K162820 · Arrow International, Inc. · DSP · Mar 31, 2017 · Cardiovascular
Device Facts
Record ID
K162820
Device Name
AC3 Series IABP System
Applicant
Arrow International, Inc.
Product Code
DSP · Cardiovascular
Decision Date
Mar 31, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.3535
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K162820 · Mar 31, 2017
AC3 Series IABP System
Arrow International, Inc.
American Heart Association (AHA) ECG database
The sponsor used real-world clinical ECG waveforms from the AHA database to validate the device's ECG trigger performance and demonstrate equivalence to the predicate device.
ECG validation; AHA database; Design validation
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
ECG trigger validation; Retrospective validation using clinical database
Clinical ECG waveforms
AutoCAT2 IABP system
ECG triggering reliability
Indications for Use
The AC3 Series IABP system is intended to provide counter-pulsation therapy to adult patients with impaired Left ventricular function. The users consist of trained hospital personnel in Intensive care areas, Cardiac Cath Labs, Cardiac Operating Rooms and emergency departments. This device is for in-hospital use and for transport between departments in a specific hospital or between facilities as required by the patient condition and treatment required.
Device Story
AC3 Series IABP System provides hemodynamic support via counter-pulsation therapy; intended for adult patients with impaired left ventricular function. Device inputs include ECG signals and arterial pressure (AP) data; utilizes pneumatic drive module to inflate/deflate intra-aortic balloon (IAB) catheter with helium during cardiac cycle. Inflation during diastole increases perfusion; deflation prior to systole reduces left ventricular workload. Operated by trained hospital personnel in ICUs, cath labs, ORs, and emergency departments. Features Autopilot mode for automated timing/triggering and Operator mode for manual control. System includes 13.3-inch touchscreen display for monitoring and control. Benefits include reduced cardiac work and oxygen demand. Device is a next-generation platform based on AutoCAT2; maintains core therapeutic algorithms while updating user interface and hardware ergonomics.
Clinical Evidence
No clinical data provided. Substantial equivalence demonstrated through bench testing, including electrical safety (IEC 60601 series), electromagnetic compatibility (RTCA DO-160), software verification (IEC 62304), human factors/usability testing (n=33 users, 22 use cases), cleaning/disinfection validation, and mechanical design verification. ECG trigger validation performed using AHA database waveforms compared against the predicate device.
Technological Characteristics
Stepper motor-driven bellows pneumatic system; helium-based inflation/deflation. Compatible with 30, 35, 40, 50cc IAB catheters. 13.3-inch high-resolution touchscreen; 6 hard keys. Connectivity includes Fiber Optic Sensor (FOS) for AP measurement. Power: 85-265V, 47-63Hz. Sealed lead-acid battery (min 90 min). Software developed per IEC 62304. Sterilization: Non-sterile (reusable device).
Indications for Use
Indicated for adult patients with impaired left ventricular function requiring counter-pulsation therapy for: a. Acute Coronary Syndrome; b. Cardiac and Non-Cardiac Surgery; c. Complications of Heart Failure.
Regulatory Classification
Identification
An intra-aortic balloon and control system is a prescription device that consists of an inflatable balloon, which is placed in the aorta to improve cardiovascular functioning during certain life-threatening emergencies, and a control system for regulating the inflation and deflation of the balloon. The control system, which monitors and is synchronized with the electrocardiogram, provides a means for setting the inflation and deflation of the balloon with the cardiac cycle.
Special Controls
*Classification.* (1) Class II (special controls) when the device is indicated for acute coronary syndrome, cardiac and non-cardiac surgery, or complications of heart failure. The special controls for this device are:(i) Appropriate analysis and non-clinical testing must be conducted to validate electromagnetic compatibility and electrical safety of the device;
(ii) Software verification, validation, and hazard analysis must be performed;
(iii) The device must be demonstrated to be biocompatible;
(iv) Sterility and shelf-life testing must demonstrate the sterility of patient-contacting components and the shelf life of these components;
(v) Non-clinical performance evaluation of the device must demonstrate mechanical integrity, durability, and reliability to support its intended purpose; and
(vi) Labeling must include a detailed summary of the device- and procedure-related complications pertinent to use of the device.
