Neoss TiBase, Neoss CoCr Abutments (Mono and Multi)
Applicant
Neoss, Ltd.
Product Code
NHA · Dental
Decision Date
Oct 8, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Indications for Use
Neoss TiBase: Neoss Abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation. The Neoss TiBase is compatible with the Sirona Dental System inCoris ZI Meso L. All digitally designed copings and/or crowns for use with the Neoss TiBase Abutments are to be designed and milled using the Sirona Dental CAD/CAM System. Neoss CoCr Abutments: Neoss abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation.
Device Story
Neoss TiBase and CoCr Abutments are endosseous dental implant abutments connecting to Neoss implants (Ø3.5-5.5 mm) to support single or multi-unit prosthetic restorations. TiBase abutments are patient-specific, designed for use with Sirona Dental CAD/CAM systems to create copings/crowns; screw-retained. CoCr abutments are available in Mono (indexed, single-tooth) and Multi (non-indexed, multi-unit) designs. Components include titanium alloy (ASTM F136) or cobalt-chromium alloy (ASTM F1537) and TiN/Au-coated titanium screws. Used in dental clinics by dentists; non-sterile, requiring autoclave sterilization before use. Output is a physical interface for prosthetic crowns/bridges, aiding restoration of chewing function and aesthetics.
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical bench testing, including engineering analysis, dimensional analysis, and static/dynamic compression-bending testing per ISO 14801. Biocompatibility confirmed via material standards (ASTM F136, ASTM F1537).
Technological Characteristics
Materials: Titanium alloy (ASTM F136) and CoCr alloy (ASTM F1537). TiBase uses TiN/Au-coated titanium screws. Sterilization: Autoclave (fractionated vacuum, 135°C, 3 min exposure, 16 min dry, SAL 10^-6 per ISO 17665-1). Interface: Platform compatible with Neoss implants (4.1 mm platform). Connectivity: Mechanical interface for Sirona CAD/CAM-milled restorations.
Indications for Use
Indicated for patients requiring prosthetic rehabilitation via endosseous dental implants. Neoss TiBase supports single or multi-unit restorations using Sirona CAD/CAM systems. Neoss CoCr abutments support single or multi-unit screw- or cement-retained restorations.
Regulatory Classification
Identification
An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.
Special Controls
*Classification.* Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)
{0}------------------------------------------------
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing right, with flowing lines representing hair or clothing.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 8, 2015
Neoss Ltd. c/o Ms. Cherita James Regulatory Consultant M Squared Associates, Inc. 575 8th Avenue, Suite 1212 New York, New York 10018
Re: K150669
Trade/Device Name: Neoss TiBase and CoCr Abutments Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: II Product Code: NHA Dated: September 8, 2015 Received: September 9, 2015
Dear Ms. James:
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,
Tina
Kiang-S
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
510(k) Number (if known) K150669
Device Name Neoss TiBase and CoCr Abutments
#### Indications for Use (Describe)
Neoss TiBase:
Neoss Abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation.
The Neoss TiBase is compatible with the Sirona Dental System inCoris ZI Meso L. All digitally designed copings and/or crowns for use with the Neoss TiBase Abutments are to be designed and milled using the Sirona Dental CAD/CAM System.
Neoss CoCr Abutments:
Neoss abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
[조] Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
# 510(k) Summary Neoss Ltd. Neoss TiBase and CoCr Abutments
October 5, 2015
| | ADMINISTRATIVE INFORMATION |
|----------------------------|--------------------------------------|
| Manufacturer Name: | Neoss Ltd. |
| | Windsor House, Cornwall Rd. |
| | Harrogate, HG1 2PW, UK |
| | Telephone +46 (0) 1423 817 733 |
| | Fax +44 (0) 1423 817 744 |
| | Official Contact Karin Darle Olsson |
| | Regulatory Assurance Director |
| Representative/Consultant: | Cherita James |
| | M Squared Associates, Inc. |
| | Telephone: +1 703-562-9800 ext 257 |
| | Fax: +1 703-562-9797 |
| | Email: Cjames@MSquaredAssociates.com |
## DEVICE NAME AND CLASSIFICATION
Trade/Proprietary Name: Neoss TiBase and CoCr Abutments Common Name: Dental Implant Abutment Classification Name: Endosseous dental implant abutment Classification Regulations: 21 CFR 872.3630, Class II Product Code: NHA Classification Panel: Dental Products Panel Reviewing Branch: Dental Devices Branch
## INTENDED USE
Neoss TiBase:
Neoss Abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation.
