K142420 · Macromedics BV · IYE · Mar 27, 2015 · Radiology
Device Facts
Record ID
K142420
Device Name
Patient Positioning Devices
Applicant
Macromedics BV
Product Code
IYE · Radiology
Decision Date
Mar 27, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.5050
Device Class
Class 2
Indications for Use
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
Device Story
Patient positioning devices for radiotherapy and radio diagnostics; includes baseplates, headsupports, thorax/breast supports, pelvic boards, SBRT systems, vacuum cushions, and thermoplastic masks. Devices provide immobilization by creating patient-specific contramoulds or using indexed baseplates on treatment couches. Thermoplastic masks are softened in water, molded to patient anatomy, and attached to baseplates via plastic profiles. Vacuum cushions are molded to patient shape and evacuated. MR-safe versions utilize glass fiber and specific 3-pin coupling mechanisms to prevent use in incompatible environments. Used in clinical radiotherapy departments; operated by radiation therapists or technicians. Output is physical patient immobilization; enables precise radiation delivery by reducing patient movement and improving reproducibility of treatment setup.
Clinical Evidence
Bench testing only. No clinical data provided. Equivalence established through comparison of design, materials, and functionality to legally marketed predicate devices.
Indicated for patient positioning during radiotherapy and radio diagnostics, including MR environments, for patients requiring immobilization for treatment or imaging.
Regulatory Classification
Identification
A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 27, 2015
MacroMedics BV % Ms.Caroline de Keijzer Quality Manager Kouwe Hoek 18 2741 PX Waddinxveen THE NETHERLANDS
Re: K142420
Trade/Device Name: Patient Positioning Devices Regulation Number: 21 CFR 892.5050 Regulation Name: Medical Charged-Particle Radiation Therapy System Regulatory Class: II Product Code: IYE, LNH Dated: February 20, 2015 Received: February 23, 2015
Dear Ms. de Keijzer:
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 (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.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Michael D'Hara
for
Robert Ochs, Ph.D. Acting Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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## 2.5-Indications for Use
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
510(k) Number (if known)
K142420
Device Name
Patient Positioning Devices
Indications for Use (Describe)
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <div style="display:inline-block"><img alt="Checked" src="checkbox_checked.png"/></div> Prescription Use (Part 21 CFR 801 Subpart D) | <div style="display:inline-block"><img alt="Unchecked" src="checkbox_unchecked.png"/></div> Over-The-Counter Use (21 CFR 801 Subpart C) |
|--------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
|--------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
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Image /page/3/Picture/1 description: The image contains the logo for "macromedics", a company that provides solutions in radiotherapy. The logo consists of a stylized letter "m" inside a circle on the left, followed by the company name in a sans-serif font. Below the company name, the tagline "SOLUTIONS IN RADIOTHERAPY" is written in a smaller font.
# 510(k) Summary of safety and effectiveness (As required by 21 CFR 807.92)
| Applicant: | MacroMedics BV |
|---------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Address: | Kouwe Hoek 18, 2741PX, Waddinxveen,<br>The Netherlands |
| Phone:<br>Fax: | 0031-(0)182 389777<br>0031-(0)182 389778 |
| Contact person: | Caroline de Keijzer, Quality and Regulatory Manager |
| Prepare date: | June 13, 2014 |
| Establishment Registration<br>Number: | 10046168 |
| FDA Type: | Traditional 510(k) |
| Common name: | -Head and neck positioning systems.<br>-Lung and thorax positioning systems<br>-Pelvic and lower extremities positioning systems<br>-SBRT systems<br>-Thermoplastic positioning systems |
| Trade / Proprietary name: | Patient Positioning Devices |
| Classification: | Class 2 devices, 892.5050, IYE, LNH |
| Review panels: | Radiology |
| Performance standards: | No applicable performance standards have been issued<br>under section 514 of the Food, Drug and Cosmetic act. |
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Image /page/4/Picture/1 description: The image shows the logo for "macromedics". The logo consists of a blue circle with a stylized "m" inside it, followed by the word "macromedics" in blue. Below the word "macromedics" is the phrase "SOLUTIONS IN RADIOTHERAPY" in a smaller blue font.
