K140102 · Vasocom, Inc. · DSB · Feb 12, 2014 · Cardiovascular
Device Facts
Record ID
K140102
Device Name
PHYSIOFLOW Q-LINK
Applicant
Vasocom, Inc.
Product Code
DSB · Cardiovascular
Decision Date
Feb 12, 2014
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.2770
Device Class
Class 2
Indications for Use
Indicated for use in adults only. The PhysioFlow Q-Link noninvasively measures cardiac output and other related cardiac parameters. These parameters include: CI (Cardiac Index), CO (Cardiac Output), CTI (Contractility Index), dZ / dt max (Maximum value dZ / dt), EDV (End Diastolic Volume), EF (Ejection Fraction), HR (Heart Rate), LCWI (Left Cardiac Work Index), PEP (Pre-Ejection Period), SV (Stroke Volume), SVR (Systemic Vascular Resistance), SVRI (Systemic Vascular Resistance Index), TFI (Thoracic Fluid Index), VET (Ventricular Ejection Time), ZO (Base Impedance). The PhysioFlow Q-Link is intended for use under the direct supervision of a licensed healthcare practitioner or personnel trained in its proper use within a hospital or facility providing healthcare.
Device Story
PhysioFlow Q-Link is a noninvasive hemodynamic monitor using thoracic electrical bioimpedance. Device connects to patient via six-lead cable and silver/silver chloride skin electrodes. Electronic unit transmits data via USB to host computer running PhysioFlow PF107 software. Software performs signal processing, parameter computation, display, and report generation. Used in hospitals/healthcare facilities by trained personnel. Provides real-time cardiac output and hemodynamic metrics to assist clinicians in patient assessment and decision-making.
Clinical Evidence
Bench testing only. Design verification tests were performed on representative samples per product development and risk management plan. All tests met pre-specified acceptance criteria.
Technological Characteristics
Thoracic electrical bioimpedance monitor. Uses silver/silver chloride skin electrodes. Wired USB connectivity to host PC. Software-based signal processing and computation. Portable, lightweight electronic unit. Excludes battery, on-board storage, and wireless features present in predicate. Operates with PhysioFlow PF107 software.
Indications for Use
Indicated for use in adults only for noninvasive measurement of cardiac output and related hemodynamic parameters (CI, CO, CTI, dZ/dt max, EDV, EF, HR, LCWI, PEP, SV, SVR, SVRI, TFI, VET, ZO) under supervision of trained healthcare personnel in clinical facilities.
Regulatory Classification
Identification
An impedance plethysmograph is a device used to estimate peripheral blood flow by measuring electrical impedance changes in a region of the body such as the arms and legs.
Special Controls
*Classification.* Class II (special controls). The device, when it is a body composition analyzer which is not intended to diagnose or treat any medical condition, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
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## 510(k) SUMMARY
# FEB 1 2 2014
This 510(k) summary is submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.87
| Establishment Registration Number: | 3005467960 |
|------------------------------------|-----------------------------------------------|
| Address of Manufacturer: | 2014 Ford Road, Unit G |
| | Bristol, PA 19007 |
| Contact Person: | James Gunnerson |
| | President |
| Date Prepared: | December 20, 2013 |
| Trade or Proprietary Name: | PhysioFlow Q-Link |
| Common or Usual Name: | Noninvasive hemodynamic monitor |
| Classification Name: | Impedance plethysmograph (21 CFR 870.2770) |
| | Product code: DBS (plethysmograph, impedance) |
| | Class II |
| Predicate Device Identification: | PhysioFlow Enduro Model PF07 (K103283) |
## Device Description:
The PhysioFlow Q-Link is a noninvasive, hemodynamic monitor that utilizes thoracic electrical bioimpedance technology to measure cardiac output and related cardiac parameters. It consists of a small, portable, lightweight electronic unit that attaches to the patient via a six lead, patient cable using commercially available silver/silver chloride skin electrodes. Monitor data is transmitted to a host computer running the PhysioFlow PF107 software. Communication to the
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host computer is via USB wired technology. The PhysioFlow PF107 software performs multiple tasks including signal processing and analysis, measured parameter computation, user interface display and control, measurement process control, event marker management, and output display/report generation. Available accessories include the patient and USB cables.
## Indications for Use:
Indicated for use in adults only.
The PhysioFlow Q-Link noninvasively measures cardiac output and other related cardiac parameters. These parameters include:
| CI | Cardiac Index |
|-------------|------------------------------------|
| CO | Cardiac Output |
| CTI | Contractility Index |
| dZ / dt max | Maximum value dZ / dt |
| EDV | End Diastolic Volume |
| EF | Ejection Fraction |
| HR | Heart Rate |
| LCWI | Left Cardiac Work Index |
| PEP | Pre-Ejection Period |
| SV | Stroke Volume |
| SVR | Systemic Vascular Resistance |
| SVRI | Systemic Vascular Resistance Index |
| TFI | Thoracic Fluid Index |
| VET | Ventricular Ejection Time |
| ZO | Base Impedance |
The PhysioFlow O-Link is intended for use under the direct supervision of a licensed healthcare practitioner or personnel trained in its proper use within a hospital or facility providing healthcare.
