K213028 · Bryan Medical, Inc. · BTR · Oct 21, 2021 · Anesthesiology
Device Facts
Record ID
K213028
Device Name
Tenax Laser Resistant Endotracheal Tube
Applicant
Bryan Medical, Inc.
Product Code
BTR · Anesthesiology
Decision Date
Oct 21, 2021
Decision
SESE
Submission Type
Special
Regulation
21 CFR 868.5730
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Tenax® Laser Resistant Endotracheal Tube is intended for endotracheal intubation. It is indicated for use for all types of surgical procedures involving carbon dioxide (10.60 microns), KTP (532 nm) or Blue Laser (445mm) laser use (normal pulsed or continuous beam delivery in the non-contact mode), when endotracheal intubation is required to administer anesthetic gases or to overcome emergency obstruction of an airway.
Device Story
Tenax® Laser Resistant Endotracheal Tube is a single-use, sterile, endotracheal tube with two inflatable cuffs; designed for use during surgical procedures involving CO2, KTP, or 445nm Blue lasers. Device features an inner aluminum scattering layer for laser resistance and an atraumatic outer layer to protect patient tissue; includes an internal dye as a warning indicator for puncture or damage. Used by clinicians in the trachea/upper GI tract to administer anesthetic gases or manage airway obstruction. Device is discarded after use. Benefits include protection against laser-induced airway fires or damage during laser surgery.
Clinical Evidence
Bench testing only. Performance data provided for laser resistance verification and validation to support safety and equivalence to the predicate device.
Technological Characteristics
Laser-resistant endotracheal tube; features inner aluminum scattering layer, atraumatic outer layer, and two inflatable cuffs. Includes internal dye indicator for puncture detection. Sterile (ethylene oxide), single-use. No software or electronic components.
Indications for Use
Indicated for adults (≥22 years) requiring endotracheal intubation during laser surgery (CO2, KTP, or 445nm Blue laser) in the upper gastro-respiratory tract. Contraindicated in patients with narrow airways or conditions precluding intubation.
Regulatory Classification
Identification
A tracheal tube is a device inserted into a patient's trachea via the nose or mouth and used to maintain an open airway.
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October 21, 2021
Bryan Medical, Inc. % Martha Russell Director of Regulatory Affairs AlvaMed. Inc. 1116 Great Plain Avenue, Suite 1 Needham, Massachusetts 02492
Re: K213028
Trade/Device Name: Tenax Laser Resistant Endotracheal Tube Regulation Number: 21 CFR 868.5730 Regulation Name: Tracheal tube Regulatory Class: Class II Product Code: BTR, BSK Dated: September 17, 2021 Received: September 21, 2021
Dear Martha Russell:
We have reviewed vour Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976. the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies.combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal
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statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801): medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531 -542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about 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,
Todd Courtney Assistant Director DHT1C: Division of Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
## K213028
Device Name Tenax ® Laser Resistant Endotracheal Tube
#### Indications for Use (Describe)
The Tenax® Laser Resistant Endotracheal Tube is intended for endotracheal intubation. It is indicated for use for all types of surgical procedures involving carbon dioxide (10.60 microns), KTP (532 nm) or Blue Laser (445mm) laser use (normal pulsed or continuous beam delivery in the non-contact mode), when endotracheal intubation is required to administer anesthetic gases or to overcome emergency obstruction of an airway.
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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Image /page/3/Picture/2 description: The image shows the logo for Bryan Medical, Inc. The logo consists of two blue, angled rectangles on the left side, followed by the word "bryan" in black, sans-serif font. Below "bryan" is the text "MEDICAL, INC." in a smaller, sans-serif font, also in black.
Special 510(k): Modification to Tenax® Laser Resistant Endotracheal Tube
Page 1
### 1.0 SPECIAL 510(K) SUMMARY FOR TENAX® LASER RESISTANT ENDOTRACHEAL TUBE
This Special 510(k) for the Tenax® Laser Resistant Endotracheal Tube is submitted based on the FDA Guidance document "The Special 510(k) Program: Guidance for Industry and Food and Drug Administration Staff' issued September 13, 2019. This Special 510(k) addresses labeling revisions to the Tenax® Instructions for Use to add the use of a 445 nm Blue Laser, and that the device is not made with natural rubber latex. In addition, the Indications for Use statement was modified to add the 445nm Blue Laser.
## 1.1. Submitter
Bryan Medical, Inc. 5725 Dragon Way, Suite 300 Cincinnati, OH 45227
Phone: (617) 517-4932
Fax: (617) 249-0955
Contact Person: Martha Kamrow-Russell, AlvaMed, Inc.
Date Prepared: September 17, 2021
#### 1.2. Device
Name of Device: Tenax® Laser Resistant Endotracheal Tube
Common or Usual Name: Endotracheal tube
Classification Name: Tracheal tube (21 CFR 868.5730)
Regulatory Class: II
Product Code: BTR, BSK
### 1.3. Predicate Device
Tenax® Laser Resistant Endotracheal Tube, K200761
### 1.4. Device Description
The Tenax® Laser Resistant Endotracheal Tube is an endotracheal tube with two inflatable cuffs. It is indicated for use in surgical procedures where intubation is required in the presence of KTP, 445nm Blue Laser, or CO2 lasers.
