K130256 · Quanta System Spa · GEX · Jul 2, 2013 · General, Plastic Surgery
Device Facts
Record ID
K130256
Device Name
MDK MULTI-APPLICATIONS PLATFORM
Applicant
Quanta System Spa
Product Code
GEX · General, Plastic Surgery
Decision Date
Jul 2, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The MDK Multi-Applications Platform is laser surgical instrument for use in general and plastic surgery and in dermatology (GEX). The MDK Multi-Applications Platform is intended for use in aesthetic, cosmetic and surgical applications requiring incision, excision, ablation, vaporization and coagulation the medical specialties of dermatology, general and plastic surgery, in endoscopic/laparoscopic general surgery, gastroenterology, gynecology, neurosurgery, otorhinolaryngology (ENT), oculoplastic, oral surgery, ophthalmology (skin around eyes), orthopedics, podiatry, pulmonary/thoracic surgery and urology for surgical and aestetic applications. For intended use in Dermatology for the coagulation and hemostasis of benign vascular leasion such as, but not limited to, rosacea, poikiloderma of civatte, and treatment of benign cutaneous lesions such as warts, scars and straie. Also intended for treatment of wrinkles as, but not limited to, periocular and perioral wrinckles. For intended use on all skin types (Fitzpateick I-VI), including tanned skin.
Device Story
Multi-source laser platform; includes Q-Switched Nd:YAG (1064/532nm), Nd:YAG (1064/1320/532nm), Alexandrite (755nm), and Intense Pulsed Light (IPL) handpieces. Inputs: user-selected parameters via touch screen. Transformation: microprocessor-controlled laser/IPL energy delivery; articulated arm or optical fiber delivery; integrated skin cooler. Output: laser/light energy for tissue interaction. Used in clinical settings (OR, clinic) by physicians. Output allows precise tissue ablation, coagulation, or hair reduction; benefits include reduced side effects via skin cooling and versatility across multiple surgical/dermatological indications. System prevents simultaneous operation of multiple sources.
Clinical Evidence
Bench testing only. No clinical data provided.
Technological Characteristics
Laser surgical platform; Q-Switched Nd:YAG, Nd:YAG, Alexandrite, and IPL sources. Wavelengths: 532nm, 755nm, 1064nm, 1320nm, and IPL (400-1200nm range). Delivery: articulated arm or optical fiber with focusing handpieces. Integrated skin cooler. Microprocessor-based controller for parameter selection. Power: AC mains converted to regulated power for flash-lamps. Cooling: internal water flow circuit with heat exchanger. Software: microprocessor-based, non-adaptive, rule-based control of laser/IPL parameters.
Indications for Use
Indicated for patients requiring soft tissue incision, excision, ablation, vaporization, coagulation, and hemostasis across various medical specialties including dermatology, plastic surgery, general surgery, gynecology, ENT, neurosurgery, orthopedics, pulmonary, thoracic, and urology. Specific applications include tattoo/pigmented lesion removal, hair reduction, vascular lesion treatment, and acne treatment. Suitable for all Fitzpatrick skin types (I-VI), including tanned skin.
Regulatory Classification
Identification
(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
{0}------------------------------------------------
# K130256
# 7. 510(K) SUMMARY
# JUL 0 2 2013
### Introduction:
This document contains the 510(k) Summary for the MDK Multi-Applications Platform. The content of this summary is based on the requirements of 21 CFR 807.92(c).
| Applicant / Manufacturer Name and Address: | Quanta System SPA<br>Via IV Novembre, 116<br>Solbiate Olona (VA)<br>Italy, 21058 |
|--------------------------------------------|-----------------------------------------------------------------------------------------|
| 510(k) Contact Person: | Maurizio Bianchi<br>Regulatory Affairs Manager<br>Quanta System SPA |
| | Email: maurizio.bianchi@quantasystem.com |
| | Phone: +39 0331 376797 |
| | Fax: +39 0331 367815 |
| Date Prepared: | November 20 <sup>th</sup> , 2012 |
| Device Name: | MDK Multi-Applications Platform |
| Classification: | Class II |
| Classification Name: | Laser surgical instrument for use in general and<br>plastic surgery and in dermatology. |
| Regulation Number: | 21 CFR 878.4810 |
| Product Code: | GEX |
### Predicate Devices:
The MDK Multi-Applications Platformis claimed to be substantially equivalent to the following legally marketed predicate devices:
- Ultrawave II (K070805) Quanta System SpA ﮯ
- -Ultrawave III (K083207) - Quanta System SpA
- Q-Plus T (K073549) Quanta System SpA -
- Q-Plus T +IPL (K123168) Quanta System Spa -
{1}------------------------------------------------
### Performance Standards:
There are no mandatory performance standards for this device.
