K182116 · Cochlear Americas · MAH · Dec 19, 2018 · Ear, Nose, Throat
Device Facts
Record ID
K182116
Device Name
BA310 Abutment, BIA310 Implant/Abutment
Applicant
Cochlear Americas
Product Code
MAH · Ear, Nose, Throat
Decision Date
Dec 19, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 874.3302
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The Cochlear Baha Connect system is intended for treatment of patients who have conductive or mixed hearing loss as a result of certain medical conditions such as bilateral atresia and chronic supportive otitis media, and for those who have Single-Sided Deafness (SSD) caused by a congenital condition, surgery, trauma, or disease. The intended use of the system is to provide an osseointegrated fixation point for connection of an external sound processor. The intended use remains unchanged from the predicate device.
Device Story
Bone-anchored hearing system; provides osseointegrated fixation point for external sound processor. Implant surgically anchored in skull bone behind ear; sound processor generates vibrations transmitted via implant/abutment directly to skull bone/cochlea via bone conduction. BA310 abutment features modified flange and reduced core diameter (0.7mm) to enable compatibility with both Cochlear Baha and Oticon Medical Ponto sound processors. Used in clinical settings by surgeons/audiologists. Benefits patients with conductive/mixed hearing loss or SSD by bypassing damaged outer/middle ear structures to improve hearing. Output is amplified sound perceived via bone conduction.
Clinical Evidence
Bench testing only. No clinical data presented. Performance verified via non-clinical testing including rotation torque, snap force, bend force, and frequency testing to confirm mechanical compatibility between the BA310 abutment and both Cochlear Baha and Oticon Medical Ponto sound processors.
Technological Characteristics
Bone-anchored hearing system consisting of titanium-based implant and skin-penetrating abutment. BA310 abutment features modified flange and 0.7mm reduced core diameter. Mechanical coupling via snap-in mechanism. Compatible with Cochlear Baha and Oticon Medical Ponto sound processors. Non-electronic mechanical component.
Indications for Use
Indicated for patients aged 5+ with conductive or mixed hearing loss (bone-conduction thresholds <=45 dB HL for Baha 4/5, <=55 dB HL for Baha 5 Power, <=65 dB HL for Baha 5 SuperPower); bilateral fitting for symmetric moderate-to-severe conductive/mixed loss; unilateral sensorineural deafness (SSD) with normal hearing in contralateral ear (air-conduction threshold <=20 dB HL); or patients indicated for AC CROS hearing aids who cannot/will not use them.
Regulatory Classification
Identification
A bone-conduction hearing aid is a wearable sound-amplifying device intended to compensate for impaired hearing and that conducts sound to the inner ear through the skull. The non-implantable components of a bone-conduction hearing aid, such as the external sound processor, are subject to the requirements in § 801.422 of this chapter.
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December 19, 2018
Cochlear Americas Beth Murray Senior Regulatory Affairs Specialist 13059 E. Peakview Ave. Centennial, CO 80111
Re: K182116
Trade/Device Name: BA310 Abutment, BIA310 Implant/Abutment Regulation Number: 21 CFR 874.3300 Regulation Name: Hearing Aid Regulatory Class: Class II Product Code: MAH Dated: November 19, 2018 Received: November 20, 2018
Dear Beth Murray:
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.
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
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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 (feporting 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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) 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 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,
Srinivas Nandkumar -S
for Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose, and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
# 510(k) Number (if known)
K182116
#### Device Name
Cochlear Baha Connect System
#### Indications for Use (Describe)
The Cochlear Baha Connect System (Baha sound processors and implant/abutment system) is intended for the following patients and indications for use:
- Patients aged 5 and older
- Patients who have a conductive or mixed hearing loss and can still benefit from sound amplification. The pure tone average bone-conduction hearing thressured at 0.5, 1, 2, and 3kHz) should be better than or equal to 45 dB HL for use with the Baha 4 and Baha 5 sound processors. 55 db HL for use with the Baha 5 Power sound processors. and 65 db HL for use with the Baha 5 SuperPower Sound Processors.
- · Bilateral fitting is intended for patients who meet the above criterion in both ears, with bilaterally symmetric moderate to severe conductive or mixed hearing loss. Symmetrical bone-conductive thresholds are defined as 10 dB average difference between ears (measured at 0.5, 1, 2, and 3 kHz), or less than a 15dB difference at individual frequencies.
- · Patients who suffer from unilateral sensorineural deafness in one ear with normal hearing in the other ear (i.e. Singlesided deafness: SSD™). Normal hearing is defined as a pure tone average air-conduction hearing threshold (measured at 0.5, 1, 2, and 3 kHz) of better than or equal to 20 dB HL.
- · Baha for SSD is also indicated for any patient who is indicated for an air-conduction contralateral routing of signals (AC CROS) hearing aid, but who for some reason cannot or will not use an AC CROS.
