THE VISUALIZED ENDOTRACHEAL TUBE SYSTEM OR VETT SYSTEM
Applicant
Pulmonx
Product Code
BTR · Anesthesiology
Decision Date
Feb 13, 1998
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5730
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Pulmonx Visualized Endotracheal Tube (VETT) is indicated for use as a temporary artificial airway in adults requiring mechanical ventilation. It is intended for oral and nasal intubations. The VETT System is indicated for viewing during difficult intubation procedures, for verifying tube placement and repositioning, for viewing during suctioning and for general inspection of the airway.
Device Story
The Pulmonx VETT system integrates fiberoptic visualization components into a standard endotracheal tube wall. It captures real-time endoscopic images from the distal tip of the tube, transmitting them to a Compact Video System (5-inch LCD display) or head-mounted display. The system allows clinicians to visualize the airway continuously or intermittently without disconnecting the patient from a mechanical ventilator. Used in clinical settings by healthcare providers for difficult intubations, tube placement verification, and airway inspection. The output provides direct visual feedback to the physician, facilitating accurate tube positioning and airway management, potentially reducing complications associated with blind intubation or tube displacement.
Clinical Evidence
Bench testing only. Performance data included measurements of cannula flexibility, lumen patency (ASTM1242), and cuff integrity (symmetry, herniation, compliance, leak resistance, tracheal sealing pressure, fatigue, and burst performance). Fiberoptic system performance was validated for image quality and light output. All tests demonstrated substantial equivalence to predicate devices.
Technological Characteristics
Thermosensitive medical-grade PVC cannula; high volume-low pressure PVC cuff. Features 70° forward-looking field of view. Illumination via light guide system with 5000°K metal halide lamp. Connectivity via custom LEMO fiberoptic connector. Mechanical shutter intensity control (0-100%). Video output in NTSC or PAL format to LCD display. Sterilized by ethylene oxide; single-use. Sizes: 7.0, 7.5, 8.0 mm ID.
Indications for Use
Indicated for adult patients requiring mechanical ventilation via oral or nasal intubation. Used for difficult intubation, tube placement verification/repositioning, suctioning, and airway inspection.
Regulatory Classification
Identification
A tracheal tube is a device inserted into a patient's trachea via the nose or mouth and used to maintain an open airway.
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FEB | 3 1998
Pulmon r
Vision in Airway Management
### 510(k) - Premarket Notif
Visualized Endotracheal Tube System
## Appendix 1; 510(k) Summary, page 1 of 3:
Submission Date: August 21, 1997
| Submitter: Pulmonx, Inc.<br>1047 Elwell Ct.<br>Palo Alto, CA 94303 | Contact Person: Tony Wondka<br>Director, Product Development<br>ph.: (650) 934-2606; fax.: X-2601 |
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Pulmonx Visualized Endotracheal Tube System, or, VETT System 1. Device Trade Name: (includes Pulmonx VETT and Pulmonx Compact Video System).
(1) Tracheal Tube (or Endotracheal Tube) with (2) integral 2. Device Common Name: Fiberoptic Flexible Bronchoscope. Also, (3) Fiberoptic Light Source/Carrier and (4) Video Display.
- 3. Device Classification Name:
- (1) Tracheal Tube, Adult, Cuffed
- (2) Bronchoscope, Flexible
- (3) Fiberoptic Light Source and Carrier
#### Device to which this device is substantially equivalent: 4.
- (1) Mallinckrodt Hi-Lo Tracheal Tube with Cuff
- (2) Olympus LF1/LF2 Tracheal Intubation Fiberscope, A.O. LS6A/LS7 Fiberoptic Laryngoscope.
- (3) Welch Allyn Hi-Lux HLS-24W Illuminator
- (4) UroHealth Integrated Visualization System, END-101
#### 5. Description of Device
The Pulmonx Visualized Endotracheal Tube (VETT) with Cuff utilizes the fiberoptic components of a bronchoscope and integrates them into the wall of a standard endotracheal tube. Real-time endoscopic visualization from the distal end of the tracheal tube is possible on a continuous or intermittent basis without disconnecting the patient from the mechanical ventilator.
The VETT is made with biocompatible materials. The device is supplied with a preformed arc, pre-cut to length and with depth markings and a full length radiopaque stripe. The distal tip is a hooded bevel with a Murphy's eye. The cuff is a low pressure-high volume cuff. The inflation system has a self sealing valve. The airway connector is a standard 15mm connector. The device is sterilized by ethylene oxide and is designed for single use. The sizes are 7.0, 7.5 and 8.0 mm ID.
The VETT works in conjunction with the Pulmonx Compact Video System which includes a 5 inch LCD display, an integral Light Source and a Remote Handpiece and Cable. A Head Mounted Display is provided as a supplement to the primary display.
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**Pulmon**x
Vision in Airway Management
Visualized Endotrachea! Tube System
# Appendix 1; 510(k) Summary, continued, page 2 of 3:
#### 6. Intended Use of the Device:
The Pulmonx Visualized Endotracheal Tube (VETT) is indicated for use as a temporary artificial airway in adults requiring mechanical ventilation. It is intended for oral and nasal intubations.
