K093613 · Escalon Medical Corp. · IYN · Dec 23, 2009 · Radiology
Device Facts
Record ID
K093613
Device Name
VASCUVIEW TAP ULTRASOUND SYSTEM
Applicant
Escalon Medical Corp.
Product Code
IYN · Radiology
Decision Date
Dec 23, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1550
Device Class
Class 2
Attributes
Pediatric, 3rd-Party Reviewed
Indications for Use
The VascuView TAP Ultrasound System with probe Model #HL.7.5/40/64D is intended for diagnostic imaging of the human body for the following clinical applications, as illustrated in the Diagnostic Indications for Use Form which can be found in Attachment 5A: Pediatric, Musculo-skeletal (Conventional), Musculo-skeletal (Superficial), Peripheral Vessels which include Intra-Venous and Perioherally-Inserted Central Catheters, as well as vascular structures and surrounding vascular regions such as nerve bundles and various structures for free hand placement of needles/catheters. The VascuView TAP Ultrasound System is not intended for fetal or ophthalmic applications.
Device Story
VascuView TAP is a high-frequency ultrasonic imaging system for vascular access guidance. Input: ultrasonic echoes captured by a 64-element linear array probe (5-10MHz). Processing: beam-former PCB transforms echoes into B-Mode, Split Screen Dual B-Mode, Color Doppler (CFM), and B-Mode with Doppler (PWD) images. Output: real-time visualization on a 12.1" TFT XGA LCD touch-screen tablet PC. Used in clinical settings by healthcare providers for needle/catheter placement. System features fixed hard-coded parameters; no user adjustments to radiated field (frequency, aperture, focus). Benefits: improved visualization of peripheral vessels and surrounding structures to facilitate accurate vascular access.
Clinical Evidence
No clinical data submitted. Evidence consists of bench testing, including compliance with international safety standards (IEC 60601 series) and measurement accuracy validation using an ATS model 539 phantom (0.7 dB/cm-MHz attenuation). Software validated via test protocol.
Technological Characteristics
Tablet-based ultrasound system; 64-element linear array probe (5-10MHz); gold-plated polymer membrane transducer with biocompatible silicone nose cone. Modes: B-Mode, Split Screen Dual B-Mode, Color Doppler, PWD. Connectivity: SCSI cable to tablet PC. Standards: IEC 60601-1, 60601-1-2, 60601-1-4, 60601-2-37, ISO 10993 (biocompatibility). Fixed-parameter software architecture.
Indications for Use
Indicated for pediatric, musculoskeletal (conventional/superficial), and peripheral vascular imaging (including IV and PICC lines) to guide needle/catheter placement and visualize vascular structures/nerve bundles. Contraindicated for fetal or ophthalmic applications.
Regulatory Classification
Identification
An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
SONOACE PICO Diagnostic Ultrasound System (K061213)
{0}------------------------------------------------
K09 3da3
2440 South 179th Street New Berlin, WI 53146 Tel 800-433-8197 Fax 262-821-9927 www.escalonvascularaccess.com
Image /page/0/Picture/3 description: The image is a logo for Escalon Vascular Access, a division of Escalon Medical Corp. The logo features a stylized "VA" with a catheter running through it horizontally. To the right of the "VA" is a symbol resembling radio waves or a signal, possibly representing access or communication.
#### Summary of Safety and Effectiveness Information
This summary of 510(k) safety and effectiveness for the VascuView TAP™ Ultrasound System is being submitted in accordance with the requirements of the Safe Medical Devices Act (SMDA) of 1990 and the Premarket Notification Procedures of 21 CFR; Part 807, Subpart E, Section 807.92 upon which the substantial equivalence (SE) determination is based.
