Pump In Style Advanced, Advanced Personal Double Breastpump
Applicant
Medela, LLC
Product Code
HGX · Obstetrics/Gynecology
Decision Date
Oct 16, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.5160
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Pump In Style® Advanced breast pump is a powered breast pump to be used by lactating women to express and collect milk from their breast. The powered breast pump is intended for a single user.
Device Story
Powered breast pump for single-user home or office use; expresses and collects milk from one or both breasts. Device uses gear-driven diaphragm-type vacuum pump powered by DC motor; controlled by microcontroller. User adjusts vacuum levels and cycle rates via rotary knob (potentiometer). Features 2-Phase Expression® Technology: Stimulation Phase (fast cycles, low vacuum) and Expression Phase (slower cycles, higher vacuum). Powered by AC adapter, AA batteries, or vehicle lighter adapter. Provides vacuum levels -50 to -240 mmHg; cycle rates up to 120 cycles/min. Healthcare provider/patient uses output (expressed milk) for infant feeding; device benefits patient by facilitating milk expression.
Clinical Evidence
Bench testing only. Performance data included biocompatibility (ISO 10993-1, -5, -10), electrical safety (AAMI/ANSI ES60601-1, IEC 60601-1-11), electromagnetic compatibility (IEC 60601-1-2), and software validation. Bench protocols confirmed vacuum levels (-50 to -240 mmHg), cycle rates (up to 120 cpm), overflow protection, and battery life across all power sources and pumping modes.
Technological Characteristics
Powered breast pump; gear-driven diaphragm vacuum pump; DC motor; microcontroller-based control. Materials: Polypropylene and thermoplastic elastomer polypropylene (breast shields). Power: Switching AC adapter (100-240V), AA batteries, or vehicle adapter. Connectivity: None. Sterilization: Provided non-sterile. Software: Embedded firmware.
Indications for Use
Indicated for lactating women to express and collect milk from their breast. Intended for single-user use.
Regulatory Classification
Identification
A powered breast pump in an electrically powered suction device used to express milk from the breast.
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October 16, 2018
Medela LLC PJ Pasia Manager, Regulatory Affairs 1101 Corporate Drive McHenry, IL 60050
Re: K181937
> Trade/Device Name: Pump In Style® Advanced Regulation Number: 21 CFR 884.5160 Regulation Name: Powered Breast Pump Regulatory Class: II Product Code: HGX Dated: July 17, 2018 Received: July 19, 2018
Dear PJ Pasia:
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.
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.
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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.html; 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 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, Sharon M. Andrews -
# S
for Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
K181937
Device Name Pump In Style® Advanced
Indications for Use (Describe)
The Pump In Style® Advanced breast pump is a powered breast pump to be used by lactating women to express and collect milk from their breast. The powered breast pump is intended for a single user.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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## 510(k) SUMMARY
In accordance with 21 CFR 807.92(a) the following summary of information is provided:
| Date Summary Prepared: | October 15, 2018 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter/Applicant | Medela LLC<br>1101 Corporate Drive<br>McHenry, IL 60050<br>Phone: 815-578-2270<br>Fax: 815-759-2548 |
| Primary Contact Person: | PJ Pasia<br>Medela LLC<br>Manager, Regulatory Affairs<br>Phone: 815- 578-2455<br>Cell: 815- 529-9613<br>Fax: 815-759-2563<br>Email pj.pasia@medela.com |
| Device Information | Trade/Device Name: Pump In Style® Advanced<br>Regulation Name: Powered Breast Pump<br>Regulation Number: 21 CFR§ 884.5160<br>Common Name: Powered Breast Pump<br>Device Classification Name: Pump, Breast, Powered<br>Product Code: HGX<br>Regulatory Class: II |
| Predicate Device Information | K031614<br>Manufacturer: Medela<br>Device Name: Pump In Style® Advanced<br>The predicate device has not been subject to a design-related |
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## Device Description:
The Pump In Style® Advanced breast pump and kit are used to express and collect milk from the breast of a lactating woman. The system is intended for daily use in a home (or similar environment such as an office) to supplement breastfeeding by a single user. Pumping with the Pump In Style® Advanced breast pump can be performed on one breast (single pumping) or on both breasts at the same time (double pumping).
The Pump In Style® Advanced breast pump employs a control knob (potentiometer) for the user to adjust the vacuum levels. Two suction rhythms are pre-programmed with variable vacuum levels and cycle rates (pump speed). The powered breast pump is capable of providing vacuum levels from -50 to -240 mmHg with cycle rates up to 120 cycles per minute.
The device employs a gear-driven diaphragm-type vacuum pump, powered by a DC motor supervised by a microcontroller. The microcontroller drives the "H" bridge providing speed and directional control over the DC motor. The device is electrically powered from external batteries (AA batteries) or from an external direct plug-in AC power supply or from a vehicle lighter adapter. The device is provided non-sterile.
The Pump In Style® Advanced breast pump provides the following user features:
- . Rotary knob for user adjustment of vacuum level/cycles and on/off
- 2-Phase Expression® Technology designed to mimic a baby's natural nursing rhythm: ●
- o Stimulation Phase (phase 1): Suction pattern with fast cycles and low vacuum to start milk flowing
- o Expression Phase (phase 2): Suction pattern with slower cycles and higher vacuum to express more milk gently and efficiently.
- . "Let-down" control to change between stimulation phase and expression phase.
- Option of either single or double breast pumping. .
#### Indications for Use:
The Pump In Style® Advanced breast pump is a powered breast pump to be used by lactating women to express and collect milk from their breast. The powered breast pump is intended for a single user.
