K173694 · Tso3, Inc. · PJJ · Mar 13, 2018 · General Hospital
Device Facts
Record ID
K173694
Device Name
STERIZONE VP4 Sterilizer
Applicant
Tso3, Inc.
Product Code
PJJ · General Hospital
Decision Date
Mar 13, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.6860
Device Class
Class 2
Indications for Use
The STERIZONE® VP4 Sterilizer is intended for use in terminal sterilization of cleaned, rinsed, and nonmetal reusable medical devices in health care facilities.
Device Story
Low-temperature sterilizer using vaporized hydrogen peroxide and ozone; multi-phase process forms hydroxyl radicals for sterilization. Operates via single pre-set cycle; dynamic system adjusts sterilant distribution based on load size, weight, and temperature. Used in healthcare facilities; operated by facility staff. Input: cleaned/rinsed medical devices (up to 75 lb). Output: terminally sterilized instruments. Subject device introduces ambient air ventilation instead of pressurized oxygen. Healthcare providers use sterilized instruments for patient procedures; ensures device safety by eliminating microbial contamination.
Clinical Evidence
Bench testing only. Validation performed using nine representative loads covering various instrument geometries (clamps, hinges, lumens, endoscopes) and packaging types. Verification confirmed residual sterilant levels meet acceptance criteria and compliance with IEC 61010-1, IEC 61010-2-040, and IEC 61326-1 standards.
Technological Characteristics
Dual-sterilant (H2O2/O3) low-temperature sterilizer; 125L chamber volume. Uses Omron PLC for software control. Critical parameters: differential chamber pressure, load temperature, wall/vaporization temperatures, exposure times, flow rates, and ozone concentration. Ventilation via ambient air. Complies with IEC 61010-1, IEC 61010-2-040, IEC 61326-1, and FCC Part 18/EN 55011.
Indications for Use
Indicated for terminal sterilization of cleaned, rinsed, and dried metal and non-metal reusable medical devices in health care facilities, including general instruments, flexible endoscopes (single, double, and multi-channel), and rigid/semi-rigid channeled instruments.
Regulatory Classification
Identification
An ethylene gas sterilizer is a nonportable device intended for use by a health care provider that uses ethylene oxide (ETO) to sterilize medical products.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
March 13, 2018
TSO3, Inc. % Cynthia Pritchard CEO BioTechnology Transfer, LLC 1016 Tobiano Lane Raleigh, North Carolina 27614
Re: K173694
Trade/Device Name: STERIZONE VP4 Sterilizer Regulation Number: 21 CFR 880.6860 Regulation Name: Ethylene Oxide Gas Sterilizer Regulatory Class: Class II Product Code: PJJ Dated: February 2, 2018 Received: February 15, 2018
Dear Cynthia Pritchard:
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 (QS) regulation (21 CFR Part 820);
{1}------------------------------------------------
and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Michael J. Ryan -S
for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology. General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
## Indications for Use
510(k) Number (if known) K173694
Device Name
STERIZONE® VP4 Sterilizer
#### Indications for Use (Describe)
The STERIZONE® VP4 Sterilizer is intended for use in terminal sterilization of cleaned, rinsed, and nonmetal reusable medical devices in health care facilities.
The single pre-set cycle of the STERIZONE® VP4 Sterilizer uses hydrogen peroxide and ozone. The injection of vaporized hydrogen peroxide is followed by the injection of ozone, with residual hydrogen peroxide to form hydroxyl radicals.
Sterilization efficacy was demonstrated using a representative sample of one or more device types and packaging, in nine separate validation loads, as described in Table 1. The load to be processed should be maintained between 20℃ to 26℃ (68°F to 78°F). Total load weight shall not exceed 75 lb, inclusive of the containers/packaging weight but excluding the 25 1b loading rack.
