K152953 · Fresenius Medical Care North America · KOC · Nov 5, 2015 · Gastroenterology, Urology
Device Facts
Record ID
K152953
Device Name
CRIT-LINE CLIP (CLIC) BLOOD CHAMBER
Applicant
Fresenius Medical Care North America
Product Code
KOC · Gastroenterology, Urology
Decision Date
Nov 5, 2015
Decision
SESE
Submission Type
Special
Regulation
21 CFR 876.5820
Device Class
Class 2
Indications for Use
The CRIT-LINE Clip (CLiC) Blood Chamber is a sterile, single use, disposable, optical cuvette designed for use with the CLiC Monitor's sensor clip during acute and chronic hemodialysis therapy. The CLiC system non-invasively measures hematocrit and oxygen saturation. The percentage change in blood volume is calculated from the real time hematocrit. The blood chamber is connected between the arterial bloodline and the dialyzer within the extracorporeal circuit during hemodialysis treatments.
Device Story
The CRIT-LINE Clip (CLiC) Blood Chamber is a sterile, single-use, disposable optical cuvette; it functions as a component of the extracorporeal circuit in hemodialysis. The device is installed between the arterial bloodline and the dialyzer. It features clear polycarbonate lenses that provide a viewing window for the CLiC Monitor's sensor clip. The monitor transmits light through the blood within the chamber; it uses light absorption and scattering principles to measure hematocrit and oxygen saturation. Percent change in blood volume is calculated from real-time hematocrit data. The device is used in clinical settings by healthcare providers to monitor patient blood parameters during dialysis, aiding in clinical decision-making regarding fluid management and treatment adjustments. The current modification involves a change to the internal geometry (taper) of the dialyzer connector.
Clinical Evidence
Bench testing only. No clinical data was required or provided. Verification testing included structural integrity, liquid/air leakage, separation force, unscrewing torque, ease of assembly, resistance to overriding, stress cracking, endurance performance, bond strength, and priming volume tests, all of which passed.
Technological Characteristics
Materials: clear polycarbonate (lenses), blue polycarbonate (body), PVC (DIN connector). Sensing principle: optical light absorption/scattering via CLiC Monitor. Form factor: disposable cuvette with male Luer-lock and female conical DIN connector. Connectivity: interfaces with CLiC Monitor sensor clip. Sterilization: Gamma radiation. Standards: ISO 594-2, ISO 8638:2010.
Indications for Use
Indicated for use during acute and chronic hemodialysis therapy to non-invasively measure hematocrit, percent change in blood volume, and oxygen saturation in patients undergoing hemodialysis treatment.
Regulatory Classification
Identification
A hemodialysis system and accessories is a device that is used as an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and that consists of an extracorporeal blood system, a conventional dialyzer, a dialysate delivery system, and accessories. Blood from a patient flows through the tubing of the extracorporeal blood system and accessories to the blood compartment of the dialyzer, then returns through further tubing of the extracorporeal blood system to the patient. The dialyzer has two compartments that are separated by a semipermeable membrane. While the blood is in the blood compartment, undesirable substances in the blood pass through the semipermeable membrane into the dialysate in the dialysate compartment. The dialysate delivery system controls and monitors the dialysate circulating through the dialysate compartment of the dialyzer.(1) The extracorporeal blood system and accessories consists of tubing, pumps, pressure monitors, air foam or bubble detectors, and alarms to keep blood moving safely from the blood access device and accessories for hemodialysis (§ 876.5540) to the blood compartment of the dialyzer and back to the patient. (2) The conventional dialyzer allows a transfer of water and solutes between the blood and the dialysate through the semipermeable membrane. The semipermeable membrane of the conventional dialyzer has a sufficiently low permeability to water that an ultrafiltration controller is not required to prevent excessive loss of water from the patient's blood. This conventional dialyzer does not include hemodialyzers with the disposable inserts (Kiil type) (§ 876.5830) or dialyzers of high permeability (§ 876.5860). (3) The dialysate delivery system consists of mechanisms that monitor and control the temperature, conductivity, flow rate, and pressure of the dialysate and circulates dialysate through the dialysate compartment of the dialyzer. The dialysate delivery system includes the dialysate concentrate for hemodialysis (liquid or powder) and alarms to indicate abnormal dialysate conditions. This dialysate delivery system does not include the sorbent regenerated dialysate delivery system for hemodialysis (§ 876.5600), the dialysate delivery system of the peritoneal dialysis system and accessories (§ 876.5630), or the controlled dialysate delivery system of the high permeability hemodialysis system § 876.5860). (4) Remote accessories to the hemodialysis system include the unpowered dialysis chair without a scale, the powered dialysis chair without a scale, the dialyzer holder set, dialysis tie gun and ties, and hemodialysis start/stop tray.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 5, 2015
Fresenius Medical Care North America Denise Oppermann Sr. Director, Regulatory Affairs 920 Winter Street Waltham, MA 02451-1457
Re: K152953
> Trade/Device Name: CRIT-LINE Clip (CLiC) Blood Chamber Regulation Number: 21 CFR§ 876.5820 Regulation Name: Hemodialysis system and accessories Regulatory Class: II Product Code: KOC Dated: October 6, 2015 Received: October 7, 2015
Dear Denise Oppermann,
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.