The VETT System is indicated for viewing during difficult intubation procedures, for verifying tube placement and repositioning, for viewing during suctioning and for general inspection of the airway.
### 7. Technical Characteristics, Comparison to Predicate Device(s)
| CHARACTERISTIC | PULMONX<br>VISUALIZED<br>ENDOTRACHEAL<br>TUBE<br>SYSTEM | (1) Mallinckrodt Medical HI-LO<br>Tracheal Tube,<br>(2) Olympus LF-1/LF-2 Tracheal<br>Intubation Fiberscope and American<br>Optical LS-6A / LS-7 Fiberoptic<br>Laryngoscope<br>(3) Welch Allyn HI-LUX HLS-<br>24W Light Source<br>(4) UroHealth END-101 Video Display |
|---------------------------------|-------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Cannula material | Thermosensitive Medical<br>Grade PVC | Thermosensitive Medical Grade PVC (1) |
| Cuff design and<br>material | Compliant Medical Grade<br>PVC, high volume-low<br>pressure | Compliant Medical Grade PVC, high<br>volume-low pressure (1) |
| Endoscope Type | Flexible | Flexible (2) |
| Field and direction of<br>View | 70° minimum forward<br>looking. | 60° forward looking (2, LS-6A) |
| Illumination method | Light Guide system | Light Guide system (2) |
| Lamp Type | Welch Allyn Hi-Lux (Metal<br>Halide) or equivalent. | Welch Allyn Hi-Lux (Metal Halide) (3) |
| Color Temp | 5000 °K | 5000 °K (3) |
| Fiber Optic Bundle<br>Interface | Custom LEMO Fiberoptic<br>Connector | ACMI (2,3) |
| Intensity Control<br>System | Mechanical Shutter (0% -<br>100%) | Mechanical Shutter (20% - 80%) (3) |
| Display Type | LCD | LCD (4) |
| Camera Format | High resolution | High resolution (4) |
| Video Format | NTSC or PAL | NTSC (4) |
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Pulmon_
Vision in Airway Management
## Appendix 1; 510(k) Summary, continued, page 3 of 3:
#### 8. Performance Data
The VETT cannula flexibility has been tested by means of measuring forces to conform to patient anatomy. The force is substantially equivalent to the predicate Mallinckrodt Medical Hi-Lo EndoTracheal Tube. The Pulmonx VETT cannula lumen patency has been tested by means of passing a steel ball (ASTM1242, A1.2) and the device passes the lumen patency test. The cannula of the VETT (with regard to lumen patency and ability to conform to patient anatomy) is demonstrated to be safe and effective.
The VETT cuff has been tested for symmetry about the tube, herniation over the distal tip of the tube, compliance, and leak resistance integrity (ASTM1242). All of these properties meet the ASTM requirement. Minimum tracheal sealing pressure, fatigue and burst performance are also evaluated and these properties meet or exceed that of the Mallinckrodt Hi-Lo Tracheal Tube. The Cuff of the VETT is demonstrated to be safe and effective.
All applicable biocompatibility testing is acceptable.
The fiberoptic system of the VETT and the Compact Video System is tested for image quality and light output. All samples show good performance and are substantially equivalent to the predicate devices. This aspect of the device is demonstrated to be safe and effective.
#### 9. Conclusions
Based on the data described above, the Pulmonx VETT is safe and effective and it is substantially equivalent to the Mallinckrodt Hi-Lo Tracheal Tube in design and performance. Also, the design and performance of the Pulmonx VETT fiberoptic system and the Pulmonx Compact Video System is substantially equivalent to the predicate device(s) and is safe and effective.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features the department's name in a circular arrangement around the perimeter. Inside the circle is a stylized graphic of an eagle or bird-like figure, represented by three curved lines that suggest wings and a body.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
FEB 1 3 1998
Mr. Robert Kotmel V.P., Research and Development Pulmonx, Inc. 1049 Elwell Court Palo Alto, CA 94303
K973191 Re: Visualized Endotracheal Tube System Requlatory Class: II (two) Product Code: BTR Dated: January 22, 1998 Received: January 26, 1998
Dear Mr. Kotmel:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in requlatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
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This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4648. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the requlation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
Thomas J. Callahan
Thomas J. Callahan, Ph.D. Director Division of Cardiovascular, Respiratory, and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Pulmonx
Vision in Airway Management
510(k) - Premarket Notification
Visualized Endotracheal Tube System
12973191 510(k) Number (if known):
Device Name:
Visualized Endotracheal Tube System
Indications for Use:
The Pulmonx Visualized Endotracheal Tube (VETT) is indicated for use as a temporary artificial airway in adults requiring mechanical ventilation, for oral and nasal intubations.
The VETT System is indicated for viewing during difficult intubation procedures, for verifying tube placement and repositioning, for viewing during suctioning and for general inspection of the airway.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE) (Division Sign-Off) Division of Cardiovascular, Respiratory, - ---------------------and Neurological Devices
OR
K473191 510(k) Number
Prescription Use
Over-the-Counter Use
(Optional Format 1-2-96)
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.