K160667 · Anybattery, Inc. · DPS · May 11, 2017 · Cardiovascular
Device Facts
Record ID
K160667
Device Name
Anybattery C2 Rechargeable Battery
Applicant
Anybattery, Inc.
Product Code
DPS · Cardiovascular
Decision Date
May 11, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2340
Device Class
Class 2
Indications for Use
To power the functions of various devices for which batteries or battery packs are configured. Since rechargeable batteries and battery packs are "device specific" and are designed to operate and fit into the equipment for which they were manufactured only qualified personnel should evaluate, test, charge, or install these devices. Battery Packs are shipped only to customers who request a replacement battery for a particular device or to replace a competitor's battery. The biomedical equipment technician therefore knows the intended use is as a replacement battery.
Device Story
Anybattery C2 Rechargeable batteries serve as primary or backup DC power sources for various medical devices (e.g., defibrillators, ECGs, patient monitors). Batteries are installed by biomedical equipment technicians in clinical settings. Input is electrical energy during charging; output is DC power to the host medical device. Operation relies on chemical reactions within Nickel-based (NiCd, NiMH) or VRLA (SLA, Gel, AGM) cells. The device maintains critical parameters and data in host equipment during power disruptions. Performance is validated against OEM benchmarks for voltage, capacity, and cycle life. Benefits include continued operation of life-critical medical equipment during power loss or mobility.
Clinical Evidence
Bench testing only. No clinical data. Performance validated via Vencon UBA Battery Analyzers using charge/discharge cycles. Testing included voltage/polarity checks, capacity threshold testing (pass/fail at 90% nominal capacity), temperature range testing (0, 25, 40°C), and mechanical integrity (drop tests).
Indicated for use as a primary or standby/backup DC power source for portable and stationary medical equipment, specifically as a replacement battery for devices for which they are configured.
Regulatory Classification
Identification
An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 14, 2017
Anybattery, Inc. % Claude Berthoin President Denterprise International, Inc./510k FDA Consulting 100 East Granade Blvd., Suite 219 Ormond Beach, Florida 32176
Re: K160667
Trade/Device Name: Anybattery C2 Rechargeable Battery, with list of 28 models attached Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II Product Code: DPS, LOS, LDD, DRT, MHX, DSI, MLD, MSX, MWI, DOK, DXH, FLL, DQA, DSJ, DSK, DSF, BZQ, and DXN Dated: April 5, 2016 Received: April 11, 2017
Dear Claude Berthoin:
This letter corrects our substantially equivalent letter of May 11, 2017.
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
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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 (OS) 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 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. 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 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,
M.A. Wilhelm
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Anybattery, Inc. List of all batteries cleared in K160667
(Total of 28 battery models, due to some batteries being grouped together under one predicate)
# Anybattery C2 Rechargeable Batteries in the VRLA Product Family.
1. Anybattery 3394 is substantial equivalent to that manufactured by:
- Zoll D-900 defibrillator cleared K913484. .
- 2. Anybattery 4028 is substantial equivalent to that manufactured by:
- Hewlett-Packard Pagewriter XLI M1700A & Pagewriter XL M1701A cleared . K895520.
- 3. Anybattery 4040 is substantial equivalent to that manufactured by:
- HP 43100 series defibrillator monitors cleared K910754. ●
- 4. Anybattery 4043 is substantial equivalent to that manufactured by:
- Hewlett-Packard Monitor, Patient Model 78333A cleared K760160. ●
- 5. Anybattery 4494 is substantial equivalent to that manufactured by:
- Physio-Control LifePak 9 Defibrillator & Cardiac Monitor cleared K881153. ●
- 6. Anybattery 4494-2 is substantial equivalent to that manufactured by:
- Physio-Control LifePak 9 series defibrillator monitors cleared K902288. ●
- 7. Anybattery 4510 is substantially equivalent to that manufactured by:
- Welch Allyn Protocol Propaq cleared K012451. ●
- 8. Anybattery 4713-2 is substantial equivalent to that manufactured by:
- Physio-Control Lifepak 10 defibrillator cleared K931053. ●
- 9. Anybattery 5349-4 is substantial equivalent to that manufactured by:
- Nihon-Kohden TEC-7511A/TEC-7521A CardioLife Portable Defibrillator & . Accessories cleared K971436.
- 10. Anybattery 6558 is e substantial equivalent to that manufactured by:
- Spacelabs Healthcare Telemetry Receiver cleared K141156 & K925510. ●
- 11. Anybattery 7714-1 and 7714-2 are substantial equivalent to that manufactured by:
- Colin Pressmate PM2100 VSM cleared K022537. .
