT) Water Treatment System is substantially equivalent to other water purification systems in commercial distribution in the United States to include the
- a) Gambro Central Water Treatment System CWP 100 WROH (K974899),
- b) Gambro WRO 300H (K093608)
- c) Aquaboss EcoRO Dia (K032004)
- All systems utilize reverse osmosis for purification of water to be used for hemodialysis ●
- All systems utilize a polyamide, thin film composite, spiral wound membrane for hemodialysis �
- All systems are intended to be used for water purification for hemodialysis. .
- All systems use substantially equivalent water contact materials for pumps, tubing and other . fittings.
- . All systems can utilize chemical disinfection using peracetic acid disinfection products
- Aquaboss EcoRO Dia I+II (HT) series as well as Gambro WRO 300H can optionally utilize ● heat for the disinfection of the RO membrane
- . Aquaboss EcoRO Dia I+II (HT) series as well as Gambro Central Water Treatment System CWP 100 WROH can optionally utilize heat for the disinfection of the connected ring main
- All system display poor water quality and pressure alarms on a display �
- All systems monitor water quality on digitally displays ●
- As a beneficial feature Aquaboss® EcoRO Dia I+II (HT) may be equipped with a second . membrane barrier to provide fully redundant 100% capacity. The optional second RO stage is completely flushed through during standard operation. That prevents the risk of microbiological growth during standby that usually present in alternating central RO systems where one RO is in standby while the second RO is operational.
We therefore consider the Aquaboss EcoRO Dia I + II (HT) Water Treatment to be substantially equivalent to the following approved devices.
#### Intended use:
Device that is intended for use with a hemodialysis system to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This device may include a water softener, sediment filter and carbon filter
Aquaboss® EcoRO Dia I + II (HT) Water Treatment System is an accessory device designed to safely and effectively provide water purification for use in Hemodialysis applications.
The product water produced will meet the minimum water quality requirements as specified by the AAMI AISI ISO standard 13959:2009 and AAMI ANSI ISO standard 23500:2011 when used as directed. Dependent on feed water quality, this unit may be used in conjunction with other approved water treatment components. Enclosed below is a chart indicating the physical differences of the EcoRO Dia Series:
2640
Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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| L/a/u/e/r<br>Membran Wassertechnik<br>Image: [logo] | EcoRO DIA I+II (HT) SERIES<br>510(k) Summary | 510(k) 5 page:7 of 8<br>Author: RD/Lh<br>Approved: Kr |
|-----------------------------------------------------|----------------------------------------------|-------------------------------------------------------|
| | project: | |
| 18.03.2013 | QM | |
Pre treatment and EcoRO Dia Series Diagram with optional dual stage RO and heat disinfection module.
Image /page/6/Figure/3 description: The image shows a diagram of a water treatment system. The system consists of four main stages: feed, pretreatment, reverse osmosis, and distribution system. The pretreatment stage includes a temperature control valve, booster pump, prefilter (5-25 μm), activated carbon (main and polisher), and an optional softener. The reverse osmosis stage includes a prefilter (5 μm), EcoRO Dia (single stage), and options for single or dual stage HT.
### Technological Characters
Comparing the proposed device to the predicate devices, some similarities and differences are noted in the design employed to accomplish the same intended use: All systems utilize reverse osmosis for purification of water to be used for Hernodialysis. All systems utilize a polyamide, thin film composite, and spiral wound membrane for Hemodialysis. All systems are intended to be used for water purification for Hemodialysis. All systems use substantially equivalent water contact materials for pumps, tubing and other fittings. All systems can utilize chemical disinfection using peracetic acid disinfection products or heat disinfection as outlined in the AAM ANSI ISO standard 23500:2011. All systems display poor water quality and pressure alarms on a display. All systems monitor water quality on digitally displays.
The Aquaboss® EcoRO Dia I + II (HT) Multi-Patient Water Treatment System may combine features of the predicate devices (heat disinfection of the ring main and heat disinfection of the RO membrane) as optional features.
