AK 98 Dialysis Machine, U9000 Ultrafilter, C705 Expansion Chamber Accessory
Applicant
Baxter Healthcare Corportation
Product Code
KDI · Gastroenterology, Urology
Decision Date
Mar 10, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5860
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The Baxter AK 98 dialysis machine is intended to be used for intermittant haemodialysis and/or isolated ultrafiltration treatments of patients with chronic or acute renal failure or fluid overload upon prescription by a physician. The AK 98 dialysis machine is indicated to be used on patients with a body weight of 25 kg or more. The AK 98 dialysis machine is intended to be used by trained operators when prescribed by a physician, in a chronic care dialysis or hospital care environment. The Baxter AK 98 dialysis machine is not intended for Selfcare or Home use.
Device Story
AK 98 is a standalone, software-controlled hemodialysis machine for intermittent hemodialysis and isolated ultrafiltration. It pumps blood from patient through bloodlines to a dialyzer for purification, then returns it. The system includes a fluid unit (produces dialysis fluid from RO water and concentrates; manages temperature, flow, composition, and ultrafiltration) and a blood unit (manages extracorporeal circuit, heparin pump for anticoagulation). Operators interact via a touchscreen/hard-key panel to set treatment parameters and alarm limits. The system monitors pressures, flows, and conductivity; provides audible/visual alarms; and enters a safe state (e.g., bypass) upon fault detection. It integrates with clinical information systems via HL7. The U9000 ultrafilter (installed in the pre-dialyzer flow-path) purifies dialysis fluid to minimize bacteria/endotoxin exposure. The C-705 expansion chamber allows conversion from double-needle to single-needle treatment mode. Benefits include waste/fluid removal for renal failure patients.
Clinical Evidence
Bench testing only. Performance verified via functional testing, electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), and adherence to IEC 60601-2-16. Biocompatibility testing per ISO 10993-1. U9000 verified for pressure drop, retention capacity (bacteria/endotoxin), ultrafiltration rate, and membrane integrity. C-705 verified for clamp performance, tensile strength, priming volume, and mechanical hemolysis.
Indicated for intermittent hemodialysis and/or isolated ultrafiltration in patients (≥25 kg) with chronic or acute renal failure or fluid overload. Used in chronic care dialysis or hospital settings by trained operators.
Regulatory Classification
Identification
A high permeability hemodialysis system is a device intended for use as an artificial kidney system for the treatment of patients with renal failure, fluid overload, or toxemic conditions by performing such therapies as hemodialysis, hemofiltration, hemoconcentration, and hemodiafiltration. Using a hemodialyzer with a semipermeable membrane that is more permeable to water than the semipermeable membrane of the conventional hemodialysis system (§ 876.5820), the high permeability hemodialysis system removes toxins or excess fluid from the patient's blood using the principles of convection (via a high ultrafiltration rate) and/or diffusion (via a concentration gradient in dialysate). During treatment, blood is circulated from the patient through the hemodialyzer's blood compartment, while the dialysate solution flows countercurrent through the dialysate compartment. In this process, toxins and/or fluid are transferred across the membrane from the blood to the dialysate compartment. The hemodialysis delivery machine controls and monitors the parameters related to this processing, including the rate at which blood and dialysate are pumped through the system, and the rate at which fluid is removed from the patient. The high permeability hemodialysis system consists of the following devices:(1) The hemodialyzer consists of a semipermeable membrane with an in vitro ultrafiltration coefficient (K uf ) greater than 8 milliliters per hour per conventional millimeter of mercury, as measured with bovine or expired human blood, and is used with either an automated ultrafiltration controller or anther method of ultrafiltration control to prevent fluid imbalance.(2) The hemodialysis delivery machine is similar to the extracorporeal blood system and dialysate delivery system of the hemodialysis system and accessories (§ 876.5820), with the addition of an ultrafiltration controller and mechanisms that monitor and/or control such parameters as fluid balance, dialysate composition, and patient treatment parameters (e.g., blood pressure, hematocrit, urea, etc.). (3) The high permeability hemodialysis system accessories include, but are not limited to, tubing lines and various treatment related monitors (e.g., dialysate pH, blood pressure, hematocrit, and blood recirculation monitors).
