The SANSIN Tubing Sets for Hemodialysis are single-use sterile medical devices intended to connect the patient to the hemodialyzer and the hemodialysis delivery system in hemodialysis treatment. The compatibility of available configurations is the responsibility of the physician/clinician in charge.
Device Story
SANSIN Tubing Sets are single-use, sterile extracorporeal blood circuits for hemodialysis. The device consists of arterial and venous lines, air capture chambers, branch tubings, female luer locks, clamps, and filters. Accessories include priming pieces, drain bags, priming needles, fluid replacement tubes, and transducer protectors. The device connects the patient to a hemodialyzer and a hemodialysis delivery system (specifically Fresenius 2008K Home Hemodialysis System). Used in clinical facilities by physicians/clinicians. The tubing facilitates blood flow between the patient and the dialyzer. The device is provided sterile (EO sterilization).
Clinical Evidence
No clinical data. Bench testing only, including biocompatibility (ISO 10993 series), sterilization validation (ISO 11135), mechanical performance (tensile strength, repeated closing, endurance pump), and stimulated operation testing to verify compatibility with the hemodialysis delivery system.
Technological Characteristics
Materials conform to ISO 10993 biocompatibility standards. Components include arterial/venous lines, air capture chambers, and luer lock fittings (ISO 594-2). Sterilization via Ethylene Oxide (SAL 10^-6). Complies with ISO 8638 for extracorporeal blood circuits. Mechanical testing per ASTM F88/F88M, F756, and F1929.
Indications for Use
Indicated for patients requiring hemodialysis treatment; intended to connect the patient to a hemodialyzer and hemodialysis delivery system.
Regulatory Classification
Identification
A hemodialysis system and accessories is a device that is used as an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and that consists of an extracorporeal blood system, a conventional dialyzer, a dialysate delivery system, and accessories. Blood from a patient flows through the tubing of the extracorporeal blood system and accessories to the blood compartment of the dialyzer, then returns through further tubing of the extracorporeal blood system to the patient. The dialyzer has two compartments that are separated by a semipermeable membrane. While the blood is in the blood compartment, undesirable substances in the blood pass through the semipermeable membrane into the dialysate in the dialysate compartment. The dialysate delivery system controls and monitors the dialysate circulating through the dialysate compartment of the dialyzer.(1) The extracorporeal blood system and accessories consists of tubing, pumps, pressure monitors, air foam or bubble detectors, and alarms to keep blood moving safely from the blood access device and accessories for hemodialysis (§ 876.5540) to the blood compartment of the dialyzer and back to the patient. (2) The conventional dialyzer allows a transfer of water and solutes between the blood and the dialysate through the semipermeable membrane. The semipermeable membrane of the conventional dialyzer has a sufficiently low permeability to water that an ultrafiltration controller is not required to prevent excessive loss of water from the patient's blood. This conventional dialyzer does not include hemodialyzers with the disposable inserts (Kiil type) (§ 876.5830) or dialyzers of high permeability (§ 876.5860). (3) The dialysate delivery system consists of mechanisms that monitor and control the temperature, conductivity, flow rate, and pressure of the dialysate and circulates dialysate through the dialysate compartment of the dialyzer. The dialysate delivery system includes the dialysate concentrate for hemodialysis (liquid or powder) and alarms to indicate abnormal dialysate conditions. This dialysate delivery system does not include the sorbent regenerated dialysate delivery system for hemodialysis (§ 876.5600), the dialysate delivery system of the peritoneal dialysis system and accessories (§ 876.5630), or the controlled dialysate delivery system of the high permeability hemodialysis system § 876.5860). (4) Remote accessories to the hemodialysis system include the unpowered dialysis chair without a scale, the powered dialysis chair without a scale, the dialyzer holder set, dialysis tie gun and ties, and hemodialysis start/stop tray.
