ASHCOM Shoulder System, Anatomical Shoulder System and Anatomical Shoulder Combined System
Applicant
Zimmer GmbH
Product Code
PHX · Orthopedic
Decision Date
Jun 1, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3660
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Anatomical Shoulder System is intended for long-term implantation into the human shoulder joint in primary or revision, total or hemi shoulder arthroplasty. The system is intended to relieve pain and restore function in patients with adequate bone stock to support the prosthesis. The ASHCOM Shoulder System is intended for reverse shoulder arthroplasty.
Device Story
Modular shoulder prosthesis system; includes humeral stems, glenoid components, and ASHCOM AC-Connector. AC-Connector acts as double-tapered adapter allowing combination of Anatomical Shoulder Humeral Stems with Comprehensive Reverse Trays. Used in primary, revision, or fracture shoulder arthroplasty to relieve pain and restore function. Implanted by orthopedic surgeons in clinical/hospital settings. Provides structural replacement of shoulder joint; enables reverse configuration for patients with gross rotator cuff deficiency. Labeling update adds MR Conditional status for existing and new components.
Clinical Evidence
No clinical data. Substantial equivalence demonstrated via non-clinical performance testing including finite element stress analysis, cyclic fatigue testing, accelerated corrosion fatigue testing, and static taper connection testing (ASTM F2009). MRI compatibility evaluated per FDA guidance.
Technological Characteristics
Modular shoulder prosthesis; materials include metal and polymer. Features double-tapered AC-Connector. Static taper connection testing performed per ASTM F2009. MR Conditional labeling applied per FDA guidance for passive implants.
Indications for Use
Indicated for patients requiring primary, fracture, or revision total/hemi shoulder arthroplasty due to degenerative, posttraumatic, or rheumatoid arthritis, avascular necrosis, omarthrosis, cuff-tear arthropathy, or complex proximal humerus fractures. Requires adequate bone stock and functional deltoid muscle for reverse applications.
Regulatory Classification
Identification
A shoulder joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. This generic type of device includes prostheses that have a humeral resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, and is limited to those prostheses intended for use with bone cement (§ 888.3027).
Special Controls
*Classification.* Class II. The special controls for this device are:(1) FDA's:
(i) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(ii) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),”
(iii) “Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement,”
(iv) “Guidance Document for the Preparation of Premarket Notification (510(k)) Application for Orthopedic Devices,” and
(v) “Guidance Document for Testing Non-articulating, ‘Mechanically Locked’ Modular Implant Components,”
(2) International Organization for Standardization's (ISO):
(i) ISO 5832-3:1996 “Implants for Surgery—Metallic Materials—Part 3: Wrought Titanium 6-aluminum 4-vandium Alloy,”
(ii) ISO 5832-4:1996 “Implants for Surgery—Metallic Materials—Part 4: Cobalt-chromium-molybdenum casting alloy,”
(iii) ISO 5832-12:1996 “Implants for Surgery—Metallic Materials—Part 12: Wrought Cobalt-chromium-molybdenum alloy,”
(iv) ISO 5833:1992 “Implants for Surgery—Acrylic Resin Cements,”
(v) ISO 5834-2:1998 “Implants for Surgery—Ultra-high Molecular Weight Polyethylene—Part 2: Moulded Forms,”
(vi) ISO 6018:1987 “Orthopaedic Implants—General Requirements for Marking, Packaging, and Labeling,” and
(vii) ISO 9001:1994 “Quality Systems—Model for Quality Assurance in Design/Development, Production, Installation, and Servicing,” and
(3) American Society for Testing and Materials':
(i) F 75-92 “Specification for Cast Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implant Material,”
(ii) F 648-98 “Specification for Ultra-High-Molecular-Weight Polyethylene Powder and Fabricated Form for Surgical Implants,”
(iii) F 799-96 “Specification for Cobalt-28 Chromium-6 Molybdenum Alloy Forgings for Surgical Implants,”
(iv) F 1044-95 “Test Method for Shear Testing of Porous Metal Coatings,”
(v) F 1108-97 “Specification for Titanium-6 Aluminum-4 Vanadium Alloy Castings for Surgical Implants,”
(vi) F 1147-95 “Test Method for Tension Testing of Porous Metal,”
(vii) F 1378-97 “Standard Specification for Shoulder Prosthesis,” and
(viii) F 1537-94 “Specification for Wrought Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implants.”
