K232937 · BTL Industries, Inc. · IPF · Dec 26, 2023 · Physical Medicine
Device Facts
Record ID
K232937
Device Name
BTL-899M
Applicant
BTL Industries, Inc.
Product Code
IPF · Physical Medicine
Decision Date
Dec 26, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5850
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions. The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes. Indications for Use for Muscle Stimulators: - Relaxation of muscle spasms - Prevention or retardation of disuse atrophy - Increasing local blood circulation - Muscle re-education - Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis - Maintaining or increasing range of motion
Device Story
BTL-899M is a non-invasive therapeutic device for clinical use under medical supervision. It comprises a main console with a color touch-screen and a single magnetic coil applicator. The device delivers electromagnetic energy to stimulate underlying muscles, joints, and connective tissue; it also provides a subtherapeutic warming sensation (up to 40°C) via bipolar radiofrequency (RF) to enhance patient comfort and relaxation. The touch-screen interface guides the clinician through therapy setup and displays parameters like therapy type, remaining time, and intensity. The applicator is secured to the patient using a fixation belt for hands-free treatment. By inducing muscle excitation and increasing local blood circulation, the device supports rehabilitative goals such as muscle re-education and atrophy prevention. The system includes a temperature sensor to monitor the RF warming modality.
Clinical Evidence
No clinical data. Bench testing only, including electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), usability (IEC 60601-1-6), software life cycle (IEC 62304), risk management (ISO 14971), and biocompatibility (ISO 10993-1, -5, -10).
Technological Characteristics
System console with generators, computer, and 15.6-inch color touch-screen. Delivers electromagnetic energy (1-150 Hz, 0.5-1.8 T, sine biphasic pulses) and bipolar RF (27.12 MHz, max 30 W). Includes temperature sensor for RF monitoring. Class II, BF electrical protection. Powered by 100-240 V AC. Hands-free applicator with fixation belt. Software developed per IEC 62304.
Indications for Use
Indicated for patients requiring neuromuscular stimulation for bulk muscle excitation in legs or arms for rehabilitation, including relaxation of muscle spasms, prevention/retardation of disuse atrophy, increasing local blood circulation, muscle re-education, post-surgical calf muscle stimulation to prevent venous thrombosis, and maintaining/increasing range of motion.
Regulatory Classification
Identification
A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name and title on the right. The symbol on the left is a stylized representation of a human figure, while the text on the right reads "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue letters.
December 26, 2023
BTL Industries, Inc David Chmel Official Correspondent 362 Elm Street Marlborough, Massachusetts 01752
Re: K232937
Trade/Device Name: BTL-899M Regulation Number: 21 CFR 890.5850 Regulation Name: Powered Muscle Stimulator Regulatory Class: Class II Product Code: IPF Dated: November 27, 2023 Received: November 27, 2023
Dear David Chmel:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
Heather L. Dean -S
for CDR Jitendra Virani, MS, MBA Assistant Director DHT5B: Division of Neuromodulation and Rehabilitation Devices OHT5: Office of Neurological and Physical Medicine Devices
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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) K232937
Device Name BTL-899M
Indications for Use (Describe)
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions.
The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes.
Indications for Use for Muscle Stimulators:
- · Relaxation of muscle spasms
- · Prevention or retardation of disuse atrophy
- Increasing local blood circulation
- Muscle re-education
- · Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- · Maintaining or increasing range of motion
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------|---------------------------------------------|
| <span style="text-decoration: overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) | 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 BTL Industries. The logo consists of three blue squares that are nested inside of each other. To the right of the squares is the text "BTL Industries" in a gray sans-serif font.
# 510(k) Summary
# K232937
# General Information
| Sponsor: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Applicant: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
| Contact Person: | David Chmel<br>BTL Industries, Inc.<br>chmel@btlnet.com |
| Summary Preparation<br>Date: | 21 December 2023 |
# Device Name
| Trade/Proprietary Name: | BTL-899M |
|-------------------------|---------------------------|
| Regulation Number: | 21 CFR 890.5850 |
| Regulation Name: | Powered Muscle Stimulator |
| Regulatory Class: | Class II |
| Product Code: | IPF |
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Image /page/5/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of two parts: a geometric symbol on the left and the text "BTL Industries" on the right. The geometric symbol is made up of three nested squares, each rotated 45 degrees, and the letters "BTL" are placed inside the innermost square. The text "BTL Industries" is written in a sans-serif font and is gray in color.
#### Legally Marketed Predicate Device
The BTL-899M is a state-of-the-art device with accessories using the electromagnetic energy for therapeutic purposes and is substantially equivalent to the current product that is already cleared for distribution in the USA under the following 510(k) Premarket Notification number:
- HPM-6000 (K160992)
#### Product Description
The BTL-899M is a non-invasive therapeutic device. The device is comprised of a main unit and an applicator that deliver electromagnetic energy to the targeted tissue. The device's output enables handsfree treatment.
