Single Use Curved Cutters, Single Use Circular Staplers, Single Use Linear Cutters and Reloads, Single Use Endoscopic Linear Cutters and Reloads, Single Use Hemorrhoidal Staplers, Single Use Linear Staplers and Reloads
K161757 · Victor Medical Instruments Co., Ltd. · GDW · Dec 5, 2016 · General, Plastic Surgery
Device Facts
Record ID
K161757
Device Name
Single Use Curved Cutters, Single Use Circular Staplers, Single Use Linear Cutters and Reloads, Single Use Endoscopic Linear Cutters and Reloads, Single Use Hemorrhoidal Staplers, Single Use Linear Staplers and Reloads
Applicant
Victor Medical Instruments Co., Ltd.
Product Code
GDW · General, Plastic Surgery
Decision Date
Dec 5, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4750
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The Single Use Endoscopic Linear Cutters and Reloads have applications in abdominal, gynecologic, pediatric and thoracic surgery for resection and creation of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and biliary structures and for transection and resection of pancreas. The Single Use Curved Cutters are intended for transection, and/or creation of anastomoses. The instrument has application in multiple open or minimally invasive general (gastrointestinal and sketal muscle), gynecologic, urologic, and thoracic surgical procedures. The Single Use Circular staplers have application throughout the alimentary tract for the creation of end-toside and side-to-side anastomoses in abdominal or thoracic surgeries. The Single Use Linear Staplers and Reloads have application in transection of tissue for abdominal, gynecological, pediatric and thoracic surgical procedures. The Single Use Linear Cutters and Reloads have application in abdominal, gynecological, thoracic and pediatic surgery transection, resection and the creation of anastomoses. The Single Use Hemorrhoidal Staplers have application for general treatment of hemorrhoids.
Device Story
Manual surgical stapling instruments; used in open or minimally invasive procedures; place titanium staples in staggered rows while simultaneously cutting tissue (except linear staplers). Input: manual activation by surgeon via handle squeeze. Output: stapled and transected tissue. Used in OR by surgeons. Benefits: facilitates tissue resection and anastomosis creation. Includes curved cutters, circular staplers, endoscopic linear cutters, linear staplers, linear cutters, and hemorrhoidal staplers. Some models support multiple reloads per procedure.
Clinical Evidence
No clinical data. Bench testing only. Testing included biological evaluation (ISO 10993-1, -5, -10), sterilization validation (ISO 11137-2), and mechanical performance testing (pressure resistance, staple formation, firing force) on swine tissue.
Indicated for patients undergoing abdominal, gynecologic, pediatric, thoracic, urologic, or general gastrointestinal/skeletal muscle surgery requiring tissue transection, resection, or anastomosis, and for the treatment of hemorrhoids.
Regulatory Classification
Identification
An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.
Predicate Devices
Disposable Circular Stapler, Disposable Linear Staplers and Reloads, Disposable Hemorrhoidal Stapler, Disposable Linear Cutter Staplers and Reloads, Disposable Curved Cutter Stapler (K131511)
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three heads, representing the department's commitment to health, human services, and science. The eagle is positioned to the right of the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA", which is arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 5, 2016
Victor Medical Instruments Co., Ltd. % Ms. Diana Hong Mid-link Consulting Co., Ltd P.O. Box 120-119 Shanghai, China 200120
Re: K161757
Trade/Device Name: Single Use Curved Cutters, Single Use Circular Staplers, Single Use Linear Cutters And Reloads, Single Use Endoscopic Linear Cutters And Reloads, Single Use Hemorrhoidal Staplers, Single Use Linear Staplers And Reloads
Regulation Number: 21 CFR 878.4750 Regulation Name: Implantable staple Regulatory Class: Class II Product Code: GDW Dated: October 31, 2016 Received: November 4, 2016
Dear Ms. Hong:
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 mav 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 of medical device
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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,
# David Krause -S
- for Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K161757
### Device Name
Single Use Curved Cutters, Single Use Circular Staple Use Linear Cutters and Reloads, Single Use Endoscopic Linear Cutters and Reloads, Single Use Hemorrhoidal Staplers, Single Use Linear Staplers and Reloads
### Indications for Use (Describe)
The Single Use Endoscopic Linear Cutters and Reloads have applications in abdominal, gynecologic, pediatric and thoracic surgery for resection and creation of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and biliary structures and for transection and resection of pancreas.
