Bio-MEM Ti Reinforced membranes are an implantable temporary non-resorbable device (membrane) for use as a spacer creation barrier in the treatment of local defects in the oral cavity in conjunction with tissue regeneration or augmentation. Bio-MEM Ti Reinforced membranes are intended to be submerged and clinically implanted more than 30 days and no longer than 6 months.
Device Story
Bio-MEM Ti Reinforced membrane is a non-resorbable, implantable barrier device; consists of shapeable titanium frame enveloped by embossed polytetrafluoroethylene (PTFE) membrane. Used in oral surgery to prevent gingival soft tissue ingrowth into bony defects; facilitates neovascularization and bone formation during repair. Provided sterile in various anatomical shapes/sizes; intended for submersion and implantation for 30 days to 6 months. Clinician trims/shapes device to fit defect; titanium reinforcement provides space-making and shape-maintenance to minimize movement and exposure during healing. Benefits patient by supporting predictable bone regeneration in oral defects.
Clinical Evidence
No clinical data required. Evidence based on bench testing, including bend and delamination testing, sterilization validation, packaging validation, and comprehensive biocompatibility testing (cytotoxicity, sensitization, irritation, acute systemic toxicity, pyrogenicity, genotoxicity, and implantation) per ISO 10993 standards.
Technological Characteristics
Non-resorbable barrier membrane; materials: PTFE (ASTM D4895) and titanium frame. Thickness: 0.25mm; Density: 3.5g/dm². Sterilization: Ethylene Oxide (ISO 11135). Form factor: various anatomical shapes/sizes, trimmable. Standalone device.
Indications for Use
Indicated for patients requiring a spacer creation barrier for treatment of local oral cavity defects in conjunction with tissue regeneration or augmentation. Intended for submersion and implantation for >30 days up to 6 months.
Regulatory Classification
Identification
Bone grafting material is a material such as hydroxyapatite, tricalcium phosphate, polylactic and polyglycolic acids, or collagen, that is intended to fill, augment, or reconstruct periodontal or bony defects of the oral and maxillofacial region.
Special Controls
*Classification.* (1) Class II (special controls) for bone grafting materials that do not contain a drug that is a therapeutic biologic. The special control is FDA's “Class II Special Controls Guidance Document: Dental Bone Grafting Material Devices.” (See § 872.1(e) for the availability of this guidance document.)(2) Class III (premarket approval) for bone grafting materials that contain a drug that is a therapeutic biologic. Bone grafting materials that contain a drug that is a therapeutic biologic, such as biological response modifiers, require premarket approval.
(c)
*Date premarket approval application (PMA) or notice of product development protocol (PDP) is required.* Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
B&Medi Co., Ltd. Taesu Kwon, CEO 56-33, Chukhang-daero 296Beon-gil, Jung-gu Incheon, Incheon 22339 KOREA. SOUTH
8/18/22
Re: K210797
Trade/Device Name: Bio-MEM Ti Reinforced Membrane Regulation Number: 21 CFR 872.3930 Regulation Name: Bone Grafting Material Regulatory Class: Class II Product Code: NPK Dated: March 11, 2021 Received: March 16, 2021
Dear Taesu Kwon:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination 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.
{1}------------------------------------------------
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-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.
