Bact-Trap Filter, Bact-Trap Mini, Bact-Trap Midi, Pharma Mini HME/Filter, Bact-HME HME/Filter and Bact-HME Midi HME/Filter
K202459 · Pharma System AB · CAH · Sep 26, 2021 · Anesthesiology
Device Facts
Record ID
K202459
Device Name
Bact-Trap Filter, Bact-Trap Mini, Bact-Trap Midi, Pharma Mini HME/Filter, Bact-HME HME/Filter and Bact-HME Midi HME/Filter
Applicant
Pharma System AB
Product Code
CAH · Anesthesiology
Decision Date
Sep 26, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5260
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Bact Trap filter is a breathing system filter which is designed to reduce possible airborne or liquid-borne cross contamination with micro-organisms and particulate matter via anaesthetic or ventilator breathing systems. The Bact Trap filter may either be used on the patient side of the ventilator anaesthetic device. The Bact HME/Bact-HME Midi/Pharma Mini is a breathing system filter and a Heat and Moisture Exchanger. The combination of a filter and a Heat and Moisture offer the benefit of both product features. Heat and Moisture Exchangers are used as a conditioning system for mechanically ventilated patients whose uppassed. In almost all cases of mechanical ventilation they are a fully valid alternative to heated humidifiers. The Bact-HME Midi/Pharma Mini should be used with patients who have a Tidal Volume between 50 - 1500 ml. The Pharma Mini™HME/Filter, Bact-HME™ filter/HME and Bact-HME™ Midi HME/Filter should be used with patients who have a Tidal Volume as follows: - Pharma Mini™ and Bact-Trap™ Mini 50-900ml - · Bact-HME™ Midi and Bact-Trap™ Midi between 100-1200 ml - · Bact-HMETM and Bact-Trap™ between 250-1500 ml The products mentioned above are designed as disposable single patient use and should be changed at least every 24 hours
Device Story
Disposable breathing circuit filters and heat/moisture exchangers (HME/HMEF) for use in hospital, sub-acute, and pre-hospital settings. Devices placed at patient end or ventilator/anesthesia machine ports. Filtration via electrostatic charge in polypropylene media; passive humidification via treated paper/foam media capturing exhaled heat/moisture for return during inhalation. Protects patients and equipment from cross-contamination; conditions breathing gases for intubated/tracheostomized patients. Healthcare providers select based on tidal volume requirements (50-1500 ml). Single-patient use; replaced every 24 hours.
Clinical Evidence
Bench testing only. Performance validated via ISO 9360-1 (gas leakage, moisture loss), ISO 10993 (biocompatibility), ISO 18562 (VOC/particulate matter), ASTM F2101 (filtration efficiency), and EN ISO 23328 (pressure drop). All tests met acceptance criteria.
Indicated for mechanically ventilated patients requiring breathing system filtration and/or heat and moisture exchange. Applicable to patients with tidal volumes ranging from 50 ml to 1500 ml, depending on specific model. Contraindicated for use beyond 24 hours.
Regulatory Classification
Identification
A breathing circuit bacterial filter is a device that is intended to remove microbiological and particulate matter from the gases in the breathing circuit.
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September 26, 2021
Pharma System AB % Scott Blood Director of Regulatory Affairs MEDIcept Inc. 200 Homer Ave Ashland, Massachusetts 01721
Re: K202459
Trade/Device Name: Bact-Trap Filter, Bact-Trap Mini, Bact-Trap Midi, Pharma Mini HME/Filter, Bact-HME HME/Filter and Bact-HME Midi HME/Filter Regulation Number: 21 CFR 868.5260 Regulation Name: Breathing Circuit Bacterial Filter Regulatory Class: Class II Product Code: CAH Dated: August 19, 2021 Received: August 23, 2021
Dear Scott Blood:
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-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 mediation-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.
