The VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of Resistance Syringe is intended for use in conjunction with an epidural needle tip placement in the epidural space by the loss of Resistance technique, it will be filled with air and/or saline during use. The loss of Resistance Syringe is not intended for injection or aspiration. The Syringe will be sold sterile individually packaged, and as part of a sterile kit.
Device Story
Manual syringe used during epidural anesthesia procedures; filled with air or saline to identify loss of resistance when needle enters epidural space. Device consists of barrel and plunger; features NRFit (ISO 80369-6) or Luer (ISO 80369-7) connectors. Used by clinicians in clinical settings. Provides tactile/visual feedback to confirm needle placement; does not perform injections or aspirations. Benefits patient by facilitating accurate epidural needle positioning.
Clinical Evidence
Bench testing only. No clinical data. Performance validated via mechanical testing (leakage, stress cracking, axial load, torque, overriding) and shelf-life studies (real-time and accelerated aging up to 5 years) per ISO 80369-6/7 and internal protocols.
Technological Characteristics
Plastic syringe with barrel and plunger. Connectors: NRFit (ISO 80369-6) and Luer (ISO 80369-7). Sterilization: Ethylene Oxide (ISO 11135). Shelf life: 5 years. Biocompatibility: ISO 10993-1 compliant. Mechanical testing per ISO 80369 series.
Indications for Use
Indicated for use in conjunction with an epidural needle to verify needle tip placement in the epidural space via loss of resistance technique. Not for injection or aspiration.
Regulatory Classification
Identification
An anesthesia conduction kit is a device used to administer to a patient conduction, regional, or local anesthesia. The device may contain syringes, needles, and drugs.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services USA seal. To the right of the seal is the FDA logo in blue, with the words "U.S. FOOD & DRUG" stacked on top of the word "ADMINISTRATION".
Pajunk GmbH Medizintechnologie Christian Quass Director Regulatory Affairs Karl-Hall-Str. 1 Geisingen, 78187 De
Re: K190345
Trade/Device Name: VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Regulation Number: 21 CFR 868.5140 Regulation Name: Anesthesia Conduction Kit Regulatory Class: Class II Product Code: CAZ Dated: April 16, 2019 Received: April 19, 2019
Dear Christian Quass:
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
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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 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,
for Michael Ryan Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K190345
Device Name
VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7)
Indications for Use (Describe)
Indication for Use: The VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of Resistance Syringe is intended for use in conjunction with an epidural needle tip placement in the epidural space by the loss of Resistance technique, it will be filled with air and/or saline during use. The loss of Resistance Syringe is not intended for injection or aspiration.
The Syringe will be sold sterile individually packaged, and as part of a sterile kit.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------|------------------------------------------------------------------------------|
| <div> <span> </span> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div> <span> </span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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Image /page/3/Picture/2 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and sans-serif. There is a small circle with an "R" inside of it to the right of the "K", indicating that the word is a registered trademark.
# 510(k) Summary as required by 21 CFR 807.92(c).
Date of Preparation: 2019-05-16
# Document Control Number: K190345
## 510(k) owner:
PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1 78187 Geisingen, Baden-Wuerttemberg, Germany
Establishment Registration Number: 9611612
# Submitter Information/ production site:
- PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1 78187 Geisingen Baden-Wuerttemberg, Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612
# Contact:
Christian G. H. Quass Director Regulatory Affairs, Safety Officer Patricia Weisbrod Regulatory Affairs Manager Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 E-Mail: christian.quass@pajunk.com E-Mail: patricia.weisbrod@pajunk.com
# USA Contact:
PAJUNK MEDICAL SYSTEMS 6611 Bay Circle, Suite 140 Norcross, GA 30071 Phone +1 (888) 9PAJUNK (72-5865) Fax +1 (678) 514-3388
Establishment Registration Number: 3004076349
# Contact
Marco Wohnig President PAJUNK® Medical Systems L.P. Phone: (770) 493-6832 Direct: (470) 448-4070 Cell: (770) 757-2449 Fax: (678) 514-3388 E-Mail: marco.wohnig@pajunk-usa.com
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# Premarket Notification Submission 510(k)
Image /page/4/Picture/1 description: The image features the word "PAJUNK" in bold, white letters against a teal background. The font is sans-serif and appears to be slightly blurred, giving it a soft, diffused look. A small registration mark is visible to the upper right of the letter "K".
