KLS Martin Individual Patient Solutions (IPS) Planning System
Applicant
KLS-Martin L.P.
Product Code
DZJ · Dental
Decision Date
Sep 13, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.4120
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a medical scamer such as a CT based system. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, splints, and case reports for use in maxillofacial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.
Device Story
System processes CT imaging data to support maxillofacial surgery planning; utilizes four COTS software applications for image segmentation and manipulation. Physician and trained engineer collaborate to create virtual surgical plans; system generates digital models and physical outputs via additive manufacturing (SLA, SLS, Selective Laser Melting) or traditional subtractive methods. Physical outputs include anatomical models, cutting/marking guides, and splints; guides may be temporarily fixated with screws (1.5-2.7mm). Output devices are provided non-sterile for steam sterilization by end-user. System aids surgeons in precise bone cutting/marking and surgical simulation; benefits include improved surgical accuracy and patient-specific treatment planning.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, including tensile/bending strength, biocompatibility (ISO 10993-1), steam sterilization validation (ISO 17665-1), and pyrogenicity (AAMI ANSI ST72).
Technological Characteristics
Software-based image segmentation and planning system. Materials: Polyamide, Titanium Alloy (Ti-6Al-4V), CP Titanium, epoxy/resin, acrylic. Manufacturing: Stereolithography (SLA), Selective Laser Sintering (SLS), Selective Laser Melting, and traditional subtractive methods. Connectivity: DICOM to .STL conversion. Sterilization: Steam (SAL 10^-6).
Indications for Use
Indicated for use in maxillofacial surgery as a pre-operative software tool for image segmentation, simulation, and evaluation of surgical treatment options, and for the creation of patient-specific anatomical models, surgical guides, splints, and case reports.
Regulatory Classification
Identification
A bone cutting instrument and accessories is a metal device intended for use in reconstructive oral surgery to drill or cut into the upper or lower jaw and may be used to prepare bone to insert a wire, pin, or screw. The device includes the manual bone drill and wire driver, powered bone drill, rotary bone cutting handpiece, and AC-powered bone saw.
KLS Martin Centre-Drive Drill-Free Screws (K971297)
Submission Summary (Full Text)
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KLS-Martin L.P. Gary Moore Quality Management and Regulatory Affairs Manager 11201 Saint Johns Industrial Pkwy S Jacksonville, Florida 32246
September 13, 2018
Re: K181241
Trade/Device Name: KLS Martin Individual Patient Solutions (IPS) Planning System Regulation Number: 21 CFR 872.4120 Regulation Name: Bone Cutting Instrument And Accessories Regulatory Class: Class II Product Code: DZJ, LLZ Dated: September 7, 2018 Received: September 10, 2018
Dear Gary Moore:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 comprehensive regulatory information about medical devices and radiation-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,
Mary S. Runner -S
forTina Kiang, Ph.D. Acting Director Division of Anesthesiology. General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known)
### K181241
Device Name
KLS Martin Individual Patient Solutions (IPS) Planning System
#### Indications for Use (Describe)
The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a medical scamer such as a CT based system. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, splints, and case reports for use in maxillofacial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D) | <input checked="" type="checkbox"/> |
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| Over-The-Counter Use (21 CFR 801 Subpart C) | <input type="checkbox"/> |
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## KUS ITT CIT CIT CIIN LIP T H201 Saint John Industrial Play S • Iocksoriile, FL322
Previous Clin Clin Carpe Phone: 904-04-1378 • Fax: 904-641-737
11201 Saint Johns Industrial Pkwy S • Jacksonville, FL 32246 www.klsmartinnorthamerica.com
### K181241 510(k) Summary 21 CFR 807.92
| Submitter: | KLS-Martin L.P.<br>11201 Saint Johns Industrial Pkwy S<br>Jacksonville, FL 32246 |
|----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Gary Moore<br>Quality Management and Regulatory Affairs Manager<br>Phone: 800-625-1557<br>Email: gmoore@klsmartin.com |
| Date Prepared: | September 13, 2018 |
| Trade Name: | KLS Martin Individual Patient Solutions (IPS) Planning<br>System |
