K133694 · Paragonix Technologies, Inc. · KDN · May 23, 2014 · Gastroenterology, Urology
Device Facts
Record ID
K133694
Device Name
SHERPA PAK TRANSPORTER
Applicant
Paragonix Technologies, Inc.
Product Code
KDN · Gastroenterology, Urology
Decision Date
May 23, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5880
Device Class
Class 2
Indications for Use
Organ storage and preservation for transplantation.
Device Story
The Paragonix Sherpa Pak Kidney Transport System provides a controlled environment for donor kidney transport. The system comprises an outer shipper with non-ice temperature-controlled elements, an inner/outer hard shell container (Sherpa Pak/Sherpa Pak Shell) for organ immersion in cold storage fluid, and a temperature display/timer. The device is used by medical personnel during organ procurement and transport to maintain hypothermic conditions (4°C–8°C) for up to 24 hours. By providing a rigid, temperature-monitored barrier, the system protects the donor organ from physical trauma and thermal fluctuations, potentially improving organ viability for transplantation.
Clinical Evidence
Bench testing only. Testing demonstrated the system maintains donor organ storage temperature between 4°C and 8°C for 24 hours and provides a robust transport environment to protect the organ. No clinical data was required or provided.
Technological Characteristics
Static cold ischemic storage system. Components include an outer shipper, hard shell container (Sherpa Pak/Sherpa Pak Shell), and temperature display/timer. Materials are identical to K123326; direct/indirect contact materials are biocompatibility tested. Sterilization of Sherpa Pak and Shell via gamma irradiation; other components non-sterile. Single-use.
Indications for Use
Indicated for static hypothermic preservation of kidney organs during transport and eventual transplantation into a recipient using compatible cold storage solutions. Maintains organ storage temperature between 4°C and 8°C for up to 24 hours.
Regulatory Classification
Identification
An isolated kidney perfusion and transport system and accessories is a device that is used to support a donated or a cadaver kidney and to maintain the organ in a near-normal physiologic state until it is transplanted into a recipient patient. This generic type of device may include tubing, catheters, connectors, an ice storage or freezing container with or without bag or preservatives, pulsatile or nonpulsatile hypothermic isolated organ perfusion apparatus with or without oxygenator, and disposable perfusion set.
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# MAY 2 3 2014
#### . 510(k) Summary Paragonix Sherpa Pak Kidney Transport System
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| Submitter: | Paragonix Technologies, Inc.<br>c/o Vaughn & Associates<br>639 Granite Street<br>Braintree, MA02184 |
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| Contact Person: | Leo Basta<br>NorthStar Biomedical Associates<br>93 Benefit Street<br>Providence, RI, 02904<br>Phone: 617.834.9866<br>lbasta@northstarbiomedical.com |
| Date Prepared: | December 23, 2013 |
| Trade Name: | Paragonix Sherpa Pak Kidney Transport System |
| Classification Name: | Isolated kidney perfusion<br>and transport system and accessories |
| Regulation Number: | 21 CFR 876.5880 |
| Product Code: | KDN |
| Predicate Devices: | Sherpa Pak Cardiac Transport System, 21 CFR 876.5880 -<br>Paragonix Technologies, Inc., K123326, Product Code MSB |
| | Avid Medical Custom Procedure Tray, 21 CFR 878.4800 -<br>Avid Medical, Class I exempt, Product Code KDD |
| | CoStorSol, 21 CFR 876.5880. Preservation Solutions Inc. -<br>K091245, Product Code KDN |
| Device Description: | The Paragonix Sherpa Pak Kidney Transport System is a<br>device intended to provide a safe, consistent method for cold<br>ischemic storage and transport of donor kidney organs to<br>recipients for transplantation. The Sherpa Pak Kidney<br>Transport System consists of 1) an outer shipper which<br>contains various non-ice based temperature controlled<br>packaging elements, 2) an inner and outer hard shell container<br>(i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, |
| | rigid barrier container in which the donor kidney is immersed<br>and suspended in a Cold Storage Fluid cleared for use in<br>storing and transporting donor organs and 3) a temperature<br>display and timer to monitor temperature and elapsed time of<br>transport, respectively. The device is identical to the cleared<br>Sherpa Pak Cardiac Transport System with the exception of<br>the indications for use specific to donor organs, and removal<br>of a connector in the canister component. |
