A steam sterilizer (Autoclave) is a device that is intended for use by a health care provider to sterilize medical products by means of pressurized steam.
Device Story
Benchtop steam sterilizer (autoclave) for healthcare settings; uses pressurized steam to sterilize medical/surgical instruments. Input: water; process: electronic control module heats water to generate steam; gravity displacement and pulsed dynamic air removal (1200-1600 mbar) cycles. Output: sterilized instruments/glassware. Features: touch screen digital display, user log, data archiving (5000 cycles), multi-level password protection. Safety: door locking mechanism, automatic shutoff, dual thermostats, pressure safety valve. Optional printer for cycle parameters. Benefits: provides validated sterilization environment for medical products; ensures instrument safety for clinical use.
Clinical Evidence
Bench testing only. Compliance with ANSI/AAMI ST55:2010, IEC 61010:2010, IEC 61326:2013, and BS EN 13060:2014. Testing included physical and microbiological performance, thermal profiling, moisture retention, and mechanical air removal. No clinical data.
Technological Characteristics
Chamber: 316 Stainless Steel (electro-polished). Energy: Electronic heating elements. Control: Electronic module with 4 pre-programmed cycles. Connectivity: Digital display, optional printer, data archiving. Safety: Door lock, dual thermostats, pressure valve. Standards: ANSI/AAMI ST55:2010, ASME Section VIII Div 1, IEC 61010:2010, IEC 61326:2013.
Indications for Use
Indicated for sterilization of metal medical instruments (unwrapped/wrapped), glassware (unwrapped), and dental hand pieces (pouches) by healthcare providers.
Regulatory Classification
Identification
A steam sterilizer (autoclave) is a device that is intended for use by a health care provider to sterilize medical products by means of pressurized steam.
Predicate Devices
Tuttnauer EZ Plus Series Electronic Table Top Autoclaves (EZ9 Plus, EZ11 Plus, EZ 15 Plus) (K111736)
Submission Summary (Full Text)
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March 2, 2018
Astell Scientific Limited Gary Doughty Quality and Compliance Manager 19-21 Powerscroft Rd Sidcup, Kent DA14 5DT United Kingdom
Re: K170304
Trade/Device Name: Astell UMB 220, UMB 240 Autoclaves/Sterilizers Regulation Number: 21 CFR 880.6880 Regulation Name: Steam Sterilizer Regulatory Class: Class II Product Code: FLE Dated: January 24, 2018 Received: January 26, 2018
Dear Gary Doughty:
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 of medical device-related adverse events) (21 CFR 803); good
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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.
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.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
# Michael J. Ryan -S
for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K170304
#### Device Name
Astell UMB 220, UMB 230, UMB 240 Autoclaves/sterilizers
Indications for Use (Describe)
A steam sterilizer (Autoclave) is a device that is intended for use by a health care provider to sterilize medical products by means of pressurized steam.
Typical applications:
Metal Medical Instruments (Unwrapped) Metal Medical Instruments (Wrapped) Glassware (Unwrapped) Hand Pieces (Pouches)
The electronic control has four pre-programmed sterilization cycles.