The Single Use Curved Cutters are intended for transection, and/or creation of anastomoses. The instrument has application in multiple open or minimally invasive general (gastrointestinal and sketal muscle), gynecologic, urologic, and thoracic surgical procedures.
The Single Use Circular staplers have application throughout the alimentary tract for the creation of end-toside and side-to-side anastomoses in abdominal or thoracic surgeries.
The Single Use Linear Staplers and Reloads have application in transection of tissue for abdominal, gynecological, pediatric and thoracic surgical procedures.
The Single Use Linear Cutters and Reloads have application in abdominal, gynecological, thoracic and pediatic surgery transection, resection and the creation of anastomoses.
The Single Use Hemorrhoidal Staplers have application for general treatment of hemorrhoids.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------|
| <span> X Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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## Exhibit #3 510(k) Summary
This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.
The assigned 510(k) Number: K161757
- 1. Date of Preparation: 12/05/2016
- Sponsor Identification 2.
## Victor Medical Instruments Co., Ltd.
NO.21, Huafeng Road, Qishuyan District, Changzhou City, Jiangsu P.R.213018 China
Establishment Registration Number: 3012428834
Contact Person: Yunhuo Chen Position: General Manager Tel: +86-519-88411357 Fax: +86-519-88411358 Email: yh.chen@victormedic.com
- Designated Submission Correspondent 3.
Ms. Diana Hong (Primary Contact Person) Ms. Ying Xu (Alternative Contact Person)
Mid-Link Consulting Co., Ltd P.O. Box 120-119, Shanghai, 200120, China
Tel: +86-21-22815850, Fax: 240-238-7587 Email: info@mid-link.net
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#### 4. Identification of Proposed Device
Trade Name: Single Use Curved Cutters
Single Use Circular Staplers Single Use Endoscopic Linear Cutters and Reloads Single Use Linear Staplers and Reloads Single Use Linear Cutters and Reloads Single Use Hemorrhoidal Staplers Common Name: Stapler and Reload
### Regulatory Information
Classification Name: Staple, Implantable Classification: II; Product Code: GDW Subsequent Product Code: GAG Regulation Number: 21CFR 878.4750 Review Panel: General& Plastic Surgery
Indication for Use:
The Single Use Endoscopic Linear Cutters and Reloads have applications in abdominal, gynecologic, pediatric and thoracic surgery for resection, transection of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and biliary structures and for transection and resection of pancreas.
The Single Use Curved Cutters are intended for transection, and/or creation of anastomoses. The instrument has application in multiple open or minimally invasive general (gastrointestinal and skeletal muscle), gynecologic, urologic, and thoracic surgical procedures.
The Single Use Circular staplers have application throughout the alimentary tract for the creation of end-to-end, end-to-side and side-to-side anastomoses in both open and laparoscopic surgeries.
The Single Use Linear Staplers and Reloads have application in the resection of tissue for abdominal, gynecological, pediatric and thoracic surgical procedures.
The Single Use Linear Cutters and Reloads have application in abdominal, gynecological, thoracic and pediatric surgery transection, resection and the creation of anastomoses.
The Single Use Hemorrhoidal Staplers have application for general treatment of hemorrhoids.
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Device Description
The Single Use Curved Cutters place four staggered curved row of titanium staples on the tissue upon activation, and cut the tissue between staple lines. The device is available in 40mm length with reload in 4.8mm staple size.
Single Use Circular staplers place a double staggered, circular row of titanium staples upon activation, which was achieved by squeezing the handles firmly as far as they could go. Immediately after formation of the staples, the excess tissue will be resect by the circular knife, and then a circular anastomosis is created. The stapler are available in 25mm, 27mm and 33mm three specifications. The staple is available in two specifications which are 4.8mm, 5.2mm to be used per different thickness of the tissue.