An additional feature of Aquaboss® EcoRO Dia I + II (HT) is the optional second RO stage. This second stage works as a redundant backup RO that is permanently flushed and flown through. As an additional benefit this configuration adds a second permeate purification step to the system to ensure best microbiological and chemical water quality.
### Assessment of non-clinical performance data
The non clinical testing applied to Aquaboss® EcoRO Dia I+II (HT) water purification units equipped with Software 1.04, in order to determine substantial equivalence with the predicate device included:
- Validation and Verification of Software including all options for single and double staged RO . systems as well as HT (hot disinfection of RO membranes and ring main) in system integration testing as well as alarm and error testing. (Internal software and performance tests)
- Disinfection chemical and heat (Internal software and performance tests) .
- Membrane performance (flux, rejection) and system performance derived from QA testing . demonstrating that system performances are equivalent with predicate devices. Substantial Equivalence with predicate devices
- Microbiological stability for bacterial counts and endotoxins according to AAMI AISI ISO standard . 13959:2009; AAMI AISO ISO standard 23500:2011
- Leachable and extractable testing (Biocompatibility External Test laboratory and predicate . devices)
Electrical safety ( IEC 61010; ون : ANSI/UL61010 external test laboratory) Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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| <img alt="Lauer Membran Wassertechnik" src="logo.png"/> | | 510(k) | 5 | page:8 of 8 |
|---------------------------------------------------------|----------------------------|------------|-------|-------------|
| | EcoRO DIA I+II (HT) SERIES | Author: | RD/Ln | |
| | 510(k) Summary | Approved : | Kr | |
| | | project: | | |
| | | 18.03.2013 | | QM |
- Electromagnetic compatibility testing according to IEC 6061-1-2 (External test laboratory) .
- . Functional safety (according to ISO 14971)
- Ergonomics and usability (IEC 62366 & Risk management according to ISO 14971) .
- . Maintenance and reliability (Long term market performance Europe and SEA)
The assessment was performed by internal and external independent personnel
### Conclusion
Testing results of demonstrate that Aquaboss® EcoRO Dia I+II (HT) water purification units meets all performance specifications equivalent to the predicate devices. In addition external and internal test results indicate that Aquaboss EcoRO Dia I+II (HT) comply with all requirements stated in applicable recognized consensus standards for water treatment for hemodialysis. Therefore we believe that Aquaboss EcoRO Dia I+II (HT) meets all AAMI/ANS//ISO standards and Federal Regulations that are applicable for water purification system for haemodialysis [21CFR876.5665]
Beyond that, heat disinfection of the RO membranes did not affect safety or membrane and performed equivalent to predicate device disinfection for the purpose of ensuring low microbiological counts.
In addition to standard tests applicable for reverse osmosis testing specific to heat disinfection of the membrane included:
- Biocompatibility testing of extract from the hydraulic flow path of product contact material .
- . Validation of heat disinfection procedure in regards to temperature and contact time
- Long term evaluation of microbiological performance of the RO systems from performance data of European installations of these systems.
Test results demonstrate that the device is as safe, as effective and performs well or better than the predicate device.
Best regards,
18. MRZ. 2013
Dr. Stephan Krietemeyer Technical Director / VP. Lauer Membran Wassertechnik GmbH
2642 510(k) Summary v3
Lauer Membran Wassertechnik GmbH · Speichermatt 9 · 79599 Wittlingen
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Image /page/8/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with three tail feathers, representing the department's mission to protect the health of all Americans and provide essential human services. 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 Center - WO66-G609 Silver Spring, MD 20993-0002
March 25, 2013
Lauer Membran Wassertechnik GmbH % Dr. Stephan Krietemeyer Technical Director. VP 9 Speichermatt WITTLINGEN BW 79599 GERMANY
Re: K124059
Trade/Device Name: Aquaboss® EcoRO I, Aquaboss® EcoRO I HT, Aquaboss® EcoRO II, Aquaboss® EcoRO II HT Regulation Number: 21 CFR§ 876.5665 Regulation Name: Water purification system for hemodialysis Regulatory Class: II Product Code: FIP Dated: December 27, 2012 Received: December 31, 2012
Dear Dr. Krietemeyer:
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. Iisting 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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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 (OS) 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,
# Herbert P. Cerner -S
for
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use Form
510(k) Number (if known):
Device Name:
K124059
Aquaboss EcoRO I, Aquaboss EcoRO I HT, Aquaboss® EcoRO II, Aguaboss® EcoRO II HT
Indications for Use:
The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are complete water treatment systems centered around reverse osmosis units of varying output which include recommended pretreatment components such as carbon filtration, backwash filters, softeners, and temperature blending valves and recommended post treatment such as final filtration intended for hemodialysis applications.
