K173147 · Revolutionary Medical Devices, Inc. · CCK · Jun 20, 2018 · Anesthesiology
Device Facts
Record ID
K173147
Device Name
SuperNO2VA Et Device
Applicant
Revolutionary Medical Devices, Inc.
Product Code
CCK · Anesthesiology
Decision Date
Jun 20, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.1400
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The SuperNO2VA Et™ Device is a nasal mask that creates a seal when positioned over a patient's nose to direct anesthesia gas, air, and / or oxygen to the upper airway during the continuum of anesthesia care. It has a means for sampling expired gases from the patient's exhaled breath from the oral / nasal areas. The SuperNO2VA Et™ Device is intended for short-term (<24 hours) use on adult patients (>30 kg.). It is a single patient use, disposable. The SuperNO2VA Et™ Device is contraindicated for use in long-term ventilation conditions and treatment of sleep apnea. To be used under clinical supervision with adequate alarms and safety systems for monitoring and treatment of ventilatory failure.
Device Story
Nasal mask device for anesthesia care; provides seal over nose to deliver anesthesia gas, air, or oxygen to upper airway; includes sampling port for nasal expired gases and 'hood' for oral expired gases. Used in hospital/sub-acute settings under clinical supervision. Clinician connects device to gas source via 15mm connector and to monitor via luer fitting. Enables oral cavity access during procedures while maintaining gas delivery and monitoring. Benefits include simultaneous airway management and capnography in non-intubated patients. Single-patient use, disposable.
Clinical Evidence
Bench testing only. Evaluated dead space, pressure drop, pressure/leakage, and O2/CO2 sampling performance against predicates using mannequin models. Results showed comparable EtCO2 measurement accuracy across various flow rates (1-5 lpm) and tidal volumes (300-500 ml) for both nasal and oral sampling paths. Biocompatibility testing performed per ISO 10993-1.
Technological Characteristics
Nasal mask with integrated oral sampling hood. Features 15mm male circuit connector, luer fitting for gas sampling, and slip-fit port for pressure monitoring/oxygen. Materials meet ISO 10993-1 for limited duration (<24h) mucosal/tissue contact. Mechanical design provides seal for gas delivery up to 30 cmH2O.
Indications for Use
Indicated for adult patients (>30 kg) requiring anesthesia gas, air, or oxygen delivery and expired gas sampling during the continuum of anesthesia care. Contraindicated for long-term ventilation and sleep apnea treatment.
Regulatory Classification
Identification
A carbon dioxide gas analyzer is a device intended to measure the concentration of carbon dioxide in a gas mixture to aid in determining the patient's ventilatory, circulatory, and metabolic status. The device may use techniques such as chemical titration, absorption of infrared radiation, gas chromatography, or mass spectrometry.
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Revolutionary Medical Devices, Inc. % Paul Dryden Consultant ProMedic, LLC 131 Bay Point Dr. NE St. Petersburg, Florida 33704
Re: K173147
Trade/Device Name: SuperNO2VA EtTM Device Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: Class II Product Code: CCK, BSJ Dated: May 23, 2018 Received: May 24, 2018
Dear Paul Dryden:
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. 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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820);
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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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
## Todd D. Courtney -S
Tina Kiang, Ph.D. for Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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See PRA Statement on last page.
Expiration Date: 06/30/2020
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
510(k) Number (if known)
### K173147
Device Name
### SuperNO2VA Et™ Device
Indications for Use (Describe)
The SuperNO2VA Et™ Device is a nasal mask that creates a seal when positioned over a patient's nose to direct anesthesia gas, air, and / or oxygen to the upper airway during the continuum of anesthesia care.
It has a means for sampling expired gases from the patient's exhaled breath from the oral / nasal areas.
The SuperNO2VA Ef™ Device is intended for short-term (<24 hours) use on adult patients (>30 kg.). It is a single patient use, disposable.
The SuperNO2VA Ef™ Device is contraindicated for use in long-term ventilation conditions and treatment of sleep apnea.
To be used under clinical supervision with adequate alarms and safety systems for monitoring and treatment of ventilatory failure.
