K133540 · Maxtec, Inc. · CCK · Mar 28, 2014 · Anesthesiology
Device Facts
Record ID
K133540
Device Name
FLOCAP
Applicant
Maxtec, Inc.
Product Code
CCK · Anesthesiology
Decision Date
Mar 28, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.1400
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The FLOCAP is to provide a semi-quantitative visualization of the CO2 in the patient airway. It is an adjunct in patient assessment, to be used in conjunction with other methods to determine clinical signs and symptoms by or on the order of a physician. The FLOCAP has a visual indicator to visually detect the end of exhalation. For use up to 24 hours. For patients greater than 15 kg (33 lbs.) Environment of use - hospital, sub-acute, pre-hospital, transport
Device Story
FLOCAP is a disposable, single-patient-use CO2 detector used in hospital, sub-acute, pre-hospital, and transport settings. It connects between a manual resuscitator/pressure source and a face mask or endotracheal tube. The device utilizes colorimetric, pH-sensitive litmus media to provide semi-quantitative CO2 visualization (Purple to Yellow color change). It includes a mechanical spinner/vane that rotates during expiratory flow (>1 lpm) to provide a visual indicator of exhalation. Operated by clinicians, the device serves as an adjunct to other clinical assessment methods to monitor patient airway status and ventilation progress. It does not require activation tabs and is designed for up to 24 hours of use.
Clinical Evidence
No clinical data. Substantial equivalence is supported by non-clinical performance testing, including color change response time, leakage, minimum static flow indication, anti-fog, packaging integrity (ISTA 2A), shelf-life, drop testing, duration of use, burst pressure, ISO 9360-1 compliance (pressure drop, internal volume), and usability (BS EN 62366).
Technological Characteristics
Colorimetric, pH-sensitive litmus media; mechanical spinner/vane for flow indication. Standard 15/22 mm conical fittings per ISO 5356-1. Dead space: 25 ml. Weight: 23g. Pressure drop: 0.7 cm H2O @ 30 lpm, 2.7 cm H2O @ 60 lpm, 5.7 cm H2O @ 90 lpm. Disposable, single-patient use. Shelf-life: 2 years. Biocompatibility tested per intracutaneous reactivity standards.
Indications for Use
Indicated for patients >15 kg (33 lbs) requiring semi-quantitative CO2 visualization in airway as an adjunct to clinical assessment. Contraindicated for hypercarbia detection, main stem bronchial intubation, mouth-to-tube ventilation, oropharyngeal tube placement, or cases where low pulmonary perfusion complicates interpretation.
Regulatory Classification
Identification
A carbon dioxide gas analyzer is a device intended to measure the concentration of carbon dioxide in a gas mixture to aid in determining the patient's ventilatory, circulatory, and metabolic status. The device may use techniques such as chemical titration, absorption of infrared radiation, gas chromatography, or mass spectrometry.
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#### 510(k) Summary Page 1 of 5 27-Mar-14
| Maxtec, LLC | | |
|----------------------------|-----------------------------------------------------------------|--|
| 6526 S Cottonwood Street | Tel: 801.327.9870 | |
| Salt lake City, UT 84107 | Fax: 801.270.5590 | |
| Official Contact: | Tammy Lavery, Regulatory Affairs & Quality | |
| Proprietary or Trade Name: | FLOCAP | |
| Common/Usual Name: | CO₂ detector | |
| Classification Name: | Carbon dioxide gas analyzer<br>CCK - 21 CFR 868.1400<br>Class 2 | |
| Predicate Devices: | Mercury Medical - StatCO₂ – K021576 | |
#### Device Description
The proposed FLOCAP is comprised of several components:
- Housing with standard 15 mm / 22 mm fittings to connect to ventilatory assist devices and a face . mask or endotracheal tube
- . Colorimetric litmus media which has been treated with chemical to detect the presence of CO2 by a change in pH
- . A spinner / vane which spins when there is expiratory flow. It is to detect presence of expiratory flow
#### Indications for Use
The FLOCAP is to provide a semi-quantitative visualization of the CO2 in the patient airway. It is an adjunct in patient assessment, to be used in conjunction with other methods to determine clinical signs and symptoms by or on the order of a physician.
The FLOCAP has a visual indicator to visually detect the end of exhalation.
For use up to 24 hours.
For patients greater than 15 kg (33 lbs.)
Environment of use - hospital, sub-acute, pre-hospital, transport
#### Predicate Device Comparison:
The Maxtec FLOCAP CO2 detector is viewed as substantially equivalent to the predicate device based upon the following:
#### Indications -
Indicated to provide semi-quantitative visualization of the CO2 in the patient airway and as an adjunct in patient assessment for use in hospital, sub-acute and pre-hospital, and
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#### 510(k) Summary Page 2 of 5 27-Mar-14
- . transport for patient greater than 15 kg and up to 24 hours of use are identical to the predicate.