The four pre-programmed sterilization cycles are for:
Cycle 1; Metal Medical Instruments (Unwrapped); 134°C for 3 minutes; Drying Time 15 minutes
Cycle 2: Metal Medical Instruments (Wrapped); 134°C for 4 minutes; Drying time 30 minutes
Cycle 3: Glassware (Unwrapped); 121°C for 30 minutes; Drying time 15 minutes
Cycle 4; Hand pieces; (Pouches) 134°C for 4 minutes; Drying time 15 minutes
The four pre-programmed cycles are for:
Cycle 1; Metal Medical Instruments (Unwrapped); 134°C for 3 minutes; Drying Time 15 minutes Maximum Load: Shelf rack can accommodate 4 instruments they have to be layered down in an open position. All instruments have to remain apart with a minimum distance of 1 cm. Maximum weight/tray: 2.5 kg, Maximum load/cycle: 10 kg
Cycle 2; Metal Medical Instruments (Wrapped); 134°C for 4 minutes; Drying time 30 minutes Maximum Load: Shelf rack can accommodate 2 pouch racks. Pouches have to stand on their side and not touching each other. Leave at least 2 cm between each item. Maximum weight/rack: 2.5 kg Maximum load/cycle: 5 kg
Cycle 3; Glassware (Unwrapped); 121°C for 30 minutes; Drying time 15 minutes Shelf rack can accommodate 4 trays. Glassware have to be placed upside down with a minimum distance of 1 cm. Maximum weight/tray: 2.5 kg Maximum load/cycle: 10 kg
Cycle 4; Hand pieces; (Pouches) 134°C for 4 minutes; Drying time 15 minutes Maximum Load; Shelf rack can accommodate 2 pouch racks. Pouches have to stand on their side and not touching each other. Leave at least 2 cm between each item. Maximum weight/rack: 2.5 kg Maximum load/cycle: 5 kg.
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Prescription Use (Part 21 CFR 801 Subpart D)
- X Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/4/Picture/0 description: The image shows the word "Astell" in blue font, followed by a blue circle with a blue triangle inside. There is also a yellow circle that is slightly offset from the blue circle. The logo is simple and clean, with a focus on the company name and a geometric symbol.
Astell Scientific Ltd Powerscroft Road Sidcup, Kent DA14 5DT United Kingdom
Tel: 0208 309 2031 Fax: 0208 300 2247
e-mail: info@astell.com
website: http://www.astell.com
## 510(K) Number K170304 Summary
| Submitter: | Astell Scientific Limited<br>19-21 Powerscroft Road<br>Sidcup<br>Kent<br>DA14 5DT<br>Telephone: +44 020 8309 2003<br>Email: gdoughty@astell.com |
|------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | G Doughty |
| Date: | 28TH February 2018 |
| Common Name: | Steam Sterilizer |
| Product Code: | FLE |
| Device Trade Name: | Astell UMB 220, UMB 230, UMB 240 Autoclaves/Sterilizers |
| Classification Name: | Steam Sterilizer: Class II Device-21 C.F.R. § 880.6880 |
| Predicate Device 510(k) No: | K111736 |
| Predicate Device Trade Name: | Tuttnauer EZ Plus Series Electronic Table Top Autoclaves (EZ9 Plus,<br>EZ11 Plus, EZ 15 Plus. |
| Classification Name: | Steam Sterilizer Class II Device-21 C.F.R § 880.6880 |
Image /page/4/Picture/6 description: The image shows a logo with a crown on top of a circle. Inside the circle are two mirrored symbols that resemble a sideways "K" or a stylized lightning bolt. Below the circle is the text "UKAS" in a sans-serif font, and below that is the word "CALIBRATION" in a smaller font size.
Image /page/4/Picture/7 description: The image contains two logos. The first logo is the ISO 9001 system certification logo with an orange checkmark inside a circle. The text "SGS" is written below the circle. The second logo is the UKAS Quality Management logo, which features a crown above a checkmark. The text "UKAS QUALITY MANAGEMENT" is written below the checkmark.
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## General Description /Technology:
The Astell Scientific range of UMB benchtop steam sterilizers are designed to offer convenience and flexibility in the sterilization of medical and surgical instruments.
Instruments for sterilization include wrapped and unwrapped Metal Medical instruments, unwrapped Glassware and pouched dental hand pieces.
A steam sterilizer (Autoclave) is a device that is intended for use by a health care provider to sterilize medical products by means of pressurized steam. Autoclaves/sterilizers heat water to generate steam as the sterilization agent, producing steam in the chamber to create a gravity displacement, pulsed dynamic air removal sterilization environment.