Type of Use (*Select one or both, as applicable*)
| | Prescription Use (Part 21 CFR 801 Subpart D) |
|--|----------------------------------------------|
| | Over-The-Counter Use (21 CFR 801 Subpart C) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
| Validation<br>load # | Load description | Load<br>weight¹ |
|----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|
| 1 | Validation load #1 consisted of general medical instruments,<br>representing the following geometries:<br>• Clamp<br>• Serrated surface<br>• Box-lock<br>• Handle<br>• Button<br>• Pivot hinge<br>• Stopcock<br>Type of packaging used: wrapped plastic tray, including<br>silicone mats and brackets, and Pouch<br>General medical instruments were spread out over three trays,<br>six pouches and one wrapped instrument. | 11 lb |
| 2 | Validation load #2 consisted of general medical instruments,<br>representing the following geometries:<br>• Gliding mechanism<br>• Hinges and screws<br>• Serrated surface<br>• Luer-lock<br>• Spring<br>• Rigid non-lumen scopes<br>Type of packaging used: wrapped plastic and aluminum tray,<br>including silicone mats and brackets, rigid aluminum container<br>and Pouch<br>General medical instruments were spread out over one<br>container, three trays, and six pouches. | 20 lb |
| 3 | Validation load #3 consisted of three single channel flexible<br>endoscopes (Ureteroscope) with inside diameter of 1.0 mm<br>and length of 850 mm, packaged individually in wrapped<br>trays or containers, including appropriate silicone brackets<br>or mats. Eight general medical instruments, each packaged<br>in a pouch, were added. | 23 lb |
| Validation<br>load # | Load description | Load<br>weight1 |
| 4 | Validation load #4 consisted of up to 15 rigid or semi-rigid<br>channeled instruments in the presence of other packaged<br>medical devices. Three double channel semi-rigid<br>endoscopes (ureteroscope – 0.7 mm × 500 mm and 1.1 mm<br>× 500 mm) were packaged individually in wrapped trays orAdditional rigid channeled instruments or stainless steel<br>rigid lumens were added to each package. Two additional<br>general medical instruments, each packaged in a pouch,<br>were added. | 19 lb |
| 5 | Validation load #5 consisted in two single channel flexible<br>endoscopes; one Ureteroscope with inside diameter of 1.0<br>mm and length of 850 mm, and a Bronchoscope with inside<br>diameter of 1.8 mm and length of 830 mm, and one double<br>channel semi- rigid endoscope (ureteroscope - 0.7 mm ×<br>500 mm and 1.1 mm × 500 mm), packaged individually in<br>wrapped trays or containers including appropriate silicone<br>brackets or mats. | 21 lb |
| 6 | Validation load #6 consisted of general medical instruments,<br>representing the following geometries:<br>• Distal end (swivel parts)<br>• Hinge with screw<br>• Cannula<br>General medical instruments packaged in one aluminum<br>sterilization container. | 9 lb |
| 7 | Validation load #7 consisted of general medical instruments,<br>representing the following geometries:<br>• Box-lock hinge<br>• Pivot hinge<br>• Luer-lock<br>General medical instruments, spread out over three<br>aluminum sterilization containers, each weighting 25 lb. | 75 lb |
| 8 | Validation load #8 consisted of two double-channel flexible<br>endoscopes (Ureteroscope) with inside diameter of 1 mm<br>and lengths of 850 and 989 mm; and one single-channel<br>flexible endoscopes (Ureteroscope) with inside diameter of<br>1 mm and length of 850 mm, packaged individually in<br>wrapped plastic sterilization trays, including appropriate<br>silicone brackets or mats. | 16 lb |
| Validation<br>load # | Load description | Load<br>weight1 |
| 9 | Validation load #9 consisted of one multi-channel flexible<br>endoscope, with no more than 4 channels (Video<br>Colonoscope), with inside diameters of 1.2 or more and<br>lengths of 1955 mm or less, or 1.45 or more and lengths of<br>3500 mm or less; packaged in aluminium sterilization<br>container. | 17 lb |
#### Table 1. Description of the nine validation loads
{4}------------------------------------------------
{5}------------------------------------------------
1Excluding the 25-lb loading rack
{6}------------------------------------------------
Image /page/6/Picture/0 description: The image shows a logo with the letters 'TSO' in blue, followed by a chemical structure in gray. The 'T' is separate, while the 'S' and 'O' are connected. The chemical structure appears to be a simplified representation of a molecule, with circles connected by lines. The number '3' is written as a subscript to the 'O'.
