K161395 · Source Production and Equipment Co., Inc. · KXK · Jul 6, 2016 · Radiology
Device Facts
Record ID
K161395
Device Name
SPEC Model M13
Applicant
Source Production and Equipment Co., Inc.
Product Code
KXK · Radiology
Decision Date
Jul 6, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.5730
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The intended use of Source Production & Equipment Co., Inc. Model M13 1991ridium Brachytherapy Source is for the treatment of cancer by temporary interstitial, intracavitary, intraluminal, intraoperative or surface irradiation.
Device Story
Model M13 192Iridium Brachytherapy Source is a singly-encapsulated radioactive source used in high dose rate (HDR) brachytherapy. The device consists of a solid 192Iridium pellet sealed in a stainless steel capsule, welded to a stranded stainless steel cable. It is designed for manipulation by a remote afterloading system (e.g., Varian GammaMed Plus). The source emits photons for localized tumor treatment. It is used in clinical settings by trained personnel within shielded enclosures. The device provides targeted radiation to treat various cancers, including those of the cervix, prostate, and breast. It is intended for temporary application, allowing for precise dose delivery to the tumor site while minimizing exposure to surrounding healthy tissue.
Clinical Evidence
No clinical data. Evidence is based on bench testing, including physical, tensile, and operational performance testing, and dosimetric analysis. Prototype sources met ANSI N43.6-2007 and ISO 2919-2012 standards (Classification C53211). Tensile testing demonstrated failure loads >85 N (exceeding maximum afterloader force by >5x). Operational testing confirmed successful navigation of curved pathways and endurance over 35,000 cycles. Dosimetry was validated via Monte Carlo simulation.
Technological Characteristics
192Iridium radioactive source; stainless steel encapsulation and 7x7+4 stranded stainless steel cable. Dimensions: Configuration H (0.9mm x 4.8mm capsule), Configuration P (0.9mm x 3.3mm capsule). Energy source: 192Iridium (73.81-day half-life) emitting photons (67 keV x-rays; 201, 311, 467, 603 keV gammas). Standards: ANSI N43.6, ISO 2919, AAPM TG-43. Non-contact device; no sterilization required. Mechanical safety: ANSI N43.6 Class C53211.
Indications for Use
Indicated for temporary interstitial, intraluminal, intraoperative or surface application to treat selected localized tumors. Used as primary treatment for anatomical sites including cervix, vagina, endometrium, rectum, esophagus, bronchus, head and neck, bile duct, brain, skin, prostate, lung, pancreas, and breast, and for sarcomas and intraoperative radiation therapy. May be used concurrently with or following external beam radiation therapy.
Regulatory Classification
Identification
A radionuclide brachytherapy source is a device that consists of a radionuclide which may be enclosed in a sealed container made of gold, titanium, stainless steel, or platinum and intended for medical purposes to be placed onto a body surface or into a body cavity or tissue as a source of nuclear radiation for therapy.
Special Controls
*Classification.* Class II (special controls). A prostate seeding kit intended for use with a radionuclide brachytherapy source only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
Predicate Devices
Source Production & Equipment Co., Inc. Model M15 (K132969)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 13, 2016
Source Production and Equipment Co.,Inc. % Ms. Kelley Richardt Regulatory and Quality Manager 113 Teal Street SAINT ROSE LA 70087
Re: K161395
Trade/Device Name: Source Production and Equipment Co., Inc. Model M13 1991ridium Brachytherapy Source Regulation Number: 21 CFR 892.5730 Regulation Name: Radionuclide brachytherapy source Regulatory Class: II Product Code: KXK Dated: May 16, 2016
Dear Ms. Richardt:
Received: May 19, 2016
This letter corrects our substantially equivalent letter of July 6, 2016.