Steam sterilization is a widely used sterilization process due to its versatility and speed. The sterilizers include as its main components a pre-programmed electronic control module, autofill water reserve, electronic heaters and an auto-drain sterilization chamber.
The free-steaming phase of the sterilization process incorporates a 20-minute dynamic air removal program pulsing at low; 1200 mbar/ high;1600 mbar
The autoclaves are equipped with multiple safety features. The door contains a safety locking mechanism that does not permit operation unless the door is closed and locked, and does not permit the door to be opened until the internal chamber pressure is no greater than 100mbar above atmospheric pressure. Additional safety features include an automatic safety shutoff to prevent the chamber overheating; two (2) thermostats; one to detect overheating of the heaters and one to prevent opening of the door if the chamber temperature is unsafe to do so (80 °C). There is also a safety valve for the pressure vessel.
A touch screen digital display with a user log, data archiving for up to 5000 cycles and multiple user access levels and multi-level password protection is used for precision control and monitoring purposes.
The differences between the UMB Autoclaves/Sterilizers in this submission is the chamber volumes:
UMB 220 (Total volume 33 Litres) UMB 230 (Total volume 43 Litres) UMB 240 (Total volume 63 Litres)
There is an optional printer available to record cycle parameters.
Only United States Food and Drug Administration cleared accessories such as sterilization wraps, sterilization pouches, chemical indicators, biological indicators, and sterilization cassettes should be used with this Autoclave.
### Design and Materials:
Astell Scientific Autoclaves are designed and manufactured in accordance with the requirements of European Medical Devices Directive 93/42/EEC, BS EN 13060:2014, ANSI/AAMI ST55:2010 and the appropriate Pressure Vessel Directive 2014/68/EU or ASME Boiler and Pressure Vessel Code Rules, Section VIII, Division 1. The manufacturing principles specified in these directives and standards are followed for the products in this submission.
The UMB range of Autoclaves sterilization chamber is manufactured from Stainless Steel Grade 316 with the internal bore electro polished. The range are fitted with electronic heating elements, an autofill water reservoir and an electronic control system. The control system is pre-programmed
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with four sterilization cycles and up to a further 50 cycles available. There is also a safety valve test cycle.
### Non-Clinical Testing:
The Astell Scientific range of Autoclave/Sterilizers within this submission are certified by a Notified Body (SGS) to be compliant with the requirements of MDD 93/42/EEC inclusive of BS EN 13060:2014, similar in scope and content to the requirements of AAMI/ANSI ST55:2010.
All testing was conducted in accordance with the requirements of AAMI/ANSI ST55:2010 inclusive of physical and microbiological performance requirements.
Model UMB240 have a total capacity of 63 litres which is larger than the 56.63 litre specification of AAMI/ANSI ST55:2010. The useable capacity of this model is 50 litres. It is therefore considered they should be evaluated as compliant with the capacity specification of AAMI/ANSI ST55:2010.
There are not any patient contacting components within this range of Autoclaves/Sterilizers.
When used as intended by competent trained personnel any patient contact will be with sterilized products.
### Indications for use.
A steam sterilizer (Autoclave) is a device that is intended for use by a health care provider to sterilize medical products by means of pressurized steam.
Typical applications include:
Metal Medical Instruments (Unwrapped) Metal Medical Instruments (Wrapped) Glassware (Unwrapped) Hand pieces (Pouches)
The electronic control has four pre-programmed sterilization cycles.