## General Device Description:
The MDK Multi-Applications Platform is laser surgical instrument for use in general and plastic surgery and in dermatology (GEX). The device includes a Q-Switched Nd:YAG laser source emitting at 1064 nm and 532 nm wavelengths, and/or an Nd:YAG laser source emitting at 1064 nm (short and long pulse) and/or at 1320 nm and/or at 532 nm, and/or an Alexandrite laser source emitting at 755 nm (long pulse) and/or an intense pulsed light (Twain IPL Handpiece).
The optical delivery system for the Q-Switched Nd:YAG laser source (1064nm and 532nm) is an articulated arm with fixed handpieces. The optical delivery system for the Nd:YAG laser source ( 1064nm long/short pulse, 755 nm long pulse, 532 nm long pulse and 1320 nm long pulse) is an optical fiber with focusing handpieces up to 12mm spot size. The optical delivery system for the IPL system is an handpiece (Twain IPL) with interchangeable light filter at different wavelengths.
IMPORTANT NOTE: The MDK Multi-Applications Platform control software allows to work only one laser source or IPL at time: it means that the laser sources works separately and indipendently. Moreover the Intense Pulse Light cannot work with any laser sources. Combined (simultaneously or sequentially) operations of different laser sources and/or IPL is not allowed.
The MDK Multi-Applications Platform architecture is based on the following main subsystems: (1) an high voltage power supply, which converts and rectifies the AC mains current to provide requlated power for the flash-lamps, simmer current and main triggering pulse; (2) a cooling system consisting of an internal water flow circuit together with water-to-air heat exchanger; (3) a Q-switched Nd:YAG laser source, capable of generating very short pulses at 1064nm and at 532 nm through a suitable (4) KTP SGH crystal. capable of converting light pulses at 1064nm into light pulses at 532nm: (5) a Nd:YAG laser source, capable of generating laser pulses at 1064nm or 1320nm wavelength and at 532 nm through a suitable (6) KTP SGH crystal, capable of converting light pulses at 1064nm into light pulses at 532nm: (7) an Alexandrite laser source, capable of generating laser pulses at 755nm with frequency up to 1,5 Hz; (8) an Intense Pulsed Light handpiece system (Twain IPL), capable of generating light pulses at a frequency of 0.5 Hz; (9) the microprocessor based controller, which requilates the functions of the laser and allows parameter selection by the user; (10) an optical delivery system, interfacing the energy from the laser to the patient via an articulated arm and focusing hand piece; (11) an optical delivery system, interfacing the energy from the laser to the patient via an optical fiber and focusing hand piece: and (12) an integral skin cooler.
{2}------------------------------------------------
The MDK Multi-Applications Platform is controlled via a touch screen display hosted in the front of the device where are also located the key switch, the emergency red push button and the operation led. On the rear panel the footswitch connector, the remote interlock and the power switch are located.
### Indications for Use
The MDK Multi-Applications Platform is laser surgical instrument for use in general and plastic surgery and in dermatology (GEX).
The MDK Multi-Applications Platform is intended for use in aesthetic, cosmetic and surgical applications requiring incision, excision, ablation, vaporization and coagulation the medical specialties of dermatology, general and plastic surgery, in endoscopic/laparoscopic general surgery, gastroenterology, gynecology, neurosurgery, otorhinolaryngology (ENT), oculoplastic, oral surgery, ophthalmology (skin around eyes), orthopedics, podiatry, pulmonary/thoracic surgery and urology for surgical and aestetic applications.
