K213274 · Qlicksmart Pty , Ltd. · MMK · Jun 22, 2022 · General Hospital
Device Facts
Record ID
K213274
Device Name
Qlicksmart BladeFlask UNIVERSAL
Applicant
Qlicksmart Pty , Ltd.
Product Code
MMK · General Hospital
Decision Date
Jun 22, 2022
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 880.5570
Device Class
Class 2
Indications for Use
The Qlicksmart BladeFlask PLUS is a single-use sharps container with a scalpel blade removal function intended to permit the safe removal of scalpel blades from most currently available scalpel handles and contain the blade immediately upon removal to eliminate the need for further handling prior to be disposed as medical waste while allowing the user to monitor its use to see when it is becoming full and will need changing.
Device Story
Single-use sharps container with integrated scalpel blade removal mechanism; used in clinical settings to remove blades from handles via single-handed action; immediately contains blades to prevent injury. Device features mechanical counting and automatic shut-off system triggered after ~100 blades; prevents overfilling. Constructed of hard plastic (ABS) and hardened steel. Operated by clinicians; mounted via bracket or tape. Benefits include reduced risk of sharps injury by eliminating manual blade handling. Disposed as hazardous waste when full; not intended for reprocessing.
Clinical Evidence
No clinical data. Bench testing only. Performance verified via ISO 23907-1 (container stability, handle strength, penetration resistance, drop/leakage testing) and UN transport standards. Functional testing confirmed blade removal, counting accuracy (100±5 blades), and automatic shut-off mechanism performance.
Technological Characteristics
Hard plastic (ABS) sharps container; hardened steel blade removal mechanism. Dimensions: 13.5cm x 9.1cm x 12.3cm. Mechanical counting and automatic shut-off system. Single-use; non-sterile. Mounted via hardware bracket or adhesive. Complies with ISO 23907-1 and AS 4031-1992.
Indications for Use
Indicated for safe removal and containment of scalpel blades from compatible handles (Swann Morton, Lawton, Martin, Aesculap, Sayco, Smic, Nopa, AB Stainless, Lance, Pro-Med, Paragon, Rocket, Conqueror, Feather, LRI, Generic, L-dent, Medesy, Jakobi, CS, Helmut Zepf) in clinical settings. Contraindicated for Beaver-type and disposable handles.
Regulatory Classification
Identification
A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.
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June 22, 2022
Qlicksmart Pty Ltd. Carlos Castellanos Quality Assurance Manager Level 1, 148 Boundary Street, West End Brisbane. Oueensland 4101 Australia
#### Re: K213274
Trade/Device Name: Qlicksmart BladeFlask UNIVERSAL Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: MMK Dated: September 30, 2021 Received: September 30, 2021
#### Dear Carlos Castellanos:
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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, Ph.D. 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) K213274
Device Name Qlicksmart BladeFlask PLUS
#### Indications for Use (Describe)
The Qlicksmart BladeFlask PLUS is a single-use sharps container with a scalpel blade removal function intended to permit the safe removal of scalpel blades from most currently available scalpel handles and contain the blade immediately upon removal to eliminate the need for further handling prior to be disposed as medical waste while allowing the user to monitor its use to see when it is becoming full and will need changing. Scalpel handles compatible with the Qlicksmart BladeFlask PLUS include:
- □ Swann Morton sizes 3. 4. 5. 6. 7. 8. and 9
- □ Lawton size 4
- □ Martin sizes 3, 4, and 7
- □ Aesculap sizes 3. 4. 6. and 7
- □ Sayco sizes 3, 4, and 5
- □ Smic sizes 3 and 4
- □ Nopa sizes 3 and 4
- □ AB Stainless size 4
- □ Lance sizes 3 and 4
- □ Pro-Med sizes 3 and 4
- □ Paragon sizes 3 and 4
- □ Rocket size 5
- □ Conqueror size 3
- □ Feather sizes 3. 4. and 7
- □ LRI sizes 3 and 4
- □ Generic handle size 4
- □ L-dent
- □ Medesy size 5
- □ Jakobi size 4
- CS size 5
- □ Helmut Zepf
Scalpel handles known to be incompatible with the Qlicksmart BladeFlask PLUS include:
- □ Beaver type handles
- □ Disposable handles
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
|X Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/4/Picture/0 description: The image shows the logo for QlickSmart. The logo features a stylized letter Q in blue, with a red swoosh across the top. Below the Q, the word "QLICKSMART" is written in blue, with a registered trademark symbol next to it. Underneath "QLICKSMART", the tagline "... and be safe" is written in a smaller font.