Fresenius 2008K Home Hemodialysis System (K124035)
Submission Summary (Full Text)
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September 6, 2021
Jiangxi Sanxin Medtec Co., Ltd. % Diana Hong General Manager Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai, 200120 CHINA
Re: K202796
> Trade/Device Name: SANSIN Tubing Sets for Hemodialysis Regulation Number: 21 CFR 876.5820 Regulation Name: Hemodialysis System and Accessories Regulatory Class: II Product Code: FJK Dated: August 4, 2021 Received: August 10, 2021
Dear Diana Hong:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 (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 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,
Glenn B. Bell, Ph.D. 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) K202796
Device Name SANSIN Tubing Sets for Hemodialysis
#### Indications for Use (Describe)
The SANSIN Tubing Sets for Hemodialysis are single-use sterile medical devices intended to connect the patient to the hemodialyzer and the hemodialysis delivery system in hemodialysis treatment. The compatibility of available configurations is the responsibility of the physician/clinician in charge.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
| <span style="font-size:100%;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-size:100%;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(k) Summary
This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.
The assigned 510(k) Number: K202796
- 1. Date of Preparation: 08/04/2021
- 2. Sponsor Identification
#### Jiangxi Sanxin Medtec Co., Ltd.
No. 999, Fushan Road, Xiaolan Economic Development, Nanchang, Jiangxi, 330200, China
Establishment Registration Number: 3005246939
Contact Person: Shuiqing Sun Position: RA Engineer Tel: +86-791-85950238 Fax: +86-791-85988030 Email: 1304921073@qq.com
- 3. Designated Submission Correspondent
Ms. Diana Hong (Primary Contact Person) Ms. Christina Wu (Alternative Contact Person)
Mid-Link Consulting Co., Ltd P.O. Box 120-119, Shanghai, 200120, China
Tel: +86(0)21 2281-5850 Fax: +1(0)360 925-3199 Email: info@mid-link.net
- 4. Identification of Proposed Device
Trade Name: SANSIN Tubing Sets for Hemodialysis Common Name: Blood Tubing Sets Models: HDJ, HDK, HDL, HDM, HDN.
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Regulatory Information Classification Name: Set, Tubing, Blood, With and Without Anti-Regurgitation Valve Classification: II Product Code: FJK Regulation Number: 876.5820 Review Panel: Gastroenterology/Urology
Indications for Use:
The SANSIN Tubing Sets for Hemodialysis are single-use sterile medical devices intended to connect the patient to the hemodialyzer and the hemodialysis delivery system in hemodialysis treatment. The compatibility of available configurations is the responsibility of the physician/clinician in charge.
#### Device Description
The propose device, SANSIN Tubing Sets for Hemodialysis, is used to connect the patient to the hemodialyzer and the hemodialysis delivery system in hemodialysis treatment. The proposed devices are provided sterile and single use.
The proposed device is intended to be used with Fresenius 2008K Home Hemodialysis manufactured by Fresenius Medical Care North America, which is a hemodialysis delivery system being submitted to FDA for premarket notification (K124035).
The proposed device mainly consists of two tubes, which are arterial line with certain components in red and venous line with certain components in blue, as well as accessories such as priming piece, drain bag, priming needle, fluid replacement tube, connecting tube, monitor and transducer protector.
The proposed devices are available in various specifications. Based on the different volume of air capture chamber, there are five models HDJ, HDK, HDL, HDM and HDN. For the detail information of these five models, please see the below Table 1.
| Table 1 | | | | | |
|-------------------------------------------------------------|-----------|-----------|-----------|-----------|-----------|
| Item | HDJ | HDK | HDL | HDM | HDN |
| Volume of air capture chamber | Different | Different | Different | Different | Different |
| Diameter and Length of air capture chamber in arterial Line | Different | Different | Different | Different | Different |
| Diameter and Length of air capture chamber in venous Line | Different | Different | Different | Different | Different |
| Length of arterial Line (mm) | Different | Different | Different | Different | Different |
| Length of venous Line (mm) | Different | Different | Different | Different | Different |
Table 1
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| Diameter of arterial Line (mm) | Same | Same | Same | Same | Same |
|------------------------------------|-----------|-----------|-----------|-----------|-----------|
| Diameter of venous Line (mm) | Same | Same | Same | Same | Same |
| Priming Volume (mL) | Different | Different | Different | Different | Different |
| Positive pressure (mmHg) | Same | Same | Same | Same | Same |
| Negative Pressure (mmHg) | Same | Same | Same | Same | Same |
| Blood Flow limits (ml/min) | Same | Same | Same | Same | Same |
| Length of Fluid replacement tube | Same | Same | Same | Same | Same |
| Diameter of Fluid replacement tube | Same | Same | Same | Same | Same |
The proposed devices are provided in sterile condition, it is subject to EO sterilization prior to release to achieve a Sterility Assurance Level (SAL) of 106.