For Clarence W. Murray, III, PhD Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control 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) K202459
## Device Name
Bact-Trap™ Filter, Bact-Trap™ Mini Filter, Bact-Trap™ Midi Filter, Pharma Mini™ HME/Filter , Bact-HME™ HME/Filter and Bact-HME™ Midi HME/Filter
## Indications for Use (Describe)
Bact Trap filter is a breathing system filter which is designed to reduce possible airborne or liquid-borne cross contamination with micro-organisms and particulate matter via anaesthetic or ventilator breathing systems. The Bact Trap filter may either be used on the patient side of the ventilator anaesthetic device.
The Bact HME/Bact-HME Midi/Pharma Mini is a breathing system filter and a Heat and Moisture Exchanger. The combination of a filter and a Heat and Moisture offer the benefit of both product features. Heat and Moisture Exchangers are used as a conditioning system for mechanically ventilated patients whose uppassed. In almost all cases of mechanical ventilation they are a fully valid alternative to heated humidifiers. The Bact-HME Midi/Pharma Mini should be used with patients who have a Tidal Volume between 50 - 1500 ml.
The Pharma Mini™HME/Filter, Bact-HME™ filter/HME and Bact-HME™ Midi HME/Filter should be used with patients who have a Tidal Volume as follows:
- Pharma Mini™ and Bact-Trap™ Mini 50-900ml
- · Bact-HME™ Midi and Bact-Trap™ Midi between 100-1200 ml
- · Bact-HMETM and Bact-Trap™ between 250-1500 ml
The products mentioned above are designed as disposable single patient use and should be changed at least every 24 hours
| Type of Use (Select one or both, as applicable) |
|-----------------------------------------------------------------------------------------------------------|
| <div> <span> <b> × </b> </span> <span>Prescription Use (Part 21 CFR 801 Subpart D)</span> </div> |
| <div> <span>□ Over-The-Counter Use (21 CFR 801 Subpart C)</span> </div> |
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Image /page/3/Picture/0 description: The image shows the logo for MEDICEPT. The word "MEDI" is in bold, dark blue letters, while "CEPT" is in a purple, cursive font. Below the logo is the text "Trusted Solutions, Rapid Response," with "Trusted Solutions" in purple and "Rapid Response" in gray.
### 1. 510(K) SUMMARY
In accordance with 21 CFR 807.87(h) and 21 CFR 807.92, the content of this 510(k) summary is provided for the Pharma Systems Bact-Trap™ Filter, Bact-Trap™Mini Filter, Bact-Trap™ Midi Filter, Pharma Mini™ HME/Filter, Bact-HME™ HME/Filter, and Bact-HME™ Midi HME/Filter.
#### 1.1. Submitter's Information
Pharma Systems AB Name: Address: Rubanksgatan 9, 741 71 Knivsta, SWEDEN
+46 18 349500 Phone: +46 18 349530 Fax: Contact: MEDIcept Inc. 200 Homer Ave Ashland, MA 01721 Scott Blood sblood@medicept.com 978.729.5978
Date Prepared: August 18, 2021
#### 1.2. Device Name
Device Name: Bact-Trap™ Filter Bact-Trap™ Mini Filter Bact-Trap™ Midi Filter Pharma Mini™ HME/Filter Bact-HME™ HME/Filter Bact-HME™ Midi HME/Filter Common Name: Breathing Circuit Bacterial Filter Classification Name: Breathing Circuit Bacterial Filter Regulatory Class: Class II per 21 CFR §868.5260 Product Code: CAH - Breathing Circuit bacterial filter and HME
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Image /page/4/Picture/0 description: The image shows the logo for MEDICEPT. The word "MEDI" is in large, bold, blue letters, and the word "CEPT" is in large, bold, purple letters. Below the logo is the phrase "Trusted Solutions, Rapid Response" in a smaller font, with "Trusted Solutions" in gray and "Rapid Response" in purple.
### Legally Marketed Predicate Device 1.3.
The following are the identified Predicate Devices:
- Pharma Systems K903056 Bact Trap filters .
- Intended Use: o
- Isolation of patients from bacterial and viral contamination, prevention of cross contamination
- Protection of ventilators, resuscitators, measuring devices, etc. from contamination.
- Pharma Systems K903058 Bact HME ●
- Intended Use: O
- Protection of patients from excessive heat and moisture loss.
