K141842 · Orthomerica Products, Inc. · MVA · Oct 6, 2014 · Neurology
Device Facts
Record ID
K141842
Device Name
STARBAND, STARLIGHT
Applicant
Orthomerica Products, Inc.
Product Code
MVA · Neurology
Decision Date
Oct 6, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.5970
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.
Device Story
STARband and STARlight are custom-fabricated cranial orthoses used to treat infant head deformities. The device applies mild pressure to prominent areas of the cranium while providing voids over depressed areas to redirect growth toward symmetry. Practitioners capture the infant's head shape using a plaster impression or 3D imaging (including the SmartSoc System). A positive model is created and modified to guide growth. The orthosis is worn ~23 hours/day. The device consists of a rigid outer shell (copolymer plastic, Surlyn, or Co-Polyester) and an optional inner foam liner (Pelite, Aliplast, or Reston). Designs include side-opening or bi-valve configurations secured with Velcro straps. The SmartSoc System uses a flexible fabric sock with a printed pattern and a consumer-grade digital camera with a non-coherent flash to capture 3D data. The device is prescribed by clinicians and managed by practitioners who adjust the interior as the infant's head grows. Benefits include improved cranial symmetry and proportion.
Clinical Evidence
Bench testing only. No clinical data. Performance was validated through repeatability and reproducibility (R&R) testing using uniform shapes representing pediatric patients, and a Cranial Shape Capture Accuracy Study comparing the SmartSoc System against traditional casting and predicate imaging methods across coordinate planes (A-P, M-L, P-D, radius parameters, squareness, and flatness).
Technological Characteristics
Custom-molded cranial orthosis. Materials: 5/32" copolymer plastic, 5/32"-1/4" Surlyn, 1/8"-7/32" Co-Polyester; liners include 1/2" Pelite or Aliplast foam. Sensing: 3D shape capture via SmartSoc System (fabric sock + consumer camera with non-coherent flash). Fabrication: 5-axis routing of positive mold. Biocompatibility: Cytotoxicity (Agar Diffusion), Closed Patch Sensitization, Primary Dermal Irritation.
Indications for Use
Indicated for infants 3-18 months old with moderate-to-severe non-synostotic positional plagiocephaly (plagiocephalic, brachycephalic, or scaphocephalic head shapes) to improve cranial symmetry/shape via mild pressure. Also indicated as adjunctive therapy for infants 3-18 months old with residual moderate-to-severe cranial deformities following surgical correction of synostosis.
Regulatory Classification
Identification
A cranial orthosis is a device that is intended for medical purposes to apply pressure to prominent regions of an infant's cranium in order to improve cranial symmetry and/or shape in infants from 3 to 18 months of age, with moderate to severe nonsynostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic-, and scaphocephalic-shaped heads.
Special Controls
*Classification.* Class II (special controls) (prescription use in accordance with § 801.109 of this chapter, biocompatibility testing, and labeling (contraindications, warnings, precautions, adverse events, instructions for physicians and parents)).
In addition to the general controls of the act, the Dynamic Orthotic Cranioplasty - DOC™ Band is subject to the following special controls in order to provide reasonable assurance of the safety and effectiveness: (1) The sale, distribution and use of this device are restricted to prescription use in accordance with 21 CFR 801.109. (2) The labeling must include (a) contraindications for the use of the device on infants with synostosis or with hydrocephalus; (b) warnings indicating the need: (i) to evaluate head circumference measurements and neurological status at intervals appropriate to the infant’s age and rate of head growth, and to describe steps that should be taken in order to reduce the potential for restriction of cranial growth and possible impairment of brain growth and development; (ii) to evaluate the skin at frequent intervals, e.g., every three to four hours, and to describe steps that should be taken if skin irritation or breakdown occurs; (c) precautions indicating the need: (i) to additionally treat torticollis, if the positional plagiocephaly is associated with torticollis; (ii) to evaluate device fit and to describe the steps that should be taken in order to reduce the potential for restriction of cranial growth, possible impairment of brain growth and development and skin irritation and/or breakdown; (iii) to evaluate the structural integrity of the device and to describe the steps that should be taken to reduce the potential for the device to slip out of place and cause asphyxiation or trauma to the eyes or skin; (d) adverse events, i.e., skin irritation and breakdown that have occurred with the use of this device; (e) clinician’s instructions for casting the infant, for fitting the device, and for care and use of the device; and (f) parents’ instructions for care and use of the device. (3) The materials must be assessed for biocompatibility with testing appropriate for long term direct skin contact.