- 5. Identification of Predicate Device
510(k) Number: K161582 Product Name: DORA Tubing Sets for Hemodialysis Manufacturer: Bain Medical Equipment (Guangzhou) Co., Ltd
- 6. Substantially Equivalent (SE) Comparison
| Table 2 Comparison of Technology Characteristics | | | | |
|--------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------|
| ITEM | Proposed Device<br>SANSIN Tubing Sets for<br>Hemodialysis | Predicate Device<br>DORA Tubing Sets for<br>Hemodialysis<br>K161582<br>BAIN-BL-001E | Remark | |
| Device Class | II | II | Same | |
| Product Code | FJK | FJK | Same | |
| Regulation<br>Number | 21 CFR 876.5820 | 21 CFR 876.5820 | Same | |
| Indications for<br>Use | The SANSIN Tubing Sets for<br>Hemodialysis are single-use sterile<br>medical devices intended to<br>connect the patient to the<br>hemodialyzer and the hemodialysis<br>delivery system in hemodialysis<br>treatment. The compatibility of<br>available configurations is the<br>responsibility of the<br>physician/clinician in charge. | The DORA Tubing Sets for<br>Hemodialysis are single-use<br>sterile medical devices<br>intended to connect the patient<br>to the hemodialyzer and the<br>hemodialysis delivery system<br>in hemodialysis treatment. The<br>compatibility of available<br>configurations is the<br>responsibility of the<br>physician/clinician in charge. | Same | |
| Compatible<br>Hemodialysis<br>Delivery<br>System | The hemodialysis delivery system<br>which is compatible with the<br>product is Fresenius 2008K<br>Home Hemodialysis System<br>manufactured by Fresenius<br>Medical Care North America. | The hemodialysis delivery<br>system which is compatible<br>with the product is Fresenius<br>2008K manufactured by<br>Fresenius Medical Care North<br>America. | Difference 1 | |
| Feature | Pre-Pump<br>Post-Pump<br>Color Coded component<br>Sterile<br>Non-pyrogenic<br>Single Use<br>Prescription Device | Pre-Pump<br>Post-Pump<br>Color Coded component<br>Sterile<br>Non-pyrogenic<br>Single Use<br>Prescription Device | Same | |
| Main<br>Configuration | Arteria Line<br>Venous Line<br>Air capture chamber<br>Branch Tubings;<br>Female Luer Lock<br>Clamps<br>Filters | Arteria Line<br>Venous Line<br>Drip Chamber<br>Branch Lines;<br>Female Luer Lock<br>Clamps<br>Filters | Difference 2 | |
| Accessory | Drain Bag<br>Transducer Protector<br>Monitor<br>Tubing in the Arterial line<br>Priming connector in the Arterial<br>and Venous lines<br>Priming Piece, Priming Needle | Drain Bag<br>Transducer Protector<br>Pillow<br>Heparin Line<br>Recirculating Connector | Difference 3 | |
| | Fluid Replacement Tube,<br>Connecting Tube | | | |
| Sterilization | SAL (10-6) | SAL (10-6) | Same | |
| Labeling | Direction for Use | Direction for Use | Same | |
| | Indications for Use | Indications for Use | | |
| | Description | Description | | |
| | Warnings and Cautions | Warnings and Cautions | | |
| | Physical<br>Performance | Length of<br>arterial Line<br>(mm) | | HDJ:3500mm<br>HDK:3500mm<br>HDL:3600mm<br>HDM:3660mm<br>HDN:3500mm |
| Length of<br>venous Line<br>(mm) | | HDJ:3000mm<br>HDK:3000mm<br>HDL:2900mm<br>HDM:2400mm<br>HDN:3000mm | 3000 | |
| Priming<br>Volume<br>(mL) | | HDJ: $143\pm10%$<br>HDK: $147\pm10%$<br>HDL: $153\pm10%$<br>HDM: $162\pm10%$<br>HDN: $167\pm10%$ | $163\pm10%$ | |
| Positive<br>pressure<br>(mmHg) | | 500 | 500 | |
| Negative<br>Pressure<br>(mmHg) | | -300 | -500 | |
| Blood Flow<br>limits(ml/min) | | 500 | 500 | |
| | Inner<br>diameter of<br>the venous<br>and arterial<br>lines(mm) | 5.6 | 4.48 | Difference 6 |
| Materials | | Various materials | Various materials | Same |
| Biocompatibility | | | | |
| Cytotoxicity | | No cytotoxicity. | Conforms to ISO 10993 Series | Same |
### Table 2 Comparison of Technology Characteristics
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Page 4 of 10
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| | | sensitization. |