Andrew Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic. Anesthesia. Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
## Indications for Use
510(k) Number (if known) K210797
Device Name
Bio-MEM Ti Reinforced membrane
#### Indications for Use (Describe)
Bio-MEM Ti Reinforced membranes are an implantable temporary non-resorbable device (membrane) for use as a spacer creation barrier in the treatment of local defects in the oral cavity in conjunction with tissue regeneration or augmentation. Bio-MEM Ti Reinforced membranes are intended to be submerged and clinically implanted more than 30 days and no longer than 6 months.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------------------------------------------------------------------------------------------------|
| <div style="display:flex; align-items:center;"><span style="margin-right:5px;">☑</span>Prescription Use (Part 21 CFR 801 Subpart D)</div> |
| <div style="display:flex; align-items:center;"><span style="margin-right:5px;">☐</span>Over-The-Counter Use (21 CFR 801 Subpart C)</div> |
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
## 510(k) Summary
### 1. Submitter
| Name: | B&Medi Co., Ltd. |
|---------------------|-----------------------------------------------------------------------|
| Address: | 56-33, Chukhang-daero 296Beong-gil, Jung-gu,<br>Incheon, 22339, Korea |
| Tel/ Fax: | Tel: 82-2-6295-0085, Fax : 82-2-6295-0085 |
| Contact: | Taesu Kwon/CEO, Email : cms@bnmedi.com |
| Date of Submission: | Aug 18, 2022 |
### 2. Device
| Trade/Device Name: | Bio-MEM Ti Reinforced Membrane |
|--------------------|---------------------------------|
| Common name: | Non-Resorbable Barrier Membrane |
| Regulation Number: | 21 CFR 872. 3930 |
| Regulation name: | Barrier, Synthetic, Intraoral |
| Regulation Class: | II |
| Product Code : | NPK |
### 3. Predicate Device
Primary Predicate Device : Neoss Ti Reinforced Membrane (K143327, Neoss, Ltd) Reference Predicate Device : Cytoplast Regentex™ Titanium 250 (K972278 ; Osteogenics Biomedical Co.,Ltd)
### 4. Description
Bio-MEM Ti Reinforced membranes are non-resorbable membranes available as Tireinforced configured of a highly shapeable Ti (Reinforced only) enveloped by an embossed polytetrafluoroethylene (PTFE) membrane. Extensive documentation demonstrates tissue compatibility of PTFE. Bio-MEM Ti Reinforced membranes are designed to avoid ingrowth of gingival soft tissue into bony defects, in order to facilitate the neovascularization and bone formation during the repair process of the defect. Bio-MEM Ti Reinforced membranes are provided STERILE and in different anatomical shapes and sizes. The titanium reinforcement is intended for space creating and shapemaintaining which minimize movements and subsequent exposure during the regenerative healing.
{4}------------------------------------------------
Image /page/4/Figure/0 description: The image shows a table with the dimensions of a component labeled PM1224A. The table lists the model number, and then the dimensions A, B, C, and D in millimeters, as well as the thickness E. The dimensions for model PM1224A are: A=24.0 mm, B=12.0 mm, C=11.0 mm, D=2.5 mm, and E=0.25 mm.
Image /page/4/Figure/1 description: The image shows a diagram of a PM1424A model with labeled dimensions. The diagram includes measurements for A, B, C, D, E, and F (thickness). According to the table, the dimensions are as follows: A is 24.0 mm, B is 14.0 mm, C is 14.84 mm, D is 8.89 mm, E is 1.59 mm, and F (thickness) is 0.25 mm.
Image /page/4/Figure/2 description: The image shows a diagram of a PM1725A model with its dimensions labeled. The diagram includes measurements for A, B, C, D, E, and F (Thickness). According to the table, the dimensions are as follows: A is 25.0 mm, B is 17.0 mm, C is 18.36 mm, D is 8.83 mm, E is 2.0 mm, and F (Thickness) is 0.25 mm.
{5}------------------------------------------------
Image /page/5/Figure/0 description: The image shows a diagram of a PM2025A model with labeled dimensions, accompanied by a table that lists the specifications. The table includes the model number PM2025A, and the dimensions A, B, C, D, and E, with corresponding values of 20.0 mm, 25.0 mm, 15.99 mm, 10.0 mm, and 1.5 mm, respectively. The thickness F is listed as 0.25.
Image /page/5/Figure/1 description: The image shows a diagram of a part with labeled dimensions, accompanied by a table providing specific measurements for two different models. The diagram labels the dimensions as A, B, C, D, E, and F. The table lists the models PM1319A and PM1318A, along with their corresponding measurements in millimeters: A(mm), B(mm), C(mm), D(mm), E(mm), and F(Thickness).
Image /page/5/Figure/2 description: The image shows a diagram of a shape with labeled dimensions, along with a table providing specific measurements for a model. The shape appears to be a rounded square, with dimensions labeled as A, B, C, D, E, and F. The table lists the model PM2530A and provides corresponding measurements: A is 30.0 mm, B is 25.0 mm, C is 17.57 mm, D is 12.65 mm, E is 1.3 mm, and F (thickness) is 0.25 mm.
{6}------------------------------------------------
Image /page/6/Figure/0 description: The image shows a diagram of a shape with labeled dimensions, accompanied by a table providing specific measurements for two models. The diagram illustrates the shape with dimensions labeled as A, B, C, D, E, and F. The table lists the models PM3040S2 and PM3040SA, along with their corresponding measurements in millimeters: A(mm) is 30.0 for both, B(mm) is 40.0 for both, C(mm) is 22.0 and 19.0, D(mm) is 18.0 and 16.0, E(mm) is 2.0 for both, and F(Thickness) is 0.25 for both.
