K161866 · Navilyst Medical, Inc. · FOZ · Sep 8, 2016 · General Hospital
Device Facts
Record ID
K161866
Device Name
BioFlo Midline Catheter
Applicant
Navilyst Medical, Inc.
Product Code
FOZ · General Hospital
Decision Date
Sep 8, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5200
Device Class
Class 2
Indications for Use
The BioFlo Midline Catheter is indicated for short term access to the peripheral venous system for intravenous therapy, including but not limited to, the administration of fluids, medications and the sampling of blood and blood products.
Device Story
BioFlo Midline Catheter is a peripheral venous access device (3-10 inches long) for short-term therapy. It is placed in arm veins (basilic, brachial, or cephalic) with the tip ending before the axillary line. The device serves as an alternative to short peripheral IVs and PICCs. It supports power injection of fluids and medications. The device is used by clinicians in a clinical setting. The healthcare provider inserts the catheter and uses it to deliver intravenous therapies or sample blood. The device benefits patients by providing reliable venous access for prescribed treatments.
Clinical Evidence
No clinical data. Bench testing only, as the modification was limited to the Directions for Use. Previous performance testing for the predicate device included power injection flow rate, static burst strength, gravity flow rate, catheter kink/flex resistance, alcohol compatibility, radiopacity, and tensile testing, conducted per FDA guidance and ISO standards (e.g., EN ISO 10555-1, EN ISO 10993-1).
Technological Characteristics
Intravascular catheter, 3-10 inches (8-25 cm) length. Materials, design, and components are identical to the predicate. Features include power injection capability, luer lock fittings (ISO 594-2), and radiopaque markers. Sterilization is not specified but implied as single-use sterile. No software or electronic components.
Indications for Use
Indicated for short-term peripheral venous access for intravenous therapy, including fluid/medication administration and blood sampling.
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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 8, 2016
Navilyst Medical, Inc. Robin Fuller Sr. Manager, Regulatory Affairs 26 Forest Street Marlborough, Massachusetts 07152
Re: K161866
Trade/Device Name: BioFlo Midline Catheter Regulation Number: 21 CFR 880.5200 Regulation Name: Intravascular Catheter Regulatory Class: II Product Code: PND Dated: July 7, 2016 Received: July 7, 2016
Dear Robin Fuller:
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.
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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,
Tina
Kiang -S
Tina Kiang, Ph.D. Acting Director Division of Anesthesiology. General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K161866
Device Name BioFlo Midline Catheter
### Indications for Use (Describe)
The BioFlo Midline catheter is indicated for short term access to the peripheral venous therapy, including but not limited to, the administration of fluids, medications and the sampling of blood and blood products.
Maximum Power Injection Flow Rate
* 3F Single Lumen/20 cm - 2 mL/sec
- * 4F Single Lumen/20 cm 6 mL/sec
- * 5F Single Lumen/20 cm 6 mL/sec
- * 5F Dual Lumen/20 cm 6 mL/sec
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
### PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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# 510(k) Summary for the BioFlo Midline Catheter
Date prepared: 8-September-2016
### A. Sponsor
Navilyst Medical, Inc 26 Forest Street Marlborough, MA 01752
### B. Contact
Robin Fuller Sr. Manager, Regulatory Affairs 508-658-7986
### Or
Wanda Carpinella Director, Regulatory Affairs 508-658-7929
#### C. Subject Device
| Trade Name: | BioFlo Midline Catheter |
|-----------------------|-------------------------|
| Common name: | Intravascular Catheter |
| Regulation Number | 21CFR§880.5200 |
| Regulation Name: | Intravascular Catheter |
| Regulatory Class: | Class II |
| Product Code: | PND |
| Classification Panel: | General Hospital |
#### D. Predicate Device
Trade Name: 510(k) Reference: Common name: Regulation Number Regulation Name: Regulatory Class: Product Code: Classification Panel:
BioFlo Midline Catheter K150407 Intravascular Catheter 21CFR§880.5200 Intravascular Catheter Class II PND General Hospital
### E. Device Description
The BioFlo Midline Catheter is a short term peripheral venous access device between 3 to 10 inches in length (8 to 25 cm). Midlines are usually placed in an arm vein such as the basilic, brachial or cephalic and the tip ends below the level of the axillary line. Midline catheters are longer than peripheral IV catheters which are generally 1 to 3 inches long and shorter than
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peripherally inserted central catheters (PICC) which extend into the superior vena cava. This device provides an alternative to short peripheral IVs and PICCs for certain treatments.
# F. Intended Use/Indications for Use
The BioFlo Midline Catheter is indicated for short term access to the peripheral venous system for intravenous therapy, including but not limited to, the administration of fluids, medications and the sampling of blood and blood products.
Maximum Power Injection Flow Rates:
- . 3F Single Lumen, 20cm: 2 mL/sec
- 4F Single Lumen, 20cm: 6 mL/sec ●
- 5F Single Lumen, 20cm: 6 mL/sec ●
- 5F Dual Lumen, 20cm: 6 mL/sec .