The Neoss TiBase is compatible with the Sirona Dental System inCoris ZI Meso L. All digitally designed copings and/or crowns for use with the Neoss TiBase Abutments are to be designed and milled using the Sirona Dental CAD/CAM System.
Neoss CoCr Abutments:
Neoss abutments are designed to be connected to the Neoss Implants and intended for use as an aid in prosthetic rehabilitation.
## DEVICE DESCRIPTION
Neoss TiBase and CoCr Abutments are endosseous dental implant abutments used to support single tooth or multi-unit prosthetic restorations. All subject abutments have a platform interface that is compatible with Neoss implant diameters Ø3.5-5.5 mm. All
{4}------------------------------------------------
Neoss implant sizes have a 4.1 mm implant platform regardless of endosseous implant diameter. Neoss TiBase abutments are provided in two prosthetic platform sizes, N (narrow) and W (wide), to accommodate different emergence profiles. The Neoss TiBase Abutment are patient specific abutments intended for the coping/crown to be designed using the Sirona CAD/CAM System. The Neoss TiBase Abutment can be screw retained.
Neoss CoCr abutments are available in two designs (Mono and Multi), one prosthetic platform size and one height (15 mm). The indexed Mono abutment can be used for single tooth screw-retained or cement-retained restorations. The non-indexed Multi abutment is used for multi-unit screw-retained restorations.
Neoss Crystaloc screw in TiN/Au coated titanium is used with the Neoss TiBase and CoCr Abutments.
#### Materials
Neoss TiBase abutment and Crystaloc abutment screws are made of titanium alloy conforming to ASTM F136 Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401). Crystaloc Abutment Screw has a TiN surface and is coated with a layer of pure gold. Neoss CoCr Abutments (Mono and Multi) are made of cobalt chromium alloy (CoCr) conforming to ASTM F1537 Standard specification for wrought cobalt-28chromium-6- molybdenum alloys for surgical implants (UNS R31537, UNS R31538, AND UNS R31539).
#### Sterilization
Neoss abutments and screws are provided non-sterile. Standard autoclave sterilization is recommended, using fractionated vacuum procedures with an FDA cleared wrap, with an exposure time of 3 minutes at 135 ℃ / 275 °F with a drying time of 16 minutes. This cycle has been validated by the overkill method to a sterility assurance level (SAL) of 10-6 according to ISO 17665-1.
### PERFORMANCE DATA
Non-clinical testing data submitted, referenced, or relied upon to demonstrate substantial equivalence included: engineering analysis, dimensional analysis, and static and dynamic compression-bending testing according to ISO 14801 Dentistry-Implants-Dynamic fatigue test for endosseous dental implants. Compatibility with Sirona inCoris blocks is secured by Neoss conducting reverse engineering of the Sirona TiBase design mating the inCoris blocks. The compatability is further secured through the fact that the interface between the TiBase and the Sirona inCoris blocks is not a metal-to-ceramic interface, but includes an intervening laver of cement corresponding to a diameter difference of 0.2 mm between the TiBase and the internal geometry of the as-sintered inCoris block which is substantial compared to the small measuring and machining tolerance of TiBase which are ±0.02 mm.