Single Use Endoscopic Linear Cutters and Reloads place two, triple-staggered rows of progressive titanium staples and simultaneously divides the tissue from central line. The devices are available in 30mm, 45mm and 60mm three lengths. Reloads are available in three staple sizes to accommodate various tissue thicknesses: 2mm-3mm, 4mm-5mm. The device may be reloaded and fired up to 8 times in a single procedure.
Single Use Linear Staplers and Reloads place a double staggered row of titanium staples and is available in 30mm, 45mm, 60mm and 100mm staple line length for use in various applications. Two staple sizes (3.5mm and 4.8mm) are available to accommodate various tissue thicknesses. It may be reloaded and fired up to 7 times for a total 8 firing in a single procedure.
Single Use Linear Cutters and Reloads place two double staggered rows of titanium staples and simultaneously cut and divides tissue between the two double rows. The devices are available in 60mm, 80mm and 100mm lengths. Reloads are available in two staple sizes to accommodate various tissue thicknesses: 3.8mm and 4.8mm. It may be reloaded and fired up to 7 times for a total 8 firings in a single procedure.
Single Use Hemorrhoidal Staplers are a set of instruments that place a double staggered, circular row of titanium staples. Immediately after the formation of staples, the circular knife blade resects the excess of compressed mucosa. The stapler are available in 32mm, 34mm two specifications. The staple size is 4.0mm. It cannot be reloaded.
- 5. Identification of Predicate Devices
Predicate Device 1 510(k) Number: K131511
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Product Name: Disposable Circular Stapler Disposable Linear Staplers and Reloads Disposable Hemorrhoidal Stapler Disposable Linear Cutter Staplers and Reloads Disposable Curved Cutter Stapler
Predicate Device 2 510(k) Number: K111825 Product Name: Endo GIATM Staplers
- б. Non-Clinical Test Conclusion
Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
- A ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process.
- > ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity.
- > ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity
- > USP 38-NF 33 <85> Bacterial Endotoxins Tests
- > ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials;
- > ASTM F1140/F1140M-13 Standard test methods for internal pressurization failure resistance of unrestrained packages;
- > ISO 11137-2: 2013 Sterilization of health care products -Radiation- Part 2: Establishing the sterilization dose
Bench test was conducted on swine stomach and intestine tissue for both proposed device and predicate device to determine substantially equivalence. The bench tests include following tests
- > Pressure Resistance Test
- > Closed Staple Height Test
- A Staple Formation Test
- > Force Required to Fire Stapler Test
- 7. Clinical Test Conclusion
No clinical study is included in this submission.
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#### 8. Substantially Equivalent (SE) Comparison
| Item | Proposed Device | Predicate Device 1 |
|--------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|
| Product Code | GDW | K131511 |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Curved Cutters are intended for transection, resection, and/or creation of anastomoses. The instrument has application in multiple open or minimally invasive general (gastrointestinal and skeletal muscle), gynecologic, urologic, and thoracic surgical procedures | Same |
| Cutting Mechanism | Curved Knife | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Reset Knob is used for preventing from mis-firing | Same |
| Closed staple height | 2.0mm | 1.9mm |
| Closed staple form | Image: staple form | Image: staple form |
| Patient-contact material | Unalloyed Titanium<br>Polycarbonate<br>Stainless Steel | Same |
| Sterilization | Irradiation Sterilization | Same |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
## Table 1 Comparison of Technology Characteristics for Single Use Curved Cutters
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| Item | Proposed Device | Predicate Device 1 |
|-----------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|
| Product Code | GDW | K131511 |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Circular staplers have<br>application throughout the alimentary<br>tract for the creation of end-to-end,<br>end-to-side and side-to-side<br>anastomoses in abdominal or thoracic<br>surgeries. | Same |
| Cutting Mechanism | Circular Knife | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Insurance is used for preventing from<br>mis-firing | Same |
| Closed staple height | 2.0mm, 2.2mm | Same |