- Isolation of patients from bacterial and viral contamination, prevention of cross contamination (HMEF)
The following is the identified Reference Device:
- ARC Medical, Inc K090738- FilterFloFilter, ThermoFlo Filter/HME ●
- o Intended Use: FilterFloTM filter is a breathing system filter which is designed to reduce possible airborne or liquid-borne cross contamination with micro-organisms and particulate matter via anesthetic or ventilator breathing systems.
The FilterFloTM filter may either be used on the patient side or on the device side of the ventilator anesthetic device and is used as a hygienic measure alternatively to decontamination of breathing system and / or breathing gas conveying parts of the ventilator.
The TherrmoFlo™ filter/HME is a breathing system filter and a Heat and Moisture Exchanger. The combination of a filter and a Heat and Moisture Exchanger offer the benefit of both product features. Heat and Moisture Exchangers are used as a conditioning system for mechanically ventilated patients whose upper airways are bypassed. In almost all cases of mechanical ventilation they are a fully valid alternative to heated humidifiers. The product is the only conditioning opportunity of breathing gases in cases of emergency ventilation or during transport since heated humidified are almost impossible to use. The TherrnoFlo™ filter/HME should be used with patients who have a Tidal Volume between 250 - 1500 ml.
The products mentioned above are designed as disposable single patient use and should be changed at least every 24 hours.
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Image /page/5/Picture/0 description: The image shows the logo for MEDICEPT. The word "MEDI" is in large, bold, blue letters, and the word "CEPT" is in a stylized purple font. Below the logo is the text "Trusted Solutions, Rapid Response" in a smaller, gray font.
The predicates referenced above have not been subject to a design-related recall.
### Device Description 1.4.
The device is a standard breathing circuit bacterial filter used for respiratory management. A breathing circuit bacterial filter is a device that is intended to remove microbiological and particulate matter from the gases in the breathing circuit. The function of any breathing circuit is to deliver oxygen and anesthetic gases, and eliminate carbon dioxide. These devices can be placed at the following locations on a breathing circuit:
- At the inhalation port of the CO2 absorber of the anesthesia gas machine ●
- At the exhalation port of the CO2 absorber of the anesthesia gas machine
- At the patient end - at the mask or ET tube
- These placements are also common on critical ventilator circuits
The Bact-Trap™ filter is a breathing filter which can be used on the patient's side or on the device side of the ventilator/anesthetic device. It is used as a hygienic measure to decontaminate the breathing circuit.
The Pharma Mini™ HME/Filter , Bact-HME™ HME/Filter and Bact-HME™ Midi HME/Filter is a breathing system filter and a Heat and Moisture Exchanger (HME).
Heat and Moisture Exchangers and HME Filters (HMEF) are designed for patients with a compromised upper airway. HME and HMEFs are used with intubated or tracheostomized patients to collect moisture and heat from the expired gases and return the inhalation cycle. HME and HMEF contain either plastic fibers or open cell polyurethane foam which offer sufficient surface area to mimic or replace the patient's upper airways while intubated. HMEFs have an additional bacterial/viral filter to help prevent the transmission of bacteria and viruses. Bacterial/Viral filter media consists of electrostatically charged fibers and water repellent cover web on both sides. They also work to prevent cross infection to and from the patient during mechanical ventilation of lungs.
The proposed devices listed below are single patient use and should be changed every 24 hours in the environment of use. The patient population applicable to these devices are specified by the tidal volumes for the filter/Heat and Moisture Exchanger.
The Pharma Mini™HME/Filter, Bact-HME™ filter/HME and Bact-HME™ Midi HME/Filter should be used with patients who have a Tidal Volume as follows:
- Pharma Mini™ and Bact-Trap™ Mini 50-900ml
- · Bact-HME™ Midi and Bact-Trap™ Midi between 100-1200 ml
- · Bact-HMETM and Bact-Trap™ between 250-1500 ml
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Image /page/6/Picture/0 description: The image is a logo for MEDICEPT. The word "MEDI" is in large, bold, blue letters, and the word "CEPT" is in a stylized, purple font. Below the words is the phrase "Trusted Solutions, Rapid Response" in a smaller, gray font. The logo is simple and professional, and the colors are eye-catching.
