K162611 · Spiration, Inc. · EOQ · Feb 9, 2017 · Ear, Nose, Throat
Device Facts
Record ID
K162611
Device Name
PeriFLEX
Applicant
Spiration, Inc.
Product Code
EOQ · Ear, Nose, Throat
Decision Date
Feb 9, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 874.4680
Device Class
Class 2
Indications for Use
This device is intended to be used through a compatible bronchoscope for the collection of tissue from the intrapulmonary regions. Do not use for any purpose other than its intended use.
Device Story
PeriFLEX Needle is a manual biopsy device used during bronchoscopy to collect tissue from intrapulmonary regions. The device consists of a handle, sheath, needle, and removable stylet. The user inserts the sheath and needle through the bronchoscope working channel to the target site; a manual needle slider on the handle extends and retracts the needle to puncture tissue and aspirate samples. A vacuum syringe and biopsy valve may be attached to assist collection. The stylet aids in sample removal. Used in surgical or endoscopy suites by physicians. The device features a laser-cut flexible distal tip to facilitate access to distal lesions and a smaller diameter for compatibility with modern bronchoscopes. It provides clinicians with tissue samples for diagnostic evaluation, potentially benefiting patients by enabling minimally invasive biopsy of lung tissue.
Clinical Evidence
Bench testing only. Performance verified through in vitro and ex vivo (bovine lung) testing. Tests included insertion/withdrawal forces, handle activation force, plastic deformation, transmission force, handle strength/durability, vacuum leak testing, and joint strength. Biocompatibility testing included cytotoxicity, sensitization, irritation, hemocompatibility, and pyrogenicity. Results met all pre-determined acceptance criteria.
Technological Characteristics
Materials: Stainless steel, PEBAX, PTFE, Nitinol. Manual operation. Single-lumen catheter. 21G needle size. Laser-cut distal tip for flexibility. Sterile, single-use. Sterilization: Ethylene Oxide. Compatible with standard bronchoscopes.
Indications for Use
Indicated for the collection of tissue from intrapulmonary regions in patients undergoing bronchoscopy. Used by or under the supervision of a physician.
Regulatory Classification
Identification
A bronchoscope (flexible or rigid) and accessories is a tubular endoscopic device with any of a group of accessory devices which attach to the bronchoscope and is intended to examine or treat the larynx and tracheobronchial tree. It is typically used with a fiberoptic light source and carrier to provide illumination. The device is made of materials such as stainless steel or flexible plastic. This generic type of device includes the rigid ventilating bronchoscope, rigid nonventilating bronchoscope, nonrigid bronchoscope, laryngeal-bronchial telescope, flexible foreign body claw, bronchoscope tubing, flexible biopsy forceps, rigid biopsy curette, flexible biopsy brush, rigid biopsy forceps, flexible biopsy curette, and rigid bronchoscope aspirating tube, but excludes the fiberoptic light source and carrier.
Predicate Devices
Wang MW-222 Transbronchial Aspiration Needle (K914181)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 9, 2017
Spiration, Inc. Aadarsh Viswanathan Regulatory Specialist 6675 185th Ave NE Redmond, Washington 98052
Re: K162611
Trade/Device Name: Periflex Regulation Number: 21 CFR 874.4680 Regulation Name: Bronchoscope (Flexible Or Rigid) And Accessories Regulatory Class: Class II Product Code: EOQ Dated: January 10, 2017 Received: January 11, 2017
Dear Aadarsh Viswanathan:
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 (reporting of medical devicerelated 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.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
Michael J. Ryan -S
for Tina Kiang, Ph.D. 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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# Indications for Use
510(k) Number (if known) K162611
Device Name PeriFLEX
Indications for Use (Describe)
This device is intended to be used through a compatible bronchoscope for the collection of tissue from the intrapulmonary regions. Do not use for any purpose other than its intended use.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary
## Submitter Information
| Date of 510(k) Summary Preparation: | February 3, 2017 |
|-------------------------------------|---------------------------------------------------------------------------------------------------------|
| Name and Address of Manufacturer: | Spiration, Inc.<br>6675 185th Avenue NE<br>Redmond, WA 98052 |
| Contact Person: | Aadarsh S. Viswanathan<br>Regulatory Affairs Specialist<br>Phone: (425) 636.5535<br>Fax: (425) 497.8802 |
## Subject Device
Device Trade Name: Common Name:
Classification: Regulation:
Product Code: Review Panel:
## Predicate Device
Trade Name: 510(k) Number: Manufacturer:
## Reference Device
Trade Name: 510(k) Number: Manufacturer:
Transbronchial Aspiration Needle III Bronchoscope (flexible or rigid) and accessories 21 CFR 874.4680
EOQ ENTB
PeriFLEX
Wang MW-222 Transbronchial Aspiration Needle K914181 Conmed, Inc.
