K160735 · Fresenius Kabi AG · CAC · Sep 16, 2016 · Anesthesiology
Device Facts
Record ID
K160735
Device Name
CATSmart
Applicant
Fresenius Kabi AG
Product Code
CAC · Anesthesiology
Decision Date
Sep 16, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5830
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The CATSmart (Continuous Autotransfusion System) device by Fresenius Kabi is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively and postoperatively to obtain washed red blood cells for reinfusion.
Device Story
CATSmart is an intraoperative/postoperative autotransfusion system; processes anticoagulated shed blood collected in a sterile reservoir. Operates via continuous flow centrifuge; removes plasmatic components, non-erythrocytic cells, activated coagulation factors, fibrinolysis products, cell trauma, and anticoagulants. Produces washed packed red cells for reinfusion. Used in clinical settings; operated by healthcare professionals. Features include hematocrit monitoring via integrated cuvette in AT3 disposable tubing; touchscreen interface. Output provides hematocrit values for process monitoring; not for diagnostic/quality control. Benefits include recovery of autologous blood for patient reinfusion.
Clinical Evidence
Bench testing only. In vitro blood quality studies compared CATSmart to the predicate C.A.T.S. across three wash programs (emergency, low volume, smart). Results confirmed successful validation of all wash programs using the AT3 tubing set. Separate evaluation demonstrated effective removal of fat and heparin. Electrical safety tested per IEC 60601-1-2:2007; additional testing performed for vibration, shock, and durability.
Technological Characteristics
Continuous flow centrifuge system. Includes AT3 disposable tubing set with integrated cuvette for hematocrit sensing. Touchscreen control interface. Electrical safety per IEC 60601-1-2:2007. System supports multiple wash programs (emergency, low volume, smart).
Indications for Use
Indicated for processing autologous shed blood collected intraoperatively and postoperatively to obtain washed packed red blood cells for reinfusion in patients undergoing surgery or trauma.
Regulatory Classification
Identification
An autotransfusion apparatus is a device used to collect and reinfuse the blood lost by a patient due to surgery or trauma.
Predicate Devices
C.A.T.S. Continuous Autotransfusion System (K960006)
FRESENIUS ATR40 AND ATR120 AUTOTRANSFUSION RESERVOIRS (K984586)
Submission Summary (Full Text)
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the text "DEPARTMENT OF HEALTH & HUMAN SERVICES" in all capital letters. The text is in a bold, serif font. The words are arranged on a single line and centered horizontally.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 16, 2016
Fresenius Kabi USA, LLC % Barry Hicks Manager, Regulatory Affairs Three Corporate Drive Lake Zurich, Illinois 60047
Re: K160735
Trade/Device Name: CATSmart Regulation Number: 21 CFR 868.5830 Regulation Name: Autotransfusion Apparatus Regulatory Class: Class II Product Code: CAC Dated: September 14, 2016 Received: September 16, 2016
Dear Barry Hicks:
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 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
{1}------------------------------------------------
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,
M.A. Willhemen
for
for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
#### Indications for Use
510(k) Number (if known) K160735
Device Name CATSmart
Indications for Use (Describe)
The CATSmart (Continuous Autotransfusion System) device by Fresenius is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively to obtain washed packed red blood cells for reinfusion.
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)
#### 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}------------------------------------------------
Image /page/3/Picture/2 description: The image shows the logo for Fresenius Kabi. The logo consists of three blue, curved lines on the left, followed by the text "FRESENIUS" in blue, and "KABI" in blue below that. The logo is simple and modern, and the blue color gives it a sense of trustworthiness.