|--------------|-----------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------|
| | Intracutaneous Reactivity Test | No intracutaneous<br>reactivity. |
| | Acute Systemic Toxicity Test | No systemic<br>toxicity. |
| | Sub chronic Toxicity Study | No chronic<br>toxicity. |
| | Hemolysis Study | No hemolysis. |
| | Complement Activation | No complement<br>activation. |
| | Prothrombin Time | The test article<br>compared with<br>that of negative<br>control article is<br>not significant<br>statistically<br>different. |
| | Partial Thromboplastin Time<br>Study | The test article<br>compared with<br>that of negative<br>control article is<br>not significant<br>statistically<br>different. |
| Genotoxicity | Bacterial Reverse<br>Mutation | No genotoxicity. |
| | In Vitro Mammalian<br>Chromosome Aberration<br>Test | No genotoxicity. |
| | | |
| | Pyrogenicity | No potential<br>febrile reaction |
Difference 1 – Compatible Hemodialysis Delivery System
The proposed device and predicate device have the different Compatible Hemodialysis Delivery System. Considering 1) Fresenius 2008K Home Hemodialysis System and Fresenius 2008K are both manufactured by Fresenius Medical Care North America. There is no huge difference. 2) They are both used by the physician in a clinical facility. 3) Stimulated Operation Testing Report demonstrated that the proposed device had good compatibility performance in hemodialysis treatment conditions with
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Fresenius 2008K Home Hemodialysis System. Therefore, this difference will not raise new problem on the safety and effectiveness.
Difference 2 – Main Configuration
The air capture chamber and branch tubing of proposed device is same with the drip chamber and branch lines of predicate device. They are only difference in the name of components. Names of components will not affect the clinical using of the proposed device, this difference will not raise new problem on the safety and effectiveness.
Difference 3 - Accessory
The predicate device has the accessory of Heparin Line, while the proposed device doesn't have this accessory. However, the component (15 tubing) has been included in the Arterial line of the proposed device. The Heparin Line of predicate device and component (15 tubing) of proposed device are both the path for heparin injection. Therefore, this difference will not raise new problem on the safety and effectiveness.
Fig.1 Assembly Drawing of SANSIN Tubing Sets for Hemodialysis (Arterial line)
Image /page/9/Figure/7 description: The image shows a diagram of a medical device with several labeled parts. The top part of the device has labels 1 through 7, while the bottom part has label 24. The device appears to be a type of tubing or connector used in medical procedures. The diagram provides a visual representation of the device's components and their arrangement.
The proposed device and predicate device have the same main configuration. The predicate device has the accessory of recirculating connector, while the proposed device doesn't have this accessory. However, the component (Priming connector) has been included in the Arterial and Venous lines of the proposed device. The Recirculating Connector of predicate device and component (Priming connector) of proposed device are both for reducing the amount of normal saline for priming. Therefore, this difference will not raise new problem on the safety and effectiveness.
The proposed device has Priming Needle, Fluid Replacement Tube and Connecting Tube, while the predicate device doesn't have these accessories. The clinicians will choose these accessories based on the clinical conditions. Having these accessories will not affect the Indications for Use of the proposed device, therefore, this difference will not raise new problem on the safety and effectiveness.