Biocompatibility of the subject devices is confirmed by conformance to FDA recognized consensus material standards (titanium alloy conforming to ASTM F136, and cobalt chromium alloy conforming to ASTM F1537). The manufacturing processes and materials for the Ti Base are identical to those used for Neoss Implant System
{5}------------------------------------------------
components previously cleared in K043195. K071838 and K113376. The pure gold and process used to coat the titanium alloy Crystaloc screw are identical to the titanium and gold screw cleared in K081851. The cobalt chromium alloy (CoCr) material is substantially equivalent to the material used in K121843 NP-Cast Abutment System. No clinical data were included.
## EQUIVALENCE TO MARKETED DEVICE
Neoss Ltd. submits the following information in this Premarket Notification to demonstrate, for the purposes of FDA's regulation of medical devices, the subject device is substantially equivalent in indications and design principles to the following legally marketed predicate devices:
Neoss Ltd., Neo Implant System cleared under K043195; (primary predicate) Reference Predicates
Neoss Ltd., Neoss Various Titanium Abutments cleared under K071838;
Neoss Ltd., Neoss Tapered Implant cleared under K113376;
Neoss Ltd., Neoss Access Abutments cleared under K081851;
Sirona Dental Systems GmbH, Sirona Dental CAD/CAM System cleared under K111421;
Sirona Dental Systems GmbH, Sirona Dental CAD/CAM System cleared under K100152;
Altatec GmbH, Camlog Implant System Modified Implants and Abutments cleared under K083496; and
OSSTEM Implant Co., Ltd., NP-Cast Abutment System cleared under K121843.
Performance data showed compatibility with the Sirona inCoris ZI Meso L and sufficient strength of the final finished device for its intended use. Any differences in the technological characteristics between the subject and predicate devices do not raise different questions of safety or effectiveness.
# CONCLUSIONS
The subject device and the predicate devices have intended use, have similar technological characteristics, and are made of similar materials. The subject device and predicate devices encompass the same range of physical dimensions, including length, width, height, and angle. The subject and predicate devices are packaged in similar materials and sterilized using similar methods.
The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.
Overall, the subject device has the following similarities to the predicate devices:
- has the same intended use. ●
- uses the same operating principle, ●
- . incorporates the same basic design,
- . incorporates the same or very similar materials, and
- has similar packaging and is sterilized using the same materials and processes. .
{6}------------------------------------------------
{7}------------------------------------------------
# Substantial Equivalence Tables
| Subject Device | Indications for Use Statement | | Subject<br>Device | Predicate Devices | | | | | | | |
|-------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|-------------------------------------------|-------------------------------------|-----------------------------------------------------|--------------------------------------|---------------------------------------------|----------------------------------------------------------------------------------|----------------------------------------------------------------------------------|------------------------------------------------------------------------|-------------------------------------------|
