K222460 · Exact Medical Manufacturing · ITX · May 12, 2023 · Radiology
Device Facts
Record ID
K222460
Device Name
Intraoperative Ultrasound Probe Cover
Applicant
Exact Medical Manufacturing
Product Code
ITX · Radiology
Decision Date
May 12, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1570
Device Class
Class 2
Indications for Use
Intraoperative Ultrasound Probe Cover can be used to minimize contamination between the patient and the probe during ultrasound scanning procedures for both intact skin and compromised tissue. The cover allows use of the transducer in scanning and needle guided procedures for body surface, Endo cavity, and intra-operative diagnostic ultrasound, while helping to prevent transfer of microorganisms, body fluids, and particulate material to the patient and healthcare worker during reuse of the transducer.
Device Story
Sterile, single-use polyurethane probe cover; functions as physical barrier between ultrasound transducer and patient; prevents cross-contamination during invasive and non-invasive procedures; used in body surface, endocavity, and intra-operative diagnostic ultrasound; compatible with various probes including endoscope, rectal, vaginal, trans-urethral, gastro-entero, pulmonary, biopsy, fiberoptic, catheter, vascular, and CNS probes; applied by healthcare professionals; protects patient and clinician from microorganisms, body fluids, and particulates; maintains sterile field during needle-guided procedures.
Material: Polyurethane polymer; tubular, sealed form factor. Sterilization: Ethylene oxide (EO) per ISO 11135-1:2014, SAL 10^-6. Single-use, disposable. No electronic components or software.
Indications for Use
Indicated for patients undergoing ultrasound scanning procedures, including body surface, endocavity, and intra-operative diagnostic ultrasound, involving both intact skin and compromised tissue. Used to minimize contamination and prevent transfer of microorganisms, body fluids, and particulates between patient and healthcare worker.
Regulatory Classification
Identification
A diagnostic ultrasonic transducer is a device made of a piezoelectric material that converts electrical signals into acoustic signals and acoustic signals into electrical signals and intended for use in diagnostic ultrasonic medical devices. Accessories of this generic type of device may include transmission media for acoustically coupling the transducer to the body surface, such as acoustic gel, paste, or a flexible fluid container.
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May 12, 2023
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
Exact Medical Manufacturing % Madison Wheeler Director of Technical Operations EMMA International Consulting Group 30150 Telegraph Rd.. Suite 120 BINGHAM FARMS MI 48025
Re: K222460
Trade/Device Name: Intraoperative Ultrasound Probe Cover Regulation Number: 21 CFR 892.1570 Regulation Name: Diagnostic ultrasonic transducer Regulatory Class: Class II Product Code: ITX Dated: August 5, 2022 Received: April 10, 2023
Dear Madison Wheeler:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Yanna S. Kang -S
Yanna Kang, Ph.D. Assistant Director Mammography and Ultrasound Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K222460
Device Name Intraoperative Ultrasound Probe Cover
#### Indications for Use (Describe)
Intraoperative Ultrasound Probe Cover can be used to minimize contamination between the probe during ultrasound scanning procedures for both intact skin and compromised tissue. The cover allows use of the transducer in scanning and needle guided procedures for body surface, Endo cavity, and intra-operative diagnostic ultrasound, while helping to prevent transfer of microorganisms, body fluids, and particulate material to the patient and healthcare worker during reuse of the transducer.
Type of Use (Select one or both, as applicable)
| <span style="font-size:16px">☒</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|------------------------------------------------------------------------------------|
| <span style="font-size:16px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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## 510(k) SUMMARY - Traditional 510(k)
K222460
A summary of information in accordance with requirements of 21 CFR 807.92.
### SUBMITTER'S INFORMATION
| Sponsor: | Exact Medical Manufacturing |
|-------------------------|-------------------------------------------------------------------------------------------------------------------|
| Address: | 4917 William St #B<br>Lancaster, NY 14086 |
| Official Correspondent: | Ryan Power, Vice President<br>Exact Medical Manufacturing<br>Kpower@exactmm.com<br>716-681-0076 |
| Contact Person: | Madison Green<br>EMMA International Consulting Group, Inc.<br>248-987-4497<br>Madison.green@emmainternational.com |
Date Summary Prepared: April 01, 2023
### DEVICE INFORMATION
Name of Device: Intraoperative Ultrasound Probe Cover Common Name: Invasive Probe Cover Classification Name: 892.1570 Diagnostic Ultrasonic Transducer Product Code: ITX Device Classification: Class II
### Predicate Device
The proposed Invasive Prove Cover is substantially equivalent to the following predicate device:
| Predicate Device | Manufacturer |
|-----------------------------------------------------------------------|------------------------------------|
| Non-Pyrogenic CIV Flex – Non-Pyrogenic<br>Ultrasound Transducer Cover | CIVCO Medical Instruments Co., Inc |
| K131528 | |
### Device Description:
Intraoperative Ultrasound Probe Cover can be used to minimize contamination between the patient and the probe during ultrasound scanning procedures for both intact skin and compromised tissue. The cover allows use of the transducer in scanning and needle quided procedures for body surface, endocavity, and intra-operative diagnostic ultrasound, while helping to prevent transfer of microorganisms, body fluids, and particulate material to the patient and healthcare worker during reuse of the transducer.