Predicate Devices
STARband and Starlight, Cranial Orthosis (K140353)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 6, 2014
Orthomerica Products, Inc. % David Kerr Chief Executive Officer 6333 N Orange Blossom Trail Orlando, Florida 32810
Re: K141842 Trade/Device Name: Starband, starlight Regulation Number: 21 CFR 882.5970 Regulation Name: Cranial Orthosis Regulatory Class: Class II Product Code: MVA, OAN Dated: July 3, 2014 Received: July 8, 2014
Dear David Kerr,
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
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the quality systems (OS) 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 yours,
# Carlos L. Pena - SVA
Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K141842
Device Name STARband and STARlight Cranial Orthosis
### Indications for Use (Describe)
The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. These devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------|
| <span style="text-decoration: overline;">\u2612</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="text-decoration: overline;">\u2610</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(k) Summary
#### I. Applicant Information
| Name: | Orthomerica Products, Inc. | |
|------------|---------------------------------|--|
| Address: | 6333 North Orange Blossom Trail | |
| | Orlando, FL 32810 | |
| Telephone: | (407) 290-6592 | |
| Facsimile: | (407) 290-2419 | |
## FDA Establishment Registration Number
1058152
## Contact Information
| Contact Person: | David Hooper, Manufacturing Engineer |
|-----------------|------------------------------------------------------|
| Address: | 6333 North Orange Blossom Trail<br>Orlando, FL 32810 |
| Telephone: | (407) 290-6592 |
| Facsimile: | (407) 290-2419 |
| Email: | dhooper@orthomerica.com |
| Date Prepared: | July 3, 2014 |
#### II. Submission Information
| Type: | Traditional 510(k) Submission |
|----------------------|--------------------------------------------------------|
| Proprietary Name: | STARband® and STARlight® |
| Common Name: | Cranial Orthosis |
| Classification: | Class II (special controls); OAN; MVA; 21 CFR 882.5970 |
| Classification Name: | Cranial Orthosis |
#### III. Manufacturer Site
| Name: | Orthomerica Products, Inc. |
|----------------------------------------|---------------------------------|
| Address: | 6333 North Orange Blossom Trail |
| | Orlando, FL 32810 |
| Telephone: | (407) 290-6592 |
| Facsimile: | (407) 290-2419 |
| FDA Establishment Registration Number: | 1058152 |
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#### IV. Description of Device/Modification
The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.
The STARband and STARlight product families as it was released in K140353 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.
The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro® strap (1½' for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.
The proposed device modification is the addition of a new 3-dimensional shape capture, specifically, the NetVirta SmartSoc™ System distributed by Orthomerica Products, Inc. This system uses a flexible fabric sock with a customized non-repetitive printed pattern and a consumer grade digital camera with it's a built-in flash light source. The built-in flash feature is a non-coherent (i.e. non-laser light) light source. Because this system
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utilizes a consumer grade camera with a non-coherent light source for a flash, it is safe to use on infant patients under all circumstances.
#### V. Statement of Indications and Intended Use
### Statement of Indications:
The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.
### Intended Use:
The STARband and STARlight are designed to treat infants with abnormal head shapes from age 3 to 18 months and is available by prescription only. Since growth is the driving factor in head shape correction, the infants wear the STARband or STARlight for approximately 23 hours per day. The most common head deformities are positional plagiocephaly, brachycephaly, and scaphocephaly. The STARband and STARlight have also been cleared to treat unresolved head deformities in patients who have undergone surgery to correct craniosynostosis. The same principles of cranial remolding apply to positional deformities and post-operative patients.
#### Predicate Devices VI.
- STARband and Starlight, Cranial Orthosis, K140353
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#### VI. Summary of Technological Characteristics
The SmartSoc System proposed in this 510(k) is an additional method to capture the infant's head shape for the fabrication of the STARband and STARlight Cranial Orthosis. The technological characteristics and the underlying principles of operation of the STARband and STARlight Cranial Orthosis shall remain exactly the same. The inclusion of the SmartSoc System is the focus of this submission and that change is indicated in Table 1 under the Approved 3-Dimensional Imaging Devices section.