| Submitter's Name | Escalon Medical Corp<br>2440 South 179th Street<br>New Berlin, WI 53146<br>800-433-8197 262-821-9182<br>Fax 262-821-9927 |
|------------------------|----------------------------------------------------------------------------------------------------------------------------|
| Contact Person | Roger Edens<br>Vice-President Engineering<br>Tel: (262) 821-9182<br>Fax: (262) 821-9927<br>reddens@escalonmed.com |
| Date of Preparation | October 13, 2009 |
| Device Trade Name | VascuView TAP™ Ultrasound System |
| Common Name(s) | Ultrasonic Pulsed Echo Imaging System<br>Diagnostic Ultrasound Transducer |
| Classification Name(s) | Ultrasonic Pulsed Echo Imaging System<br>FR Number: 892.1560<br>Product Code: 90-IYO |
| | Diagnostic Ultrasound Transducer<br>FR Number: 892-1570<br>Product Code: 90-ITX |
| | Ultrasonic Pulsed Doppler Imaging System<br>FR Number: 892-1550<br>Product Code: 90-IYN |
| Device Classification | Class II |
| Predicate Device(s) | SONOACE PICO Diagnostic Ultrasound System<br>510(k) Number: K061213<br>SE Clearance Date: May 16, 2006 |
| | Sonosite iLook 25 Personal Imaging Tool<br>510(k) Number: K033367<br>SE Clearance Date: November 5, 2003 |
DEC 2 3 2009
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#### VascuView TAP Device Description
The VascuView TAP Ultrasound System is a high-frequency ultrasonic imaging system intended to be used for assisted vascular access of veins and arteries, in addition to other vascular access applications such as the real-time viewing of perigheral vascular structures and their surrounding regions in order to provide quidance for the placement of needles and catheters within these structures. The system software runs on Windows XP Professional Operating System and utilizes features of the Windows interface to direct the operation of the system and maintain patient records; providing a user-friendly environment for clinical applications. The VascuView TAP System consists of the following components:
- UL and TUV 60950 Approved Tablet PC with Integrated Outer Enclosure . A Kiosk tablet oc is provided with a UL approved Medical-grade power supply and Medical-grade power cord. The VascuView TAP ultrasound system consists of an integrated carrying handle. probe holder, cord wrap, table stand, and shock absorbent corner bumpers. The pc includes a large 12.1" TFT XGA LCD wide angle display which facilitates an intuitive touch screen control interface with clear-cut functionality and preset settings to ameliorate image optimization. Additionally, the oc provides for the operation of the software, as well as the storage of archived images and video clips.
- . Ultrasound Beam-former PCB with 64-element Linear Array Probe The handheld ultrasound probe Model #HL7.5/40/64D and beam-former PCB consists of a sixtyfour element pulsed linear array capable of capturing both images and videos in four different modes of operation: B-Mode, Split Screen Dual B-Mode, Color Doppler (CFM), and B-Mode with Doppler (PWD). The probe is connected to the pc via the included SCSI cable and operates within a frequency range of 5MHz -- 10MHz, which allows for the visualization of surface vessels at scan depths up to 9cm. The transducer material is made of a gold plated polymer membrane and a biocompatible nose cone sufficient for its use (Silicon).
- . VascuView TAP System Software
All features and controls of the system are provided for in the VascuView TAP software which comes pre-loaded onto the tablet pc. The software uses an icon-based interface whereby the user can select any of the primary functional screens at any time by clicking on an icon located on the screen, for that function. The software enables ultrasound image storage and display, measurement functions, enhancements, and printing. All parameters within the hard-coding of the VascuView TAP software program are fixed, therefore the user cannot make any adjustments to the operation of the transducer that will have an effect on the radiated field (i.e. center frequency, aperture, focus, field of view, sample rate, etc.)
The VascuView TAP Ultrasound System has been designed, as applicable to its features, to comply with the following product safety standards listed in the table below.