For intended use in Dermatology for the coagulation and hemostasis of benign vascular leasion such as, but not limited to, rosacea, poikiloderma of civatte, and treatment of benign cutaneous lesions such as warts, scars and straie. Also intended for treatment of wrinkles as, but not limited to, periocular and perioral wrinckles.
For intended use on all skin types (Fitzpateick I-VI), including tanned skin.
### Comparison of Technological Characteristics:
The specifications for the MDK Multi-Applications Platform is substantially equivalent to the specifications for its identified predicate devices with respect to the laser and IPL sources, wavelengths, maximum energy, spot size, fluence, pulse width, repetition rate, beam delivery, power monitor, actuator, and aiming beam.
### Comparison of Intended Use:
The intended use of the MDK Multi-Applications Platform is the same as the intended use of its previously cleared devices.
### Substantial Equivalence:
The Quanta System MDK Multi-Applications Platform is as safe and effective as the predicate devices.
The MDK Multi-Applications Platform has the same intended use and similar technological characteristics and principles of operation as its predicate devices. The
{3}------------------------------------------------
minor technological differences between the MDK Multi-Applications Platform and its predicate devices raise no new issues of substantial equivalence or safety and effectiveness. . .
Thus, MDK Multi-Applications Platform is substantially equivalent to its identified predicate devices. .
{4}------------------------------------------------
Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of a human figure embracing a bird.
### DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G60 Silver Spring, MD 20993-002
July 2, 2013
Quanta System SpA % Mr. Maurizio Bianchi Via IV Novembre No 116 21058 Solbiate Olona (VA), Italy
Re: K130256
Trade/Device Name: MDK Multi-Applications Platform Regulation Number: 21 CFR 878.4810 Regulation Name: Laser surgical instrument for use in general surgery and plastic surgery and in dermatology Regulatory Class: Class II Product Code: GEX Dated: June 01, 2013 Received: June 05, 2013
Dear Mr. Bianchi:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act, The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA 's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21
{5}------------------------------------------------
Page 2 - Mr. Maurizio Bianchi
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events} (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/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.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
FOR
Mark N. Melkerson Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Peter D. Rumm -S
Enclosure
{6}------------------------------------------------
510(k) Number (if known): K130256
#### Device Name: MDK Multi-Applications Platform
### Indications for Use:
The MDK Multi-Applications Platform is is in assthetic and surgical applications requiring incision, extision ablation, vaporization and coagulation of body soft tissues
In the modical specialites of demations plastic surgery, endoscopic/lapercecopic general surgery, gastroenlerology, gynecology, otorhinolaryngology (ENT), neurosurgery, oral surgery as follows:
#### Nd:YAG 1064nm Q-switched and 632nm Q-switched
The MDK Mull-Applications Platform is intention of vacular lesions, pigmented teslons, and for hair, tattoo removel and the incision, excision, ablation, vaporization of soft tissue.
#### General dermatology
(attation, vaportzation, incision, excision and coagulation of set tissue) indicated for treatment such as but not limited to treatment of: Tatloo removal
- 1064nm: suggested for dark blue and black ink
- 532nm: suggested for red, orange, yellow, and purple ink 0
- Pigmented lesion removal (benign)
- Caté au lait spot 0
- Ephalides, solar lentigo (lentigines
- Becker News
- Ota Nevus
- Nevus sodus
Prescription Use (Part 21 C.F.R. 801 Subpart D) AND/OR
Over-The-Counter Use (21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE) Neil R Ogden ....
Neil R Ogden
2013.06.27 15:13:32 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number K130256
Pag_1_of_6
{7}------------------------------------------------
### 510(k) Number (if known): K130256
#### Device Name: MDK Multi-Applications Platform Indications for Use: continued
#### Nd: YAG 1064nm (long & ghort RH&D)
The MDK Multi-Applications Platorn is interest surgical applications; dermatoryplastic surgen; andoscopic - laprosecopic surgery; general surgery; gynecology; ENT; hemostmaly; occuloplasios; putmonary surgery; thoracle surgery; and orthopsdics.
#### General Sumical Appl .:
Incision, excision, cosgulation, hemostation, andor abletion of soft ilsue in dermatology & plastic surgery, endoscopic laparoscopic general surgery, ganeel surgery, gynecdogy, head and neck-obrhindlaryngology (ENT), neurosurgery, oculoplastics, orthopedics, pulmonary surgery, thoracic surgery and urology.
