Kangaroo OMNI™ Enteral Feeding Pump (385400 );Kangaroo OMNI™ Feeding Set 500ml (B5FD );Kangaroo OMNI™ ENtelliSet 500ml (E5FD );Kangaroo OMNI™ Feeding Set 1000ml (B10FD );Kangaroo OMNI™ ENtelliSet 1000ml (E10FD );Kangaroo OMNI™ ENPlus Spike Set (BSPFD );Kangaroo OMNI™ ENtelliSet ENPlus Spike ( ESPFD );Kangaroo OMNI™ Feeding Set 500ml with Flush Bag ( B5FF);Kangaroo OMNI™ ENtelliSet 500ml with Flush Bag (E5FF);Kangaroo OMNI™ Feeding Set 1000ml with Flush Bag ( E10FF );Kangaroo OMNI™
K221603 · Cardinal Health, LLC · LZH · Dec 20, 2022 · General Hospital
Device Facts
Record ID
K221603
Device Name
Kangaroo OMNI™ Enteral Feeding Pump (385400 );Kangaroo OMNI™ Feeding Set 500ml (B5FD );Kangaroo OMNI™ ENtelliSet 500ml (E5FD );Kangaroo OMNI™ Feeding Set 1000ml (B10FD );Kangaroo OMNI™ ENtelliSet 1000ml (E10FD );Kangaroo OMNI™ ENPlus Spike Set (BSPFD );Kangaroo OMNI™ ENtelliSet ENPlus Spike ( ESPFD );Kangaroo OMNI™ Feeding Set 500ml with Flush Bag ( B5FF);Kangaroo OMNI™ ENtelliSet 500ml with Flush Bag (E5FF);Kangaroo OMNI™ Feeding Set 1000ml with Flush Bag ( E10FF );Kangaroo OMNI™
Applicant
Cardinal Health, LLC
Product Code
LZH · General Hospital
Decision Date
Dec 20, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5725
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
Intended for delivery of enteral fluids, including nutritional fluids and/or water to the gastrointestinal system via nasogastric, orogastric, nasojejunal, gastrostomy, and jejunostomy tubes. Not for use with neonates. Intended for any patients ages infant, child/adolescent and adult who are physically unable to eat and swallow or who are unable to get sufficient nutrition through eating and swallowing. Intended to be used in hospital and acute care settings, as well as long term and home care settings by users ranging from clinicians to laypersons and patients. Some patients may need a caregiver to support using the device. It is intended to be used in both stationary and ambulatory conditions including ground and air transport while using backpack accessory. The Kangaroo OMNI™ Enteral Feeding Pump and Feeding Set are intended to be used together as a system. Kangaroo OMNI™ Enteral Feeding Sets for administration of standard formula are able to be connected to access devices of all sizes that are ENFit™ compatible. The Kangaroo OMNI™ Thick Formula Feeding Sets for administration of thick formula can be used with access devices 8 Fr size or greater that are ENFit™ compatible.
Device Story
Kangaroo OMNI™ Enteral Feeding Pump is a rotary peristaltic tension loop pump delivering nutritional fluids/water to GI tract. System includes pump, disposable feeding sets, and accessories. Used in hospital, acute, long-term, and home care settings by clinicians, laypersons, or patients (with caregiver support). Operates in stationary or ambulatory modes (via backpack). Pump incorporates menu-controlled software to set feed rates/volumes. Features include feed/flush capability, thick formula delivery, and auto-prime. Sensors (2 ultrasonic, 1 force) monitor flow and detect occlusions (upstream/downstream). Output is controlled fluid delivery; healthcare providers use pump interface to manage nutrition/hydration therapy. Benefits include reliable enteral nutrition for patients unable to ingest food orally.
Clinical Evidence
No clinical data. Bench testing only, including software verification/validation, electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), essential performance (flow rate accuracy, alarm detection), human factors/usability engineering, biocompatibility (ISO 10993), and battery testing (IEC 62133).
Technological Characteristics
Rotary peristaltic tension loop pump. Powered by rechargeable Lithium Ion battery. Features 2 ultrasonic sensors and 1 force sensor. Color TFT display (320x240). IP26 liquid ingress protection. Connectivity: standalone. Software: Major Level of Concern. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-8, IEC 60601-1-11, IEC 60601-2-24, IEC 62304, IEC 62366, IEC 62133.
Indications for Use
Indicated for delivery of enteral fluids (nutritional/water) to GI tract via nasogastric, orogastric, nasojejunal, gastrostomy, or jejunostomy tubes. Patient population: infants, children/adolescents, and adults unable to eat/swallow or requiring supplemental nutrition. Contraindicated for neonates.
