K153760 · DEKA Research & Development · LDR · Oct 3, 2016 · General Hospital
Device Facts
Record ID
K153760
Device Name
Volumetric Infusion Controller
Applicant
DEKA Research & Development
Product Code
LDR · General Hospital
Decision Date
Oct 3, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5725
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Volumetric Infusion Controller is intended for the delivery of general maintenance fluids and non-critical antibiotics to adult patients using gravity infusion in a clinical setting by a trained medical professional. The device is not intended to administer critical fluids, including high-risk medications.
Device Story
Volumetric Infusion Controller (VIC) is a gravity-based electronic infusion controller; regulates flow rate by monitoring drip chamber via integrated video camera and vision processing system. System provides feedback to flow control valve to maintain target delivery rates without user intervention. Operates on AC power or internal rechargeable battery; includes secondary battery for safety alarms during power failure. Used in clinical settings by trained medical professionals. Healthcare providers set target infusion rates; device monitors drop formation to distinguish between falling drops and splashing, ensuring accurate flow control. Benefits include precise, automated gravity-based fluid delivery for non-critical medications, reducing manual adjustment needs.
Clinical Evidence
No clinical data. Evidence consists of bench testing, including flow rate accuracy (IEC 60601-2-24:2012), reliability analysis (MTBF > 7951 hours with zero failures), electrical/mechanical safety (AAMI/ANSI ES60601-1), electromagnetic compatibility, and human factors/usability testing (IEC 62366).
Technological Characteristics
Gravity-based electronic infusion controller. Uses video camera and vision processing for drop sensing. Powered by AC (120/240V) or internal rechargeable lithium battery. Compatible with 10 drop/mL IV administration sets. Software classified as 'Major' level of concern. Standards: IEC 60601-2-24:2012 (flow accuracy), AAMI/ANSI ES60601-1:2005/(R)2012 (safety), IEC 60601-1-2:2007 (EMC), IEC 60601-1-8:2006 (alarms), IEC 62366 (human factors).
Indications for Use
Indicated for adult patients requiring delivery of general maintenance fluids and non-critical antibiotics via gravity infusion in clinical settings. Not indicated for critical fluids or high-risk medications.
Regulatory Classification
Identification
An infusion pump is a device used in a health care facility to pump fluids into a patient in a controlled manner. The device may use a piston pump, a roller pump, or a peristaltic pump and may be powered electrically or mechanically. The device may also operate using a constant force to propel the fluid through a narrow tube which determines the flow rate. The device may include means to detect a fault condition, such as air in, or blockage of, the infusion line and to activate an alarm.
{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 to the right, stacked on top of each other.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 3, 2016
DEKA Research & Development Mr. Roger Leroux Regulatory Affairs Project Manager 340 Commercial St. Manchester, New Hampshire 03101
Re: K153760
Trade/Device Name: Volumetric Infusion Controller Regulation Number: 21 CFR 880.5725 Regulation Name: Infusion Pump Regulatory Class: II Product Code: LDR Dated: September 1, 2016 Received: September 2, 2016
Dear Mr. Roger Leroux:
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 (OS) 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,
Image /page/1/Picture/8 description: The image shows a signature and the name "Tina Kiang". There is a large, looping signature to the left of the name. Below the name is the text "-S".
Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
510(k) Number (if known)
K153760
Device Name
Volumetric Infusion Controller
Indications for Use (Describe)
The Volumetric Infusion Controller is intended for the delivery of general maintenance fluids and non-critical antibiotics to adult patients using gravity infusion in a clinical setting by a trained medical professional. The device is not intended to administer critical fluids, including high-risk medications.
| Type of Use (Select one or both, as applicable) | |
|---------------------------------------------------------------|--|
| <div> Prescription Use (Part 21 CFR 801 Subpart D) </div> | |
| <div> Over-The-Counter Use (21 CFR 801 Subpart C) </div> | |
#### 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."
Form Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below.
{3}------------------------------------------------
#### 510(K) SUMMARY K153760
This 510(k) summary is being submitted in accordance with the requirements of the Safe Medical Device Act (SMDA) of 1990. The content of this 510(k) summary is provided in conformance with 21 CFR 807.92.
