This sterile, single-use device is intended to be used as an accessory to medicinal nonventilatory nebulizers for respiratory therapy or for tracheal irrigation or lavage therapy. This device is not intended for parenteral use or for preparations intended for parenteral use. The use of this device requires prescription.
Device Story
Device is 3mL or 5mL Sodium Chloride Inhalation Solution USP, 0.9%; sterile, preservative-free, aqueous solution. Supplied in color-coded (pink) blow-fill-sealed low-density polyethylene (LDPE) unit-dose vials. Used as accessory to medicinal nonventilatory nebulizers for respiratory therapy or for tracheal irrigation/lavage. Operated by clinicians or patients under prescription. Provides saline for dilution of nebulized medications or irrigation. Benefits include sterile, convenient unit-dose delivery for respiratory care.
Clinical Evidence
No clinical data. Substantial equivalence demonstrated via in vitro analytical methods including assay, fill uniformity, sterility, and container integrity testing against USP monograph requirements.
Technological Characteristics
Materials: Low-density polyethylene (LDPE) meeting direct food/drug contact criteria. Formulation: 0.9% w/v Sodium Chloride USP in Water for Injection USP. Configuration: Blow-fill-sealed unit-dose vials (3mL or 5mL). Manufacturing: cGMP compliant Blow/Fill/Seal system. Sterilization: Sterile, preservative-free.
Indications for Use
Indicated for patients requiring respiratory therapy via medicinal nonventilatory nebulizers or tracheal irrigation/lavage. Not for parenteral use. Requires prescription.
Regulatory Classification
Identification
A nebulizer is a device intended to spray liquids in aerosol form into gases that are delivered directly to the patient for breathing. Heated, ultrasonic, gas, venturi, and refillable nebulizers are included in this generic type of device.
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Image /page/0/Picture/0 description: The image shows the logo for Nephron Pharmaceuticals Corporation. The logo consists of two Erlenmeyer flasks with tubes coming out of the top. To the right of the flasks is the text "nephron pharmaceuticals corporation" stacked on three lines.
JUN 1 9 2012
K 113 000 Section 5: 510(k) Summary
## Date Premarket Notification Summary was Prepared
This 510(k) premarket notification summary was prepared February 02, 2012 in conjunction with the notification.
# Applicant Name & Address
Nephron Pharmaceuticals Corporation 4121 SW 34th Street Orlando, FL 32811 (407) 246-1389 (407) 872-0001 Fax
# Contact Persons
Lou Kennedy President/CEO
Marcus Juliano Vice President, Quality Assurance & Regulatory Affairs (regulatory contact)
#### Kimberly Grevera
Manager, Regulatory Affairs (regulatory contact)
| Proprietary or<br>Trade Name: | Sodium Chloride Inhalation Solution USP, 0.9% |
|-------------------------------|--------------------------------------------------------------------------------|
| Common/Usual Name: | Saline Solution |
| Classification Name: | Nebulizer (Direct Patient Interface) - Accessory<br>CAF – 868.5630<br>Class II |
| Device: | Inhaled saline solution – 0.9% |
| Predicated Devices: | Holopack – K972466<br>Steripak – K980829 |
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Image /page/1/Picture/0 description: The image shows the logo for Nephron Pharmaceuticals Corporation. The logo features two Erlenmeyer flasks with tubes coming out of the top. The text "nephron pharmaceuticals corporation" is written to the right of the flasks.
Section 5: 510(k) Summary
## Device Description
The subject device is 3mL or 5 mL Sodium Chloride Inhalation Solution USP, 0.9%. The single-use device is a color-coded (pink) blow-fill-sealed, low density polyethylene (LDPE) vial containing sterile, preservative-free, clear, colorless, aqueous solution as labeled for inhalation therapy (respiratory therapy and tracheal lavage. For respiratory therapy, Sodium Chloride Inhalation Solution USP, 0.9% is used for dilution of solutions used in nebulizers. The product contains 0.9% w/v Sodium Chloride USP in Water for Injection USP. The formulation contains no additives.
| Contents | Volume | Container |
|-----------------------------------------------|----------|----------------------|
| 0.9% Sodium Chloride Inhalation Solution, USP | 3mL Fill | Pink, Embossed Label |
| 0.9% Sodium Chloride Inhalation Solution, USP | 5mL Fill | Pink, Embossed Label |
## Indications for Use
This sterile, single-use device is intended to be used as an accessory to medicinal nonventilatory nebulizers for respiratory therapy or for tracheal irrigation or lavage therapy.
