The device is intended to be used to provide an artificial airway in order to provide access to the patient's airway for airway management. When inserted in a tracheotomy stoma, the device is secured in place with a neck strap around the patient's neck which is attached to an integral neck plate, thereby providing for a secure artificial airway for spontaneous breathing or direct hook-up to ventilation or anesthesia equipment.
Device Story
Dual cannula tracheostomy tube; disposable inner cannula; provides artificial airway for spontaneous breathing or mechanical ventilation/anesthesia. Used in clinical environments (critical/non-critical care, long-term care, home). Inserted into tracheotomy stoma; secured via neck strap or suture holes in flange. Features: radiopaque PVC outer cannula; pliable neck plate; tapered tip for percutaneous insertion; integrated 15mm connector. TaperGuard cuff version includes low-pressure cuff with inflation line/luer valve/pilot balloon to seal airway and minimize tracheal damage. Translucent inner cannula allows inspection/maintenance. Physician/clinician-operated; facilitates airway access; benefits patient by maintaining secure airway.
Clinical Evidence
No clinical data. Substantial equivalence established via bench testing, including ISO 5356-1:2004, ISO 5366-1:2009, ISO 5361:2012, biocompatibility (cytotoxicity, sensitization, irritation, acute systemic toxicity, genotoxicity, subchronic toxicity), and performance testing (cuff pressure mapping, flange tie, air leak, inflation line pull, cuff puncture, insertion/removal, percutaneous compatibility).
Technological Characteristics
Materials: Medical grade PVC with citrate/DEHT plasticizers; Polymethylpentene (TPX) 15mm connector; Polypropylene obturator; Cotton tie strap. Design: Dual cannula, flexible molded flange, tapered tip. Energy: None (passive). Connectivity: None. Sterilization: Validated cycle (SAL 10E-6). Standards: ISO 5366-1:2009, ISO 5356-1:2004, ISO 5361:2012.
Indications for Use
Indicated for adult patients requiring an artificial airway for tracheal access and airway management. The TaperGuard cuff version is also indicated for use with Cook Percutaneous Dilatational Tracheotomy (PDT) procedures.
Regulatory Classification
Identification
A tracheostomy tube and tube cuff is a device intended to be placed into a surgical opening of the trachea to facilitate ventilation to the lungs. The cuff may be a separate or integral part of the tracheostomy tube and is, when inflated, intended to establish a seal between the tracheal wall and the tracheostomy tube. The cuff is used to prevent the patient's aspiration of substances, such as blood or vomit, or to provide a means for positive-pressure ventilation of the patient. This device is made of either stainless steel or plastic.
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Image /page/0/Picture/1 description: The image shows the seal of the U.S. Department of Health and Human Services. The seal features the department's name in a circular arrangement around a stylized symbol. The symbol consists of a stylized caduceus, which is a staff with two snakes coiled around it, and a stylized human figure.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 24, 2015
Covidien Brianna Reynolds Regulatory Affairs Specialist 6135 Gunbarrel Avenue Boulder, CO 80301
Re: K142296
> Trade/Device Name: Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula; Shiley™ Adult Flexible Tracheostomy Tube with TaperGuardTM Cuff, Disposable Inner Cannula Regulation Number: 21 CFR 868.5800 Regulation Name: Tracheostomy Tube and Tube Cuff Regulatory Class: II Product Code: JOH Dated: January 22, 2015 Received: January 23, 2015
Dear Ms. Reynolds,
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.
{1}------------------------------------------------
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 devicerelated 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 Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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,
Teiashri 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
{2}------------------------------------------------
## Indications for Use Statement
K142296 510(k) Number (if known):
Device Name:
Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula
Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff, Disposable Inner Cannula
## Indications for Use:
- Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula is ● intended for use in providing tracheal access for airway management.
- . Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff, Disposable Inner Cannula is intended for use in providing tracheal access for airway management.
- Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff, Disposable Inner . Cannula is also intended for use with Cook® Percutaneous Dilatational Tracheotomy (PDT) procedures.
- o The Shiley™ Disposable Inner Cannula is intended to be used with the appropriate Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff or Cuffless to provide tracheal access for airway management.
Prescription Use X (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C)
> (PLEASE DO NOT WRITE BELOW THIS LINE -CONTINUE ON ANOTHER PAGE IF NEEDED)
# CONCURRENCE OF CDRH, OFFICE OF DEVICE EVALUATION (ODE)
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Image /page/3/Picture/0 description: The image contains the word "COVIDIEN" in a sans-serif font. The word is in blue and is positioned to the right of a blue and white square logo. The logo consists of a dark blue square with a light blue vertical line and a white rectangle in the center.