The application of electromagnetic energy to the patient's feeling of magnetic stimulation of underlying muscles, joints and connective tissue accompanied by a pleasant feeling of warming sensation in the application area, which may contribute to increased local blood circulation and help the patient to relax and make the treatment more comfortable.
The BTL-899M is equipped with a large color touch-screen that significantly facilitates the use of the device. The on-screen information guides the user step-by-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen of the device. During the therapy, the device displays information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.
#### Indications for Use
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions.
The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes.
Indications for Use for Muscle Stimulators:
- Relaxation of muscle spasms
- Prevention or retardation of disuse atrophy
- Increasing local blood circulation ●
- . Muscle re-education
- Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- Maintaining or increasing range of motion
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Image /page/6/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares on the left side, with the letters "BTL" inside the innermost square. To the right of the squares is the text "BTL Industries" in a sans-serif font. The logo is in a dark blue color.
# Non-clinical Testing (Performance, Bench Testing)
The BTL-899M device has been thoroughly evaluated for electrical safety. The device has been found to comply with the following applicable medical device safety standards:
| IEC 60601-1 | Medical electrical equipment – Part 1: General requirements for basic safety<br>and essential performance |
|---------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1-2 | Medical electrical equipment - Part 1-2: General requirements for basic safety<br>and essential performance - Collateral standard: Electromagnetic compatibility<br>– Requirements and tests |
| IEC 60601-1-6 | Medical electrical equipment - Part 1-6: General requirements for basic safety<br>and essential performance – Collateral standard: Usability |
| IEC 62304 | Medical device software - Software life cycle processes |
| ISO 14971 | Medical devices – Application of risk management to medical devices |
| ISO 10993-1 | Biological evaluation of medical devices – Part 1: Evaluation and testing within<br>a risk management process |
| ISO 10993-5 | Biological evaluation of medical devices – Part 5: Tests for in vitro cytotoxicity |
| ISO 10993-10 | Biological evaluation of medical devices - Part 10: Tests for irritation and skin<br>sensitization |
# Clinical Testing
Not applicable
## Technological Characteristics
The BTL-899M device has the same intended use and identical technological characteristics and principles of operation to its predicate device. The BTL-899M device and its predicate are comprised of a system console and an applicator. The system console consists of the generators, computer, and the touch-screen control panel.
The mechanism of action and technological similarities and differences between the BTL-899M device and the predicate device are described below in the comparison table. The differences do not raise any new types of safety or effectiveness questions.
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Image /page/7/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three overlapping squares with the letters B, T, and L inside them. The text "BTL Industries" is written to the right of the logo in a sans-serif font.
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Image /page/8/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares nested inside each other, with the letters "BTL" inside the innermost square. To the right of the logo is the text "BTL Industries" in a gray sans-serif font.
# Comparison with the Predicate Device
| 510(k) number | K232937 | K160992 |
|-------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device name | BTL-899M | HPM-6000 |
| Company name | BTL Industries, Inc. | BTL Industries, Inc. |
| Product Code<br>and Regulation | Physical Medicine<br>21 CFR 890.5850<br>IPF - Stimulator, Muscle, Powered | Physical Medicine<br>21 CFR 890.5850<br>IPF - Stimulator, Muscle, Powered |
| Indications for Use | The BTL-899M device is intended to<br>be used under medical supervision for<br>adjunctive therapy for the treatment of<br>medical diseases and conditions.<br>The BTL-899M device is indicated for<br>use in stimulating neuromuscular<br>tissue for bulk muscle excitation in the<br>legs or arms for rehabilitative<br>purposes.<br>Indications for Use for Muscle<br>Stimulators:<br>• Relaxation of muscle spasms<br>• Prevention or retardation of disuse<br>atrophy<br>• Increasing local blood circulation<br>• Muscle re-education<br>• Immediate post-surgical stimulation<br>of calf muscles to prevent venous<br>thrombosis<br>• Maintaining or increasing range of<br>motion | The HPM-6000 device is intended to<br>be used under medical supervision for<br>adjunctive therapy for the treatment of<br>medical diseases and conditions.<br>The HPM-6000 device is indicated for<br>use in stimulating neuromuscular<br>tissue for bulk muscle excitation in the<br>legs or arms for rehabilitative<br>purposes.<br>Indications for Use for Muscle<br>Stimulators:<br>• Relaxation of muscle spasms<br>• Prevention or retardation of disuse<br>atrophy<br>• Increasing local blood circulation<br>• Muscle re-education<br>• Immediate post-surgical stimulation<br>of calf muscles to prevent venous<br>thrombosis<br>• Maintaining or increasing range of<br>motion |
| Electrical Protection | Class II, BF | Class II, BF |