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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 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 vours.
Herbert P. Lerner -S
for
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K152953
Device Name CRIT-LINE Clip (CLiC) Blood Chamber
### Indications for Use (Describe)
The CRIT-LINE Clip (CLiC) Blood Chamber is a sterile, single use, disposable, optical cuvette designed for use with the CLiC Monitor's sensor clip during acute and chronic hemodialysis therapy to non-invasively measure hematocrit, percent change in blood volume, and oxygen saturation. The blood chamber is connected between the arterial bloodline and the dialyzer within the extracorporeal circuit during hemodialysis treatment.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
| <span style="font-size:100%;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-size:100%;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the Fresenius Medical Care logo. On the left side of the logo, there is a blue symbol that consists of three downward-pointing chevrons stacked on top of each other. To the right of the symbol, the words "FRESENIUS MEDICAL CARE" are written in blue, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.
#### 510(K) SUMMARY 5.
This 510(k) Summary is in accordance with the requirements of the Safe Medical Device Act (SMDA) of 1990. The content of this 510(k) summary is provided in conformance with 21 CFR & 807.92.
#### 5.1. Submitter's Information
| Name: | Fresenius Medical Care Renal Therapies Group, LLC |
|-------------------|-------------------------------------------------------------------|
| Address: | 920 Winter Street<br>Waltham, MA<br>02451-1457 |
| Phone: | (781) 699-4479 |
| Fax: | (781) 699-9635 |
| Contact Person: | Denise Oppermann, Senior Director<br>Regulatory Affairs – Devices |
| Preparation Date: | 10/06/2015 |
#### 5.2. Device Name
| Trade Name: | CRIT-LINE® Clip (CLiC) Blood Chamber |
|------------------------------------|------------------------------------------|
| Common Name: | CLiC Blood Chamber |
| Classification Name : | Accessories, Blood Circuit, Hemodialysis |
| Regulatory Class: | Class II per 21 CFR 876.5820 |
| Product Code/Classification Panel: | KOC / Gastroenterology-Urology |
#### 5.3. Legally Marketed Predicate Device
The predicate device is FMC-RTG's CRIT-LINE Clip (CLiC) Blood Chamber originally cleared under K141281 (14 August 2014).
#### Device Description 5.4.
Like the predicate, the modified CRIT LINE Clip (CLiC) Blood Chamber is a non-invasive, disposable, optical cuvette with transparent lenses designed to connect between the arterial bloodline and the dialyzer in the extracorporeal circuit during hemodialysis treatment. The chamber's two (2) clear polycarbonate viewing lenses serve to secure the CLiC Monitor's sensor clip and provide a uniform cross section, allowing a clear view of the blood passage for the CLiC Monitor to transmit light through the blood. The CLiC Monitor uses the principle of light absorption and scattering to measure oxygen saturation (O2 SAT) and hematocrit (HCT) levels in the blood.