## 510(k) Summary
Date summary prepared 23 February 2015
## 510(k) Submitter/Holder
Covidien IIc 6135 Gunbarrel Avenue Boulder, CO 80301
### Contact
Danielle Mueller Regulatory Affairs Manager Phone: 303-305-2603 Fax: 303-305-2212
### Name of Device
| Trade Name: | Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula<br>Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable<br>Inner Cannula |
|----------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Catalog Numbers: | xUNxx and xCNxx |
| Common Name: | Tube Tracheostomy and Tube Cuff |
| Classification Name: | JOH, Tube Tracheostomy and Tube Cuff (21 CFR 868.5800) Class II, 73-<br>Anesthesiology |
## Purpose of Submission
The purpose of this submission is to introduce the Covidien Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula and Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula. The subject and predicate device have the submission is to notify the FDA of the following changes:
- Updated the materials used in the Tracheostomy tubes to a Medical Grade PVC ● with a citrate and DEHT based plasticizer
- . Addition of the Covidien taper-shaped cuff referred to as TaperGuard
- Tapered tracheostomy tube tip compatible with percutaneous insertion ●
- Line extension to include 3 intermediate sizes for cuffed and cuffless .
- Integrated ISO compliant 15 mm connector
- Flexible molded flange ●
{4}------------------------------------------------
## Predicate Device
The Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula and the Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula were compared and found to be substantially equivalent to the following products of comparable type in commercial distribution:
| Trade Name: | Shiley ™ Tracheostomy Tubes |
|---------------------|----------------------------------------------------------|
| Device Common Name: | Tube Tracheostomy and Tube Cuff |
| 510(k) Number: | K962173 |
| Manufacturer: | Covidien, formerly Tyco Healthcare |
| Trade Name: | Shiley™ DCT Adult Cuffed Percutaneous Tracheostomy Tubes |
| Device Common Name: | Tube Tracheostomy and Tube Cuff |
| 510(k) Number: | K963732 |
| Manufacturer: | Covidien, formerly Tyco Healthcare |
## Intended Use
The device is intended to be used to provide an artificial airway in order to provide access to the patient's airway for airway management. When inserted in a tracheotomy stoma, the device is secured in place with a neck strap around the patient's neck which is attached to an integral neck plate, thereby providing for a secure artificial ainway for spontaneous breathing or direct hook-up to ventilation or anesthesia equipment.
## Indications for Use
- . Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula is intended for use in providing tracheal access for airway management.
- Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff, Disposable Inner . Cannula is intended for use in providing tracheal access for airway management.
- . Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff. Disposable Inner Cannula is also intended for use with Cook® Percutaneous Dilatational Tracheotomy (PDT) procedures.
- The Shiley™ Disposable Inner Cannula is intended to be used with the appropriate Shiley™ . Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff or Cuffless to provide tracheal access for airway management.
{5}------------------------------------------------
### De vice De scription
The Shiley ™ Adult Flexible Tracheostomy Tube Cuffless is a dual cannula tracheostomy tube with a disposable inner cannula. The device is used to provide an artificial ainway in order to provide access to the patient's airway for airway management. It contains an integrated 15 mm connector for use with standard ventilation and anesthesia equipment. The tracheostomy tube has a radiopaque outer cannula constructed of polyvinyl chloride. A pliable neck plate allows conformity to individual neck anatomies and contains two suture holes. The tapered tracheostomy tube tip is compatible with percutaneous insertion. The smooth, rounded tip obturator facilitates insertion. The disposable inner cannula is translucent for easy inspection and allows for airway maintenance. This tracheostomy tube can be used with or without the disposable inner cannula included in the package however, use of the inner cannula is recommended.
The Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff is a dual cannula tracheostomy tube with a disposable inner cannula. The device is used to provide an artificial airway in order to provide access to the patient's airway management. It contains an intecrated 15 mm connector for use with standard ventilation and anesthesia equipment. The Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff has a radiopaque outer cannula constructed of polyvinyl chloride. A pliable neck plate allows conformity to individual neck anatomies and contains two suture holes. The tapered tracheostomy tube tip is compatible with percutaneous insertion. The smooth, rounded tip obturator facilitates insertion. The disposable inner cannula is translucent for easy inspection and allows for airway maintenance. The tracheostomy tube has a taper-shaped, low-pressure cuff to provide an effective air and fluid seal and minimize tracheal wall damage. The cuff inflation line has a luer valve with an integral pilot balloon. The Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard™ Cuff can be used with or without the disposable inner cannula included in the package however, use of the inner cannula is recommended.