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 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
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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" (21CFR 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,
Michael D'Hara
For
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K161395
#### Device Name
Source Production & Equipment Co., Inc. Model M13 192Iridium Brachytherapy Source
#### Indications for Use (Describe)
Source Production & Equipment Co., Inc. Model M13 192Iridium Brachytherapy Source, with individual activity up to 12 Ci, is indicated for temporary interstital, intraluminal, intraoperative or surface application to treat selected localized turnors. This source can be used as primary treatment for a variety of anatomical sites commonly treated with high dose rate brachytherapy, including the cervix, vagina, endometrium, rectum, esophagus, bronchus, head and neck, bile duct, brain, skin, prostate, lung, pancreas, and breast and for treatment of sarcomas and for intraoperative radiation therapy. This source may be used concurrently with or following treatment with external beam radiation therapy.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| <span style="font-family: Arial;"> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span style="font-family: Arial;"> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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Image /page/3/Picture/0 description: The image shows the word "spec" in a stylized font, with each letter outlined in black. To the right of the word, there is a radiation symbol, also in black. The word and the symbol are the only elements in the image, set against a white background. The overall design is simple and graphic.
# Section 5 510(k) Summary
Section 807.92(a)
- Submitter Source Production & Equipment Co., Inc. Tel: 504.464.9471 (1) 113 Teal Street 504.467.7685 Fax: St. Rose. LA 70087 Establishment Registration No.: 1000437833 Contact Person: John J. Munro III Vice President e-mail: johnm@spec150.com (2) Device Name:
- Radionuclide Brachytherapy Source (892.5730) (90 KXK) Classification Name: Brachytherapy Source Assembly Common or Usual Name: Proprietary Name: Source Production & Equipment Co., Inc. Model M13 192 Iridium Brachytherapy Source
- (3) Legally Marketed Predicate Device:
Source Production & Equipment Co., Inc. Model M15, cleared under 510(k) number K132969 dated 02 January 2014
- Description of Source Production & Equipment Co., Inc. Model M13 192 ridium (4) Brachytherapy Source:
Source Production & Equipment Co., Inc. Model M13 192 ridium Brachytherapy Source is a sinqly-encapsulated 1921ridium Brachytherapy Source. It consists of a stainless steel capsule containing a solid radioactive 1921ridium pellet is sealed in a stainless steel capsule that is attached to a cable to permit manipulation by the remote afterloading system.
- (5) Intended Use
The intended use of Source Production & Equipment Co., Inc. Model M13 1991ridium Brachytherapy Source is for the treatment of cancer by temporary interstitial, intracavitary, intraluminal, intraoperative or surface irradiation.
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- (6) Technological Characteristics:
Source Production & Equipment Co., Inc. Model M13 192ridium Brachytherapy Source is similar to the predicate high dose rate brachytherapy source that utilizes photons from 192 Iridium.
| Technological<br>Characteristic | Source Production & Equipment Co.,<br>Inc. (SPEC)<br>M13 192Iridium High Dose Rate<br>Brachytherapy Source | Source Production & Equipment Co.,<br>Inc. (SPEC)<br>M15 192Iridium High Dose Rate<br>Brachytherapy Source |
|-----------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Design | The source consists of a solid 192Iridium<br>pellet (Configuration H: 0.6 mm dia x 3.5<br>mm long; Configuration P: 0.6 mm dia x<br>2.0 mm long)) singly encapsulated in<br>stainless steel (Configuration H: 0.9 mm<br>dia x 4.8 mm long; Configuration P: 0.9<br>mm dia x 3.3 mm long) and welded to a<br>7x7+4 stranded stainless steel cable (0.9<br>mm dia x 2100 mm long). | The source consists of a solid 192Iridium<br>pellet (0.6 mm dia x 3.5 mm long) singly<br>encapsulated in stainless steel (1.1 mm<br>dia x 4.8 mm long) and welded to a 7x7<br>stranded stainless steel cable (1.1 mm dia<br>x 2000 mm long). |
| Materials<br>Radionuclide<br>Encapsulation | 192Iridium<br>Stainless Steel | 192Iridium<br>Stainless Steel |
| Cable | Stainless Steel | Stainless Steel |
| Performance<br>Dosimetry (TG43)<br>Dose Rate Const (λ)<br>Anisotropy (φav): | Configuration H<br>1.11 cGy h-1 U-1<br>0.97 | Configuration P<br>1.12 cGy h-1 U-1<br>0.97 |
| Sterility | This source assembly never directly<br>contacts the patient; sterility is not<br>required. | This source assembly never directly<br>contacts the patient; sterility is not<br>required. |
| Biocompatibility | This source assembly never directly<br>contacts the patient; biocompatibility<br>assessment is not applicable. The<br>outside of the entire assembly is<br>fabricated from stainless steel, which is a<br>biocompatible material. | This source assembly never directly<br>contacts the patient; biocompatibility<br>assessment is not applicable. The<br>outside of the entire assembly is<br>fabricated from stainless steel, which is a<br>biocompatible material. |