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Public Health Service
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 1, 2017
Zimmer Gmbh Dr. Annemie Rehor Kausch Senior Specialist Regulatory Affairs Sulzerallee 8. P.O. Box 8404 Winterthur. Switzerland
Re: k170711
Trade/Device Name: ASHCOM™ Shoulder System, Anatomical Shoulder™ System And Anatomical Shoulder™ Combined System Regulation Number: 21 CFR 888.3660 Regulation Name: Shoulder joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: PHX, HSD, KWS, KWS, KWT, PAO Dated: March 7, 2017 Received: March 8, 2017
Dear Dr. Kausch:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR
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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 (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.
Mark N. Melkerson -S
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K170711
Device Name
ASHCOM™ Shoulder System Anatomical Shoulder™ System Anatomical Shoulder™ Combined System
Indications for Use (Describe) Anatomical Shoulder System and ASHCOM Shoulder System
Hemi or Total Arthroplasty Application of the Anatomical Shoulder Humeral Stems and Domelock System The Anatomical Shoulder Humeral Stems and Domelock System are indicated for
- · Advanced wear and tear of the shoulder joint resulting from degenerative, posttraumatic or theumatoid arthritis.
- · Avascular necrosis.
- · Conditions consequent to earlier operations.
- · Omarthrosis.
- · Rheumatoid arthritis.
- · Revision of shoulder prosthesis.
The Humeral Stems Cemented are intended for cemented use and the Humeral Stems Uncemented are intended for uncemented use. When used in a total shoulder application, the Anatomical Shoulder Pegged and Keeled Glenoids Cemented and the Biomet all-polyethylene Keeled Glenoid are intended for cemented use only. The Biomet Modular Hybrid Glenoid is intended to be implanted with bone cement. The optional porous titanium peg may be inserted without bone cement. The optional polyethylene peg should be inserted with bone cement.
Reverse Application of the Anatomical Shoulder System and ASHCOM Shoulder System
· The Anatomical Shoulder Inverse/Reverse System and ASHCOM Shoulder System are indicated for primary, fracture or revision total shoulder replacement for the relief of pain and significant disability due to gross rotator cuff deficiency. • The patient's joint must be anatomically suited to receive the selected implants and a functional deltoid muscle is necessary to use the device.
The Humeral Stems Cemented are intended for cemented use and the Humeral Stems Uncemented are intended for uncemented use. When used with the Anatomical Shoulder Glenoid Fixation, it is intended for uncemented use and requires two screws for fixation.
Fracture Application of the Anatomical Shoulder Fracture System
The Anatomical Shoulder Fracture System is intended for use in prosthetic replacement of the glenoid articular surface of the scapula during total-, hemi and fracture shoulder arthroplasty in treatment of the following:
- · Complex 3- and 4-part fractures of the proximal humerus with subluxation of the head fragment
- · Complex 3- and 4-part fractures of the proximal humerus with loosening of the spongiosa in the head fragment
- · Complex 3- and 4-part fractures of the proximal humerus with additional cross split of the head fragment
- Fracture instability after osteosynthesis of 3- and 4-part fragments of the proximal humerus
- · Posttraumatic necrosis of the humeral head
- · Posttraumatic arthrosis after humeral head fracture
The Humeral Fracture Stems are intended for either cemented use. When used in a total shoulder application, the Anatomical Shoulder Pegged and Keeled Glenoids Cemented are intended for cemented use only. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Anatomical Shoulder Combined System
· Omarthrosis.
Advanced destruction of the shoulder joint resulting from:
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• Rheumatoid arthritis
- Post-traumatic arthritis
- · Avascular necrosis of the humeral head
- · Cuff-tear arthropathy (Bigliani/Flatow Heads with heights of 27mm or greater)
· Conditions following earlier operations (including revision shoulder arthroplasty).
The Anatomical Shoulder Combined System is intended for cemented or cementless use.
When used with the following humeral stems the Anatomical System is intended for cemented use:
- · Anatomical Shoulder Standard Cemented Humeral Stem.
- · Anatomical Shoulder Revision Stem.
When used with the following humeral stem the Anatomical System is intended for cementless use: · Anatomical Shoulder Standard Uncemented Stem.
When used with the following humeral stems the Anatomical System is intended for cemented or cementless use:
- · Anatomical Shoulder Fracture Stem.
- · Anatomical Shoulder Fracture Long Stem.
When used with the following glenoids the Anatomical System is intended for cemented use:
- · Bigliani/Flatow Glenoid (pegged and keeled).
• Trabecular Metal™ Glenoid.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/4/Picture/1 description: The image contains the logo for Zimmer Biomet. The logo features a blue circle with a stylized "Z" inside it. Below the circle, the word "zimmer" is written in lowercase, using the same blue color as the circle and "Z".