Pioneering medical technology
| Device Information: | |
|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name: | VPC (Visual Pressure Control) NRFit™<br>(ISO80369-6) and LUER (ISO80369-7) |
| Sterilization method: | Ethylene Oxide<br>Disposable device, supplied sterile to the end<br>user and non-sterile intended to be sterilized<br>prior to use to repackagers/ medical device<br>manufacturers |
| Contract Sterilizer: | Sterigenics Germany GmbH<br>Kasteler straße 45<br>65203 Wiesbaden<br>Germany, Hessen<br>Establishment Registration Number:<br>3002807090 |
| Document Control Number | K190345 |
| Classification Name: | conduction, anesthetic |
| Classification Reference: | 21 CFR 868.5140 |
| Product Code: | CAZ |
| Establishment Registration Number: | 9611612 |
| Regulatory Class: | II |
| Panel: | Anesthesiology |
| Predicate Device | K061737, Busse Loss of Resistance Syringe |
PAJUNK® GmbH Medizintechnologie is submitting this 510(k) for the VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) for identification of loss of resistance prior to epidural anaesthesia procedures with either NRFit™ Connector according to ISO80369-6 or LUER-Connector according to ISO80369-7.
The VPC is considered a Class II medical device according to the predicate device as defined in 21 CFR §868.5140, product code CAZ.
The device is a sterile finished disposable device, supplied sterile to the end user and non-sterile intended to be sterilized prior to use to re-packagers/ medical device manufacturers.
The predicate devices chosen for demonstrating substantial equivalence is the Busse Loss of Resistance Syringe manufactured by ROBERT BUSSE & CO., INC. P.O. BOX 11067 Hauppauge, NY 11788 and cleared by the Food and Drug Administration for market under K061737, product code CAZ, review panel Anaesthesiology.
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Image /page/5/Picture/1 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and slightly blurred, giving them a soft appearance. A small registered trademark symbol is visible to the upper right of the letter "K".
#### Indications for use
Indication for Use: The VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of Resistance Syringe is intended for use in conjunction with an epidural needle, to verify the needle tip placement in the epidural space by the loss of Resistance technique, it will be filled with air and/or saline during use.
The loss of Resistance Syringe is not intended for injection or aspiration.
The Syringe will be sold sterile individually packaged, and as part of a sterile kit.
## Determination methods and results of Substantial Equivalence Determination:
| Intended Use | Result: Substantially Equivalent |
|--------------|----------------------------------|
| Design | Result: Substantially Equivalent |
| Performance | Result: Substantially Equivalent |
# Equivalence in materials used
| Characteristics | Predicate device<br>Busse LOR Syringe<br>K061737 | Subject Device<br>VPC (Visual Pressure Control)<br>NRFit™ (ISO80369-6) and LUER<br>(ISO80369-7) Loss of Resistance<br>Syringe | Result of<br>comparison, if<br>necessary with<br>rationale |
|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Biocompatibility | Both devices are classified as externally communicating. Therefore, ISO10993-1<br>biocompatibility applies. | | Substantially equivalent |
| Packaging | Individually sterile in soft blister pouch<br>or as part of a kit | Individually sterile in soft blister pouch or<br>as part of a kit | Same packaging<br>The PAJUNK® individual<br>packaging was selected<br>according to a validated<br>sterilization and<br>transportation process |
| Indications for<br>Use | Indication for Use: The Busse Loss of<br>Resistance Syringe is intended for<br>use in conjunction with an epidural<br>needle, to verify the needle tip<br>placement in the epidural space by<br>the loss of Resistance technique, it<br>will be filled with air and/or saline<br>during use. The loss of Resistance<br>Syringe is not intended for injection or<br>aspiration. The Syringe will be sold<br>sterile individually packaged, and as<br>part of a sterile kit. | Indication for Use: The VPC (Visual<br>Pressure Control) NRFit™ (ISO80369-<br>6) and LUER (ISO80369-7) Loss of<br>Resistance Syringe is intended for use<br>in conjunction with an epidural needle,<br>to verify the needle tip placement in the<br>epidural space by the loss of Resistance<br>technique, it will be filled with air and/or<br>saline during use.<br>The loss of Resistance Syringe is not<br>intended for injection or aspiration.<br>The Syringe will be sold sterile<br>individually packaged, and as part of a<br>sterile kit. | identical |
| Overall design: | Barrel, Plunger | Barrel, Plunger | identical<br>Both devices do not<br>have direct patient<br>contact and are made<br>from plastic materials |
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# Premarket Notification Submission 510(k)
Image /page/6/Picture/1 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and slightly blurred, giving them a soft appearance. A small circled "R" trademark symbol is located to the right of the "K".