## 510(k) Summary K173694
| General<br>Information: | Owner's Name:<br>Address: | TSO3 Inc.<br>TSO3 Inc.<br>2505, Avenue Dalton<br>Quebec, QC G1P 3S5, Canada |
|-------------------------|----------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| | Contact Person: | Alexandre Jokic<br>TSO3, Inc. Director Regulatory Affairs and<br>Quality Assurance |
| | Address: | TSO3 Inc.<br>2505, Avenue Dalton<br>Quebec, QC G1P 3S5, Canada |
| | Telephone:<br>Fax Number: | 418-651-0003 ext. 287<br>418-653-5726 |
| Subject Device: | Trade Name:<br>Common Name:<br>Product Code:<br>FDA Regulation:<br>Device Classification: | STERIZONE® VP4 Sterilizer<br>Dual sterilant sterilizer<br>PJJ<br>21 CFR 880.6860<br>Class II |
| Predicate Device: | Trade Name:<br>Common Name:<br>Product Code:<br>FDA Regulation:<br>Device Classification:<br>Premarket Notification: | STERIZONE® VP4 Sterilizer<br>Dual sterilant sterilizer<br>PJJ<br>21 CFR 880.6860<br>Class II<br>K153689 |
{7}------------------------------------------------
Image /page/7/Picture/0 description: The image shows a logo with the letters 'TSO' in blue, followed by a chemical structure in gray. The 'O' in 'TSO' is also part of the chemical structure. A small '3' is located at the bottom right of the logo, also in gray. The logo appears to represent a company or organization related to chemistry or science.
The STERIZONE® VP4 Sterilizer is intended for use in terminal sterilization of Indications for Use: cleaned, rinsed, and dried metal and non-metal reusable medical devices in health care facilities. The single pre-set cycle of the STERIZONE® VP4 Sterilizer uses hydrogen peroxide and ozone. The injection of vaporized hydrogen peroxide is followed by the injection of ozone, which reacts with residual hydrogen peroxide to form hydroxyl radicals.
> Sterilization efficacy was demonstrated using a representative sample of one or more device types and packaging, in nine separate validation loads, as described in Table 1. The load to be processed should be maintained between 20°C to 26°C (68°F to 78°F). Total load weight shall not exceed 75 lb, inclusive of the containers/packaging weight but excluding the 25-lb loading rack.
| Validation<br>load # | Load description | Load<br>weight |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|
| 1 | Validation load #1 consisted of general medical<br>instruments, representing the following geometries:<br>• Clamp<br>• Serrated surface<br>• Box-lock<br>• Handle<br>• Button<br>• Pivot hinge<br>• Stopcock<br>Type of packaging used: wrapped plastic tray, including<br>silicone mats and brackets, and Pouch. General medical<br>instruments were spread out over three trays, six<br>pouches and one wrapped instrument. | 11 lb |
| 2 | Validation load #2 consisted of general medical<br>instruments, representing the following geometries:<br>• Gliding mechanism<br>• Hinges and screws<br>• Serrated surface<br>• Luer-lock<br>• Spring<br>• Rigid non-lumen scopes<br>Type of packaging used: wrapped plastic and aluminum<br>tray, including silicone mats and brackets, rigid aluminum<br>container and Pouch. General medical instruments were<br>spread out over one container, three trays, and six<br>pouches. | 20 lb |
| 3 | Validation load #3 consisted of three single-channel<br>flexible endoscopes (Ureteroscope) with inside diameter<br>of 1.0 mm and length of 850 mm, packaged individually<br>in wrapped trays or containers, including appropriate<br>silicone brackets or mats. Eight general medical<br>instruments, each packaged in a pouch, were added. | 23 lb |
| 4 | Validation load #4 consisted of up to 15 rigid or semi-<br>rigid channeled instruments in the presence of other<br>packaged medical devices. Three double channel semi-<br>rigid endoscopes (ureteroscope – 0.7 mm × 500 mm and<br>1.1 mm × 500 mm) were packaged individually in<br>wrapped trays or containers including appropriate<br>silicone brackets or mats. Additional rigid channel<br>instruments or stainless steel rigid lumens were added to<br>each package. Two additional general medical<br>instruments, each packaged in a pouch, were added. | 19 lb |