Specific models of the Cochlear Baha abutments can be used with either the Cochlear Baha Connect System or compatible sound processors from Otical AB. Refer to the Cochlear Baha abutment labeling for a list of compatible Oticon Medical sound processors.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|
| <div> <span> <input checked="true" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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# 1. 510(k) Summary
# A. Submitter Information
| Submitted by: | Cochlear Americas<br>13059 East Peakview Ave.<br>Centennial, CO 80111 |
|--------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| On behalf of the manufacturer: | Cochlear Bone Anchored Solutions AB<br>Konstruktionsvägen 14<br>SE-435 33 Mölnlycke<br>Sweden<br>(Establishment Number 9616024) |
| Contact: | Beth Murray<br>Email: bemurray@cochlear.com<br>(303) 264-2318 (o)<br>(303) 524-6825 (f) |
#### Date Prepared August 02, 2018
# B. Device Name and Classification Information
| Trade Name: | Cochlear ™ Baha® Implant System |
|-----------------------|----------------------------------------------------------------------|
| Common or Usual Name: | Bone Conduction Hearing Implant System |
| Classification Name: | Hearing Aid, Bone Conduction, Implanted<br>21 CFR 874.3300, Class II |
| Classification Panel: | Ear, Nose, and Throat |
| Product Codes: | MAH |
# C. Predicate Devices:
| Device | 510(k) no. | Manufacturer |
|---------------------------------------------------------------|------------|----------------------------------------|
| BA300 Cochlear Baha Abutment<br>(primary predicate device) | K100360 | Cochlear Bone Anchored Solutions<br>AB |
| BA400 Cochlear Baha Abutment<br>(additional predicate device) | K121317 | Cochlear Bone Anchored Solutions<br>AB |
| Ponto System<br>(additional predicate device) | K161671 | Oticon Medical AB |
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## Device Description
# Intended Use
The Cochlear Baha Connect system is intended for treatment of patients who have conductive or mixed hearing loss as a result of certain medical conditions such as bilateral atresia and chronic supportive otitis media, and for those who have Single-Sided Deafness (SSD) caused by a congenital condition, surgery, trauma, or disease. The intended use of the system is to provide an osseointegrated fixation point for connection of an external sound processor. The intended use remains unchanged from the predicate device.
## Indications for Use
The Cochlear Baha Connect System (Baha sound processors and implant/abutment system) is intended for the following patients and indications for use:
- Patients aged 5 and older ●
- . Patients who have a conductive or mixed hearing loss and can still benefit from sound amplification. The pure tone average bone-conduction hearing threshold (measured at 0.5, 1, 2, and 3kHz) should be better than or equal to 45 dB HL for use with the Baha 4 and Baha 5 sound processors, 55 db HL for use with the Baha 5 Power sound processors, and 65 db HL for use with the Baha 5 SuperPower Sound Processors.
- Bilateral fitting is intended for patients who meet the above criterion in both ears, with bilaterally symmetric moderate to severe conductive or mixed hearing loss. Symmetrical bone-conductive thresholds are defined as less than a 10 dB average difference between ears (measured at 0.5, 1, 2, and 3 kHz), or less than a 15dB difference at individual frequencies.
- Patients who suffer from unilateral sensorineural deafness in one ear with normal hearing ● in the other ear (i.e. Single-sided deafness: SSD™). Normal hearing is defined as a pure tone average air-conduction hearing threshold (measured at 0.5, 1, 2, and 3 kHz) of better than or equal to 20 dB HL.
- Baha for SSD is also indicated for any patient who is indicated for an air-conduction ● contralateral routing of signals (AC CROS) hearing aid, but who for some reason cannot or will not use an AC CROS.
Specific models of the Cochlear Baha abutments can be used with either the Cochlear Baha Connect System or compatible sound processors from Oticon Medical AB. Refer to the Cochlear Baha abutment labeling for a list of compatible Oticon Medical sound processors.
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### Technological Characteristics
The BA310 abutments are modifications of the previously cleared BA300 abutments and provide additional sound processor compatibility than the previously cleared abutments. A bone anchored hearing system consists of a sound processor connected to an implant with a skin penetrating abutment. The implant is surgically anchored in the skull bone behind the ear. Vibrations generated by the sound processor are transmitted via the implant directly through the skull bone to the cochlea as bone conduction sound. Compared to the currently cleared BA300 and BA400 Abutments, a small "flange" has been added to the upper part of the BA310 Abutment and the core diameter of the abutment has been reduced by 0.7mm. This design allows sound processors from Oticon Medical to snap on the outside of the abutment while maintaining the same snap in coupling design for connection to Baha sound processors. It was identified that the design change may have an impact on the surgical procedure if changing from a BA300 or BA400 abutment to a BA310 abutment. It was also identified that due to the close contact between the soft tissue and the snap on coupling connection of the Oticon Sound Processor, there may be an impact on soft tissue reaction. Both of these potential issues are mitigated through recommendations added to the BA310 surgery guide and any residual risk is regarded as acceptable when weighed against the benefit of the Baha system.
### Performance Data
Pertinent dimensions of the BA310 Abutment were designed to permit compatibility between the Oticon Medical Ponto sound processors and BA310/BIA310 abutments/implants, and also between Cochlear Baha sound processors. The Cochlear Baha sound processor and Baha BA310 Abutment snap in coupling connection has been tested in cross combination with the Oticon Medical Ponto sound processor with snap on coupling connection. Rotation torque, snap force, bend force and frequency testing verifies the compatibility of both Oticon Medical Ponto sound processors and Cochlear Baha sound processors with the BA310 Abutment.
#### Substantial Equivalence
The Baha system with modified abutment has the same intended use, same indications, same principles of operations, and same materials as compared to the predicate Baha abutment. The only technological difference is a simple design change to the abutment. The updated labelling accounts for the abutment diameter change when changing from the BA300 or BA400 abutment to the BA310 abutment and accounts for the closer contact of Oticon Medical's sound processors snap coupling to the soft tissue. All design requirements were met and the conclusions drawn from non-clinical testing and analysis demonstrate the modified abutment is as safe, as effective, and performs as well as the previously cleared versions of the Baha system and Ponto abutment.
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The minor design change has been accounted for through labeling recommendations and verified as safe and effective through non-clinical testing. It can be concluded that the BA310/BIA310 Abutments are substantially equivalent.
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.