Image /page/6/Figure/1 description: The image shows a diagram of a PM3040A model with labeled dimensions. The diagram includes measurements for A, B, C, D, E, and F (Thickness). A table below the diagram lists the values for each dimension, with A being 40.0 mm, B being 30.0 mm, C being 26 mm, D being 20.93 mm, E being 2.22 mm, and F (Thickness) being 0.25 mm.
Image /page/6/Figure/2 description: The image shows a technical drawing of an object with labeled dimensions, accompanied by a table providing specific measurements. The table includes the model number PM2536A, along with dimensions A, B, C, D, E, and F in millimeters. The corresponding measurements are 25.0, 36.0, 15.99, 10.13, 1.5, and 0.25 respectively.
O B&Medi
{7}------------------------------------------------
Image /page/7/Figure/0 description: The image shows a technical drawing of an object with labeled dimensions, accompanied by a table providing specific measurements. The table includes the model number PM3041A, along with dimensions A, B, C, D, E, and F in millimeters. The corresponding values are 30.0, 41.0, 18.97, 12.92, 1.4, and 0.25 respectively.
Image /page/7/Figure/1 description: The image shows a technical drawing of a part with dimensions labeled A, B, C, and D. A table below the drawing provides specific measurements for a model named PMB2431. The table indicates that for model PMB2431, A is 31.0 mm, B is 24.0 mm, C is 19.0 mm, D is 3.5 mm, and the thickness E is 0.25 mm.
Image /page/7/Figure/2 description: The image shows a technical drawing of a part with dimensions labeled A, B, C, D, and E. A table below the drawing provides specific measurements for the part, identified as model PMB2030. According to the table, dimension A is 30.0 mm, B is 20.0 mm, C is 14.7 mm, D is 8.6 mm, and the thickness (E) is 0.25 mm.
Image /page/7/Picture/3 description: The image shows the logo for B&Medi. The logo consists of a stylized symbol to the left of the text "B&Medi". The symbol appears to be an abstract representation of a medical device or a stylized heart. The text "B&Medi" is written in a sans-serif font and is dark blue.
{8}------------------------------------------------
Image /page/8/Figure/0 description: The image shows a diagram of a part with labeled dimensions, along with a table providing specific measurements. The table includes the model number PMB2228 and lists the dimensions A, B, C, and D in millimeters, as well as the thickness E. The corresponding values are: A=28.0 mm, B=22.0 mm, C=19.3 mm, D=9.2 mm, and E=0.25.
Image /page/8/Figure/1 description: The image shows a table with the dimensions of a PMB2530S model. The table includes the model number, and the dimensions A, B, C, and D in millimeters. The thickness E is also provided. The dimensions are as follows: A is 30.0 mm, B is 25.0 mm, C is 16.8 mm, D is 10.6 mm, and the thickness E is 0.25.
| | | | C | | | |
|----|---------|-------|-------|-------|-------|--------------|
| No | Model | A(mm) | B(mm) | C(mm) | D(mm) | E(Thickness) |
| 17 | PMB1319 | 19.0 | 13.0 | 14.0 | 9.0 | 0.25 |
| 18 | PMB1318 | 18.0 | 13.0 | 13.4 | 8.5 | 0.25 |
Image /page/8/Picture/3 description: The image shows the logo for B&Medi. The logo consists of a stylized symbol resembling two overlapping hearts or leaves, followed by the text "B&Medi" in a bold, sans-serif font. The color of both the symbol and the text is a dark blue.
{9}------------------------------------------------
Image /page/9/Figure/0 description: The image shows a technical drawing of a part with dimensions labeled A, B, C, and D. A table below the drawing lists the dimensions for a specific model, PMB3338. The table indicates that for model PMB3338, dimension A is 38.0 mm, B is 33.0 mm, C is 19.8 mm, D is 14.85 mm, and the thickness E is 0.25 mm.
Image /page/9/Figure/1 description: The image shows a diagram of a PMB3040S model. The diagram includes measurements for A, B, C, D, and E. According to the table, the A measurement is 40.0 mm, B is 30.0 mm, C is 28.2 mm, D is 17.1 mm, and E (thickness) is 0.25.
Image /page/9/Figure/2 description: The image shows a diagram of a PMB3040 model with its dimensions labeled. The diagram includes labels A, B, C, D, and E, which correspond to the dimensions listed in the table below the diagram. According to the table, the PMB3040 model has the following dimensions: A(mm) = 40.0, B(mm) = 30.0, C(mm) = 26.8, D(mm) = 25.03, and E(Thickness) = 0.25.
