VASCULAB VL4000 PHOTOPLETHYSMOGRAPH WITH PULSE VOLUME RECORDING
Applicant
Us Vascular, LLC
Product Code
JOP · Cardiovascular
Decision Date
Sep 27, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2880
Device Class
Class 2
Indications for Use
The VL40xx is a Non-Invasive diagnostic system designed to detect peripheral vascular pathology in adults. In all cases the intended use is for spot checking and attended use by trained medical professionals in a hospital or medical facility by the order of a medical doctor. The VL40xx is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field.
Device Story
The VascuLab VL40xx is a non-invasive peripheral vascular diagnostic system used by trained medical professionals in hospitals or clinics. It utilizes three primary modalities: Continuous Wave (CW) Doppler (4 or 8 MHz probes), Photoplethysmography (PPG), and Pulse Volume Recording (PVR). Inputs include acoustic signals from blood flow (Doppler), reflected IR light (PPG), and pressure changes in pneumatic cuffs (PVR). The device processes these signals to display heart-beat waveforms and calculate segmental systolic blood pressures and pressure indices (e.g., ABI). The system features a base unit with a PCB, battery, and speaker; optional modules include PPG sensors and pneumatic air channels (2, 6, or 12). Operators interact via keyboard, mouse, touchscreen, or wireless remote. The system provides visual waveform traces and numerical data to assist clinicians in detecting peripheral vascular pathology. It supports data management features like patient history, printing, and DICOM/Structured Reporting. The device benefits patients by providing non-invasive, objective vascular assessments to guide clinical decision-making.
Clinical Evidence
Bench testing only. The device underwent biocompatibility, electrical safety, mechanical safety, acoustic output, EMC emissions/immunity, and functional performance testing. No clinical data was required or presented.
Technological Characteristics
System includes CW Doppler (4/8 MHz), PPG, and PVR modalities. Materials include standard medical-grade plastics and electronics. Connectivity includes USB, DICOM/SR, and wireless remote. Software is embedded, performing signal processing and data management. Tested to EN-60601-1, IEC-60601-1-2, IEC-60601-2-37, IEC-62304, ISO 14971, and ISO 10993 standards.
Indications for Use
Indicated for adult patients requiring non-invasive peripheral vascular diagnostic evaluation. Not for fetal applications or use within the sterile field.
Regulatory Classification
Identification
An ultrasonic transducer is a device applied to the skin to transmit and receive ultrasonic energy that is used in conjunction with an echocardiograph to provide imaging of cardiovascular structures. This device includes phased arrays and two-dimensional scanning transducers.
{0}------------------------------------------------
K131860
# 510(k) Summary 807.92(c)
| Sponsor Company Name: | US Vascular, LLC | 807.92(a)(1) |
|---------------------------|--------------------------------------------|--------------|
| Company Address: | 4970 SW Menlo Drive<br>Beaverton, OR 97005 | |
| Telephone: | 800-326-1169 | |
| Contact Person: | Galen Spooner | |
| Summary Preparation Date: | June 20, 2013 | |
| Device Name: | | 807.92(a)(2) |
| Trade Name: | VascuLab VL40xx, VL4000, VL4010, VL4030 | |
| Common/Usual Name: | CW Doppler, PPG, VPR / PVR | |
| Classification Name: | Transducer, Ultrasonic | |
| Regulation Number: | 21 CFR 870.2880 | |
| Product Code: | JOP | |
| Device Classification: | Class II | |
#### Predicate Device
#### 807.92(a)(3)
| 510k Number - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - | :<br>and and the first of the first of the first of the first of | " -- " Company --------------------------------------------------------------------------------------------------------------------------------------------------------------- |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Viasonix, LTD | Falcon/Pro, Falcon/Quad and | K111416 |
| | Falcon/ABI+ | |
#### Device Description
#### 807.92(a)(4)
The VL40xx is a family of products designed for non-invasive peripheral vascular diagnostic systems. The VL40 indicates the family of products that are all made from the same parts with the only differences being that some parts are not installed or some features are not enabled. The "xx" will be used to indicate the family of products. Options of what Doppler or PPG probes are installed do not qualify for a specific model number because there is no physical change to the device to add them. Different air channels require a model number because the valves require a physical change to the device that can only be done at the factory. Specifically the following models are used.