The Pharma Mini, Bact-HME Midi and Bact-HME HME Filters and Bact-Trap Mini, Bact-Trap Midi and Bact-Trap filters are offered in several housing configurations, all of which are typical of filters. These configurations include:
- All have standard conical 15 mm / 22 mm fittings for connections ●
- Some models have a port version Female luer lock port for gas sampling for end-tidal . CO2
- Some models have a straight version .
- Some models have an angled version eliminates the need for a mask elbow .
- Straight version packaged with a standard mask elbow for convenience of the user ●
#### 1.4.1. Environment of Use
Hospital, sub-acute institutions, and pre-hospital
#### Principles of Operation 1.4.2.
There are two principles of operation with the subject devices:
- . Filtration is via the principle of electrostatic charges that attract and capture the microbes in the polypropylene media.
- Passive humidification is the use of a "treated" media (paper or foam) which absorbs the patient's exhaled heat and moisture and upon inhales the retained heat and humidity is released to the dry inhalation gases.
#### 1.4.3. Materials of Use
The proposed devices contain the following biocompatible materials:
- The Bacterial/viral filters Bact-Trap, Bact-Trap Midi, Bact-Trap Mini, Bact-Trap Gas Return 7010, 7011, 7015, 7050, 7054, 7055, 7061, 7110, 7120 are composed of the following biocompatible materials:
- . SBC
- . Polypropylene
- Acrylic and Polypropylene fibers .
- . Polyethylene
- The Heat- and Moisture Exchange Filters Bact-HME, Bact-HME Midi, Pharma Mini 6000, 6020, 6100, 6120, 6121, 6130. 6310, 6320 are composed of the following biocompatible materials:
- . SBC
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Image /page/7/Picture/0 description: The image shows the logo for MEDICEPT. The first part of the logo, "MEDI", is in large, bold, dark blue letters. The second part of the logo, "CEPT", is in a cursive, purple font. Below the logo is the text "Trusted Solutions, Rapid Response" in a smaller, gray font.
- . Polypropylene
- Acrylic and Polypropylene fibers .
- . Polyethylene
- Cross linkable acrylic polymer .
- . Silicone antifoam emulsion
- . Polyethylene
- Thermally bound Polyester(Polyethylene Terephthalate) .
# Duration and Type of Contact:
The proposed devices are intended for limited or less than 24 hours of use. When in use, the devices come in indirect contact with the human body (i.e Mucosal membrane of mouth and nose).
### 1.5. Indications for Use
Bact Trap filter is a breathing system filter which is designed to reduce possible airborne or liquid-borne cross contamination with micro-organisms and particulate matter via anaesthetic or ventilator breathing systems. The Bact Trap filter may either be used on the patient side or on the device side of the ventilator anaesthetic device.
The Bact HME/Bact-HME Midi/Pharma Mini is a breathing system filter and a Heat and Moisture Exchanger. The combination of a filter and a Heat and Moisture Exchanger offer the benefit of both product features. Heat and Moisture Exchangers are used as a conditioning system for mechanically ventilated patients whose upper airways are bypassed. In almost all cases of mechanical ventilation they are a fully valid alternative to heated humidifiers. The Bact HME/Bact-HME Midi/Pharma Mini should be used with patients who have a Tidal Volume between 50 - 1500 ml.
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Image /page/8/Picture/0 description: The image shows the logo for MEDICEPT. The word "MEDI" is in bold, dark blue letters, while "CEPT" is in a lighter purple color. Below the logo is the text "Trusted Solutions, Rapid Response", with "Trusted Solutions" in purple and "Rapid Response" in gray.