The Aquaboss water treatment systems are to be used at dialysis clinics or hospitals. The Aquaboss® EcoRO I, EcoRO I HT, EcoRO Dia II and EcoRO Dia II HT are intended to remove organic and inorganic substances and microbial contaminants from water. The treated water will then be used to prepare and dilute dialysate concentrate to form dialysate and/or rinse dialyzers for multiple uses and/or to prepare dilute solutions for reprocessing procedures in multiple-use dialyzers.
The water treatment systems are designed to meet current AAMI/ISO and Federal (U.S.) standards.
The Aquaboss water treatment systems come in the following configurations:
- EcoRO I: Single-Pass / Single staged; Chemical Disinfection -(1)
Catalogue numbers : 1106073-1109093-1106108-1106128-1106143-1106143-1106183-1106213-1106248 - 1106283 - 1106363 Description: Single staged reverse osmosis with permeate capacity of 700 l/h to 3600 l/. Chemical disinfection possible. Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves.
Post-treatment: Ringmain with optional final filtration for distribution of permeate to point of use.
- (2) EcoRO II Twin-Pass / Double Staged Chemical Disinfection
#### Catalogue numbers:
1107073 - 1107094 - 1107108 - 1107128 - 1107143 - 1107184 - 1107214 - 1107249 - 1107283 - 1107363
Dual/ Double staged reverse osmosis with permeate capacity of 700 I/h to 3600 V:
Chemical Disinfection possible.
Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves.
Post-treatment: Ringmain with optional final filtration for distribution of permeate to point of use.
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- (3) EcoRO | HT Single-Pass / Single Staged Heat Disinfection
::
. .
Catalogue numbers: 1106072- 1106092- 1106107 - 1106127 - 1106142 - 1106182- 1106212 -1106247 - 1106282 - 1106362 Description: Single staged reverse osmosis with permeate capacity of 700 l/h to 3600 II. Chemical disinfection possible Hot water sanitization with Aquaboss® HotRinse SMART 10/ 20/30/40/60. Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves. Post-treatment: Ringmain with optional final filtration for distribution of permeate to point of use.
- (4) EcoRO II HT Twin-Pass / Double Staged Chemical Disinfection
Catalogue numbers: 1107072 - 1107093 - 1107107 - 1107142 - 1107183 - 1107213 - 1107248 -1107282 - 1107362 Description: Dual/ Double staged reverse osmosis with permeate capacity of 700 l/h to
3600 V.
Chemical disinfection possible
Hot water sanitization with Aquaboss® HotRinse SMART 10/ 20/30/40/60.
Pretreatment of potable water with components such as carbon filtration, backwash filters, softeners, and temperature blending valves.
Post-treatment: Ringmain with optional final filtration for distribution of permeate to point of use.
# Herbert Platerner -S
(Division Sign-Off) Division of Reproductive, Gastro-Renal, and Urological Devices K124059 510(k) Number
Prescription Use YES (Part 21 CFR 801 Subpart D)
.
AND/OR
Over-The-Counter Use: n/a (21 CFR 801 Subpart C)
#### (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED) ﻮ "ﻧ
Concurrence of CDRH, Office of Device Evaluation (ODE)
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.