K213274 page 1 of 9 www.qlicksmart.com +61 7 3844 1182 T +61 7 3844 1183 F
# K213274 510(k) SUMMARY
I. SUBMITTER
Qlicksmart Pty Ltd Level 1, 148 Boundary Street West End. OLD. 4101. Australia Phone: +61 7 3844 1182 Contact Person: Michael Sinnott Date Prepared: 17 June 2022
II. SUBJECT DEVICE
Trade Name of Device: Qlicksmart BladeFlask PLUS Common or Usual Name: Sharps Container with a scalpel blade removing function Classification Name: Hypodermic single lumen needle (21 CFR 880.5570) Regulatory Class: II Product Code: MMK
#### III. PREDICATE DEVICE
Predicate Device 510(k) application number: K983367 Original Name of the legally marketed predicate device was OLICKSMART®, Current trading name of the legally marketed predicate device: Qlicksmart BladeFLASK
#### IV. DEVICE DESCRIPTION
The Qlicksmart BladeFlask PLUS is a single-use sharps container with a scalpel blade removal function that is used under non-sterile conditions. The Qlicksmart BladeFlask PLUS removes scalpel blades from scalpel handles in a single-handed action and then immediately contains the used scalpel blade inside the Qlicksmart BladeFlask PLUS. The handle is intended to be used to dispose the entire container as hazardous waste when full (100 removed blades and shut-off system is activated) and the device is not intended to be reprocessed.
The Qlicksmart BladeFlask PLUS combines a hard plastic sharps container with an internal blade remover mechanism made of hard plastic and hardened steel parts.
It is approximately (13.5 cm) tall by (9.1 cm) wide by (12.3 cm) deep. It weighs less than 250gm per unit when empty. It is red in color. It is labelled as shown on the samples provided with this application.
#### V. INDICATIONS FOR USE
The Qlicksmart BladeFlask PLUS is a single-use sharps container with a scalpel blade removal function intended to permit the safe removal of scalpel blades from most currently available scalpel handles and contain the blade immediately upon removal to eliminate the need for further handling
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Image /page/5/Picture/0 description: The image shows the logo for QlickSmart. The logo features the word "QLICKSMART" in a bold, blue font. Above the text is a stylized graphic of a red swoosh over a blue arc. Below the text is the tagline "... and be safe" in a smaller, less bold font.
K213274 page 2 of 9 www.qlicksmart.com +61 7 3844 1182 T +61 7 3844 1183 F
prior to be disposed as medical waste while allowing the user to monitor its use to see when it is becoming full and will need changing. Scalpel handles compatible with the Qlicksmart BladeFlask PLUS include:
- Swann Morton sizes 3, 4, 5, 6, 7, 8, and 9
- Lawton size 4 ●
- Martin sizes 3, 4, and 7 ●
- Aesculap sizes 3, 4, 6, and 7
- Savco sizes 3. 4. and 5 ●
- . Smic sizes 3 and 4
- Nopa sizes 3 and 4
- . AB Stainless size 4
- Lance sizes 3 and 4
- Pro-Med sizes 3 and 4
- Paragon sizes 3 and 4
- Rocket size 5
- Conqueror size 3
- Feather sizes 3. 4. and 7
- . LRI sizes 3 and 4
- Generic handle size 4
- . L-dent
- Medesy size 5 ●
- Jakobi size 4
- CS size 5 ●
- Helmut Zepf ●
Scalpel handles known to be incompatible with the Olicksmart BladeFlask PLUS include:
- Beaver type handles ●
- Disposable handles ●
#### TECHNOLOGICAL CHARACTERISTICS COMPARISON OF WITH THE VI. PREDICATE DEVICE
A sharps container with a scalpel blade removal function that is used under non-sterile conditions is the technological principle for both the subject and predicate devices. It is based on the use of a mechanism for removing scalpel blades from scalpel handles in a single-handed action and then immediately contains the used scalpel blade inside the device.
