KYPHON Xpede Bone Cement, CD HORIZON Fenestrated Screw Set
Applicant
Medtronic
Product Code
PML · Orthopedic
Decision Date
Oct 23, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3027
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
When used without cement, the CD HORIZON™ Fenestrated Screws (with or without SEXTANT™ or LONGITUDE™ instrumentation) are intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, tumor and/or trauma (i.e., fracture or dislocation), spinal stenosis, curvatures (i.e., scoliosis, kyphosis, or lordosis), pseudarthrosis, and/or failed previous fusion. When used in conjunction with Medtronic HV-R™ Fenestrated Screw Bone Cement or Kyphon™ XPEDE™ Bone Cement, the CD HORIZON™ Fenestrated Screws are intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the thoracic and lumbar spine in whom life expectancy is of insufficient duration to permit achievement of fusion. CD HORIZON™ Fenestrated Screws augmented with either Medtronic HV-R™ Fenestrated Screw Bone Cement or Kyphon™ XPEDE™ Bone Cement are for use at spinal levels where the structural integrity of the spine is not severely compromised. KYPHON™ Xpede™ Bone Cement is indicated for the treatment of pathological fractures of the vertebral body due to osteoporosis, cancer, or benign lesions a cementoplasty (i.e. kyphoplasty or vertebroplasty) procedure. It is also indicated for the fixation of pathological fractures of the sacral vertebral body or ala using sacral vertebroplasty or sacroplasty. Cancer includes multiple myeloma and metastatic lesions, including those arising from breast or lung cancer, or lymphoma. Benign lesions include hemangioma and giant cell tumor. Pathological fracture may include a symptomatic microfracture (as documented by appropriate imaging and/or presence of a lytic lesion) without obvious loss of vertebral body height.
Device Story
System comprises cannulated multi-axial fenestrated screws and PMMA bone cement. Screws (4.5-10.5mm diameter) feature six distal fenestrations for controlled delivery of high-viscosity, radiopaque PMMA cement into vertebral bodies. Used in posterior spinal fixation; screws serve as traditional pedicle screws without cement or as augmented anchors with cement. Operated by surgeons in clinical/OR settings. Cement components (powder/liquid) mixed to initiate polymerization. Fluoroscopic imaging guides cement injection. Output is stabilized spinal segment. Benefits include restored spinal integrity in patients with advanced tumors or pathological fractures where fusion is contraindicated or life expectancy is limited.
Clinical Evidence
Bench testing only. Axial pull-out testing per ASTM F543-07 demonstrated equivalent strength between screws augmented with subject cement and predicate cement. Flow rate analysis via fluoroscopic imaging confirmed equivalent injection characteristics.
Indicated for patients with degenerative disc disease, spondylolisthesis, spinal tumors, trauma (fracture/dislocation), spinal stenosis, spinal curvatures, pseudarthrosis, or failed fusion. Also indicated for pathological vertebral/sacral fractures due to osteoporosis, cancer (multiple myeloma, metastatic breast/lung, lymphoma), or benign lesions (hemangioma, giant cell tumor). Augmented screw use indicated for advanced stage thoracic/lumbar tumors where fusion is not feasible.
Regulatory Classification
Identification
Polymethylmethacrylate (PMMA) bone cement is a device intended to be implanted that is made from methylmethacrylate, polymethylmethacrylate, esters of methacrylic acid, or copolymers containing polymethylmethacrylate and polystyrene. The device is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement.”
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
October 23, 2017
Medtronic Mr. Lee Grant Distinguished Regulatory Affairs Advisor 1800 Pvramid Place Memphis, Tennessee 38132
Re: K171938
Trade/Device Name: KYPHON™ Xpede™ Bone Cement, CD HORIZON™ Fenestrated Screw Set Regulation Number: 21 CFR 888,3027 Regulation Name: Polymethylmethacrylate (PMMA) bone cement Regulatory Class: Class II Product Code: PML, NDN, MNI Dated: September 14, 2017 Received: September 19, 2017
Dear Mr. Grant:
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 Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related 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.
