K161266 · Exploramed Nc7, Inc. · HGX · Aug 11, 2016 · Obstetrics/Gynecology
Device Facts
Record ID
K161266
Device Name
Athena Breast Pump
Applicant
Exploramed Nc7, Inc.
Product Code
HGX · Obstetrics/Gynecology
Decision Date
Aug 11, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.5160
Device Class
Class 2
Indications for Use
The ExploraMed NC7 Athena Breast Pump is intended to express milk from lactating women in order to collect milk from their breasts. The device is intended for a single user.
Device Story
Athena Breast Pump is a small, portable, electric device for lactating women to express and collect breast milk. User aligns nipple in flange; initiates session via control panel. Device operates in two modes: Stimulation (moderate vacuum for letdown) and Expression (higher vacuum). User adjusts vacuum levels (60-245 mmHg). System uses microcontroller-based electrical pressure control to generate suction. Device is single-user, reusable, and non-sterile. Powered by Li-Ion battery. After use, user separates flange from pump and removes milk bag. Benefits include portable, adjustable milk expression. Healthcare providers do not operate the device; it is for home use by the patient.
Clinical Evidence
No clinical data was required or provided. Substantial equivalence was demonstrated through bench testing, including reliability, vacuum profile, sound, cycle frequency, dimensional, bag pressure, and bag puncture verification testing.
Technological Characteristics
Electric breast pump; microcontroller-based pressure control system. Suction range: 60-245 mmHg. Two modes: Stimulation and Expression. Power: Li-Ion battery. Portable form factor. Biocompatibility per ISO 10993-1. Electrical safety per IEC 60601-1, 60601-1-11, 60601-1-6, 62366, 62133. EMC per IEC 60601-1-2.
Indications for Use
Indicated for lactating women to express and collect breast milk. Intended for single-user use.
Regulatory Classification
Identification
A powered breast pump in an electrically powered suction device used to express milk from the breast.
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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 an emblem featuring a stylized depiction of three human profiles facing right, with flowing lines beneath them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 11, 2016
ExploraMed NC7, Inc. Keri Y. Ng VP Regulatory, Quality, Clinical 201 San Antonio Circle #172 Mountain View, CA 94040
Re: K161266
> Trade/Device Name: Athena Breast Pump Regulation Number: 21 CFR§ 884.5160 Regulation Name: Powered Breast Pump Regulatory Class: II Product Code: HGX Dated: June 29, 2016 Received: June 30, 2016
Dear Keri Y. Ng:
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.
Douglas Silverstein -S 2016.08.11 14:22:47 -04'00'
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) K161266
Device Name Athena Breast Pump
Indications for Use (Describe)
The ExploraMed NC7 Athena Breast Pump is intended to express milk from lactating women in order to collect milk from their breasts. The device is intended for a single user.
Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(K) Summary – K161266 Athena Breast Pump
| Sponsor/Submitter: | ExploraMed NC7, Inc<br>201 San Antonio Circle #172<br>Mountain View, CA 94040 |
|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | John Chang<br>Vice President, R&D<br>Phone: (650) 559-5805<br>Fax: (650) 284-2552 |
| Date Prepared: | August 11, 2016 |
| Device Trade Name: | Athena Breast Pump |
| Common Name: | Breast Pump |
| Device Classification: | Class II |
| Regulation Number: | 21 CFR 884.5160 |
| Classification Name: | Pump, Breast, Powered |
| Product Code: | HGX |
| Predicate Device: | Medela Ag Freestyle Breast Pump (K150499) |
| Device Description: | The ExploraMed NC7 Athena Breast Pump (Athena) is a small<br>electric breast pump that is intended for lactating women to express<br>and collect breast milk. The subject device is intended for multiple<br>uses with a single user. Athena may be operated as a single or<br>double pumping system. For a user to pump both breasts<br>simultaneously, she would need to use two (2) Athena devices at<br>the same time, one on each breast. |
| Device Operation: | The user turns on the Pump by pressing the “On/Off” button and<br>aligns the nipple in the Flange. Following alignment, the user start<br>the pumping session by pressing the “Play/Pause” button on the<br>control panel of the Pump. The subject device has two modes:<br>Stimulation and Expression. The Pump starts pumping in<br>Stimulation mode at a moderate vacuum level to stimulate milk<br>letdown from the user. After letdown, the Pump changes to<br>Expression mode and increases the vacuum level. The user is able<br>to increase or decrease the vacuum level. When the pumping<br>session ends, the user removes the Pump from the breast; separates<br>the Flange from the Pump; and removes the Milk Bag. The<br>Charger can be inserted into the power port to charge the Pump<br>when not in use. |