(2) Class III (premarket approval) when the device is indicated for septic shock and pulsatile flow generation.
(c)
*Date premarket approval application (PMA) or notice of completion of product development protocol (PDP) is required.* A PMA or notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before March 31, 2014, for any intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation that was in commercial distribution before May 28, 1976, or that has, on or before March 31, 2014, been found to be substantially equivalent to any intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation that was in commercial distribution before May 28, 1976. Any other intra-aortic balloon and control system indicated for septic shock or pulsatile flow generation shall have an approved PMA or declared completed PDP in effect before being placed in commercial distribution.
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Image /page/0/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 31, 2017
Arrow International, Inc. Alifiya Jagmag Manager, Regulatory Affairs 16 Elizabeth Dr. Chelmsford, Massachusetts 01824
Re: K162820
Trade/Device Name: AC3 Series IABP System Regulation Number: 21 CFR 870.3535 Regulation Name: Intra-Aortic Balloon and Control System Regulatory Class: Class II Product Code: DSP Dated: March 3, 2017 Received: March 6, 2017
Dear Alifiya Jagmag:
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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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 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" (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,
M.A. Hillebrenner
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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## Indications for Use
510(k) Number (if known) K162820
Device Name AC3TM Series IABP System
#### Indications for Use (Describe)
The AC31M Series IABP (Intra-Aortic Balloon Pump) System is clinically indicated for the following conditions:
- a. Acute Coronary Syndrome
- b. Cardiac and Non-Cardiac Surgery
- c. Complications of Heart Failure
Type of Use (Select one or both, as applicable)
| <span style="font-size:12px">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|------------------------------------------------------------------------------------|
| <span style="font-size:12px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# Section 5- 510(k) Summary
| 5.1<br>Statement | This 510(k) summary is being submitted in accordance with the<br>requirements of Safe Medical Device Act (SMDA) 1990 and CFR<br>807.92. |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 5.2<br>Submitter | Arrow International, Inc. (Subsidiary of Teleflex, Inc.)<br>16 Elizabeth Drive<br>Chelmsford, MA 01824<br>Establishment Registration: 3010532612<br>Arrow International, Inc. (Subsidiary of Teleflex, Inc.)<br>Reading, PA 19605:<br>Owner/ Operator: 2518433 |
| 5.3<br>Company<br>Contact | Alifiya Jagmag<br>Manager, Regulatory Affairs<br>Arrow International, Inc.<br>16 Elizabeth Drive<br>Chelmsford, MA 01824<br>Alifiya.Jagmag@teleflex.com<br>Phone: 978-250-5100 extension 725172<br>Date Prepared: 30 March 2017 |
| 5.4 | Proprietary Name: AC3TM Series IABP System |
| Device Name | Common Name: Intra-Aortic Balloon Control System |
| | Classification Name: Intra-aortic balloon and control system<br>(21 CFR 870.3535), Regulatory Class: II, Product Code: DSP |
| 5.5 | The AC3 Series Intra-Aortic Balloon Pump (IABP) System, which is |
|---------------------|--------------------------------------------------------------------|
| Predicate | the subject of this submission, is substantially equivalent to the |
| Legally | previously cleared Arrow AutoCAT®2 IABP System which was |
| Marketed<br>Devices | previously cleared via K060309. |
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5.6 The AC3 Series IABP System is the next generation platform which is based on the existing AutoCAT2 IABP System; cleared Device via K060309 on 6 April 2006. Description
> The AC3 Series IABP System (AutoCAT3) includes a new Graphical User Interface. The primary algorithms that control the therapeutic function of the device have not been altered from the AutoCAT2.
This premarket notification is applicable to the following part numbers:
Versions utilizing the Fiber Optic Sensor (FOS) or WAVE (Wind Kessel Aortic Valve Equation) capabilities:
- IAP-0700 AC3 Optimus™ IABP ●
- IAP-0701 AC3 Optimus™ IABP .
Versions without the FOS or WAVE capabilities:
- IAP-0600 AC3™ IABP ●
- IAP-0601 AC3™ IABP .
