An instant warm pack intended to be used on an infant's heel to increase blood circulation to the area to aid in the drawing of blood for analysis. It is a single use, non-toxic, non-sterile, disposable warmer. The device is primarily used in hospitals, doctor's offices, and other healthcare facilities.
Device Story
Single-use, non-sterile, disposable instant warm pack; used in hospitals and clinics to increase blood circulation to infant heels for blood sampling. Device consists of biaxially oriented nylon/polyethylene pouch containing supersaturated sodium acetate solution (liquid version) or sodium acetate/water/hydroxyethylcellulose (gel version). Activation via flexing internal stainless steel disc initiates exothermic crystallization, generating heat (max peak 107°F). Adhesive tape secures device to infant heel. Healthcare providers apply device to patient; heat aids blood draw. Benefits include improved blood flow for easier sampling and reduced risk of thermal injury.
Clinical Evidence
No human clinical data. Bench testing included temperature profile comparisons against predicate (thermocouple measurements at 5-second intervals for 30 minutes) and shelf-life stability testing. Biocompatibility testing performed per AAMI/ANSI/ISO 10993-5:2003 and 10993-10:2010. Animal study (n=6 pigs) evaluated thermal insult and erythema; results showed no thermal injury and negligible erythema (scores 0-1).
Indicated for infants requiring increased blood circulation to the heel to facilitate blood collection for analysis.
Regulatory Classification
Identification
A hot or cold disposable pack is a device intended for medical purposes that consists of a sealed plastic bag incorporating chemicals that, upon activation, provides hot or cold therapy for body surfaces.
Predicate Devices
Rapid Aid Instant Disposable Infant Heel Warmer - Disc (K150627)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 18, 2016
CooperSurgical Inc. c/o Roaida Johnson Associate Director, New Product Development 95 Corporate Drive Trumbull, CT 06611
Re: K151845
Trade/Device Name: Infant Heel Warmer (Model 24401) and WarmGel Infant Heel Warmer (Model 20418) Regulation Number: 21 CFR 890.5710 Regulation Name: Hot or cold disposable pack Regulatory Class: Class I Product Code: MPO Dated: February 16, 2016 Received: February 17, 2016
Dear Ms. Johnson:
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 comply with all the Act's requirements, including, but not limited to: registration and listing (21
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CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of 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/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of 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,
# Michael J.Hoffmann -A
Carlos L. Peña, PhD, MS for Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K151845
Device Name Infant Heel Warmer (Model 24401) WarmGel® Infant Heel Warmer (Model 20418)
#### Indications for Use (Describe)
An instant warm pack intended to be used on an infant's heel to increase blood circulation to the area to aid in the drawing of blood for analysis. It is a single use, non-toxic, non-sterile, disposable warmer.
The device is primarily used in hospitals, doctor's offices, and other healthcare facilities.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|
| <span style="font-family: sans-serif;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: sans-serif;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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## K151845
Image /page/3/Picture/1 description: The image shows the logo for CooperSurgical. The logo is in black and features the company name in a stylized font. The 'C' in Cooper is stylized with two concentric circles.
## 510(k) Summary WarmGel® Infant Heel Warmer (Model 20418) Infant Heel Warmer (Model 24401)
#### Submitter Information
| Company Name: | CooperSurgical Inc. |
|------------------|------------------------------------------|
| Company Address: | 95 Corporate Drive<br>Trumbull, CT 06611 |
| Telephone: | 203-601-5200 |
| Fax: | 203-601-9870 |
| Contact Person: | Roaida Johnson |
|-----------------|----------------|
| Date Prepared: | March 17, 2016 |
#### Device Information
| Trade Names: | The Infant Heel Warmer (Model 24401)<br>WarmGel® Infant Heel Warmer (Model 20418) |
|----------------------|-----------------------------------------------------------------------------------|
| Common Name: | Infant Heel Warmer |
| Classification: | Class I per 21 CFR 890.5710 |
| Classification Name: | Hot or cold disposable pack |
| Product Code: | MPO |
#### Predicate Device Information
The CooperSurgical Infant Heel Warmer is substantially equivalent to the following predicates:
Primary Predicate: Rapid Aid Instant Disposable Infant Heel Warmer - Disc (K150627) Additional Predicate: DeRoyal Industries Infant Heel Warmer (K954716)
### Device Description
The CooperSurgical Infant Heel Warmer, which is available in both a liquid version (The Infant Heel Warmer, Model 24401) and a gel version (WarmGel® Infant Heel Warmer, Model 20418), is a non-sterile, single-use, disposable device comprised of a biaxially oriented nylon (BON)/polyethylene outer pouch filled with a supersaturated solution of food grade sodium acetate and water (liquid version), or food grade sodium acetate, water, and hydroxyethylcellulose, a common thickener (gel version). An adhesive tape is attached to the pouch, which can hold the warmer in place if desired. The pouch also contains a stainless steel disc that, when flexed, initiates an exothermic crystallization of the sodium acetate, generating heat. When activated at 75° + 1° F, the maximum peak temperature of the CooperSurgical Infant Heel Warmer is 107° F, which is reached in approximately 40 seconds and then gradually decreases over time.