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#### SUMMARY OF TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE COMPARED TO THE PREDICATE DEVICE
#### Determination of Substantial Equivalence:
The table below identifies key similarities and differences of the proposed Pump In Style® Advanced breast pump to the legally marketed predicate version of this device (K031614).
| | Pump In Style® Advanced<br>(Predicate Version)<br>K031614 | Pump In Style® Advanced<br>(Current Version) |
|----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------|
| General Device Characteristics | | |
| Indications for Use | Powered breast pump to be used by lactating women<br>to express and collect milk from their breasts. The<br>powered breast pump is intended for a single user. | Same |
| Environment of Use | Home | Same |
| Manufacturer | Medela LLC | Same |
| Regulation No. | 21 CFR 884.5160 | Same |
| Device Class | Class II | Same |
| Suction Modes | Stimulation and Expression | Same |
| Overflow protection | Membrane/Valve combination | Same |
| User Interface and Controls | | |
| User Control | On/Off rotary switch (potentiometer) to adjust vacuum levels "Let-Down" button (membrane switch), used to select between stimulation phase and expression phase. Integral tubing port for double or single pumping DC Input port for power connection | Same |
| Visual Indicator | No visual indicator | Same |
| Pumping options | Single and double pumping | Same |
| | Pump In Style® Advanced<br>(Predicate Version)<br>K031614 | Pump In Style® Advanced<br>(Current Version) |
| Adjustable Suction<br>Level | Yes | Same |
| User Skin Contact | Breast shield | Same |
| Cleaning Method | Tubing - wash or sanitize weekly, or if milk or condensation is present in the tubing Breast pump kit and bottles - wash and sanitize Breast pump carrying case/bag - wipe with clean, damp cloth | Same |
| Specifications | | |
| Power Source -<br>AC Adapter | Type: Linear Power Supply<br>Input Rating: 110- 120V, 60Hz, 18W<br>Output Rating: 9Vdc, 1.0A<br>Class 2 (double insulated) | Type: Switching Power Supply<br>Input Rating:<br>100-240V, 50-60Hz, 0.7A<br>Output Rating:<br>9Vdc, 2A<br>Class 2 (double Insulated) |
| Software | Embedded | Same |
| Power Source-External<br>Battery | Type: AA batteries<br>Qty: 8 pcs. | Same |
| Power Source- vehicle<br>lighter adapter | Type: Switching vehicle power adapter<br>Input Rating: 12-24Vdc<br>Output Rating: 9Vdc, 1.0A | Same |
| Vacuum aggregate type | Diaphragm-type | Same |
| Cycling Control<br>Mechanism | Microcontroller | Same |
| Max Vacuum (mmHg)-<br>Expression- double and<br>single pumping | Approx. -295 mmHg | Same |
| Vacuum range - double<br>mmHg/kPa | -50 to -240mmHg | Same |
| Vacuum range - single<br>mmHg/kPa | -50 to -240mmHg | Same |
| Cycle Speed | 120 Cycles | Same |
| Breast Shields | Round only (Polypropylene) | Oval and round (Polypropylene and<br>thermoplastic elastomer polypropylene) |
Table 5.1 Comparison of Pump In Style® Advanced to Predicate Device
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The subject and predicate devices have identical indications for use and the same intended use expressing milk from the breasts of lactating women. Although the current version of the Pump In Style® Advanced has the same fundamental technology and principles of operation as the previously cleared version, several modifications have been made to the subject device. The subject and predicate devices do not have identical technological characteristics because the current version utilizes a switching AC power supply (Input: 100-240, 50/60Hz, 0.7A; Output: 9VDC, 2A) rather than a linear power supply of the predicate device (Input:110-120 VAC, 60Hz18W; Output: 9Vdc, 1.0A). In addition, the subject device includes oval shaped breast shields which are manufactured with a different material compared to the round breast shields of the
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predicate device. These differences between the subject and predicate devices do not raise different questions of safety or effectiveness.
#### SUMMARY OF NON-CLINICAL TESTS:
The Pump In Style® Advanced breast pump complies with voluntary standards for electrical safety, electromagnetic compatibility, use in the home healthcare environment and usability. The following performance data were provided in support of the substantial equivalence determination:
- Biocompatibility evaluation in accordance with ISO 10993-1:2009 Biological evaluation ● of medical devices -- Part 1: Evaluation and testing within a risk management process.
- Cytotoxicity testing per ISO 10993-5:2009 O
- Guinea Pig Maximization Sensitization testing perISO 10993-10:2010 O
- Irritation testing per ISO 10993-10:2010 O
- Electrical Safety testing in accordance with:
- AAMI / ANSI ES60601-1:2005/A1:2012, Medical Electrical Equipment: Part O 1: General Requirements.
- Electrical safety testing for use in home in accordance with IEC 60601-1 o 11:2015. General requirements for basic safety and essential performance --Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment.
- Risk analysis in accordance with ISO 14971:2007 ●
- . Electromagnetic compatibility testing in accordance with IEC 60601-1-2:2014 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests.
- Software Validation: The software/firmware verification and validation was provided in ● accordance with the FDA Guidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices," dated May 11, 2005.
- . Bench performance testing was conducted with internal test protocols to determine the minimum and maximum vacuum levels of the pump, as well as cycle rate and overflow protection, as compared to its specifications. The specifications were met for vacuum levels, cycle rate and overflow protection. Battery use life testing was also conducted to demonstrate the subject device maintains its specifications throughout its use life. These results held under conditions of single and double pumping modes with varying power sources (e.g. AC/DC power, vehicle lighter adapter, external battery pack).
## Conclusion:
The subject and predicate devices have the same intended use and the technological differences do not raise different questions of safety or effectiveness. The performance data demonstrate the subject device is substantially equivalent to the predicate device.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.