#### Head and neck positioning systems (1/2)
ExaFix-5 ExaFix-5A ExaTilt ExaFix-IMRT baseplate ExaFix-IMRT baseplate MR MaxSupport 1,2,3,4,5,6,7 Block low, Block high Wedge 7, 5, 10, 15 MaxSupport 25,35,45
#### Intended use / Indications for use:
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
#### Device description:
Baseplates and headsupports which are designed to position the head and neck and on which thermoplastic masks can be attached to fix the head and neck of the patient. Baseplates can be positioned on the couch using CouchStrips. The ExaFix-IMRT baseplates are attached onto the couches and extent the head of the patient from the couch at the cranial side. Various accessories offered for specific patient head and neck set-ups. The different headsupports are designed for different head positions. Different blocks are available for lifting the head, wedges and ExaTilt to incline the head. For the Exafix-5 baseplate an acrylic alternative (Exafix-5a) is available for identical head- and neck positioning in the MR environment. For the IMRT baseplates a glassfiber alternative (Exafix IMRT baseplate MR) is available for identical head- and neck positioning in MR environment. The MR safe devices have a 3Pin slot on the bottomside and are compatible with the glassfiber 3Pin CouchStrip. The MR unsafe devices are not compatible with the 3Pin MR safe CouchStrip, which prevents the use in the wrong environment.
| MacroMedics devices | Predicate devices: | 510(k) number: |
|--------------------------------------------------------------------|--------------------------|---------------------------------|
| ExaFix-5 | Sinmed Posifix-2 | K060737 (IYE) |
| ExaFix-5A | Sinmed Posifix-1 | K060737 (IYE) |
| | | K093738 (LNH, reference device) |
| ExaTilt | Sinmed Positilt | K060737 (IYE) |
| ExaFix-IMRT baseplate | Sinmed IMRT baseplate | K060737 (IYE) |
| ExaFix-IMRT baseplate MR | Sinmed IMRT baseplate | K060737 (IYE) |
| | | K093738 (LNH, reference device) |
| MaxSupport 1,2,3,4,5,6,7 | Sinmed headsupports | K060737 (IYE) |
| | | K093738 (LNH, reference device) |
| Block low, Block high<br>Wedge 7, 5, 10, 15<br>MaxSupport 25,35,45 | Sinmed Blocks and wedges | K060737 (IYE) |
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Image /page/5/Picture/1 description: The image shows the logo for "macromedics", a company that provides solutions in radiotherapy. The logo consists of a stylized letter "m" inside a circle on the left, followed by the company name in a sans-serif font. Below the company name, the tagline "SOLUTIONS IN RADIOTHERAPY" is written in a smaller font size.
#### Head and neck positioning systems (2/2)
#### Comparision of technological characteristics:
The designs of the MacroMedics and predicate head and neck positioning systems are equivalent in shape, construction materials and functionality. Both the Sinmed devices and the MacroMedics devices are made out of carbon fiber, PE foam and acrylic. MacroMedics uses glass fiber for the MR safe alternative of the carbon fiber IMRT baseplates. The Sinmed headsupports are made out of PE foam, the MacroMedics headsupports have a PU-foam alternative. Both the biocompatibility and the MR safety of these new materials have been described in this 510(k).
#### Substantial equivalence summary:
MacroMedics claims the proposed head and neck positioning systems to be substantially equivalent to the devices previously cleared by the FDA in the 510(k)'s specified above. These devices are also cleared for use in a radiotherapy and/or MR environment.
MacroMedics claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, patient positioning and used materials. Although small technological differences exist, these products have similar position and immobilization characteristics for use radiotherapy and radio-diagnostics.
#### Conclusions:
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Image /page/6/Picture/1 description: The image is a logo for "macromedics". The logo features a stylized letter "m" inside a circle on the left side. To the right of the symbol is the word "macromedics" in a sans-serif font. Below the word "macromedics" is the phrase "SOLUTIONS IN RADIOTHERAPY" in a smaller font.
#### Lung and thorax positioning systems (1/2)
BreastBoard LX ThoraxSupport ThoraxSupport MR
#### Intended use / Indications for use:
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
#### Device description:
The BreastBoard LX and ThoraxSupports are devices which position the breast and lung area of a patient. The arms are placed above the head and a headsupport can be placed into the baseplate. The backsupport of the BreastBoard LX can be tilted, to tilt the upperpart of the patient´s body for other treatment possibilities. The ThoraxSupport does not have this tilting possibility. Various accessories are provided for positioning of the arms or the thorax.