# K190345
Pioneering medical technology
| | Predicate device | Subject Device | Result of |
|-----------------|------------------------------|-------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Characteristics | Busse LOR Syringe<br>K061737 | VPC (Visual Pressure Control)<br>NRFit™ (ISO80369-6) and LUER<br>(ISO80369-7) Loss of Resistance<br>Syringe | comparison, if<br>necessary with<br>rationale |
| Picture | | | Both systems allow<br>easy handling and<br>connecting and have a<br>smooth plunger for<br>LOR-technique |
| Materials used | Plastic materials | Plastic materials | identical<br>Each of the materials<br>used either in the<br>Predicate Devices or<br>the Subject Device are<br>established materials<br>used for manufacturing<br>medical devices. |
| Connectivity | ISO 80369-7 | ISO 80369-6 NRFit™<br>ISO 80369-7 LUER | Both systems do have<br>identical connectivity<br>towards syringe and<br>needle; 2017´s state of<br>the art connection type<br>is NRFit™ which<br>slightly differs in<br>dimensions of the male<br>and female connectors<br>in order to avoid<br>misconnections. |
| Markings Area | 0ml — 10ml | 0ml — 10ml | identical |
| Priming Volume | 10ml | 10ml | identical |
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Image /page/7/Picture/1 description: The image features the word "PAJUNK" in bold, white letters against a teal background. The font is sans-serif and appears slightly blurred, giving it a soft, diffused look. A small, superscripted "R" in a circle, indicating a registered trademark, is positioned to the upper right of the letter "K".
#### Equivalence in the Indications for use
#### Subject Device:
Indication for Use: The VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of Resistance Syringe is intended for use in conjunction with an epidural needle, to verify the needle tip placement in the epidural space by the loss of Resistance technique. it will be filled with air and/or saline during use.
The loss of Resistance Syringe is not intended for injection or aspiration. The Syringe will be sold sterile individually packaged, and as part of a sterile kit.
#### Predicate Devices:
Indication for Use: The Busse Loss of Resistance Syringe is intended for use in conjunction with an epidural needle, to verify the needle tip placement in the epidural space by the loss of Resistance technique, it will be filled with air and/or saline during use.
The loss of Resistance Syringe is not intended for injection or aspiration. The Syringe will be sold sterile individually packaged, and as part of a sterile kit.
## Discussion
The indications for use as well as the intended use of the predicate devices and of the subject device are identical.
Conclusion: Substantially Equivalent
#### Sterilization
#### Subject Device:
Sterilized with Ethylene Oxide. Shelf Life: 5 years.
#### Predicate Devices:
Sterilized with Ethylene Oxide. Shelf Life: 5 years.
## Discussion
Both devices are sterilized using Ethylene Oxide and have a shelf life of 5 years.
Conclusion: Substantially Equivalent
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Image /page/8/Picture/1 description: The image features the word "PAJUNK" in a bold, sans-serif font. The letters are white, and they stand out against a teal background. The registered trademark symbol is visible to the right of the letter "K".
# Performance Testing
## Subject Device:
Connectivity: LUER and NRFit™ (ISO 80369-6 and ISO 80369-7). Stability of markings: Complies with internal protocol Stability of connectivity during Shelf Life: LUER and NRFit™ (ISO 80369-6 and ISO 80369-7). Identification of LOR: Complies with internal protocol Identification of LOR during Shelf Life: Complies with internal protocol
## Predicate Devices:
Stability of markings: Complies with internal protocol Identification of LOR: Complies with internal protocol
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Image /page/9/Picture/1 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are slightly blurred, giving them a soft appearance. A small circle with an R inside is located to the right of the K.
