K133446 · Excelsior Medical Corporation · NZW · Nov 14, 2014 · General Hospital
Device Facts
Record ID
K133446
Device Name
HEPARIN LOCK / FLUSH SYRINGES
Applicant
Excelsior Medical Corporation
Product Code
NZW · General Hospital
Decision Date
Nov 14, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5200
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Flushing of IV catheters and IV tubing only. Solution is intended for maintenance of patency of intravenous injection devices. Prior to and after administration of intermittent medication, entirely flush the intravenous injection device (catheter and or tubing) with Heparin Lock Flush, USP. Use in accordance with any warnings or precautions appropriate to medication being administered. This device is not to be used for anticoagulant therapy.
Device Story
Single-use, pre-filled, terminally sterilized syringes containing heparin sodium USP and 0.9% sodium chloride USP. Used by clinicians to flush IV catheters and tubing to maintain patency between intermittent medication administration, blood sampling, or dialysis. Device connects to standard luer lock/taper valves. Benefits include prevention of catheter occlusion. No clinical decision-making software or automated analysis involved.
Clinical Evidence
Bench testing only. Evidence includes raw material qualification, biocompatibility (ISO 10993-1), stability studies, sterilization validation (ISO 17665-1 and -2), extractables/leachables testing, and final product testing against the Heparin Lock Flush Solution USP Monograph.
Indicated for maintenance of patency of IV catheters and tubing in patients requiring intermittent IV medication, blood sampling, total parenteral nutrition, or hemodialysis. Not for use in anticoagulant therapy.
Regulatory Classification
Identification
An intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings and that is inserted into the patient's vascular system for short term use (less than 30 days) to sample blood, monitor blood pressure, or administer fluids intravenously. The device may be constructed of metal, rubber, plastic, or a combination of these materials.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-000
November 14, 2014
Excelsior Medical Corporation Mr. John Linfante Vice President RA/QA 1933 Heck Avenue Neptune, NJ 07753
Re: K133446
Trade/Device Name: Heparin Lock Flush, USP Regulation Number: 21 CFR 880.5200 Regulation Name: Heparin, Vascular Access Flush Regulatory Class: II Product Code: NZW Dated: October 16, 2014 Received: October 16, 2014
Dear Mr. Linfante
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Tejashri Purohit-Sheth, M.D.
Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR
Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital. Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K133446
Device Name
Heparin Lock Flush, USP
#### Indications for Use (Describe)
Flushing of IV catheters and IV tubing only. Solution is intended for maintenance of patency of intravenous injection devices. Prior to and after administration of intermittent medication, entirely flush the intravenous injection device (catheter and or tubing) with Heparin Lock Solution, USP. Use in accordance with any warnings or precautions appropriate to medication being administered. This device is not to be used for anticoagulant therapy.