The proposed device is the same as the predicate. CRIT LINE Clip (CLiC) Blood Chamber (K141281) with a change only to the internal geometry (taper) of the dialyzer connector (also referred to as the 'female DIN connector').
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Image /page/4/Picture/0 description: The image shows the logo for Fresenius Medical Care. On the left is a blue symbol that looks like three chevrons stacked on top of each other. To the right of the symbol is the text "FRESENIUS MEDICAL CARE" in blue, with "FRESENIUS" on top and "MEDICAL CARE" on the bottom.
#### 5.5. Intended Use
The CRIT-LINE® Clip (CLiC) Blood Chamber is a sterile, single use, disposable, optical cuvette designed for use with the CLiC Monitor's sensor clip during acute and chronic hemodialysis therapy. The CLiC system non-invasively measures hematocrit and oxygen saturation. The percentage change in blood volume is calculated from the real time hematocrit. The blood chamber is connected between the arterial bloodline and the dialyzer within the extracorporeal circuit during hemodialysis treatments.
#### 5.6. Indications for Use
The CRIT-LINE Clip (CLiC) Blood Chamber is a sterile, single use, disposable, optical cuvette designed for use with the CLiC Monitor's sensor clip during acute and chronic hemodialysis therapy to non-invasively measure hematocrit, percent change in blood volume, and oxygen saturation. The blood chamber is connected between the arterial bloodline and the dialyzer within the extracorporeal circuit during hemodialysis treatment.
### 5.7. Comparison of Technological Characteristics with the Predicate Device
The proposed device has the same technological characteristics as the predicate, CRIT-LINE Clip (CLiC) Blood Chamber (K141281) as detailed in Table 1.
| Feature | Predicate Device<br>(P/N CL10041021) | Proposed Device<br>(P/N CL10041021) | Comment |
|------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|
| | CLiC Blood Chamber<br>(K141281) | CLiC Blood Chamber | |
| Classification<br>Product Code<br>/ Regulation | KOC/876.5820 | KOC/876.5820 | Same |
| Feature | Predicate Device<br>(P/N CL10041021) | Proposed Device<br>(P/N CL10041021) | Comment |
| | CLiC Blood Chamber<br>(K141281) | CLiC Blood Chamber | |
| Indications for<br>use | The CRIT-LINE Clip (CLiC)<br>Blood Chamber is a sterile, single<br>use, disposable, optical cuvette<br>designed for use with the CLiC<br>Monitor's sensor clip during<br>acute and chronic hemodialysis<br>therapy to non-invasively<br>measure hematocrit, percent<br>change in blood volume, and<br>oxygen saturation. The blood<br>chamber is connected between<br>the arterial bloodline and the<br>dialyzer within the extracorporeal<br>circuit during hemodialysis<br>treatment. | The CRIT-LINE Clip (CLiC)<br>Blood Chamber is a sterile,<br>single use, disposable, optical<br>cuvette designed for use with the<br>CLiC Monitor's sensor clip<br>during acute and chronic<br>hemodialysis therapy to non-<br>invasively measure hematocrit,<br>percent change in blood volume,<br>and oxygen saturation. The blood<br>chamber is connected between<br>the arterial bloodline and the<br>dialyzer within the<br>extracorporeal circuit during<br>hemodialysis treatment. | Same |
| Principle of<br>Operation | Disposable cuvette secured to the<br>extracorporeal circuit prior to<br>hemodialysis treatment to provide<br>a clear viewing surface for the<br>CLiC Monitor to transmit light<br>through the blood. | Disposable cuvette secured to the<br>extracorporeal circuit prior to<br>hemodialysis treatment to<br>provide a clear viewing surface<br>for the CLiC Monitor to transmit<br>light through the blood. | Same |
| Configuration | Two, clear polycarbonate lenses<br>are sonically welded to a<br>translucent, blue polycarbonate<br>body. A secure connection with<br>the arterial bloodline is made<br>with an integrally molded male<br>Luer-lock connector in the body.<br>Connection to the hemodialyzer<br>is made with a polyvinylchloride<br>(PVC), female conical fitting<br>with external threads (DIN<br>connector*) that is solvent<br>bonded to the chamber body.<br>Each connection is capped: caps<br>are removed prior to treatment to<br>cover the internal blood area and<br>threads. | Two, clear polycarbonate lenses<br>are sonically welded to a<br>translucent, blue polycarbonate<br>body. A secure connection with<br>the arterial bloodline is made<br>with an integrally molded male<br>Luer-lock connector in the body.<br>Connection to the hemodialyzer<br>is made with a polyvinylchloride<br>(PVC), female conical fitting<br>with external threads (DIN<br>connector*) that is solvent<br>bonded to the chamber body.<br>Each connection is capped: caps<br>are removed prior to treatment to<br>cover the internal blood area and<br>threads. | Same |