Olympus NA-1C Needle K904667 Olympus Corporation
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## Device Description
The PeriFLEX Needle is intended to be used through a compatible bronchoscope for the collection of tissue from the intrapulmonary regions. The device is supplied sterile and intended for single patient use.
The main components of the device are a handle, a sheath, a needle, and a stylet. The sheath and needle (together termed the insertion portion) are attached to the handle. The removable stylet runs the full length of the device and fits inside the lumen of the handle and the needle.
The needle is housed within the sheath. These components, i.e., the insertion portion, are inserted into the working channel of the endoscope and advanced to the target site. The handle is connected to the insertion and has a needle slider component. The needle slider is controlled manually by the user to extend and retract the needle from the sheath at the target site. Once a sample is collected, the stylet may be used to assist with removing the sample from the needle.
The PeriFLEX Needle is available in one model only (PERIFLEX-21G), with a needle size of 21 gauge (21G). The PeriFLEX Needle can be used with the following accessories: vacuum syringe (to assist with sample collection), biopsy valve (to assist with creating a vacuum), and guide sheath (to extend the working length). However, these accessories are not included with the PeriFLEX Needle's packaging and must be obtained separately by the user.
## Indications for Use
The PeriFLEX Needle is intended to be used through a compatible bronchoscope for the collection of tissue from the intrapulmonary regions. Do not use for any purpose other than its intended use.
#### Comparison to Predicate Device
The PeriFLEX Needle is substantially equivalent to the chosen predicate, the Conmed Wang MW-222 Needle cleared under K914181. The PeriFLEX Needle has similar technological characteristics as the predicate device; there are no differences that raise different questions of safety and effectiveness relative to the predicate devices. Both devices operate in the same manner to obtain a tissue biopsy using a bronchoscope.
The primary difference between the subject and predicate device lies in the flexibility of the needle; the PeriFLEX Needle has a more flexible tip than the predicate device. Other differences between the subject device and the predicate device include a smaller diameter to facilitate compatibility with newer bronchoscopes with smaller working channels and a longer needle for better accessibility to distal lesions.
A detailed comparison of the PeriFLEX Needle, the chosen predicate device, and the reference device is provided in the following table.