When inserted in a tracheotomy stoma, the device may be secured in place with a neck strap around the patient's neck which is attached to an integral neck plate. It also may be secured in place by using the suture holes in the flange of the tracheostomy tube, thereby providing for a secure artificial ainway for spontaneous breathing or direct connection to ventilation or anesthesia equipment.
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| | Subject Device: | Predicate Device | Predicate Device |
|---------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Shiley ™ Adult Flexible Tracheostomy Tube<br>Cuffless, Disposable Inner Cannula and Shiley ™<br>Adult Flexible Tracheostomy Tube with<br>TaperGuard™ Cuff, Disposable Inner Cannula | Shiley ™ Tracheostomy Tubes<br>(K962173)<br>(Cuffless and Cuffed) | Shiley ™ DCT Adult Cuffed Percutaneous<br>Tracheostomy Tubes (K963732) |
| | | | |
| Indications for<br>Use | Shiley ™ Adult Flexible Tracheostomy Tube<br>Cuffless, Disposable Inner Cannula is intended for<br>use in providing tracheal access for airway<br>management. | This device is intended for use in providing<br>tracheal access for airway management. | This device is intended for use in providing<br>tracheal access for airway management.<br>The device is primarily intended for use in |
| | Shiley ™ Adult Flexible Tracheostomy Tube with<br>TaperGuard™ Cuff, Disposable Inner Cannula is<br>intended for use in providing tracheal access for<br>airway management. | | conjunction with Percutaneous Dilatational<br>Tracheostomy and is inserted into the patient<br>using the introducer provided with the<br>Percutaneous kit. |
| | The Shiley ™ Disposable Inner Cannula is<br>intended to be used with the appropriate Shiley ™<br>Adult Flexible Tracheostomy Tube with<br>TaperGuard™ Cuff or Cuffless to provide<br>tracheal access for airway management. | | |
| | Shiley ™ Adult Flexible Tracheostomy Tube with<br>TaperGuard™ Cuff, Disposable Inner Cannula is<br>also intended for use with Cook® Percutaneous<br>Dilatational Tracheotomy (PDT) procedures. | | |
| Intended Use | The device is intended to be used to provide and<br>artificial airway in order to provide access to the<br>patient's airway for airway management. When<br>inserted in a tracheotomy stoma, the device is<br>secured in place with a neck strap around the<br>patient's neck which is attached to an integral neck<br>plate, thereby providing for a secure artificial<br>airway for spontaneous breathing or direct hook-<br>up to ventilation or anesthesia equipment. | The device is intended to be used to provide and<br>artificial airway in order to provide access to the<br>patient's airway for airway management. When<br>inserted in a tracheotomy stoma, the device is<br>secured in place with a neck strap around the<br>patient's neck which is attached to an integral<br>neck plate, thereby providing for a secure artificial<br>airway for spontaneous breathing or direct hook-<br>up to ventilation or anesthesia equipment | The device is intended to be used to provide<br>and artificial airway in order to provide access to<br>the patient's airway for airway management.<br>When inserted in a tracheotomy stoma, the<br>device is secured in place with a neck strap<br>around the patient's neck which is attached to<br>an integral neck plate, thereby providing for a<br>secure artificial airway for spontaneous<br>breathing or direct hook-up to ventilation or<br>anesthesia equipment |
| Device class | Class 2 | Class 2 | Class 2 |
| Product code | JOH | JOH | JOH |
| Patient<br>Population | Adult patients requiring an artificial airway | Adult patients requiring an artificial airway | Adult patients requiring an artificial airway |
| Environment of<br>Use | The product shall be used in a clinical environment<br>such as critical care units of a hospital, non-critical<br>care units of a hospital, long term care facilities<br>and home care. | The product shall be used in a clinical<br>environment such as critical care units of a<br>hospital, non-critical care units of a hospital, long<br>term care facilities and home care. | The product shall be used in a clinical<br>environment such as critical care units of a<br>hospital, non-critical care units of a hospital,<br>long term care facilities and home care. |