Discussion - The indications for use are identical for the proposed and predicate device. Mercury Medical STAT CO2 - K021576.
#### Contraindications -
The contraindications are almost identical to the predicate. .
Discussion - We added hypercarbia as part of the contraindications, but this does not alter the contraindications and they can be found to be substantially equivalent to the predicate -Mercury Medical STAT CO2- K021576.
#### Technology -
- The technology of a colorimetric, pH sensitive, media to detect the presence and the . amount of CO2 is identical to the predicate.
Discussion - There are no differences in technology between the proposed device and the predicate - Mercury Medical STAT CO2 - K021576.
#### Environment of Use -
- Hospital, sub-acute, Pre-hospital, and transport environments of use are identical to the ● predicate.
Discussion - The environments of use are similar between the proposed device and the predicates - Mercury Medical STAT CO2 - K021576. While the predicate only specifies hospital and transport, sub-acute is a subset of hospitals and pre-hospital is a subset of transport (EMS). The proposed language is only to clarify the environments of use better.
#### Non-clinical Performance Testing
- We compared performance to specifications to the predicate as well as performed . specific tests related to the device. These tests included:
- o Color change response time
- Leakage o
- Minimum static flow indication o
- Anti-fog O
- Packaging integrity per ISTA 2A O
- Operational environment 0
- Shelf-life (aging) o
- Drop test O
- Duration of Use O
- Burst Pressure O
- Compliance per ISO 9360-1 O
- Pressure Drop per ISO 9360-1 O
- Internal Volume (Dead space) O
- 0 Usability per BS EN 62366
Discussion - The bench testing as well as the comparative specifications we found to be similar to the predicate - Mercury Medical STAT CO2 - K021576
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#### 510(k) Summary Page 3 of 5 27-Mar-14
Matcrials -
- • The materials ultized in the FLOCAP are typical and common and have been even so novel billion in in biocompatibility
Discussion The materials vere tested in the finish Intracutancous reactivity.
| Features | Predicate<br>Mercury Medical STAT CO₂<br>(K021576) | Proposed<br>FLOCAP |
|-----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for use | The Mercury STAT CO₂ is intended to provide a semi-<br>quantitative visualization of the CO₂ in the patient<br>airway. It is an adjunct in patient assessment, to be<br>used in conjunction with other methods to determine<br>clinical signs and symptoms by or on the order of a<br>physician. | The FLOCAP is to provide a semi-quantitative visualization<br>of the CO₂ in the patient airway. It is an adjunct in patient<br>assessment, to be used in conjunction with other methods to<br>determine clinical signs and symptoms by or on the order of<br>a physician. The FLOCAP has a visual indicator to visually<br>detect the end of exhalation. |
| Patient Use / Duration if use | Single patient use, disposable, < 24 hours | Single patient use, disposable, < 24 hours |
| Environment of Use | Hospital | Hospital<br>Sub-acute<br>Pre-hospital |
| | Transport | Transport |
| Patient Population<br>Contraindications | Greater than 15 kg (33 lbs.)<br>• Do not use to detect hypercapnia<br>• Do not use to detect main stem bronchial intubation<br>• Do not use during mouth-to-tube ventilation<br>• Do not use to detect oropharyngeal tube placement<br>When low pulmonary perfusion coincides with accidental<br>esophageal intubation, colorimetric CO₂ indication cannot be<br>properly interpreted. However, if proper tube placement is<br>ascertained by independent means, then the STAT CO₂ may<br>be used to help assess the progress of positive pressure<br>ventilation as evidenced by an increase in end-tidal CO₂. | Greater than 15 kg (33 lbs.)<br>• Do not use to detect hypercapnia / hypercarbia<br>• Do not use to detect main stem bronchial intubation<br>• Do not use during mouth-to-tube ventilation<br>• Do not use to detect oropharyngeal tube placement<br>When low pulmonary perfusion coincides with accidental<br>esophageal intubation, colorimetric CO₂ indication cannot<br>be properly interpreted. However, if proper tube placement<br>is ascertained by independent means, then the FLOCAP may<br>be used to help assess the progress of positive pressure<br>ventilation as evidenced by an increase in end-tidal CO₂. |
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# 510(k) Summary
| Features | Predicate<br>Mercury Medical STAT CO₂<br>(K021576) | Proposed<br>FLOCAP |
|-----------------------------------------------------|--------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|
| Principle of Operation | Colorimetric, pH sensitive dye for detecting presence of CO₂<br>and the amount | Colorimetric, pH sensitive dye for detecting presence of<br>CO₂ and the amount |
