This device is used in palliation of malignant neoplasms in the biliary tree
Device Story
Zilver 635 Biliary Stent is a self-expanding nitinol stent designed for permanent implantation in the biliary tree to maintain duct patency. The device consists of a laser-cut, open-ended nitinol cylinder with gold radiopaque markers at both ends for fluoroscopic visualization. It is supplied preloaded on a coaxial delivery system, which includes a handle assembly, introducer assembly, and pusher ring. The device is used endoscopically by a physician, guided by fluoroscopy, to treat malignant biliary obstructions. The stent exerts outward radial force upon deployment to establish patency. The delivery system is compatible with 0.035-inch wire guides. The device is intended for single use and is provided sterile.
Clinical Evidence
Bench testing only. Performance data included biocompatibility evaluation per ISO 10993-1, simulated use, deployment testing, dimensional testing, joint strength testing, MRI compatibility, and shelf-life testing. No clinical data was provided.
Technological Characteristics
Self-expanding laser-cut nitinol stent with gold radiopaque markers. Delivery system includes handle assembly, introducer assembly, and pusher ring. Compatible with 0.035-inch wire guides. Sterilized via ethylene oxide. Single-use. Complies with ISO 10993-1 for biocompatibility and FDA guidance for metal expandable biliary stents.
Indications for Use
Indicated for the palliation of malignant neoplasms in the biliary tree.
Regulatory Classification
Identification
A biliary catheter and accessories is a tubular flexible device used for temporary or prolonged drainage of the biliary tract, for splinting of the bile duct during healing, or for preventing stricture of the bile duct. This generic type of device may include a bile collecting bag that is attached to the biliary catheter by a connector and fastened to the patient with a strap.
Special Controls
*Classification.* Class II (special controls). The device, when it is a bile collecting bag or a surgical biliary catheter that does not include a balloon component, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 23, 2016
Cook Ireland Ltd. Nora O'Connor Regulatory Affairs Specialist O'Halloran Road, National Technology Park Limerick Ireland
Re: K163018 Trade/Device Name: Zilver 635® Biliary Stent Regulation Number: 21 CFR§ 876.5010 Regulation Name: Biliary Catheter and Accessories Regulatory Class: II Product Code: FGE Dated: October 27, 2016 Received: October 31, 2016
Dear Nora O'Connor:
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 and the limitations described below. 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.
The Office of Device Evaluation has determined that there is a reasonable likelihood that this device will be used for an intended use not identified in the proposed labeling and that such use could cause harm. Therefore, in accordance with Section 513(i)(1)(E) of the Act, the following limitation must appear in the Warnings section of the device's labeling:
The safety and effectiveness of this device for use in the vascular system have not been established
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Furthermore, the indication for biliary use must be prominently displayed in all labeling. including pouch box, and carton labels, instructions for use, and other promotional materials, in close proximity to the trade name, of a similar point size, and in bold print.
Please note that the above labeling limitations are required by Section 513(i)(1)(E) of the Act. Therefore, a new 510(k) is required before these limitations are modified in any way or removed from the device's labeling.
The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and permits your device to proceed to the market. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification if the limitation statement described above is added to your labeling.
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 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.
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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,
# John W. Sheets Jr -S
John W. Sheets Jr., Ph.D. Director Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Cook Zilver® 635 Biliary Stent
Attachment A
| | Page 1 of 1 |
|--|----------------------|
| | Company Confidential |
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
**Indications for Use**
| | Form Approved: OMB No. 0910-0120 |
|---------------------------------------|-----------------------------------|
| | Expiration Date: January 31, 2017 |
| | See PRA Statement below. |
| 510(k) Number <i>(if known)</i> | K163018 |
| Device Name | Zilver 635® Biliary Stent |
| Indications for Use <i>(Describe)</i> | |
This device is used in palliation of malignant neoplasms in the biliary tree
Type of Use *(Select one or both, as applicable)*
| <span style="text-align:left">☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="text-align:left">☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
|-------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
|-------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
CONTINUE ON A SEPARATE PAGE IF NEEDED.