| 5 | Validation load #5 consisted in two single channel flexible<br>endoscopes; one Ureteroscope with inside diameter of<br>1.0 mm and length of 850 mm, and a Bronchoscope with<br>inside diameter of 1.8 mm and length of 830 mm, and<br>one double channel semi- rigid endoscope (ureteroscope<br>– 0.7 mm × 500 mm and 1.1 mm × 500 mm), packaged<br>individually in wrapped trays or containers including<br>appropriate silicone brackets or mats. No additional item<br>was added. | 21 lb |
| 6 | Validation load #6 consisted of general medical<br>instruments, representing the following geometries:<br>• Distal end (swivel parts)<br>• Hinge with screw<br>• Cannula<br>General medical instruments packaged in one aluminum<br>sterilization container. | 9 lb |
| 7 | Validation load #7 consisted of general medical<br>instruments, representing the following geometries:<br>• Box-lock hinge<br>• Pivot hinge<br>• Luer-lock<br>General medical instruments, spread out over three<br>aluminum sterilization containers, each weighting 25 lb | 75 lb |
| 8 | Validation load #8 consisted of two double-channel<br>flexible endoscopes (Ureteroscope) with inside diameter<br>of 1 mm and lengths of 850 and 989 mm; and one single-<br>channel flexible endoscopes (Ureteroscope) with inside<br>diameter of 1 mm and length of 850 mm, packaged<br>individually in wrapped plastic sterilization trays,<br>including appropriate silicone brackets or mats. | 16 lb |
| 9 | Validation load #9 consisted of one multi-channel flexible<br>endoscope, with no more than 4 channels (Video<br>Colonoscope), with inside diameters of 1.2 mm or more<br>and lengths of 1955 mm or less, or inside diameters of<br>1.45 mm or more and lengths of 3500 mm or less;<br>packaged in aluminum sterilization container. | 17 lb |
Table 1: Description of the validation loads
{8}------------------------------------------------
Image /page/8/Picture/0 description: The image shows a logo for an organization or company. The logo consists of the letters "TSO" in blue, with the "O" stylized to resemble a chemical structure. To the right of the "O" is a small "3" in blue, likely indicating a chemical formula. Above the "SO" portion of the logo is a gray chemical structure, further emphasizing the scientific or chemical nature of the organization.
{9}------------------------------------------------
Image /page/9/Picture/0 description: The image shows a logo with the letters 'TS' in blue, followed by a stylized chemical structure in gray. The chemical structure appears to represent a molecule with three oxygen atoms, indicated by the subscript '3' next to the 'O'. The overall design is clean and modern, suggesting a company or organization related to science, technology, or chemistry.
4Excluding the 25-lb loading rack
Device The STERIZONE® VP4 Sterilizer is a versatile low temperature sterilizer Description: using two sterilants (vaporized hydrogen peroxide [H₂O₂] and ozone [O₃]) in a multi-phase process to sterilize reusable medical instruments up to a maximum load of 75 lb. In contrast to the sterilization processes using H2O2 only and having multiple cycles, the STERIZONE® VP4 Sterilizer enables the sterilization of a wider range of instruments and load configuration with only one preset cycle. The dynamic system to distribute the sterilant ensures an adequate supply of the sterilant through multiple successive pulsed injections that adapt to the different load conditions (size, weight and temperature). The STERIZONE® VP4 Sterilizer offers a unique preset sterilization cycle (Cycle 1) to sterilize a wide range of loads consisting of general instruments, flexible endoscopes with one channel, double channels and multi-channels, and devices with rigid and semi-rigid channels, including rigid endoscopes with single or double channels.