| Characteristics | Subject Device | Predicate Device | Comparison |
|--------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Qlicksmart BladeFlask PLUS<br>(Proposed Trade Name) | QLICKSMART® [Original<br>Trade Name used in the<br>premarket 510(k) notification]<br>Qlicksmart BladeFLASK<br>(Current Trade Name) | N/A |
| Product Code | MMK | MMK | Identical |
| 510(k) Number | K213274 | K983367 | N/A |
| Regulation<br>Number | 21 CFR 880.5570 | 21 CFR 880.5570 | Identical |
| Characteristics | Subject Device | Predicate Device | Comparison |
| Intended use | The Qlicksmart BladeFlask<br>PLUS is a sharps container with<br>a scalpel blade removal<br>function.<br>The Qlicksmart BladeFlask<br>PLUS is a single-use sharps<br>container with a scalpel blade<br>removal function that is used<br>under non-sterile conditions.<br>The Qlicksmart BladeFlask<br>PLUS removes scalpel blades<br>from scalpel handles in a single-<br>handed action and then<br>immediately contains the used<br>scalpel blade inside the<br>Qlicksmart BladeFlask PLUS.<br>The handle is intended to be<br>used to dispose the entire<br>container as hazardous waste<br>when full (100 removed blades<br>and shut-off system is activated)<br>and the device is not intended to<br>be reprocessed. | The QLICKSMART® is a<br>sharps container with a scalpel<br>blade removal function.<br>The QLICKSMART® is a<br>single-use sharps container with<br>a scalpel blade removal function<br>that is used under non-sterile<br>conditions.<br>The QLICKSMART® removes<br>scalpel blades from scalpel<br>handles in a single-handed<br>action and then immediately<br>contains the used scalpel blade<br>inside the QLICKSMART®.<br>The handle is intended to be<br>used to dispose the entire<br>container as hazardous waste<br>when full (100 removed blades<br>and shut-off system is activated)<br>and the device is not intended to<br>be reprocessed. | Identical |
| Indications for<br>use | The Qlicksmart BladeFlask<br>PLUS is a single-use sharps<br>container with a scalpel blade<br>removal function intended to<br>permit the safe removal of<br>scalpel blades from most<br>currently available scalpel<br>handles and contain the blade<br>immediately upon removal to<br>eliminate the need for further<br>handling prior to be disposed as<br>medical waste while allowing<br>the user to monitor its use to see<br>when it is becoming full and<br>will need changing. Scalpel<br>handles compatible with the<br>Qlicksmart BladeFlask PLUS<br>include:<br>• Swann Morton sizes 3, 4, 5, 6,<br>7, 8, and 9<br>• Lawton size 4<br>• Martin sizes 3, 4, and 7<br>• Aesculap sizes 3, 4, 6, and 7<br>• Sayco sizes 3, 4, and 5<br>• Smic sizes 3 and 4<br>• Nopa sizes 3 and 4 | The QLICKSMART® is a<br>single-use sharps container with<br>a scalpel blade removal function<br>intended to permit the safe<br>removal of scalpel blades<br>commonly available scalpel<br>handles and contain the blade<br>immediately upon removal to<br>eliminate the need for further<br>handling prior to be disposed as<br>medical waste while allowing<br>the user to monitor its use to see<br>when it is becoming full and<br>will need changing. Scalpel<br>handles compatible with<br>Qlicksmart® include:<br>• Swann Morton sizes 3, 4, 7,<br>and 9<br>• Lawton sizes 3 and 4<br>• Martin sizes 3, 4, and 7<br>• Aesculap sizes 3, 3L, 4, and 7<br>• Sayco sizes 3, 4, and 5<br>• Smic sizes 3 and 4<br>• Nopa sizes 3 and 4<br>• AB Stainless size 4<br>• Lance sizes 3 and 4 | Similar.<br>The subject device<br>removes scalpel<br>blades from size<br>No. 3, 4, 5, 6, 7, 8<br>& 9 scalpel handles<br>whereas the<br>predicate device<br>removes scalpel<br>blades from size<br>No. 3, 4, 7 & 9<br>scalpel<br>handles.<br>The subject device<br>removes scalpel<br>blades up to a<br>maximum blade<br>size #60B whereas<br>the<br>predicate device<br>removes scalpel<br>blades up to a<br>maximum blade<br>size #36. |
| Characteristics | Subject Device | Predicate Device | Comparison |
| | • Lance sizes 3 and 4<br>• Pro-Med sizes 3 and 4<br>• Paragon sizes 3 and 4<br>• Rocket size 5<br>• Conqueror size 3<br>• Feather sizes 3, 4, and 7<br>• LRI sizes 3 and 4<br>• Generic handle size 4<br>• L-dent<br>• Medesy size 5<br>• Jakobi size 4<br>• CS size 5<br>• Helmut Zepf | • Paragon sizes 3 and 4<br>• Rocket size 5<br>• Conqueror size 3<br>• Feather size 7<br>• LRI size 4<br>• Generic handle size 4<br>• Jakobi size 4<br>Scalpel handles known to be incompatible with the Qlicksmart® include:<br>- Barron Handle<br>- Beaver type handles<br>- Disposable handles | |
