ARROW Pressure Injectable Midline Catheter with Chlorag+ard Antimicrobial and Antithrombogenic Technology
K161313 · Arrow International, Inc. (Subsidiary of Teleflex, Inc.) · PND · Aug 24, 2016 · General Hospital
Device Facts
Record ID
K161313
Device Name
ARROW Pressure Injectable Midline Catheter with Chlorag+ard Antimicrobial and Antithrombogenic Technology
Applicant
Arrow International, Inc. (Subsidiary of Teleflex, Inc.)
Product Code
PND · General Hospital
Decision Date
Aug 24, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5200
Device Class
Class 2
Indications for Use
The Arrow® Pressure Injectable Midline Catheter with Chlorag+ard® Antimicrobial and Antithrombogenic Technology is indicated for short-term (< 30 days) peripheral access to the venous therapy, blood sampling. infusion, and pressure injection of contrast media. The maximum pressure injector equipment used with the Arrow Antimicrobial and Antithrombogenic Pressure Injectable Midline Catheter may not exceed 300 psi (2068.4kPa). The maximum pressure injection flow rate for the specific lumen being used for pressure injection is printed on the extension line hub. Chlorag+ard Technology treatment on the external surface of the catheter body as well as the entire fluid pathway of the catheter has been shown to be effective in reducing microbial colonization and thrombus accumulation on catheter surfaces. Antimicrobial and antithrombogenic effectiveness was evaluated using in vitro and in vivo test methods and no correlation between these testing methods and clinical outcome has currently been ascertained. It is not intended to be used for the treatment of existing infections or vein thrombosis.
Device Story
Single-use, radiopaque polyurethane midline catheter; provides short-term (<30 days) peripheral venous access. Features Chlorag+ard antimicrobial/antithrombogenic coating on external surface and internal fluid path. Available in 4.5 Fr (single lumen) and 5.5 Fr (double lumen) configurations; 15 cm length. Includes Blue FlexTip for atraumatic insertion. Used for IV therapy, blood sampling, and contrast media injection (max 300 psi). Operated by clinicians in clinical settings. Output is venous access; healthcare providers use device to deliver fluids/medications or extract blood. Benefits include reduced microbial colonization and thrombus accumulation on catheter surfaces, potentially lowering catheter-related complications.
Clinical Evidence
Bench testing only. Performance evaluated via priming volume, gravity flow rate, pumped flow rate, pressure injection, static burst, mechanical hemolysis, and tensile testing. Antimicrobial/antithrombogenic efficacy evaluated via in vitro and in vivo methods; no clinical outcome correlation established.
Technological Characteristics
Polyurethane catheter body with 30% Bismuth Oxychloride; Blue FlexTip; Chlorhexidine-based coating. 4.5 Fr (single lumen) and 5.5 Fr (double lumen). Pressure injection up to 300 psi. Standards: ISO 10555-1, ISO 10555-3, ISO 10993-7, ISO 11135, ASTM F756-08.
Indications for Use
Indicated for short-term (< 30 days) peripheral venous access for IV therapy, blood sampling, infusion, and contrast media pressure injection in patients requiring peripheral venous access. Contraindicated for treatment of existing infections or vein thrombosis.
Regulatory Classification
Identification
An intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings and that is inserted into the patient's vascular system for short term use (less than 30 days) to sample blood, monitor blood pressure, or administer fluids intravenously. The device may be constructed of metal, rubber, plastic, or a combination of these materials.