| Mechanical Safety | ANSI N43.6 Class C53211<br>Applied for Louisiana Registration | ANSI N43.6 Class C53211<br>Louisiana Sealed Source Registration<br>LA-0612-S-117-S |
| Chemical Safety | This source assembly never directly<br>contacts the patient; chemical safety<br>assessment is not applicable. The<br>outside of the entire assembly is<br>fabricated from stainless steel, which is<br>will not chemically react with body tissue. | This source assembly never directly<br>contacts the patient; chemical safety<br>assessment is not applicable. The<br>outside of the entire assembly is<br>fabricated from stainless steel, which is<br>will not chemically react with body tissue. |
| Energy Delivered | 192Iridium (half-life: 73.81 days) which<br>decays by beta emission and electron<br>capture with the emission of characteristic<br>photons and electrons. The betas and<br>electrons are absorbed by the stainless<br>steel wall of the source capsule. The | 192Iridium (half-life: 73.81 days) which<br>decays by beta emission and electron<br>capture with the emission of characteristic<br>photons and electrons. The betas and<br>electrons are absorbed by the stainless<br>steel wall of the source capsule. The |
| | principal photon emissions are 67 keV x-<br>rays and 201, 311, 467, and 603 keV<br>gammas. | principal photon emissions are 67 keV x-<br>rays and 201, 311, 467, and 603 keV<br>gammas. |
| Compatibility with<br>Environment and<br>Other Devices | 192Iridium is a radioactive material and<br>should be strictly controlled. | 192Iridium is a radioactive material and<br>should be strictly controlled. |
| | The source should only be used following<br>the conditions and limitations specified by<br>the licensing authority (NRC or Agreement<br>State). | The source should only be used following<br>the conditions and limitations specified by<br>the licensing authority (NRC or Agreement<br>State). |
| | The source should be stored in a shielded<br>container, either the remote afterloader<br>with which it is used or the transport<br>container in which it is delivered. | The source should be stored in a shielded<br>container, either the remote afterloader<br>with which it is used or the transport<br>container in which it is delivered. |
| | If any source cannot be accounted for, the<br>loss should be reported to the federal or<br>state licensing agency. | If any source cannot be accounted for, the<br>loss should be reported to the federal or<br>state licensing agency. |
| | Store at normal room temperature. | Store at normal room temperature. |
| | When disposal is indicated, radioactive<br>material should be transferred to an<br>authorized recipient, typically the source<br>supplier. Radioactive material should<br>never be disposed of in normal waste. | When disposal is indicated, radioactive<br>material should be transferred to an<br>authorized recipient, typically the source<br>supplier. Radioactive material should<br>never be disposed of in normal waste. |
| Where Used | This source should only be used within a<br>properly shielded enclosure designed to<br>maintain radiation dose rates outside the<br>enclosure within regulatory limits. | This source should only be used within a<br>properly shielded enclosure designed to<br>maintain radiation dose rates outside the<br>enclosure within regulatory limits. |
| Standards Met<br>Mechanical<br>Dosimetry | ANSI N43.6<br>AAPM TG-43 | ANSI N43.6<br>AAPM TG-43 |
| Electrical Safety | Not Applicable | Not Applicable |
| Thermal Safety | Not Applicable | Not Applicable |
| Radiation Safety | This 192Iridium source is radioactive, and<br>appropriate precautions must be taken<br>during handling to minimize radiation<br>exposure to personnel. Personnel<br>monitoring is required. | This 192Iridium source is radioactive, and<br>appropriate precautions must be taken<br>during handling to minimize radiation<br>exposure to personnel. Personnel<br>monitoring is required. |
| | This source should only be used within a<br>properly shielded enclosure designed to<br>maintain radiation dose rates outside the<br>enclosure within regulatory limits. | This source should only be used within a<br>properly shielded enclosure designed to<br>maintain radiation dose rates outside the<br>enclosure within regulatory limits. |
| | In circumstances where emergency<br>operations must be performed within<br>protective barriers, the operator should<br>use proper applicators, maintain safe<br>working distances and work as rapidly as<br>safely possible to minimize radiation<br>exposure. | In circumstances where emergency<br>operations must be performed within<br>protective barriers, the operator should<br>use proper applicators, maintain safe<br>working distances and work as rapidly as<br>safely possible to minimize radiation<br>exposure. |
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#### Section 807.92(b)
#### (1) Nonclinical Tests
#### Physical Testing
The Model M13 source has been subjected to the tests specified in American National Standard (ANSI) N43.6 and International Organization for Standardization (ISO) Standard 2919, as referenced in the FDA "Guidance for the Submission of Premarket Notifications for Photon-Emitting Brachytherapy Sources" dated 2 August 2000.
