The Ergonomic Products Workstation is a dental operative unit, which is an AC-powered device that is intended to supply power to and serve as a base for other dental devices and accessories. The device is to be operated and used by dentists and other legally qualified professionals.
Device Story
Ergonomic Products Workstation serves as a consolidated dental operative unit; provides air, water, vacuum, and electricity to handheld dental instruments; acts as a base for dental accessories. Used in professional dental offices by dentists and qualified practitioners. Features include doctor/assistant tables, instrument holders, mechanical controls for air/water, and various storage/utility options (e.g., consumable bins, waste bins, USB outlets). Device facilitates organized delivery of care by centralizing instrument support and utility connections. No patient-contacting surfaces; no clinical data required.
Clinical Evidence
No clinical data. Bench testing only. Device conforms to IEC 60601-1 (safety), ISO 7494-1 (dental units), and ISO 7494-2 (water/air supply). Biocompatibility testing not required as device has no patient-contacting surfaces.
Technological Characteristics
AC-powered dental operative unit. Materials: mechanical enclosure, solid surface work areas. Features: pivoting delivery system, control block, handpiece oil collector, solids collector, self-contained water system, quick disconnects. Connectivity: electrical outlets, USB outlets. Standards: IEC 60601-1, ISO 7494-1, ISO 7494-2. No software-based algorithm or patient-contacting materials.
Indications for Use
Indicated for use by dentists and legally qualified professionals as a base and power supply for dental devices and accessories in a professional dental office setting.
Regulatory Classification
Identification
A dental operative unit and accessories is an AC-powered device that is intended to supply power to and serve as a base for other dental devices, such as a dental handpiece, a dental operating light, an air or water syringe unit, and oral cavity evacuator, a suction operative unit, and other dental devices and accessories. The device may be attached to a dental chair.
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APR 1 8 2014
## Ergonomic Products, Inc. Workstation Traditional 510(k) Premarket-Notification Submission
# Traditional 510(k) Summary
| A) Manufacturer: | Ergonomic Products, Inc.,<br>767 Main Road, Suite One<br>Westport, MA 02790<br>Phone Number: 1- 866-374-6487<br>Fax: 508-636-3680 |
|---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|
| Consultant: | Global Regulatory Compliance<br>767 Main Road, Suite One<br>Westport, MA 02790<br>401-651-6513<br>Contact: Renee Gould |
| B) Date Prepared: | February 11, 2014 |
| C) Device Name | Unit, Operative Dental |
| Proprietary Name: | Ergonomic Products Workstation |
| Device Regulations: | 21 CFR 872.6640 |
| Class: | II |
| Product Code: | EIA |
| Review Panel: | Dental |
| D) Predicates: | K000966 A-Dec 4631 Duo Delivery System, A-Dec, Inc.<br>K935325 A-Dec Cascade 3072 Wallmount, A-Dec, Inc.<br>K962071 Spirit S1/S2, Pelton & Crane, Co. |
# E) Device Description:
The Ergonomic Products Workstations provide a consolidated work area for the purpose of delivering air, water, vacuum, and electricity to handheld instruments, and is for use in a professional dental office by professional dental practitioners for administering care to dental patients. Ergonomic Products manufactures dental office delivery units in several formats, all using the same technology - Doctor Workstation, Hygiene Inwall Workstation, Universal Cart and Assistant Cart.
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F) Intended Use:
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The Ergonomic Products Workstation is a dental operative unit, which is an AC-powered device that is intended to supply power to and serve as a base for other dental devices and accessories. The device is to be operated and used by dentists and other legally qualified professionals.