| Intended Use: | Organ storage and preservation for transplantation. |
| Indications for Use: | The Sherpa Pak Kidney Transport System is intended to be<br>used for the static hypothermic preservation of kidney organs<br>during transportation and eventual transplantation into a<br>recipient using cold storage solutions indicated for use with<br>this organ. |
| | The Sherpa Pak Kidney Transport System can maintain the<br>donor organ storage temperature between 4°C and 8°C<br>through 24 hours. |
| Functional Testing: | Descriptive information and laboratory bench testing were<br>provided to demonstrate the device meets its design<br>specifications, performs as intended, and is safe for its<br>intended use. Additional biocompatibility testing was not<br>necessary as there were no material changes from the device<br>cleared under K123326. |
| | Specifically, testing to demonstrate that the Sherpa Pak<br>Kidney Transport System provides a transport system robust<br>enough to protect the donor organ during transport and<br>maintain temperature throughout the duration of transport, was<br> |
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Paragonix Kidney 510(k) Rev. B
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Paragonix Kidney 510(k)
Rev. B
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K133694
Page 3 of 6
| Device Characteristic | Proposed Sherpa Pak Kidney<br>Transport System<br>[current 510(k)] | Proposed Sherpa Pak Cardiac<br>Transport System Device -<br>K123326 | CoStorSol Cold<br>Storage Solution -<br>K091245 | Avid Medical<br>Custom<br>Procedure Tray<br>- Class 1 510(k)<br>Exempt |
|----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | Organ storage and preservation for<br>transplantation. | Organ storage and preservation for<br>transplantation. | Organ storage and preservation for<br>transplantation. | Organ storage and preservation<br>for transplantation |
| Indications for<br>Use | "The Sherpa Pak Kidney Transport<br>System is intended to be used for the<br>static hypothermic preservation of<br>kidney organs during transportation<br>and eventual transplantation into a<br>recipient using cold storage solutions<br>indicated for use with this organ.<br><br>The Sherpa Pak Kidney Transport<br>System can maintain the donor organ<br>storage temperature between 4°C and<br>8°C through 24 hours." | "The Sherpa Pak Cardiac Transport<br>System is intended to be used for the<br>static hypothermic preservation of<br>hearts, up to 4 hours, during<br>transportation and eventual<br>transplantation into a recipient, using<br>cold storage solutions indicated for<br>use with the heart." | "CoStorSol® is intended for the<br>flushing and cold storage of kidney,<br>liver and pancreas organs at the time<br>of organ removal from the donor in<br>preparation for storage, transportation<br>and eventual transplantation into a<br>recipient." | Specific indication statement is<br>unknown. However, the Avid<br>procedure tray is sold to organ<br>procurement centers, for organ<br>packaging with Cold Storage<br>Solutions for transportation to<br>recipient for transplantation. |
| Regulation<br>Number | 878.5880 | 878.5880 | 878.5880 | 878.4800 |
| Product Code | KDN | MSB | KDN | KDD |
| Device<br>Classification<br>Name | Device Classification Name – Isolated<br>kidney perfusion and transport system<br>and accessories | Device Classification Name – System<br>& Accessories, Isolated Heart,<br>Transport & Preservation | Device Classification Name –<br>Isolated kidney perfusion and<br>transport system and accessories | Kit, surgical instrument,<br>disposable. |
| Mode of<br>Operation | Static cold ischemic storage | Static cold ischemic storage | Static cold ischemic storage | Static cold ischemic storage |
| Meets UNOS<br>Policy 5¹ | Yes | Yes | Yes | Yes |
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' http://www.optn.transplant.hrsa.gov
Paragonix Kidney 510(k)
Rev. B
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K133694
Page 5 of 6
| Characteristic | Proposed Sherpa Pak Kidney<br>Transport System<br>[current 510(k)] | Proposed Sherpa Pak Cardiac<br>Transport System Device –<br>K123326 | CoStorSol Cold<br>Storage Solution –<br>K091245 | Avid Medical<br>Custom<br>Procedure Tray<br>- Class I 510(k) Exempt |