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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 (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 (DICE) 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
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known) K171938
Device Name CD HORIZON™ Fenestrated Screw Set
### Indications for Use (Describe)
When used without cement, the CD HORIZON™ Fenestrated Screws (with or without SEXTANT™ or LONGITUDE™ instrumentation) are intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, tumor and/or trauma (i.e., fracture or dislocation), spinal stenosis, curvatures (i.e., scoliosis, kyphosis, or lordosis), pseudarthrosis, and/or failed previous fusion.
When used in conjunction with Medtronic HV-R™ Fenestrated Screw Bone Cement or Kyphon™ XPEDE™ Bone Cement, the CD HORIZON™ Fenestrated Screws are intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the thoracic and lumbar spine in whom life expectancy is of insufficient duration to permit achievement of fusion. CD HORIZON™ Fenestrated Screws augmented with either Medtronic HV-R™ Fenestrated Screw Bone Cement or Kyphon™ XPEDE™ Bone Cement are for use at spinal levels where the structural integrity of the spine is not severely compromised.
Type of Use (Select one or both, as applicable)
| <span style="font-family: Arial, sans-serif;"> <span style="font-size: 10pt;"> <span style="color: black;"> <span style="font-weight: bold;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </span> </span> |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <span style="font-family: Arial, sans-serif;"> <span style="font-size: 10pt;"> <span style="color: black;"> ☐ Over-The-Counter Use (21 CFR 801 Subpart C) </span> </span> </span> |
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# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known) K171938
Device Name KYPHONTM Xpede™ Bone Cement
### Indications for Use (Describe)
KYPHON™ Xpede™ Bone Cement is indicated for the treatment of pathological fractures of the vertebral body due to osteoporosis, cancer, or benign lesions a cementoplasty (i.e. kyphoplasty or vertebroplasty) procedure. It is also indicated for the fixation of pathological fractures of the sacral vertebral body or ala using sacral vertebroplasty or sacroplasty. Cancer includes multiple myeloma and metastatic lesions, including those arising from breast or lung cancer, or lymphoma. Benign lesions include hemangioma and giant cell tumor. Pathological fracture may include a symptomatic microfracture (as documented by appropriate imaging and/or presence of a lytic lesion) without obvious loss of vertebral body height.
When used in conjunction with CD HORIZON™ Fenestrated Screws, KYPHON™ Xpede™ bone cement is intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the thoracic and lumbar spine in whom life expectancy is of insufficient duration to permit achievement of fusion. CD HORIZON™ Fenestrated Screws augmented with KYPHON™ Xpede™ Bone Cement are for use at spinal levels where the structural integrity of the spine is not severely compromised.
Type of Use (Select one or both, as applicable)
| <div> <span> <svg height="16" width="16"> <rect height="16" style="fill:lightgrey;stroke-width:1;stroke:rgb(0,0,0)" width="16"></rect> <path d="M2,2 L14,14 M14,2 L2,14" stroke="black" stroke-width="2"></path> </svg> </span> Prescription Use (Part 21 CFR 801 Subpart D) </div> |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <div> <span> <svg height="16" width="16"> <rect height="16" style="fill:white;stroke-width:1;stroke:rgb(0,0,0)" width="16"></rect> </svg> </span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