## Limitations for Use
This device is not intended for parenteral use or for preparations intended for parenteral use. The use of this device requires prescription.
## Technological Characteristics of the Subject Device and Predicate Devices
The subject unit-dose device of this premarket notification is formed of polyethylene resins meeting the direct food and drug contact criteria. The formed units meet the criteria for direct food and drug contact as prefilled unit containers. The solution component, at the stated concentration of Sodium Chloride Inhalation Solution, meets the USP monograph requirements.
The single-use containers are embossed with identifying product text.
The finished device product configuration characteristics of this inhalation device are similar to those of the predicate devices.
The Blow/Fill/Seal system on which this device is manufactured represents technological advances in the production of this device for inhalation therapy and in the control of the manufacturing environment. This device is manufactured under conditions of current Good Manufacturing Practices (cGMP).
There are no technological differences between the subject device and predicate devices that raise new questions of safety and effectiveness. Performance characteristics of this device that is the subject of this notification are equal to or greater than the predicate devices.
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Image /page/2/Picture/0 description: The image shows the logo for Nephron Pharmaceuticals Corporation. The logo consists of two Erlenmeyer flasks on the left, with the word "nephron" above the words "pharmaceuticals corporation" on the right. The flasks are partially filled with a dark liquid.
Section 5: 510(k) Summary
# Nonclinical and Clinical Testing
The component materials of the accessory device container have been substantiated to each meet the criteria for direct food and drug contact or additive respectively. The formulation components of the filled device solution have been substantiated to each meet their respective USP monograph criteria. The finished device undergoes testing to meet the stated USP monograph and container criteria.
Clinical testing is not necessary to show substantial equivalence for either safety or efficacy of intended use to the predicate devices as there are several various in vitro analytical methods (assay; fill uniformity; sterility; container integrity) and physicalchemical characteristics (solution properties; unit configuration) available which demonstrate this equivalence.
Summary Conclusions
The subject device:
### 0.9% Sodium Chloride Inhalation Solution, USP
as manufactured by Nephron Pharmaceuticals Corporation of Orlando, FL claims substantial equivalence, with the same intended use, to several devices which have received market clearance through established equivalence.
This device is designed to meet current USP specifications. The device containers have embossed unit identification and shelf carton labeling so that label requirements are met.
Analytical testing to the stated specifications demonstrates that this device will have comparable safety and efficacy in use.
The device, as manufactured by Nephron, is produced using Blow Fill Seal technology specifically designed filling operations. These manufacturing systems represent a technological advance for the production of these types of devices.
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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 consists of a stylized eagle with three tail feathers, representing the department's mission to protect the health of all Americans and provide essential human services. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
# JUN 1 9 2012
Mr. Marcus Juliano Vice President Nephron Pharmaceutical Corporation 4121 S.W. 34th Street Orlando, Florida 32811-6475
Re: K113033
Trade/Device Name: Sodium Chloride Inhalation Solution USP. 0.9% Regulation Number: 21 CFR 868.5630 Regulation Name: Nebulizer Regulatory Class: II Product Code: CAF . Dated: May 3, 2012 Received: May 4, 2012
Dear Mr. Juliano:
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.
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# Page 2 - Mr. Juliano
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 (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); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Nh for
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
#### Enclosure
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Image /page/5/Picture/0 description: The image shows the logo for Nephron Pharmaceuticals Corporation. The logo features two Erlenmeyer flasks on the left side, with the company name written in a simple, sans-serif font to the right. The word "nephron" is on the top line, "pharmaceuticals" is on the second line, and "corporation" is on the third line.
Section 4: Indications for Use Statement
| 510(k) Number: | Not Known |
|----------------|-----------------------------------------------|
| Device Name: | Sodium Chloride Inhalation Solution USP, 0.9% |
### Indications for Use:
This sterile, single-use device is intended to be used as an accessory to medicinal nonventilatory nebulizers for respiratory therapy or for tracheal irrigation or lavage therapy.
This device is not intended for parenteral use or for preparations intended for parenteral use.
Prescription Use X (21 CFR 801 Subpart D) and/or
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
L. Schultheis
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: k113033
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.