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## Comparison of Predicates and the PeriFLEX Needle
| | PeriFLEX Needle | Conmed Wang MW-222<br>Needle | Olympus NA-1C Needle<br>(K904667) |
|-------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | (K162611) | (K914181) | (Reference Device) |
| | (Subject Device) | (Predicate Device) | |
| Intended Use<br>Statement | This device is intended to be<br>used through a compatible<br>bronchoscope for the<br>collection of tissue from the<br>intrapulmonary regions. Do<br>not use for any purpose<br>other than its intended use | Used to puncture the<br>trachobronchial wall and<br>aspirate sufficient tissue<br>and/or cell specimens to<br>stage bronchogenic<br>carcinoma. | These needles are intended<br>for endoscopic submucosal<br>and extra-bronchial<br>aspiration of tissue and<br>fluids. Do not use them for<br>any purpose other than their<br>intended function. |
| Anatomical Site | Lung | Lung | Lung |
| Use Conditions | Surgical suite, endoscopy or<br>bronchoscopy suite, used<br>with a bronchoscope | Surgical suite, endoscopy or<br>bronchoscopy suite, used<br>with a bronchoscope | Surgical suite, endoscopy or<br>bronchoscopy suite, used<br>with a bronchoscope |
| Intended User | By or under the supervision<br>of a physician | By or under the supervision<br>of a physician | By or under the supervision<br>of a physician |
| Mechanics of Action | Manual | Manual | Manual |
| Mode of Action | Single/multiple puncture and<br>aspirate | Single/multiple puncture and<br>aspirate | Single/multiple puncture and<br>aspirate |
| General Design | Handle, Sheath, Needle,<br>Stylet | Handle, Sheath, Needle,<br>Stylet | Handle, Sheath, Needle,<br>Stylet |
| Biocompatible | Yes | Yes | Yes |
| Patient Contacting<br>& Fluid Path<br>Materials | Stainless Steel, PEBAX,<br>PTFE, Nitinol | Stainless Steel, Teflon<br>(PTFE) | Information Not Available |
| Sterility | Sterile | Sterile | Sterile (the sheath must be<br>sterilized before use by the<br>user) |
| Sterilization Method | Ethylene Oxide | Information Not Available | Ethylene Oxide (30%)/CO2<br>(70%) |
| Single Use Only | Single Use Only | Single-Use Only | Single Use Needle Section,<br>Reusable Sheath |
| Working OD (mm) | 1.5 | 1.9 | 1.8 |
| Catheter Length<br>(cm) | 115 | 140 | 105 |
| Catheter Cross<br>Section | Single Lumen | Single and Double Lumen<br>Available | Single Lumen |
| | PeriFLEX Needle<br>(K162611)<br>(Subject Device) | Conmed Wang MW-222<br>Needle<br>(K914181)<br>(Predicate Device) | Olympus NA-1C Needle<br>(K904667)<br>(Reference Device) |
| Needle Gauge<br>(Size) | 21G | 22G | 21G |
| Needle Tip Material | Stainless Steel | Stainless Steel | Stainless Steel |
| Needle Length<br>(mm) | 20 | 13 | 13 |
| Needle Flexibility | Distal 20 cm flexible due to<br>laser-cut. | Information Not Available | Not designed for greater<br>flexibility |
| Stylet OD (in) | 0.0185 | Information Not Available | 0.0115 |
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## Performance Data
Device performance of the PeriFLEX Needle was verified through in vitro (bench) and ex vivo testing. Testing was designed to mimic stresses encountered in a clinical setting met the pre-determined acceptance criteria as outlined in the test protocols.
Sheath and Needle Insertion and Withdrawal Force Stylet Insertion and Withdrawal Force Bronchoscope Angulation Handle Activation Force Plastic Deformation Angle Transmission Force Handle Assembly Strength Handle Durability Durability Vacuum Leak Test Sheath to Handle Joint Strength Biopsy Sample Size1 Simulated use - ex vivo (bovine lung) bench testing
1 For direct comparison to a reference device, testing was also conducted on the Olympus NA-1C Needle
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Additional Testing of the PeriFLEX Needle to Support Safety and Effectiveness
- Sterilization Validation Product Adoption Comparative Resistance Packaging and Shelf Life Biocompatibility Cytotoxicity (MEM Elution) Sensitization (Magnusson-Kligman Method) Irritation (Intracutaneous Toxicity) Hemocompatibility (Indirect and Direct Contact) Toxicity Pyrogenicity
The results from this testing demonstrate that the performance and technological characteristics of the PeriFLEX Needle meet defined design requirements and that the device performs equivalently to the predicate aspiration needles.
## Conclusion (Statement of Equivalence)
The data and information presented within this 510(k) Premarket Notification (including in vitro bench and ex vivo testing) support a determination of substantial equivalence of the PeriFLEX Needle to the cleared Conmed Wang MW-222 Needle.
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.