#### Technology Characteristics/ Performance Testing
The contract sterilizer and the sterilizing process are identical to the process and sterilizer used for all PAJUNK® - manufactured devices which are already cleared for market or exempt.
Sterilization parameters are
| SAL | 10-6 |
|-----------------|----------------------------------------------------------------------------------|
| Type of gas | Ethylene Oxide 99,99% |
| Exposure time | 300 min. |
| Aeration method | evacuation<br>2 airwashes |
| Aeration period | residual EtO-gas is removed in circulating<br>air at 40° C (±5) for at least 48h |
Sterilization has been validated according to ISO 11135-1 Overkill Approach (1 sublethal cycle, 2 half cycle, 1 full cycle)
Residuals of EO and ECH are in compliance with ISO 10993-7.
Cleaning and Sterilization method, which ensures SAL of 10° as well as compliance with limits for chemical burden, bioburden, pyroburden (i.e. LAL) and EtO-residuals as well as shelf life have been validated and are safe and effective.
The limits listed below are met by each device:
Limits for Residuals of Ethylene oxide and Ethylene chlorohydrin are met.
Limit for Pyrogen/ endotoxin is met.
The VPC is also available in bulk non-sterile. If appropriately packed and sterilized with Ethylene oxide according to the parameters above the technological parameters remain unchanged. However, final responsibility for sterilization remains with the customer of VPC purchased bulk non-sterile.
#### Shelf Life
Efficacv of sterile product's lifecycle has been validated.
Sterility tests have been performed. Performance of the essential performance of the device (NRFit and LUER connection, stability of connections) has been tested with real time aged devices (1 year) and devices subject to accelerated aging (1 year, 3 years, 5 years). There is no decrease in performance after 5 years.
Shelf-life is set to 5 years.
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Image /page/10/Picture/0 description: The image features the word "PAJUNK" in bold, white letters against a teal background. The font is sans-serif, and the letters are closely spaced, creating a solid block of text. A small circle with an "R" inside, indicating a registered trademark, is positioned to the upper right of the letter "K".
#### Biocompatibility:
All products comply with ISO 10993-1, 2nd and 3rd edition.
The Subject Device is an external communicating device with no direct patient contact. Therefore, based upon ISO10993-1 biocompatibility is evaluated.
Therefore, and based upon sterilization and residuals validation the devices are considered to be biocompatible.
#### Standards/ Requirements
The Subject Device has been tested to comply with the state-of-the-art standards listed below. For connector standards both, the male and female connectors have been tested:
| Test Detail | Standard | FDA-Rec.-No. | Result |
|----------------------------------------|-------------------|--------------|--------|
| Sterilization | ISO 11135 | 14-452 | Pass |
| Residuals | ISO 10993-7 | 14-408 | Pass |
| Biocompatibility | ISO 10993-1 | 2-220 | Pass |
| Liquid Leakage | ISO 80369-7, 6.1 | 5-115 | Pass |
| Air Leakage | ISO 80369-7, 6.2 | 5-115 | Pass |
| Stress Cracking | ISO 80369-7, 6.3 | 5-115 | Pass |
| Axial Load | ISO 80369-7, 6.4 | 5-115 | Pass |
| Unscrewing torque | ISO 80369-7, 6.5 | 5-115 | Pass |
| Overriding | ISO 80369-7, 6.6 | 5-115 | Pass |
| Liquid Leakage | ISO 80369-6, 6.1 | 5-108 | Pass |
| Air Leakage | ISO 80369-6, 6.2 | 5-108 | Pass |
| Stress Cracking | ISO 80369-6, 6.3 | 5-108 | Pass |
| Axial Load | ISO 80369-6, 6.4 | 5-108 | Pass |
| Unscrewing torque | ISO 80369-6, 6.5 | 5-108 | Pass |
| Overriding | ISO 80369-6, 6.6 | 5-108 | Pass |
| Stability of markings | Internal protocol | n.a. | Pass |
| Identification of LOR | Internal Protocol | n.a. | Pass |
| ISTA Procedure 2A (ASTM D 6653 et al.) | | | |
| ASTM F1886 - 09 | | | |
| ASTM F 1929 – 98 | | | |
| ASTM E 515 – 05 (4a)) | | | |
| DIN EN 868-5:2009-09 | | | |
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Image /page/11/Picture/0 description: The image shows the word "PAJUNK" in white font on a teal background. The word is in all caps and has a registered trademark symbol after it. The font is sans-serif and appears to be bolded.