|--------------------------|------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------|---------------------------------------------------------------------|
| Single Use/Reuse | Entire system is single use/patient only. | Entire system is single use/patient only. | Single use/patient only. | Single use/patient only.<br>Commercial cooler may be reused. |
| Sterilization | Sherpa Pak and Sherpa Pak Shell are<br>sterilized by gamma irradiation. All<br>other components are non-sterile. | Sherpa Pak, Sherpa Pak Shell, and<br>Heart connector are sterilized by<br>gamma irradiation. All other<br>components are non-sterile. | Sterilized. | EO sterilized. |
| Biocompatibility | Direct and indirect organ contact<br>materials have been tested for<br>biocompatibility. | Direct and indirect heart contact<br>materials have been tested for<br>biocompatibility. | Yes. | Unknown. |
| Intended storage<br>time | Device can maintain 4° C to 8° C<br>through 24 hours | Currently indicated for up to 4 hours.<br>Device testing demonstrates<br>maintenance of 4° C to 8° C range<br>through 12 hours. | No time within indication statement | Unspecified |
Paragonix Kidney 510(k)
Rev. B
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### Summary of Substantial Equivalence:
The design, intended use, principles of operation, and technological characteristics of the Sherpa Pak Kidney Transport System are substantially equivalent to the previously cleared Sherpa Pak Cardiac Transport System (K123326). The intended use of the subject device is the same as all the cited predicates and the labeled indications for use is similar for each device. Substantial equivalence is based upon descriptive characteristics of the various cited predicate devices and upon the testing conducted to demonstrate that the subject device performs as intended and is substantially equivalent to the predicate devices in terms of its ability to safely store and transport a donor organ at a clinically acceptable temperature range to a recipient for transplantation.
Paragonix Kidney 510(k) Rev. B
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 23, 2014 '
Paragonix Technologies, Inc. % Leo L. Basta Owner NorthStar Biomedical Associates 93 Benefit Street Providence, RI 02904
Re: K133694
:
Trade/Device Name: Paragonix Sherpa Pak Kidney Transport System Regulation Number: 21 CFR§ 876.5880 Regulation Name: Isolated kidney perfusion and transport system and accessories Regulatory Class: II Product Code: KDN Dated: May 15, 2014 Received: May 16, 2014
Dear Leo L. Basta,
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.
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.
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Page 2 - Leo L. Basta
You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/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,
Image /page/7/Picture/7 description: The image shows the name "Herbert P. Lerner - S" in a bold, sans-serif font. The name is written in black ink on a white background. The letters are evenly spaced and easy to read. The text appears to be a signature or a title.
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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#### INDICATION FOR USE
510(k) Number (if known): K133694
Device Name: Paragonix Sherpa Pak Kidney Transport System
Indications for Use:
The Sherpa Pak Kidney Transport System is intended to be used for the static hypothermic preservation of kidney organs during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with this organ.
The Sherpa Pak Kidney Transport System can maintain the donor organ storage temperature between 4°C and 8°C through 24 hours.
Prescription Use: ____________________________________________________________________________________________________________________________________________________________ Over-The Counter Use: (Per 21 CFR 801 Subpart C) (Per 21 CFR 801 Subpart D) ...................................................................................................................................................
## (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Page 1 of 1
Image /page/8/Picture/10 description: The image shows the name "Herbert P. Lerner" in bold, black font at the top. Below the name is the date and time "2014.05.23 07:10:27 -04'00'" also in bold, black font. The text appears to be a timestamp or record of some kind.
Paragonix Kidney 510(k) Rev. B
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.