| Common Name: | System for the creation of patient specific anatomical<br>models, cutting/marking guides, splints, and case reports |
| Classification Name: | Bone Cutting Instruments and Accessories (21 CFR<br>872.4120); System, Image Processing, Radiological (21 CFR<br>892.2050 |
| Regulatory Class: | II |
| Product Code: | DZJ, LLZ |
| Predicate Device: | VSP System (K120956) - Primary |
| Reference Devices: | KLS Martin Individual Patient Solutions (K163579)<br>KLS Mini Osteosynthesis System (K943347)<br>KLS Martin Centre-Drive Drill-Free Screws (K971297) |
| Device Description: | The KLS Martin Individual Patient Solutions (IPS) Planning<br>System is a collection of software and associated additive<br>manufacturing (rapid prototyping) equipment intended to<br>provide a variety of outputs to support reconstructive and<br>orthognathic surgeries. The system uses electronic medical<br>images of the patients' anatomy (CT data) with input from<br>the physician, to manipulate original patient images for<br>planning and executing surgery. The system processes the<br>medical images and produces a variety of patient specific<br>physical and/or digital output devices which include<br>anatomical models, guides, splints and case reports. |
| Indications for Use: | The KLS Martin Individual Patient Solutions (IPS) Planning<br>System is intended for use as a software system and image<br>segmentation system for the transfer of imaging information<br>from a medical scanner such as a CT based system. The<br>input data file is processed by the IPS Planning System and<br>the result is an output data file that may then be provided as |
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Image /page/4/Picture/0 description: The image shows the logo for KLS Martin L.P. The letters "KLS" are in red, while the word "martin" is in gray. The letters "L.P." are in black. The logo is simple and modern.
of the system that produces physical outputs including anatomical models, guides, splints, and case reports for use in maxillofacial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.
### Technological Characteristics/Substantial Equivalence Discussion:
The intended use of the subject device, KLS Martin Individual Patient Solutions (IPS) Planning System, is similar to the predicate device, VSP System (K120956):
The subject and primary predicate devices are intended for use as a software system and image segmentation system for the transfer of imaging information from a medical scanner such as a CT based system. The input data file is processed through the virtual planning software systems and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs. These physical outputs can be anatomical models, guides, splints, templates, and case reports. All digital data and physical devices are used to aid the surgeon during maxillofacial surgeries. They are both also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.
### Similarities to Predicate
Both the subject and primary predicate devices use image data obtained from medical scanners, such as a CT scan. They both use validated commercially off-the-shelf (COTS) software applications to transfer patient imaging from a DICOM format to a .STL format and manipulate the images to produce a final design file.
Both systems use additive manufacturing methods to produce physical output devices that include patient specific anatomical models, guides, and splints. In addition, the systems produce digital models and case reports for the physician to use for planning of maxillofacial surgeries or to use during surgery.
Materials used in the manufacture of the output devices are similar in that both the subject and predicate devices use biocompatible polymers/acrylic resins. All output devices from both systems are provided non-sterile and must be sterilized by the end user prior to use. Validated sterilization studies were performed to ensure a sterility assurance level (SAL) of 10-6.
Output devices in both systems are temporarily fixated with screws of varying sizes and lengths to aid the surgeon in cutting and marking bone more precisely and accurately. In addition, both devices require trained employees/engineers who utilize the software applications to manipulate data and work with the physician to create the virtual planning session. The physician provides input for model manipulation and interactive feedback through viewing of digital models of system outputs that are modified by the trained employee/engineer during the planning session.
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Image /page/5/Picture/0 description: The image shows the logo for KLS Martin L.P. The letters "KLS" are in red, while the word "martin" is in gray. The letters "L.P." are in black. The logo is simple and modern.