| Closed staple form | Image: staple form | Image: staple form |
| Patient-contact<br>material | Unalloyed Titanium<br>Acrylonitrile-Butadiene-Styrene<br>Stainless Steel | Similar |
| Sterilization | Irradiation Sterilization | Same |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
Table 2 Comparison of Technology Characteristics for Single Use Circular Staplers
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| Item | Proposed Device | Predicate Device 2 |
|--------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|
| | | K111825 |
| Product Code | GDW | Same |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Endoscopic Linear<br>Cutters and Reloads have<br>applications in abdominal,<br>gynecologic, pediatric and thoracic<br>surgery for resection, transection and<br>creation of anastomosis. They may be<br>used for transection and resection of<br>liver substance, hepatic vasculature<br>and biliary structures and for<br>transection and resection of pancreas. | Same |
| Cutting Mechanism | Linear Knife | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Green button for preventing from<br>mis-firing | Same |
| Closed staple height | 0.8-1.5mm, 1.5-2.25mm, 2.25-3.0mm | Same |
| Closed staple form | Image: staple form | Image: staple form |
| Patient-contact material | Unalloyed Titanium<br>Acrylonitrile-Butadiene-Styrene<br>Stainless Steel | Unknown |
| Sterilization | Irradiation Sterilization | Unknown |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
Table 3 Comparison of Technology Characteristics for Single Use Endoscopic Linear Cutters and Reloads
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| Item | Proposed Device | Predicate Device 1 |
|--------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|
| Product Code | GDW | K131511 |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Linear Staplers and Reloads have application in the resection or transection of tissue for abdominal, gynecological, pediatric and thoracic surgical procedures. | Same |
| Cutting Mechanism | N.A. | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Safety release for preventing from mis-firing | Same |
| Closed staple height | 1.5mm, 2.0mm | 1.5mm, 1.8mm |
| Closed staple form | | Image: Closed staple form |
| Patient-contact material | Unalloyed Titanium<br>Polycarbonate<br>Stainless Steel | Same |
| Sterilization | Irradiation Sterilization | Same |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
Table 4 Comparison of Technology Characteristics for Single Use Linear Staplers and Reloads
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| Item | Proposed Device | Predicate Device 1 |
|--------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|
| | | K131511 |
| Product Code | GDW | Same |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Linear Cutters and Reloads have application in abdominal, gynecological, thoracic and pediatric surgery transection, resection and the creation of anastomoses. | Same |
| Cutting Mechanism | Linear Knife | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Safety release for preventing from mis-firing | Same |
| Closed staple height | 1.5mm, 2.0mm | 1.5mm, 1.8mm |
| Closed staple form | Image: staple form | Image: staple form |
| Patient-contact material | Unalloyed Titanium<br>Polycarbonate<br>Stainless Steel | Same |
| Sterilization | Irradiation Sterilization | Same |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
Table 5 Comparison of Technology Characteristics for Single Use Linear Cutters and Reloads
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| Item | Proposed Device | Predicate Device 1 |
|--------------------------|---------------------------------------------------------------------------------------------|--------------------|
| Product Code | GDW | K131511 |
| Regulation Number | 21 CFR 878.4750 | Same |
| Intended Use | The Single Use Hemorrhoidal Staplers have application for general treatment of hemorrhoids. | Same |
| Cutting Mechanism | Circular Knife | Same |
| Operation Principle | Manual | Same |
| Safety Mechanism | Safety release for preventing from mis-firing | Same |
| Closed staple height | 2.0mm | 1.9mm |
| Closed staple form | Image: staple form | Image: staple form |
| Patient-contact material | Unalloyed Titanium<br>Acrylonitrile-Butadiene-Styrene<br>Stainless Steel | Same |
| Sterilization | Irradiation Sterilization | Same |
| Endotoxin Limit | 20 EU | Same |
| Labeling | Conforms with 21 CFR 801 | Same |
Table 6 Comparison of Technology Characteristics for Single Use Hemorrhoidal Cutters
- 9. Substantially Equivalent (SE) Conclusion
Based on the comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.
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.