K192563 · Meditera Tibbi Malzeme San VE Tic AS · CCK · Jan 17, 2020 · Anesthesiology
Device Facts
Record ID
K192563
Device Name
Altera gas Sampling Lines
Applicant
Meditera Tibbi Malzeme San VE Tic AS
Product Code
CCK · Anesthesiology
Decision Date
Jan 17, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.1400
Device Class
Class 2
Indications for Use
The Altera Gas Sampling Lines are intended to connect from a port in the breathing circuit to the expired gas monitor.
Device Story
Altera Gas Sampling Lines are disposable, single-patient-use, coextruded (PE/EVA/PVC) narrow-diameter tubes; lengths of 2, 2.5, and 3 meters; standardized male luer connectors at both ends. Device functions as a conduit for one-directional gas flow from a patient breathing circuit port to a host gas monitor. Host device utilizes an internal vacuum pump to pull gas samples through the line for analysis. Used in hospitals, sub-acute, and pre-hospital settings. Healthcare providers connect the line to the circuit and monitor to facilitate respiratory gas analysis (e.g., capnography). Output allows clinicians to monitor patient respiratory status, aiding in clinical decision-making regarding ventilation and gas exchange.
Clinical Evidence
Bench testing only. Testing included flow resistance, mechanical testing (separation force, unscrewing torque, resistance to overriding), fluid/air leakage per ISO 80601-2-55, stress cracking, and luer fitting compliance per ISO 80369-7:2018. Accelerated aging studies confirmed 3-year shelf-life performance.
Technological Characteristics
Coextruded PE/EVA/PVC tubing; 1.2 mm ID / 2.8 mm OD; standardized male luer connectors per ISO 80369-7. Passive conduit; no internal energy source. Sterilization not specified. Bench testing per ISO 80601-2-55 and ISO 10993.
Indications for Use
Indicated for any patient population requiring gas monitoring via connection from a breathing circuit port to an expired gas monitor.
Regulatory Classification
Identification
A carbon dioxide gas analyzer is a device intended to measure the concentration of carbon dioxide in a gas mixture to aid in determining the patient's ventilatory, circulatory, and metabolic status. The device may use techniques such as chemical titration, absorption of infrared radiation, gas chromatography, or mass spectrometry.
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Meditera Tibbi Malzeme San. ve Tic. A.S. % Paul Dryden Consultant ProMedic, LLC 131 Bay Point Dr NE St. Petersburg, Florida 33704
Re: K192563
Trade/Device Name: Altera Gas Sampling Lines Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: Class II Product Code: CCK Dated: December 18, 2019 Received: December 19, 2019
Dear Paul Dryden:
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/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)
## K192563
Device Name
## Altera Gas Sampling Lines
Indications for Use (Describe)
The Altera Gas Sampling Lines are intended to connect from a port in the breathing circuit to the expired gas monitor.
Type of Use (Select one or both, as applicable)
XX Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### Date Prepared:
#### 16-Dec-2019
ALTERA TIBBI MALZEME SAN VE TIC AS Ibni Melek Mah Organize Sanayi Bolgesi Tire Izmir, TURKEY 35900 +90 232 513 51 10
| Official Contact: | Cenk Kılıç Kalkan<br>Quality Assurance Team Leader |
|----------------------------|-----------------------------------------------------------------|
| Proprietary or Trade Name: | Altera Gas sampling Lines |
| Common/Usual Name: | Carbon Dioxide Gas Analyzer |
| Classification: | 21CFR 868.1400<br>CCK - Carbon Dioxide Gas Analyzer<br>Class II |
| Predicate Device: | K171678 - Vyaire - Vital Signs Gas sampling Lines |
#### Device Description:
The Altera Gas Sampling Lines consists of a disposable single patient use coextruded gas sampling line which is provided in 3 different lengths: 2, 2.5, and 3 meters. The disposable single patient use gas sampling lines are smooth narrow diameter tubes that have standardized male luer connectors at both ends.
The gas sampling line connects from a port in a circuit to an expired gas monitor. The gas sampling line provides a conduit for drawing gas samples from the sampling port to the gas monitor to analyze respiratory gases. These disposable single patient use gas sampling lines are used to transmit one directional flow of gas sample from the patient breathing circuit port to the gas module host device. A vacuum source and gas measurement sensors are in the host device, which pull the gas from the sampling port to the host device for gas monitoring.
### Principle of Operation:
The principle of operation is that gas is pulled from a luer port on a circuit on the patient end of the tubing to the other end which is connected to a gas sampling monitor which has an internal vacuum pump pulling the gas to be sampled.
### Indications for Use:
The Altera Gas Sampling Lines are intended to connect from a port in the breathing circuit to the expired gas monitor.
The following table presents a comparison of the subject device to the predicate.