ArrowEVOLUTION™ Pressure Injectable PICC with Chlorag+ard Antimicrobial and Antithrombogenic Technology (K112896)
Submission Summary (Full Text)
{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 stylized representation of three human profiles facing to the right, stacked on top of each other. The profiles are depicted with simple, curved lines. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the emblem.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 24, 2016
Arrow International, Inc. (subsidiary of Teleflex Inc.) Ms. Julie Lawson Regulatory Affairs Specialist 2400 Bernville Road Reading, Pennsylvania 19605
Re: K161313
Trade/Device Name: Arrow Pressure Injectable Midline Catheter with Chlorag+arde Antimicrobial and Antithrombogenic Technology Regulation Number: 21 CFR 880.5200 Regulation Name: Intravascular Catheter Regulatory Class: II Product Code: PND Dated: July 22, 2016 Received: July 25, 2016
Dear Ms. Lawson:
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,
Tina Kiang
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
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
### 510(k) Number (if known) K161313
#### Device Name
- ARROW Pressure Injectable Midline Catheter with Chlorag+ard Antimicrobial and Antithrombogenic Technology
#### Indications for Use (Describe)
The Arrow® Pressure Injectable Midline Catheter with Chlorag+ard® Antimicrobial and Antithrombogenic Technology is indicated for short-term (< 30 days) peripheral access to the venous therapy, blood sampling. infusion, and pressure injection of contrast media. The maximum pressure injector equipment used with the Arrow Antimicrobial and Antithrombogenic Pressure Injectable Midline Catheter may not exceed 300 psi (2068.4kPa). The maximum pressure injection flow rate for the specific lumen being used for pressure injection is printed on the extension line hub.
Chlorag+ard Technology treatment on the external surface of the catheter body as well as the entire fluid pathway of the catheter has been shown to be effective in reducing microbial colonization and thrombus accumulation on catheter surfaces. Antimicrobial and antithrombogenic effectiveness was evaluated using in vitro and in vivo test methods and no correlation between these testing methods and clinical outcome has currently been ascertained. It is not intended to be used for the treatment of existing infections or vein thrombosis.
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."
{3}------------------------------------------------
### 510(k) SUMMARY
### ARROW PRESSURE INJECTABLE MIDLINE CATHETER WITH CHLORAG ARD ANTIMICROBIAL AND ANTITHROMBOGENIC TECHNOLOGY
### 1. Submitter Information
| Name: | Arrow International, Inc. (subsidiary of Teleflex Inc.) |
|-------------------|---------------------------------------------------------|
| Address: | 2400 Bernville Road<br>Reading, PA 19605-9607 |
| Telephone Number: | (610) 378-0131 |
| Contact Person: | Julie Lawson<br>Regulatory Affairs Specialist |
| Telephone Number: | (610) 378-0131 Extension 603256 |
| Fax Number: | (610) 478-3179 |
| Email: | julie.lawson@teleflex.com |
Date Prepared: May 9, 2016
### 2. Device Name
| Device Trade Name: | Arrow® Pressure Injectable Midline Catheter<br>with Chlorag+ard® Antimicrobial and Antithrombogenic<br>Technology |
|--------------------|-------------------------------------------------------------------------------------------------------------------|
| Common Name: | Midline Catheter |
| Regulation Number: | 21 CFR: 880.5200 |
| Regulation Name: | Intravascular Catheter |
| Product Code: | PND |
## 3. Predicate and Reference Devices
Arrow Peripherally Inserted Midline Catheter (K963257) - Predicate
ArrowEvolution™ Pressure Injectable PICC with Chlorag ard Antimicrobial and Antithrombogenic Technology (K112896) - Reference
## 4. Device Description
The Arrow Pressure Injectable Midline Catheter with Chlorag ard Antimicrobial and Antithrombogenic Technology is a single use catheter designed to provide short-term peripheral access to the venous system. It consists of a non-tapered, radiopaque polyurethane extruded catheter body with a softer, contoured Blue FlexTip (flexible distal tip). The catheter is available in 4.5 Fr. Single lumen and 5.5 Fr. Double lumen configurations with a usable catheter length of 15 cm. The catheters can be used for the injection of contrast media. The maximum recommended infusion rate is 5 mL/sec. The external catheter body and the entire internal fluid path of the device are treated with a Chlorhexidine-based solution
{4}------------------------------------------------
technology. Studies have shown the technology to possess both antimicrobial and antithrombogenic properties.
The catheters will be packaged sterile in kits that will include components to facilitate insertion. The Chlorag+ard technology that is incorporated in the modified device's physical design is the same as the reference device.