{10}------------------------------------------------
Image /page/10/Figure/0 description: The image shows a diagram of a part with labeled dimensions. The dimensions are labeled as A, B, C, D, and E. A table below the diagram lists the dimensions for a specific model, PMB2536. The table indicates that A is 25.0 mm, B is 36.0 mm, C is 16.59 mm, D is 10.6 mm, and E (thickness) is 0.25.
Image /page/10/Figure/1 description: The image shows a technical drawing of a part with dimensions labeled A, B, C, D, and E. A table below the drawing provides specific measurements for each dimension. According to the table, for Model PMB3041, A is 30.0 mm, B is 41.0 mm, C is 19.8 mm, D is 14.85 mm, and E (Thickness) is 0.25.
| No | Model | A(mm) | B(mm) | C(mm) | D(mm) | E(Ø) | F(Thickness) |
|----|---------|-------|-------|-------|-------|------|--------------|
| 24 | PMB2021 | 19.8 | 20.71 | 10.7 | 13.35 | 2.7 | 0.25 |
{11}------------------------------------------------
Image /page/11/Figure/0 description: The image shows a diagram of a PMB2325 model with various dimensions labeled A through F. The corresponding table lists the dimensions for the PMB2325 model. Dimension A is 25.16 mm, B is 23.56 mm, C is 9.15 mm, D is 14.02 mm, E is 2.7 mm, and F is 0.25 mm.
Image /page/11/Figure/1 description: The image shows a table with the dimensions of a model. The model number is PMB2029. The table lists the following dimensions: A(mm) is 19.82, B(mm) is 29, C(mm) is 9.85, D(mm) is 17, E(Ø) is 2.7, and F(Thickness) is 0.25.
Image /page/11/Figure/2 description: The image shows a diagram of a PMB2127 model with various dimensions labeled A through F. A(mm) is 21.44, B(mm) is 15.59, C(mm) is 8.91, and D(mm) is 15.59. E(Ø) is 2.7, and F(Thickness) is 0.25. The diagram includes a shape with circular patterns inside.
{12}------------------------------------------------
| No | Model | A(mm) | B(mm) | C(mm) | D(mm) | E(Ø) | F(Thickness) |
|----|---------|-------|-------|-------|-------|------|--------------|
| 28 | PMB2830 | 28.4 | 30 | 18.4 | 20 | 2.7 | 0.25 |
| 29 | PMB2025 | 24.9 | 20 | 14.9 | 10 | 2.7 | 0.25 |
| 30 | PMB2028 | 28.4 | 20 | 18.4 | 10 | 2.7 | 0.25 |
| 31 | PMB2530 | 24.9 | 30 | 14.9 | 20 | 2.7 | 0.25 |
### 5. Indication for use
Bio-MEM Ti Reinforced membranes are an implantable temporary non-resorbable device (membrane) for use as a spacer creation barrier in the treatment of local defects in the oral cavity in conjunction with tissue regeneration or augmentation. Bio-MEM Ti Reinforced membranes are intended to be submerged and clinically implanted more than 30 days and no longer than 6 months.
## 6. Comparison with Primary Predicate Device and Reference Predicate Device
| Subject | Subject Device | Primary Predicate Device | Reference<br>Predicate Device | Comment |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| Product<br>Name | Bio-MEM Ti reinforced<br>Membrane | Neoss Ti-Reinforced<br>Membrane | Cytoplast Regentex™<br>Titanium 250 | |
| 510(k) | K210797 | K143327 | K972278 | |
| Manufacturer | B&Medi Co., Ltd. | Neoss, Ltd | Osteogenics<br>biomedical Co., Ltd | |
| Indications<br>for use | Bio-MEM Ti Reinforced<br>membranes are an implantable<br>temporary non- resorbable<br>device (membrane) for use as a<br>spacer creation barrier in the<br>treatment of local defects in<br>the oral cavity in conjunction<br>with tissue regeneration or<br>augmentation. Bio-MEM Ti<br>Reinforced membranes are<br>intended to be submerged and<br>clinically implanted more than<br>30 days and no longer than 6<br>months. | Ti Reinforced Membrane is an<br>implantable temporary non-<br>resorbable device (membrane) for<br>use as a spacer creation barrier in<br>the treatment of local defects in<br>the oral cavity in conjunction with<br>tissue regeneration or<br>augmentation. Neoss membranes<br>are intended to be submerged and<br>clinically implanted more than 30<br>days with an expected duration of<br>implantation up of 6 months. | A Temporarily implantable<br>material (non-resorbable)<br>for use as a space-making<br>barrier in the treatment of<br>periodontal defects. | Wording<br>is similar<br>and<br>principle<br>of<br>operation<br>is the<br>same |
{13}------------------------------------------------