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| Attribute | Predicate<br>Vyaire Vital Signs | Proposed<br>Altera GSL | Comparison | Does the difference raise<br>new questions of safety<br>and effectiveness? |
|--------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|----------------|----------------------------------------------------------------------------------------------------------------------|
| K# | K171678 | N/A | N/A | N/A |
| Classification | CCK - Carbon Dioxide Gas Analyzer<br>21 CFR 868.1400 | CCK - Carbon Dioxide Gas<br>Analyzer<br>21 CFR 868.1400 | Same | No |
| Indications for Use | The Vital Signs Gas Sampling Lines are<br>intended to connect from a port in the<br>breathing circuit to the expired gas monitor.<br>These gas sampling lines are used with GE<br>Healthcare Compact Airway modules and<br>CARESCAPE Respiratory modules for<br>monitoring CO2, O2, N2O and anesthetic<br>agents and with E-miniC for monitoring<br>CO2. | The Altera Gas Sampling Lines<br>are intended to connect from a<br>port in the breathing circuit to<br>the expired gas monitor. | Similar | No.<br>The predicate is specific to<br>certain monitors, but they<br>have the same intended<br>use. |
| Principle of Operation | Gas is pulled from one end of the<br>tube to the other by a pump in<br>the gas sampling device. | Gas is pulled from one end of<br>the tube to the other by a pump<br>in the gas sampling device. | Similar | No |
| Patient Population | Any patient population requiring gas<br>monitoring | Any patient population<br>requiring gas monitoring | Similar | No |
| Environments of use | Hospitals | Hospitals, sub-acute, pre-hospital | Similar | No.<br>Expired gas monitoring is<br>utilized in other clinical<br>settings |
| Compatibility with<br>environment and other<br>devices | Designed for the use with GE Healthcare<br>Compact Airway modules and<br>CARESCAPE Respiratory modules for<br>monitoring CO2, O2, N2O and anesthetic<br>agents and with EminiC for monitoring<br>CO2. | Designed for use with gas<br>monitoring device (for example<br>a capnography) with luer<br>connections for gas sampling. | Similar | No.<br>While the predicate lists<br>specific monitors, all<br>expired gas sampling tend<br>to utilize a luer fitting |
| Single patient use,<br>disposable | Yes | Yes | Similar | No |
| Attribute | Predicate<br>Vyaire Vital Signs | Proposed<br>Altera GSL | Compa<br>rison | Does the difference raise<br>new questions of safety<br>and effectiveness? |
| Characteristics | | | | |
| Materials | ISO 10993 tested<br>Co-extruded PE/EVA/PVC | ISO 10993 tested<br>Co-extruded PE/EVA/PVC | Similar | No |
| Performance testing | Flow resistance –<br>~ 26 cmH2O @ 150 ml/min<br>Leakage per ISO 80601-2-55<br>< 10 ml/min | Flow resistance –<br>~ 12 - 17.5 cmH2O @ 150<br>ml/min<br>Leakage per ISO 80601-2-55<br>< 10 ml/min | Similar | No<br>Flow resistance is just a<br>reported value |
| Tubing<br>ID / OD | ID - 1.2 mm<br>OD - 2.8 mm | ID - 1.2 mm<br>OD - 2.8 mm | Similar | No |
| Lengths | Up to 3 meters | 2, 2.5 and 3 meters | Similar | No |
| Connectors | Standard ISO 80369 small bore luer fittings –<br>male / female | Standard ISO 80369 small bore<br>luer fittings - male / female | Similar | No<br>Predicate referenced ISO<br>594-2 vs. ISO 80369-7 |
| Separation force of<br>connectors | >35 Newtons | >35 Newtons | Similar | No |
| Leakage of connectors | 0.02-0.05 ml/min | < $0.005Pa*m3/s$<br>Units per ISO 80369-7 | Similar | No |
| ISO 594-2 or<br>ISO 80369-7 | ISO 594-2<br>Unscrewing torque<br>Resistance to overriding<br>Stress cracking | ISO 80369-7<br>Unscrewing torque<br>Resistance to overriding<br>Stress cracking | Similar | No<br>Both devices passed the<br>requirements for luer<br>fittings even though they<br>used a different standard |
| Performance post<br>aging | N/A | After 3 years accelerated aging<br>performance testing still met the<br>pre-established acceptance<br>criteria | | No |
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## Performance Testing
We completed the following performance testing:
- . Flow resistance
- Accelerated ageing including environmental ●
- 3 years shelf-life
- . Mechanical testing
- Luer fitting per ISO 80369-7:2018
- Fluid leakage
- Air leakage
- Stress cracking
- Separation force
- . Unscrewing torque
- Resistance to overriding .
- Air leakage (ISO 80601-2-55) ●
## Diseussion of Differences and Substantial Equivalence Conclusion
There are no differences between the proposed device and the predicate. The performance testing has demonstrated that the subject devise met the applicable standard performance requirements. There were no differences which raise different risks vs. the predicate.
The sponsor has demonstrated through performance testing, design and features, and non-clinical testing that the proposed device and predicate have been found to be substantially equivalent.
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.