Exodus Array Multipurpose Drainage Catheters are intended for percutaneous drainage of fluid or air in the chest, abdomen and pelvis, e.g., abscesses, cysts, pneumothoraces, and other general purpose drainage applications. Exodus Nuance Nephrostomy Drainage Catheters are intended for percutaneous drainage of fluid collections in the urinary system. Exodus Believe Biliary Drainage Catheters are intended for percutaneous drainage of the biliary tree.
Device Story
Radiopaque polyurethane drainage catheter; distal locking pigtail configuration; GLYCE hydrophilic coating; centimeter shaft markings. Includes polymer marker band (select models), metal/plastic cannulas, and trocar needle (multipurpose only). Used for percutaneous drainage of fluid/air in chest, abdomen, pelvis, urinary system, or biliary tree. Operated by clinicians in clinical settings. Device facilitates drainage via catheter placement; output is fluid/air removal. Benefits include minimally invasive management of fluid collections/pneumothorax.
Clinical Evidence
Bench testing only. No clinical data provided. Performance evaluation included tensile testing, catheter surface analysis, RO marker scrape test, radiopacity, flow rate, fluid leak, aspiration strength, column strength, coating lubricity, pigtail diameter, suture force, and catheter compatibility. Biocompatibility testing performed per ISO 10993-1.
Technological Characteristics
Radiopaque polyurethane (Carbothane 55D/95A blend) catheter. Distal locking pigtail with GLYCE hydrophilic coating. Sizes: 6, 8, 10, 12, 14 French. Lengths: 15, 25, 35 cm. Includes polymer marker band. Sterilization: Ethylene oxide. Packaging: Tyvek/Mylar pouch. No software or electronic components.
Indications for Use
Indicated for percutaneous drainage of fluid or air in the chest, abdomen, and pelvis (abscesses, cysts, pneumothoraces); fluid collections in the urinary system; and the biliary tree.
Regulatory Classification
Identification
A biliary catheter and accessories is a tubular flexible device used for temporary or prolonged drainage of the biliary tract, for splinting of the bile duct during healing, or for preventing stricture of the bile duct. This generic type of device may include a bile collecting bag that is attached to the biliary catheter by a connector and fastened to the patient with a strap.
Special Controls
*Classification.* Class II (special controls). The device, when it is a bile collecting bag or a surgical biliary catheter that does not include a balloon component, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 24, 2015
Navilyst Medical, Inc. Michael P. Hanley Specialist 1, Regulatory Affairs 26 Forest Street Marlborough, MA 01752
Re: K152069
> Trade/Device Name: Exodus Array Multipurpose Drainage Catheter, Exodus Nuance Nephrostomy Drainage Catheter, Exodus Believe Biliary Drainage Catheter Regulation Number: 21 CFR§ 876.5010 Regulation Name: Biliary catheter and accessories Regulatory Class: II Product Code: FGE, LJE, GBO Dated: July 23, 2015 Received: July 29, 2015
Dear Michael P. Hanley,
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies.
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You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 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 vours.
# Jeffrey W. Cooper -S
for
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K152069
#### Device Name
Exodus Array Multipurpose Drainage Catheters Exodus Nuance Nephrostomy Drainage Catheters Exodus Believe Biliary Drainage Catheters
Indications for Use (Describe)
Exodus Array Multipurpose Drainage Catheters are intended for percutaneous drainage of fluid or air in the chest, abdomen and pelvis, e.g., abscesses, cysts, pneumothoraces, and other general purpose drainage applications.
Exodus Nuance Nephrostomy Drainage Catheters are intended for percutaneous drainage of fluid collections in the urinary system.
Exodus Believe Biliary Drainage Catheters are intended for percutaneous drainage of the biliary tree.
Type of Use (Select one or both, as applicable)
| <span style="text-decoration: underline;">Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="text-decoration: underline;">Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
|-----------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------|
| <div> <input checked="true" type="checkbox"/> </div> | <div> <input type="checkbox"/> </div> |
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## 510(k) Summary - Exodus Drainage Catheters
OR
#### A. Sponsor
Navilyst Medical, Inc. 26 Forest Street Marlborough, MA 01752
# B. Contact
Michael P. Hanley Specialist I, Global Regulatory Affairs 508-658-7983
#### C. Device Name
Trade Name:
Common/Usual Name:
Classification Name:
Classification Panel: Pro Code:
#### D. Predicate Device(s)
Predicate 510(k) Trade Name:
Common/Usual Name: Classification Name:
Classification Panel: Pro Code: Reference 510 (k)s
Wanda Carpinella Director, Global Regulatory Affairs 508-658-7929
Exodus Array Multipurpose Drainage Catheter Exodus Nuance Nephrostomy Drainage Catheter Exodus Believe Biliary Drainage Catheter
Biliary, Nephrostomy, Multipurpose Percutaneous Drainage Catheters
- . FGE - Catheter, Biliary, Diagnostic 21 CFR §876.5010, Class II
- LJE - Catheter, Nephrostomy Pre-Amendment, unclassified
- GBO - Catheter, Nephrostomy, General & Plastic Surgery 21 CFR§878.4200, Class I
Gastroenterology - Urology FGE, LJE, GBO
#### K093392
Exodus Multipurpose Drainage Catheter Exodus Nephrostomy Drainage Catheter Exodus Biliary Drainage Catheter
Percutaneous Drainage Catheter
- . FGE - Catheter, Biliary, Diagnostic 21 CFR §876.5010, Class II
- LJE Catheter, Nephrostomy Pre-. Amendment, unclassified
- GBO Catheter, Nephrostomy, General & ● Plastic Surgery 21 CFR§878.4200, Class I
- GBX Catheter, Nephrostomy, General & ● Plastic Surgery 21 CFR§878.4200, Class I
Gastroenterology - Urology FGE, LJE, GBO K103353,K141335,K951475,K053245
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# E. Device Description
The Exodus Drainage Catheter consists of a radiopaque polyurethane catheter. The distal end of the catheter is configured as a locking pigtail and is coated with GLYCE hydrophilic coating. Catheter markings are provided in centimeters on the shaft to indicate the distal tip. The Exodus Array Multipurpose Drainage Catheter (when applicable) and the Exodus Believe Biliary Catheter include a polymer marker to assist with catheter placement.