| Feature | Predicate Device<br>(P/N CL10041021)<br>CLiC Blood Chamber<br>(K141281) | Proposed Device<br>(P/N CL10041021)<br>CLiC Blood Chamber | Comment |
| Blood<br>Pathway | The blood pathway created by the<br>CLiC chamber exposes the blood<br>to three different materials; PVC<br>(DIN connector), clear<br>polycarbonate (lenses), and blue<br>polycarbonate (chamber body).<br>The inside of each polycarbonate<br>lens is molded with two mixing<br>posts that align when the lenses<br>are welded to the blue<br>polycarbonate body. These<br>mixing posts are positioned<br>directly below the male access<br>port. | The blood pathway created by<br>the CLiC chamber exposes the<br>blood to three different materials;<br>PVC (DIN connector), clear<br>polycarbonate (lenses), and blue<br>polycarbonate (chamber body).<br>The inside of each polycarbonate<br>lens is molded with two mixing<br>posts that align when the lenses<br>are welded to the blue<br>polycarbonate body. These<br>mixing posts are positioned<br>directly below the male access<br>port. | Same |
| Dialyzer<br>Connection<br>(DIN<br>Connector*) | Female conical fitting with<br>external threads, meeting ISO<br>8638 and 594-2 performance<br>requirements. | Female conical fitting with<br>external threads, meeting ISO<br>8638 and 594-2 performance<br>requirements. | Substantially<br>Equivalent |
| Arterial<br>Bloodline<br>Connection | Male Luer-lock conical fitting<br>with internal threads, meeting<br>ISO 8638 and 594-2 performance<br>requirements. | Male Luer-lock conical fitting<br>with internal threads, meeting<br>ISO 8638 and 594-2 performance<br>requirements. | Same |
| Connection<br>Caps | Caps do not come into contact<br>with the blood path and are<br>discarded prior to treatment.<br>Provided to cover the blood path<br>access and protect the threads. | Caps do not come into contact<br>with the blood path and are<br>discarded prior to treatment.<br>Provided to cover the blood path<br>access and protect the threads. | Same |
| Sensor Clip<br>to Lens<br>Interface | Each lens employs an exterior<br>uniform annular ring to interface<br>with the complementary shroud<br>design of the CLiC Monitor's<br>sensor clip. The shroud fills the<br>area between the annular ring on<br>the chamber and the outside edge<br>of the lens. Each lens features an<br>anti-rotation detent which<br>interlocks with complementary<br>tabs on both sides of the clip to<br>prevent rotation of the clip. | Each lens employs an exterior<br>uniform annular ring to interface<br>with the complementary shroud<br>design of the CLiC Monitor's<br>sensor clip. The shroud fills the<br>area between the annular ring on<br>the chamber and the outside edge<br>of the lens. Each lens features an<br>anti-rotation detent which<br>interlocks with complementary<br>tabs on both sides of the clip to<br>prevent rotation of the clip. | Same |
| Feature | Predicate Device<br>(P/N CL10041021) | Proposed Device<br>(P/N CL10041021) | Comment |
| | CLiC Blood Chamber<br>(K141281) | CLiC Blood Chamber | |
| Sterilization<br>Method | Gamma Radiation | Gamma Radiation | Same |
| Pyrogenicity | Non-pyrogenic | Non-pyrogenic | Same |
| Sterile<br>Barrier | Unit Packaging | Unit Packaging | Same |
| Single use or<br>reuse | Single use only | Single use only | Same |
| Biological<br>Safety | Biologically Safe | Biologically Safe | Same |
Device Description and Comparison to the Predicate Table 1:
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Image /page/5/Picture/0 description: The image shows the logo for Fresenius Medical Care. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons, stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.