Special Controls
*Classification.* Class II. The special controls for this device are FDA's:(1) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Device—Part I: Evaluation and Testing,’ ”
(2) “Guidance for the Content of 510(k)s for Conventional and High Permeability Hemodialyzers,”
(3) “Guidance for Industry and CDRH Reviewers on the Content of Premarket Notifications for Hemodialysis Delivery Systems,”
(4) “Guidance for the Content of Premarket Notifications for Water Purification Components and Systems for Hemodialysis,” and
(5) “Guidance for Hemodialyzer Reuse Labeling.”
Single Needle Conversion Kit (Gambro Cartridge Blood Set) (K070414)
Submission Summary (Full Text)
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March 10, 2021
Baxter Healthcare Corporation Kristen Bozzelli Manager, Regulatory Affairs 25212 W. Illinois Route 120 Round Lake, Illinois 60073
Re: K201809
> Trade/Device Name: AK 98 Dialysis Machine, U9000 Ultrafilter, C705 Expansion Chamber Accessory Regulation Number: 21 CFR 876.5860 Regulation Name: High permeability hemodialysis system Regulatory Class: II Product Code: KDI, FIP, FJK Dated: February 5, 2021 Received: February 9, 2021
Dear Kristen Bozzelli:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies.
You must comply with all the Act's requirements. including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatoryinformation/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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,
Carolyn Y. Neuland, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology 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) K201809
Device Name Baxter AK 98 Dialysis Machine
#### Indications for Use (Describe)
The Baxter AK 98 dialysis machine is intended to be used for intermittant haemodialysis and/or isolated ultrafiltration treatments of patients with chronic or acute renal failure or fluid overload upon prescription by a physician. The AK 98 dialysis machine is indicated to be used on patients with a body weight of 25 kg or more. The AK 98 dialysis machine is intended to be used by trained operators when prescribed by a physician, in a chronic care dialysis or hospital care environment. The Baxter AK 98 dialysis machine is not intended for Selfcare or Home use.
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#### K201809 (CONTINUED)
Device Name: Baxter C-705 Accessory Expansion Chamber
C-705 Accessory Expansion Chamber is a single use sterile medical device intended to be used during the delivery of Hemodialysis treatment in Single Needle mode, on patients affected by chronic renal failure. The C-705 Accessory Expansion Chamber is an ancillary device used to allow the conversion from Double Needle to Single Needle administration mode of treatments, after connection to proper Blood Tubing System intended for Haemodialysis treatment in Double Needle mode and to a Dialyzer filter. C-705 Accessory Expansion Chamber shall be used in combination with Blood Tubing System suitable for AK 98 haemodialysis delivery system only. The total extracorporeal blood volume for the extracorporeal circuit including the set, dialyzer and accessories should represent less than 10% of the patient's blood volume.