Type of Use (Select one or both, as applicable)
XX Prescription Use (Part 21 CFR 801 Subpart D)
- Over-The-Counter Use (21 CFR 801 Subpart C)
### PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED.
#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
FORM FDA 3881 (7/17)
Page 1 of 1
PSC Publishing Services (301) 443-6740 EF
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### 510(k) Summary Page 1 of 9 20-Jun-18
| Revolutionary Medical Devices, Inc.<br>4090 E. Bujia Primera | | | | |
|--------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------|--|--|--|
| Tucson, AZ 85718 | Tel - (520)-844-3729 | | | |
| Official Contact: | David M. Kane - President and CEO | | | |
| Proprietary or Trade Name: SuperNO2VA EtTM Device | | | | |
| Common/Usual Name: | Nasal anesthesia face mask with gas sampling | | | |
| Classification Code/Name: | CCK - analyzer, gas, carbon-dioxide, gaseous-phase<br>21CFR 868.1400, Class 2 | | | |
| Device: | SuperNO2VA EtTM Device | | | |
| Predicate Devices: | Primary - K011050 - Oridion Microstream (CapnoLine) - CCK<br>Secondary - K163277 - RMD - SuperNO2VATM Device - BSJ | | | |
| Reference Devices: | Class 510(k) exempt - Medline - Anesthesia Face Mask<br>K133806 - Monitor Mask - M1 | | | |
### Device Description:
The SuperNO2VA Et™ Device is a nasal mask with a sampling port for the nasal portion and a sampling "hood" for over the mouth.
The subject device is similar to an anesthesia or oxygen mask with gas sampling port. Instead of covering the full face the SuperNO2VA Et™ Device design is to allow the clinician to have access to the oral cavity during a procedure but still be able to provide air, oxygen or anesthesia gases to the patient while also sampling expired gases from the nasal or oral areas.
The design incorporates the standard 15 mm male circuit connector, luer fitting for the gas sampling line and a slip-fit port for pressure monitoring or oxygen if the mask is used with a manual resuscitator or hyperinflation bag.
The mask is not considered a long-term use device as it would only be used from pre- to postoperative care. This would be similar to the standard anesthesia mask.
It is not for use in long-term ventilation conditions or the treatment of sleep apnea.
#### Indications for Use:
The SuperNQ2VA Et™ Device is a nasal mask that creates a seal when positioned over a patient's nose to direct anesthesia gas, air, and / or oxygen to the upper airway during the continuum of anesthesia care.
It has a means for sampling expired gases from the patient's exhaled breath from the oral / nasal areas.
The SuperNO2VA Et™ Device is intended for short-term (<24 hours) use on adult patients (>30 kg.). It is a single patient use, disposable.
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### 510(k) Summary Page 2 of 9 20-Jun-18
The SuperNO2VA Et™ Device is contraindicated for use in long-term ventilation conditions and treatment of sleep apnea.
To be used under clinical supervision with adequate alarms and safety systems for monitoring and treatment of ventilatory failure.
Patient Population: Adult patients (>30 kg)
Environment of Use: Hospital, Sub-acute
Substantial Equivalence Discussion: Table 1 below compares the key features of the proposed SuperNO2VA Et™ Device mask with the identified primary and secondary predicates and reference devices to demonstrate that the proposed device can be found to be substantially equivalent.
Indications for Use – SuperNO2VA Et™ Device combines indications for use from the predicates, namely expired gas sampling - oral and nasal, with the secondary predicate SuperNO2VA, K163277, which provides a seal to delivery of gases.
Discussion - The proposed indications are a combination of the predicate and reference devices and there are no differences in the indications which raise new concerns of safety and effectiveness when compared to the predicates.
Technology and construction - SuperNO2VA Et™ Device is a nasal mask with a means, a "hood" to also sample expired exhaled from the mouth.
Like the predicate and reference devices they all sample exhaled gases via a port which is a conduit for the samples gases to be delivered to the monitor.