- . Model 4000: full system, twelve channel air
- Model 4010: full system, two channel air portable .
- Model 4030: ABI (Ankle Brachial Index), six channel air .
The base unit has the same main printed circuit board (PCB), battery, speaker, software, and power supply.
{1}------------------------------------------------
Adding the PPG option requires installing a PCB module to the main PCB and attaching the PPG sensors to the outside of the case.
Adding the Doppler requires attaching the desired frequency probe (4 or 8 MHz) to the case. All Doppler frequency probes use the same PCB logic. This means that any probe frequency can be added without any changes to the main PCB or the connectors. The universal Doppler probe is possible because all the Doppler electronics are in the probe. The device PCB for the Doppler only has the logic to turn on the probe and read the data. The Doppler probe has all the electronics to control the IQ signal separation and power output of the probe.
Adding the temperature reading requires purchasing a cleared FDA IR temperature probe from a 3rd party (example Exergen model TAT 5000, K011291). The IR device is a complete standalone product with its own FDA clearance. The VL40xx simply provides a method in software for the operator to record the temperature samples in a table for convenience of reporting. The temperature tests protocols do not care about the absolute temperature readings but do care about the differential readings. What is important is the temperature difference of before and after readings.
For the above features there are no changes to the case and the changes can be made at any time.
The following features require changes to the back panel of the case to support the number of air hoses. The number of air hoses installed is 2, 6, or 12. Internally only the required valves, pressure sensors, and pumps will be installed. Adding air hoses later would require a new case and the appropriate valves, pressure sensors, and pumps to be added. It is much easier to install all the valves and manage the air connectors by choosing what air hoses are attached externally. Unless weight / portability are an issue the easiest solution will always be to choose the 12 air hose system and manage the external air hoses. The external air hoses can be changed at any time to create a system that has 2-12 air hoses as needed. The VL4000 is the model with all air hoses enabled internally.
The air hoses are color coded to help the user attach them to the correct blood pressure cuff. Each air hose has a Red for Right and Lemon for Left code in addition to another color (white, black. orange, yellow, blue, and green) to help identify the location of the software always displays the color of the side (Red or Lemon) and the color of the location that it intends to use. The system has no way to determine that the user connects the air hose to the correct cuff at the correct location.
The software for all models is exactly the same. The software automatically detects what features are installed. All models have the following software features: patient history, comments, storage, printing, print preview, configuration, and online help. Optional software features include Modality Work List (MWL), exporting of data using DICOM Images / Structured Reporting, email, native PDF, long term data storage, data mirroring, and online support.
The VL4030 ABI system will have all tests disabled in software except for the ABI specific tests.
One of the main measurements of the system is segmental systolic blood pressures. In general, the measurement is conducted by applying an appropriately sized cuff to the measured segment, obtaining
{2}------------------------------------------------
a reference PPG or a Doppler signal in a location distal to the cuff placement, and then inflating the cuff to such a pressure that will occlude the blood vessels and prevent blood flow distal to the cuff location, which will result in disappearance of the reference signal. Then, a slow cuff deflation begins, and the instantaneous cuff pressure at which the reference signal reappears is typically defined as the segmental systolic blood pressure. While the software automatically places a cursor at the time location which is suspected as being the systolic pressure, it is the total responsibility of the system operator and the medical staff to modify the cursor location according to their medical training, and define the correct segmental pressure.
Based on the segmental pressures, the pressure indices are calculated, as the ratio between the systolic segmental pressure, and the higher of the 2 brachial systolic pressures that does not exceed a noncompressible limit (usually 240 mmHg). The ABI index is a commonly used index, which is a specific case of the above, calculated as the systolic right or left ankle pressure, divided by the hight or left brachial systolic pressure.
The other main measurement of the system is recording a wave that represents the flow of blood for each heartbeat. The three main modalities for this are the Doppler, PPG, and PVR wave forms. All three of these modalities produce a wave form that has a systolic up stroke, a diastolic down stroke, a pause, and a repeat. Researchers have shown that the shape of these waveforms is a great indicator of disease and that the actual measurement of the wave is not as important.
The system has a wireless remote control. Everything that the remote can do can also be done with the keyboard. The advantage of the remote is that it provides the most common functions needed to perform the measurement without requiring the operator to reach for the keyboard.
