K173433 · Philips Medical Systems Dmc GmbH · OWB · Feb 5, 2018 · Radiology
Device Facts
Record ID
K173433
Device Name
ProxiDiagnost N90
Applicant
Philips Medical Systems Dmc GmbH
Product Code
OWB · Radiology
Decision Date
Feb 5, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1650
Device Class
Class 2
Attributes
Pediatric
Indications for Use
ProxiDiagnost N90 is a multi-functional general R/F system. It is suitable for all routine radiography and fluoroscopy exams, including specialist areas like angiography or pediatric work, excluding mammography.
Device Story
ProxiDiagnost N90 is a floor-mounted, nearby-controlled fluoroscopy and radiography system. It comprises a motorized, tilt-adjustable patient support table (-85° to +90°) and a scan unit with an X-ray tube, collimator, and Pixium FE4343F dynamic flat-panel detector. The system integrates with the Eleva Workspot for image acquisition and workflow management. It can be configured with a ceiling-suspended tube and vertical stand for digital radiography. Operated by clinicians in a clinical setting, the device captures X-ray signals, which are processed by the image chain to produce high-resolution diagnostic images on displays. These images assist healthcare providers in clinical decision-making for routine and specialized diagnostic exams. The system benefits patients by providing versatile, high-quality imaging across various clinical applications.
Clinical Evidence
No clinical data required. Substantial equivalence was demonstrated through non-clinical performance testing, including verification and validation, image quality testing, and adherence to international consensus standards (ISO 14971, IEC 60601 series, IEC 6220-1).
Indicated for routine radiography and fluoroscopy exams, including angiography and pediatric applications, excluding mammography.
Regulatory Classification
Identification
An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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Philips Medical Systems DMC GmbH % Ming Xiao Regulatory Affairs Manager North America Roentgenstrasse 24-26 22335 Hamburg GERMANY
February 5, 2018
#### Re: K173433
Trade/Device Name: ProxiDiagnost N90 Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OWB, JAA Dated: November 9, 2017 Received: November 13, 2017
Dear Ming Xiao:
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 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.
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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 mediation-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 D. O'Hara For
Robert Ochs. Ph.D Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K173433
Device Name
ProxiDiagnost N90
#### Indications for Use (Describe)
ProxiDiagnost N90 is a multi-functional general R/F system. It is suitable for all routine radiography and fluoroscopy exams, including specialist areas like angiography or pediatric work, excluding mammography.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="unicode-bidi:isolate; direction:ltr;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="unicode-bidi:isolate; direction:ltr;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 7. 510(k) Summary
# 510(k) Summary of Safety and Effectiveness
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR §807.92.
Establishment registration number: 3003768251
- Date Prepared: January 29, 2018 Manufacturer: Philips Medical Systems DMC GmbH Roentgenstrasse 24-26 22335 Hamburg GERMANY
- Contact Person: Ming Xiao Regulatory Affairs Manager, North America Phone: +49 40 5078-2306 Fax: +49 40 5078-2425 E-mail: ming.xiao@philips.com
- Device Name: ProxiDiagnost N90
- Classification: Classification Name: Image-intensified fluoroscopic x-ray system Classification Regulation: 21CFR 892.1650 Classification Panel: 90 -- Radiology Device Class: Class II OWB Classification Product Code: Secondary Product Codes: JAA Philips EasyDiagnost Eleva Predicate Device: Trade Name: Manufacturer: Philips Medical System DMC 510(k) Clearance: K031535 - June 17, 2003 Classification Name: Image-intensified fluoroscopic x-ray system; Stationary x-ray system; Spot-film device; Tilting Radiographic table Classification Regulation: 21CFR 892.1650 Classification Panel: 90 -- Radiology
ProxiDiagnost N90 Premarket Notification – Traditional 510(k) Page 43 of 135
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| | Device Class: | Class II |
|------------------------|-------------------------------------------|---------------------------------------------------------|
| | Product code: | JAA |
| Reference<br>Device_1: | Trade Name: | CombiDiagnost R90 |
| | Manufacturer: | Philips Medical System DMC |
| | 510(k) Clearance: | K163210 - Jan 31, 2017 |
| | Classification Name: | Image-intensified fluoroscopic x-ray<br>system |
| | Classification Regulation: | 21CFR 892.1650 |
| | Classification Panel: | 90 -- Radiology |