# Premarket Notification Submission 510(k)
Pioneering medical technology
| Test Detail | Standard | FDA-Rec.-No. | Result |
|-----------------------|----------|--------------|--------|
| DIN EN 868-10:2009-09 | | | |
# Conclusion:
The comparison between the predicate devices and the subject device of this submission as well as the validated sterilization process and the results of the standard testing and performance testing demonstrates that the subject device is substantially equivalent to the predicate device without raising different questions of safety and effectiveness.
{12}------------------------------------------------
PAJUNK®
| Device: VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of<br>Resistance Syringe | | | |
|---------------------------------------------------------------------------------------------------------------|-------------------|---------------------------|--------|
| Test Detail | Standard | Level | Result |
| Liquid Leakage | ISO 80369-7, 6.1 | 3 years accelerated aging | Pass |
| Air Leakage | ISO 80369-7, 6.2 | 3 years accelerated aging | Pass |
| Stress Cracking | ISO 80369-7, 6.3 | 3 years accelerated aging | Pass |
| Axial Load | ISO 80369-7, 6.4 | 3 years accelerated aging | Pass |
| Unscrewing torque | ISO 80369-7, 6.5 | 3 years accelerated aging | Pass |
| Overriding | ISO 80369-7, 6.6 | 3 years accelerated aging | Pass |
| LOR | Internal protocol | 3 years accelerated aging | Pass |
| Tightness | Internal Protocol | 3 years accelerated aging | Pass |
| Stability Markings | Internal Protocol | 3 years accelerated aging | Pass |
| Device: VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of<br>Resistance Syringe | | | |
|---------------------------------------------------------------------------------------------------------------|-------------------|---------------------------|--------|
| Test Detail | Standard | Level | Result |
| Liquid Leakage | ISO 80369-7, 6.1 | 5 years accelerated aging | Pass |
| Air Leakage | ISO 80369-7, 6.2 | 5 years accelerated aging | Pass |
| Stress Cracking | ISO 80369-7, 6.3 | 5 years accelerated aging | Pass |
| Axial Load | ISO 80369-7, 6.4 | 5 years accelerated aging | Pass |
| Unscrewing torque | ISO 80369-7, 6.5 | 5 years accelerated aging | Pass |
| Overriding | ISO 80369-7, 6.6 | 5 years accelerated aging | Pass |
| LOR | Internal protocol | 5 years accelerated aging | Pass |
| Tightness | Internal Protocol | 5 years accelerated aging | Pass |
| Stability Markings | Internal Protocol | 5 years accelerated aging | Pass |
{13}------------------------------------------------
PAJUNK®
| Device: VPC (Visual Pressure Control) NRFit™ (ISO80369-6) and LUER (ISO80369-7) Loss of<br>Resistance Syringe | | | |
|---------------------------------------------------------------------------------------------------------------|-------------------|------------------------|--------|
| Test Detail | Standard | Level | Result |
| Liquid Leakage | ISO 80369-7, 6.1 | 1 year real time aging | Pass |
| Air Leakage | ISO 80369-7, 6.2 | 1 year real time aging | Pass |
| Stress Cracking | ISO 80369-7, 6.3 | 1 year real time aging | Pass |
| Axial Load | ISO 80369-7, 6.4 | 1 year real time aging | Pass |
| Unscrewing torque | ISO 80369-7, 6.5 | 1 year real time aging | Pass |
| Overriding | ISO 80369-7, 6.6 | 1 year real time aging | Pass |
| LOR | Internal protocol | 1 year real time aging | Pass |
| Tightness | Internal Protocol | 1 year real time aging | Pass |
| Stability Markings | Internal Protocol | 1 year real time aging | Pass |
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.