#### Submitter's Information
| 510(k) Sponsor: | DEKA Research & Development<br>340 Commercial Street<br>Manchester, NH 03101 |
|-----------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Julie Perkins<br>Regulatory Affairs Project Manager<br>DEKA Research & Development Corporation<br>Phone: (603) 669-5139<br>Fax: (603) 624-0573<br>jperkins@dekaresearch.com |
| Date of Preparation | December 28, 2015 |
|---------------------|-------------------|
|---------------------|-------------------|
#### Device Information
| Common/Usual Name: | Controller, Infusion, Intravascular, Electronic |
|-------------------------|-------------------------------------------------|
| Trade/Proprietary Name: | Volumetric Infusion Controller |
| Regulation Number: | 21 CFR 880.5725 |
| Regulation Name: | Infusion Pump |
| Regulatory Class: | Class II |
| Product Code: | LDR |
| Device Panel: | General Hospital |
#### Predicate Device
The Volumetric Infusion Controller is substantially equivalent to the DEKA Jr. Volumetric Infusion Controller, which was previously cleared under application K863204.
#### Device Description
The Volumetric Infusion Controller (VIC) is a gravity-based electronic infusion controller relying on head height to provide the delivery pressure necessary to meet the target infusion delivery rates. The drip chamber of an administration set is monitored by a vision system for drop growth. This information is used to provide feedback to the flow control valve to establish and maintain the target flow-rate without user intervention.
{4}------------------------------------------------
The device is capable of operating from wall power or on battery power. The VIC comes with an AC power supply (120V or 240V). When unplugged, the device is capable of running an infusion for more than 8 hours powered by the internal rechargeable battery. The device also has a second battery powering a safety system capable of stopping the infusion and alarming in the case of a sudden power failure.
## Indications for Use
The Volumetric Infusion Controller is intended for the delivery of general maintenance fluids and non-critical antibiotics to adult patients using gravity infusion in a clinical setting by a trained medical professional. The device is not intended to administer critical fluids, including high-risk medications.
## Technological Characteristics
The Volumetric Infusion Controller (VIC) has similar technological characteristics as compared to the predicate device. Similar to the DEKA Jr. predicate device, the VIC is a drop counter paired with a clamp that allows for the control of flow. Both devices operate by counting drops and ensuring that they are falling at the correct rate to achieve the desired flow rate. The predicate device uses "beam break" technology to determine when a drop had fallen whereas the VIC uses a video camera and vision processing to monitor the drop formation and detect drops falling. Beam break uses two beams of known width and known distance apart and uses the time period these beams are broken to determine the height of the drop, which is used to estimate the actual size of the drop. The VIC method is robust as it is less susceptible to interference from splashing. The VIC vision system uses similar algorithms to make the distinction between drops falling from the spout in the drip chamber and splashes of fluid adhering to the sides of the drip chamber. In addition, by watching the drop form, the VIC can determine if drops are forming quickly enough to achieve the desired flow rate between drops falling providing more accurate and more reactive control especially at low flow rates where the drop rate can be as one drop per 36 seconds.
Risk analysis has been completed and potential hazards associated with the proposed device have been identified and mitigated. All potential risks were deemed acceptable after mitigation.