| IEC<br>Standard | IEC 60601-1:2005 Medical Electrical Equipment: Part 1 - General Requirements for Safety IEC 60601-1-1:2000 Medical Electrical Equipment Collateral Standard: Safety Requirements for Medical<br>Electrical Systems IEC 60601-1-2:2001 Medical Electrical Equipment Collateral Standard: Electromagnetic Compatibility IEC 60601-1-4:1996 Medical Electrical Equipment Collateral Standard: Part 4: Safety Requirements for<br>Programmable Electronic Medical Systems IEC 60601-2-37:2004 Medical Electrical Equipment: Part 2 - Particular Requirements for the Safety of<br>Ultrasonic Medical Diagnostic and Monitoring |
|-------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| EN<br>Standard | EN 61000-3-2:2000 Limits for Harmonic Current Emissions EN 61000-3-3:1995 Electromagnetic Compatibility: Limitation of Voltage Fluctuation and Flicker in Low-<br>Voltage Supply Systems with Rated Current Up to 16 Amps EN 55011: 1998 (A1:1999) Group 1, Class A for Industrial, Scientific, and Medical (ISM) Equipment |
| CISPR<br>Standard | CISPR 11:2004 Group 1, Class A, for Industrial, Scientific, and Medical (ISM) Equipment: Radio<br>Frequency Equipment Electromagnetic Disturbance Characteristics Limits and Methods of Measurement |
| ISO<br>Standard | ISO 14971:2007 Medical Devices - Applications of Risk Management to Medical Devices ISO 13485:2003 Medical Devices Quality Management Systems - Requirements for Regulatory Purposes ISO 10993-1:2009 Biological Evaluation of Medical Devices Part 1 -- Evaluation and Testing within a Risk<br>Management Process ISO 10993-5:2009 Biological Evaluation of Medical Devices: Part 5 - Tests for In Vitro Cytoxicity ISO 10993-10:2002 Biological Evaluation of Medical Devices: Part 10 - Tests for Irritation and Delayed-<br>Type Hypersensitivity ISO 10993-11:2006 Biological Evaluation of Medical Devices: Part 11 - Tests for Systemic Toxicity |
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## Intended Use / Indications for Use
The VascuView TAP Ultrasound System with probe Model #HL.7.5/40/64D is intended for diagnostic imaging of the human body for the following clinical applications, as illustrated in the Diagnostic Indications for Use Form which can be found in Attachment 5A: Pediatric, Musculo-skeletal (Conventional), Musculo-skeletal (Superficial), Peripheral Vessels which include Intra-Venous and Perioherally-Inserted Central Catheters, as well as vascular structures and surrounding vascular regions such as nerve bundles and various structures for free hand placement of needles/catheters. The VascuView TAP Ultrasound System is not intended for fetal or ophthalmic applications.
## Device Technology Characteristics and Comparison to Predicate Device(s)
The legally marketed predicate device(s) to which the VascuView TAP Ultrasound System is considered substantially equivalent through the 510(k) premarket notification process are the SONOACE PICO Diagnostic Ultrasound System cleared under K061213 and the SonoSite® iLook 25 Ultrasound System cleared under K033367.
Based on the Comparison with Predicate Devices as shown in the table illustrated in Section 6 of this 510(k) submission, as per the guidance of FDA Substantial Equivalence recommendations, the VascuView TAP Ultrasound System is deemed sufficient in the demonstration of substantial equivalence to both predicate devices. A summarization of the similarities and differences between the VascuView TAP and each of the proposed predicate devices is discussed below.
| Proprietary Device Name | SONOACE PICO Diagnostic Ultrasound System | SonoSite® iLook 25 Ultrasound System |
|-----------------------------|-------------------------------------------|--------------------------------------|
| Trade Name | SONOACE PICO Ultrasound System | iLook 25 Ultrasound System |
| 510(k) Submitter/Holder | Medison, Co., Ltd. | SonoSite, Inc. |
| 510(k) Number | K061213 | K03367 |
| Regulatory Class | Class II | Class II |
| Regulation Number | 21 CFR 892.1550 | 21 CFR 892.1550 |
| Classification Product Code | IYN | IYN |
Summary for explanation of the Predicate Device(s) Technological Characteristics
Similarities of the SONOACE PICO and the VascuView TAP include:
- . Both systems are intended for Pediatric, Vascular, and Musculoskeletal applications.
- Both systems are mobile, software-controlled systems whose function is to acquire ultrasound . data and to display the data in different imaging modes.
- Both systems are capable of displaying images in the following modes of operation: 2D B-Mode, . Color Doppler (CFM), and B-Mode with Doppler (PWD).
- Both systems possess linear measurement capabilities. .
- Both systems include a 64-element linear array probe design operating within a frequency range . of 5MHz - 10MHz.
- Both systems have an LCD display .
- . Both systems include Cine review capabilities.
- Both systems transmit ultrasonic energy into patients. then perform post-processing of received . echoes to generate on-screen display of anatomic structures within the body.
- . Both systems allow for specialized measurements of structures.
- . Both systems provide for on-screen display of thermal and mechanical indices related to potential bio-effect mechanisms
Differences of the SONOACE PICO and the VascuView TAP include:
- . The SONOACE PICO is a dedicated device, while the VascuView TAP system utilizes a tablet pc set up to launch immediately into the VascuView TAP software.
- The VascuView TAP provides for a larger screen to aid in visualization. .
- The SQNOACE PICO offers M-Mode Imaging, Tissue Harmonic Imaging, Trapezoidal Imaging, . and freehand 3D imaging tools of which are not provided for in the Vascuview TAP.