## 5. Indications for Use
The Arrow Pressure Injectable Midline Catheter with Chlorag ard® Antimicrobial and Antithrombogenic Technology is indicated for short-term (< 30 days) peripheral access to the venous system for intravenous therapy, blood sampling, infusion, and pressure injection of contrast media. The maximum pressure injector equipment used with the Arrow Antimicrobial and Antithrombogenic Pressure Injectable Midline Catheter may not exceed 300 psi (2068.4kPa). The maximum pressure injection flow rate for the specific lumen being used for pressure injection is printed on the extension line hub.
Chlorag ard Technology treatment on the external surface of the catheter body as well as the entire fluid pathway of the catheter has been shown to be effective in reducing microbial colonization and thrombus accumulation on catheter surfaces. Antimicrobial and antithrombogenic effectiveness were evaluated using in vitro and in vivo test methods and no correlation between these testing methods and clinical outcome has currently been ascertained. It is not intended to be used for the treatment of existing infections or vein thrombosis or vein thrombosis.
## 6. Technological Characteristics and Substantial Equivalence
The Arrow Pressure Injectable Midline Catheter with Chlorag+ard Antimicrobial and Antithrombogenic Technology is substantially equivalent to the predicate Arrow Peripherally Inserted Midline Catheter (K963257) in terms of Indications for use. Both the predicate and the subject Indications for Use refer to use for peripheral access to the venous system. The difference in the Indications for use is that the subject Indications for use specifies in more detail the uses for the device and includes the ability to use the device for pressure injection as well as describing the antimicrobial and antithrombogenic properties of the subject catheter. (The predicate device does not contain antimicrobial and antithrombogenic properties.)
The Arrow Pressure Injectable Midline Catheter with Chlorag ard Antimicrobial and Antithrombogenic Technology is substantially equivalent to the reference device, the ArrowEVOLUTION™ Pressure Injectable PICC with Chlorag ard Antimicrobial and Antithrombogenic Technology (K112896) in terms of overall design, manufacturing process, functional performance, and materials of construction. The indications for use for the subject catheter are the same as the reference device (K112896) in all aspects aside from providing central venous access and the ability to use the device
{5}------------------------------------------------
for central venous pressure monitoring. The tip of the reference device (K112896) is intended to terminate in the Superior Vena Cava (central venous system) whereas the tip of the subject device is intended to terminate below the axillary line (venous system).
The same Chlorag+ard Technology treatment that is used for the reference device, the ArrowEVOLUTION™ Pressure Injectable PICC with Chlorag+ard Antimicrobial and Antithrombogenic Technology (K112896) is used for the subject device. The process of application of the Chlorag+ard Technology treatment is also the same as that of the reference device.
| Design<br>Characteristic | Predicate Device<br>Arrow Peripherally<br>Inserted Midline Catheter<br>(K963257) | Reference Device<br>AM/AT PICC (K112896) | Subject Pressure<br>Injectable CG+<br>MIDLINE |
|---------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | The Midline Catheter<br>permits venous access to the<br>peripheral circulation. It<br>offers an alternative method<br>of intravenous access for<br>select adult and pediatric<br>patients. | The Pressure Injectable<br>Peripherally Inserted<br>Central Catheters are<br>intended for short-term or<br>long-term peripheral access<br>to the central venous<br>system for intravenous<br>therapy and blood<br>sampling. | The Pressure Injectable<br>Midline Catheters are<br>intended for short-term<br>peripheral access to the<br>venous system for<br>intravenous therapy and<br>blood sampling. |