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#### K201809 (CONTINUED)
Device Name: Baxter U9000 Ultrafilter
The U9000 Ultrafilter is indication of incoming water for dialysis fluid as well as purification of dialysis fluid to obtain standard dialysis fluid in accordance with international standards requirements and local regulations. The risk of exposure to bacteria and endotoxins can thereby be minimized. The U9000 Ultrafilter is intended to be used in conjunction with a water treatment system.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### Section 5. 510(k) Summary
10 March, 2021
#### OWNER:
Baxter Healthcare Corporation One Baxter Parkway Deerfield, Illinois 60015
#### CONTACT PERSON:
Kristen Bozzeli Manager, Global Regulatory Affairs 25212W. Illinois Route 120 Round Lake, IL 60073 Telephone: +1.224.948.5585 Fax: 224-270- 4119
#### IDENTIFICATION OF THE DEVICES:
Common Name: Hemodialysis Delivery System Trade/Device Name: AK 98 Classification Panel: 78 Gastroenterology and Urology Regulation Number: 21 CFR 876.5860 Regulation Name: High Permeability Hemodialysis System Regulatory Class: Class II Product Code: 78KDI
Common Name: Ultrafilter/Water Purification Subsystem Trade/Device Name: U9000 Classification Panel: 78 Gastroenterology and Urology Regulatory Class: Class II Product Code: 78FIP
Common Name: : Set, Tubing, Blood, With and Without Anti-Regurgitation Valve Trade/Device Name: C-705 Classification Panel: 78 Gastroenterology and Urology Regulatory Class: Class II Product Code: 78FJK
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| Product code | Name |
|--------------|-----------------------------------|
| 955607 | AK 98 Dialysis Machine |
| 112062 | U9000 Ultrafilter |
| 6430771A | C-705 Accessory Expansion Chamber |
#### Table 1. Product codes in this submission
## PREDICATE DEVICES:
| Proposed | Predicates | | | |
|--------------------------------------|--------------------------------------------------------------------|--------------------------|---------------------|-------------------|
| Device | Device | 510k submitter | Predicate<br>510(k) | Clearance<br>Date |
| AK 98 Dialysis<br>Machine | Phoenix<br>Hemodialysis<br>Delivery System | Gambro Renal<br>Products | K103832 | May 2011 |
| U9000 Ultrafilter | Diaclear Ultrafilter | Gambro Renal<br>Products | K003957 | January 2001 |
| C-705 Accessory<br>Expansion Chamber | Single Needle<br>Conversion Kit<br>(Gambro Cartridge<br>Blood Set) | Gambro Renal<br>Products | K070414 | October 2007 |
#### Table 2. Predicate Device(s)
## DESCRIPTION OF THE DEVICES:
The proposed device AK 98 Hemodialysis system, which is subject for this Traditional 510(k) premarket notification, consists of the following:
- AK 98 dialysis machine
- U9000 (Ultrafilter)
- C-705 (Accessory Expansion chamber)
## AK 98 Dialysis Machine
AK 98 is a standalone, software controlled hemodialysis machine intended to be used in a chronic care dialysis or hospital care environment for intermittent hemodialysis and/or isolated ultrafiltration treatments of patients with chronic or acute renal failure or fluid overload.
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The goal of hemodialysis treatment is to remove waste products and excess fluid from the patient's bloodstream.
The AK 98 is to be used with compatible blood lines, liquid A-concentrate, sodium bicarbonate powder (BiCart) or liquid bicarbonate, Ultrafilter (U9000) and dialyzers (e.g. Revaclear, Polyflux).
The AK 98 pumps blood from the patient into the compatible bloodline, through the dialyzer (where the blood purification takes place), and then back to patient. The AK 98 handles treatment details, monitors and regulates the pressure and flow on both blood and fluid side, and continually monitors the operation of the dialysis machine.
The AK 98 dialysis machine can be divided into the following parts:
- . Fluid unit - is used to produce the dialysis fluid (with the correct temperature, flow, and composition) from reverse osmosis water and concentrates (dry or liquid), and to transport the dialysis fluid through the dialyzer. The fluid unit offers Profiling of Ultrafiltration and/or conductivity, it also offers isolated Ultrafiltration. The fluid unit also includes "Clearance Measurement" (Diascan). The fluid unit maintains the dialysis fluid flow through the dialyzer and controls ultrafiltration. If a fault occurs, the machine enters a patient safe state, which depending on the fault, can include actions such as bypassing the dialyzer.