# Technological Characteristics Comparison with the Predicate 1.6. Devices
| Device<br>Feature | Proposed Device: Bact-<br>Trap, Pharma Mini,<br>Bact-HME, Backt-<br>HME Filter and<br>HME/Filter<br>K202459 | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903056 - Bact<br>Trap filters | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903058 -<br>Bact HME | Reference Predicate:<br>ARC Medical<br>K090738-<br>ThermoFlo™ |
|------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications<br>for Use | Bact Trap filter is a<br>breathing system filter<br>which is designed to<br>reduce possible airborne<br>or liquid-borne cross<br>contamination with<br>micro-organisms and<br>particulate matter via<br>anaesthetic<br>or ventilator breathing<br>systems.<br>The Bact Trap filter may<br>either be used on the<br>patient side or on the<br>device side of the<br>ventilator anaesthetic<br>device.<br>The Bact HME/Bact-<br>HME Midi/Pharma Mini<br>is a breathing system<br>filter and a Heat and<br>Moisture Exchanger.<br>The combination of a<br>filter and a Heat and<br>Moisture Exchanger<br>offer the benefit of both<br>product features. Heat<br>and Moisture<br>Exchangers are used as a<br>conditioning system for<br>mechanically ventilated<br>patients whose upper<br>airways are bypassed. In<br>almost all cases of<br>mechanical ventilation<br>they are a fully valid<br>alternative to heated | Isolation of<br>patients from<br>bacterial and<br>viral<br>contamination,<br>prevention of<br>cross<br>contamination.<br>Protection of<br>ventilators,<br>resuscitators,<br>measuring<br>devices, from<br>contamination. | Protection of<br>patients from<br>excessive heat<br>and moisture<br>loss.<br>Isolation of<br>patients from<br>bacterial and<br>viral<br>contamination<br>prevention of<br>cross-<br>contamination<br>(HMEF) | FilterFlo™ filter is a<br>breathing system filter<br>which is designed to<br>reduce possible<br>airborne or liquid-<br>borne cross<br>contamination with<br>micro-organisms and<br>particulate matter via<br>anaesthetic or<br>ventilator breathing<br>systems.<br>The FilterFlo™ filter<br>may either be used on<br>the patient side or on<br>the device side of the<br>ventilator/<br>anaesthetic device and<br>is used as a hygienic<br>measure alternatively<br>to decontamination of<br>breathing system and /<br>or breathing gas<br>conveying parts of the<br>ventilator.<br>The ThermoFlo™<br>filter/HME is a<br>breathing system filter<br>and a Heat and<br>Moisture Exchanger.<br>The combination of a<br>filter and a Heat and<br>Moisture Exchanger<br>offer the benefit of<br>both product features.<br>Heat and Moisture<br>Exchangers are used<br>as a conditioning<br>system for<br>mechanically |
| Device<br>Feature | Proposed Device: Bact-<br>Trap, Pharma Mini,<br>Bact-HME, Backt-<br>HME Filter and<br>HME/Filter | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903056 - Bact<br>Trap filters | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903058 –<br>Bact HME | Reference Predicate:<br>ARC Medical<br>K090738-<br>ThermoFlo™ |
| | humidifiers. The Bact<br>HME/Bact-HME Midi/<br>Pharma Mini should be<br>used with patients who<br>have a Tidal Volume<br>between 50 - 1500 ml. | | | ventilated patients<br>whose upper airways<br>are bypassed. In<br>almost all cases of<br>mechanical ventilation<br>they are a fully valid<br>alternative to heated<br>humidifiers. The<br>product is the only<br>conditioning<br>opportunity of<br>breathing gases in<br>cases of emergency<br>ventilation or during<br>transport since heated<br>humidified are almost<br>impossible to use. The<br>ThermoFlo™<br>filter/HME should be<br>used with patients who<br>have a Tidal Volume<br>between 250 - 1500<br>ml. |
| Classification | II | Same | Same | Same |
| Target<br>Population | Adult Tidal Volume<br>50-1500 ml | Same | Same | Tidal Volume 250-<br>1500ml |
| Clinical<br>Setting | Hospital, sub-acute,<br>pre-hospital and<br>home | Same | Same | Same |
| Principle of<br>Operation | Filtration via the<br>principle of<br>electrostatic charges<br>in the media.<br>Passive | Same | Same | Same |
| Device<br>Feature | Proposed Device: Bact-<br>Trap, Pharma Mini,<br>Bact-HME, Backt-<br>HME Filter and<br>HME/Filter | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903056 - Bact<br>Trap filters | Primary<br>Predicate:<br>Pharma<br>Systems<br>K903058 -<br>Bact HME | Reference Predicate:<br>ARC Medical<br>K090738-<br>ThermoFlo™ |
| | functioning as heat<br>and moisture<br>exchangers. | | | |
| Compatibility<br>with<br>Environment<br>of Use | Intended for use<br>with ventilators,<br>anesthesia gas<br>machines | Same | Same | Same |
| Prescriptive | Yes | Yes | Yes | Yes |
| Sterile/Non-<br>Sterile | Non-Sterile | Non-Sterile | Non-Sterile | Non-Sterile |
| Single Patient<br>Use | Yes | Yes | Yes | Yes |
| Maximum<br>Use | 24 hours | Same | Same | Same |
| Shelf-Life | 3 years | Same | Same | Unknown |
| Filtration<br>Efficiency | BFE: >99.999%<br>VFE: >99.99% | Same | Same | Unknown |
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Image /page/9/Picture/0 description: The image shows the logo for MEDICEPT. The first part of the logo, "MEDI" is in large, bold, blue letters. The second part of the logo, "CEPT" is in a stylized purple font. Underneath the logo is the text "Trusted Solutions, Rapid Response" in a smaller font.