Regulatory Classification
Identification
An infusion pump is a device used in a health care facility to pump fluids into a patient in a controlled manner. The device may use a piston pump, a roller pump, or a peristaltic pump and may be powered electrically or mechanically. The device may also operate using a constant force to propel the fluid through a narrow tube which determines the flow rate. The device may include means to detect a fault condition, such as air in, or blockage of, the infusion line and to activate an alarm.
Predicate Devices
Kangaroo™ Connect Enteral Feeding Pump with Kangaroo™ Connect Feeding Sets and Kangaroo™ Connect Portal (K153074)
Reference Devices
Kendall ePump Enteral Feeding Pump and Enteral Feeding Sets
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image shows the logo for the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
December 20, 2022
Cardinal Health LLC Varela Fredy Manager, Regulatory Affairs 3651 Birchwood Drive Waukegan. Illinois 60085
## Re: K221603
Trade/Device Name: Kangaroo OMNI™ Enteral Feeding Pump (385400):Kangaroo OMNI™ Feeding Set 500ml (B5FD );Kangaroo OMNI™ ENtelliSet 500ml (E5FD );Kangaroo OMNI™ Feeding Set 1000ml (B10FD );Kangaroo OMNI™ ENtelliSet 1000ml (E10FD );Kangaroo OMNI™ ENPlus Spike Set (BSPFD );Kangaroo OMNI™ ENtelliSet ENPlus Spike ( ESPFD );Kangaroo OMNI™ Feeding Set 500ml with Flush Bag ( B5FF);Kangaroo OMNI™ ENtelliSet 500ml with Flush Bag (E5FF):Kangaroo OMNI™ Feeding Set 1000ml with Flush Bag ( E10FF );Kangaroo OMNI™ ENPlus Spike Set with Flush Bag ( BSPFFF);Kangaroo OMNI™ ENtelliSet ENPlus Spike with Flush Bag (ESPFF);Kangaroo OMNI™ Thick Formula ENtelliSet 500ml (E5FDR);Kangaroo OMNI™ Thick Formula ENtelliSet 500ml with Flush Bag (E5FFR);Kangaroo OMNI™ Thick Formula ENtelliSet 1000ml (E10FDR);Kangaroo OMNI™ Thick Formula ENtelliSet 1000ml with Flush Bag (E10FFR):Kangaroo OMNI™ Burette ENtelliSet (ER100);Kangaroo™ Power Cord with Adapter (384491);Kangaroo™ Adjustable Pole Clamp (384492):
Regulation Number: 21 CFR 880.5725 Regulation Name: Infusion Pump Regulatory Class: Class II Product Code: LZH Dated: December 1, 2022 Received: December 2, 2022
Dear Varela Fredy:
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
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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 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
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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,
# Courtney H. Lias -S
Courtney H. Lias, Ph.D. Director 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) K221603
#### Device Name
Kangaroo™ Omni Enteral Feeding Pump, Kangaroo™ Omni Feeding Sets, and Kangaroo™ Accessories
#### Indications for Use (Describe)
Intended for delivery of enteral fluids, including nutritional fluids and/or water to the gastrointestinal system via nasogastric, orogastric, nasojejunal, gastrostomy, and jejunostomy tubes. Not for use with neonates. Intended for any patients ages infant, child/adolescent and adult who are physically unable to eat and swallow or who are unable to get sufficient nutrition through eating and swallowing. Intended to be used in hospital and acute care settings, as well as long term and home care settings by users ranging from clinicians to laypersons and patients may need a caregiver to support using the device. It is intended to be used in both stationary and ambulatory conditions including ground and air transport while using backpack accessory.
The Kangaroo OMNI™ Enteral Feeding Set are intended to be used together as a system. Kangaroo OMNI™ Enteral Feeding Sets for administration of standard formula are able to be connected to access devices of all sizes that are ENFit™ compatible. The Kangaroo OMNI™ Thick Formula Feeding Sets for administration of thick formula can be used with access devices 8 Fr size or greater that are ENFit™ compatible.