# Section 5: 510(k) Summary
## 1. Submitter
This 510(k) summary was created on 14 March 2016.
| The 510(k) owner and contact person for this application is: | |
|--------------------------------------------------------------|-------------------------------------------------------|
| Name: | Barry G. Hicks |
| Position: | Manager, Regulatory Affairs |
| Company: | Fresenius Kabi USA, LLC. |
| Address | Three Corporate Drive<br>Lake Zurich, IL<br>60047 USA |
| Phone: | 847-550-7981 |
| Fax: | 847-550-2960 |
| Email: | barry.hicks@fresenius-kabi.com |
| Establishment registration number: | 3004548776 |
### 2. Device Name and Classification
| Proprietary / Trade Name: | CATSmart |
|---------------------------|---------------------------------------------------|
| Common Name: | Automated Blood Processing Autotransfusion System |
| Classification Name: | Apparatus, Autotransfusion |
| Classification: | Class II per 21 CFR § 868.5830 |
| Product Code: | CAC |
| Panel: | Anesthesiology |
## 3. Predicate Device
This application is intended to demonstrate that the CATSmart Autotransfusion System, including its associated disposables, is substantially equivalent to the following predicate device:
| 510(k) number: | K960006 |
|---------------------------|-----------------------------------------------------------------|
| Proprietary / Trade Name: | C.A.T.S. Continuous Autotransfusion System |
| Common Name: | Automated Blood Processing Autotranfusion System |
| Classification Name: | Apparatus, Autotransfusion |
| Classification: | Class II per 21 CFR § 868.5830 |
| Product Code: | CAC |
| Panel: | Cardiovascular |
| Manufacturer: | Fresenius AG, Frankfurter Str. 6-8, 66606 St. Wendel<br>Germany |
{4}------------------------------------------------
CATSmart
Image /page/4/Picture/2 description: The image contains the logo for Fresenius Kabi. The logo consists of three blue vertical lines that are curved at the top. To the right of the lines, the words "FRESENIUS" and "KABI" are written in blue, with "FRESENIUS" on top of "KABI". The logo is simple and modern.
The C.A.T.S. Autotransfusion System was modified with the addition of the following accessories under K984233 and K984586:
| 510(k) number: | K984233 |
|---------------------------|------------------------------------------------------------------------------------------------------------|
| Proprietary / Trade Name: | C.A.T.S AUTOTRANSFUSION ACCESSORIES,<br>MODELS ATS SUCTION LINE, ATY Y-ADAPTER,<br>AND ATO OXYGENATOR LINE |
| Common Name: | Automated Blood Processing Autotranfusion System |
| Classification Name: | Apparatus, Autotransfusion |
| Classification: | Class II per 21 CFR § 868.5830 |
| Product Code: | CAC |
| Panel: | Cardiovascular |
| Manufacturer: | Fresenius AG, Frankfurter Str. 6-8, 66606 St. Wendel,<br>Germany |
| 510(k) number: | K984586 |
| Proprietary / Trade Name: | FRESENIUS ATR40 AND ATR120<br>AUTOTRANSFUSION RESERVOIRS |
| Common Name: | Cardiovascular Surgical Devices |
| Classification Name: | Reservoir, Blood, Cardiopulmonary Bypass |
| Classification: | Class II per 21 CFR § 870.4400 |
| Product Code: | DTN |
| Panel: | Cardiovascular |
| Manufacturer: | Fresenius AG, Frankfurter Str. 6-8, 66606 St. Wendel,<br>Germany |
#### 4. Description
The product described in this document is the CATSmart (Continuous Autotransfusion System) including the disposables AT1, AT3, ATS, ATY, ATO, ATR40 and ATR120, ATV-70 and ATV-180, ATF40 and ATF120.
The Fresenius Kabi CATSmart device is an intraoperative autotransfusion system for intraand/or postoperative processing of blood lost through surgery or trauma. The CATSmart device operates on the principle of a continuous flow centrifyge, comparable to continuous systems for hemapheresis which, for decades, have been widely used in blood banks.
The shed blood, which is anticoagulated and collected in a sterile reservoir, is processed in a continuous washing process to obtain washed packed red cells for reinfusion to the patient. During this process all plasmatic and non-erythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed. The packed red cells are collected in a reinfusion bag from which they can be reinfused to the patient via a transfusion set when needed.
{5}------------------------------------------------
Image /page/5/Picture/1 description: The image contains the logo for Fresenius Kabi. The logo consists of three blue, curved lines on the left side. To the right of the lines, the words "FRESENIUS" and "KABI" are stacked on top of each other, also in blue. The logo is simple and modern in design.