The proposed Exodus Drainage Catheters will include the following accessories: a metal cannula and a plastic cannula (all product offerings) and a 0.038" trocar needle (in multipurpose offerings only).
# F. Intended Use/Indications for Use
The proposed Exodus Drainage Catheter has the following Indications for Use:
- . Exodus Array Multipurpose Drainage Catheters are intended for percutaneous drainage of fluid or air in the chest, abdomen and pelvis, e.g., abscesses, cysts, pneumothoraces, and other general purpose drainage applications
- Exodus Nuance Nephrostomy Drainage Catheters are intended for percutaneous drainage of ● fluid collections in the urinary system.
- Exodus Believe Biliary Drainage Catheters are intended for percutaneous drainage of the biliary ● tree.
## G. Summary of Similarities and Differences in Technological Characteristics and Performance
The proposed Exodus Drainage Catheter is substantially equivalent to the Navilyst Medical Percutaneous Drainage Catheter. When compared to the predicate, the proposed Exodus Drainage Catheters have similar materials, design, components, fundamental technology, and operating principles and the same indications for use. The modifications from the predicate device include: new catheter material and polymer marker band; addition 6F sizes; and 15cm as shortest catheter length. These similarities and differences are illustrated in the following table.
| Comparison of Proposed Exodus Drainage Catheters | | |
|--------------------------------------------------|----------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------|
| And Predicate Percutaneous Drainage Catheter | | |
| Characteristic | Proposed Exodus Drainage Catheters | Predicate Drainage Catheter (K093392) |
| Types of Catheters | Multipurpose Drainage Catheter<br>Nephrostomy Drainage Catheter<br>Biliary Drainage Catheter | Multipurpose Drainage Catheter<br>Nephrostomy Drainage Catheter<br>Biliary Drainage Catheter |
| Shaft Materials | Blended:<br>Carbothane 55D (70%)<br>Carbothane 95A (30%) | Co-extruded:<br>Carbothane 55D (inner layer)<br>Carbothane 85A (outer layer) |
| Shaft Depth Markers | Yes | Yes |
| Proximal Hub Assembly | SureTwist Hub locking<br>Mechanism | SureTwist Hub locking<br>Mechanism |
| Distal Hydrophilic Coating | Yes | Yes |
| Distal Configuration | Locking Pigtail | Non-Locking<br>Locking Pigtail |
| Sizes | 6, 8, 10, 12 &14 French | 8, 10, 12, &14 French |
| Radiopaque Marker | Yes: | Yes |
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| Comparison of Proposed Exodus Drainage Catheters<br>And Predicate Percutaneous Drainage Catheter | | |
|--------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------|-------------------------------------------------------------------|
| Characteristic | Proposed Exodus Drainage Catheters | Predicate Drainage Catheter (K093392) |
| | Polymer Marker band on select<br>Multipurpose Catheters and all<br>Biliary Drainage Catheters | Platinum / Iridium RO marker on<br>all Biliary Drainage only |
| Useable Length | 15 cm<br>25 cm<br>35 cm | 20 cm<br>25 cm<br>35 cm |
| Included Insertion Accessories | Plastic Stiffening Cannula,<br>Metal Stiffening Cannula<br>Trocar | Plastic Stiffening Cannula,<br>Metal Stiffening Cannula<br>Trocar |
| Packaging | Tyvek/Mylar (PET/LDPE) Pouch | Tyvek/Mylar (PET/LDPE) Pouch |
| Sterilization Method | Ethylene oxide | Ethylene oxide |
# H. Performance Data
The performance evaluation of the proposed Exodus Drainage Catheter included testing conducted in accordance to the following FDA Guidance Documents, and international standards: Results of this testing demonstrate safety and effectiveness of the proposed device and substantial equivalence. Results of biocompatibility testing performed in accordance with ISO 10993-1 demonstrate the proposed device is acceptable for its intended use.
- Tensile Testing
- . Catheter Surface
- RO Marker Band Scrape Test ●
- Radiopacity Testing ●
- Flow Rate Testing ●
- Fluid Leak Testing
- Aspiration Strength
- . Catheter Column Strength
- Coating Lubricity
- Pigtail Diameter
- Suture Force to Pigtail
- Catheter Compatibility ●
- Biocompatibility Testing per ISO 10993-1 ●
# I. Conclusion
Based upon successful results of testing and responses to questions posed within FDA's 510(k) Decision-Making Tree, the proposed device is determined to be 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.