K192324 · Teleflexmedical, Inc. · BTR · Dec 6, 2019 · Anesthesiology
Device Facts
Record ID
K192324
Device Name
Sheridan Spiral-Flex Endotracheal Tubes
Applicant
Teleflexmedical, Inc.
Product Code
BTR · Anesthesiology
Decision Date
Dec 6, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5730
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
Sheridan cuffed, uncuffed and reinforced tracheal tubes are designed for oral or nasal intubation and are indicated for airway management.
Device Story
Sheridan Spiral-Flex Endotracheal Tubes are sterile, single-use devices designed to establish a patent airway for ventilation. The tube is inserted into the trachea via the mouth or nose. It features a spiral wire embedded between two layers of PVC, a compatible cuff, inflation line, pilot balloon, one-way valve, and a 15mm connector. The device is used by clinicians in clinical settings for airway management. The tube facilitates mechanical ventilation or oxygenation, benefiting patients requiring airway support. The device includes a Murphy eye, bite block, and X-ray marker for clinical positioning and safety.
Clinical Evidence
Bench testing only. Testing included visual inspection, cuff inflation/deflation, inflation system leak tests, cuff herniation tests, pilot cuff pull tests, and simulated use testing. Biocompatibility was evaluated per ISO 10993-1:2009. Performance verified against ASTM F623 requirements.
Technological Characteristics
Materials: PVC shaft with spiral wire embedded between two PVC layers. Design: Cuffed (high volume tapered), uncuffed, and reinforced options; Murphy eye; beveled tip; 15mm connector. Sterilization: Ethylene Oxide. Connectivity: None. Dimensions: Cuffed 5.0–9.0 mm, Uncuffed 3.0–5.0 mm. Standards: ASTM F623, ISO 10993-1.
Indications for Use
Indicated for airway management via oral or nasal intubation in adult and pediatric patients. No contraindications.
Regulatory Classification
Identification
A tracheal tube is a device inserted into a patient's trachea via the nose or mouth and used to maintain an open airway.
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TeleflexMedical, Inc Lori Pfohl Senior Regulatory Affairs Specialist 3015 Carrington Mill Blvd, Suite 600 North Morrisville, North Carolina 27560
Re: K192324
Trade/Device Name: Sheridan Spiral-Flex Endotracheal Tubes Regulation Number: 21 CFR 868.5730 Regulation Name: Tracheal Tube Regulatory Class: Class II Product Code: BTR Dated: August 22, 2019 Received: August 27, 2019
## Dear Lori Pfohl:
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. 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
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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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Todd Courtney Assistant 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)
#### Device Name
Sheridan Spiral-Flex Endotracheal Tubes
#### Indications for Use (Describe)
Sheridan cuffed, uncuffed and reinforced tracheal tubes are designed for oral or nasal intubation and are indicated for airway management.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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## 510(k) Summary
## A. Name, Address, Phone and Fax Number of Applicant
Teleflex Medical, Inc. 3015 Carrington Mill Blvd Morrisville, NC 27560 Phone: 919-433-4831 Fax: 919-361-3939
## B. Contact Person
Lori Pfohl Senior Regulatory Affairs Specialist
## C. Date Prepared
August 23, 2019
## D. Device Name
| Trade Name: | Teleflex Sheridan Spiral-Flex Tracheal Tube |
|-----------------------|---------------------------------------------|
| Common Name: | Tube, Tracheal |
| Product Code: | BTR |
| Regulation Number: | CFR 868.5730 |
| Classification Name: | Tracheal Tube |
| Classification: | II |
| Classification Panel: | Anesthesiology |
## E. Predicate Device
This submission demonstrates substantial equivalence to the predicate device:
Sheridan Reinforced Tracheal Tube K844296 and Spiral-Flex Tracheal Tube K860105
## F. Device Description
The Sheridan Spiral-Flex Endotracheal Tubes are spiral tracheal tubes that are inserted into the trachea via the mouth or the nose in order to establish a patent airway to allow ventilation. The subject device are sterile, single use devices. The tracheal tubes contain a compatible cuff, inflation line, pilot balloon and one-way valve. Each tracheal tube is supplied with an appropriately sized 15mm connector.