| Neoss Ltd.<br>Neoss TiBase and CoCr Abutments | Neoss TiBase: Neoss abutments are designed to be connected to the Neoss Implants and<br>intended for use as an aid in prosthetic rehabilitation.<br><br>The Neoss TiBase is compatible with the Sirona Dental System inCoris ZI Meso L. All digitally<br>designed copings and/or crowns for use with the Neoss TiBase Abutments are to be designed<br>and milled using the Sirona Dental CAD/CAM System.<br><br>Neoss CoCr Abutments:<br>Neoss abutments are designed to be connected to the Neoss Implants and intended for use as an<br>aid in prosthetic<br>rehabilitation. | | Neoss Ltd. | Neoss Ltd. | Neoss Ltd. | Neoss Ltd. | Neoss Ltd. | Sirona Dental<br>Systems GmbH | Sirona Dental<br>Systems GmbH | Altatec<br>GmbH | Osstem Implant<br>Co., Ltd |
| Predicate Devices | | | Neoss<br>TiBase<br>and CoCr<br>Abutment | Neo<br>Implant<br>System<br>K043195 | Neoss<br>Various<br>Titanium<br>Abutment<br>K071838 | Neoss<br>Taper<br>Implant<br>K113376 | Neoss<br>Access<br>Abutment<br>s<br>K081851 | Sirona Dental<br>CAD/CAM<br>System<br>K111421 | Sirona Dental<br>CAD/CAM<br>System<br>K100152 | Camlog<br>Implant<br>System<br>Modified<br>Implants<br>and<br>Abutment | NP-Cast<br>Abutmen<br>t System<br>K121843 |
| Neoss Ltd.<br>Neo Implant System<br>K043195 (Primary Predicate) | The Neo Implants - Neo Implant System are for single-stage and two-stage surgical procedures<br>and cement or screw retained restorations. The Neo Implants - Neo Implant System are intended<br>for immediate placement and function on single tooth and /or multiple tooth applications<br>recognizing sufficient bone stability and appropriate occlusal loading, to restore<br>chewing function. Multiple tooth applications may be splinted with a bar. | Design | | | | | | | | | |
| Neoss Ltd.<br>Neoss Various Titanium Abutments<br>K071838 | The Neoss various Titanium Abutments are designed to be connected to the Neoss implants and<br>intended for use as an aid in prosthetic rehabilitation. | Implant<br>Diameter<br>(mm) | NA | 3.5, 4.0, 4.5,<br>5.0, 5.5 | NA | 3.5, 4.0,<br>5.0, 5.5 | NA | NA | NA | 3.3, 3.8, 4.3,<br>6.0 | NA |
| Neoss Ltd.<br>Neoss Tapered Implant<br>K113376 | The Neoss Tapered Implant is for single-stage or two-stage surgical procedure and cement or<br>screw retained restorations.<br><br>The Neoss Tapered Implant is intended for immediate placement and function on single tooth<br>and for multiple tooth applications recognizing sufficient bone stability and appropriate occlusal<br>loading, to restore chewing function. Multiple tooth applications may be splinted with a bar. | Abutment<br>Diameter<br>(mm) | 4.1 Interface | 4.1 Interface | 4.1 Interface | NA | 4.1 Interface | 3.3, 3.4, 3.5,<br>3.8, 4.0, 4.1,<br>4.3, 4.5, 4.8,<br>5.0, 5.5, 5.7,<br>6.0, 6.5 | 3.3, 3.4, 3.5,<br>3.8, 4.0, 4.1,<br>4.3, 4.5, 4.8,<br>5.0, 5.5, 5.7,<br>6.0, 6.5 | 3.3, 3.8, 4.3,<br>6.0 | 4.0, 4.5, 5.0, 6.3 |
| Neoss Ltd.<br>Neoss Access Abutments<br>K081851 | The Neoss Access Abutments are designed to be connected to the Neoss implants and intended<br>for use as an aid in prosthetic rehabilitation.<br><br>Neoss Access Abutments represent a two piece abutment system and are designed to be<br>connected to the Neoss implants, to receive another abutment or framework and intended for use<br>as an aid in multiple-unit prosthetic rehabilitation such as dental bridge restorations. | Abutment<br>Angle | Straight | Straight, 20° | Straight, 15°,<br>20° | NA | Straight, 10°,<br>20°, 30° | Straight to 20° | Straight to 20° | Straight, 15°,<br>20° | Straight to 30° |