{5}------------------------------------------------
# Comparison to Predicate Device
| Characteristic | Predicate (DEKA Jr.)<br>(K863204) | Proposed (Volumetric<br>Infusion Controller)<br>(K153760) | Assessment of Difference |
|----------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| General Characteristics | | | |
| Intended Use | Electronic infusion<br>controller designed to<br>regulate the infusion of<br>a wide variety of fluids<br>where gravity provides<br>adequate head pressure<br>to achieve the desired<br>flow rate. | The Volumetric Infusion<br>Controller is intended for the<br>delivery of general<br>maintenance fluids and non-<br>critical antibiotics to adult<br>patients using gravity infusion<br>in a clinical setting by a<br>trained medical professional.<br>The device is not intended to<br>administer critical fluids,<br>including high-risk<br>medications. | Although the intended use<br>for the proposed device has<br>been modified to include<br>categories of fluids to be<br>used with the device,<br>intended users, and intended<br>environment, both devices<br>are indicated for use for the<br>purpose of controlling<br>delivery of fluids using<br>gravity infusion. Therefore,<br>we believe that the<br>differences in the<br>indications for use do not<br>raise new questions of safety<br>or effectiveness. |
| Drop counter | Beam break technology | Video camera and vision<br>processing | The predicate and proposed<br>devices are both drop<br>counters paired with a clamp<br>that allows for the control of<br>flow. The difference in the<br>method for counting drops<br>has been modified in the<br>proposed device based on<br>current technology. In<br>addition to counting drops,<br>the proposed device also<br>monitors the drop formation<br>and detects drops falling.<br>This difference between the<br>predicate and proposed<br>device does not raise safety<br>or effectiveness questions. |
| Volumetric | Yes | Same | N/A |
| Disposable to be<br>used with device | Dedicated IV<br>administration set | Baxter Healthcare 10<br>drop/mL<br>• 1C8109S (DEHP)<br>• 2H8401 (non-DEHP) | N/A |
| System Performance | | | |
| Volumetric<br>Delivery accuracy | ± 10% | ± 10% | N/A |
| Flow rate range<br>(for 10 drop/mL<br>set) | 30-500 mL/hr | 10-300 ml/hr | No new associated risk. |
| Flow rate range<br>(for 60 drop/mL<br>set) | 10-250 mL/hr | Not applicable – device is<br>only compatible with 10<br>drop/mL IV administration<br>sets. | N/A |
| Time to target | Less than 5 minutes | Same | N/A |
| Operating | One IV administration | Up to 72 hours with a single | N/A - Assumed that the |
| duration | set change | IV administration set. | operation duration for the<br>predicate device based on<br>one IV administration set<br>change was 72 hours. |
| Environmental Requirements | | | |
| Operating<br>temperature range | 10C to 40C | 15C to 30C | No new associated risk. |
| Operating non-<br>condensing<br>humidity range | 5% to 95% | 20% to 85% | No new associated risk. |
| Operating altitude<br>range | Unknown | Sea level to 2000m | Operating altitude for the<br>predicate device not known. |
| Physical Specification and Electrical Power Requirements | | | |
| Weight | <340grams | <600grams (not including<br>power supply and IV<br>administration set) | No new associated risk. |
| Physical Size | 2" x 2.5" x 6" | 3.94" x 2.76" x 7.09" | No new associated risk. |
| Power Supply | 6.25 VDC, 5 AA cells | 100-127/220-240 VAC,<br>Rechargeable Lithium Battery | No new associated risk. |
| Alarms | | | |
| Air in line | No | Same | N/A |
| Low battery | Yes | Same | N/A |
| Flow rate error | Yes | Same | N/A |
| Door open | Yes | Same | N/A |
| Drop sensor | Yes | Same | N/A |
| Occlusion | Yes | Same | N/A |
| Invalid IV Set | No | Yes | N/A |
| Reverse flow | No | Yes | N/A |
| Stream | No | Yes | N/A |
| No flow | No | Yes | N/A |
{6}------------------------------------------------
The VIC and the predicate device are both intended for use for the purpose of controlling delivery of fluids using gravity infusion. The modification of the indications for use of the VIC from the predicate to include categories of fluids to be used with the device, intended users, and intended environment do not adversely affect the performance of the VIC.
The method for counting drops has been modified in the proposed device based on current technology. The VIC proposed device uses a video camera and vision processing to monitor the drop formation and detect drops falling. The VIC method is robust as it is less susceptible to interference from splashing. The vision system uses similar algorithms to make the distinction between drops falling from the spout in the drip chamber and splashes of fluid adhering to the sides of the drip chamber. Based on demonstrable evidence provided in this 510(k), the device differences described within this submission do not affect the intended use, the fundamental technology or operating principles of the device, or raise safety or effectiveness issues. The changes to the technology allow for a robust system for monitoring and controlling flow rate.
{7}------------------------------------------------
# Performance Data
The following performance data are provided in support of the substantial equivalence determination.