For the ThoraxSupport a glassfiber MR alternative (Thoraxsupport MR) is available for identical lung and thorax positioning in MR environment. The MR safe device has a 3Pin slot on the bottomside and is compatible with the glassfiber 3Pin CouchStrip. The MR unsafe devices are not compatible with the 3Pin MR safe CouchStrip, which prevents the use in the wrong environment.
| MacroMedics Devices | Predicate devices: | 510(k) number: |
|---------------------|--------------------|--------------------------------------------------|
| BreastBoard LX | Sinmed Posiboard | K060737 (IYE) |
| ThoraxSupport | Sinmed Posirest | K060737 (IYE) |
| ThoraxSupport MR | Sinmed Posirest | K060737 (IYE)<br>K093738 (LNH, reference device) |
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Image /page/7/Picture/1 description: The image is a logo for Macromedcis. The logo features a blue circle with a stylized "m" inside of it. To the right of the circle is the word "macromedics" in a sans-serif font, also in blue. Below the word "macromedics" is the phrase "SOLUTIONS IN RADIOTHERAPY" in a smaller, lighter blue font.
#### Lung- and thorax positioning systems (2/2)
#### Comparision of technological characteristics:
The designs of the MacroMedics and predicate lung and thorax positioning systems are equivalent in shape, construction, materials and functionality.
Both the Sinmed devices and the MacroMedics devices are made out of carbon fiber with components of plastic, aluminium and foam. MacroMedics uses glass fiber for the MR safe alternative of the ThoraxSupport. Both the biocompatibility and the MR safety of these new materials have been described in this 510(k).
#### Substantial equivalence summary:
MacroMedics claims the proposed lung and thorax positioning systems to be substantially equivalent to the devices previously cleared by the FDA in the 510(k)'s specified above. These devices are also cleared for use in a radiotherapy and/or MR environment.
MacroMedics claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, patient positioning and used materials. Although small technological differences exist, these products have similar position and immobilization characteristics for use radiotherapy and radio-diagnostics.
#### Conclusions:
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Image /page/8/Picture/1 description: The image shows the logo for Macromedics. On the left is a blue circle with a stylized "m" inside. To the right of the circle is the word "macromedics" in a sans-serif font, also in blue. Below the word "macromedics" are the words "SOLUTIONS IN RADIOTHERAPY" in a smaller, sans-serif font.
#### Pelvic and lower extremities positioning systems (1/2)
Pelvic Prone Board Pelvic Prone Board MR LEPS
#### Intended use / Indications for use:
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
#### Device description:
Baseplates which are designed to position the pelvic or (lower) extremities of a patient. The Pelvic Prone Board positions the patient in prone position with the arms in cranial direction, belly is placed in an aperture. The shape of the pelvic prone board moves the small bowel and reduces the irradiated small bowel volume while treating the lower abdomen.
The LEPS position the legs on a KneeSupport which can be tilted and the feet are positioned in a FeetSupport. Both baseplates can be positioned on the couch using fixation rails.
For the Pelvic Prone Board a glassfiber MR alternative (Pelvic Prone Board MR) is available for identical positioning in MR environment. The LEPS is a MR safe device. The MR safe devices have 3Pin slots on the bottomside and are compatible with the glassfiber 3Pin CouchStrip. The MR unsafe device is not compatible with the 3Pin MR safe CouchStrip, which prevents the use in the wrong environment.
| MacroMedics Devices | Predicate | 510(k) number: |
|-----------------------|-------------------|--------------------------------------------------------|
| Pelvic Prone Board | Sinmed Bellyboard | K060737 (IYE) |
| Pelvic Prone Board MR | Sinmed Bellyboard | K060737 (IYE)<br>K121545 (LNH & IYE, reference device) |
| LEPS | Sinmed Combifix | K060737(IYE)<br>K093738 (LNH, reference device) |
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Image /page/9/Picture/1 description: The image contains the logo for Macromedics, a company that provides solutions in radiotherapy. The logo consists of a circular icon with a stylized "m" inside, followed by the company name "macromedics" in a sans-serif font. Below the company name, the tagline "SOLUTIONS IN RADIOTHERAPY" is written in smaller letters.