### Differences to Predicate
The indications for use statements differ slightly in that the predicate device stipulates physical outputs to include "anatomical models, templates, and surgical guides" whereas the subject device includes "anatomical models, guides, splints, and case reports." The predicate device includes splints and case reports in the narrative description, but splints and case reports were included in the indications for use of the subject device to describe all physical outputs.
The subject device utilizes four (4) commercially off-the-shelf (COTS) software applications for image segmentation and manipulation, whereas the predicate device utilizes thirteen (13) pieces of software that is a combination of COTS and custom.
Materials used in the manufacture of the subject output devices are synthetic polymers, acrylic resins, and titanium (CP titanium & Titanium Alloy). The predicate device manufactures output devices from acrylic and polymers only and uses surgical grade stainless steel cutting and drilling inserts for use in the cutting guides.
In addition, the subject device uses previously cleared fixation screws that are utilized for temporary guide fixation during cutting and marking of the bone. The screws range from 1.5 mm – 2.7 mm with lengths of 4 mm – 22 mm. The predicate device does not indicate screw diameter or length for temporary fixation of cutting guides.
### Reference Devices
The KLS Martin Individual Patient Solutions (K163579) has been included as a reference device to address differences in technological characteristics between the KLS Martin IPS Planning System and the predicate device with regard to material composition, biocompatibility, manufacturing process, performance testing, as well as cleaning and sterilization for titanium guides. The KLS Martin IPS Planning System titanium guides are manufactured from identical materials (CP Titanium Alloy), undergo the same manufacturing processes, have the same biocompatibility, demonstrate similar performance characteristics, and are cleaned and sterilized using the same validated methods as the titanium implants in the KLS Martin Individual Patients Solutions clearance (K163579).
The KLS Mini Osteosynthesis System (K943347) has been included as a reference device to address the differences in screw dimensions from the reference device KLS Martin Individual Patient Solutions (K163579). In reference device K163579, screw dimensions range from 2.0 mm - 3.2 mm with lengths of 5 mm - 22 mm. The KLS Mini Osteosynthesis System has been included to cover the 1.5 mm screw dimensions and a minimum length down to 4 mm that is identical to the subject device temporary fixation screws.
The KLS Martin Centre-Drive Drill-Free Screw (K971297) has been included as a reference device to address the difference in screw dimension and style from the reference device KLS Martin Individual Patient Solutions (K163579). In reference device K163579, screw dimensions ranged from 2.0 mm - 3.2 mm with lengths of 5 mm - 22 mm and a drill-free screw style. The KLS Martin Centre-Drive Drill-Free Screw has been included to cover the 1.5 mm screw dimensions with a drill-free screw style that is identical to the subject device temporary fixation screws.
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## kıs martın ı.p.
11201 Saint Johns Industrial Pkwy S • Jacksonville, FL 32246 Phone: 904-641-7746 • 800-625-1557 • Fax: 904-641-7378 www.klsmartinnorthamerica.com
| Device Comparison Table | | | | | |
|---------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | KLS Martin IPS Planning<br>System<br>(Subject Device) | Medical Modeling VSP®<br>System<br>K120956<br>(Primary Predicate) | KLS Martin Individual<br>Patient Solutions<br>K163579<br>(Reference Device) | KLS Mini Osteosynthesis<br>System<br>K943347<br>(Reference Device) | KLS Martin Centre-Drive<br>Drill-Free Screw<br>K971297<br>(Reference Device) |