Discussion - The difference is the combination of a nasal mask and the "hood" over the mouth. The predicate uses nasal cannula and an additional sampling means for the mouth. However, the comparison performance testing has demonstrated equivalence.
The difference of delivering gases is similar to the secondary predicate SuperNO2VA, K163277, which provides a seal to delivery of gases. Delivery of gases under pressure to only the nasal area only is consistent with the secondary predicate and thus does not raise different concerns of safety or effectiveness than the predicates.
Environment of Use - The environment of use is similar to the predicates and reference devices. Discussion - The subject device does not include the pre-hospital setting.
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### 510(k) Summary Page 3 of 9
20-Jun-18
### Table 1 – Comparison to Predicate and Reference Devices
| Feature | Proposed | Primary Predicate | Secondary Predicate | Reference | Reference | | |
|-----------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|---------------------------------------------------|-----------------------------------------------------|
| | SuperNO2VA Et™ | K011050 | K163277 | Exempt | K133806 | | |
| | Device | Oridion - Capnostream | RMD SuperNO2VA | Medline Anesthesia | Monitor Mask - M1 | | |
| | | Oral / Nasal Cannula | Mask | mask | | | |
| Product | CCK | CCK | | | CCK | | |
| Classification | 868.1400 | 868.1400 | | | 868.1400 | | |
| | BSI | | BSI | BSI | | | |
| | 868.5550 (Secondary) | | 868.5550 | 868.5550 | | | |
| Indications for | The SuperNO2VA Et™ Device | Is used whenever the | The SuperNO2VA™ Device | Positioned over a | The M1 Capnagraphy Mask | | |
| Use | is a nasal mask that creates a | physician needs to | is a mask that creates a seal | patient's nose or mouth | is a single-use device | | |
| | seal when positioned over a | measure the CO2 in a | when positioned over a | to direct anesthetic | intended for delivering | | |
| | patient's nose to direct | patient's breathing in a | patient's nose and mouth, or | gases to the upper | supplemental oxygen and | | |
| | anesthesia gas, air, and / or | non-intubated patient. | nose only, to direct anesthesia | airway. | monitoring exhaled carbon | | |
| | oxygen to the upper airway | | gas, air, and / or oxygen to the | | dioxide in non-intubated | | |
| | during the continuum of | Intended to conduct a | upper airway during the | | spontaneously breathing | | |
| | anesthesia care. | sample of the patient's | continuum of anesthesia care. | | patients. Standard oxygen | | |
| | It has a means for sampling | breathing from the patient | To be used under clinical | | tubing and two female luer | | |
| | expired gases from the patient's | to the gas measurement | supervision with adequate | Port for expired gas | ports for gas sample line | | |
| | exhaled breath from the oral / | device for measuring the | alarms and safety systems for | sampling | attachment are Included. | | |
| | nasal areas. | percentage of CO2 in the | monitoring and treatment of | | | | |
| | To be used under clinical | patient's exhalation. | ventilatory failure. | | | | |
| | supervision with adequate | | | | | | |
| | alarms and safety systems for | | The SuperNO2VA™ Device | | | | |
| | monitoring and treatment of | | is intended for short-term | | | | |
| | ventilatory failure. | | (<24 hours) use on adult | | | | |