Heparin Lock Flush, USP is supplied as:
- · 3 USP Units per 3 mL (1 USP unit per mL); 3 mL volume in a 10 mL syringe
- · 6 USP Units per 3 mL (2 USP unit per mL); 3 mL volume in a 10 mL syringe
- · 30 USP Units per 3 mL (10 USP unit per mL); 3 mL volume in a 10 mL syringe
- · 50 USP Units per 5 mL (10 USP unit per mL); 5 mL volume in a 10 mL syringe
- · 300 USP Units per 3 mL (100 USP unit per mL); 3 mL volume in a 10 mL syringe
- · 500 USP Units per 5 mL (100 USP unit per mL); 5 mL volume in a 10 mL syringe
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------|----------------------------------------------------------------------|
| <input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) | <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) |
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| Manufacturer Name: | Excelsior Medical Corporation |
|--------------------|---------------------------------------|
| Address: | 1933 Heck Avenue<br>Neptune, NJ 07753 |
| Contact Name: | John Linfante |
| Title: | Vice President RA/QA |
| Phone Number: | 732-643-6088 |
| Fax Number: | 732-776-7600 |
| Date Prepared: | October 16, 2014 |
# 510(k) Summary
| Device Proprietary Name: | Heparin Lock Flush, USP |
|------------------------------|--------------------------------|
| Device Common or Usual Name: | Heparin Lock Flush, USP |
| Classification Name: | Heparin, Vascular Access Flush |
| Classification Code: | NZW |
| Regulation Number: | 21 CFR Part 880.5200 |
| Device Classification: | II |
## Predicate Devices:
Substantial equivalence is claimed to the following devices as related to intended use, design, and material characteristics:
- . Syrex Pre-Filled Syringe, 10 U/mL & 100 U/mL, Excelsior Medical Corporation, K023740
- . Syrex Heparin Lock Flush Syringe, 1 U/mL & 2 U/mL, Excelsior Medical Corporation, K061497
## Description of the Device
Excelsior Medical's Heparin Lock Flush, USP devices are provided as terminally sterilized, single-use, pre-filled, pre-packaged products. The products contain a solution of heparin sodium, USP and 0.9% sodium chloride, USP. The solution is delivered through the luer lock of a venous access device to maintain catheter patency (lock catheters) between treatments. Typically, the venous access device is flushed with normal saline before and after the administration of intermittent medication therapy, blood sampling, total parenteral nutrition, or hemodialysis.
Heparin Lock Flush, USP is available as follows:
- . Heparin Lock Flush, USP, 3 USP Units per 3 mL (1 USP unit per mL); 3 mL volume in a 10 mL syringe
- Heparin Lock Flush, USP, 6 USP Units per 3 mL (2 USP unit per mL); 3 mL volume ● in a 10 mL syringe
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- Heparin Lock Flush, USP, 30 USP Units per 3 mL (10 USP unit per mL); 3 mL volume in a 10 mL syringe
- Heparin Lock Flush, USP, 50 USP Units per 5 mL (10 USP unit per mL); 5 mL volume in a 10 mL syringe
- Heparin Lock Flush, USP, 300 USP Units per 3 mL (100 USP unit per mL); 3 mL ● volume in a 10 mL syringe
- Heparin Lock Flush, USP, 500 USP Units per 5 mL (100 USP unit per mL); 5 mL volume in a 10 mL syringe
The product is intended for use with commercially available valves and catheters fitted with a standard mating luer lock or luer taper.
# Intended Use/Indications for Use
Flushing of IV catheters and IV tubing only. Solution is intended for maintenance of patency of intravenous injection devices. Prior to and after administration of intermittent medication, entirely flush the intravenous injection device (catheter and or tubing) with Heparin Lock Flush, USP. Use in accordance with any warnings or precautions appropriate to medication being administered. This device is not to be used for anticoagulant therapy.
# Technological Characteristics
The heparin lock/flush syringes subject to this filing have been previously cleared by FDA under K023740 and K061497. A comparison of the products is provided in the table below.