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## Indications for Use
An instant warm pack intended to be used on an infant's heel to increase blood circulation to the area to aid in the drawing of blood for analysis. It is a single use, non-toxic, disposable warmer.
The device is primarily used in hospitals, doctor's offices, and other healthcare facilities.
## Substantial Equivalence Analysis
The substantial equivalence of the CooperSurgical Infant Heel Warmer to the predicates is shown by similarity in intended use, indications for use, materials, and performance. The table below provides a comparison of the technological characteristics of the subject device to the predicates.
| Property | Subject Device<br>CooperSurgical<br>Infant Heel Warmer | Primary<br>Predicate<br>Instant<br>Disposable<br>Infant Heel<br>Warmer - Disc | Additional<br>Predicate<br>Infant Heel<br>Warmer | Comparison |
|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------|--------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | CooperSurgical Inc. | Rapid Aid Corp. | DeRoyal<br>Industries | --- |
| 510(k)<br>Number | K151845 | K150627 | K954716 | --- |
| Pouch<br>Material | Poly/nylon | Poly/nylon | Unknown | Same as primary<br>predicate |
| Solution<br>Material | Liquid version -<br>Sodium acetate (food<br>grade) and water<br>Gel version - Sodium<br>acetate (food grade),<br>water, and<br>hydroxyethylcellulose | Sodium acetate<br>(food grade) and<br>water | Unknown | The<br>hydroxyethylcellulose<br>is a non-toxic<br>thickening agent. The<br>addition of the material<br>does not raise new<br>issues of safety and<br>effectiveness. |
| Activation<br>Method | Flexing metal disc | Flexing metal<br>disc | Squeeze to burst<br>inner pouch | Same as primary<br>predicate |
| Average<br>Maximum<br>Temperature | 104° F | 104° F | 105° F | Same as primary<br>predicate |
| Maximum<br>Peak<br>Temperature | 107° F | Unknown | Unknown | An animal study was<br>performed to confirm<br>no new issues of safety<br>and effectiveness. |
| Size of Pouch | 5" x 3.5" | 5.5" x 3.75" | 5" x 3.5" | Same as secondary<br>predicate |
| Method of<br>Attachment to<br>Heel | Adhesive strap | Adhesive strap | Adhesive strap | Same as both<br>predicates |
| Sterility.<br>Number of<br>Uses | Non-sterile, Single<br>Use, Disposable | Non-sterile,<br>Single Use,<br>Disposable | Non-sterile,<br>Single Use,<br>Disposable | Same as both<br>predicates |
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### Non-Clinical Performance Testing
Temperature profile testing was performed on the CooperSurgical Infant Heel Warmer and on the predicate DeRoyal Infant Heel Warmer, and the results of this testing were used to determine the substantial equivalence of the Infant Heel Warmer to the predicate. For each sample, a calibrated thermocouple was attached to the center, the device was activated to allow the exothermic reaction to begin, and temperature readings were taken at 5 second intervals for 30 minutes. The samples were activated at a temperature of 75° + 1° F. The temperature profiles were compared between the CooperSurgical Infant Heel Warmer and the predicate DeRoyal Infant Heel Warmer, and were found to be equivalent.
Stability testing was also performed on the CooperSurgical Infant Heel Warmer to confirm its shelf life. Biocompatibility was performed on the patient-contacting components of the device (outer pouch and adhesive tape) per AAMI/ANSI/ISO 10993-5:2003, and AAMI/ANSI/ISO 10993-10:2010.
An animal study was performed to determine the temperature of the skin after application of the device. The study consisted of three light-skinned and three dark-skinned pigs, aged 3 to 3.5 weeks. A WarmGel Infant Heel Warmer was placed on one side of the animal while the opposite side served as a control. Temperatures were measured using thermocouples adhered to the animal, one under the heel warmer and one on the control side, at 1-minute intervals for a total of 22 minutes. The animals were then graded against established criteria for both thermal insult and erythema. There was no evidence of thermal injury in any of the animals, and all but one animal received an erythema score of 0, with the one animal receiving a score of 1, which is barely perceptible.
## Conclusion
Based on the indications for use, technological characteristics, performance testing, and comparison to the predicates, the CooperSurgical Infant Heel Warmer has been shown to be substantially equivalent to the predicate devices identified, and does not present any new issues of safety or effectiveness.
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.