The device is provided sterile (EO). After use, the device is discarded and disposed of in accordance with local regulations. There are no associated device accessories.
### 1.5. Indication For Use
The Tenax® Laser Resistant Endotracheal Tube is intended for endotracheal intubation. It is indicated for use for all types of surgical procedures involving carbon dioxide (10.60 microns), KTP (532 nm), or Blue (445 nm) laser use (normal pulsed or continuous beam delivery in the non-contact mode), when endotracheal intubation is required to administer anesthetic gases or to overcome emergency obstruction of an airway.
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| Image: bryan MEDICAL, INC. logo | Special 510(k): Modification to<br>Tenax® Laser Resistant Endotracheal<br>Tube | Page 2 |
|---------------------------------|--------------------------------------------------------------------------------|--------|
|---------------------------------|--------------------------------------------------------------------------------|--------|
| Intended Population: | Adults (≥22 years old) requiring endotracheal intubation during<br>laser surgery procedures in the upper gastro-respiratory tract. |
|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Environment of Use: | Trachea/Upper GI Tract |
| Contraindications: | The Tenax® Laser Resistant Endotracheal Tube should not be<br>used in patients with narrow airways, which could restrict<br>ventilation, resulting in excessive elevation of intratracheal<br>pressure. Do not use in any patient suffering from conditions that<br>may preclude endotracheal intubation. Do not use this device for<br>any purpose other than its intended use. |
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Image /page/5/Picture/2 description: The image shows the logo for Bryan Medical, Inc. The logo features a blue, stylized "B" shape on the left, followed by the word "bryan" in black, sans-serif font. Below "bryan" is the text "MEDICAL, INC." in a smaller, sans-serif font, also in black. The overall design is clean and professional.
# 1.6. Comparison of Technological Characteristics with the Predicate Device
| | Subject Device:<br>Tenax® Laser Resistant Endotracheal<br>Tube | Predicate Device:<br>Tenax® Laser Resistant Endotracheal<br>Tube |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Bryan Medical, Inc. | Bryan Medical, Inc. |
| 510(k)<br>Number | To be assigned. | K200761 |
| Product Code | BTR, BSK | BTR, BSK |
| Requlation<br>Number | 868.5730 | 868.5730 |
| Regulation<br>Description | Tracheal tube | Tracheal tube |
| Common<br>Name | Endotracheal tube | Endotracheal tube |
| Indications<br>for Use | The Tenax® Laser Resistant<br>Endotracheal Tube is intended for<br>endotracheal intubation. It is indicated for<br>use for all types of surgical procedures<br>involving carbon dioxide (10.60 microns),<br>Blue (445 nm), or KTP (532 nm) laser<br>use (normal pulsed or continuous beam<br>delivery in the non-contact mode), when<br>endotracheal intubation is required to<br>administer anesthetic gases or to<br>overcome emergency obstruction of an<br>airway. | The Tenax® Laser Resistant<br>Endotracheal Tube is intended for<br>endotracheal intubation. It is indicated for<br>use for all types of surgical procedures<br>involving carbon dioxide (10.60 microns)<br>or KTP (532 nm) laser use (normal<br>pulsed or continuous beam delivery in<br>the non-contact mode), when<br>endotracheal intubation is required to<br>administer anesthetic gases or to<br>overcome emergency obstruction of an<br>airway. |
| Sterility | Sterile (ethylene oxide) | Sterile (ethylene oxide) |
| Single Use | Yes | Yes |
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Image /page/6/Picture/2 description: The image shows the logo for Bryan Medical, Inc. The logo consists of two blue rectangles stacked on top of each other on the left side. To the right of the rectangles is the word "bryan" in black, with the words "MEDICAL, INC." in smaller black letters underneath.
Special 510(k): Modification to Tenax® Laser Resistant Endotracheal Tube
Both devices are laser resistant endotracheal tubes. They share an identical indication for use (outside of the addition of the Blue 445 nm laser for the subject device) and are intended for use in the same manner. The subject and predicate devices also share the following technological characteristics:
- Laser resistance using an inner aluminum scattering layer, ●
- Atraumatic outer layer for protection of patient tissue, ●
- Inflatable cuffs,
- Use of internal dye as a warning indicator to alert practitioners of device puncture or ● damage.
#### 1.7. Performance Data
The following performance data were provided in support of the substantial equivalence determination:
- Laser resistance
#### 1.8. Conclusion
The non-clinical data support the safety of the device and the verification and validation testing demonstrate that the Tenax® Laser Resistant Endotracheal Tube shall perform as intended in the specified use conditions. The data demonstrate that the Tenax® Laser Resistant Endotracheal Tube performs comparably to the predicate device currently marketed for the same intended use.
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.