The four pre-programmed cycles are for:
Cycle 1; Metal Medical Instruments (Unwrapped); 134°C for 3 minutes; Drying Time 15 minutes Maximum Load: Shelf rack can accommodate 4 instruments they have to be layered down in an open position. All instruments have to remain apart with a minimum distance of 1 cm. Maximum weight/tray: 2.5 kg, Maximum load/cycle: 10 kg
Cycle 2; Metal Medical Instruments (Wrapped); 134°C for 4 minutes; Drying time 30 minutes Maximum Load: Shelf rack can accommodate 2 pouch racks. Pouches have to stand on their side and not touching each other. Leave at least 2 cm between each item. Maximum weight/rack: 2.5 kg Maximum load/cycle: 5 kg
Cycle 3; Glassware (Unwrapped); 121°C for 30 minutes; Drying time 15 minutes Shelf rack can accommodate 4 trays. Glassware have to be placed upside down with a minimum distance of 1 cm. Maximum weight/tray: 2.5 kg Maximum load/cycle: 10 kg
Cycle 4; Hand pieces; (Pouches) 134°C for 4 minutes; Drying time 15 minutes Maximum Load: Shelf rack can accommodate 2 pouches have to stand on their side and not touching each other. Leave at least 2 cm between each item. Maximum weight/rack: 2.5 kg Maximum load/cycle: 5 kg.
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## Technical Standards:
The Astell Scientific UMB series of autoclaves have been assessed to be compliant with the requirements of the following FDA recognised standards:
#### ANSI/AAMI ST55:2010: Tabletop Steam Sterilizers
BS EN 13060 is the European equivalent of ANSI/AAMI ST55:2010. The Astell range of AMB/UMB sterilizers have been certified by SGS as compliant with BS EN 13060. Astell conducted additional testing to the following ANSI/AAMI ST55:2010 specifications:
- 5.4.3; Sterilizer temperature control
- 5.5 Biological performance of sterilizers
- 5.6 Mechanical air removal
- 5.7 Moisture retention
- 5.8 Sterilizer performance certification and record keeping.
#### IEC 61010:2010: Electrical safety for laboratory equipment
EN 61010-1 1993/A2:1995; Report 071-607596-00; Test date 05/15/2002
IEC 61010:2010; Report 071-75934461-000; Test date 05/06/2016
IEC 61010:2010; Report 071-071-75935721; Test date 08/08/2016
The above tests were conducted on 50L useable volume sterilizers. The models with a useable volume of 50 litres are AMB/UMB 240 Total volume 63L.
Models UMB 220, 230 and 240 are electrically identical (utilizing the same electrical components).
Original compliance testing report 071-607596-00 was conducted to EN 61010-1 1993/A2:1995. Test reports 071-75934461-000 and 071-071-75935721 are gap analysis reports to demonstrate compliance with IEC 61010:2010. Testing was only conducted on the elements which had changed in the standard revision process.
The original test report and the subsequent gap analysis reports demonstrate all models in this application are compliant with the content of IEC 61010:2010.
## IEC 61010-2-040: Safety requirements for electrical equipment for measurement, control, and laboratory use. Particular requirements for sterilizers and washer-disinfectors used to treat medical materials
Particular requirements for sterilizers and washer-disinfectors used to treat medical materials is an element within the Medical Devices Directive 93/42 EEC. Compliance is demonstrated by selfcertification completion of an Electrical Safety checklist validated by Notified Body SGS.
## IEC 61326:2013: Electrical equipment for measurement, control and laboratory use. EMC requirements. General requirements
EMC testing in accordance with the requirements of IEC 61326:2013
EN 61326-1:2006; Report 02-556/3886/1/09; Test date 16th – 23 February 2009
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## EN 61326-1:2013; Report 04/8557-2-16; Test date 13th April 2016
The above tests were conducted on AMB/UMB 230 with a total volume of 43L and an AMB/UMB 220 with a total volume of 33L.
Models UMB 220, 230 and 240 are electrically identical (utilizing the same electrical components).
Original compliance testing report 02-556/3886/1/09 was conducted to EN 61326-1:2006. Test report 04/8557-2-16 is a gap analysis to demonstrate compliance with EN 61326-1:2013. Testing was only conducted on the elements which had changed in the standard revision process.
The original test report and the subsequent gap analysis report demonstrates all models in this application are compliant with the content of EN 61326-1:2013.