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## G. Indications for Use
Sheridan cuffed, uncuffed and reinforced tracheal tubes are designed for oral or nasal intubation and are indicated for airway management.
## H. Contraindications
None
## I. Substantial Equivalence
The subject device is substantially equivalent to the predicate devices with respect to intended use, technology and construction. The differences between the predicates and the subject devices are minor and any risks have been mitigated through testing. Table 07.1 summarizes the differences between the subject and predicate device.
The subject devices are substantially equivalent to the predicate device:
| Features | Teleflex Sheridan Spiral-Flex<br>Tracheal Tube (Subject<br>Device) | Teleflex<br>Sheridan Reinforced<br>Tracheal Tube<br>K844296 (Predicate<br>Device 1) | Teleflex Sheridan<br>Spiral-Flex Tracheal<br>Tube K860105<br>(Predicate Device-2) |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|
| Classification<br>Name | Tracheal Tube | Same | Same |
| Regulation<br>Number | 868.5730 | Same | Same |
| FDA Procode | BTR | BTR | BTR |
| Class | II | Same | Same |
| Indication for Use | Sheridan cuffed, uncuffed<br>and reinforced tracheal tubes<br>are designed for oral or nasal<br>intubation and are indicated<br>for airway management. | Intended for airway<br>management<br>procedures requiring<br>flexing of the neck | Airway management<br>procedures requiring<br>flexing of the neck |
| Contraindications | None | None | None |
| Single Use | Yes | Yes | Same |
| Population | Adult and Pediatric | Adult | Adult and Pediatric |
| Size Range | Cuffed oral/nasal 5.0–9.0 mm<br>Uncuffed 3.0–5.0 mm | Oral 5.0 – 10.0 mm<br>Nasal 5.0 – 9.0 mm | Uncuffed<br>Oral 2.0 – 7.0 mm<br>Nasal 2.0 – 7.0 mm |
Table 07.1 - Comparison of Predicate vs. Subject Devices
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| Sterile | Yes | Yes | Same |
|-------------------------|----------------------------------------------------------------------|----------------|----------------|
| Sterilization<br>Method | Ethylene Oxide | Ethylene Oxide | Ethylene Oxide |
| Valve System | Integral pilot balloon and<br>valve | Same | Same |
| Shaft Material | PVC. Spiral wire completely<br>embedded between two<br>layers of PVC | Same | Same |
| Connector | Standard 15mm | Same | Same |
| Cuff Design | High Volume tapered cuff | Same | Same |
| Murphy Eye | Yes | Same | Same |
| Bite Block | Yes | Same | Same |
| Stylet | Yes | Same | Same |
| Tube Tip | Beveled | Same | Same |
| X-Ray Marker | At extreme end | Same | Same |
## J. Comparison to the Predicate
Table 7.1 illustrates the similarities and differences between the subject and predicate devices. The basic technological and operating principles are the same for both devices. Although the wording is not identical, both the subject and predicate devices are for airway management. Both the subject and predicate devices are intended for similar patient populations adult and pediatric, male and female. Both the subject and predicate devices are disposable, sterile, single patient use devices. As evidenced by comparison Table 7.1. above, the subject device is substantially equivalent to the predicate device. There are no significant differences that would affect safety and efficacy.
## K. Performance Data
The bench testing performed verifies that the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device. These tests include:
- Visual Inspection (No delamination on tip of reinforced tubes) ●
- Cuff inflation deflation test ●
- Inflation system leak test
- Cuff herniation test
- Pilot Cuff Pull test ●
- Simulated Use Test
- ISO 10993-1:2009 - Biological Evaluation of Medical Devices -- Part 1: Evaluation and testing within a risk management process
The testing performed verifies that the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device.
The subject devices were tested to the requirements of ASTM F623.
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# L. Conclusion
The subject device has the same intended use and technological characteristics and construction as the predicate. Test results demonstrate that the subject device meets it's intended use. It is for these reasons that the subject device can be found substantially equivalent to the predicate devices.
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.