If the IR remote is not available then the user will access the VL40xx using a directly wired keyboard, mouse, or touchscreen.
The scientific principal of CW Doppler in very high level terms is as follows. A crystal is cut in half. One half of the crystal has a 4 or 8 MHz sine wave applied. When the acoustic output of the crystal is focused into human tissue it will bounce back and be absorbed by the remaining crystal. Any Doppler effect caused by moving blood can be detected in the phase shift when the transmitted signal is compared with the echoed signal. The phase shift for blood in humans is usually less than 6 kHz and therefore makes for a nice audio signal that can easily be heard. Most modern CW Doppler systems will use IQ modulation and FFT to detect the spectral of the audio signal returned. Tracing the envelope of the spectral will provide the familiar heart beat trace. The CW Doppler can measure the velocity of blood in a specific artery.
The scientific principal of PPG in very high level terms is as follows. An Infra-Red pulse is provided by an LED and applied to the skin. The blood and tissue will absorb and reflect the IR signal. The amount of blood in the capillaries will determine how much IR signal is absorbed or reflected. An LED sensor is applied that measures the reflected IR signal. Displaying the LED sensor output will provide the familiar heart beat trace. The PPG can measure the change in blood flow in the skin.
25
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#### K131860 page 4 of 9
The scientific principal of VPR in very high level terms is as follows. A cuff is placed around an arm or leg and inflated to 60 mmHg. The higher the pressure without occluding the blood flow (below systolic blood pressure) will produce the best pressure change in the cuff for each heartbeat will cause a pressure change in the cuff ranging from 0.01 – 0.5 mmHg. Displaying the pressure sensor output will provide the familiar heart beat trace. The VPR can measure the change in blood flow for a network of arteries.
The speaker is located on the front of the VL40xx and all other connectors (Doppler, PPG, VPR, USB, power supply, and status LEDs) are on the back.
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Image /page/4/Picture/1 description: The image shows two views of a VascuLab 410 device. The first image shows the top, front, and side of the device, including a speaker. The second image shows the top, back, and side of the device, including several ports and tubes. The date 2012/10/11 is visible in the bottom right corner of both images.
27
{5}------------------------------------------------
Image /page/5/Picture/1 description: The image shows a collection of medical equipment and accessories. There is a class II power supply with a cable, an IR remote receiver with a USB cable, and color-coded air hoses. Additionally, there are PPG sensors, BP cuffs, and a Doppler probe with a cable. The date 2012/10/11 is visible in the corner of some of the images.
#### Indications for Use
807.92(a)(5)
The VL40xx is a Non-Invasive diagnostic system designed to detect peripheral vascular pathology in adults. In all cases the intended use is for spot checking and attended use by trained medical professionals in a hospital or medical facility by the order of a medical doctor.
The VL40xx is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field.
{6}------------------------------------------------
## Comparison of Technical Characteristics
# 807.92(a)(6)
| Feature | Falcon<br>Pro, Quad, ABI+ | VL40xx<br>VL4000, VL4010, VL4030 | Diff |
|----------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|
| 510(k) number | K111416 | this 510(k) | |
| classification | JOP | JOP | |
| date | 2011-11-15 | pending | |
| manufacture | Viasonix | US Vascular | |
| Indications for Use | intended for use in the<br>noninvasive evaluation of<br>peripheral vascular pathology in<br>patients.<br>The devices are not intended to<br>replace other means of<br>evaluating vital patient<br>physiological processes, are not<br>intended to be used in fetal<br>applications, and are not<br>intended to be used inside the<br>sterile field.<br>They are to be used by trained<br>medical personnel in hospitals,<br>clinics and physician's offices by<br>prescription or doctor's orders. | A Non-Invasive diagnostic system<br>designed to detect peripheral<br>vascular pathology in adults. In<br>all cases the intended use is for<br>spot checking and attended use<br>by trained medical professionals<br>in a hospital or medical facility<br>by the order of a medical doctor.<br>The VL40xx is not intended to<br>replace other means of<br>evaluating vital patient<br>physiological processes, is not<br>intended to be used in fetal<br>applications, and is not intended<br>to be used inside the sterile field. | |