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Image /page/10/Picture/0 description: The image shows the logo for MEDICEPT. The first part of the name, "MEDI", is in bold, dark blue letters. The second part of the name, "CEPT", is in a cursive, purple font. Below the name is the phrase "Trusted Solutions, Rapid Response" in a smaller font.
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Image /page/11/Picture/0 description: The image shows the logo for MEDI-CEPT. The word "MEDI" is in large, bold, blue letters, while "CEPT" is in a stylized purple font. Below the company name is the tagline "Trusted Solutions, Rapid Response" in a smaller font, with "Trusted Solutions" in purple and "Rapid Response" in gray.
### 1.7. Summary of Non-Clinical Testing
| Test Method | Test Performed | Summary | Results<br>(pass/fail) |
|--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|------------------------|
| ISO 9360-1 | Gas Leakage and compliance test<br>Moisture loss test | No leak @ 1 psi for 2 min<br>Equivalent to Predicate device | Pass |
| ISO 10993 | Cytotoxicity test<br>Sensitization test<br>Irritation test | Non-cytotoxic<br>Non-sensitizer<br>Non-irritant | Pass |
| ISO 18562-2 and<br>-3 | VOC and Particulate Matter<br>Testing | All test method acceptance<br>criteria were met. | Pass |
| ISO 18562-4 | Leachables evaluation in polar and<br>nonpolar solvents | All test method acceptance<br>criteria were met. | Pass |
| ISO 10993-17<br>and ISO 10993-<br>18 | Toxicological Risk Assessment | All test method acceptance<br>criteria were met. | Pass |
| ASTM 1980-16 | Accelerated Aging | Device meets its performance<br>specification post-<br>conditioning | Pass |
| ASTM F2101 | Viral Filtration Efficiency<br>Bacterial Filtration Efficiency | Filtration efficiency is<br>equivalent to Predicate device<br>Filtration efficiency is<br>equivalent to Predicate device | Pass |
| EN ISO 23328-2<br>EN ISO 23323-2 | Pressure Drop | Device meets its performance<br>specification | Pass |
| N/A | Housing Burst Strength | The measured values are<br>sufficient for ensuring safe<br>use of the measured devices. | Pass |
| ISO 23328-1 | Filtration Performance of<br>Technostat Plus filter media for<br>Bact-Trap bacterial/viral filters and<br>HME filters shelf life confirmation | The measured values are<br>sufficient for ensuring safe<br>use of the measured devices. | Pass |
| ISO 9360-1 | Bact-Trap bacterial/viral filters and<br>HME filters shelf life confirmation | The measured values are<br>sufficient for ensuring safe<br>use of the measured devices. | Pass |
#### 1.8. Conclusion
The conclusions drawn from the nonclinical tests demonstrate that the device (Bact-Trap, Pharma Mini, Bact-HME, Bact-HME Filter and HME/Filter) is as safe, as effective, and performs as well as or better than the legally marketed device
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.