Zimmer GmbH Sulzerallee 8
8404 Winterthur Switzerland
# 510(k) Summary
| Sponsor: | Zimmer GmbH<br>Sulzerallee 8, P.O. Box<br>8404 Winterthur, Switzerland |
|----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Annemie Rehor Kausch<br>Senior Specialist, Regulatory Affairs<br>Telephone: +41 58 854 82 61<br>Fax: + 41 52 244 86 58 |
| Date: | May, 09, 2017 |
| Trade Name: | ASHCOM TM Shoulder System<br>Anatomical Shoulder TM System<br>Anatomical Shoulder TM Combined System |
| Classification Product Code / | PHX – Shoulder Prosthesis, Reverse Configuration<br>HSD - Prosthesis, Shoulder, Hemi-, Humeral,<br>Metallic Uncemented<br>KWS - Prosthesis, Shoulder, Semi-Constrained,<br>Metal/Polymer Cemented<br>KWT - Prosthesis, Shoulder, Non-Constrained,<br>Metal/Polymer Cemented<br>PAO - Prosthesis, Shoulder, Semi-constrained,<br>Metal/Polymer + Additive, Cemented |
| Device Classification Name: | Shoulder Prosthesis |
| Regulation Number / Description: | 21 CFR § 888.3690 – Shoulder joint humeral<br>(hemishoulder) metallic uncemented prosthesis<br>21 CFR § 888.3660 – Shoulder joint metal/polymer<br>semi-constrained cemented prosthesis<br>21 CFR § 888.3650 – Shoulder joint metal/polymer<br>non-constrained cemented prosthesis |
| Predicate Device: | The following devices serve as predicate for the<br>ASHCOM Shoulder System: |
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Anatomical Shoulder System manufactured by Zimmer GmbH, K142403, cleared November 24, 2014 Comprehensive Reverse Shoulder, manufactured by Biomet Inc. K080642, cleared September 7, 2008, K113069, cleared January 11, 2012 and K113121, cleared December 16, 2011. The following predicate devices are labelled "MR conditional": Anatomical Shoulder System, manufactured by Zimmer GmbH, K990136, cleared March, 01, 1999; K030259, cleared April, 24, 2003; K051623, cleared July, 19, 2005, K053274, January, 25, 2006; K052906, cleared December, 19, 2005; K062029, cleared October, 31, 2006; K142403 cleared November 24, 2014, K160085, cleared March, 8, 2016 and K161620, cleared November, 1, 2016. Anatomical Shoulder Combined System, manufactured by Zimmer GmbH, K103404, cleared May, 15th, 2011. The ASHCOM Shoulder AC-Connector is a double tapered Adaptor that allows the combination of the Anatomical Shoulder Humeral Stems with the Comprehensive Trays. The male oval cone taper of the ASHCOM Shoulder AC-Connector is compatible with the cemented, uncemented and fracture humeral stems of the Anatomical Shoulder System. The female round taper is compatible with the Comprehensive Reverse Trays. In combination with compatible Zimmer Biomet reverse glenoid the implant is intended for a reverse application. The existing Anatomical Shoulder System, for which MR conditional labeling is proposed, is a modular shoulder prosthesis designed to be used in primary or revision, total or hemi shoulder arthroplasty. The existing Anatomical Shoulder Combined System, for which MR conditional labeling is proposed, allows the combination of a Bigliani/Flatow® Head with any Anatomical Shoulder Humeral Stem.
Device Description:
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| Intended Use: | The Anatomical Shoulder System is intended for<br>long-term implantation into the human shoulder joint<br>in primary or revision, total or hemi shoulder<br>arthroplasty. The system is intended to relieve pain<br>and restore function in patients with adequate bone<br>stock to support the prosthesis. |
|----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | The ASHCOM Shoulder System is intended for<br>reverse shoulder arthroplasty. |
| Indications for Use: | Hemi or Total Arthroplasty Application of the<br>Anatomical Shoulder Humeral Stems and Domelock<br>System<br>The Anatomical Shoulder Humeral Stems and<br>Domelock System are indicated for<br>• Advanced wear and tear of the shoulder joint<br>resulting from degenerative, posttraumatic or<br>rheumatoid arthritis.<br>• Avascular necrosis.<br>• Conditions consequent to earlier operations.<br>• Omarthrosis.<br>• Rheumatoid arthritis.<br>• Revision of shoulder prosthesis. |
| | The Humeral Stems Cemented are intended for<br>cemented use and the Humeral Stems Uncemented<br>are intended for uncemented use. When used in a total<br>shoulder application, the Anatomical Shoulder<br>Pegged and Keeled Glenoids Cemented and the<br>Biomet all-polyethylene Keeled Glenoid are intended<br>for cemented use only. The Biomet Modular Hybrid<br>Glenoid is intended to be implanted with bone<br>cement. The optional porous titanium peg may be<br>inserted without bone cement. The optional<br>polyethylene peg should be inserted with bone<br>cement. |
| | Reverse Application of the Anatomical Shoulder<br>System and ASHCOM Shoulder System |
| | • The Anatomical Shoulder Inverse/Reverse System<br>and the ASHCOM Shoulder System are indicated for<br>primary, fracture or revision total shoulder<br>replacement for the relief of pain and significant |
- disability due to gross rotator cuff deficiency. • The patient's joint must be anatomically and structurally suited to receive the selected implants and
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a functional deltoid muscle is necessary to use the device.