#### BS EN ISO 14971:2012: Application of Risk Management to Medical Devices
Particular requirements for sterilizers and washer-disinfectors used to treat medical materials is an element within the Medical Devices Directive 93/42 EEC. Compliance is demonstrated by selfcertification completion of an Electrical Safety checklist validated by Notified Body SGS.
### IEC 62366:2015: Application of Usability to Medical Devices
Requirements for Medical Devices is an element within the Medical Devices Directive 93/42 EEC. Compliance is demonstrated by self-certification completion of an Electrical Safety checklist validated by Notified Body SGS.
#### IEC 62304: 2006: Software Life Cycle Processes
Requirements for Medical Devices is an element within the Medical Devices Directive 93/42 EEC. Compliance is demonstrated by self-certification completion of an Electrical Safety checklist validated by Notified Body SGS.
#### Technical Directives
Medical Devices Directive; 93/42/EEC
Pressure Equipment Directive 2014/68/EU
#### Quality Management Systems
Astell Scientific's Quality Management system is compliant with the following standards which are annually audited by Notified Body SGS.
ISO EN 13485: 2012
ISO 9001:2008
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## Technological Characteristics Comparison Tables
| Table 1: Technological characteristics Comparison | | | |
|------------------------------------------------------|------------------|---------------|--------------------------------------|
| Description | K170304 | K111736 | Substantially Equivalence Comparison |
| Sterilization cycles operate by gravity displacement | Yes | Yes | Same |
| Sterilizing Medical and Surgical goods | Yes | Yes | Same |
| 316 Stainless Steel Chamber | Yes | Yes | Same |
| Chamber Diameter | 13.8" | 9"-15" | Similar |
| Chamber Depth | 14.2-26" | 19.8-30" | Similar |
| Chamber Volume Range | 8.7 -16.6 US Gal | 5.2-22 US Gal | Similar |
| Pre-programmed Sterilization Cycles | 4 | 4 | Same |
| Electrically generated steam | Yes | Yes | Same |
| Multiple Safety Features | Yes | Yes | Same |
| Door Safety Locking Mechanism | Yes | Yes | Same |
| Automatic Safety Shutoff | Yes | Yes | Same |
| Two overheating Thermostats | Yes | Yes | Same |
| Safety Pressure Valve | Yes | Yes | Same |
| Digital Display | Yes | Yes | Same |
| Optional Printer | Yes | Yes | Same |
### Table 1; Technological characteristics Comparison
## Table 2; volumetric characteristics Comparison
| Model | Capacity (Litres) | Chamber (Dia x Depth-mm) | Model | Capacity (Litres) | Useable Capacity (Litres) | Chamber (Dia x Depth-mm) | Substantially Equivalence Comparison |
|-----------|-------------------|--------------------------|---------|-------------------|---------------------------|--------------------------|--------------------------------------|
| EZ9 Plus | 19.8 | 230 x 504 | UMB 220 | 33 | 23 | 350 x 360 | Similar |
| EZ11 Plus | 28.5 | 280 x 504 | UMB 230 | 43 | 33 | 350 x 460 | Similar |
| EZ15 Plus | 84 | 380 x 760 | UMB 240 | 63 | 50 | 350 x 660 | Similar |
## Table 3A; Tuttnauer Indication for Use
| K111736 | | | | | |
|----------------------------|------------------------------------|------------------------------|------------------------------------|----------|------------------------------|
| Recommended Use | Device<br>functions | Sterilization<br>Temperature | Sterilization<br>Time<br>(Minutes) | Dry Time | Substantially<br>Equivalence |
| Instruments<br>(Unwrapped) | EZ9 (G)<br>EZ11 (1A)<br>EZ15 (1A) | 132°C | 3 | 1 | Similar |