| | Scalpel handles known to be incompatible with the Qlicksmart BladeFlask PLUS include:<br>• Beaver type handles<br>• Disposable handles | | |
| Conditions of Use | Non-Sterile, Single use, Non-reusable when full with appx 100 blades. Disposal as Hazardous Waste | Non-Sterile, Single use, Non-reusable when full with appx 100 blades. Disposal as Hazardous Waste | Identical |
| Anatomical Site | Not applicable | Not applicable | Identical |
| Where used | General hospitals and other clinical settings. It can be fixed in the correct position by a hardware bracket or sticky tape. | General hospitals and other clinical settings. It can be fixed in the correct position by a hardware bracket or sticky tape. | Identical |
| Materials of Construction | The flask is a hard plastic (ABS), opaque and red in color, fully enclosed single-use sharps container.<br><br>The minimum thickness of the flask is 1.5mm, no value below this is permitted.<br><br>The two parts of the container have been designed and mechanically sealed to | The flask is a hard plastic (ABS), opaque and red in color, fully enclosed single-use sharps container.<br><br>The minimum thickness of the flask is 1.5mm, no value below this is permitted.<br><br>The two halves are contiguously ultrasonically welded together. | Similar. The subject device is mechanical sealed to ensure the container is leak proof whereas the predicate device is ultrasonically welded two keep the two halves together. |
| Characteristics | Subject Device | Predicate Device | Comparison |
| Weights and<br>Dimensions | Approximately (13.5cm) tall by (9.1 cm) wide by (12.3) cm) deep. The volume is sufficient to hold 100 of the largest scalpel blades tested. Weights less than 250gm per unit when empty | Approximately (15 cm) tall by (10 cm) wide by (13 cm) deep. The volume is 14.2ml, sufficient to hold 100 of the largest scalpel blades tested. Weights less than 250gm per unit when empty | Similar.<br>The subject device is slightly smaller than the predicate device.<br>However, the volume is sufficient to hold 100 of the largest scalpel blades tested. |
| Technological<br>Characteristics | A scalpel blade removal mechanism that:<br>Contains a mechanism, that strips scalpel blades from scalpel handles; that is, made up of plastic and hardened steel It incorporates a mechanical counting mechanism and automatic mechanical shut off system that closes the unit once the unit has removed around 100 blades and thus prevents overfilling The mechanism is designed to be operated using one hand. Removes scalpel blades from size No. 3, 4, 5, 6, 7, 8, & 9 scalpel handles Removes scalpel blades up to a maximum blade size #60B. Is not to be used for Beaver handles, or Disposable handles. | A scalpel blade removal mechanism that:<br>Contains a mechanism, that strips scalpel blades from scalpel handles; that is, made up of plastic and hardened steel It incorporates a mechanical counting mechanism and automatic mechanical shut off system that closes the unit once the unit has removed around 100 blades and thus prevents overfilling The mechanism is designed to be operated using one hand. Removes scalpel blades from size No. 3, 4, 7, & 9 scalpel handles Removes scalpel blades up to a maximum blade size #36. Is not to be used for Baron handles, Beaver handles, or Disposable handles. | Similar.<br>The subject device removes blades from additional handle types and additional types of blades.<br>Differences in operational range addressed by the performance testing.<br>No new issues of safety raised. |
| Shelf Life | Not applicable | Not applicable | Identical |
| Performance<br>Specifications | It underwent the following tests conducted by Falcon Test Engineers, a NATA (National Association of Testing Authorities) approved laboratory: | It underwent the following tests conducted by ETRS, a NATA (National Association of Testing Authorities) approved laboratory: Performance Tests | Additional performance testing for subject device based upon the recognize standard ISO |
| Characteristics | Subject Device | Predicate Device | Comparison |