| battery powered | no | yes | 1 |
| auto cuff inflation | yes | yes | |
| pressure channels | 4, 10 | 2, 6, 12 | 2 |
| PVR sensors | 4, 10 | 2 | 2 |
| PPG sensors | 4, 5 | 2 | 2 |
| CW Doppler probes | 4, 8, 10 MHz | 4, 8 MHz | 3 |
| acoustic testing | track 1 | track 1 | |
| Max Ispta.3 4 MHz | 691 mW/cm² | 177 mW/cm² | 4 |
| Max Ispta.3 8 MHz | 662 mW/cm² | 249 mW/cm² | 4 |
| Doppler volume control | yes | yes | |
| Doppler spectral | 256 FFT | 256 FFT | |
| Directional Doppler invert | yes | yes | |
| Doppler envelope | yes | yes | |
·
:
{7}------------------------------------------------
| Feature | Falcon<br>Pro, Quad, ABI+ | VL40xx<br>VL4000, VL4010, VL4030 | Diff |
|--------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|
| Temperature Measurement | Yes, auto | Yes, manual | |
| remote control | yes | yes | |
| touch screen | yes | yes | |
| mouse & keyboard | yes | yes | |
| printer | yes | yes | |
| strip chart | no | no | |
| DICOM/SR | yes | yes | |
| patient storage | yes | yes | |
| Doppler, PVR, segmental<br>pressure, exercise, reflux,<br>Raynauds | yes | yes | |
| Standards tested to | EN-60601-1 (1990)<br>IEC-60601-1-2 (Ed3:2007)<br>IEC-60601-2-37 (2007)<br>IEC-62304 (2006)<br>ISO 14971 (2007) | EN-60601-1 (1990)<br>IEC-60601-1 (Ed2:1998)<br>IEC-60601-1-1 (Ed2)<br>IEC-60601-1-2 Ed3:2007<br>NEMA UD-2 (2004)<br>IEC-62304 (2006)<br>ISO 14971 (2007)<br>ISO 10993-* | |
The following technical characteristics where differences exist were compared to determine if any new issues of safety and efficacy exists.
# 1) Battery powered
Marketing requires the device to have eight hours of battery life and be able to recharge overnight.
## 2) Number of pressure, PVR, and PPG channel
Marketing requires an option to cover the least expensive, the full coverage, and something in the middle. US Vascular and Viasonix marketing guys tend to disagree on the number of channels to provide at the desired price points. The number of channels has no effect diagnostically.
## 3) 10 MHz Doppler Probe
Marketing does not require the option of a 10 MHz probe.
## 4) Doppler Performance
US Vascular and Viasonix make no public claims to the sensitivity or accuracy of their Doppler probes. Bench testing shows the US Vascular Doppler to be as sensitive as the
{8}------------------------------------------------
Viasonix with significantly less power output. US Vascular power output has almost 200% tolerance to the FDA limits. The Viasonix power output has less than 10% tolerance.
#### Non-Clinical Testing
#### 807.92(b)(1)
The VascuLab VL40xx (VL 4000, VL40010, and VL4030) range of non-invasive peripheral vascular diagnostic systems have been subjected to Bio-Compatibility, Electrical Safety, Mechanical Safety, Acoustic Output, EMC emissions and immunity, and performance testing by certified laboratories. Internally the VL40xx is subjected to unit testing, verification, performance testing, and validation to ensure that the devices meet all of their functional specifications.
The VascuLab VL40xx (VL 4000, VL40010, and VL4030) range of non-invasive peripheral vascular diagnostic systems labeling includes instructions for safe and effective use, warnings, cautions and guidance for use. In addition, all of the warnings, cautions, and instructions for use are provided by the program for immediate online review by the user. It is therefore shown to be safe and effective.
#### Conclusions
#### 807.92(b)(3)
The conclusion drawn from these tests is that the VascuLab VL40xx (VL 4000, VL40010, and VL4030) range of non-invasive peripheral vascular diagnostic systems are equivalent in safety and efficacy to the predicate devices listed in the predicate product comparison table above.
{9}------------------------------------------------
Public Health Service
Image /page/9/Picture/13 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles a caduceus, which is a traditional symbol of medicine, but in this case, it is a more abstract design.