- 12. Anybattery 8601 is substantial equivalent to that manufactured by:
- Welch Allyn Atlus Monitor cleared K984033. .
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## Anybatterv C2 Rechargeable Batteries in the Nickel-Based Rechargeable Batterv Product Eamily
- 1. Anybattery 3777 is substantial equivalent to that manufactured by:
- . Burdick EK10 Series ECG cleared K870880.
- 2. Anybattery 4218 is substantial equivalent to that manufactured by
- General Electric MAC Series Electrocardiographs cleared K991735. .
- 3. Anybattery 4227 is substantial equivalent to that manufactured by:
- Marquette Eagle 4000 Patient Monitor cleared K964750. .
- 4. Anybattery 5960 is substantial equivalent to that manufactured by:
- Schiller AT-5 cleared K941462. ●
- 5. Anybattery 6459, 7062-1 and 7062-2 are substantial equivalent to that manufactured by:
- Burdick Eclipse Series ECG cleared K943959 & K946281. ●
- 6. Anybattery 7023 is substantial equivalent to that manufactured by:
- General Electric MAC Series Electrocardiographs cleared K991735.
- 7. Anybattery 7038 is substantial equivalent to that manufactured by:
- Spacelabs Medical Patient Monitors cleared K102422.
- 8. Anybattery 7050 is substantial equivalent to that manufactured by:
- . Critikon Dinamap Pro 1000 Monitor cleared K002248.
- 9. Anybattery 7059 is substantial equivalent to that manufactured by:
- BCI Intl., Inc. 6004 NIBP Monitor cleared K983796 & K984618. ●
- 10. Anybattery 7171 is substantial equivalent to that manufactured by:
- . Nihon Kohden ECG-1250A Series and ECG-1350A Series ECGs cleared K072217.
- 11. Anybattery 7711 is substantial equivalent to that manufactured by:
- Nihon Kohden BSM-2300A Series Bedside Monitor cleared K011918. .
- 12. Anybattery 7726 is substantial equivalent to that manufactured by
- CAS Medical 740 Series Monitor cleared K033048. .
- 13. Anybattery 7732 is substantial equivalent to that manufactured by:
- Cardiac Science Atria 3100, 6100 cleared K060167. .
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# Indications for Use
510(k) Number (if known) K160667
Device Name
Anybattery Battery Pack
Indications for Use (Describe)
To power the functions of various devices for which batteries or battery packs are configured.
Since rechargeable batteries and battery packs are "device specific" and are designed to operate and fit into the equipment for which they were manufactured only qualified personnel should evaluate, test, charge, or install these devices.
Battery Packs are is shipped only to customers who request a replacement battery for a particular device or to replace a competitor's battery. The biomedical equipment technician therefore knows the intended use is as a replacement battery.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------|------------------------------------------------------------------|
| <span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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100 East Granada Blvd., Suite 219
Ormond Beach, FL 32176
386-506-8711
# 510 (k) Summary
# I. Submitter/Applicant
Anybattery, Inc. 2605 160th Street West, Unit 116 Rosemount, Minnesota 55068
Phone: 651-423-0555 Point of Contact: Edward J. Speegle, (ed@anybattery.net)
# Preparer/Consultant
Denterprise International, Inc. 100 East Granada Blvd., Suite 219 Ormond Beach, FL 32176
Phone: 386-506-8711 Fax: 386-672-4402 Primary Contact: Joyce St. Germain, Regulatory Assistant (joyce@510kfda.com) Secondary Contact: Claude Berthoin, President (joyce@510kfda.com) Preparation Date: March 3, 2016
## II. Device Classification
| Trade Name: | Anybattery C2 Rechargeable Battery |
|----------------------|------------------------------------|
| Common Name: | Box Battery or Pack Battery |
| Submission Type: | 510(k) |
| Regulatory Class: | II |
| Classification Name: | Box Battery, Rechargeable |
| Panel: | Cardiovascular |
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| Product<br>Code | Regulation | Device |
|-----------------|---------------|----------------------------------------------------------------------------------------------------------|
| DPS | 21CFR870.2340 | Electrocardiograph |