| | <b>Performance Tests</b><br>The performance tests were<br>conducted in accordance with<br>the AS 4031-1992 "Non-<br>reusable containers for the<br>collection of sharp medical<br>items used in health care<br>areas".<br>These tests included:<br>• Impact resistance,<br>integrity of closure and<br>leakage as per Appendix<br>B of AS 4031:1992<br>• Handle integrity as per<br>Appendix A of AS<br>4031:1992<br>• Toppling resistance as per<br>Appendix D of AS<br>4031:1992<br>• Resistance to penetration as<br>per Appendix C of AS<br>4031:1992<br><br>Additional performance tests<br>were conducted in<br>accordance with the<br>Recognized Standard ISO<br>23907-1 First edition 2019-<br>01, "Sharps injury protection<br>- Requirements and test<br>methods - Sharps containers".<br>These tests included<br>• Container Stability<br>• Strength of Handle<br>• Resistance to Penetration<br>• Resistance to Damage<br>and Leakage after<br>Dropping<br>• Resistance to Spillage by<br>Toppling | The performance tests were<br>conducted in accordance with<br>the AS 4031-1992 "Non-<br>reusable containers for the<br>collection of sharp medical<br>items used in health care<br>areas".<br>These tests included:<br>• Impact resistance,<br>integrity of closure and<br>leakage as per Appendix<br>B of AS 4031:1992<br>• Handle integrity as per<br>Appendix A of AS<br>4031:1992<br>• Toppling resistance as per<br>Appendix D of AS<br>4031:1992<br>• Resistance to penetration<br>as per Appendix C of AS<br>4031:1992 | 23907-1 did not<br>raise new issues<br>of safety or<br>efficacy. |
| Mechanical<br>and Functional<br>Tests | The mechanical and<br>functional tests were<br>conducted in accordance with<br>the ETRS Scalpel Blade<br>Removal Testing Protocols<br>that were specifically<br>designed in collaboration | The mechanical and<br>functional tests were<br>conducted in accordance with<br>the ETRS Scalpel Blade<br>Removal Testing Protocols<br>that were specifically<br>designed in collaboration | The subject<br>device passed all<br>testing as the<br>predicate device<br>did. |
| Characteristics | Subject Device | Predicate Device | Comparison |
| | with Qlicksmart for this type<br>of devices. The battery of<br>testing included the following<br>tests:<br>• Blade removal function<br>• Counting mechanism<br>activation<br>• Automatic shut-off<br>mechanism activation<br>• It can be installed into the<br>bracket with reasonable<br>force<br>• Uses force to strip a<br>scalpel blade from a<br>scalpel handle that is less<br>that the force required to<br>uninstall the device from<br>the bracket<br>• Incorrect insertion of the<br>scalpel handle | with Qlicksmart for this type<br>of devices. The battery of<br>testing included the following<br>tests:<br>• Blade removal function<br>• Counting mechanism<br>activation<br>• Automatic shut-off<br>mechanism activation<br>• It can be installed into the<br>bracket with reasonable<br>force<br>• Uses force to strip a<br>scalpel blade from a<br>scalpel handle that is less<br>that the force required to<br>uninstall the device from<br>the bracket<br>• Incorrect insertion of the<br>scalpel handle | |
| Transportation<br>Tests | Tests for the subject device<br>were conducted in<br>accordance with the United<br>Nations Recommendations<br>on the Transport of<br>Dangerous Goods 21st<br>Edition 6.1.5.3 and 6.1.5.6.<br>Falcon Test Engineers found<br>that Qlicksmart BladeFlask<br>PLUS successfully passed all<br>these tests<br>The battery of testing<br>included the following tests:<br>• Drop Test<br>• Stacking Test | Tests for the subject device<br>were conducted in<br>accordance with the United<br>Nations Recommendations<br>on the Transport of<br>Dangerous Goods 21st<br>Edition 6.1.5.3 and 6.1.5.6.<br>Falcon Test Engineers found<br>that Qlicksmart BladeFlask<br>PLUS successfully passed all<br>these tests<br>The battery of testing<br>included the following tests:<br>• Drop Test<br>• Stacking Test | The subject<br>device passed all<br>testing as the<br>predicate device<br>did. |
| TEST METHOD or<br>STANDARD | TEST<br>PURPOSE | ACCEPTANCE CRITERIA | RESULTS |
| ISO 23907-1 | Test Container<br>Stability | The container shall not topple over<br>when tested | PASS |
| ISO 23907-1 | Test Strength of<br>Handle | The handle shall not break or detach<br>during testing…
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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.
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.