The probe cover is designed for use in both invasive and non-invasive procedures. It comes in a sterile form only. The sterile cover made used in invasive procedures where it will come into direct contact with compromised tissue. The probe cover may be used with any multiple
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different probes including, but not limited to, an Endoscope re-usable, any rectal, vaginal, trans-urethral, gastro-entero probes, or pulmonary probe, In-vitro Fertilization instruments, biopsy probes, fiberoptic probes, catheter probes, any probe that is used during a surgical procedure, re-usable vascular (visualization) probes, and re-usable central nervous system (CNS) or cerebral probes.
### Indications for Use:
Intraoperative Ultrasound Probe Cover can be used to minimize contamination between the patient and the probe during ultrasound scanning procedures for both intact skin and compromised tissue. The cover allows use of the transducer in scanning and needle guided procedures for body surface, Endo cavity, and intra-operative diagnostic ultrasound, while helping to prevent transfer of microorganisms, body fluids, and particulate material to the patient and healthcare worker during reuse of the transducer.
### Technoloqical Characteristics:
No technological characteristics have changed between the proposed device and predicate devices. Both the predicates and the proposed device are comprised of equivalent materials.
### Comparison to Predicate Devices:
Intraoperative Ultrasound Probe Cover has the equivalent intended uses and is subject to the same regulation as the CIVCO Medical Instruments Non-Pyrogenic CIV Flex (K131528):
| Description | Intraoperative Ultrasound Probe<br>Cover | PREDICATE DEVICE CIVCO Medical<br>Instruments - Non-Pyrogenic CIV-Flex |
|-----------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for<br>Use | Intraoperative Ultrasound Probe Cover<br>can be used to minimize contamination<br>between the patient and the probe during<br>ultrasound scanning procedures for both<br>intact skin and compromised tissue. The<br>cover allows use of the transducer in<br>scanning and needle guided procedures<br>for body surface, Endo cavity, and intra-<br>operative diagnostic ultrasound, while<br>helping to prevent transfer of<br>microorganisms, body fluids, and<br>particulate material to the patient and<br>healthcare worker during reuse of the<br>transducer. | Protective cover or sheath placed over<br>diagnostic ultrasound transducer / probe /<br>scan head instruments. The cover allows use<br>of the transducer in scanning and needle<br>guided procedures for body surface,<br>endocavity, central nervous system, and<br>intra-operative diagnostic ultrasound, while<br>helping to prevent transfer of<br>microorganisms, body fluids, and particulate<br>material to the patient and healthcare worker<br>during reuse of the transducer. The cover<br>also provides a means for maintenance of a<br>sterile field. The cover is single use patient /<br>procedure, non-pyrogenic, and disposable. |
| Classification<br>and Code | Polyurethane Probe Cover ITX,<br>21CFR892.1570, Class II | Non-Pyrogenic CIV Flex ITX,<br>21CFR892.1570 |
| Material of<br>Construction | POLYMER, Polyurethane, tubular, sealed | Polyurethane (CIV-Flex TM) and<br>polyethylene |
| Sterile (via EO<br>Gas) | ISO 11135-1:2014, Sterilization of health<br>care products - Ethylene oxide - Part 1.<br>SAL 10-6 | EtO method. SAL 10-6. Non-pyrogenic.<br>Endotoxin Method: LAL Kinetic Method<br>(Chromogenic). Endotoxin Release<br>Specification: 2.15 EU/device. |
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| USE | Disposable, Single Use Only | Single use, non-pyrogenic, and disposable |
|-----|-----------------------------|-------------------------------------------|
|-----|-----------------------------|-------------------------------------------|
# Non-Clinical Testing:
The Intraoperative Ultrasound Probe Cover is substantially equivalent and meets the same acceptance criteria as the predicate device as in K131528. Non-clinical performance testing was conducted for the following barrier properties, tensile, elongation, linting, sterility, biocompatibility, acoustics performance, ethylene oxide residuals, bacterial endotoxins, viral penetration, water resistance/hydrostatic pressure, water resistance/impact penetration, and synthetic blood penetration. All results of the testing met acceptance criteria. Sterility, packaging, shelf life, biocompatibility, and performance testing completed on the predicate devices remains applicable for the proposed device and this testing is summarized in the submission.
### Conclusions:
This premarket submission for the Intraoperative Ultrasound Probe Cover has demonstrated substantial equivalence to the CIVCO Medical Instruments Non-Pyrogenic CIV Flex as defined and understood in the Federal Food, Drug and Cosmetic act and various guidance documents issued by the Center for Devices and Radiological Health. Based on comparison against predicate devices and endotoxin testing, the Intraoperative Ultrasound Probe Cover is safe and effective for its intended use.
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.