| LDD | 21CFR870.5300 | Dc-Defibrillator, Low-Energy, (Including Paddles) |
| DRT | 21CFR870.2300 | Monitor, Cardiac (Incl. Cardiotachometer & Rate Alarm) |
| MHX | 21CFR870.1025 | Arrhythmia Detector and Alarms |
| DXN | 21CFR870.113 | System, Measurement, Blood-Pressure, Non-Invasive<br>Monitor, Physiological, Patient (without Arrhythmia |
| MWI | 21CFR870.2300 | Detection or Alarms) |
| LOS | | Unclassified, pre-amendment device |
| DSI | 21CFR870.1025 | Arrhythmia Detector and Alarm |
| MLD | 21CFR870.1025 | Arrhythmia Detector and Alarm |
| MSX | 21CFR870.2300 | Cardiac Monitor |
| DQK | 21CFR870.1425 | Programmable Diagnostic Computer |
| DXH | 21CFR870.2920 | Telephone Electrocardiograph Transmitter and Receiver |
| FLL | 21CFR880.2910 | Clinical Electronic Thermometer |
| DQA | 21CFR870.2700 | Oximeter |
| DSJ | 21CFR870.1100 | Blood Pressure Alarm |
| DSK | 21CFR870.1110 | Blood Pressure Computer |
| DSF | 21CFR870.2810 | Paper Chart Recorder |
| BZO | 21CFR868.2375 | Breathing Frequency Monitor |
# III. Predicate Device
This submission compares the specifications and functionally of various rechargeable battery packs with those of similar devices that were included as part of the following original predicate devices and submissions.
### Anybattery C2 Rechargeable Batteries in the VRLA Product Family.
- 1. Anybattery 3394 is substantial equivalent to that manufactured by:
- Zoll D-900 defibrillator cleared K913484. .
- 2. Anybattery 4028 is substantial equivalent to that manufactured by:
- Hewlett-Packard Pagewriter XLI M1700A & Pagewriter XL M1701A cleared . K895520.
- 3. Anybattery 4040 is substantial equivalent to that manufactured by:
- HP 43100 series defibrillator monitors cleared K910754. .
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- 4. Anybattery 4043 is substantial equivalent to that manufactured by:
- . Hewlett-Packard Monitor, Patient Model 78333A cleared K760160.
- 5. Anybattery 4494 is substantial equivalent to that manufactured by:
- . Physio-Control LifePak 9 Defibrillator & Cardiac Monitor cleared K881153.
- 6. Anybattery 4494-2 is substantial equivalent to that manufactured by:
- . Physio-Control LifePak 9 series defibrillator monitors cleared K902288.
- 7. Anybattery 4510 is substantially equivalent to that manufactured by:
- Welch Allyn Protocol Propaq cleared K012451. ●
- 8. Anybattery 4713-2 is substantial equivalent to that manufactured by:
- Physio-Control Lifepak 10 defibrillator cleared K931053. .
- 9. Anybattery 5349-4 is substantial equivalent to that manufactured by:
- Nihon-Kohden TEC-7511A/TEC-7521A CardioLife Portable Defibrillator & . Accessories cleared K971436.
- 10. Anybattery 6558 is e substantial equivalent to that manufactured by:
- Spacelabs Healthcare Telemetry Receiver cleared K141156 & K925510. .
- 11. Anybattery 7714-1 and 7714-2 are substantial equivalent to that manufactured by:
- Colin Pressmate PM2100 VSM cleared K022537. .
- 12. Anybattery 8601 is substantial equivalent to that manufactured by:
- Welch Allyn Atlus Monitor cleared K984033. .
### Anybatterv C2 Rechargeable Batteries in the Nickel-Based Rechargeable Battery Product Family
- 1. Anybattery 3777 is substantial equivalent to that manufactured by:
- Burdick EK10 Series ECG cleared K870880. .
- 2. Anybattery 4218 is substantial equivalent to that manufactured by
- . General Electric MAC Series Electrocardiographs cleared K991735.
- 3. Anybattery 4227 is substantial equivalent to that manufactured by:
- Marquette Eagle 4000 Patient Monitor cleared K964750. ●
- 4. Anybattery 5960 is substantial equivalent to that manufactured by:
- . Schiller AT-5 cleared K941462.
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5. Anybattery 6459, 7062-1 and 7062-2 are substantial equivalent to that manufactured by:
- Burdick Eclipse Series ECG cleared K943959 & K946281. ●
- 6. Anybattery 7023 is substantial equivalent to that manufactured by:
- General Electric MAC Series Electrocardiographs cleared K991735. ●
- 7. Anybattery 7038 is substantial equivalent to that manufactured by:
- Spacelabs Medical Patient Monitors cleared K102422. ●
- 8. Anybattery 7050 is substantial equivalent to that manufactured by:
- . Critikon Dinamap Pro 1000 Monitor cleared K002248.