| Feature | From K140353 | Proposed Device |
|-----------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended<br>Use | Maintains total contact over areas of<br>bossing or protrusion and creates voids<br>over areas of depression or flattening to<br>redirect cranial growth toward greater<br>symmetry. | Maintains total contact over areas of<br>bossing or protrusion and creates voids<br>over areas of depression or flattening to<br>redirect cranial growth toward greater<br>symmetry. |
Table 1 - Comparison of Predicate Device cleared in K140353 to the Proposed Device
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| Materials | K141842 - STARband® and STARlight® |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Material for STARband Side Opening design and STARband Bi-Valve design Outer shell of 5/32" copolymer plastic An inner liner of 1/2" Pelite polyethylene foam or 1/2" Aliplast foam | Material for STARband Side Opening design and STARband Bi-Valve design Outer shell of 5/32" copolymer plastic An inner liner of 1/2" Pelite polyethylene foam or 1/2" Aliplast foam |
| Material for STARlight Side Opening design and STARlight Bi-Valve design 5/32" - 1/4" clear Surlyn or 1/8" – 7/32" Clear Co-Polyester plastic shell | Material for STARlight Side Opening design and STARlight Bi-Valve design 5/32" - 1/4" clear Surlyn or 1/8" – 7/32" Clear Co-Polyester plastic shell |
| Material for STARlight PRO design 1/4" – 3/8" clear Surlyn | Material for STARlight PRO design 1/4" - 3/8" clear Surlyn |
| Closure for Bivalve design Sliding/Overlap closure system Chicago screw (or similar) for top sliding mechanism 1" Velcro strap 1" chafe buckle Speedy rivets | Closure for Bivalve design Sliding/Overlap closure system Chicago screw (or similar) for top sliding mechanism 1" Velcro strap 1" chafe buckle Speedy rivets |
| Closure for STARband Side Opening design 1 ½" Velcro Strap 1 ½" chafe buckle A Gap Block made from ½" firm Pelite polyethylene foam Large Flange, Blind Rivet | Closure for STARband Side Opening design 1 ½" Velcro Strap 1 ½" chafe buckle A Gap Block made from ½" firm Pelite polyethylene foam Large Flange, Blind Rivet |
| Closure for STARlight Side Opening design and the STARlight PRO design: 1" Velcro Strap | Closure for STARlight Side Opening design and the STARlight PRO design: 1" Velcro Strap |
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| Feature | From K140353 | Proposed Device |
|--------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | 1" chafe buckle<br>Optional tamper resistant strap<br>(qty 2 for the STARlight PRO<br>design) | 1" chafe buckle<br>Optional tamper resistant strap<br>(qty 2 for the STARlight PRO<br>design) |
| Product<br>Design | Custom made cranial orthosis,<br>approximately 6 to 10oz in weight.<br>STARlight PRO weighs 12.5 to 18.5 oz. | Custom made cranial orthosis,<br>approximately 6 to 10oz in weight.<br>STARlight PRO weighs 12.5 to 18.5 oz. |
| Production | Form orthosis from a positive<br>mold of infant's head | Form orthosis from a positive<br>mold of infant's head |
| | Positive mold is formed based<br>upon measurements of the infant's<br>head taken by an approved 3-<br>dimensional imaging device from<br>which a 3-dimensional image is<br>made or from a traditional plaster<br>cast | Positive mold is formed based<br>upon measurements of the infant's<br>head taken by an approved 3-<br>dimensional imaging device from<br>which a 3-dimensional image is<br>made or from a traditional plaster<br>cast |
| | The 3-dimensional image is used<br>to produce a positive mold using a<br>5-axis routing machine | The 3-dimensional image is used<br>to produce a positive mold using a<br>5-axis routing machine |
| Approved 3-<br>Dimensional<br>Imaging<br>Devices | STARscanner I<br>STARscanner II<br>Omega Scanner<br>scanGogh-II<br>3dMDhead System<br>3dMDcranial System<br>3dMDflex System | STARscanner I<br>STARscanner II<br>Omega Scanner<br>scanGogh-II<br>3dMDhead System<br>3dMDcranial System<br>3dMDflex System<br>SmartSoc System |
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K141842 - STARband® and STARlight® Repeatability and Reproducibility (R&R) Repeatability and Reproducibility (R&R) Testing Analysis Analysis Utilized uniform shapes with Utilized uniform shapes with known dimensions that represent known dimensions that represent various sizes of pediatric patients various sizes of pediatric patients between ages 3 to 18 months of between ages 3 to 18 months of age age -Compared proposed device to cast -Compared proposed device to cast and predicate device and predicate device --Associated parameters includes Associated parameters includes A-P and M-L A-P and M-L Proposed device is substantially -Proposed device is substantially equivalent to predicate device equivalent to predicate device Cranial Shape Capture Accuracy Study Cranial Shape Capture Accuracy Study Utilized a representative cranial Utilized a representative cranial shape that possesses a predefined shape that possesses a predefined shape with known dimensions shape with known dimensions -Compared proposed device to cast -Compared proposed device to cast and predicate device and predicate device Associated Coordinate Planes (A---Associated Coordinate Planes (A-P; M-L; P-D and various Radius P; M-L; P-D and various Radius Parameters; Squareness; Flatness) Parameters; Squareness; Flatness) Proposed device is substantially Proposed device is substantially -equivalent to predicate device equivalent to predicate device