| Placement | Between manual resuscitator or pressure source and the<br>patient face mask or endotracheal tube | Between manual resuscitator or pressure source and the<br>patient face mask or endotracheal tube |
| Features, Specifications and Performance | | |
| Standard 15 / 22 mm connections<br>Per ISO 5356-1 | Yes | Yes |
| Internal Volume (dead space) | 25 ml | 25 ml |
| Weight | 22 gr | 23 gr |
| Compliance per ISO 9360-1 | Not provided | 0.44 ml/kPa |
| Leakage per ISO 9360-1 | Not provided | 0.0 ml/min |
| Pressure Drop per ISO 9360-1 | @ 60 lpm - 3.0 cm H₂O | @ 30 lpm - 0.7 cm H₂O<br>@ 60 lpm - 2.7 cm H₂O<br>@ 90 lpm - 5.7 cm H₂O |
| Shelf-life | 2 years | 2 years |
| Packaging and method to<br>"activate" | Polybag<br>Remove plastic tab to expose litmus media | Foil pouch<br>Nothing required to be done to activate |
| Detected % CO₂ ranges and<br>Colors | 0% CO₂ - Blue<br>1.0 to 2.0% CO₂ - Green<br>> 5.0% CO₂- Permanent Yellow | 0% CO₂ - Purple<br>1.0 to 2.0% CO₂ - Beige<br>> 5.0% CO₂- Yellow |
| Method of Communicating<br>Meaning of Color Changes | Matching Colored Label on the Outside of the device | Matching Colored Label on the Outside of the device |
| Meanings of detecting patient<br>exhalation | Color change | Color change<br>Spinning vane - visual indicator (detects exhalation flow > 1<br>lpm) |
| Standards | ISO 5356-1 - Conical fittings | ISO 5356-1 - Conical fittings<br>ISO 9360-1 HME in part |
.
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510(k) Summary Page 5 of 5 27-Mar-14
#### Differences -
There are limited differences between the proposed FLOCAP and the predicate.
- Filter element .
- The predicate includes a filter element to capture any gross particulates that may o come from the device or to protect the colorimetric media from an patient secretions
- o The proposed device does not contain a filter element, as some predicate colorimetric CO2 detectors. For the FLOCAP gas passes around the media and does not have to go through it so protection from patient secretions is less of an issue.
Discussion - All these devices contain notes that if the device is subjected to patient secretions it should be removed and replaced. Therefore this difference is not significant and does not raise any new concerns of safety or effectiveness.
- . Pull tab to active the device
- o The predicate has a tab which seals the media from any ambient air and must be removed prior to use.
- The proposed FLOCAP does not require this tab as the media as the packaging o has demonstrated that it can be safely stored for 2 years without deterioration in performance.
Discussion - The proposed FLOCAP without the pull tab does not raise any new concerns.
#### Substantial Equivalence Conclusion -
The sponsor has demonstrated through performance testing, design and features, and non-clinical testing that the proposed device and predicate have been found to be substantially equivalent.
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Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular arrangement of text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA". Inside the circle is a stylized symbol that resembles an abstract caduceus or a representation of human figures. The logo is presented in black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center -- WO66-G609 Silver Spring, MD 20993-0002
April 9, 2014
Maxtec, Limited Liability Company Mr. Paul Dryden Consultant 6526 South Cottonwood Street Salt Lake City, UT 84107
Re: K133540
Trade/Device Name: FLOCAP Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: Class II Product Code: CCK Dated: February 21, 2014 Received: February 24, 2014
Dear Mr. Dryden:
This letter corrects our substantially equivalent letter of March 28, 2014.
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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Page 2 – Mr. Dryden
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 vours.
Todd D. Courtney -S 2014.04.09 14:38:11 -04'00'
for
Erin I. Keith, M.S. Acting 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 Statement
Page 1 of 1
K133540 510(k) Number: (To be assigned)
Device Name: FLOCAP
Indications for Use:
The FLOCAP is to provide a semi-quantitative visualization of the CO2 in the patient airway. It is an adjunct in patient assessment, to be used in conjunction with other methods to determine clinical signs and symptoms by or on the order of a physician.
The FLOCAP has a visual indicator to visually detect the end of exhalation.
For use up to 24 hours.
For patients greater than 15 kg (33 lbs.)
Environment of use - hospital, sub-acute, pre-hospital, transport
| Prescription Use XX | or | Over-the-counter use |
|-----------------------------|----|------------------------|
| (Part 21 CFR 801 Subpart D) | | (21 CFR 807 Subpart C) |
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
## Todd D. Courtney -S 2014.03.24 13:52:13 -04'00'
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.