| Invasive / Non-<br>Invasive | Invasive | Invasive | Invasive |
| Sterilization | Sterile: The SAL is 10E-6 utilizing the existing<br>equivalent validated cycle 2. | Sterile: The SAL is 10E-6 utilizing the existing<br>validated cycle 66. | Sterile: The SAL is 10E-6 utilizing the existing<br>validated cycle 66. |
| Shelf Life | 2-year shelf life | 5-year shelf life | 5-year shelf life |
| Materials | | | |
| Cannula | Medical Grade PVC with a citrate Based plasticizer | Medical Grade PVC | Medical Grade PVC |
| Neck Plate | Medical Grade PVC with a citrate based plasticizer | Medical Grade PVC | Medical Grade PVC |
| 15 MM connector | Polymethylpentene - TPX | Medical Grade PVC | Medical Grade PVC |
| Cuff if applicable<br>by product type | Medical Grade PVC with a DEHT based plasticizer | Medical Grade PVC | Medical Grade PVC |
| Inflation System | Medical Grade PVC with a citrate based plasticizer | Medical Grade PVC and<br>Acrylonitrile butadiene styrene (ABS) | Medical Grade PVC and<br>Acrylonitrile butadiene styrene (ABS) |
| Obturator | Medical Grade Polypropylene | Medical Grade Polypropylene | Medical Grade Polypropylene |
| Tie Strap | Cotton | Cotton | Cotton |
{7}------------------------------------------------
| Subject Device | | | | Predicate Device | | | | Predicate Device | | | | | | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------|---------|---------|-------------------------------------------------------------------|---------|---------------------------------|-----------------------------------------------------------|------------------------------------------------------------------------|-------------|---------|---------|------------------|-------------|--|
| Shiley ™ Adult Flexible Tracheostomy Tube<br>Cuffless, Disposable Inner Cannula and Shiley ™<br>Adult Flexible Tracheostomy Tube with<br>TaperGuard ™ Cuff, Disposable Inner Cannula | | | | Shiley ™ Tracheostomy Tubes<br>(K962173)<br>(Cuffless and Cuffed) | | | | Shiley ™ DCT Adult Cuffed Percutaneous<br>Tracheostomy Tubes (K963732) | | | | | | |
| Sizes | | | | Cuffless: | | | | | | | | | | |
| | REF | ID (mm) | OD (mm) | Length (mm) | REF | ID (mm) | OD (mm) | Length (mm) | REF | ID (mm) | OD (mm) | Length (mm) | Flange (mm) | |
| | 4UN65A | 6.5 | 9.4 | 62 | 4DCT | 5.0 | 9.4 | 62 | 6PERC | 6.4 | 10.8 | 74 | 24.1 | |
| | 5UN70A | 7.0 | 10.1 | 68 | 6DCT | 6.4 | 10.38 | 74 | 8PERC | 7.6 | 12.2 | 79 | 27.2 | |
| | 6UN75A | 7.5 | 10.8 | 74 | 8DCT | 7.6 | 12.2 | 79 | | | | | | |
| | 7UN80A | 8.0 | 11.4 | 77 | 10DCT | 8.9 | 13.8 | 79 | | | | | | |
| | 8UN85A | 8.5 | 12.2 | 79 | | | | | | | | | | |
| | 9UN90A | 9.0 | 12.7 | 79 | Cuffed: | REF | ID (mm) | OD (mm) | Length (mm) | Flange | | | | |
| | 10UN10A | 10.0 | 13.8 | 79 | | | | | | | | | | |
| | Cuffed: | | | | | | | | | | | | | |
| | REF | ID (mm) | OD (mm) | Length (mm) | | | | | | | Flange | | | |
| | 4CN65A | 6.5 | 9.4 | 62 | | | | | | | 20.6 | | | |
| | 5CN70A | 7.0 | 10.1 | 68 | | | | | | | 25.4 | | | |
| | 6CN75A | 7.5 | 10.8 | 74 | 25.4 | 4DCFS | 5.0 | 9.4 | 62 | 20 | | | | |
| | 7CN80A | 8.0 | 11.4 | 77 | 25.4 | 6DCFS | 6.4 | 10.38 | 74 | 24 | | | | |
| | 8CN85A | 8.5 | 12.2 | 79 | 28.6 | 8DCFS | 7.6 | 12.2 | 79 | 27 | | | | |
| | 9CN90A | 9.0 | 12.7 | 79 | 28.6 | 10DCFS | 8.9 | 13.8 | 79 | 29 | | | | |
| | 10CN10A | 10.0 | 13.8 | 79 | 28.6 | Percutaneous<br>Compatible Size | Cuffed:<br>-4CN65<br>-5CN70<br>-6CN75<br>-7CN80<br>-8CN85 | | | | NA | 6 PERC<br>8 PERC | | |
| Percutaneous<br>Compatible Size | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | Cuffless:<br>-4UN65<br>-5UN70<br>-6UN75<br>-7UN80<br>-8UN85 | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| | | | | | | | | | | | | | | |
| Use | Single Patient Use | | | Single Patient Use | | | | Single Patient Use | | | | | | |
| Design | Tracheostomy Tube Design | | | Tracheostomy Tube Design | | | | Tracheostomy Tube Design | | | | | | |