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# G) Comparison to Predicate Device(s):
| | Ergonomic Products<br>Workstations | A-Dec<br>4631 Duo Delivery System<br>K000966<br>Cascade 3072 Wallmount<br>K935325 | |
|-------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------|
| Product code | EIA | EIA | |
| Intended Use/ Indication<br>for Use | The Ergonomic Products<br>Workstation is a dental<br>operative unit, which is an AC-<br>powered device that is intended<br>to supply power to and serve as<br>a base for other dental devices<br>and accessories. The device is to<br>be operated and used by dentists<br>and other legally qualified<br>professionals. | This device delivers air, water,<br>vacuum and electricity to<br>handheld instruments, for use in<br>a professional dental office. It is<br>designed to be used by<br>professional dental practitioners<br>for administering care to dental<br>patients. | Are dental<br>powered<br>power to<br>other devices<br>accessories<br>operated<br>other legally<br>professi |
| Description | Doctor/assistant tables with<br>instrument holder and<br>mechanical enclosure with<br>controls for air and water. | Doctor/assistant tables with<br>instrument holder and<br>mechanical enclosure with<br>controls for air and water. | Doctor/assistant<br>instrument<br>mechanical<br>controls |
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| Product Features/<br>Technological Characteristics | Ergonomic Products<br>Carts | A-Dec Carts | Pelton &<br>Crane Spirit<br>Carts |
|----------------------------------------------------|---------------------------------|---------------------------------|------------------------------------|
| Formats | Multiple including<br>wallmount | Multiple including<br>wallmount | Multiple<br>including<br>wallmount |
| Pivoting Delivery System | Standard | Standard | Standard |
| Control Block | Standard | Standard | Standard |
| Hand Piece Oil Collector | Standard | Standard | Standard |
| Wet Dry Foot Control | Optional | Standard | Standard |
| Wet Dry Panel Control | Standard | No | No |
| Solids Collector | Standard | Standard | Standard |
| Pivoting Instrument Arm | No | Standard | Standard |
| Autoclavable HVE and Saliva Ejector | Standard | Standard | Standard |
| Self Contained Water System | Standard | Standard | Standard |
| Water Quick Disconnect | Standard | Standard | Standard |
| Flow Control For QD | No | Standard | No |
| Cable Prewiring | Standard | Standard | Optional |
| Duplex Outlet | Standard Single | Standard | Standard |
| Height Adjustable Work<br>Surface | Standard | Standard | Standard |
| Laminate Work Surface | No | Standard | Yes |
| Autoclavable syringe | Optional | Optional | Optional |
| Quick Disconnect for Air | Standard | Optional | Optional |
| Dual HVE | Optional | Optional | Optional |
| Quad Voltage Interoral Light<br>Source | No | Optional | Optional |
| Programmable Chair<br>Touchpad | No | Optional | Optional |
| Arm Mount Tray Holder | Solid Surface 2nd Tier | Optional | Standard |
| Solid Surface Worksurface | Standard | Optional | Standard |
| Computer Keyboard Tray | Standard | No | Optional |
| USB Outlet | Standard 2 Locations | No | No |
| Consumable Bin | Standard | No | No |
| Med Waste Bin | Standard | No | No |
| Bien Air handpiece integration | Optional | No | Optional |
| Piezo scaler | Optional | Optional | Optional |
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#### Substantial Equivalence Discussion
The Ergonomic Products Workstation has the same Intended Use, is a base for other dental devices and accessories, and has the same basic feature set as the predicate devices. Differences in format and/or options do not raise new issues of safety or effectiveness. Therefore, the Ergonomic Products Workstation is substantially equivalent to the predicate devices.
#### Performance
No specific performance standards promulgated for this device, and not specific performance testing was conducted.
Biocompatibility was not required as the Workstations have no patient contacting surfaces.
### Conformity to Standards
- . IEC 60601-1: 2005+C1:2009 +A2: 2010 Medical electrical equipment - Part 1: General requirements for safety
- ISO 7494-1 First edition 2004-11-01 Dentistry Dental units Part 1: General . requirements and test methods
- . ISO 7494-2 First edition 2003-03-01 Dentistry - Dental units - Part 2: Water and air supply
### Conclusion
The Ergonomic Products Workstation has the same Intended Use, is a base for other dental devices and accessories, and has the same basic feature set as the predicate devices. Therefore, the Ergonomic Products Workstation is substantially equivalent to the predicate devices.
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Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles a human figure embracing another person, representing the department's mission of protecting the health of all Americans.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
#### April 18, 2014
Ergonomic Products, Inc. C/O Ms. Renee Gould Principal Consultant Global Regulatory Compliance 240 Annette Ave Woonsocket, RI 02895
Re: K132315
Trade/Device Name: Ergonomic Products Workstation Regulation Number: 21 CFR 872.6640 Regulation Name: Unit, Operative Dental Regulatory Class: II Product Code: EIA Dated: March 4, 2014 Received: March 13, 2014
#### Dear Ms. Gould:
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.
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Page 2 - Ms. Gould
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 (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 tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Image /page/6/Picture/7 description: The image shows a logo with the letters FDA. The letters are stylized and have a three-dimensional appearance, with multiple outlines creating a layered effect. The logo is simple and bold, making it easily recognizable.
Digitally signed by Richard C. Chapman Date: 2014.04.18 11:13:15 -04'00'
for
Erin I. Keith, M.S. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
#### Enclosure
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# Indications for Use
510(k) Number (if known):
Device Name: Ergonomic Products Workstation
Indications for Use: The Ergonomic Products Workstation is a dental operative unit, which is an AC-powered device that is intended to supply power to and serve as a base for other dental devices and accessories. The device is to be operated and used by dentists and other legally qualified professionals.
Prescription Use X OR (21 CFR 801, Subpart D)
Over-the-Counter Use (21 CFR 801, Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NECESSARY)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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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.
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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?
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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.
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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.
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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.
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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.
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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.