| Instruments (Wrapped) | EZ9 (1A)<br>EZ11 (1A)<br>EZ15 (1A) | 132°C | 4 | 30 | Similar |
| Glassware (Unwrapped) | EZ9 (G)<br>EZ11 (1A)<br>EZ15 (1A) | 121°C | 30 | 1 | Similar |
| Hand pieces | EZ9 (7A)<br>EZ11 (7A)<br>EZ15 (5A) | 132°C | 4 | 30 | Similar |
(G) = Gravity displacement: (A) = Dynamic Air Removal Pulse
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| K170304 | | | | | | |
|---------------------------------------------|----------------------------------------------------|------------------------------|------------------------------------|-------------|--------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Recommended<br>Use | Device<br>functions | Sterilization<br>Temperature | Sterilization<br>Time<br>(Minutes) | Dry<br>Time | Substantially<br>Equivalence<br>Comparison | Maximum Load |
| Metal Medical<br>Instruments<br>(Unwrapped) | | 134°C | 3 | 15 | Similar | Shelf rack can accommodate 4<br>instrument trays instruments<br>they have to be layered down<br>in an open position. All<br>instruments have to remain<br>apart with a minimum<br>distance of 1cm. Maximum<br>weight/tray: 2.5kg Maximum<br>load/cycle: 10 kg. |
| Metal Medical<br>Instruments<br>(Wrapped) | UMB 220<br>(P)<br>UMB 230<br>(P)<br>UMB 240<br>(P) | 134°C | 4 | 30 | Similar | Shelf rack can accommodate 2<br>pouch racks. Pouches have to<br>stand on their side and not<br>touching each other. Leave at<br>least 2cm between each item<br>Maximum weight/rack: 2.5 kg<br>Maximum load/cycle: 5 kg. |
| Glassware<br>(Unwrapped) | UMB 240<br>(P) | 121°C | 30 | 15 | Similar | Shelf rack can accommodate 4<br>trays. Glassware have to be<br>placed upside down with a<br>minimum distance of 1 cm<br>Maximum weight/tray: 2.5kg<br>Maximum load/cycle: 10 kg. |
| Hand pieces<br>(Pouches) | | 134°C | 4 | 30 | Similar | Shelf rack can accommodate 2<br>pouch racks. Pouches have to<br>stand on their side and not<br>touching each other. Leave at<br>least 2cm between each item<br>Maximum weight/rack: 2.5 kg<br>Maximum load/cycle: 5 kg. |
## Table 3B; Astell Indications for Use
## Table 4: Technical Standards Comparison
| Standard Title | K170304 | K111736 | Substantially<br>Equivalence |
|------------------------------|---------|---------|------------------------------|
| ANSI/AAMI ST55:2010 | ✓ | ✓ | Same |
| ASME Section VIII Division 1 | ✓ | ✓ | Same |
| IEC 61010:2010 | ✓ | ✓ | Same |
| IEC 61010-2-040 | ✓ | ✓ | Same |
| IEC 61326:2013 | ✓ | × | Similar |
| BS EN ISO 14971:2012 | ✓ | × | Similar |
| IEC 62366:2015 | ✓ | × | Similar |
| IEC 62304: 2006 | ✓ | × | Similar |
| ISO EN 13485: 2012 | ✓ | ✓ | Same |
| ISO 9001:2008 | ✓ | ✓ | Same |
| Canada Standards: CMDR | × | ✓ | Same |
| ISO 17665-1:2006 | × | ✓ | Same |
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## Table 5: Thermal Profiling Comparison
| Sterilization Temperature<br>Tolerance | K170304 | K111736 | Substantially<br>Equivalence<br>Comparison |
|----------------------------------------|---------------------|---------------------|--------------------------------------------|
| -0°c and + 3°c | Cycle 121°c; Passed | Cycle 121°c; Passed | Same |
| -0°c and + 3°c | Cycle 134°c Passed | Cycle 132°c; Passed | Similar |
## Conclusion:
The conclusions drawn from the nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well or better than the legally marketed predicate device, K111736
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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.