#### Technological Characteristics Comparison Table
| Device Trade<br>Name | Predicate STERIZONE VP4 Sterilizer<br>K153689 | STERIZONE VP4<br>Sterilizer<br>(with air vent<br>option) K173694 |
|------------------------------|---------------------------------------------------------------------------------|------------------------------------------------------------------|
| Device Class | Class II | Same |
| Product Code /<br>Regulation | PJJ | Same |
| Regulation Name | Dual sterilant sterilizer | Same |
| Indications for<br>Use | Terminal sterilization of reusable medical devices<br>in health care facilities | Same |
{10}------------------------------------------------
Image /page/10/Picture/0 description: The image shows a logo with the letters 'TSO' in blue, followed by a stylized molecular structure in gray. The '3' is in gray and smaller, positioned as a subscript to the 'O'. The logo appears to represent a company or organization related to science or technology, possibly in the fields of chemistry or engineering.
| | | Inner Diameter | Lumen Length | Inner Diameter | Lumen Length |
|-------------------------------------------|---------------------------------------------------------------------------------------------------------------------|-----------------------|------------------------|----------------------------------|--------------|
| | Single Channel Flexible Endoscope | ≥ 1mm | ≤ 850 mm | Same | Same |
| | Single & Double Channel Flexible Endoscope | ≥ 1 mm | ≤ 989 mm | Same | Same |
| | Multi-channel Flexible Endoscope (colonoscope – the FDA considers this a 4-channel device) | ≥ 1.2 mm<br>≥ 1.45 mm | ≤ 1955 mm<br>≤ 3500 mm | Same | Same |
| | Rigid Single & Double Channel Endoscope | ≥ 0.7 mm | ≤ 500 mm | Same | Same |
| Sterilant | Vaporized Hydrogen Peroxide/Ozone | | | Same | |
| H2O2<br>Concentration by<br>Weight | 50% | | | Same | |
| Number of<br>Sterilization<br>Cycles | 1 ("Cycle 1") | | | Same | |
| Critical Process<br>Parameters | Differential Chamber Pressure (ΔP) and Load Temperature | | | Same | |
| General Physical<br>Process<br>Parameters | Wall temperature, vaporization temperature, exposure times, flow rates, ozone concentration, component temperatures | | | Same | |
| Chamber Volume | 125L | | | Same | |
| Software Control | Omron PLC | | | Same | |
| Ventilation gas | ≥94% oxygen | | | Ambient air | |
| Component<br>changes | NA | | | Installation kit [filter: valve] | |
### Cycle Process Parameters Comparison Table
| Device Trade Name | | | Predicate<br>STERIZONE® VP4<br>Sterilizer<br>K153689 | STERIZONE®<br>VP4 Sterilizer<br>(Air vent<br>option) |
|-------------------|--------------------------|---------------------------------------------------------------------------|------------------------------------------------------|------------------------------------------------------|
| Phase | Cycle Steps | Controlled parameter | Value | Value |
| | Pre-conditioning | Pressure | 1 Torr | Same |
| Phase 1 | Dynamic H2O2<br>exposure | Differential pressure of<br>125-280 Solution<br>vaporized<br>and injected | 19 Torr | Same |
| | H2O2 reduction: | Ozone injection | 2 mg/L | Same |
| | | Ozone dwell | 5 min. | Same |
{11}------------------------------------------------
Image /page/11/Picture/0 description: The image shows a logo with the letters 'TS' in blue, followed by 'O3' in a lighter gray color. The 'S' and 'O' are stylized with rounded corners, giving them a modern look. Above the 'O3' is a graphic of three circles connected by lines, also in gray, resembling a molecular structure or a network. The overall design is clean and simple, suggesting a technology or science-related company.