| Code | NPK | NPK | LYC | |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------|----------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Design | A variety of configurations.<br>May be trimmed and shaped to<br>fit bone defect. For further<br>information, please see 4.<br>Description | 5 configurations. May be<br>trimmed and shaped to fit<br>bone defect. | 8 configurations. May be<br>trimmed and shaped to fit bone<br>defect | Geometries<br>are similar to<br>the predicate<br>and reference<br>devices.<br>Thickness<br>and density<br>are within the<br>range of<br>predicate and<br>reference<br>devices.<br>Usage and<br>sterilization<br>are the same. |
| Material | PTFE<br>(Polytetrafluoroethylene)<br>membranes reinforced with a<br>Titanium frame | ePTFE and dense PTFE<br>membranes reinforced with a<br>Titanium frame | High density PTFE<br>membranes reinforced with a<br>Titanium frame | |
| Thickness | 0.25mm | 0.3mm | 0.23mm | |
| Density | 3.5g/d m² | 3.5g/d m² | 4.0g/d m² | |
| Usage | Single use only | Single use only | Single use only | |
| Biocompa<br>tibility | Yes | Yes | Yes | |
| Sterilizati<br>on | EO Gas Sterilization | EO Gas Sterilization | EO Gas Sterilization | |
## 7. Technological Characteristics
As summarized in the comparison Table above, the geometries of Bio-MEM Ti Reinforced membranes are similar to the primary predicate device, Neoss Ti-Reinforced Membrane and the reference device, Cytoplast Regentex™ Titanium 250 as featured in the labeling for the predicate and reference devices. The thickness and density are in the range of the predicate and reference devices. Both the subject and predicate devices are comprised of biocompatible nonresorbable PTFE and Titanium and biocompatibility tests (see 8. Performance Testing) support substantially equivalent biocompatibility. The PTFE material of Bio-MEM device is similar in density (mass/area) and thickness to both the predicate and reference devices. The dense material of the Bio-MEM membrane is similar to the Cytoplast membrane. The intended use, principle of operation, and sterilization are the same between the subject and predicate devices.
### 8. Performance Testing
The Bio-MEM Ti Reinforced Membrane was evaluated for Bend and Delamination Testing in order to confirm the strength, integrity and functionality of the device. Sterilization validation and packaging validation were conducted to support EO sterilization and packaging shelf-life of 5 years. Cytotoxicity, sensitization, irritation, acute systemic toxicity, material-mediated pyrogenicity, genotoxicity (AMES and micronucleus), and implantation testing support biocompatibility of the subject device.
The subject device and processes were tested according to the following standards:
- � ISO 10993-3 (2014) Biological evaluation of medical devices Part3, Test for Genotoxicity, Carcinogenicity and Reproductive Toxicity.
- � ISO 10993-5 Biological Evaluation Of Medical Devices: Test for in vitro
# () B&Medi
{14}------------------------------------------------
cytotoxicity
- � ISO 10993-6(2007) Biological evaluation of medical devices - Part 6: Tests for local effects after implantation.
- � ISO 10993-7[2008] Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals
- � ISO 10993-10 Biological evaluation of medical devices - part 10: tests for irritation and skin sensitization
- � ISO 10993-10 Biological evaluation of medical devices - part 11: tests for systemic toxicity, 5 Acute systemic toxicity
- ISO 11135 [2014] Validation and routine control of ethylene oxide sterilization �
- � ASTM D4895 - 10 Standard Specification for Polytetrafluoroethylene (PTFE) Resin Produced From Dispersion
- � ISO11607, ISO11737, ASTM F1980, ASTM F88, ASTM F1929:2012. Standards which the tests were used in the packaging validation.
- � USP 29 Biological tests <151> Pyrogen Test
## 9. Clinical Testing
Clinical Data was not required to establish the substantial equivalence of the Bio-MEM Ti Reinforced Membrane.
### 10. Conclusion
The Bio-MEM Ti Reinforced Membrane is similar to legally marketed devices listed previously in that they share similar indications for use and incorporate similar technological characteristics. All evaluations determined that the Bio-MEM Ti Reinforced Membrane is substantially equivalent to the predicate devices.
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.