The Humeral Stems Cemented are intended for cemented use and the Humeral Stems Uncemented are intended for uncemented use. When used with the Anatomical Shoulder Glenoid Fixation, it is intended for uncemented use and requires two screws for fixation.
### Fracture Application of the Anatomical Shoulder Fracture System
The Anatomical Shoulder Fracture System is intended for use in prosthetic replacement of the proximal humerus and the glenoid articular surface of the scapula during total-, hemi and fracture shoulder arthroplasty in treatment of the following: · Complex 3- and 4-part fractures of the proximal
humerus with subluxation of the head fragment · Complex 3- and 4-part fractures of the proximal humerus with loosening of the spongiosa in the head fragment
· Complex 3- and 4-part fractures of the proximal humerus with additional cross split of the head fragment
· Fracture instability after osteosynthesis of 3- and 4part fracture fragments of the proximal humerus
- Posttraumatic necrosis of the humeral head
- · Posttraumatic arthrosis after humeral head fracture
The Humeral Fracture Stems are intended for either cemented or uncemented use. When used in a total shoulder application, the Anatomical Shoulder Pegged and Keeled Glenoids Cemented are intended for cemented use only.
Anatomical Shoulder Combined System Advanced destruction of the shoulder joint resulting from:
- Omarthrosis.
- Rheumatoid arthritis
- Post-traumatic arthritis
- Avascular necrosis of the humeral head
• Cuff-tear arthropathy (Bigliani/Flatow Heads with heights of 27mm or greater)
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· Conditions following earlier operations (including revision shoulder arthroplasty).
The Anatomical Shoulder Combined System is intended for cemented or cementless use.
When used with the following humeral stems the Anatomical Shoulder Combined System is intended for cemented use:
· Anatomical Shoulder Standard Cemented Humeral Stem.
· Anatomical Shoulder Revision Stem.
When used with the following humeral stem the Anatomical Shoulder Combined System is intended for cementless use:
· Anatomical Shoulder Standard Uncemented Stem.
When used with the following humeral stems the Anatomical Shoulder Combined System is intended for cemented or cementless use:
- · Anatomical Shoulder Fracture Stem.
· Anatomical Shoulder Fracture Long Stem.
When used with the following glenoids the Anatomical Shoulder Combined System is intended for cemented use:
- · Bigliani/Flatow Glenoid (pegged and keeled).
- · Trabecular Metal™ Glenoid.
Comparison to Predicate Device:
The ASHCOM AC-Connector allows the combination of the Anatomical Shoulder Humeral Stems with the Comprehensive Reverse Trays. The indications are shared with the reverse application of the Anatomical Shoulder predicate device. The ASHCOM AC-Connector utilizes the same material as the Anatomical Shoulder Humeral Stem and the same manufacturing process, and has similar technical features as the Anatomical Shoulder predicate device.
This submission further covers a labeling modification to the existing Anatomical Shoulder and Anatomical Shoulder Combined System. The labeling modification consists of the addition of Magnetic Resonance Imaging (MRI) compatibility information to the Package Insert, and application of the "MR
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Conditional" symbol on the package label. No other changes are proposed.
Performance Data (Nonclinical and/or Clinical):
Results of non-clinical performance testing and analyses demonstrate that the ASHCOM Shoulder System is safe and effective and substantially equivalent to the predicate devices. Performance analyses included:
1. Finite Element Stress analysis and cyclic fatigue testing under worst case conditions 2. Accelerated Corrosion Fatigue Testing 3. Static taper connection testing according ASTM F2009
The components of the ASHCOM Shoulder System, the Anatomical Shoulder System and the Anatomical Shoulder Combined System and have been evaluated for compatibility in the MRI environment, per Guidance for Industry and FDA Staff, "Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment", August 2014. Based upon the results, the subject shoulder implants are recommended to bear the "MR Conditional" labeling and include MR compatibility safety information within the package insert.
Clinical Performance and Conclusions: Clinical data and conclusions were not needed to demonstrate substantial equivalence.
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.