#### Intended use and comparison to predicate devices:
The PhysioFlow O-Link and PhysioFlow Enduro Model PF-07 have the same intended for use/indications for use. Both devices are intended for use in adults only to noninvasively measure cardiac output and other related cardiac parameters, including the following: cardiac output, cardiac index, contractility index, maximum value dZ/dt, end diastolic volume, ejection fraction, heart rate, left cardiac work index, pre-ejection period, stroke volume, systemic vascular resistance, systemic vascular resistance index, thoracic fluid index, ventricular ejection time, and base impedance. Both devices are intended for use under the direct supervision of a licensed
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practitioner or personnel trained in its proper use within a hospital or facility providing healthcare.
## Technological characteristics and comparison to predicate devices:
The PhysioFlow Q-Link is a modification of the PhysioFlow Enduro Model PF-07. It utilizes the same thoracic electrical bioimpedance technology to measure the same cardiac output and related cardiac parameters. It remains similar to the predicate device in size, but excludes the battery power source, on-board data storage, and wireless Bluetooth technology features of the predicate device. The PhysioFlow Q-Link will fill a position amongst the PhysioFlow family of devices for users who find the battery life or wireless communication features of the PhysioFlow Enduro Model PF-07 to be inconvenient or cumbersome, but still desire a small, portable unit. Like the PhysioFlow Enduro Model PF-07, the PhysioFlow Q-Link continues to interface with a MS Windows based host computer running the previously-cleared PhysioFlow PF107 software (K103283). No changes to the PhysioFlow PF107 software were required to enable its use with the PhysioFlow Q-Link.
The differences in technological characteristics between the subject and predicate devices do not raise new types of safety or effectiveness questions. Accepted scientific methods, such as performance (bench) testing, do exist for assessing the effect of the differences in characteristics.
## Summary of performance data:
1
Design verification tests were performed on representative samples of the PhysioFlow O-Link as a result of a comprehensive product development and risk management plan. All tests were verified to meet the pre-specified acceptance criteria. As such, the PhysioFlow Q-Link is considered substantially equivalent to the PhysioFlow Enduro Model PF-07.
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Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal features an eagle-like symbol with three curved lines representing wings or feathers. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the symbol.
Public Health Service
February 12, 2014
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
Vasocom, Inc. Mr. James Gunnerson President 2014 Ford Rd., Unit G Bristol, PA 19007 US
Re: K140102
> Trade/Device Name: Physioflow Q-link Regulation Number: 21 CFR 870.2770 Regulation Name: Noninvasive Hemodynamic Monitor Regulatory Class: Class II (two) Product Code: DSB Dated: January 14, 2014 Received: January 15, 2014
Dear Mr. James Gunnerson:
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. You must
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Page 2 - Mr. James Gunnerson
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.htmfor 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,
Owen-PFaris -S
for
Bram D. Zuckerman. M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
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Vasocom, Inc.
K140102 Page 1 of 1
# Indications for Use
510(k) Number (if known):
PhysioFlow Q-Link Device Name:
Indications for Use:
Indicated for use in adults only.
The PhysioFlow Q-Link noninvasively measures cardiac output and other related cardiac parameters. These parameters include:
| CI | Cardiac Index |
|-------------|------------------------------------|
| CO | Cardiac Output |
| CTI | Contractility Index |
| dZ / dt max | Maximum value dZ / dt |
| EDV | End Diastolic Volume |
| EF | Ejection Fraction |
| HR | Heart Rate |
| LCWI | Left Cardiac Work Index |
| PEP | Pre-Ejection Period |
| SV | Stroke Volume |
| SVR | Systemic Vascular Resistance |
| SVRI | Systemic Vascular Resistance Index |
| TFI | Thoracic Fluid Index |
| VET | Ventricular Ejection Time |
| ZO | Base Impedance |
The PhysioFlow Q-Link is intended for use under the direct supervision of a licensed healthcare practitioner or personnel trained in its proper use within a hospital or facility providing healthcare.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
## Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use: ____________________________________________________________________________________________________________________________________________________________ (21 CFR 801 Subpart D)
AND/OR
Over-the-Counter Use: _ (21 CFR 807 Subpart C)
Digitally signed by
Owen P. Faris -S
Date: 2014.02.11
16:04:51-05'00'
l
Special 510(k) - PhysioFlow Q-Link December 31, 2013
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.