- Blood unit - is designed to control and supervise the extracorporeal blood circuit. Double needle treatments are most common. Single needle treatments can also be performed with one pump (double clamp function). To prevent coagulation, anticoagulants can be administered by means of the integrated heparin pump. Disposable blood lines are used to transport the blood from the patient to the AK 98 machine and back to the patient.
- . Power supply - The mains voltage is fed to an AC/DC converter within the AK 98, which generates different DC supplies for the machine.
Operator's panel - Both the blood unit and the fluid unit are controlled from the operator's panel. The panel contains a touch screen and a number of hard key buttons to the right of the screen. The screen allows the operator to interact with the dialysis machine by pressing various buttons. The hard-key buttons are language independent. The information in the display can be set to different languages.
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The Operator's panel (User Interface) lets the Operator set Treatment parameters and Alarm limits (where applicable) and it shows limits and measured values, remaining time for Treatment and Disinfection and other information to the Operator. In an alarm situation, the dialysis machine provides audible and visual indications. Additionally, the visual indication is shown on the alarm light bar on top of the dialysis machine.
It is also possible for a Technician to enter Service mode via the User interface sub-system by use of a PIN code.
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Image /page/10/Picture/2 description: The image shows a dialysis machine, which is a medical device used to remove waste products and excess fluid from the blood when the kidneys are not functioning properly. The machine is blue and white and has a variety of tubes and connectors. There is a screen on the top of the machine that displays information about the dialysis treatment. The machine is on wheels, which makes it easy to move around.
Figure 1. Photograph of AK 98 dialysis machine
#### U9000 Ultrafilter
The Ultrafilter product family (U9000, and its predicate device Diaclear) are ultrafilters intended for water filtration (removal of pyrogens and microorganisms), and filtration of dialysis fluid. The risk of exposure to bacteria and endotoxins can thereby be minimized.
The U9000 is intended to be used in conjunction with an upstream water treatment system. The Ultrafilter U9000 can only be used with Baxter/Gambro/Hospal dialysis
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machines equipped with a dedicated U9000 filter holder. This places the U9000 ultrafilter in the pre-dialyzer flow-path to filter the fluid before it reaches the dialyzer.
On the US market, The U9000 is intended to be used as a required component of the AK 98 Hemodialysis System, to minimize the risk of exposure to bacteria and endotoxins by creating a microbiologically high quality dialysate.
## C-705 Accessory Expansion Chamber
The C-705 Accessory Expansion Chamber is a single use sterile medical device for hemodialysis intended to be connected to compatible bloodlines for hemodialysis that allow the channeling of blood from the body through its circuits into another device that carries out the hemodialysis effect of the treatment.
C-705 is intended to be used during the delivery of hemodialysis treatment in Single Needle mode; it allows the conversion from Double Needle to Single Needle administration mode of treatments. C705 intended to be used on patients affected by chronic renal failure in an in-center hemodialysis environment. At this time, AK 98 is the only hemodialysis system compatible with the C705 accessory on the US market.
## INDICATIONS FOR USE PROPOSED DEVICES:
## AK 98 Dialysis Machine
The Baxter AK 98 dialysis machine is intended to be used for intermittent haemodialysis and/or isolated ultrafiltration treatments of patients with chronic or acute renal failure or fluid overload upon prescription by a physician.
The AK 98 dialysis machine is indicated to be used on patients with a body weight of 25 kg or more. The AK 98 dialysis machine is intended to be used by trained operators when prescribed by a physician, in a chronic care dialysis or hospital care environment.The Baxter AK 98 dialysis machine is not intended for Selfcare or Home use.
## U9000 Ultrafilter
The U9000 Ultrafilter is indicated for purification of incoming water for dialysis fluid as well as purification of dialysis fluid to obtain standard dialysis fluid in accordance with international standards requirements and local regulations. The risk of exposure to bacteria and endotoxins can thereby be minimized. The U9000 Ultrafilter is intended to be used in conjunction with a water treatment system.