| Indications for Use | The KLS Martin Individual<br>Patient Solutions (IPS)<br>Planning System is<br>intended for use as a<br>software system and image<br>segmentation system for the<br>transfer of imaging<br>information from a medical<br>scanner such as a CT based<br>system. The input data file<br>is processed by the IPS<br>Planning System and the<br>result is an output data file<br>that may then be provided<br>as digital models or used as<br>input to a rapid prototyping<br>portion of the system that<br>produces physical outputs<br>including anatomical<br>models, guides, splints, and<br>case reports for use in<br>maxillofacial surgery. The<br>IPS Planning System is also<br>intended as a pre-operative<br>software tool for<br>simulating/ evaluating<br>surgical treatment options. | The VSP® System is<br>intended for use as a<br>software system and image<br>segmentation system for<br>the transfer of imaging<br>information from a medical<br>scanner such as a CT based<br>system. The input data file<br>is processed by the VSP®<br>System and the result is an<br>output data file that may<br>then be provided as digital<br>models or used as input to a<br>rapid prototyping portion of<br>the system that produces<br>physical outputs including<br>anatomical models,<br>templates, and surgical<br>guides for use in<br>maxillofacial surgery. The<br>VSP® System is also<br>intended as a pre-operative<br>software tool for<br>simulating/evaluating<br>surgical treatment options. | KLS Martin Individual<br>Patient Solutions implant<br>devices are intended for use<br>in the stabilization and<br>fixation of mandibular<br>fractures and mandibular<br>reconstruction. | 1) Fractures<br>2) Osteotomies<br>3) Reconstruction<br>procedures | KLS Martin Centre-Drive<br>Drill-Free Screws are<br>intended for use in rigid<br>internal fixation of the oral-<br>maxillo-cranio-facial bones.<br>The bone screws are used to<br>anchor plates which are<br>contoured to fit the bony<br>surface and stabilize the<br>bone fragments. The addition<br>of the self drilling feature is<br>the only difference between<br>the submitted device and the<br>predicate device referenced. |
| Device Comparison Table | | | | | |
| | KLS Martin IPS Planning<br>System<br>(Subject Device) | Medical Modeling VSP®<br>System<br>K120956<br>(Primary Predicate) | KLS Martin Individual<br>Patient Solutions<br>K163579<br>(Reference Device) | KLS Mini Osteosynthesis<br>System<br>K943347<br>(Reference Device) | KLS Martin Centre-Drive<br>Drill-Free Screw<br>K971297<br>(Reference Device) |
| Contraindications | 1. Obvious infections.<br>2. Hypersensitivity to foreign bodies.<br>3. Circulatory problems, systemic diseases, and metabolic disorders.<br>4. Insufficient or inadequate bone tissue.<br>5. Secondary diseases such as degenerative processes that may negatively influence the healing process.<br>6. Interventions carried out in a non-sterile environment (e.g. paranasal sinuses).<br>7. Regions exposed to inappropriate forces or excessive weight loads.<br>8. Patients unwilling or unable to follow instructions during the postoperative phase due to their mental, neurological, or physical condition.<br>9. Bone tumors located | The models, templates and guides from the VSP System and the associated case report should not be used if any of the following occur:<br>1. Patient has an active infection.<br>2. Significant changes to patient's anatomy have occurred since the medical scan used for product definition was obtained. | 1. Obvious infections.<br>2. Hypersensitivity to foreign bodies.<br>3. Suspected sensitivity to the implant material.<br>4. Circulatory problems, systemic diseases and metabolic disorders.<br>5. Insufficient or inadequate bone tissue.<br>6. Secondary diseases such as degenerative processes that may negatively influence the healing process.<br>7. Interventions carried out in a non-sterile environment (e.g. paranasal sinuses).<br>8. Regions exposed to inappropriate forces or excessive weight loads.