| Sirona Dental Systems GmbH<br>Sirona Dental CAD/CAM System<br>K111421 | The Sirona Dental CAD/CAM System is intended for use in partially or fully edentulous<br>mandibles and maxillae in support of single or multiple-unit cement retained restorations. The<br>system consists of three major parts: TiBase, InCoris mesostructure, and CAD/CAM software.<br>Specifically, the InCoris mesostructure and TiBase components make up a twopiece<br>abutment which is used in conjunction with endosseous dental implants to restore the function<br>and aesthetics in the oral cavity. The InCoris mesostructure may also be used in conjunction<br>with the Camlog Titanium base CAD/CAM (types K2244.xxxx) (K083496) in the Camlog<br>Implant System. The CAD/CAM software is intended to design and fabricate the<br>InCoris mesostructure. The InCoris mesostructure and TiBase two-piece abutment is compatible<br>with the following implant systems: | Prosthesis<br>Attachment | TiBase: Screw<br>CoCr: Screw or<br>Cement | Screw- or<br>Cement<br>retain | Screw- or<br>Cement<br>retain | NA | Screw-<br>retained | Cement<br>retained | Cement<br>retained | Screw-<br>retained,<br>Cement-<br>retained | Screw-retained,<br>Cement-<br>retained |
| Sirona Dental Systems GmbH<br>Sirona Dental CAD/CAM System<br>K100152 | • Nobel Biocare Replace (K020646) • Nobel Biocare Branemark (K022562)<br>• Friadent Xive (K013867) • Biomet 3i Osseotite (K980549) • Astra Tech Osseospeed (K091239) | Restoration | Single, Multi | Single, Multi | Single, Multi | NA | Multi | Single, Multi | Single, Multi | Single, Multi | Single,Multi |
| Sirona Dental Systems GmbH<br>Sirona CAD/CAM System<br>K100152 (cont.) | The Sirona Dental CAD/CAM System is intended for use in partially or fully edentulous mandibles and maxillae in support of single or multiple-unit cement retained restorations. The system consists of three major parts: TiBase, InCoris mesostructure, and CAD/CAM software. Specifically, the InCoris mesostructure and TiBase components make up a twopiece abutment which is used in conjunction with endosseous dental implants to restore the function and aesthetics in the oral cavity. The InCoris mesostructure may also be used in conjunction with the Camlog Titanium base CAD/CAM (types K2244.xxxx) (K083496) in the Camlog Implant System. The CAD/CAM software is intended to design and fabricate the InCoris mesostructure. The InCoris mesostructure and TiBase two-piece abutment is compatible with the following implants systems:<br>• Nobel Biocare Replace (K020646) • Nobel Biocare Branemark (K022562)<br>• Friadent Xive (K013867) • Biomet 3i Osseotite (K980549)<br>• Astra Tech Osseospeed (K091239) • Zimmer Tapered Screw-Vent (K061410)<br>• Straumann SynOcta (K061176) | Material | | | | | | | | | |
| Altatec GmbH<br>Camlog Implant System<br>Modified Implants and Abutments<br>K083496 | Camlog Implant System implants are intended for immediate or delayed placement in the bone of the maxillary or mandibular arch. Camlog Implant System Abutments are intended for use as support for crowns, bridges or overdentures.<br>When a one-stage surgical approach is applied, the implant may be immediately loaded when good primary stability is achieved and the functional load is appropriate. | Abutment | Ti6Al4V,<br>CoCr | CpTi<br>Gr4,<br>Ti6Al4V, | CpTi<br>Gr4,<br>Ti6Al4V | NA | CpTi Gr4,<br>Ti6Al4V,<br>Au | Ti6Al4V,<br>Y-TZP | Ti6Al4V,<br>Y-TZP | CpTi Gr4,<br>Ti6Al4V,<br>Y-TZP, | Co-Cr-Mo<br>Alloy |
| OSSTEM Implant Co., Ltd.<br>NP-Cast Abutment System<br>K121843 | NP-Cast Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures. | Abutment<br>Screw | Ti6Al4V,<br>TiN/Au | Ti6Al4V, Au | Ti6Al4V | NA | Ti6Al4V, Au,<br>TiN/Au | Ti6Al4V | Ti6Al4V | Ti6Al4V | Ti6Al4V |
| Bonding<br>Material | TiBase:<br>PANAVIA F<br>2.0 | NA | PANAVIA F<br>2.0 | NA | NA | PANAVIA F 2.0 | PANAVIA F 2.0 | NA | NA | | |
{8}------------------------------------------------
{9}------------------------------------------------
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.