#### Table 1: Device Description and Comparison to the Predicate
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Image /page/6/Picture/0 description: The image shows the logo for Fresenius Medical Care. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons, stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.
#### Table 1: Device Description and Comparison to the Predicate
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Image /page/7/Picture/0 description: The image shows the Fresenius Medical Care logo. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right, also in blue. The symbol is made up of three downward-pointing chevrons, stacked on top of each other.
#### Table 1: Device Description and Comparison to the Predicate
*note: The term 'DIN Connector' is a legacy term used internally by FMC-RTG to describe the dialyzer connector and does not imply conformance to the German national standards Deutsches Institut für Normung (DIN) for locking connections.
#### Summary of Verification and/or Validation Data 5.8.
The application of Risk Management techniques was used to identify the appropriate verification and/or validation activities to support the proposed change. Based on the results of the testing, outlined in Table 2, FMC-RTG concludes that the modified connector does not introduce any new questions of safety and effectiveness to the finished device.
| Verification Test | Test Method Description | Pass / Fail |
|------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------|-------------|
| Performance Test: Mechanical<br>Characteristic / Structural Integrity<br>per ANSI/AAMI/ISO 8638:2010 | Confirm the bonding between the chamber<br>and the DIN Connector P/N 55-4299 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Liquid Leakage Test<br>per ISO 594-2 | Ensure the connectors meet the<br>performance requirements of ISO 594-2 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Air Leakage Test per<br>ISO 594-2 | Assure leakage resistance to satisfy the<br>requirements of ISO 594-2 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Separation Force Test<br>per ISO 594-2 | Assure the separation force of the conical<br>fitting meets the ISO 594-2 requirements | PASS |
Table 2: Performance and Functional Testing
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Image /page/8/Picture/0 description: The image shows the logo for Fresenius Medical Care. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons, stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.
| Verification Test | Test Method Description | Pass / Fail |
|----------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------|-------------|
| Dialyzer Connector (Female DIN<br>Connector): Unscrewing Torque<br>Test per ISO 594-2 | Assure an adequate unscrewing force to<br>satisfy the requirements of ISO 594-2 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Ease of Assembly Test<br>per ISO 594-2 | Assure ease of assembly fit will satisfy the<br>requirements of ISO 594-2 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Resistance to<br>Overriding Test per ISO 594-2 | Assure the reference fitting resists<br>overriding the test fitting to satisfy the<br>requirements of ISO 594-2 | PASS |
| Dialyzer Connector (Female DIN<br>Connector): Stress Cracking Test<br>per ISO 594-2 | Assure the female fitting will resist stress<br>cracking to satisfy the requirements of ISO<br>594-2 | PASS |
| Endurance Performance Test per<br>ISO 8368:2010 | Demonstrate the product performs at<br>maximum labeled pressures without<br>resulting in loose connection or leaks | PASS |
| Bond Strength Test per ISO<br>8368:2010 | Confirm solvent bonding between the CLiC<br>blood chamber's blue polycarbonate body<br>and clear PVC DIN Connector meet<br>specification | PASS |
| Blood Pathway Volume (Priming<br>Volume) Test per ISO 8368:2010 | Verify the established the blood pathway<br>volume of the blood chamber meets<br>specification. | PASS |
#### 5.9. Conclusions
The only proposed change to the CLiC Blood Chamber relates to the internal geometry (taper) of the dialyzer connector. This change has no impact on the Intended Use, Indications for Use or the Technological Characteristic of the finished device.
Results of verification and/or validation testing demonstrate that the modified device meets the performance requirements of ISO 594-2. The safety and efficacy of the device for its intended use remain unchanged.
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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.