K153228 · Navilyst Medical, Inc. · LJT · Dec 4, 2015 · General Hospital
Device Facts
Record ID
K153228
Device Name
NMI Port, NMI Port II
Applicant
Navilyst Medical, Inc.
Product Code
LJT · General Hospital
Decision Date
Dec 4, 2015
Decision
SESE
Submission Type
Special
Regulation
21 CFR 880.5965
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The NMI Port and NMI Port II with and without PASV Valve Technology are indicated for patients who require long-term access to the central venous system for administration of fluids including but not limited to hydration fluids, chemotherapy, analgesics, nutritional therapy and blood products. The device is also indicated for blood specimen withdrawal. When used with a power injectable needle, the NMI Port II are indicated for power injection of contrast media. The maximum recommended infusion rate is 5 ml/sec with a 19G or 20G non-coring power injectable needle or 2 ml/sec with a 22G non-coring power injectable needle.
Device Story
Subcutaneous implantable venous access device consisting of a reservoir and catheter; provides long-term central venous access. Clinician accesses reservoir via non-coring Huber needle through self-sealing silicone septum. Available in plastic or titanium, single lumen, valved (PASV) or non-valved configurations. Catheter shaft incorporates Endexo polymer to reduce thrombus formation. Radiopaque CT mark identifies power injectability. Used in clinical settings for fluid administration, blood withdrawal, and power injection of contrast media. Benefits include reliable long-term venous access and reduced risk of thrombus accumulation.
Clinical Evidence
Bench testing only. Performance evaluation included power injection and burst testing, aspiration strength (open and closed-ended), CT ink durability, port body height, and port body break strength. All tests met pre-established acceptance criteria per FDA guidance and EN ISO 10555-1:2013 and EN ISO 10555-3:2013 standards.
Technological Characteristics
Subcutaneous port with silicone septum and radiopaque catheter. Materials include plastic or titanium port body and Endexo polymer-coated catheter. Features PASV (Pressure Activated Safety Valve) technology. Dimensions: port body height 1.29 +/- 0.21 cm. Catheter diameter 6F or 8F. Power injection rated up to 300 psi and 5 ml/sec. Sterilization method not specified.
Indications for Use
Indicated for patients requiring long-term central venous access for fluid administration (hydration, chemotherapy, analgesics, nutrition, blood products) and blood specimen withdrawal. NMI Port II indicated for power injection of contrast media when used with compatible non-coring power injectable needles.
Regulatory Classification
Identification
A subcutaneous, implanted, intravascular infusion port and catheter is a device that consists of a subcutaneous, implanted reservoir that connects to a long-term intravascular catheter. The device allows for repeated access to the vascular system for the infusion of fluids and medications and the sampling of blood. The device consists of a portal body with a resealable septum and outlet made of metal, plastic, or combination of these materials and a long-term intravascular catheter is either preattached to the port or attached to the port at the time of device placement. The device is available in various profiles and sizes and can be of a single or multiple lumen design.
Special Controls
*Classification.* Class II (special controls) Guidance Document: “Guidance on 510(k) Submissions for Implanted Infusion Ports,” FDA October 1990.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 4, 2015
Navilyst Medical, Inc. Robin Fuller Sr. Manager, Regulatory Affairs 26 Forest Street Marlborough, Massachusetts 01752
Re: K153228
Trade/Device Name: NMI Port and NMI Port II Regulation Number: 21 CFR 880.5965 Regulation Name: Subcutaneous, Implanted, Intravascular Infusion Port and Catheter Regulatory Class: II Product Code: LJT Dated: November 4, 2015 Received: November 6, 2015
Dear Robin Fuller:
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.
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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 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
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### Indications for Use
510(k) Number (if known) K153228
Device Name NMI Port and NMI Port II
#### Indications for Use (Describe)
The NMI Port and NMI Port II with and without PASV Valve Technology are indicated for patients who require longterm access to the central venous system for administration of fluids including but not limited to hydration fluids, chemotherapy, analgesics, nutritional therapy and blood products. The device is also indicated for blood specimen withdrawal. When used with a power injectable needle, the NMI Port II are indicated for power injection of contrast media. The maximum recommended infusion rate is 5 ml/sec with a 19G or 20G non-coring power injectable needle or 2 ml/sec with a 22G non-coring power injectable needle.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary for the NMI Port and NMI Port II
# K153228
Date prepared: 19-November-2015
### A. Sponsor
Navilyst Medical, Inc 26 Forest Street Marlborough, MA 01752
#### B. Contact
Robin Fuller Sr.Manager, Regulatory Affairs 508-658-7986
#### C. Device Name
| Trade Name: | NMI Port and NMI Port II |
|----------------------|--------------------------------------------------------------------------------------------|
| Common/Usual name: | Implanted port catheter |
| Classification Name: | Implanted port catheter, subcutaneous, implanted, intravascular infusion port and catheter |
## 21CFR§880.5965, Class II Classification Panel: ProCode:
### D. Predicate Device(s)
Trade Name: Common/Usual name: Classification Name:
General Hospital LJT
NMI Port and NMI Port II Implanted port catheter Implanted port catheter, subcutaneous, implanted, intravascular infusion port and catheter
| 21CFR§880.5965, Class II | |
|--------------------------|------------------|
| Classification Panel: | General Hospital |
| ProCode: | LJT |
| Predicate 510(k)s: | K122767, K131694 |
### E. Device Description
The NMI Port and NMI Port II with and without PASV Valve Technology are a subcutaneous implantable venous access device with one reservoir and is designed for optional power injection of contrast media, CECT. The ports are designed to be accessed using a non-coring Huber needle introduced through the skin into the self-sealing silicone septum covering the reservoir.