| | Evacuation | Pressure | 1 Torr | Same | |
|---------|--------------------------|---------------------------------------------------------------------------|-------------------------------------------------|----------------------------------------------|------|
| Phase 2 | Dynamic H2O2<br>exposure | Differential pressure of<br>125-280 Solution<br>vaporized<br>and injected | 19 Torr | Same | |
| | | H2O2 reduction: | Ozone injection | 2 mg/L | Same |
| | | | Ozone dwell | 5 min. | Same |
| | Evacuation | Pressure | 1 Torr | Same | |
| | Ventilation | depressurization | Atmospheric<br>pressure using<br>pressurized O2 | Atmospheric<br>pressure using<br>ambient air | |
Labeling: There has been no change to the intended use. There have been no changes to warnings, contraindications, or precautions in comparison to the device cleared in K153689. The mode of operation remains the same. This new feature does not impact the device usability in any way. Statement on These changes do not in any way alter the fundamental scientific technology upon which the device is based. The operating principle has Fundamental Technology: not changed. The sterilizer incorporates the same basic design. The sterilization cycle is identical to that of the predicate. The software has not changed. The only changes made are mechanical component changes, to allow the use of ambient air, instead of pressurized oxygen, for final ventilation of the chamber. Biocompatibility The purpose of the biocompatibility testing was to provide evidence of the biological safety of materials commonly found in medical devices after being processed in the STERIZONE® VP4 Sterilizer. Materials were tested in accordance with ISO 10993-1:2009 (Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process) to determine which tests are necessary to
demonstrate biocompatibility of the patient-contacting materials present in the finished device.
- Cytotoxicity (in vitro)
- Sensitization reactivity
- Hemocompatibility
- Irritation (Ocular) ● Acute systemic toxicity
● Intracutaneous This design change did not in any way impact the biocompatibility of the materials of the sterilized devices, since the materials sterilized, and the sterilant residuals, have not changed.
{12}------------------------------------------------
Image /page/12/Picture/0 description: The image shows the logo for TSO3. The logo features the letters 'TSO' in blue, with the 'O' stylized to resemble a chemical structure. To the right of the 'O', there is a gray chemical structure. Below the 'O', there is a small subscript '3' in gray.
| Microbiological,<br>Functional and<br>Compatibility<br>Testing<br>Safety Testing | Verification test results demonstrated that residual sterilants present<br>on the selected materials were within the acceptance criteria already<br>cleared for the STERIZONE® VP4 sterilizer.<br><br>The STERIZONE® VP4 Sterilizer has been designed, constructed and<br>tested to meet the safety and performance requirements of applicable<br>North American safety codes and international standards. The<br>STERIZONE® VP4 Sterilizer complies with the applicable portions of the<br>following standards:<br>• IEC 61010-1 2004 Safety requirement for measurement, control<br>and laboratory use - Part 1: General<br>• IEC 61010-2-040 2005 Safety requirement for measurement,<br>control and laboratory use Part 2 particular requirements for<br>sterilizers and washer-disinfectors used to treat medical materials<br>• IEC 61326-1: 2012 Electrical equipment for measurement, control<br>and laboratory use - EMC requirements - Part 1: General<br>requirements<br>• Federal Communication Commission (FCC) Part 18 / EN 55011 |
|----------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Risk Management | There was one potential risk [sterilant residual levels] identified due to<br>the change of gas for final ventilation. However, verification testing<br>showed that residuals were within acceptance criteria for previously<br>cleared versions of the STERIZONE VP4. All potential hazards and failure<br>modes identified during the design and development processes were<br>addressed and did not impact the existing labeling. The risk<br>management activities included application FMEA, design FMEA and<br>manufacturing process FMEA. |
| Conclusion | The results of the verification/validation tests and the risk analyses have<br>demonstrated that the STERIZONE® VP4 Sterilizer (air vent option;<br>K173694) is substantially equivalent to the STERIZONE® VP4 Sterilizer<br>(K153689) |
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.