| Standards met | ISO 5366-1:2009 Anesthetic and Respiratory<br>Equipment -- Tracheostomy Tubes -- Part 1: Adult<br>Tracheostomy Tubes | | | 5356 (1987)<br>5366 (1985) | | | | 5356 (1987)<br>5366 (1985) | | | | | | |
| | ISO 5356-1:2004 Anesthetic and respiratory<br>equipment - Conical connectors: Part 1: Cones<br>and sockets | | | | | | | | | | | | | |
| | ISO 5361: 2012<br>Anesthetic and respiratory equipment-Tracheal<br>tubes and connectors | | | | | | | | | | | | | |
{8}------------------------------------------------
## Technological Characteristics
The Covidien Shiley™ Adult Flexible Tracheostomy Tube Cuffless. Disposable Inner Cannula and the Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula have technological characteristics that differ from its predicates.
The materials used in the Covidien Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula and the Shiley™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula have been updated to a Medical Grade PVC with a Citrate and DEHT plasticizer. The subject device includes the addition of the Covidien taper-shaped cuff referred to as TaperGuard. A flexible molded flange with an integrated 15mm connector was designed into the tracheostomy tube. A one piece disposable inner cannula was designed to facilitate use of the tracheostomy tube both with and without the inner cannula in place. Finally, a product line extension has been added to include 3 intermediate sizes of cuffed and cuffless product. All other fundamental technological characteristics are identical to the predicate devices.
## Non-Clinical Data
The following types of non-clinical testing were performed to establish substantial equivalence to the predicates:
- -ISO 5356-1:2004
- ISO 5366-1:2009 -
- -ISO 5361:2012
- Biocompatibility: -
- Cytotoxicity o
- Sensitization O
- Irritation o
- Acute systemic toxicity O
- Genotoxicity O
- Subchronic toxicity implantation O
- Chemical characterization O
- Risk assessment O
- Performance testing:
- O Cuff pressure mapping
- Flange tape tie O
- Air leak O
- Inflation line pull tests O
- Cuff puncture & air seal tests O
- Insertion/removal tests O
- Percutaneous compatibility O
The results of these non-clinical tests show that the subject device can be considered substantially equivalent to the legally marketed predicate and no new questions of safety and efficacy have been raised.
# Clinical Data
-
Not required to show substantial equivalence.
{9}------------------------------------------------
### Substantial Equivalence
The Covidien Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula and the Shiley ™ Adult Flexible Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula have the same fundamental technology and design of the predicate Shiley ™ Tracheostomy Tubes (K962173) and the Shiley™ DCT Adult Cuffed Percutaneous Tracheostomy Tubes (K963732). The materials on the tracheostomy tube have been updated to include a medical grade PVC with citrate and DEHT based plasticizer. A tapered tracheostomy tube tip is compatible with percutaneous insertion has been included. The subject device also includes the addition of the Covidien taper-shaped cuff referred to as TaperGuard.
The changes in the Covidien Shiley™ Adult Flexible Tracheostomy Tube Cuffless, Disposable Inner Cannula and the Shiley™ Tracheostomy Tube with TaperGuard Cuff, Disposable Inner Cannula do not impact the safety or effectiveness of the finished device.
## Conclusion
Substantial equivalence of the subject device is shown through performance testing, as stated above. The subject and predicate devices have similar indications, size range, intended use, environment of use, and patient population. The subject and predicate devices differ in number of sizes available, taper shape, materials and enhanced basic design. No new questions of safety and effectiveness have been raised. From the evidence presented in the Premarket Notification, the subject device can be considered substantially equivalent.
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.