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| FORM FDA 3881 (8/14) | Page 1 of 1 | PSC Publishing Services (301) 443-6740<br>EF |
|----------------------|-------------|----------------------------------------------|
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## Section 5: 510(k) Summary
#### I. SUBMITTER
Cook Ireland Ltd. O' Halloran Road National Technology Park Limerick Ireland
Phone: +353 61 334440 Fax: +353 61 239293
Contact Persons: Nora O'Connor, Regulatory Affairs Specialist Jacinta Kilmartin, Regulatory Affairs Manager
Phone: +353 61 334440 Fax: +353 61 239293
Date Prepared: October 27, 2016
#### II. DEVICE
Trade Name of Device: Zilver 635® Biliary Stent
The model numbers are ZILBS-635-6-4, ZILBS-635-6-6, ZILBS-635-6-8, ZILBS-635-6-10, ZILBS-635-6-12, ZILBS-635-8-4, ZILBS-635-8-6, ZILBS-635-8-8, ZILBS-635-8-10, ZILBS-635-8-12, ZILBS-635-10-4, ZILBS-635-10-6, ZILBS-635-10-8, ZILBS-635-10-10 and ZILBS-635-10-12
Common or Usual Name: Biliary Stent
Classification Name: Catheter, Biliary Diagnostic (21 CFR 876.5010)
Regulatory Class: II
Product Code: FGE
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#### III. PREDICATE DEVICE
Primary Predicate: Zilver® 635™ Biliary Stent (ZIB6) cleared under the following 510(k)s: K040505 cleared on Mar 16, 2004 K043481 cleared on Dec 29, 2004 K051124 cleared on July 12, 2005 K080037 cleared on Aug 01, 2008
Second Predicate: Zilver® Biliary Stent (ZILBS) cleared under the following 510(k): K020788 cleared on May 08, 2002
#### DEVICE DESCRIPTION IV.
The Zilver 635 Biliary Stent (ZILBS-635) consists of the following two components: a selfexpanding metal stent and stent delivery system. The stent is a laser cut self-expanding openended cylinder of nitinol. It is a slotted tube that is designed to provide support while allowing conformance to the duct upon deployment. Post-deployment, the stent is designed to impart an outward radial force upon the inner lumen of the duct, establishing patency in the stented region, thereby maintaining flow in the duct. The ZILBS-635 has radiopaque markers at both ends to assist in fluoroscopic visualization of the stent position. This stent delivery system like the predicate devices allows for co-axial deployment of the stent delivery system accepts a 0.035 inch wire guide. The stent delivery system includes a handle assembly and an introducer assembly. The handle assembly consists of a handle, a wire guide FLLA, holding bushing, a cannula, a check flo hub FLLA/cap and a safety tab. The introducer assembly consists of an outer sheath, an inner carrier and tip. The stent delivery system has an endoscopic pusher ring located on the inner carrier near the proximal end of the loaded stent. The outer sheath has a radiopaque maker band located within the wall of the outer sheath at the distal end. The stent delivery system is supplied with a syringe for flushing through the wire guide FLLA and the check flo hub FLLA.
#### V. INDICATIONS FOR USE
This device is used in palliation of malignant neoplasms in the biliary tree.
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### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH A VI. PREDICATE DEVICE
The subject device is substantially equivalent to the currently marketed primary predicate Zilver® 635™ Biliary Stent (ZIB6), cleared under the following 510(k)s:
K040505 cleared on Mar 16, 2004 K043481 cleared on Dec 29, 2004
K051124 cleared on July 12, 2005
K080037 cleared on Aug 01, 2008
In brief, the subject device has the same technological characteristics as the primary predicate ZIB6 with respect to the following:
- Both devices have the same intended use and indications for use. .
- . Both devices are for use in the biliary tree.
- Both devices allow single or overlapping in their stent placement configurations.
- . Both devices are intended for single use only.
- . Both devices are supplied with a syringe for flushing.
- Both devices are sold sterile and are sterilised using ethylene oxide. ●
- . Both devices are visible under fluoroscopy (radiopaque).
- Both devices have 1 radiopaque marker band on the stent delivery system.