- 9. Anybattery 7059 is substantial equivalent to that manufactured by:
- BCI Intl., Inc. 6004 NIBP Monitor cleared K983796 & K984618.
- 10. Anybattery 7171 is substantial equivalent to that manufactured by:
- Nihon Kohden ECG-1250A Series and ECG-1350A Series ECGs cleared ● K072217.
- 11. Anybattery 7711 is substantial equivalent to that manufactured by:
- Nihon Kohden BSM-2300A Series Bedside Monitor cleared K011918. .
- 12. Anybattery 7726 is substantial equivalent to that manufactured by
- CAS Medical 740 Series Monitor cleared K033048. ●
- 13. Anybattery 7732 is substantial equivalent to that manufactured by:
- Cardiac Science Atria 3100, 6100 cleared K060167. ●
# IV. Device Description
Batteries have become a critical component in many medical devices. As more devices are computerized and more have become mobile, batteries play an important part in system performance and reliability. Medical batteries are treated as a piece of medical equipment, they are entered as an asset into the facilities equipment database and our included in the preventative maintenance schedule. The end use of the equipment is used to establish the frequency for preventative maintenance. Both the recommendation of the manufacturer of the medical device and the battery spec sheet from the battery manufacturer help establish the maintenance protocol.
Anybattery C2 Rechargeable batteries and battery packs are utilized as a primary direct current (d-c) power source or as a standby or backup d-c power source for portable as well as stationary medical equipment.
Anybattery C2 Rechargeable batteries and battery packs either the primary or secondary source of power and they retain critical parameters and data in the event of power
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disruption. These batteries range in size, while they are mostly 12-volt, they range in capacity from two-amp hour right up to 36-amp hour batteries.
The performance and life span of a rechargeable battery depends on several factors. Battery operating conditions of temperature, current drain, and charge/discharge method. are taken into account in the design of such batteries. Anybattery's goal is to develop a battery that maintains its battery capacity as high as possible and as long as possible.
There are several types of rechargeable batteries introduced and marketed for medical uses. In this submission are batteries in the Nickel-Based Rechargeable Battery Product Family and the Valve-Regulated Lead-Acid (VRLA) Rechargeable Battery Product Family.
### Nickel-Based Rechargeable Battery Product Family
- The Nickel-Cadmium battery (NDC) is the most widely used rechargeable • battery. Its efficient charge and discharge characteristics, reliability and economic nature have made it very popular and widely utilized in the medical industry. Manufacturers have developed nickel-cadmium batteries that can be charged up completely in one hour.
- The Nickel Metal Hydride (NMH) battery is a new technology being-worked on that can provide a 50% increase in energy density compared to Nickel Cadmium batteries. The Lithium battery recently introduced with energy densities of greater than twice that of NiCad batteries.
### VRLA Rechargeable Battery Product Family
The Valve-Regulated Lead-Acid (VRLA) battery more commonly known as a sealed battery (SLA) is a type of lead-acid rechargeable battery. Due to their construction, the Gel and AGM types of VRLA can be mounted in any orientation, and do not require constant maintenance. There are three primary types of VRLA batteries, Sealed VR wet cell, AGM and Gel. Gel cells add silica dust to the electrolyte, forming a thick putty-like gel. These are sometimes referred to as "silicone batteries". AGM (absorbed glass mat) batteries feature fiberglass between the battery plates, which serves to contain the electrolyte. Both designs offer advantages and disadvantages compared to conventional batteries and sealed VR wet cells, as well as each other.
# V. Indications for Use [Same as Intended Use]
To power the functions of various devices for which batteries or battery packs are configured.
Since rechargeable batteries and battery packs are "device specific" and are designed to operate and fit into the equipment for which they were manufactured only qualified personnel should evaluate, test, charge, or install these devices.
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Battery Packs are shipped only to customers who request a replacement battery for a particular device or to replace a competitor's battery. The biomedical equipment technician therefore knows the intended use is as a replacement battery.