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| Feature | From K140353 | Proposed Device |
|---------|------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------|
| | Material Biocompatibility Testing<br>- Cytotoxicity –Agar Diffusion<br>- Closed Patch Sensitization<br>- Primary Dermal Irritation | Material Biocompatibility Testing<br>- Cytotoxicity –Agar Diffusion<br>- Closed Patch Sensitization<br>- Primary Dermal Irritation |
The STARband and STARlight Cranial Orthosis have already received FDA 510(k) clearance under K140353 for being manufactured from a 3-dimensional imaging device that utilizes a non-coherent light source and takes 2-dimensional (2D) images from triangulated positions for shape capture (3dMD Systems). The SmartSoc System also utilizes a non-coherent light source and takes 2D images from triangulated positions for shape capture. Considering that STARband and STARlight are still the same device as it was in the predicate device and that the shape capture devices have the same technological characteristics; the STARband and STARlight Cranial Othosis are substantially equivalent to the predicate device.
The STARband and STARlight are essentially the same Cranial Orthosis. The main difference between the STARband and STARlight are the materials used to produce them. The STARband and STARlight materials have been biocompatibility tested, and the results of the tests are listed below in Table 2.
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| Orthosis | | | |
|---------------------------------|----------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------|
| Material | Test | Results | Conclusion |
| Surlyn | Closed Patch<br>Sensitization | A score of 0.00/0.00 (Test/Control)<br>was given for both Incidence and<br>Severity in the 24 hour and 48 hour<br>scoring interval. | Not a Sensitizer<br>No Erythema or<br>Edema Formation |
| Surlyn | Primary Dermal<br>Irritation | Primary Irritation Index: 0.00 | Negligible Dermal<br>Response |
| Surlyn | Cytotoxicity –<br>Agar Diffusion | Cell culture treated with test sample<br>exhibited no reactivity (Grade 0). | Non-cytotoxic |
| Copolymer with<br>Pelite Foam | Closed Patch<br>Sensitization | A score of 0.00/0.00 (Test/Control)<br>was given for both Incidence and<br>Severity in the 24 hour and 48 hour<br>scoring interval. | Not a Sensitizer<br>No Erythema or<br>Edema Formation |
| Copolymer with<br>Pelite Foam | Primary Dermal<br>Irritation | Primary Irritation Index: 0.06 | Negligible Dermal<br>Response |
| Copolymer with<br>Pelite Foam | Cytotoxicity –<br>Agar Diffusion | Cell culture treated with test sample<br>exhibited no reactivity (Grade 0). | Non-cytotoxic |
| Copolymer with<br>Aliplast Foam | Closed Patch<br>Sensitization | A score of 0.00/0.00 (Test/Control)<br>was given for both Incidence and<br>Severity in the 24 hour and 48 hour<br>scoring interval. | Not a Sensitizer<br>No Erythema or<br>Edema Formation |
| Copolymer with<br>Aliplast Foam | Primary Dermal<br>Irritation | Primary Irritation Index: 0.00 | Negligible Dermal<br>Response |
| Copolymer with<br>Aliplast Foam | Cytotoxicity –<br>Agar Diffusion | Cell culture treated with test sample<br>exhibited slight reactivity (Grade 1). | Non-cytotoxic |
Table 2 - Biocompatibility Testing Summary for STARband and STARlight Cranial Orthosis
#### Summary and Conclusions of Non-Clinical Performance Data VII.
The SmartSoc System was evaluated for safety and efficacy. The system uses a consumer grade camera and is safe to use on infants without any eye protection. The shape capture repeatability and reproducibility was evaluated and determined to be acceptable. An additional, Cranial Shape Capture Accuracy Study was performed concluding that the SmartSoc System yields a safe and effective product that is substantially equivalent to the predicate device.4 With sufficient accuracy and no concerns with the safety of the system, the SmartSoc System was determined safe and effective for capturing infant head shape data to manufacture the STARband and STARlight Cranial Orthosis.
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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.
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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.
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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.
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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.