Note: The 01 ending indicates physical language labeling only. The part numbers IAP-0700 and IAP-0600 include the North American (NA) and European (EU) languages and the part numbers IAP-0701 and IAP-0601 include the NA, Asia, Japan and Latin America (AJLA) languages. All the part numbers will be commercially released OUS (outside of United States of America) after respective country registrations have been received. Functionally all the above mentioned part numbers are equivalent in performance and specifications.
#### System Description:
The AC3 Series IABP system provides counter-pulsation therapy to adult patients with impaired Left Ventricular (LV) Function. It provides hemodynamic support of blood pressure and reduced cardiac work through volume displacement principles. The IABP is attached to an IAB (Intra-aortic Balloon) catheter which is inserted into the femoral artery and positioned in the descending thoracic aorta.
The IABP delivers Helium (HE) into the IAB during diastole to displace blood above and below the IAB, increasing blood pressure and perfusion to organs close to the IAB catheter. The
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IABP deflates or removes HE from the IAB just prior to or in the early phase of systole, reducing the pressure in the aorta and therefore the pressure the LV must generate to open the aortic valve and eject its contents into the circulatory system. This results in a decrease in work and oxygen demand.
The AC3 Series IABP System consists of two main components:
- The pump control / display module which incorporates a . touch screen and keypad for system operation
- . The pneumatic drive module which is incorporated into the body of the device.
The AC3 is designed to be used with 30, 35, 40, and 50cc Intra-Aortic Balloons with the appropriate connectors. (UltraFlex™, Ultra 80, NarrowFlex®, and RediGuard® Catheters).
The system offers two modes of operation:
- . Autopilot Mode, where most functions are automatically selected and controlled by the IABP
- Operator mode, where an operator can control most . settings and selections.
| 5.7<br>Device | Indications For Use: |
|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications<br>and Intended<br>use | The AC3 IABP (Intra-Aortic Balloon Pump) System is clinically<br>indicated for the following conditions:<br>a. Acute Coronary Syndrome<br>b. Cardiac and Non-Cardiac Surgery<br>c. Complications of Heart Failure |
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5.8 Extensive performance testing has been completed to demonstrate that the AC3 is substantially equivalent to the AutoCAT2 device Performance previously cleared via K060309. Testing
> Following is a summary of the testing that has been completed to demonstrate substantial equivalence.
> Electrical Safety and Electromagnetic Compatibility Testing Electrical Safety and Compliance testing was conducted by an outside test house.
> Test reports provided confirm that the AC3 is in compliance with the standards as noted in Table 5.1 below.
| Standard | Description |
|-------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1<br>3rd edition | Medical electrical equipment - Part 1: General<br>requirements for basic safety and essential<br>performance |
| IEC 60601-1-2<br>3rd edition | Medical Electrical Equipment - Part 1-2:<br>General Requirements for Basic Safety and<br>Essential Performance - Collateral Standard:<br>Electromagnetic Compatibility - Requirements<br>and Tests |
| IEC 60601-1-6<br>3rd edition | Medical Electrical Equipment - Part 1-6:<br>General Requirements for Basic Safety and<br>Essential Performance - Collateral Standard:<br>Usability |
| IEC 60606-1-8<br>2nd edition | Medical electrical equipment - Part 1-8:<br>General requirements for basic safety and<br>essential performance - Collateral Standard:<br>General requirements, tests and guidance for<br>alarm systems in medical electrical equipment<br>and medical electrical systems |
| IEC 60601-2-27<br>3rd edition | Medical electrical equipment - Part 2-27:<br>Particular requirements for the basic safety<br>and essential performance of<br>electrocardiographic monitoring equipment<br>medical electrical equipment - Part 2-27:<br>Particular requirements for the basic safety<br>and essential performance of<br>electrocardiographic monitoring equipment |
Table 5.1: IEC Standards Applicable to the AC3 IABP
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| Standard | Description |
|-----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-2-34<br>3rd edition | Medical electrical equipment. Particular<br>requirements for the basic safety and<br>essential performance of invasive blood<br>pressure monitoring equipment |
| IEC 60601-2-49<br>2nd edition | Medical electrical equipment. Particular<br>requirements for the basic safety and<br>essential performance of multifunction patient<br>monitoring equipment |
| RTCA DO-160<br>Section 20<br>Category R | Radio Frequency Susceptibility (Conducted<br>and Radiated) |
| N/A | Design Considerations for Devices Intended<br>for Home Use Guidance Document |
#### Software Verification Testing
The software has been developed in accordance with IEC 62304:2006, Medical device software-Software lifecycle processes. Software Verification testing has been completed to demonstrate that the software requirements have been met. Documentation has been supplied to also comply with FDA's quidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices".