| Indications<br>for<br>Use | The Midline Catheter<br>permits venous access to the<br>peripheral circulation. It<br>offers an alternative method<br>of intravenous access for<br>select adult and pediatric<br>patients. | The ArrowEVOLUTION™<br>Pressure Injectable PICC<br>with Chlorag+ard<br>Antimicrobial and<br>Antithrombogenic<br>Technology is indicated for<br>short-term or long-term<br>peripheral access to the<br>central venous system for<br>intravenous therapy, blood<br>sampling, infusion, pressure<br>injection of contrast media,<br>and allows for central<br>venous pressure<br>monitoring. The maximum<br>pressure of pressure<br>injector equipment used<br>with the | The Arrow Pressure<br>Injectable Midline<br>Catheter with<br>Chlorag+ard<br>Antimicrobial and<br>Antithrombogenic<br>Technology is indicated<br>for short-term (< 30 days)<br>peripheral access to the<br>venous system for<br>intravenous therapy,<br>blood sampling, infusion,<br>and pressure injection of<br>contrast media. The<br>maximum pressure of<br>pressure injector<br>equipment used with the<br>Arrow Antimicrobial and<br>Antithrombogenic |
| Design<br>Characteristic | Predicate Device<br>Arrow Peripherally<br>Inserted Midline Catheter<br>(K963257) | Reference Device<br>AM/AT PICC (K112896) | Subject Pressure<br>Injectable CG+<br>MIDLINE |
| | | Pressure Injectable PICC<br>may not exceed 300 psi.<br>Chlorag+ard Technology<br>treatment on the external<br>surface of the catheter body<br>as well as the entire fluid<br>pathway of the catheter has<br>been shown to be effective<br>in reducing microbial<br>colonization and thrombus<br>accumulation on catheter<br>surfaces. Antimicrobial<br>and antithrombogenic<br>effectiveness were<br>evaluated using <i>in vitro</i> and<br><i>in vivo</i> test methods and no<br>correlation between these<br>testing methods and clinical<br>outcome has currently been<br>ascertained. It is not<br>intended to be used for the<br>treatment of existing<br>infections or vein<br>thrombosis. | Pressure Injectable<br>Midline Catheter may not<br>exceed 300 psi<br>(2068.4kPa). The<br>maximum pressure<br>injection flow rate for the<br>specific lumen being used<br>for pressure injection is<br>printed on the extension<br>line hub.<br>Chlorag+ard Technology<br>treatment on the external<br>surface of the catheter<br>body as well as the entire<br>fluid pathway of the<br>catheter has been shown<br>to be effective in<br>reducing microbial<br>colonization and<br>thrombus accumulation<br>on catheter surfaces.<br>Antimicrobial and<br>antithrombogenic<br>effectiveness were<br>evaluated using <i>in vitro</i><br>and <i>in vivo</i> test methods<br>and no correlation<br>between these testing<br>methods and clinical<br>outcome has currently<br>been ascertained. It is not<br>intended to be used for<br>the treatment of existing<br>infections or vein<br>thrombosis. |
| Catheter OD | 3, 4 and 5 Fr | 4.5 Fr and 5.5 Fr | Same as reference device:<br>4.5 Fr and 5.5 Fr. |
| Catheter<br>Usable Length | 15 cm | 40, 50, and 55 cm | Same as predicate device:<br>15 cm. |
| Design<br>Characteristic | Predicate Device<br>Arrow Peripherally<br>Inserted Midline Catheter<br>(K963257) | Reference Device<br>AM/AT PICC (K112896) | Subject Pressure<br>Injectable CG+<br>MIDLINE |
| Number<br>of Lumens | 3, 4 and 5 Fr. - 1 lumen<br>4 and 5 Fr. - 2 lumens | 4.5 Fr. - 1 lumen<br>5.5 Fr. - 2 lumens | Same as reference device:<br>4.5 Fr. - 1 lumen<br>5.5 Fr. - 2 lumens |
| Internal<br>Lumen<br>Configuration | Round<br>Circle/crescent | 4.5 Fr. - Round<br>5.5 Fr. - Double D | Same as reference device:<br>4.5 Fr. - Round<br>5.5 Fr. - Double D |
| Catheter Tip<br>Configuration | Blunt Tip | Blue FlexTip | Same as reference device:<br>Blue FlexTip |
| Pressure<br>Injection<br>Capabilities | None | Distal lumen – 5 mL/sec,<br>Pressure Injectable<br>Proximal lumen – 5<br>mL/sec, Pressure Injectable | Distal lumen - 5 mL/sec,<br>Pressure Injectable<br>Proximal lumen- Not<br>labeled for Pressure<br>Injection |