| | The SuperNO2VA Et™ Device | | patients (>30 kg.) It is a single | | | | |
| | is intended for short-term (<24 | | patient use, disposable. | | | | |
| | hours) use on adult patients | | | | | | |
| | (>30 kg.). It is a single patient | | The SuperNO2VA™ Device | | | | |
| | use, disposable. | | is contraindicated for use in | | | | |
| | The SuperNO2VA Et™ Device | | long-term ventilation | | | | |
| | is contraindicated for use in | | conditions and treatment of | | | | |
| | long-term ventilation | | sleep apnea. | | | | |
| | conditions and treatment of | | | | | | |
| | sleep apnea. | | | | | | |
| Feature | Proposed<br>SuperNO2VA EtTM<br>Device | Primary Predicate<br>K011050<br>Oridion - Capnostream<br>Oral / Nasal Cannula | Secondary Predicate<br>K163277<br>RMD SuperNO2VA<br>Mask | Reference<br>Exempt<br>Medline Anesthesia<br>mask | Reference<br>K133806<br>Monitor Mask – M1 | | |
| Patient<br>Population | Adult Patients > 30 kg | All patients | Adult Patients > 30 kg | All patients | All patients | | |
| | Environment of<br>Use | Hospital<br>Sub-acute | Hospital<br>Sub-acute<br>Pre-hospital | Hospital<br>Sub-acute | Hospital<br>Sub-acute<br>Pre-hospital | Hospital<br>Sub-acute<br>Pre-hospital | |
| Duration of Use | | Single patient use,<br>Disposable < 24 hours | Single patient use,<br>disposable | Single patient use,<br>Disposable < 24 hours | Single patient use,<br>disposable | Single patient use,<br>disposable | |
| Technological Characteristics | | | | | | | |
| Where expired<br>gas sampled | Nasal<br>Oral | Nasal<br>Oral | No sampling | No sampling | Nasal<br>Oral | | |
| | Where is gas<br>delivered | Nasal | Nasal | Nasal<br>Oral | Nasal<br>Oral | Nasal<br>Oral | |
| Technology for<br>directing gases<br>under pressure | | Seal at nasal area | No seal | Seal at both nasal and oral | Seal at both nasal and<br>oral | No seal | |
| | Technology for<br>sampling expired<br>gases | Luer port in nasal mask<br>Open hood for oral portion | Open sampling in nasal<br>area<br>Open hood for oral<br>portion | No sampling port | Luer port in mask | Luer port in mask | |
| | | Provides a seal<br>for delivery of<br>gas | Yes<br>Nasal only | No | Yes<br>Nasal and Oral | Yes<br>Nasal and Oral | No |
| Oxygen or<br>pressure<br>monitoring port | | | Yes | No | Yes | No | Yes |
| | | | Method of<br>sampling expired<br>gases | At nasal portion via a port<br>At oral via a hood | At nasal via a cannula<br>At oral via a hood | Does not sample | At oral and nasal via a<br>port |
| | Patient<br>connector | 15 mm connector for delivered<br>gas source | | No patient connector | 15 mm connector for<br>connecting delivered gases | 15 / 22 mm connector<br>for delivered gas source | Oxygen tubing connector<br>for delivered gas source |
| Feature | | Proposed<br>SuperNO2VA EtTM<br>Device | | Primary Predicate<br>K011050<br>Oridion - Capnostream<br>Oral / Nasal Cannula | Secondary Predicate<br>K163277<br>RMD SuperNO2VA<br>Mask | Reference<br>Exempt<br>Medline Anesthesia<br>mask | Reference<br>K133806<br>Monitor Mask – M1 |
| Performance Comparison | | | | | | | |
| Internal volume | Nasal mask only<br>Medium – 53 ml<br>Large - 87 ml | Not applicable | Nasal mask only<br>Medium – 53 ml<br>Large - 87 ml | Full mask<br>~ 158 ml | Not applicable | | |
| Pressure to<br>maintain a seal<br>for gas delivery | Up to 30 cmH2O | Not applicable | Up to 30 cmH2O | Not specified | Not applicable | | |