#### Pelvic and lower extremities positioning systems (2/2)
#### Comparision of technological characteristics:
The designs of the MacroMedics and predicate pelvic and lower extremities positioning systems are equivalent in shape, construction, materials and functionality. Both the Sinmed devices and the MacroMedics devices are made out of carbon fiber with
components of plastic and foam. MacroMedics uses glass fiber for the MR safe alternative of the Pelvic Prone Board. Both the biocompatibility and the MR safety of this different material have been described in this 510(k).
#### Substantial equivalence summary:
MacroMedics claims the pelvic and lower extremities positioning systems to be substantially equivalent to the devices previously cleared by the FDA in the 510(k)'s specified above. These devices are also cleared for use in a radiotherapy and/or MR environment.
MacroMedics claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, patient positioning and used materials. Although small technological differences exist, these products have similar position and immobilization characteristics for use radiotherapy and radio-diagnostics.
#### Conclusions:
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Image /page/10/Picture/1 description: The image is a logo for "macromedics". The logo features a stylized letter "m" enclosed in a circle on the left side. To the right of the symbol is the word "macromedics" in a sans-serif font. Below the company name is the text "SOLUTIONS IN RADIOTHERAPY".
## SBRT systems (1/2)
SBRT EAMIS SBRT EAMIS Lite SBRT OmniBoard (UATB) SBRT MultiBoard (UTB) SBRT MultiFrame (UTF) VacuumCushions CouchStrips
#### Intended use / Indications for use:
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
#### Device description:
The SBRT systems (Stereotactic Body Radiation Therapy Systems) are devices which can position various bodyparts of the patient. The MacroMedics SBRT systems are carbon fiber baseplates over which various plastic bridges can be placed with attached accessories to position the patient's body. The SBRT OmniBoard does have an inclination possibility of the upper body. The accessories are identical, but the baseboards are different, each baseboard has slightly different features for customer preferences. The patient set-up is similar on all boards, supine position with the arms mainly positioned above the patient's head. Bottom, knees and feet positioned in indexed positions.
Vacuumcushions are used for positioning by moulding the cushion around the patients and then take the air out with a vacuumpump. The contrashape of the patient stays in the cushion during the treatment.
CouchStrips are strips which connect the patient positioning device onto the couch at indexed positions. Depending on the indexing system of the couch, width of the couch, preference in transverse adjustability and required MR safety different types are available.
The SBRT carbon fiber baseplates are MR unsafe and have a 2Pin CouchStrip slot. They are not compatible with the 3Pin MR CouchStrip, which prevents the use in the wrong environment. The CouchStrips for MR are made out of MR safe materials and have 3pins. MR unsafe devices have a 2Pin CouchStrip slot on the bottomside and are not compatible with this 3Pin MR CouchStrip. The Vacuumcushions are MR safe.
| MacroMedics Devices | Predicate devices: | 510(k) number: |
|-----------------------|-------------------------|--------------------------------------------------|
| SBRT EAMIS | CIVCO Body Pro Lok | K111340 (LNH & IYE) |
| SBRT OmniBoard (UATB) | CIVCO Body Pro Lok | K111340 (LNH & IYE) |
| SBRT MultiBoard (UTB) | CIVCO Body Pro Lok | K111340 (LNH & IYE) |
| SBRT MultiFrame (UTF) | CIVCO Body Pro Lok | K111340 (LNH & IYE) |
| SBRT EAMIS Lite | CIVCO Rails-Only System | K111340 (LNH & IYE) |
| CouchStrips | CIVCO LokBar | K111340 (LNH & IYE) |
| VacuumCushions | Sinmed Repovac Cushions | K060737 (IYE)<br>K093738 (LNH, reference device) |
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Image /page/11/Picture/1 description: The image shows the logo for "macromedics". The logo consists of a circular icon with a stylized "m" inside, followed by the word "macromedics" in a sans-serif font. Below the word "macromedics" is the phrase "SOLUTIONS IN RADIOTHERAPY" in a smaller font size. The logo is in a light blue color.