- The SONOACE PICO indications for use includes: fetal applications, whereas the VascuView . TAP is not.
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Similarities of the SonoSite® iLook 25 Ultrasound System and the VascuView TAP include:
- Both systems are intended for Pediatric, Vascular, and Musculoskeletal (both conventional and . superficial), and Peripheral Vessel applications.
- . Both systems are highly portable, software-controlled systems whose function is to acquire ultrasound data and to display the data in different imaging modes.
- Both systems are capable of displaying images in the following modes of operation: 2D B-Mode, . and Color Doppier (CFM) Mode.
- . Both systems possess linear measurement capabilities which incorporate a linear array probe and beamformer (pulser and receiver) circuitry.
- . Both systems provide controls for touch screen data input, menu, freeze, patient information, save and power.
- . Both systems provide a power Doppler mode that displays different colors (red or blue) by determining directionality of blood flow within vessels which, given the anatomical location of the vessel and orientation of the ultrasound probe.
- . Both systems assist the user in determining whether a vessel is a vein or artery by allowing for the observation of whether the vessel is pulsing (indicating an artery) or not (indicating a vein), in addition to anatomical location.
- Both systems include Cine review to retain images for frame-by-frame viewing. .
- Both systems provide for system optimization presets and a crystal display with brightness and . contrast controls.
Differences of the SonoSite® iLook 25 Ultrasound System and the VascuView TAP include:
- The SonoSite® iLook 25 is a dedicated device, while the VascuView TAP system utilizes a tablet . pc set up to launch immediately into the VascuView TAP software.
- . The VascuView TAP provides for a larger screen to aid in visualization; approximately 4x greater in viewing area.
- . The SonoSite® iLook 25 is limited to an internal storage capacity of 74 images, while the VascuView TAP system has virtually unlimited storage (tens of thousands of images on tablet pc hard drive and ability to connect external hard drives if additional storage is required).
- The SonoSite® iLook 25 indications for use includes: fetal applications, whereas the VascuView . TAP is not.
#### Non-Clinical Performance Data
The VascuView TAP will be assessed as verified as compliant with the requirements of several international safety standards, including IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, and IEC 60601-2-37 (including acoustic output limits), and others. Additionally, the measurement accuracy of the VascuView TAP system was confirmed via a measurement validation test protocol (Attachment 8A Measurement Accuracy Validation Report) using an ATS model 539 phantom with 0.7 dB/cm-MHz attenuation. The software has been also been validated using a test protocol.
#### Clinical Performance Data
None submitted.
#### Conclusions from Non-Clinical (and Clinical) Data
Based upon the results of the data as summarized above, the VascuView TAP system has demonstrated that it is as safe, as effective, performs as well as or better than the predicate devices, and includes similar design characteristics and intended use. Furthermore, based on the comparison with the predicate devices as shown in the discussion above, as well as guidance provided by FDA 510(k) Substantial Equivalence Decision-Making Process Flowchart, the Escalon Vascular Access VascuView TAP ultrasound system is deemed to be substantially equivalent to the proposed predicate devices.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle-like symbol with three lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged in a circular fashion around the symbol.
DEC 2 3 2009
Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002
: '
Escalon Medical Corporation % Mr. Mark Job Responsible Third Party Official Regulatory Technology Services LLC 1394 25th Street NW BUFFALO MN 55313
Re: K093613
Trade/Device Name: VU65000 - VascuView TAP Ultrasound System Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic pulsed doppler imaging system Regulatory Class: II Product Code: IYN, IYO, and ITX Dated: December 16, 2009 Received: December 17, 2009
Dear Mr. Job:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and we 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). 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.
This determination of substantial equivalence applies to the following transducers intended for use with the VU65000 - VascuView TAP Ultrasound System, as described in your premarket notification:
## Transducer Model Number
## HL7.5/40/64D
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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.
{5}------------------------------------------------
Page 2 - Mr. Job
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); 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.
This letter will allow you to begin marketing your device as described in your premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus permits your device to proceed to market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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.
If you have any questions regarding the content of this letter, please contact Shahram Vaezy at (301) 796-6242.
Sincerely vours.
Joha C. Myri
for
Janine M. Morris Acting Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure(s)
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# Indications for Use
510(k) Number (if known):
K0936/3
Device Name:
Indications For Use:
VascuView TAP Ultrasound System
The VascuView TAP ultrasound system provides ultrasound imaging of peripheral vascular structures in order to provide for ultrasound guidance for placement of needles and catheters in these structures. The VascuView TAP is also used for ultrasound imaging of vascular structures and surrounding regions of the vascular such as nerve bundles and various structures.