September 27, 2013
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Us Vascular, Lic E.J. Smith 1468 Harwell Ave Crofton, MD 21114 US
Re: K131860
Trade/Device Name: Vasculab v14000 photoplethysmograph with pulse volume recording Regulation Number: 21 CFR 870.2880 Regulation Name: Ultrasonic Transducer Regulatory Class: Class II Product Code: JOP Dated: August 30, 2013 Received: August 30, 2013
Dear E.J. Smith:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting 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 contact 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
{10}------------------------------------------------
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 Small Manufacturers, International and Consumer Assistance at its to!!-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
# Owen P. Faris -S
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{11}------------------------------------------------
K131860
page 1 of 3
# Indications for Use Form
Indications for Use
510(k) Number (if known):
Device Name: VL4000 (VL40XX)
Indications for Use:
The VL40xx is a Non-Invasive diagnostic system designed to detect peripheral vascular pathology in adults. In all cases the intended use is for spot checking and attended use by trained medical professionals in a hospital or medical facility by the order of a medical doctor.
The VL40xx is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field.
Prescription Use X (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 OF NEEDED)
### Concurrence of CDRH, Office of Device Evaluation (ODE)
Page _ 1_ of _ 1_
# Owen P. Faris -S
19
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#### Contains Nonbinding Recommendations Appendix G
# Appendix G: Example Diagnostic Ultrasound Indications For Use Format
US Vascular Model VL40xx System: 4 MHz CW Model MTB HD.CW0400.02 Transducer:
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| Clinical Application | | Mode of Operation | | | | | | |
|-----------------------------|------------------------------------|-------------------|---|-----|-----|------------------|-----------------------|---------------------|
| General<br>(Track 1 Only) | Specific<br>(Tracks 1 & 3) | B | M | PWD | CWD | Color<br>Doppler | Combined<br>(Specify) | Other*<br>(Specify) |
| Ophthalmic | Ophthalmic | | | | | | | |
| Fetal<br>Imaging<br>& Other | Fetal | | | | | | | |
| | Abdominal | | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | | | | | | | |
| | Small Organ (Specify) | | | | | | | |
| | Neonatal Cephalic | | | | | | | |
| | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal<br>(Conventional) | | | | | | | |
| | Musculo-skeletal<br>(Superficial) | | | | | | | |
| | Intravascular | | | | | | | |
| | Other (Specify) | | | | | | | |
| Cardiac | Cardiac Adult | | | | | | | |
| | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral vessel | | | | N | | | |
| | Other (Specify) | | | | | | | |
N = new indication; P = previously cleared by FDA; E = added under this appendix
* Examples of other modes of operation may include: A-mode, Amplitude Doppler, 3-D Imaging, Harmonic Imaging, Tissue Motion Doppler, and Color Velocity Imaging
{13}------------------------------------------------
Contains Nonbinding Recommendations Appendix G
# Appendix G: Example Diagnostic Ultrasound Indications For Use Format
US Vascular Model VL40xx System: 8 MHz CW Model MTB HD.CW0800.02 Transducer:
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| Clinical Application | | Mode of Operation | | | | | | |
|-----------------------------|------------------------------------|-------------------|---|-----|-----|------------------|-----------------------|---------------------|
| General<br>(Track 1 Only) | Specific<br>(Tracks 1 & 3) | B | M | PWD | CWD | Color<br>Doppler | Combined<br>(Specify) | Other*<br>(Specify) |
| Ophthalmic | Ophthalmic | | | | | | | |
| Fetal<br>Imaging<br>& Other | Fetal | | | | | | | |
| | Abdominal | | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | | | | | | | |
| | Small Organ (Specify) | | | | | | | |
| | Neonatal Cephalic | | | | | | | |
| | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal<br>(Conventional) | | | | | | | |
| | Musculo-skeletal<br>(Superficial) | | | | | | | |
| | Intravascular | | | | | | | |
| | Other (Specify) | | | | | | | |
| Cardiac | Cardiac Adult | | | | | | | |
| | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral vessel | | | | N | | | |
| | Other (Specify) | | | | | | | |
N = new indication; P = previously cleared by FDA; E = added under this appendix
* Examples of other modes of operation may include: A-mode, Amplitude Doppler, 3-D Imaging, Harmonic Imaging, Tissue Motion Doppler, and Color Velocity Imaging
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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.