<br>9. Patients unwilling or unable to follow instructions during the postoperative phase due to their mental, neurological or physical condition.<br>10. Osteoporosis or | 1. Active infection.<br>2. Patient conditions including: blood supply limitations, insufficient quantity or quality of bone or latent infections.<br>3. Patients with mental or neurologic conditions who are unwilling or incapable of following postoperative care instructions.<br>4. Foreign body sensitivity. Where material sensitivity is suspected, tests are to be made prior to implantation. | 1. Active infection.<br>2. Patient conditions including: blood supply limitations, insufficient quantity or quality of bone or latent infections.<br>3. Patients with mental or neurologic conditions who are unwilling or incapable of following postoperative care instructions.<br>4. Foreign body sensitivity. Where material sensitivity is suspected, tests are to be made prior to implantation. |
| Device Comparison Table | | | | | |
| | KLS Martin IPS Planning<br>System<br>(Subject Device) | Medical Modeling VSP®<br>System<br>K120956<br>(Primary Predicate) | KLS Martin Individual<br>Patient Solutions<br>K163579<br>(Reference Device) | KLS Mini Osteosynthesis<br>System<br>K943347<br>(Reference Device) | KLS Martin Centre-Drive<br>Drill-Free Screw<br>K971297<br>(Reference Device) |
| | in the implant base<br>region.<br>10. Obvious drug or<br>alcohol abuse.<br>11. Significant changes to<br>the patient's anatomy<br>has occurred since the<br>medical scan used for<br>planning purposes<br>was obtained. | | osteomalacia or other<br>structural bone damage<br>preventing the stable<br>fixation of implant<br>components.<br>11. Bone tumors located in<br>the implant base region.<br>12. Obvious drug or alcohol<br>abuse. | | |
| Classification | 21 CFR 872.4120, Class II<br>21 CFR 892.2050, Class II | 21 CFR 872.4120, Class II<br>21 CFR 892.2050, Class II | 21 CFR 872.4760, Class II | 21 CFR 872.4760, Class II | 21 CFR 888.3040, Class II |
| Product Code | DZJ, LLZ | DZJ, LLC | JEY | JEY | HWC |
| Material | Anatomical Models:<br>Epoxy/Resin, Acrylic<br>Cutting/Marking Guides:<br>Polyamide, Titanium Alloy<br>(Ti-6Al-4V), CP Titanium<br>Splints: methacrylate | Acrylic and epoxy<br>photopolymers, surgical<br>instrument grade stainless<br>steel | Anatomical Models:<br>Epoxy/Resin, Acrylic<br>Implants: CP Titanium &<br>Titanium Alloy (Ti-6Al-4V) | Implants: CP Titanium &<br>Titanium Alloy (Ti-6Al-4V) | Screws: Titanium Alloy (Ti-<br>6Al-4V) |
| Manufacturing<br>Method | Epoxy/Resin, Acrylic:<br>Stereolithography (SLA)<br>CP Titanium: Traditional<br>(Subtractive)<br>Ti-6Al-4V: 3D (Additive;<br>Selective Laser Melting)<br>Polyamide: 3D (Additive;<br>Selective Laser Sintering) | 3D (Additive) | Epoxy/Resin, Acrylic:<br>Stereolithography (SLA)<br>CP Titanium: Traditional<br>(Subtractive)<br>Ti-6Al-4V: 3D (Additive;<br>Selective Laser Melting) | CP Titanium & Titanium<br>Alloy (Ti-6Al-4V):<br>Traditional (Subtractive) | Titanium Alloy (Ti-6Al-4V):<br>Traditional (Subtractive) |
| Device Comparison Table | | | | | |
| | KLS Martin IPS Planning<br>System<br>(Subject Device) | Medical Modeling VSP®<br>System<br>K120956<br>(Primary Predicate) | KLS Martin Individual<br>Patient Solutions<br>K163579<br>(Reference Device) | KLS Mini Osteosynthesis<br>System<br>K943347<br>(Reference Device) | KLS Martin Centre-Drive<br>Drill-Free Screw<br>K971297<br>(Reference Device) |
| Sterilization | Non-sterile (Steam) | Non-sterile (Steam) | Non-sterile (Steam) | Non-sterile (Steam) | Non-sterile (Steam) |
| Temporary/Permanent<br>Screw Diameter | Temporary: 1.5 mm - 2.7<br>mm | Temporary: Unknown | Permanent: 2.0 mm - 3.2 mm | Permanent: 1.5 mm - 2.0<br>mm | Permanent: 1.0 mm - 2.0<br>mm |
| Temporary/Permanent<br>Screw Length | Temporary: 4 mm - 22 mm | Temporary: Unknown | Permanent: 5 mm - 22 mm | Permanent: 4 mm - 19 mm | Permanent: 2 mm - 9 mm…
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.