Type of Use *(Select one or both, as applicable)*
| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> □ Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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#### K221603 510(K) SUMMARY
| Manufacturer's Name: | Cardinal Health LLC<br>3651 Birchwood Drive<br>Waukegan, IL 60085 |
|------------------------------------|---------------------------------------------------------------------------------------------------------------|
| Corresponding Official: | Fredy Varela<br>Manager, Regulatory Affairs |
| Telephone Number:<br>E-mail: | 847.887.5781<br>fred.varela@cardinalhealth.com |
| Preparation Date: | December 19, 2022 |
| Trade Name: | Kangaroo OMNITM Enteral Feeding Pump, Kangaroo OMNITM Feeding<br>Sets and KangarooTM Accessories |
| Common or Usual<br>Name: | Enteral Feeding pump, Infusion pump |
| Classification Name and<br>Number: | Infusion Pump<br>21 CFR 880.5725<br>Class II<br>Product Code: LZH |
| Primary Predicate<br>Device: | KangarooTM Connect Enteral Feeding Pump with KangarooTM<br>Connect Feeding Sets and KangarooTM Connect Portal |
| Reference Device: | Kendall ePump Enteral Feeding Pump and Enteral Feeding Sets |
#### Device Description
The Kangaroo OMNI™ Enteral Feeding Pump, Kangaroo OMNI™ Feeding Sets and Kangaroo™ Accessories consist of an enteral feeding pump and disposable enteral feeding sets along with accessories that deliver fluids via rotary peristaltic tension loop pumping to provide hydration and nutrition for those who do not have the ability to orally ingest food or drinks.
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#### Intended Use/Indications for Use
Intended for delivery of enteral fluids, including nutritional fluids and/or water to the gastrointestinal system via nasogastric, orogastric, nasojejunal, gastrostomy, and jejunostomy tubes. Not for use with neonates. Intended for any patients ages infant, child/adolescent and adult who are physically unable to eat and swallow or who are unable to get sufficient nutrition through eating and swallowing. Intended to be used in hospital and acute care settings, as well as long term and home care settings by users ranging from clinicians to laypersons and patients. Some patients may need a caregiver to support using the device. It is intended to be used in both stationary and ambulatory conditions including ground and air transport while using backpack accessory.
The Kangaroo OMNI™ Enteral Feeding Pump and Feeding Set are intended to be used together as a system. Kangaroo OMNI™ Enteral Feeding Sets for administration of standard formula are able to be connected to access devices of all sizes that are ENFit™ compatible. The Kangaroo OMNI™ Thick Formula Feeding Sets for administration of thick formula can be used with access devices 8 Fr size or greater that are ENFit™ compatible.
| Feature | Predicate Device<br>Kangaroo™<br>Connect<br>K153074 | Subject Device<br>Kangaroo™ OMNI<br>K221603 (current submission) | Subject vs. Predicate Device Differences<br>Substantial Equivalence |
|-----------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended<br>Use/Indications<br>for Use | Intended to<br>deliver nutritional<br>formula at a<br>controlled rate to<br>the<br>gastrointestinal<br>system of a<br>patient who is<br>physically unable<br>to eat and<br>swallow. Not for<br>use with neonates.<br>The feeding pump<br>and feeding sets<br>are intended to be<br>used in clinical or<br>home care<br>settings by users<br>ranging from<br>laypersons to<br>physicians. | Intended for delivery of enteral fluids,<br>including nutritional fluids and/or water to<br>the gastrointestinal system via nasogastric,<br>orogastric, nasojejunal, gastrostomy, and<br>jejunostomy tubes. Not for use with<br>neonates. Intended for any patients ages<br>infant, child/adolescent and adult who are<br>physically unable to eat and swallow or who<br>are unable to get sufficient nutrition<br>through eating and swallowing. Intended to<br>be used in hospital and acute care settings,<br>as well as long term and home care settings<br>by users ranging from clinicians to<br>laypersons and patients. Some patients may<br>need a caregiver to support using the<br>device. It is intended to be used in both<br>stationary and ambulatory conditions<br>including ground and air transport while<br>using backpack accessory.<br>The Kangaroo OMNI™ Enteral Feeding Pump<br>and Feeding Set are intended to be used<br>together as a system. Kangaroo OMNI™<br>Enteral Feeding Sets for administration of<br>standard formula are able to be connected<br>to access devices of all sizes that are ENFit™<br>compatible. The Kangaroo OMNI™ Thick<br>Formula Feeding Sets for administration of<br>thick formula can be used with access<br>devices 8 Fr size or greater that are ENFit™<br>compatible. | General purpose of the subject device or its<br>function, condition and patient population are<br>the same as predicate device. Subject device<br>feature is substantially equivalent to that of<br>the predicate device |