The VascuView TAP ultrasound system is not intended for fetal or ophthalmic applications.
× Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21. CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
_
(Division Sign-Off)_
Division of Reproductive, Abdominal. and Radiological Devices 510(k) Number.
Page 1 of
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#### Appendix G
# Appendix G: Diagnostic Ultrasound Indications For Use Form
VU65000 - Vascu\/iew TAP Ultrasound System System:
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| Clinical Application | Modes of Operations | | | | | | | |
|-----------------------------|------------------------------------|---|---|-----|-----|------------------|-----------------------|---------------------|
| | Specific<br>(Tracks 1 & 3) | B | M | PWD | CWD | Color<br>Doppler | Combined<br>(Specify) | Other*<br>(Specify) |
| General<br>(Track 1 Only) | Opthalmic | | | | | | | |
| Opthalmic | Fetal | | | | | | | |
| | Abdominal | | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | N | | N | | N | Note [1] | |
| | Small Organ (Specify) | | | | | | | |
| | Neonatal Cephalic | | | | | | | |
| Fetal<br>Imaging<br>& Other | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal<br>(Conventional) | N | | N | | N | Note [1] | |
| | Musculo-skeletal<br>(Superficial) | N | | N | | N | Note [1] | |
| | Intravascular | | | | | | | |
| | Other (Specify) | | | | | | | |
| Cardiac | Cardiac Adult | | | | | | | |
| | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral Vessel Note [2] | N | | N | | N | Note [1] | |
| | Other (Specify) Note [3] | N | | N | | N | Note [1] | |
N = new indication; P = previously cleared by FDA; E = added under this appendix
*Example of other modes of operation may include: A-mode, Amplitude Doppler, 3-D Imaging, Harmonic Imaging, Tissue Motion Doppler, and Color Velocity Imaging for prescription use.
Notes:
- [1] B+PW, B+Color Doppler
- [2] Includes Intra-Venous, Peripherally-Inserted Central Catheters
- [3] Imaging of vascular structures and surrounding regions of the yascular such as nerve bundles and various structures for free hand placement of needles/catheters.
Nommhing
(Division Sign-Off) Division of Reproductive, Abdominal and Radiological Device
510(k) Number K0436
{8}------------------------------------------------
## Appendix G
# Appendix G: Diagnostic Ultrasound Indications For Use Form
VU65000 - VascuView TAP Ultrasound System System: Probe Model #HL7 5/40/64D Transducer:
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| Clinical Application | Modes of Operations | | | | | | | |
|-----------------------------|------------------------------------|---|---|-----|-----|---------------|--------------------|------------------|
| General<br>(Track 1 Only) | Specific<br>(Tracks 1 & 3) | B | M | PWD | CWD | Color Doppler | Combined (Specify) | Other* (Specify) |
| Opthalmic | Opthalmic | | | | | | | |
| | Fetal | | | | | | | |
| | Abdominal | | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | N | N | N | | N | Note [1] | |
| | Small Organ (Specify) | | | | | | | |
| | Neonatal Cephalic | | | | | | | |
| Fetal<br>Imaging<br>& Other | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal<br>(Conventional) | N | N | N | | N | Note [1] | |
| | Musculo-skeletal<br>(Superficial) | N | N | N | | N | Note [1] | |
| | Intravascular | | | | | | | |
| | Other (Specify) | | | | | | | |
| | Cardiac Adult | | | | | | | |
| Cardiac | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral Vessel Note [2] | N | N | N | | N | Note [1] | |
| | Other (Specify) Note [3] | N | N | N | | N | Note [1] | |
N = new indication; P = previously cleared by FDA; E = added under this appendix
*Example of other modes of operation may include: A-mode, Amplitude Doppler, 3-D Imaging, Harmonic Imaging, Tissue Motion Doppler, and Color Velocity Imaging for prescription use.
Notes:
- [1] B+PW. B+Color Doppler
- [2] Includes Intra-Venous, Peripherally-Inserted Central Catheters
- [3] Imaging of vascular structures and surrounding regions of the vascular such as nerve bundles and various structures for free hand placement of needles/catheters.
Norm Whing
(Division Sign-Off)
Division of Reproductive, Abdominal. and Radiological Devi
510(k) Number K0936
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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.