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#### Difference 4- Physical performance (Length of arterial line & venous Line, Priming Volume)
The length of arterial and venous tubes of proposed device is different to that of the predicate device. The difference on the length of arterial and venous tubes leads to the difference on the priming volume. Differences in the tubing length and priming volume can impact the mechanical and performance characteristics of device. The bench tests such as stimulated operation test, pressure leak test, priming volume test, tubing compliance test, mechanical hemolysis test, Tensile Strength Test, Repeated Closing Test and Endurance Pump Test were conducted to approve that the proposed device meet the requirements of mechanical and performance characteristics. Therefore, the differences in length of arterial line & venous line, priming volume will not lead to new safety and effectiveness problems.
#### Difference 5- Physical performance (Negative Pressure)
The negative pressure limitation of the proposed device is smaller than that of the predicate device. The negative pressure has been tested in the Endurance Pump Test and Endurance Pump Test after Aging. The test result approved that the product can maintain the safety and effectiveness of the product under -300 pressure. The negative pressure will affect the blood flow. The stimulated operation test was conducted to approve that the proposed device meets the requirements of blood flow.
In additional, this negative pressure is included in the user will set the negative pressure based on the user manual and will therefore be limited to hemodialysis with a negative pressure up to -300 mmHg as opposed to -500 mmHg for the predicate. Therefore, the difference in negative pressure will not lead to new safety and effectiveness problems.
#### Difference 6- Physical performance (Inner diameter of the venous and arterial lines)
The inner diameter of the venous and arterial lines for the predicate device is 4.48 mm. The inner diameter of the venous and arterial lines for the proposed device is 5.6 mm. The inner diameter of the venous and arterial lines will affect the blood flow. The stimulated operation test was conducted to approve that the proposed device meets the requirements of blood flow. Therefore, the differences in the inner diameter of the venous and arterial lines will not lead to new safety and effectiveness problems.
#### 7. Non-Clinical Test Conclusion
Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. For full titles of the standards and guidances used, see below. The tests performed on the relevant device configurations include:
#### Repeated closing test
The repeated closing test was performed on proposed device. The test result demonstrated that the
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proposed device is able to meet the maximum closing time. This test is an internal test.
#### Tensile Strength Test
The tensile strength test was performed on proposed device. The test result demonstrated that any connections between the components of the transfusion set of the proposed device, excluding protective caps, shall withstand a static tensile force. This test is an internal test.
#### Endurance Pump Test
The endurance pump test was performed on proposed device. The test result demonstrated that the proposed device is able to meet the endurance requirements. This test is an internal test.
#### Stimulated Operation Test
The stimulated operation test was performed on proposed device. The test result demonstrated that the proposed device has good compatibility performance in hemodialysis treatment conditions with specific hemodialysis delivery system. This test is an internal test.
The test results demonstrated that the proposed device complies with the following standards and guidance. The following tests were conducted as applicable to the subject devices:
- > ISO 10993-3:2014 Biological evaluation of medical devices - Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity
- > ISO 10993-4:2017 Biological evaluation of medical devices-Part 4: Selection of tests for interactions with blood
- > ISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
- > ISO 10993-10:2010 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization
- > ISO 10993-11:2017 Biological evaluation of medical devices - Part 11: Tests for systemic toxicity
- > ISO 11135:2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices [Including: Amendment 1 (2018)]
- > ASTM F88/F88M-15: Standard Test Method for Seal Strength of Flexible Barrier Materials
- > ASTM F756-17: Standard Practice for Assessment of Hemolytic Properties of Materials
- > ASTM F1929-15: Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration
- > USP 42-NF 37:2019 <85> Bacterial Endotoxins Test
- > USP 42-NF 37:2019 <151> Pyrogen Test (USP Rabbit Test)
- > ISO 594-2:1998 Conical fittings with a 6 % (Luer) taper for syringes, needles and certain other medical equipment - Part 2 Lock fittings
- > ISO 8638:2010 Cadiovascular implants and extracorporeal blood circuit for hemodialyzers, hemodialfilters, and hemofilters
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- 8. Clinical Test Conclusion
No clinical study is included in this submission.
- 9. Substantially Equivalent (SE) Conclusion
Based on the comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate device.
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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.
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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?
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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.
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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.
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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.
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.