## Human Factors Testing / Usability Testing
Testing was completed to demonstrate that the changes to the user interface did not negatively impact the performance of the device. Testing was completed in accordance with FDA's Final Guidance document, Applying Human Factors and Usability Engineering to Medical Devices and in accordance with IEC 62366:2007.
As part of this evaluation 33 users participated in the evaluation. Each participant was asked to perform 22 uses cases that were developed based on critical tasks and areas for potential risk due to potential use errors. There were no use errors observed during testing and 96% of the use cases were completed successfully with no operational difficulty (on the first attempt) whereas 4% of the use cases were completed with only minor operational difficulty.
#### Cleaning and Disinfection
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Cleaning: A study was conducted by an outside test house in accordance with the following recognized standards:
- AAMI TIR12:2010 - Designing, testing, and labeling reusable medical devices for reprocessing in health care facilities.
AAMI TIR30:2011 - A compendium of processes, materials, ● test methods, and acceptance criteria for cleaning reusable medical devices, and Reprocessing Medical Devices in Health Care Settings
Testing was completed to verify the effectiveness of the recommended cleaning methods. Components of the device that represented the worst case based on the material and the use profile of the components were selected for inclusion in the protocol..
Disinfection: Testing was also completed to demonstrate the recommended method of disinfection would result in a six log10 reduction in colony forming units (CFU) of selected organisms. Testing was completed in accordance with the following recognized standards:
AAMI TIR12:2010 - Designing, testing, and labeling ● reusable medical devices for reprocessing in health care facilities.
ANSI/AAMI ST58:2013 - Chemical sterilization and high-. level disinfection in health care facilities, and Reprocessing Medical Devices in Health Care Settings.
Testing demonstrated the AC3 Series IABP system could effectively be cleaned and disinfected using the recommended methods.
## Environmental/ Mechanical Testing
Mechanical design verification testing was conducted to confirm that the AC3 Series IABP System meets all requirements with respect to operational parameters and reliability and is substantially equivalent to the predicate device, AutoCAT2 IABP. The result of this testing confirms that the device meets all acceptance criteria and specifications as required.
#### Design Validation Testing
ECG trigger validation Testing was conducted using recordings of real Electro-Cardiogram (ECG) waveforms from the American Heart Association (AHA) database to confirm that the AC3 Series IABP system ECG Triggering was equivalent to the AutoCAT2 ECG Triggering. As part of this testing an AutoCAT2 and AC3
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Series IABP system were simultaneously assessed using the same ECG input. The data confirmed that the devices are substantially equivalent with regard to their triggering reliability.
Reliability testing was also completed to confirm that the AC3 Series IABP system could run continuously and perform as intended. As part of this test AC3 pumps were run continuously for 9 days; from 216 to 218 hours. All pumps successfully inflated and deflated the attached IAB catheter and met all acceptance criteria for this test.
Rate limit testing was completed to verify that the AC3 Series IABP system was able to successfully inflate and deflate the various size IAB catheters i.e. 30cc, 35cc, 40cc and 50cc that were connected to the IABP system. Testing confirmed that the inflation and deflation of connected balloons met all requirements.
Table 5.2 provides a comparison of the AutoCAT2 IABP cleared via K060309 and the AC3 Series IABP system that is the subject of this submission.