#### Dermatology/Plastic Surgery;
Coaguation and hemostasis of beline such as, but not limited to, port wine stains, hemantionas, werb, telangiectass rosacea, venus lake, leg and spieler veins and civate and treatmant of benign cutuneous lesions such as wards, scars, strae and psodasis. It addition, the laser is intention of benign pigmented lessins such as but not limited to, lentigos (goe spots), solar laniaca (sun socies, seborteic keraloses, nevi, chossme, verruce, skip lace, kerabeas, tattoor (significant reduction in the intensity of blue and/or black tattoos), and plaques.
The laser is also indicated for pigments lesion size, for palients with testins that would potentially benefit from aggressive treatment, and for patients with lesions that have not responded to other laser treatments.
The laser is also indicated for the treatment of facial wrinkles.
It is indicated for the removal of unwanted half for the stable long-larm, or permanent, hair reduction of melario in hair follices, and for the treatment of people (PFB). Pormanent hair reduction is delined as the bonglarm, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
It is indicated for the reduction of red pigmentation in hypertophic and kebid scars where vascularity is an integral part of the scar. It is indicated for use on all skin types (Fitzpatic) 1-1) } including tanned akin, and the removal and permanent reduction of unwarded hair in Fitzpatrick I-VI, including suntanned skin types.
#### Orthopedics:
Cutting, ablation, and/or hemostasis of intro-articular tissue in orthopedic surgical and arthroscopic applications,
#### Pulmonary Sumary
Paliative treatment of beign and meilight postousions, including squartous cell carcinoma, adenocarcinoma carcinoid, benign turnors, granulomas, and benign strictures.
Over-The-Counter Use Prescription Use AND/OR (Part 21 C.F.R. 801 Subpart D) (21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Neil R Ogden -- 3 2013.06.27 15:14:00 =04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510{k) Number K130256
{8}------------------------------------------------
### 510(k) Number (if known): K130256
Device Name: MDK Multi-Applications Platform
### Indications for Use: continued
#### Nd:YAG 1064nm (long & short pulse) - Continued
Thoracis Sumary Including excision, coegulation of set lissue. Thoracic applications, including but not limited to, isotation of vessels for endarterectomy and/or by-pass
grafts, wedge resections, thoractor of pacemaker pockets; vaporization, coaghation, incisionexcision, debuiking, and ablation of lung tissue (thoracoscopy).
Urology:
All applications including supericial urnors, invasire bladder carcinoma, uretoral strictures and lealins of the orternal genitalia (including condyloma acuminate).
#### Nd:YAG_1320mm
Indicated for use in general surgery and dematology for the incision, ablation, vaporization, coagulation and haemostasis of soft tosue. It is also indicated for the treatment of perioral wrinkles, fine lines and wrinkles, and the beathers of back acne and strophic acne scars.
#### Alexandrite 766 mm
Intention for coagulation and hemostasions and the removal and permanent reduction of unwanted hair in Fitzpatick skin types I-VI, beluding suntamed skin indicated for pigmented tesions and writtings. Parmanent hair roduction is defined as the long-larm, stable reduction in the number of halm measured at 6. 9, and 12 months after the campletion of a treatment regime.
Prescription Use (Part 21 C.F.R. 801 Subpart D) AND/OR
### Over-The-Counter Use (21 C.F.R. 807 Subpart C)
### (PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Neil R Ogden. 2013.06.27 15:14:24 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number K130256
{9}------------------------------------------------
510(k) Number (if known): K130256
Device Name: MDK Multi-Applications Platform
### Indications for Use: continued
#### Nd:YAG_532nm (Long puke)
For the coagulation and hemostasis of vascular lesions.
#### Dermatology/Plastic Surgery:
For photocogniation and hemostasis of vasular and colaneous including but not limited to, the following general categories: vascular lesions (engiomas (port wine), telangiecasia (facial or ex-tremities telangiectasias, venous anomalios, leg veinst, benign pigmanted lastons, chlossma, cate au- lat, tattoos (red and green ink), vernucae, skin tags, keraloses, plaques, cutaneous lesion treatment (hemostasis, color lightening, flattening, reduction of lesion size.