# G.Summary of Similarities and Differences in Technological Characteristics and Performance
The proposed device is identical in regards to materials, design and components and technological characteristics as the predicate device. The only difference between the proposed device and the predicate device is a change to the Directions For Use (DFU). These changes are noted in Table 1 below.
| DFU Section | Proposed Device:<br>BioFlo Midline<br>Catheter | Predicate Device:<br>BioFlo Midline<br>Catheter (K150407) |
|----------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended<br>Use/Indications For<br>Use | The BioFlo Midline<br>is indicated for short<br>term access to the<br>peripheral venous<br>system for<br>intravenous therapy,<br>including but not<br>limited to, the<br>administration of<br>fluids, medications<br>and the sampling of<br>blood and blood<br>products. | The BioFlo Midline is<br>indicated for short<br>term access (< 30<br>days) to the peripheral<br>venous system for<br>intravenous therapy,<br>including but not<br>limited to, the<br>administration of<br>fluids, medications<br>and the sampling of<br>blood and blood<br>products. |
| | Maximum Power<br>Injection Flow Rate<br>● 3F Single<br>Lumen/20 cm – | Therapies not<br>appropriate for BioFlo<br>Midline catheters<br>include continuous<br>vesicant therapy,<br>parenteral nutrition |
| | 2mL/sec 4F Single Lumen/20 cm – 6 mL/sec 5F Single Lumen/20 cm – 6mL/sec 5F Dual Lumen/20 cm – 6mL/sec | infusates with pH less than 5 or greater than 9, and infusates with an osmolarity greater than 600 mOsm/L<br>Maximum Power Injection Flow Rate 3F Single Lumen/20 cm – 2mL/sec 4F Single Lumen/20 cm – 6 mL/sec 5F Single Lumen/20 cm – 6mL/sec 5F Dual Lumen/20 cm – 6mL/sec |
| Warnings | Therapies not appropriate for BioFlo Midline Catheters include those therapies requiring central venous access. | Therapies not appropriate for BioFlo Midline Catheters include: Continuous vesicants * parenteral nutrition * solutions with pH < 5 and > 9 * solutions > 600 mOsmL |
| | | |
# Table 1: Comparison of DFU changes
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Consistent with the Infusion Nurses Society Standards Practice (INS) 2011, the BioFlo Midline Catheter DFU lists out the therapies not appropriate for Midline Catheters under the Indications for Use and Warnings sections. In the INS 2011 version under the section on Midline catheters it states:
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"Therapies not appropriate for midline catheters include continuous vesicant therapy, parenteral nutrition, infusates with pH less than 5 or greater than 9, and infusates with an osmolality greater than 600 mOsm/L".
Since the original 510(k) submission was concurred (K150407) the INS Standards of Practice has been revised (2016). In the INS 2016 version they have removed reference to infusates with pH less than 5 or greater than 9 and increased the infusates with osmolality from greater than 600 mOsm/L to greater than 900 mOsm/L. In order to not have to update the DFU each time the INS standard changes, we are proposing to change this information in the DFU to refer to the standards of practice. This is similar to the DFU of another Midline Catheter, the Bard PowerGlide Midline catheter (K133856). The Bard PowerGlide Catheter does not refer to therapies not appropriate and the Warning section does not list out therapies not appropriate but rather, refers to those therapies requiring central venous access and refers to standards of practice. The change being made to the BioFlo Midline Catheter DFU would be the same as the Bard PowerGlide Midline DFU.
The change in the Directions for Use does not change the intended use of the device which is to be used for short term access (< 30 days) to the peripheral venous system for intravenous therapy, including but not limited to, the administration of fluids, medications and the sampling of blood and blood products. The change to the DFU is within an approved set of indications and does not affect the safety or effectiveness of the device.
# H.Performance Data
There was no performance testing required due to the DFU change. Performance testing of the predicate BioFlo Midline Catheter included non-clinical bench testing conducted in accordance to the following FDA Guidance Documents and international standards:
- . FDA's "Guidance on Premarket Notification [510(k)] Submissions for Short-Term and Long-Term Intravascular Catheters";
- . EN ISO 10555-1:2013 - "Intravascular Catheters - Sterile and Single-Use Catheters -Part 1: General Requirements"
- EN ISO 10555-3:2013 "Intravascular Catheters Sterile and Single-Use Catheters -● Part 3: Central Venous Catheters"
- ISO 594-2:1998 - "Conical Fittings with a 6% (Luer) Taper for Syringes, Needles, and Certain Other Medical Equipment - Part 2: Lock Fittings"
- EN ISO 10993-1:2009 "Biological Evaluation of Medical Devices Part 1: Evaluation . and Testing Within a Risk Management Process"
Bench testing included:
- . Power Injection Flow Rate
- Static Burst Strength
- Multiple Power Injections
- Gravity Flow Rate ●
- Catheter Length
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- Priming Volume ●
- Midline Identification
- Dimensional Verification (including ID, OD, Length) ●
- Catheter Kink/Flex Resistance (including Elongation, Stiffness, Flex Life Strength) ●
- Alcohol Compatibility ●
- Catheter Marking & Identification/Radiopacity Testing ●
- Tensile Testing (of Catheter and Assembly) ●
- Compatibility Testing .
# F. Conclusion
Based on the proposed device having identical materials, design and components and technological characteristics as the predicate device and the same or similar Intended Use as the predicate device the proposed device is determined to be substantially equivalent to the predicate device.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.