## 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."
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#### 510(k) Summary - K171938 Medtronic Sofamor Danek CD HORIZON™ Fenestrated Screw Set October 20, 2017 Medtronic Sofamor Danek USA Submitter 1800 Pyramid Place Memphis, Tennessee 38132 Telephone: (901) 396-3133 Fax: (901) 346-9738 Lee Grant Contact(s) Distinguished Regulatory Affairs Advisor Direct Telephone - 901-344-0807 Date Prepared October 20, 2017 1) Kyphon® Xpede™ Bone Cement Trade Name 2) Medtronic HV-RTM Fenestrated Screw Cement (K152604) 3) CD HORIZON™ Fenestrated Screw Set 1) Kyphon® Xpede™ Bone Cement and Medtronic HV-R™ Fenestrated Regulatory Class Screw Cement Class II Regulation Number Regulation Name and Device 888.3027 Polymethylmethacrylate (PMMA) Bone Cement Product Classification Code PML, NDN 2) CD HORIZON™ Fenestrated Screw Set Class II 21 CFR 888.3070 Pedicle Screw System MNI Predicate Devices 1) K102397 - Kyphon® Xpede™ Bone Cement (Primary Predicate, SE 02/28/2011) Secondary Predicate 2) K152604 – Kyphon HV-RTM Fenestrated Screw Cement (Medtronic HV-RTM Fenestrated Screw Cement) and CD HORIZON™ Fenestrated Screw Set (SE 01/06/16) The predicate devices have not been subject to a design related recall Description of Device Kyphon Xpede™ Bone Cement is self-curing PMMA based (high viscosity, radiopaque) bone cement. Kyphon Xpede™ Bone Cement is provided sterile in two components: 20 grams of powder and nine grams of liquid. The powder contains methylmethacrylate-styrene co-polymer, barium sulfate as a radiopacifier, and di-benzoyl peroxide as an initiator. This liquid contains methylmethacrylate monomer, N, N dimethyl-p-toluidine as a promoter and hydroquinone as a stabilizer. The powder and liquid components are mixed, in the provided liquid-to-powder proportions, into a homogenous paste, to initiate the polymerization reaction of monomer into polymer. Medtronic HV-RTM Fenestrated Screw Cement is self-curing PMMA based (high viscosity, radiopaque) bone cement. Medtronic HV-RTM Fenestrated Screw Cement is provided sterile in two components: 20 grams of powder and nine grams of liquid. The powder contains methylmethacrylate-styrene co-polymer. barium sulfate as a radiopacifier, and di-benzoyl peroxide as an initiator. This liquid contains methylmethacrylate monomer, N, N dimethyl-p-toluidine as a promoter and hydroquinone as a stabilizer. The powder and liquid components are mixed, in the provided liquid-to-powder proportions, into a homogenous paste,
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| | to initiate the polymerization reaction of monomer into polymer. |
|---------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | The CD HORIZON™ Fenestrated Screw Set consists of a variety of cannulated |
| | multi-axial screws (MAS) with fenestrations offered in diameters ranging from |
| | 4.5mm to 10.5mm, with lengths ranging from 30-100mm based on CD |
| | HORIZON™ LEGACY™ and CD HORIZON™ SOLERA™ implants |
| | contained in the CD HORIZON™ Spinal System. The CD HORIZON™ |
| | Fenestrated Screws are specifically designed to connect to 4.75mm, 5.5mm, and |
| | 6.0mm diameter rods and associated connecting components contained within |
| | the CD HORIZON™ Spinal System. The screws contain six fenestrations near |
| | the distal tip of the screw which provides a controlled means to deliver a small |
| | amount of polymethylmethacrylate (PMMA) bone cement into a targeted |
| | vertebral body. These implants may also serve as traditional pedicle screws when |
| | used without bone cement. These screws are provided non-sterile. |
| Indications for Use: | When used without cement, the CD HORIZON™ Fenestrated Screws (with or |
| | without SEXTANT™ or LONGITUDE™ instrumentation) are intended for |
| | posterior, non-cervical fixation as an adjunct to fusion for the following |
| | indications: degenerative disc disease (defined as back pain of discogenic origin |
| | with degeneration of the disc confirmed by history and radiographic studies), |
| | spondylolisthesis, tumor and/or trauma (i.e., fracture or dislocation), spinal |
| | stenosis, curvatures (i.e., scoliosis, kyphosis, or lordosis), pseudarthrosis, and/or |
| | failed previous fusion. |
| | |
| | When used in conjunction with Medtronic HV-R™ Fenestrated Screw Bone |
| | Cement or Kyphon XPEDE™ Bone Cement, the CD HORIZON™ |
| | Fenestrated Screws are intended to restore the integrity of the spinal column |
| | even in the absence of fusion for a limited time period in patients with advanced |
| | stage tumors involving the thoracic and lumbar spine in whom life expectancy is |
| | of insufficient duration to permit achievement of fusion. CD HORIZON™ |
| | Fenestrated Screws augmented with Medtronic HV-R™ Fenestrated Screw |
| | Cement or Kyphon™ XPEDE™ Bone Cement are for use at spinal levels where |