#### General Surgery:
Vaporizing, Caagulating, Incising, Debulking, and Ablating of Soll Tissue as well as in Endoscopic (e.g., laparecopic) or open surgeries.
#### Gastroenterology:
Tissue ablation and hemostals in the gastronities track Esophaged necknown , including squamous call carcinoma and adenocarcherna; Gastrontestinal hemosas, Esophagitis, Esophageal Ucor, Mallory-Weiss taar, Gastic Ucer, Anglodysplassa, Stomal Ucers, Non-bleeding Ulcors, Gestrontastinal Tissue ablation (Benign and Malignant neoplasm, Angiodysplasia, Polyps, Ulcer, Colitis, Hemorrhoids).
#### Head and Otorhinolaryngology (ENT); Tissue incluin, excision, ablation, and vessel hernostasis
#### Hemostasis during Surgery
Adjunctive coagulation and hemostasis (bleeding control) during surgery in endoscopic (e.g., laparoscopic) and open surgery
#### Neurosurgery:
Hemostasis for: Pituitary Tumor, Memagioblastoms; AVMs; Globlasbona; Astrocytoma; Ollyodendroglioma.
### Qphthalmology:
Post-vitrectorny endophotocoagulation of the retina.
Prescription Use (Part 21 C.F.R. 801 Subpart D) AND/OR
### Over-The-Counter Use (21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Connerrence of CDRH, Office of Device Evaluation (ODE) Neil R Ogden
2013.06.27 115:15:03 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number_K130256
{10}------------------------------------------------
510(k) Number (if known): K130256
Device Name: MDK Multi-Applications Platform
### Indications for Use: continued
### Nd:YAG_632nm (long_pulse) - continued
#### Pulmonary Surgery,
Pallative treatment of benign and malling sistery obstructions, including Squamous Coll Carcinoma, Adenocarcinoma; Carcinoid: Benign Tumors; Granulomas; Banign Strictures.
#### Thoracic Surgery,
Cuting (incision and excision), coagueling of soft tissue Thoracic applications including, but not limited to: Isolation of vessels for endartecetony and/or by-pass grafts, Wedge Resections, Formation of Pacemation pockets. Vaporization, coagulation, incision and excision, debulking, and ablation offing tissue (Thoracoscopy).
#### Urology:
All applications including: Superficial urinary bladder carcinoma; Urethrol Stricture; Lesions of the external genitalia (including condyloma acuminata).
#### IPL 590-1200nm: 626-1200nm: 660-1200nm
Indicated for permanent hair removal,
Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
#### IPL 560-1200nm;670-1200nm
Indicated for phoboxagulation of dermanlogical vascular lesion (i.e. face telangiectasia), photothermolysis of blood vessels (restment of facial and leg veins), and treatment of benign pigmented lesions
#### IPL 400-1200mm
Indicated for inflammatory acne (acne vulgaris).
Prescription Use (Part 21 C.F.R. 801 Subpart D) AND/OR
### Over-The-Counter Use (21 C.F.R. 807 Subpart C)
### (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Commirrence of CDRH, Office of Device Evaluation (ODE) Neil R Ogden ... . . . . .
2013.06.27 15:15:34 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number K130256
{11}------------------------------------------------
510(k) Number (if known): K130256
Device Name: · MDK Multi-Applications Platform
#### Indications for Use: continued
#### Integrated Skin Cooler
The intended use of the integrated cooling system in the MDK Multi-Applications Platorm hand-piece is to provide cooling of the skin prior to laser treatment, for the reduction of painting laser treatment, to allow for the use of higher flucinces such as hair removal and vascular lesion, and to reduce the potential side effects of laser treatments.
Any other different use is considered incorrect.
· Prescription Use _ × (Part 21 C.F.R. 801 Subpart D) AND/OR
Over-The-Counter Use (21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
# Concurrence of CDRH, Office of Device Evaluation (ODE)
Neil R Ogden ( 4) 2013.06:27 11:5:16:01 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number K130256
Pag 6 of 6
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
Learn the FDA Browser
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.