| Resistance to<br>flow | 0.46 cmH2O @ 50 lpm<br>1.8 cmH2O @ 100 lpm | Not applicable | 0.46 cmH2O @ 50 lpm<br>1.8 cmH2O @ 100 lpm | 30 lpm – 0.13 cmH2O<br>60 lpm – 0.25 cmH2O<br>90 lpm – 0.51 cmH2O | Not tested | | |
| Leak rate under<br>pressure | 0.8 Lpm @ 20 cmH2O | Not applicable | 0.8 Lpm @ 20 cmH2O | Not tested | Not tested | | |
| Biocompatibility | ISO 10993-1<br>Externally communicating<br>Tissue<br>Surface Contact<br>Skin / Mucosal<br>Limited duration (< 24<br>hours) | ISO 10993-1<br>Externally<br>communicating Tissue<br>Surface Contact<br>Skin / Mucosal<br>Prolonged duration | ISO 10993-1<br>Externally communicating<br>Tissue<br>Surface Contact<br>Skin / Mucosal<br>Limited duration (< 24 hours) | ISO 10993-1<br>Externally<br>communicating Tissue<br>Surface Contact<br>Skin / Mucosal<br>Limited duration | ISO 10993-1<br>Externally<br>communicating Tissue<br>Surface Contact<br>Skin / Mucosal<br>Prolonged duration | | |
| Performance<br>testing | Internal volume<br>Resistance to flow through<br>the connector<br>Leakage under simulated<br>seal conditions with a<br>mannequin face<br>Connector – 15 mm testing<br>– pre- and post-aging<br>Drop<br>Environmental – Operating | EtCO2 performance | Internal volume<br>Resistance to flow through<br>the connector<br>Leakage under simulated seal<br>conditions with a mannequin<br>face<br>Connector – 15 mm testing –<br>pre- and post-aging<br>Drop<br>Environmental – Operating / | Resistance to flow<br>through the connector<br>Leakage under simulated<br>seal conditions with a<br>mannequin face<br>Connector – 15 mm<br>testing | EtCO2 performance | | |
| Feature | Proposed<br>SuperNO2VA EtTM<br>Device | Primary Predicate<br>K011050<br>Oridion - Capnostream<br>Oral / Nasal Cannula | Secondary Predicate<br>K163277<br>RMD SuperNO2VA<br>Mask | Reference<br>Exempt<br>Medline / Ventlab<br>Anesthesia mask | Reference<br>K133806<br>Monitor Mask – M1 | | |
| Dead space | Nasal mask only<br>Medium – 53 ml<br>Large – 87 ml | – – N/A | Nasal mask only<br>Medium – 53 ml<br>Large – 87 ml | Large – 158 ml<br>(Nasal and Oral)<br>Medium – | – – N/A | | |
| Pressure / Leak | Can maintain pressure of ><br>20 cmH2O with 10 lbs. force<br><br>Leakage < 2 Lpm | | Can maintain pressure of ><br>20 cmH2O with 10 lbs. force<br><br>Leakage < 2 Lpm | Can maintain pressure of ><br>20 cmH2O with 10 lbs. force<br><br>Leakage ave. 2.6 Lpm | | | |
| Pressure Drop<br>Acceptance<br>< 5 cmH2O @60 Lpm | 30 lpm – 0.13 cmH2O<br>60 lpm – 0.38 cmH2O<br>90 lpm – 1.15 cmH2O | – – N/A | 30 lpm – 0.13 cmH2O<br>60 lpm – 0.38 cmH2O<br>90 lpm – 1.15 cmH2O | 30 lpm – 0.13 cmH2O<br>60 lpm – 0.25 cmH2O<br>90 lpm – 0.51 cmH2O | – – N/A | | |
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# 510(k) Summary
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### 510(k) Summary Page 5 of 9
20-Jun-18
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### 510(k) Summary Page 6 of 9
20-Jun-18
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### 510(k) Summary Page 7 of 9
20-Jun-18
### Table 2 – Comparative O2 / CO2 Performance Nasal and Oral Sampling
| Feature | Proposed<br>SuperNO2VA EtTM<br>Nasal Sampling | K011050<br>Oridion - Capnostream<br>Nasal Sampling | Proposed<br>SuperNO2VA EtTM<br>Oral Sampling | K011050<br>Oridion - Capnostream<br>Oral Sampling |
|---------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|
| Adult | | | | |