| | the structural integrity of the spine is not severely compromised. |
| | |
| | Additionally, KYPHON™ Xpede™ Bone Cement is indicated for the treatment of |
| | pathological fractures of the vertebral body dueto osteoporosis, cancer, or benign |
| | lesions using a cementoplasty (i.e. kyphoplasty or vertebroplasty) procedure. It is |
| | also indicated for the fixation of pathological fractures of the sacral vertebral body |
| | or ala using sacral vertebroplasty or sacroplasty. Cancer includes multiple |
| | myeloma and metastatic lesions, including those arising from breast or lung |
| | cancer, or lymphoma. Benign lesions include hemangioma and giant cell tumor. |
| | Pathological fracture may include a symptomatic microfracture (as documented by |
| | appropriate imaging and/or presence of a lytic lesion) without obvious loss of |
| | vertebral body height. |
| Comparison of<br>Technological<br>Characteristics<br>with<br>the<br>Predicate Devices | 1) The Kyphon Xpede™ Bone Cement is identical in composition, method of<br>manufacture and sterilization to the primary predicate Kyphon Xpede™<br>Bone Cement cleared by the FDA in K102397 (SE 02/28/11). The<br>predicate cement is intended to be used in patients diagnosed with<br>pathological fractures in the vertebral body caused by conditions such as<br>osteoporosis and cancer. The subject cement is also intended to be used in<br>patients with metastatic cancer. Pathological fractures reflect one means in |
| | which spinal instability occurs and therefore in both instances the |
| | predicate and subject cement are intended to treat spinal instability. The<br>only differences between the subject and predicate cement are the method<br>in which the cement is delivered and that the subject cement is limited to<br>patients with advanced stage tumors involving the thoracic and lumbar<br>spine in whom life expectancy is of insufficient duration to permit<br>achievement of fusion.<br><br>2) No changes or additions have been made to the fenestrated screws which<br>comprise the CD HORIZONTM Fenestrated Screw Set cleared previously<br>in K152604 for the same indications when used in conjunction with<br>cement augmentation. They are identical in all aspects with respect to<br>indications, design, size, intended use, cannulation, fundamental scientific<br>technology, and materials. |
| Performance Data | <b>Biocompatibility</b> |
| | Identical to the primary predicate screws, the CD HORIZONTM Fenestrated<br>Screws are provided non-sterile form. They are manufactured from medical grade<br>titanium alloy (in accordance with ASTM F136), medical grade titanium (in<br>accordance with ASTM F67) and medical grade cobalt-chromium-molybdenum<br>alloy (in accordance with ASTM F1537). |
| | The subject XpedeTM Bone Cement is identical to the predicate XpedeTM Bone<br>Cement. The subject cement utilizes equivalent implant materials, sterilization<br>methods and bacterial endotoxin testing applying the same 20 EU/ml pyrogen<br>limit specifications utilizing the gel clot test method as the predicate Kyphon<br>XpedeTM Bone Cement (K102397). |
| | The materials used in the implants and instruments have a long clinical history of<br>safe and effective use in similar commercially available medical devices.<br>Therefore, no additional biocompatibility testing is required. |
| | <b>Mechanical Testing</b> |
| | In accordance with, Guidance for Industry and FDA Staff - Spinal System<br>510(k)'s", Medtronic has evaluated the subject devices to demonstrate substantial<br>equivalence to the predicate devices. Axial Pull Out Testing in accordance with<br>ASTM F543-07 was performed and compared CD HORIZONTM Fenestrated<br>Screws augmented with the subject Kyphon XepedeTM Bone Cement and the<br>Medtronic HV-RTM Fenestrated Screw Cement. Test results demonstrated the pull-<br>out strength of the screws were equivalent when using Kyphon XpedeTM Bone<br>Cement or Medtronic HV-RTM Fenestrated Screw Cement.<br>Additionally, a flow rate analysis was performed to compare Kyphon XpedeTM<br>Bone Cement to the Medtronic HV-RTM Fenestrated Screw Cement with respect to<br>injection and flow characteristics of the two cements. The cements were evaluated<br>using fluoroscopic imaging. Testing found the flow rates of the subject and<br>predicate cements to be substantially equivalent. |
| Conclusion | Based upon the test results and additional supporting documentation provided in<br>the pre-market notification, the subject Kyphon XpedeTM Bone Cement is |
| | substantially equivalent to the Kyphon® Xpede Bone Cement (K102397, SE<br>02/28/11) and to the Medtronic HV-RTM Fenestrated Screw Cement (K152604, SE<br>01/06/16). |
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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.