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#### C-705 Accessory Expansion Chamber
C-705 Accessory Expansion Chamber is a single use sterile medical device intended to be used during the delivery of Hemodialysis treatment in Single Needle mode, on patients affected by chronic renal failure.
The C-705 Accessory Expansion Chamber is an ancillary device used to allow the conversion from Double Needle to Single Needle administration mode of treatments, after connection to proper Blood Tubing System intended for Haemodialysis treatment in Double Needle mode and to a Dialyzer filter. C-705 Accessory Expansion Chamber shall be used in combination with Blood Tubing System suitable for AK 98 haemodialysis delivery system only. The total extracorporeal blood volume for the extracorporeal circuit including the set, dialyzer, and accessories should represent less than 10% of the patient's blood volume.
## TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE:
#### AK 98 Dialysis Machine
The differences between the predicate Phoenix machine and the proposed AK 98 dialysis machine as discussed in the AK 98 Device Comparison Table are considered substantially equivalent. See the comparison in Table 3.
Identification of Predicate Device:
- Trade Name: Phoenix Hemodialysis Delivery System
- 510(k) Holder: Gambro Renal Products
- Common Name: Hemodialysis Delivery System.
- Clearance: K103832 cleared on May 20, 2011.
Identification of Proposed Device:
- Trade Name: AK 98 Dialysis Machine
- 510(k) Holder:: Gambro Lundia AB, Sweden
- Common Name: Hemodialysis Delivery System.
- Clearance: Pending
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## U9000 Ultrafilter
The differences between the predicate Diaclear Ultrafilter and the proposed device U9000 Ultrafilter as reflected in the Substantial Equivalence (SE) Table are considered substantially equivalent. See the comparison in Table 4.
Identification of Predicate Device
- Trade Name: Diaclear™ Ultrafilter
- 510(k) Submitter/holder: Gambro Industries, Meyzieu Cedex, France.
- Common name: Ultrafilter/Water Purification Subsystem
- Clearance: K003957
## Identification of Proposed Device
- Trade Name: U9000 Ultrafilter
- 510(k) Submitter/holder: Baxter Healthcare Corporation
- Common name: Ultrafilter/Water Purification Subsystem
- Clearance: Pending
## C-705 Accessory Expansion Chamber
The differences between the predicate Single Needle Conversion Kit and the proposed device C705 Accessory Expansion Chamber as reflected in the Substantial Equivalence (SE) Table are considered substantially equivalent. See the comparison in Table 5.
Identification of Predicate Device
Trade Name: 510(k) Holder:: Common name: Clearance:
Identification of Proposed Device
- Trade Name: C705 Accessory Expansion Chamber
- 510(k) Submitter/holder: Baxter Healthcare Corporation
- Common name: Clearance: Pending
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| Features | Predicate Device<br>Phoenix 3.40<br>Cleared under K103832 | Proposed Device<br>AK 98 (software version 3.x.x) | Assessment of Differences |
|--------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended use | The Phoenix® Hemodialysis<br>delivery system is intended to be<br>used to provide high flux and<br>flow flux hemodialysis.<br>hemofiltration and ultrafiltration<br>on patients weighing 15<br>Kilograms or more. The Phoenix<br>system is to be used with either<br>high or low permeability<br>dialyzers. The device is intended<br>to be used by trained operators<br>when prescribed by a physician,<br>in a chronic care dialysis facility<br>or acute care unit. | The Baxter AK 98 dialysis machine<br>is intended to be used for<br>intermittent hemodialysis and/or<br>isolated ultrafiltration treatments of<br>patients with chronic or acute renal<br>failure or fluid overload upon<br>prescription by a physician.