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| Attribute | AutoCAT2 Series IABP<br>(Predicate Device) | AC3 Series IABP system<br>(Subject Device) | Comparison |
|---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for<br>Use | The AutoCAT2 Intra-<br>Aortic Balloon Pump<br>(IABP) is clinically<br>indicated for the<br>following conditions:<br>a. Acute Coronary<br>Syndrome<br>b. Cardiac and Non-<br>Cardiac Surgery<br>c. Complications of<br>Heart Failure | The AC3 Series Intra-<br>Aortic Balloon Pump<br>(IABP) System is<br>clinically indicated for<br>the following conditions:<br>a. Acute Coronary<br>Syndrome<br>b. Cardiac and<br>Non-Cardiac<br>Surgery<br>c. Complications of<br>Heart Failure | No change.<br>Same as<br>AutoCAT2 |
| Intended Use | The AutoCAT2 IABP is<br>intended to provide<br>counter-pulsation<br>therapy to adult patients<br>with impaired Left<br>ventricular function.<br>The users consist of<br>trained hospital<br>personnel in Intensive<br>care areas, Cardiac Cath<br>Labs, Cardiac Operating<br>Rooms and emergency<br>departments. This<br>device is for in-hospital<br>use and for transport<br>between departments in<br>a specific hospital or<br>between facilities as<br>required by the patient<br>condition and treatment<br>required. | The AC3 Series IABP<br>system is intended to<br>provide counter-<br>pulsation therapy to<br>adult patients with<br>impaired Left ventricular<br>function.<br>The users consist of<br>trained hospital<br>personnel in Intensive<br>care areas, Cardiac<br>Cath Labs, Cardiac<br>Operating Rooms and<br>emergency<br>departments. This<br>device is for in-hospital<br>use and for transport<br>between departments in<br>a specific hospital or<br>between facilities as<br>required by the patient<br>condition and treatment<br>required. | No change.<br>Same as<br>AutoCAT2 |
| Compatible<br>Disposable | 30, 35, 40, and 50cc<br>Intra-aortic balloons | 30, 35, 40, and 50cc<br>Intra-aortic balloons | No change.<br>Same as |
| Attribute | AutoCAT2 Series IABP<br>(Predicate Device) | AC3 Series IABP system<br>(Subject Device) | Comparison |
| Sets | marked with Arrow | marked with Arrow | AutoCAT2 |
| Sterility | Non-sterile | Non-sterile | No change.<br>Same as<br>AutoCAT2 |
| Environmental<br>Specifications | Operating Temperature:<br>5°C to 45°C (without<br>Fiber Optic Sensor)<br>5°C to 35°C (with Fiber<br>Optic Sensor) | Operating Temperature:<br>0°C to 45°C (without<br>Fiber Optic Sensor)<br>0°C to 35°C (with Fiber<br>Optic Sensor) | Greater range<br>of operating<br>temperature<br>and storage<br>and transport<br>humidity<br>conditions all<br>other<br>specifications<br>remains the<br>same. |
| | Specification Storage<br>and transport<br>Temperature: -15°C to<br>40°C | Specification Storage<br>and transport<br>Temperature: -15°C to<br>40°C | |
| | Storage and transport<br>Atmospheric Pressure:<br>200 hPa - 1060 hPa<br>(150mmHg - 796mmHg) | Storage and transport<br>Atmospheric Pressure:<br>200 hPa - 1060 hPa<br>(150mmHg - 796mmHg) | |
| | Storage and Transport<br>Humidity: 15% - 80% | Storage and Transport<br>Humidity: 15% - 85% | |
| | Stepper motor driven<br>bellows pneumatic<br>system with augmented<br>deflation and no<br>disposable parts. | Stepper motor driven<br>bellows pneumatic<br>system with augmented<br>deflation and no<br>disposable parts. | No change.<br>Same as<br>AutoCAT2 |
| | Pumping volume: 0.5cc –<br>50cc, adjustable in 0.5cc<br>increments | Pumping volume: 0.5cc<br>– 50cc, adjustable in<br>0.5cc increments | |
| | Performance<br>Specifications | Sealed Lead Acid battery<br>(minimum of 90 minutes)<br>with an optional battery<br>upgrade to double<br>battery life. | Sealed Lead Acid<br>battery (minimum of 90<br>minutes) with an<br>optional battery upgrade<br>to double battery life. |
| | | Power supply 85 to 265V<br>47 to 63Hz<br>Power consumption<br>225W or 3.1A | Power supply 85 to<br>265V 47 to 63Hz<br>Power consumption<br>110V- 5.1A<br>220V- 2.8A |