| 510(k) Number | | K061497 | K023740 |
|-------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | Heparin Lock Flush,<br>USP | Syrex Heparin Lock<br>Flush Syringes | Syrex Pre-Filled<br>Syringe |
| Manufacturer | Excelsior Medical Corporation | | |
| Intended Use | Flushing of IV<br>catheters and IV<br>tubing only. Solution<br>is intended for<br>maintenance of<br>patency of<br>intravenous injection<br>devices. Prior to and<br>after administration<br>of intermittent<br>medication, entirely<br>flush the intravenous<br>injection device<br>(catheter and or | Excelsior Medical<br>Heparin Lock Flush<br>Solutions (1 Unit/mL<br>and 2 Units/mL) are<br>indicated for use in<br>maintaining patency<br>of vascular access<br>devices designed for<br>intermittent or<br>infusion therapy.<br>Prior to and after<br>administration of<br>intermittent<br>medication, entirely | Flushing of IV<br>catheters and IV<br>tubing only. Prior to<br>and after<br>administration of<br>intermittent<br>medication, entirely<br>flush the catheter<br>and/or tubing with<br>Heparin Lock Flush<br>Solution, either USP<br>10 Units/mL, or USP<br>100 Units/mL. Use<br>in accordance with |
| | tubing) with Heparin<br>Lock Flush, USP.<br>Use in accordance<br>with any warning or<br>precautions<br>appropriate to<br>medication being<br>administered. This<br>device is not to be<br>used for anti-<br>coagulant therapy. | flush the vascular<br>access device with<br>Heparin Lock Flush<br>Solution, USP. Use<br>in accordance with<br>any warning or<br>precautions<br>appropriate to<br>medication being<br>administered. This<br>device is not to be<br>used for anti-<br>coagulant therapy | any warning or<br>precautions<br>appropriate to<br>medication being<br>administered. This<br>device is not to be<br>used for anti-<br>coagulant therapy.<br>Protect from freezing<br>and avoid excessive<br>heat. Store at 25°C<br>(77°F); excursions<br>permitted to 15°-<br>30°C (59°-86°F). |
| Solution | Heparin Lock Flush<br>Solution, USP (0.9%<br>Sodium Chloride<br>Injection, USP) | Heparin Lock Flush<br>Solution, USP (0.9%<br>Sodium Chloride<br>Injection, USP) | Heparin Lock Flush<br>Solution, USP (0.9%<br>Sodium Chloride<br>Injection, USP) |
| Concentrations | 1 U/mL<br>2 U/mL<br>10 U/mL<br>100 U/mL | 1 U/mL<br>2 U/mL<br>N/A<br>N/A | N/A<br>N/A<br>10 U/mL<br>100 U/mL |
| Single Use<br>Device | Yes | Yes | Yes |
| Sterility | Terminally sterilized<br>via steam; SAL 10-6 | Terminally sterilized<br>via steam; SAL 10-6 | Terminally sterilized<br>via steam; SAL 10-6 |
| Barrel<br>Material | Polypropylene and<br>silicone lubricant | Polypropylene and<br>silicone lubricant | Polypropylene |
| Plunger Rod<br>Material | Medical grade<br>polypropylene | Medical grade<br>polypropylene | Medical grade<br>polypropylene |
| Piston | Synthetic isoprene<br>rubber | Synthetic isoprene<br>rubber | Synthetic isoprene<br>rubber |
| Tip Cap | Medical grade<br>polypropylene and<br>TPE plus colorant | Medical grade<br>polypropylene and<br>TPE plus colorant | Medical grade<br>polypropylene and<br>TPE plus colorant |
| Tip Cap<br>Colorants | 1 U/mL - Green<br>2 U/mL - Lavender<br>10 U/mL - Blue<br>100 U/mL - Yellow | 1 U/mL - Green<br>2 U/mL - Lavender | 10 U/mL - Blue<br>100 U/mL - Yellow |
| Packaging | Tamper evident over-<br>wrap | Tamper evident over-<br>wrap | Tamper evident over-<br>wrap |
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As seen above there are no significant differences between the subject and predicate devices. The purpose of this submission is to add alternate suppliers of the heparin sodium (USP) raw material for all of Excelsior Medical's heparin products.
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# Non-Clinical Testing
The following studies have been performed or are being relied upon to support the safety and effectiveness of the product:
- Raw material qualification ●
- Biocompatibility (ISO 10993-1) ●
- Stability Studies ●
- Sterilization validation (ISO 17665-1 and -2) ●
- Extractables/Leachables
- Testing of final product to Heparin Lock Flush Solution USP Monograph
### Conclusion
As noted above, the only change to the Heparin Lock Flush, USP products as cleared in K023749 and K061497 is the source of heparin. This change is supported by the studies cited above, and results of the testing show that there are no new questions of safety and effectiveness. Therefore, it is concluded that the product is as safe and as effective for use, and is substantially equivalent to the identified predicate devices.
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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.
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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.
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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.
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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.
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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.
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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?
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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.
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Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
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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.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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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.