# VI. Comparison of Technological Characteristics
The design components and functionality of the various batteries and battery packs included in this submission are similar to those of their predicate devices. Typical cell chemistries are Sealed -Lead Acid (SLA), Nickel-Cadmium (NiCad), and Nickel-Metal Hydride (NiMH). Both the new devices and the predicate devices provide a means of supplying electrical power through chemical reaction. The energy provided depends upon the voltage and capacity rating of a particular pack and the amount of current used by the device which they are installed. The performance and life span of the new devices and the predicate devices depends on operating conditions of temperature, current drain, and the charge/discharge method (if applicable). These parameters are taken into account in designing such batteries. The goal of all battery manufacturers is to develop batteries and battery packs that maintain capacity for as high and as long as possible. In comparison analysis, OEM Battery Packs (Predicate devices) set the benchmark and the Anybattery batteries replacement devices met and/or exceed the benchmark.
# VII. Performance Data
# Battery Pack Testing
General Protocol. The same battery testing protocol is used by the manufacturers of the predicate devices and the new devices.
### Incoming Inspection
All cells are inspected for correct specification, visible damage, and randomly voltage tested prior to acceptance. The lot numbers are recorded for tracking purposes should any fail during final assembly and inspection activities. Cases are also inspected for form, fit, function, and cosmetics.
### Vencon Testing
Voltage and capacity of battery cells and packs are tested using Vencon UBA Battery Analyzers in the "Test Mode" upon full completion of battery assembly design. This exercises the batteries in order to identify performance characteristics by running them through three (3) full charge/discharge cycles in the NKL based family and two (2) full cycles in the VRLA family. Tests typically take 12~48 hours for each battery pack.
All battery chemistries can be tested using custom test parameters, depending on Quality Control and customer requirements. This allows for various C -Rates, delta V (1:N), and volts-per-cell to be entered into the test protocol the Vencon UBA Software (Reference UBA Test Report Examples - Figures 1 and 2)
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Target capacity is the percentage of the battery capacity compared to nominal capacity and serves as a threshold. This threshold, or target capacity, can be set to any desired range (90 - 95% is typical).
Target capacity is a pass/fail mark for design acceptance. Our batteries must meet or exceed a required threshold of 90%, or higher, prior to final design control acceptance. Any samples that do not meet the criteria are rejected. Batch build sheets require 100% >then cutoff voltage, and polarity testing. Subsequently, the entire lot is tested and documented in this manner.
Battery packs are shipped in various states of dis-charge. There are specific DOT, FAA, and EPA regulations and guidelines that address these concerns.
### Voltage Testing - Completed Packs
All Battery Packs are tested 100% for correct voltage and polarity prior to shipment. Those devices that fail are rejected and quarantined.
# Safety and Performance
Safety and performance testing of battery packs are performed to ensure that these devices meet all functional requirements and performance specifications. In comparison analysis, OEM Battery Packs set the benchmark. Replacement devices must meet or exceed these benchmark results consistently.
Concerns that are addressed during bench test comparison analysis are:
- . Life cycle
The replacement battery must provide as many or more charge and discharge cycles as the original. This is an ongoing process and is not part of the standard QC final inspection protocol. The cycle life is based on cycles under criteria set forth in IEC61951-2 Secondary cells and batteries containing alkaline or other non-acid electrolytes - Portable sealed rechargeable single cells. Part 2: Nickel-Metal hydride and IEC 61056-1 General purpose lead-acid batteries (valve-regulated types) Part 1: General requirements, functional characteristics - Methods of test. As there is no internationally recognized shelf life determination, it is determined the device life shall be 12 months from point of sale.
- Temperature •
The replacement battery must function correctly over the same temperature range as compared to the original. Testing is done at 0, 25, and 40℃ (32, 77, and 104°F respectively).
- . Mechanical & Electrical Component Integrity
Normal testing would involve drop tests from a predetermined height, usually 2-3 feet, onto a hard, uniform surface. Battery packs are inspected for case cracks, cell separation, and electrical/electronic component damage. Root cause analysis is performed should any damage occur.
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# VIII. Conclusion
In conclusion, Anybattery C2 Rechargeable battery packs are the substantial equivalent to the predicate devices. Anybattery C2 Rechargeable batteries and battery packs are the substantial equivalent in design, function and intended use to their predicate devices. In comparison analysis, the predicate batteries and battery packs set the benchmark and Anybattery C2 Rechargeable batteries and battery packs met or exceed the predicate devices in design and functionality, material, safety and performance, packing protocol, principal of operation, mechanical capacity, and physical properties, i.e., dimension, weight, voltage, discharge capacity, impedence and storage and device life. It is deemed after a comprehensive comparison analysis that Anybattery C2 Rechargeable batteries and battery packs are the substantial equivalent to the predication devices.
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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.