| Attribute | AutoCAT2 Series IABP<br>(Predicate Device) | AC3 Series IABP<br>system<br>(Subject Device) | Comparison |
| | Universal Power Supply | Universal Power Supply | specifications. |
| | 10.3 Inch Color LCD<br>display.<br>26 Hard keys available | 13.3 Inch High<br>Resolution touchscreen<br>display | AC3 Series<br>IABP system<br>has a larger, |
| | for all functions. No<br>touch screen. | 6 hard keys for<br>frequently used or<br>safety functions. | high resolution<br>touchscreen<br>with an<br>improved user<br>interface |
| Display | Hard keys are backlit<br>LEDs for selection. | Hard keys and text are<br>both backlit LEDs and<br>color coded | Improved<br>visibility of keys<br>in dark |
| | No Alarm indication<br>corner switch | AC3 Display head has a<br>color coded corner<br>switch that illuminates<br>when an alarm is active. | The Corner<br>switch acts as a<br>visual indicator<br>for the priority<br>of alarm and<br>also allows the<br>user to reset<br>alarm. |
| | 2 Operational Modes:<br>Autopilot and Operator<br>mode | 2 Operational Modes:<br>Autopilot and Operator<br>mode | No change.<br>Same as<br>AutoCAT2 |
| Operational<br>Modes | Autopilot mode Includes:<br>• Automatic trigger<br>selection<br>• Automatic<br>ECG/Arterial Pressure<br>(AP) source selection<br>• Automatic timing<br>method selection and<br>timing control<br>• Best Signal Analysis<br>• Deflation Timing<br>Management | Autopilot mode<br>Includes:<br>• Automatic trigger<br>selection<br>• Automatic ECG/<br>Arterial Pressure (AP)<br>source selection<br>• Automatic timing<br>method selection and<br>timing control<br>• Best Signal Analysis<br>• Deflation Timing<br>Management | AC3 and<br>AutoCAT2<br>series IABP<br>systems have<br>the same<br>Autopilot mode<br>functionality. |
| | Operator mode includes:<br>• 7 modes for trigger<br>selection | Operator mode<br>includes:<br>• 7 modes for trigger | AC3 and<br>AutoCAT2<br>series IABP |
| Attribute | AutoCAT2 Series IABP<br>(Predicate Device) | AC3 Series IABP system<br>(Subject Device) | Comparison |
| | • ECG Source: 2 selections and 1 key press to change leads<br>• ECG gain: Automatic, Manual and User adjustable<br>• AP Source: 3 selections<br>• AP Scaling: Automatic, Manual and User selectable<br>• Timing can be selected using Soft keys and the selected timing setting is displayed on the screen. | selection<br>• ECG Source: 2 selections and 1 key press to change leads<br>• ECG gain: Automatic, Manual and User adjustable<br>• AP Source: 3 selections<br>• AP Scaling: Automatic, Manual and User selectable<br>• Touchscreen has the timing controls under the Timing Key. A reminder message is shown if the user leaves the timing screen in 1:2 or lower assist. | systems have the same Operator mode functionality. |
| FiberOptix® Technology | AutoCAT2 WAVE® only:<br>Allows Arterial Pressure (AP) to be measured by Fiber Optic method while using Arrow FiberOptix® IAB catheter. | AC3 Optimus™ only:<br>Allows Arterial Pressure (AP) to be measured by Fiber Optic method while using Arrow FiberOptix® IAB catheter. The AC3 Series IABP system has an updated position for the FOS connection. | New position for the FOS connection will facilitate connection |
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5.9 The AC3 Series IABP System has the same indications for use and incorporates the same fundamental technology as the legally Conclusion marketed predicate devices. Performance test results and verification Regarding activities demonstrate that the proposed device meets its intended Substantial use. It is for these reasons that the proposed device can be found Equivalence substantially equivalent to the predicate device.
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Learn the FDA Browser
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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.
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.