| BPR = 12<br>TV (ml) = 500 ml<br>CO2% - 1%<br>O2 Flow rate – 1 and 5 lpm | EtCO2 @ 1% and 1 Lpm<br>Ave. - 1.00%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.93% | EtCO2 @ 1% and 1 Lpm<br>Ave. - 0.93%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 0.88% | EtCO2 @ 1% and 1 Lpm<br>Ave. - 0.98%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.95 | EtCO2 @ 1% and 1 Lpm<br>Ave. - 0.86%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.19% |
| BPR = 12<br>TV (ml) = 500 ml<br>CO2% - 5%<br>O2 Flow rate – 1 and 5 lpm | EtCO2 @ 5% and 1 Lpm<br>Ave. - 0.94%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. - 4.92% | EtCO2 @ 5% and 1 Lpm<br>Ave. - 4.22%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. - 4.07% | EtCO2 @ 5% and 1 Lpm<br>Ave. - 0.90%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. - 4.46% | EtCO2 @ 5% and 1 Lpm<br>Ave. - 0.79%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. - 3.59% |
| Pediatric | | | | |
| BPR = 20<br>TV (ml) = 300 ml<br>CO2% - 1%<br>O2 Flow rate – 1 and 5 lpm | EtCO2 @ 1% and 1 Lpm<br>Ave. 0.91%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.62% | EtCO2 @ 1% and 1 Lpm<br>Ave. - 0.82%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.02% | EtCO2 @ 1% and 1 Lpm<br>Ave. 0.87%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.67% | EtCO2 @ 1% and 1 Lpm<br>Ave. - 0.77%<br>EtCO2 @ 1% and 5 Lpm<br>Ave. - 4.01% |
| BPR = 20<br>TV (ml) = 300 ml<br>CO2% - 5%<br>O2 Flow rate – 1 and 5 lpm | EtCO2 @ 5% and 1 Lpm<br>Ave. - 0.88%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. - 4.60% | EtCO2 @ 5% and 1 Lpm<br>Ave. -0.81<br>EtCO2 @ 5% and 5 Lpm<br>Ave - 3.96% | EtCO2 @ 5% and 1 Lpm<br>Ave. 0.91%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. 4.06% | EtCO2 @ 5% and 1 Lpm<br>Ave. - 0.72%<br>EtCO2 @ 5% and 5 Lpm<br>Ave. 3.35% |
| Note: Testing of the Secondary Predicate for EtCO2 is not applicable as the device does not have this feature | | | | |
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### 510(k) Summary Page 8 of 9 20-Jun-18
| Feature | Proposed<br>SuperNO2VA EtTM<br>Both Nasal / Oral Sampling | Reference - Exempt<br>Medline Anesthesia mask<br>Both Nasal / Oral Sampling |
|---------------------|-----------------------------------------------------------|-----------------------------------------------------------------------------|
| Adult | | |
| BPR = 12 | EtCO2 @ 1% | EtCO2 @ 1% |
| TV (ml) = 500 ml | Ave. - 0.98% | Ave. - 0.97% |
| CO2% - 1% | | |
| Pressure - 20 cmH2O | | |
| BPR = 12 | EtCO2 @ 5% | EtCO2 @ 5% |
| TV (ml) = 500 ml | Ave. - 4.96% | Ave. - 4.90% |
| CO2% - 5% | | |
| Pressure - 20 cmH2O | | |
| Pediatric | | |
| BPR = 20 | EtCO2 @ 1% | EtCO2 @ 1% |
| TV (ml) = 300 ml | Ave. - 1.00% | Ave. - 0.95% |
| CO2% - 1% | | |
| Pressure - 20 cmH2O | | |
| BPR = 20 | EtCO2 @ 5% | EtCO2 @ 5% |
| TV (ml) = 300 ml | Ave. - 5.00% | Ave. - 4.62% |
| CO2% - 5% | | |
| Pressure - 20 cmH2O | | |
### Table 3 - Comparative O2 / CO2 Performance under Positive Pressure
Note: Testing of the Secondary Predicate for EtCO2 is not applicable as the device does not have this feature
#### Non-Clinical Testing Summary -
#### Bench Testing
We performed testing which evaluated the design. These tests included:
- . Dead space / volume
- Pressure drop
- Pressure and leakage ●
- O2 / CO2 performance at various simulated settings including positive pressure, oral / nasal sampling only
- . Age and shelf-life
- . Drop testing
### Biocompatibility
SuperNO2VATM based upon ISO 10993-1 is considered:
Surface Co…
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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.