Prototype sources were subiected to the tests specified in ANSI N43.6-2007 and ISO 2919-2012 and have equaled or exceeded the requirements corresponding to a classification of C53211, which is the requirement for brachytherapy sources. This is equivalent to the physical testing of the predicate device.
#### Tensile Testing
Prototype sources were subiected to a tensile load to failure with the minimum failure load of 85 N (19 lb). The maximum force that can be applied by the Varian GammaMed Plus Afterloader is 16 N (3.6 lb). Therefore, this test load was more than 5 times the maximum force that can be applied by the Varian GammaMed Plus Afterloader.
In addition, prototypes were subjected to a series of tensile fatique tests consisting of:
- a tensile load in excess of 40 N (9 lb), which is more than 2.5 times the maximum . force than can be applied to the cable by the Varian GammaMed Plus Afterloader
- ten sequential applications of a tensile load of in excess of 16 N (3.6 lbs) which is . more than the maximum load that can be applied by the Varian GammaMed Plus Afterloader, and then
- a tensile load in excess of 40 N (9 lb), which is more than 2.5 times the maximum ● force than can be applied to the cable by the Varian GammaMed Plus Afterloader
- . and finally a tensile load to failure of each of the welds of the source assembly, where the the minimum failure load was 84 N (19 lb) which is more than 5 times the maximum force that can be applied by the Varian GammaMed Plus Afterloader.
It is concluded that that the tensile strength of this source assemble is sufficient for its intended application. This is equivalent to or better than the tensile testing of the predicate device.
#### Operational Testing
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Image /page/7/Picture/0 description: The image shows the word "spec" in a stylized font, with each letter outlined in black. To the right of the word, there is a radiation symbol, also in black. The word and the symbol are the only elements in the image, and they are set against a white background. The overall design is simple and graphic.
A prototype source assembly was subjected to a curved pathway performance test consisting of driving the source cable through a series of "S" and "U" curves with a variety of radii which simulate the various pathways of applicators used with the GammaMed Plus Afterloader. The source capsule and cable successfully negotiated all of these pathways. There was no damage to the M13 source assembly.
Subsequently, the same source assembly was subjected to an endurance performance test in a simulated GammaMed Plus Afterloader, where the source assembly performed more than 35,000 exposure/retract cycles. As a result of these tests, there was no failure of the source cable, the source capsule or the connection of the source capsule to the source cable.
This is equivalent to the physical testing of the predicate device.
### Dosimetry
The dose distribution around the Model M13 source was calculated by Monte Carlo simulation in accordance with the recommendations of the American Association of Physicists in Medicine and the European Society for Therapeutic Radiation Oncology. 1 This is equivalent to the dosimetry of the predicate device.
- (2) Clinical Tests
Not Applicable
- (3) Conclusions
The results of the nonclinical physical, tensile, operational tests and the dosimetric analysis, demonstrate that the SPEC Model M13 High Dose Rate Brachytherapy Source is as safe, as effective, and performs as well or better than the leqally marketed predicate device, SPEC Model M15 High Dose Rate Brachytherapy Source.
<sup>1</sup> Perez-Calatayud J, Ballester F, Das RK, Dewerd LA, Ibbott GS, Meigooni AS, Ouhib Z, Rivard MJ, Sloboda RS, Williamson JF, Dose calculation for photon-emitting brachytherapy sources with average energy higher than 50 keV: report of the AAPM and ESTRO, Med Phys. 2012 May;39(5):2904-29
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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.
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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.