| Technological<br>Characteristics | Peristaltic<br>pumping action | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Design (Pump) | The pump<br>incorporates a<br>menu-controlled,<br>operating system<br>which contains on<br>board custom<br>software designed<br>to allow the user | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Feature | Predicate Device<br>Kangaroo™<br>Connect<br>K153074 | Subject Device<br>Kangaroo™ OMNI<br>K221603 (current submission) | Subject vs. Predicate Device Differences<br>Substantial Equivalence |
| | to set feed rates<br>and volumes as<br>well as other<br>feeding options | | |
| Free Flow<br>Mechanism | Anti-Free Flow<br>Valve | Stopcock Valve | Difference does not introduce or raise concerns<br>regarding the safe and effective use of the<br>subject device. |
| Feed<br>Capability | Yes | Same | Subject device feature is substantially<br>equivalent to that of the predicate device |
| Feed and Flush<br>Capability | No | Yes | Difference is considered an added<br>benefit/option for the user, and does not<br>introduce or raise concern regarding the safe<br>and effective use of the subject device |
| Thick Formula<br>Capability | No | Yes | Difference is considered an added<br>benefit/option for the user, and a design<br>improvement that does not introduce or raise<br>concern regarding the safe and effective use of<br>the subject device. Clinical benefits offered by<br>thick formula feeding option outweigh the risks<br>associated with it. |
| Flow<br>Monitoring | Yes, 2 Ultrasonic<br>sensors | Same 2 ultrasonic sensors and 1 new force<br>sensor | Difference is considered a design improvement<br>that does not introduce or raise concerns<br>regarding the safe and effective use of the<br>subject device. |
| Occlusion<br>Detection | Yes, Upstream and<br>Downstream | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Accuracy<br>(Standard<br>Formula<br>Feeding Sets) | $\pm$ 5% | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Accuracy<br>(Thick Formula<br>Feeding Sets) | N/A | ±10% | Difference is considered a design improvement<br>that does not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device |
| Delivery Rate<br>Range | 1-600ml in 1ml<br>increments | 1 to 400mL per hour in 1mL increments<br>(Standard Formula Feeding Sets)<br>1 to 200mL per hour in 1mL increments<br>(Thick Formula Feeding Sets) | Difference is considered a design improvement<br>that does not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device |
| Dose Range | 1-3000ml in 1ml<br>increments | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Power<br>requirements | 120V, 60Hz, 1Amp | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Autoprime | Yes | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Display | Color TFT<br>(320x240<br>pixels) | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Maximum<br>Occlusion<br>Pressure | 20 psi | 16 psi | Difference is considered a design improvement<br>that does not introduce or raise concerns<br>regarding the safe and effective use of the<br>subject device. |
| Feature | Predicate Device<br>Kangaroo™<br>Connect<br>K153074 | Subject Device<br>Kangaroo™ OMNI<br>K221603 (current submission) | Subject vs. Predicate Device Differences<br>Substantial Equivalence |
| Size | 3.9" x 6.1" x 1.6" | 5.5" x 6.8" x 2.6" | Differences do not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Weight | 0.73 lbs (0.33 kg) | 1.7 lbs (770 grams) | Differences do not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Pole Clamp<br>Mountable | Yes | same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Battery Life | 24 hours | 20 hours | Difference is considered a design improvement<br>that does not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device |
| Battery<br>Recharge Time | 7 hours | 12 hours | Difference is considered a design improvement<br>that does not introduce or raise concern<br>regarding the safe and effective use of the<br>subject device |
| Battery<br>Operation<br>Indicator | Yes | same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Operating<br>Temperature<br>Range | 5°-40°C (41°-<br>104ºF) at 93% R.H.<br>(non-condensing) | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Storage<br>Temperature<br>Range | 0°-50°C (32°-<br>122°F) at 93% R.H.<br>(non-condensing) | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Medical and<br>Electrical<br>Safety<br>Standards | IEC 60601-1<br>ANSI/AAMI ES<br>60601-1<br>IEC 60601-1-1<br>IEC 60601-1-2<br>IEC 60601-1-6<br>IEC 60601-1-8<br>IEC 60601-1-11<br>IEC 60601-2-24<br>IEC 62304<br>IEC 62366 | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Degree of<br>Protection<br>Against<br>Electrical<br>Shock | Class 2 Type BH<br>per IEC Standards<br>Pass | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| Degree of<br>Protection for<br>liquid ingress | IP26 = Water Jet<br>proof per IEC<br>60529<br>Pass | Same | Subject device feature is the same as the<br>predicate device. Subject device feature is<br>substantially equivalent to that of the<br>predicate device |
| EMC/ EMI and<br>ESD standards | IEC 60601-1-2<br>Parts 1 and 2 | Same…
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.