<br>The AK 98 dialysis machine is<br>indicated to be used on patients with<br>a body weight of 25 kg or more.<br>The AK 98 dialysis machine is<br>intended to be used by trained<br>operators when prescribed by a<br>physician, in a chronic care dialysis<br>or hospital care environment.<br>The Baxter AK 98 dialysis machine<br>is not intended for Selfcare or Home<br>use. | AK 98 can be used with both low and<br>high flux dialyzers for hemodialysis.<br>Performance of the Phoenix and AK 98<br>machines are equivalent, but the patient<br>weight limit is determined at the system<br>level.<br>Hemofiltration is not supported by AK<br>98. |
| Treatment modalities | Hemodialysis (HD)<br>- HD DN/SP(Double<br>Needle/Single Pump) treatment<br>- HD SN/SP (Single<br>Needle/Single Pump) treatment<br>Hemofiltration | Hemodialysis<br>- HD DN/SP treatment<br>- HD SN/SP treatment | Hemofiltration is not supported by AK<br>98. |
| Dialysate conductivity monitoring | Yes | Yes | None |
| Features | Predicate Device<br>Phoenix 3.40<br>Cleared under K103832 | Proposed Device<br>AK 98 (software version 3.x.x) | Assessment of Differences |
| pH sensor | Yes | No | The AK 98 System controls risk by<br>monitoring the concentrate (pumps'<br>speed. The difference does not impact on<br>safety and effectiveness |
| Isolated UF | Yes | Yes | None |
| Ultrafiltration control | Yes | Yes | None |
| Ultrafiltration supervision | Yes, monitored by TMP<br>(Transmembrane pressure) | Yes, supervision in accordance with<br>IEC 60601-2-16, 4th edition | Both predicate and proposed device<br>supervise Ultrafiltration however due to<br>requirement in IEC 60601-2-16 ed.4; the<br>AK 98 uses separate Ultrafiltration<br>supervision as protection instead of TMP<br>as used by Phoenix.<br>(subclause 201.12.4.4.103 NET FLUID<br>REMOVAL TMP monitoring is not<br>considered to be an adequate protection<br>against fluid balancing errors in the case<br>of high-flux DIALYSERS.). |
| Ultrafiltration accuracy | Between ±35 and ±160 g/h,<br>depending on dialysis fluid flow<br>rate and the ultrafiltration rate.<br>Note: Ultrafiltration accuracy<br>calculated per the Phoenix<br>Operator's Manual a, section<br>9.2.6 Ultrafiltration system. | Between ±50 and ±100 g/h,<br>depending on ultrafiltration rate.<br>Note: Ultrafiltration accuracy<br>calculated per section 13.1.6 in the<br>AK 98 Operator's Manual | The difference is considered clinically<br>insignificant for low dialysis fluid flow<br>rate. In a worst case scenario the AK 98<br>has improved accuracycompared to the<br>predicate device. Therefore Baxter<br>considers the ultrafiltration accuracy of<br>the proposed device and the predicate<br>device to be equivalent. |
| Air detector | Yes | Yes | None |
| Blood leak detector | Yes | Yes | None |
| Features | Predicate Device<br>Phoenix 3.40<br>Cleared under K103832 | Proposed Device<br>AK 98 (software version 3.x.x) | Assessment of Differences |
| Temperature monitoring | Yes | Yes | None |
| Fail-safe response during power<br>failure | Yes | Yes | None |
| Prescription profiling | Conductivity profiling (Na) | Conductivity profiling (Na, HCO3) | AK 98 supports profiling of both Na and<br>HCO3. |
| Disinfection programs | Heat<br>Chemical | Heat<br>Chemical | None |
| Anti coagulant administration<br>rate: | 0/0.5 – 9.9 ml/h | 0 - 10.0 ml/h | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Anti coagulant bolus: | 0/0.5 - 10.0 ml | 0 - 10.0 ml | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Blood Flow Rate | 10 - 580 ml/min | 20 -600 ml/min | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Blood flow rate accuracy | Accuracy ± 10% if pressure<br>before the pump is not lower<br>(more negative) than - 150<br>mmHg | For pre-pump pressure range from -<br>200 mmHg to 0 mmHg:<br>±10 mL/min or ±10% of the set<br>point value, whichever is the largest | The accuracy difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Dialysate Flow Rate | 350 - 800 ml/min | 300 - 800 ml/min | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Features | Predicate Device<br>Phoenix 3.40<br>Cleared under K103832 | Proposed Device<br>AK 98 (software version 3.x.x) | Assessment of Differences |