- Flow rate accuracy Conducted in accordance with IEC 60601-2-24:2012 under three test . conditions.
| Condition | Acceptance Criteria | Test Results | Conclusion |
|---------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|-----------------|------------|
| Minimum 72 hour<br>infusion at 10 mL/h<br>and head height<br>within operating<br>range | The second hour is within ±20%<br>of the programmed flow rate | -1.00 to -2.00% | |
| | The last hour of the infusions are<br>within ±20% of the programmed<br>flow rate | -0.80 to -1.80% | Pass |
| Minimum 2 hour<br>infusion at 25 mL/h<br>and a head height<br>simulated negative<br>back pressure | The second hour is within ±20%<br>of the programmed flow rate | -0.40 to -2.93% | Pass |
| 1L infusion at 300<br>mL/h and a head<br>height within<br>operating range | The second hour is within ±20%<br>of the programmed flow rate | 5.56 to 6.42% | |
| | The last hour of the infusions are<br>within ±20% of the programmed<br>flow rate | 5.33 to 6.64% | Pass |
- . Maintenance of set flow rate despite changes in head height – Conducted under worst case conditions using the accuracy calculation method of IEC 60601-2-24:2012 at two flow rates (10 and 300 mL/h) with increasing (50 to 200cm) and decreasing head heights (200 to 50cm).
| Condition | Acceptance Criteria | Test Result | Conclusion |
|-----------------------------------------|-----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------|------------|
| Increasing head<br>height (50 to 200cm) | • The device continues<br>infusing and the<br>accuracy does not<br>exceed ±25%; or<br>• The device alarms | At 10mL/hr:<br>-7.03 to -9.87%<br>At 300mL/hr:<br>6.23 to 6.27%<br>(1 device alarmed) | Pass |
| Decreasing head<br>height (200 to 50cm) | • The device continues<br>infusing and the<br>accuracy does not<br>exceed ±25%; or<br>The device alarms | At 10mL/hr:<br>-10.57 to -13.17%<br>At 300mL/hr:<br>4.01%<br>(2 devices alarmed) | Pass |
{8}------------------------------------------------
- . Reliability analysis – Tested as Mean Time Between Failures (MTBF). Devices are setup in nominal operating conditions and are continuously infusing solutions at flow rates that are changed each time the solution is resupplied. Between infusions, the devices are cleaned and disinfected according to the Instructions for Use. The total infusion time and the number of alarms are recorded over the course of the test.
| Acceptance Criteria | Test Result | Conclusion | | | | | | | | | | | | | | | | | | |
|------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|--|--|--|--|--|--|--|--|--|--|--|--|--|--|--|--|--|--|
| The devices performed the minimum number of infusion hours for the associated number of failures as shown in the table below | In order to pass with zero failures the number of infusion hours to establish MTBF $\ge$ 6 months with 90% confidence would need to be $\ge$ 7596 hours. The actual number of infusion hours before discontinuing testing, with zero failures, was 7951 hours. | Pass | | | | | | | | | | | | | | | | | | |
| Number of Failures Number of Uses Number of Hours 0 422 7596 1 712 12816 2 974 17532 3 1223 22014 4 1463 26334 | | | | | | | | | | | | | | | | | | | | |
- Electrical, hardware, and mechanical safety testing per AAMI/ANSI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012
- Electromagnetic compatibility testing per 60601-1-2:2007. In addition, testing . for immunity to proximity fields from RF wireless communications equipment was conducted.
- Verification and validation of safety control mechanisms, alarms (per IEC ● 60601-1-8:2006), operating specifications (such as battery life), and environmental specifications
- . Software verification and validation testing - Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "Major" level of concern, since a failure or latent flaw in the software could directly result in serious injury or death to the patient or operator.
- Human factors – Usability evaluation and human factors testing was conducted in accordance with IEC 62366-1:2015 and IEC 62366:2007 +A1:2014 as well as collateral standards of IEC 60601-1 with relevant human factors requirements.
The proposed device was tested to verify conformance with the design specifications and applicable industry standards. Validation and human factors evaluations for the VIC were conducted in simulated environments to ensure user needs and intended uses were met. A
{9}------------------------------------------------
clinical investigation was not conducted, as the bench testing and human factors testing is sufficient to show the product is substantially equivalent in performance for its intended use.
## Conclusion
The performance data included in this premarket notification demonstrate that the proposed device is substantially equivalent to the predicate device.
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.