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The NMI Port and NMI Port II are available in plastic or titanium single lumen and valved or nonvalved configurations. The ports are available with either silicone filled or non-filled suture fixation holes. Ports with non-filled suture fixation holes are generally utilized based on clinical need to anchor the port to the subcutaneous tissue; whereas ports with filled suture holes, designed to prevent tissue in-growth to the suture holes, are generally utilized when not anchoring the port to the subcutaneous tissue. If needed, filled suture holes are accessed through the silicone. All port configurations have a radiopaque identifier (CT mark) to identify the port as power injectable. The radiopaque catheter has graduated marks at 1 centimeter intervals and can be cut to the desired length by the clinician. Ports are provided with a variety of procedural accessories.
The NMI Port II catheter shaft incorporates Endexo polymer for improved resistance to thrombus accumulation and/or formation on the catheter.
### F. Indication for Use
The NMI Port and NMI Port II with and without PASV Valve Technology are indicated for patients who require long-term access to the central venous system for administration of fluids including but not limited to hydration fluids, chemotherapy, analgesics, nutritional therapy and blood products. The device is also indicated for blood specimen withdrawal.
When used with a power injectable needle, the NMI Port II are indicated for power injection of contrast media. The maximum recommended infusion rate is 5 ml/sec with a 19G or 20G non-coring power injectable needle or 2 ml/sec with a 22G non-coring power injectable needle.
#### G. Summary of Similarities and Differences in Technological Characteristics and Performance
The proposed NMI Port and NMI Port II devices have identical materials, design and components and technological characteristics as predicate devices with the only difference being that the plastic port body ultrasonic welding process will be brought in-house to Navilyst Medical's manufacturing facility from the current outside contract manufacturer. Both the NMI Port II and predicate ports are, in brief, intended for patients who require long-term access to the central venous system for administration of fluids including but not limited to hydration fluids, chemotherapy, analgesics, nutritional therapy and blood products; available in single lumen configurations; with and without PASV Valve Technology (Pressure Activated Safety Valve); plastic or titanium port body available with either a 6F or 8F outside diameter catheter; rated for maximum power injector settings up to 300 psi with maximum power injection flow rate up to 5 ml/second based on model; and available kitted with a variety of procedural accessories.
#### H. Performance Data
A risk analysis and necessary verification and validation activities to demonstrate that the design outputs of the modified device met the design input requirements were completed. The performance evaluation of the NMI Port and NMI Port II included testing conducted in accordance with the following FDA guidance documents and international standards:
- . FDA's "Guidance on 510(k) Submissions for Implanted Infusion Ports dated October 1990.
- . EN ISO 10555-1:2013, Sterile, Single Use Intravascular Catheters - Part 1: General Requirements
- . EN ISO 10555-3:2013, Sterile, Single Use Intravascular Catheters – Part 3: Central Venous Catheters
The proposed NMI Port and NMI Port II successfully passed relevant testing per the above Guidance. standards, and pre-established acceptance criteria, including:
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| Test | Acceptance Criteria | Samples<br>Tested | Results of<br>Verification |
|---------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|
| Power<br>Injection<br>and Burst | Port assembly must<br>withstand 15 power<br>injection cycles without<br>any failures (leaking,<br>fracturing and bursting)<br>with an 11.8cp fluid at<br>300 psi maximum<br>pressure setting and a 5<br>mL/sec flow rate setting<br>for a 19 or 20 ga infusion<br>set, and a 2 mL/sec flow<br>rate setting for a 22 g<br>infusion set.<br><br>The port must then have a<br>static burst strength of 50<br>psi minimum. Record<br>burst strength. | Three lots<br>of 15 each<br>(45 total). | All samples tested met<br>the acceptance criteria.<br>Average static burst<br>pressures were 138.7,<br>148.8 and 149.2 psi. |
| Aspiration<br>Strength -<br>Open<br>Ended | Port must be able to be<br>aspirated (no occlusions<br>or wall collapses<br>preventing aspiration)<br>using a 10 mL syringe on<br>an open ended catheter<br>without leaking or<br>bursting post 4 hour<br>conditioning at 37°C +/-<br>2ºC. Record as<br>PASS/FAIL | Three lots<br>of 75 each<br>(225<br>total). | All samples tested met<br>the acceptance criteria. |
| Aspiration<br>Strength -<br>Closed<br>Ended | No leaks during<br>aspiration with a 10 mL<br>syringe for 15 seconds<br>(leak = ingress of air<br>bubbles to the syringe)<br>post 4 hour conditioning<br>at 37°C +/- 2°C without<br>leaking or bursting on an<br>occluded catheter.<br>Record as PASS/FAIL | Three lots<br>of 75 each<br>(225<br>total). | All samples tested met<br>the acceptance criteria. |
| CT Ink<br>Durability | CT printing shall not<br>flake or chip off.<br>Additional requirements<br>soaking port in saline at<br>body temperature for 24<br>hours and perform and<br>alcohol rub. Record as<br>PASS/FAIL | Three lots<br>of 75 each<br>(225<br>total). | All samples tested met<br>the acceptance criteria |
| Port body<br>height | 1.29 +/- 0.21 cm | Three lots<br>of 75 each<br>(225<br>total). | All samples tested met<br>the acceptance criteria |
| Port Body<br>Break<br>Strength | Must not break at less<br>than 636 lb force. Record<br>as PASS/FAIL | Three lots<br>of 75 each<br>(225<br>total). | All samples tested met<br>the acceptance criteria |
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#### I. Conclusion
Based on successful results of testing and on responses to questions posed in FDA 's 510(k) Decision Making Tree, the proposed device is determined to be substantially equivalent to the predicate devices.
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.