## SBRT systems (2/2)
#### Comparision of technological characteristics:
The designs of the MacroMedics and predicate SBRT positioning systems are equivalent in construction, accessories, materials and functionality. Both the predicate and the MacroMedics SBRT devices are made out of carbon fiber baseplates with bridges of plastic which clamp on the sides of the baseplates, foam head- knee and FeetSupports can be placed at indexed positions. MacroMedics and Sinmed vacuum cushions are both constructed with a small polystyrene bullets in a nylon bag and a valve for creating vacuum.
MacroMedics CouchStrips and the CIVCO LokBars have similar designs, almost identical dimensions and materials. MacroMedics added a carbon fiber alternative for its good mechanical and dosimetric properties.
#### Substantial equivalence summary:
MacroMedics claims the proposed SBRT systems to be substantially equivalent to the devices previously cleared by the FDA in the 510(k)'s specified above. These devices are also cleared for use in a radiotherapy and/or MR environment.
MacroMedics claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, patient positioning and used materials. Although small technological differences exist, these products have similar position and immobilization characteristics for use radiotherapy and radio-diagnostics.
#### Conclusions:
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Image /page/12/Picture/1 description: The image shows the logo for Macromedics. The logo consists of a circular icon with a stylized "M" inside, followed by the word "macromedics" in a sans-serif font. Below the word "macromedics" is the tagline "SOLUTIONS IN RADIOTHERAPY" in a smaller font. The logo is primarily in a light blue color.
## Thermoplastic positioning systems (1/2)
Thermoplastics various sizes and profiles DSPS & SSPS thermoplastic masks DSPS & SSPS cradles
#### Intended use / Indications for use:
Positioning of the patient during radiotherapy and radio diagnostics, including MR where indicated.
#### Device description:
MacroMedics thermoplastic masks are developed in order to position the individual patient. The thermoplastic masks are placed in a waterbath of about 70 degrees where they become flexible. After drying and cooling, they make a perfect contramould of the bodypart which needs to be positioned. Plastic profiles attach the mask onto the baseplate. Masks and profiles are available in many different shapes, in order to fit on different baseplates and bodyparts.
DSPS offers a possibility to create a thermoplastic mask for both occipital- and facial areas for extra accurate positioning. Both masks are attached onto the DSPS cradle, and the DSPS cradle is attached onto the baseplate.
MacroMedics thermoplastic masks with plastic profiles are MR safe.
| MacroMedics devices Predicate devices: | | 510(k) number: |
|-------------------------------------------|-------------------------|---------------------------------|
| Thermoplastics various sizes | Sinmed Posicast | K060737 (IYE) |
| and profiles | immobilization system | K093738 (LNH, reference device) |
| DSPS & SSPS thermoplastic | CIVCO head | K080072 (IYE) |
| masks | immobilization plastics | K093738 (LNH, reference device) |
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Image /page/13/Picture/1 description: The image shows the logo for "macromedics". The logo consists of a circular icon with a stylized "m" inside, followed by the word "macromedics" in a sans-serif font. Below the word "macromedics" is the phrase "SOLUTIONS IN RADIOTHERAPY" in a smaller font.
## Thermoplastic positioning systems (2/2)
#### Comparision of technological characteristics:
The designs of the MacroMedics and predicate systems are equivalent in construction, design, materials and functionality. Both the predicate and the MacroMedics masks are made out of thermoplastics which are cut in shape and glued or welded into plastic injection moulded profiles. Both thermoplastic masks become soft in warm water and make a contrashape of the patient and are connected onto a baseplate, where they become a rigid patient positioning device after cooling. The DSPS cradle is made out of a carbon fiber construction and can be positioned on the baseplate. With the DSPS both a facial and occipital contrashape can be moulded and fixed. The predicate Medtec and CIVCO devices provide a similar occipital moulding possibility.
#### Substantial equivalence summary:
MacroMedics claims the proposed thermoplastic positioning systems to be substantially equivalent to the devices previously cleared by the FDA in the 510(k)'s specified above. These devices are also cleared for use in a radiotherapy and/or MR environment.
MacroMedics claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, product handling, patient positioning and used materials. Although small technological differences exist, these products have similar position and immobilization characteristics for use radiotherapy and radio-diagnostics.
#### Conclusions:
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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.