| Dialysate Flow Rate accuracy | $\pm$ 5% | $\pm$ 10 % or 50 mL/min whichever is<br>largest | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Transmembrane Pressure (TMP) | -100 to +450 mmHg (calculated<br>value) ALARM range | -200 - +500 mmHg (calculated<br>value) set of LIMITS | For the proposed device TMP is used for<br>detecting clotting, unlike the predicate<br>device which uses it for Ultrafiltration<br>supervision. |
| Net Fluid Removal Rate | 0 - 4 kg/h | 0 - 4 L /h | None |
| Dialysate Temperature | 34 - 39.5 °C | 33 - 40 °C | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Dialysate Conductivity set range | 13-17 mS/cm | 9-16 mS/cm | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Arterial pressure | -400 to +150 mmHg | -400 - +300 mmHg | The range difference is not impacting<br>safety and effectiveness. The range can be<br>set by the user. |
| Venous Pressure | 0 to +450 mmHg | +10 - +500 mmHg | The range difference is negligible and<br>therefore no impact on safety and<br>effectiveness. |
| Blood pressure measurements<br>(BPM) | Yes | Yes | None |
{15}------------------------------------------------
{16}------------------------------------------------
{17}------------------------------------------------
{18}------------------------------------------------
| Features | Predicate Device<br>Phoenix 3.40<br>Cleared under K103832 | Proposed Device<br>AK 98 (software version 3.x.x) | Assessment of Differences |
|-----------------|-----------------------------------------------------------------|-------------------------------------------------------------------------|---------------------------|
| IT connectivity | Yes -<br>Integrates with the EXALIS<br>Dialysis Management Tool | Yes -<br>Integrates with CIS (clinical<br>information system) using HL7 | None |
| | | protocol | |
| Features | Predicate Device - Diaclear<br>Cleared under K003957 | Proposed Device<br>U9000 Ultrafilter | Assessment of Differences |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | The DIACLEAR ultrafilter is intended to<br>be used only with either HOSPAL<br>Integra or Innova or GAMBRO Phoenix<br>dialysis machines equipped with the<br>feature for dialysate filtration. | The Ultrafilter U9000 is intended to be used in<br>conjunction with a water treatment system.<br>WARNING! The Ultrafilter U9000 can only be<br>used with Gambro/Baxter/Hospal dialysis<br>machines equipped with U9000 filter holder. | U9000 is to be used on a new<br>generation of dialysis machines,<br>including AK 98.<br>Diaclear is not compatible with the<br>new system. |
| Indications for<br>Use | Ultrafiltration with the DIACLEAR<br>ultrafilter is indicated for purification of<br>dialysis fluid to obtain microbiologically<br>high quality dialysis fluid.<br>The risk of exposure to bacteria and<br>endotoxins can thereby be minimised. | The Ultrafilter U9000 is indicated for purification<br>of incoming water for dialysis fluid as well as<br>purification of dialysis fluid to obtain standard<br>dialysis fluid in accordance with international<br>standards requirements and local regulations.<br>The risk of exposure to bacteria and endotoxins<br>can thereby be minimized. The Ultrafilter U9000<br>is intended to be used in conjunction with a water<br>treatment system | No significant difference |
| Sterile | Yes | No<br>(Unsterile Device) | The U9000 ultrafilter is produced<br>in a clean room environment, and<br>the bioburden level of the product is<br> |
| Features | Predicate Device – Diaclear<br>Cleared under K003957 | Proposed Device<br>U9000 Ultrafilter | Assessment of Differences…
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.