| Indications for Use: | The ExploraMed NC7 Athena Breast Pump is intended to express<br>milk from lactating women in order to collect milk from their<br>breasts. The device is intended for a single user. |
| Technological<br>Characteristics: | Athena generates suction and extracts breast milk. The Flange fits<br>on the breast to create a seal and facilitate the suction. The Pump<br>has two modes and has user-adjustable suction levels ranging from<br>60mmHg to 245mmHg. |
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### Substantial Equivalence Comparison
| Attribute | Predicate Device<br>Medela Ag Freestyle Breast Pump | Subject Device<br>ExploraMed NC7 Athena Breast Pump |
|-----------------------------------------------------------|-------------------------------------------------------------------|-------------------------------------------------------------------------|
| 510(k) number | K150499 | K161266 |
| Intended Use | Express milk from breast | Same, Express milk from breast |
| Single User | Yes | Same, Yes |
| Provided Non-Sterile | Yes | Same, Yes |
| Re-usable | Yes | Same, Yes |
| Direct User Contact | Yes | Same, Yes |
| Technological<br>Characteristics | Electrical pressure control pumping<br>system to generate suction | Same, Electrical pressure control<br>pumping system to generate suction |
| Power Source | AC Adaptor or Li-Ion Battery | Same, Li-Ion Battery |
| Suction Levels<br>(mmHg) | 40-245 | Same, 60-245 |
| Adjustable Suction<br>Levels | Yes | Same, Yes |
| Suction Settings | 9 | 7 |
| Back Flow Protection | Yes | Same, Yes |
| Control Mechanism | Microcontroller | Same, Microcontroller |
| Single or Double<br>Pumping | Single or Double | Same, Single or Double |
| Mobile | Yes | Same, Yes |
| Number of Reusable<br>Components That<br>Require Cleaning | 5 | 2 |
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The physical characteristics of Athena are similar to the predicate device as demonstrated by the following:
- Athena is intended to generate suction to express milk from a lactating mother, which is identical . to the predicate device.
- Athena is reusable and provided non-sterile to the customer, which is the same as the predicate device.
- The operating suction levels and suction cycles for Athena are within the established range for the predicate device.
- . Both devices utilize a closed pumping system.
- . Both devices use an electrical pressure control pumping system to generate suction.
- . Athena has adjustable suction levels and a backflow protection mechanism, identical to the predicate device.
- . Both the predicate device and subject device are intended to be portable.
The differences between the subject device and the predicate device are as follows:
- There are seven (7) vacuum levels in Athena and nine (9) vacuum levels in the predicate device. ●
- . Athena automatically switches from Stimulation mode to Expression mode. It does not allow the user to manually alternate between modes. The predicate device has a let-down button that allows the user to manually change phases.
- Athena is operative via Li Ion battery and the predicate consists of Li Ion battery and AC adaptor.
- . There are only two components that require manual cleaning in Athena; whereas, there are five components that require manual cleaning in the predicate.
The differences between the subject device and predicate device do not raise different questions of safety or efficacy.
Performance Data: The following performance data were provided to verify that the subject device met all design specifications and provided support of the substantial equivalence determination.
- Bench Testing
- Reliability testing o
- Vacuum Profile testing O
- O Sound testing
- Cycle Frequency testing O
- Dimensional testing O
- Bag Pressure testing O
- Bag Puncture Verification testing o
- Electrical Safety ●
- IEC 60601-1+A1: 2012 O
- IEC 60601-1-11:2015 O
- IEC 60601-1-6: 2010 + A1:2013 O
- IEC 62366:2007 + A1: 2014 o
- IEC 62133:2012 o
- Electromagnetic Compatibility ●
- o IEC 60601-1-2:2014
- . Biocompatibility (ISO 10993-1)
- O Sensitization
- O Irritation
- Cytotoxicity O
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| Cleaning Validation AAMI TIR 12:2010 AAMI TIR 30:2011 FDA Guidance “Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling” issued March 17, 2015 (UCM253010). Software Validation FDA Guidance: “Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices” issued May 11, 2005. | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Clinical Data: | Clinical testing was not required to demonstrate substantial equivalence of the Athena to its predicate device. |
| Animal Data: | No animal performance data was required to demonstrate substantial equivalence of the Athena to its predicate device. |
| Summary of Substantial Equivalence: | The ExploraMed NC7 Athena Breast Pump is substantially equivalent to the predicate device as confirmed through relevant performance tests and device attributes. Therefore, the ExploraMed NC7 Athena Breast Pump is as safe and effective as 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.