CATSmart is based on the predecessor products C.A.T.S. and C.A.T.SP."", which have been in clinical use for almost 20 years. CATS was originally cleared in 1996. Following minor modifications it has been marketed as C.A.T.Smits since 2005. CATSmart has as an additional technical feature: monitoring of the hematocrit value.
# 5. Intended Use
The CATSmart (Continuous Autotransfusion System) device by Fresenius Kabi is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively and postoperatively to obtain washed red blood cells for reinfusion.
# 6. Substantial Equivalence
Fresenius CATSmart is substantially equivalent to the predicate device system, with the following components.
#### a) The reusable autotransfusion device:
CATSmart is based on the predecessor products C.A.T.S. and C.A.T.SP.446, which have been in clinical use for almost 20 years. The main functions of CATSmart and the underlying methodology remained unchanged. In fact, the only functional difference of CATSmart compared to C.A.T.S./C.A.T.S./C.A.T.S./C.A.T.S. of the hematocrit value as an additional technical feature. Moreover, the main controller software was updated. The update includes the hematocrit function as a new item and usage of a touchscreen control instead of a keyboard. The software structure and the requirements remain unchanged compared to the C.A.T.S./C.A.T.Splus software.
#### b) Disposables:
The predicate device C.A.T.S./C.A.T.SPl46 system also includes the disposable blood processing chamber with all necessary tubing (called AT1) as described in the 510(k) submission K960006. The new disposable for the proposed device CATSmart is AT3. The only difference between AT3 and AT1 is the integration of a cuvette into the tubing for the hematocrit measurement. The AT1 disposable may also be used with CATSmart, but no hematocrit information will be displayed.
The following disposables have received prior 510(k) clearance, do not change in their usage with CATSmart, and are not further mentioned in this 510(k):
- ATS suction line (cleared under K984233), -
- ATY Y-Adapter (cleared under K984233). -
- -ATO Oxygenator Line (cleared under K984233).
- ATR40 Autotransfusion Reservoir (cleared under K984586), -
- ATR120 Autotransfusion Reservoir (cleared under K984586) -
{6}------------------------------------------------
Image /page/6/Picture/1 description: The image contains the logo for Fresenius Kabi. The logo consists of three blue, curved lines on the left side. To the right of the lines, the text "FRESENIUS KABI" is written in blue, with "FRESENIUS" on top of "KABI".
The following additional disposables are exempted from 510(k) submission, do not change with their usage with CATSmart, and are not further mentioned in this 510(k):
- -ATV-70 and ATV-180 vacuum lines. These devices are classified as cardiopulmonary bypass accessory equipment and exempted according to 21 CFR & 870.4200.
#### Discussion of differences between CATSmart and the predicate device.
The only functional difference of CATSmart compared to C.A.T.S./C.A.T.Sn/W is the monitoring of the hematocrit value as an additional feature. The hematocrit monitoring function of CATSmart is only used to monitor the wash process for informational purposes and is not intended for diagnostic or quality control purpose. As stated in the Operator's Manual, the hematocrit values given by the device are not a substitute for the hematocrit check on the product before it is reinfused in the patient. The sensors are not calibrated measuring instruments.
#### Conclusion:
Based on the identified characteristics it is claimed that the device is substantially equivalent to the predicate devices.
### 7. Performance testing
The performance of the CATSmart device was tested by in vitro blood quality studies in direct comparison to the predicate device C.A.T.S. (currently marketed as C.A.T.Sº™). All three wash programs (emergency wash program, low volume wash, smart wash) were tested. Overall it was judged that all validation tests were passed for all wash programs on the CATSmart device with the AT3 tubing set. A separate in vitro evaluation demonstrated that fat and heparin were almost completely removed from the processed blood. The electrical safety of the CATSmart device was tested according to the general requirements for basic safety and essential performance directive of IEC 60601-1-2:2007. Furthermore, vibration and shock resistance was tested as well as the durability.
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.