| Chlorhexidine<br>-Based<br>Coating<br>Performance | None | Antimicrobial Efficacy<br>Effective in reducing<br>microbial colonization<br>Antithrombogenic Efficacy<br>Effective in reducing<br>thrombus accumulation | Same as reference device:<br>Antimicrobial Efficacy<br>Effective in reducing<br>microbial colonization<br>Antithrombogenic<br>Efficacy<br>Effective in reducing<br>thrombus accumulation |
| Catheter Body<br>Material | White Polyurethane with<br>20% Barium Sulfate | Blue Polyurethane<br>with 30% Bismuth<br>Oxychloride | Same as reference device:<br>Blue Polyurethane<br>with 30% Bismuth<br>Oxychloride |
| Catheter Tip<br>Material | White Polyurethane with<br>20% Barium Sulfate | Blue Polyurethane with<br>30% Bismuth Oxychloride | Same as reference device:<br>Blue Polyurethane with<br>30% Bismuth<br>Oxychloride |
| Juncture<br>Hub Material | White Polyurethane | Transparent Light Blue<br>Polyurethane | Same as reference device:<br>Transparent Light Blue<br>Polyurethane |
| Extension Line | Clear Polyurethane | Clear Polyurethane | Same as reference device: |
| Design<br>Characteristic | Predicate Device<br>Arrow Peripherally<br>Inserted Midline Catheter<br>(K963257) | Reference Device<br>AM/AT PICC (K112896) | Subject Pressure<br>Injectable CG+<br>MIDLINE |
| Material | | | Clear Polyurethane |
| Extension<br>Hub<br>Material | Natural Polyurethane | Distal - Pink Polyurethane<br>Proximal – White<br>Polyurethane | Same as reference device:<br>Distal – Pink<br>Polyurethane<br>Proximal – White<br>Polyurethane |
| Printing Ink | Printing Ink NT16 Black Ink<br>Black Hot Stamp Printing<br>Foil | Printing Ink 2405 Black Ink | Same as reference device:<br>Printing Ink 2405 Black<br>Ink |
| Safety and<br>Performance<br>Testing | Mechanical testing to:<br>• ISO 10555-1<br>• ISO 10555-3<br>Biocompatibility testing | Mechanical testing to:<br>• ISO 10555-1<br>• ISO 10555-3<br>Biocompatibility testing | Same as both predicate<br>and reference device:<br>Mechanical testing to:<br>• ISO 10555-1<br>• ISO 10555-3<br>Biocompatibility testing |
## Predicate, Reference and Subject Device Comparison
{6}------------------------------------------------
{7}------------------------------------------------
{8}------------------------------------------------
{9}------------------------------------------------
# 7. Nonclinical Testing
The following performance testing related to the device changes has been completed to support the substantial equivalence of the subject devices to the predicate and reference devices:
- O priming volume
- gravity flow rate O
- 10 psi pumped flow rate O
- O rate limited pressure injection
- pressure limited injection O
- static burst O
- mechanical hemolysis O
- tensile testing (extension line to luer hub) O
The following standards were used in the non-clinical testing listed above:
- o ASTM F756-08
- o ISO 10555-1
- ISO 10555-3 O
- o ISO 10993-7
- o ISO 11135
# 8. Conclusions
The Arrow Pressure Injectable Midline Catheter with Chlorag ard Antimicrobial and Antithrombogenic Technology is the same device as the reference device, the ArrowEVOLUTION Pressure Injectable PICC with Chlorag ard Antimicrobial and Antithrombogenic Technology (K112896) with the exception of usable catheter length, extension line hub design (on proximal lumen of 2 lumen midline catheter) and extension line text. The results of the testing performed have demonstrated that the devices are safe, effective, and perform as intended. The subject device and predicate and reference devices (K963257 and K112896 respectively) have the same insertion site and associated insertion procedure. The final indwelling tip position of the subject and predicate (K963257) device is the same because they are both midline catheters per the proposed indications for use.
In conclusion, the Arrow Pressure Injectable Midline Catheter with Chlorag ard Antimicrobial and Antithrombogenic Technology is substantially equivalent to the predicate Arrow Peripherally Inserted Midline Catheter (K963257) and the reference device, the ArrowEVOLUTION Pressure Injectable PICC with Chlorag ard Antimicrobial and Antithrombogenic Technology (K112896).
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.