- . Both stents are radiopaque.
- . Both stents are composed of nitinol with gold radiopaque markers at both ends of the stent.
- Both stents are laser cut and self-expanding. ●
- Both stents are intended to be permanently implanted. ●
- The stent outer diameters of 6, 8 and 10 mm are within the predicate diameter range (4 mm . to 14 mm).
- The stents lengths of 40, 60, 80, 100 and 120 mm are within the predicate length range (20 . mm to 140 mm).
- Both stents are supplied preloaded on a 6 Fr stent delivery system. ●
- Both stents are deployed using a coaxial catheter system.
- Both stent delivery systems are compatible with 0.035'' wire guides. .
The following technological differences exist between the subject device and the ZIB6, primary predicate device:
- Instructions for Stent Placement Configuration i)
- Method of Placement and Stent Delivery System Markers ii)
- iii) Stent Delivery System Introducer Dimensions (Length) and Compatibility
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- iv) Stent Delivery System and Syringe (Accessory) Materials
- v) Stent Delivery System Outer Sheath to Check-Flo Hub FLLA
- vi) Stent Delivery System Outer Sheath Middle Layer
- vii) Syringe Volume
The subject device is substantially equivalent to the currently marketed second predicate Zilver® Biliary Stent (ZILBS), cleared under the following 510(k)s: K020788 cleared on May 08, 2002
In brief, the subject device has the same technological characteristics as the second predicate ZILBS with respect to the following:
- . Both devices have the same intended use and indications for use.
- Both devices are for use in the biliary tree. .
- Both devices allow single or overlapping in their stent placement configurations. .
- Both devices are placed endoscopically (using endoscopic and fluoroscopic techniques). ●
- Both devices are intended for single use only. .
- . Both devices are supplied with a syringe for flushing.
- Both devices are sold sterile and are sterilised using ethylene oxide. ●
- Both devices are visible under fluoroscopy (radiopaque). ●
- Both stents are radiopaque.
- Both stents are composed of nitinol with gold radiopaque markers at both ends of the stent. .
- . Both stents are laser cut and self-expanding.
- Both stents are intended to be permanently implanted. ●
- Both stents are available in outer diameters 6, 8 and 10 mm. ●
- Both stents come preloaded on the stent delivery system. .
- . Both stents are deployed using a coaxial catheter system.
- . Both stent delivery systems are compatible with 0.035" wire guides.
- Both stent delivery systems have the same working length. ●
- Both stent delivery systems have a minimum duodenoscope accessory channel of 2.8 mm ● for placement of single or overlapping stents.
The following technological differences exist between the subject device and the ZILBS, second predicate device:
- i) Instructions for Stent Placement Configuration
- ii) Stent Delivery System Markers
- iii) Stent Lengths
- iv) Stent Delivery System Introducer Dimensions (Outer Diameter) and Compatibility
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- v) Stent Delivery System and Syringe (Accessory) Materials
- vi) Stent Delivery System Outer Sheath to Check-Flo Hub FLLA Joint
- vii) Stent Delivery System Outer Sheath Middle Layer
- viii) Syringe Volume
#### PERFORMANCE DATA VII.
The biocompatibility evaluation for the Zilver 635° Biliary Stent (ZILBS-635) was conducted in accordance with the FDA's Use of International Standard ISO 10993-1,"Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" June 16, 2016 and International Standard ISO 10993-1 "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process" (ISO10993-1:2009).
The device specific guidance document was consulted in preparing this premarket submission, FDA's Guidance for the Content of Premarket Notifications for Metal Expandable Biliary Stents, February 5, 1998. Performance testing such as simulated use, deployment testing, dimensional testing, joint strength testing, MRI and shelf life testing were performed as per Cook's design control system.
#### CONCLUSIONS VIII.
The non-clinical data supports the safety of the subject device and demonstrates that the Zilver 635® Biliary Stent (ZILBS-635) is safe and effective and should perform as intended in the specified use conditions. This non-clinical data supports the substantial equivalence of the Zilver 635® Biliary Stent (ZILBS-635) to the predicate devices.
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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.
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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).
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
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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.
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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.