| Interface | Touch screen | Touch-screen |
| Type of Energy | Electromagnetic energy for magnetic<br>stimulation and application of warming<br>sensation through radiofrequency | Magnetic field |
| Type of Applicator | Single magnetic coil | Single magnetic coil |
| Number of Magnetic<br>coils in the<br>Applicators | 1 | 1 |
| Number of<br>Applicators | 1 | 2 |
| Color Touch Screen | 15.6 in<br>39.6 cm<br>1920 x 1080 px. | 8.4 in<br>21.3 cm<br>800x400 pixel |
| Type of Operation | Continuous | Continuous |
| Pulse Repetition<br>Rate - supported by<br>the device | 1 - 150 Hz | 1-150 Hz |
| Magnetic Field<br>Intensity | AP-C-1 - 0.5 to 1.8 T | 299-1 applicator: 0.5-1.8 T<br>299-2 applicator: 0.7-2.5 T |
| Pulse Duration | AP-C-1 - 280 µs ± 20% | 299-1 applicator: 280 µs ± 20%<br>299-2 applicator: 280 µs ± 20% |
| Pulse Amplitude | 0–100 % | 0-100 % |
| Shape of<br>Stimulation Pulse | Sine, biphasic | Sine, biphasic |
| RF Type | bipolar | N/A |
| Max. RF Power | 30 W | N/A |
| RF Frequency | 27.12 Mhz | N/A |
| Temperature Sensor | Yes | N/A |
| Therapy Time | Up to 30 min | Up to 60 min |
| Application | Hands-free, applicator fixed by fixation<br>belt | Hands-free, applicator fixed in application<br>arm |
| External<br>Exchangeable Fuse | Yes | Yes |
| Energy Source | 100 - 240 V AC, 50-60 Hz | 100 - 240 V AC, 50-60 Hz |
| System Dimensions<br>( $W×H×D$ ) | 23 x 39 x 29 in<br>(592 x 985 x 730 mm) | 20×38×23 in<br>(500 x 970 x 580 mm) |
| System Weight | 70 kg | 33 kg |
| | | |
| Operating Ambient<br>Temperature | +10°C to +30°C | +10°C to +30°C |
| Operating Relative<br>Humidity | 30% to 75% | 30% to 75% |
| Environmental<br>Specifications | For indoor use only<br>In vertical position - On castors | For indoor use only<br>In vertical position - On castors |
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Image /page/9/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of a blue geometric design on the left and the text "BTL Industries" on the right. The geometric design is made up of three interlocking squares, each with the letters "BTL" inside. The text "BTL Industries" is written in a simple, sans-serif font.
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Image /page/10/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares, each containing the letters "BTL" inside. To the right of the squares is the text "BTL Industries" in a gray, sans-serif font. The logo is simple and modern, and the use of blue and gray gives it a professional look.
# Therapy Time
The subject device has a standard adjustable therapy duration of up to 30 minutes, which differs from the predicate device, which allows therapy to be set for up to 60 minutes. However, the device has the same output parameters as the predicate device in terms of maximum frequency, duty factor, maximum magnetic field intensity and pulse duration. If the operator deems it necessary to provide longer therapy to a patient, the subject device can be used repeatedly and the final dosage of energy delivered per the same time will be the same as for the predicate device. Therefore, this difference does not raise any unacceptable risks or unacceptable questions in relation to safety or efficacy.
# Number of applicators
The applicator AP-C-1 is intended to be used with the subject device to achieve the intended purpose whereas the predicate device allows the use of one of two available applicators 299-1 or 299-2 to achieve the intended purpose of the device. The AP-C-1 applicator intended to be used with the subject device has the same maximum output parameters in terms of maximum magnetic field intensity and pulse duration as the predicator 299-1. Therefore, this difference does not raise any unacceptable risks or unacceptable questions in relation to safety or efficacy.
## Weight & Dimensions
These parameters do not have any significant effect on the efficiency or safety of the device.
## Additional energy and its parameters
BTL-899M incorporates application of the warming sensation on subtherapeutic level (up to 40°C) at the patient application site to increase patient convenience, soothe, and relax them during therapy. This application of additional energy does not raise any unacceptable risks or questions related to safety or effectiveness.
## Temperature sensor
BTL-899M incorporates application of the warming sensation on subtherapeutic level (up to 40°C) at the patient application site to increase patient convenience, soothe and relax them during therapy. Based on this additional energy presence, there is a temperature sensor to monitor and regulate this additional modality. This application of additional energy does not raise any unacceptable risks or questions related to safety or effectiveness.
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Image /page/11/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares on the left side of the image. The text "BTL Industries" is on the right side of the image in a sans-serif font.
# Substantial Equivalence
The BTL-899M device has the same intended use as its predicate device. The technological characteristics of the predicate device are similar to the BTL-899M device. Any differences between the predicate device and BTL-899M have no significant influence on safety and effectiveness of the BTL-899M device. Therefore, the BTL-899M is substantially equivalent to the predicate device.
# Conclusion
Based upon the intended use and the known technical and clinical data provided in this pre-market notification, the BTL-899M device has been shown to be substantially equivalent to the currently marketed predicate device.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.