| | Device Class: | Class II |
| | Product code:<br>Secondary Product Codes: | JAA<br>KPR, MQB |
| Reference<br>Device_2: | Trade Name: | Eleva Workspot with SkyFlow |
| | Manufacturer: | Philips Medical System DMC |
| | 510(k) Clearance: | K153318 - Dec 22, 2015 |
| | Classification Name: | Solid State X-Ray Imager (Flat<br>Panel/Digital Imager) |
| | Classification Regulation: | 21CFR 892.1680 |
| | Classification Panel: | 90 -- Radiology |
| | Device Class: | Class II |
| | Product code:<br>Secondary Product Codes: | MQB<br>LLZ |
| Reference<br>Device_3: | Trade Name: | Pixium 4343RCE |
| | Manufacturer: | Philips Medical System DMC |
| | 510(k) Clearance: | K170113 – Feb 9, 2017 |
| | Classification Name: | Solid State X-Ray Imager (Flat<br>Panel/Digital Imager) |
| | Classification Regulation: | 21CFR 892.1680 |
| | Classification Panel: | 90 -- Radiology |
| | Device Class: | Class II |
| | Product code: | MQB |
| Reference | Trade Name: | SkyPlate Detector For Philips |
ProxiDiagnost N90 Premarket Notification – Traditional 510(k)
Page 44 of 135
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#### Radiography/Fluoroscopy Systems Manufacturer: Philips Medical System DMC K171461 – July 7, 2017 510(k) Clearance: Classification Name: Solid State X-Ray Imager (Flat Panel/Digital Imager) Classification Regulation: 21CFR 892.1680 90 -- Radiology Classification Panel: Device Class: Class II Product code: MQB
# Device Description:
The ProxiDiagnost N90 is a multi-functional nearby controlled fluoroscopy system in combination with a high-end digital radiography system consisting of a floor-mounted tiltadjustable patient support table and a scan unit consisting of a tube and a flat panel dynamic detector, Pixium FE4343F, for the fluoroscopy examinations. The tabletop can be moved by a motor in the lateral and longitudinal direction and can be tilted -85° to +90° degrees. The scan unit tilts with the table and can be moved in the longitudinal and lateral direction, relative to the table and to the patient. The fully integrated system is provided with a x-ray tube(s) with collimator and high resolution displays. The ProxiDiagnost N90 is configured with a Philips x-ray generator and a flat panel dynamic detector, Pixium FE4343F, components of the Philips radiography/fluoroscopy Image Chain. As additional options, the ProxiDiagnost N90 can be used as a digital radiography system consisting of a mounted tube in a ceiling suspension together with the portable or fixed detector in the vertical stand.
The ProxiDiagnost N90 uses the same workflow as the currently marketed and predicate device, Philips EasyDiagnost Eleva (K031535, cleared June 17, 2003). The ProxiDiagnost N90 incorporates the following features, previously cleared by FDA in the following reference devices:
| Design Feature/ Attribute | Currently Marketed and Reference Device |
|-------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|
| | Philips Medical Systems |
| Image Chain acquisition-station and workflow<br>(Eleva Workspot) | Eleva Workspot with SkyFlow (K153318, December 22, 2015) |
| Dynamic flat detector, PixiumFE4343F and<br>motorized collimator (in ceiling suspensions) | CombiDiagnost R90 (K163210, January 31, 2017) |
| Wireless portable detector | SkyPlate Detector for Radiography/Fluoroscopy<br>Systems (K171461, July 7, 2017) |
| Fixed static detector | Pixium 4343 RCE (K170113, February 9, 2017) |
#### Device 4:
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# Indications for Use:
ProxiDiagnost N90 is a multi-functional general R/F system. It is suitable for all routine radiography and fluoroscopy exams, including specialist areas like angiography or pediatric work, excluding mammography.
# Fundamental Scientific Technology:
The ProxiDiagnost N90 employs the same basic construction and fundamental scientific technology as the currently marketed and predicate EasyDiagnost Eleva (K031533), with regards to the functionality of the following components: table, system-control, X-Ray tube, and generator (see the comparison table comparing the ProxiDiagnost N90 to the currently marketed and predicate EasyDiagnost Eleva provided below).
The ProxiDiagnost N90 employs the following cleared features: fixed detector (Pixium FE 4343F K163210), wireless detectors (Pixium 4343RCE, K170113, February 9, 2017; SkyPlate Detector for R/F Systems, K171461, July 7, 2017) and the image chain acquisitionstation and workflow (fluoroscopy) (Eleva Workspot with SkyFlow, K153318, Dec 22, 2015). The fixed detector, wireless portable detectors, and the image chain and workstation of the ProxiDiagnost N90 are identical to the fixed detector, wireless portable detectors, and the image chain and workstation of the currently marketed and reference devices. Therefore, the fixed detector, wireless portable detectors, and the image chain and workstation employ identical fundamental scientific technology.
The outcome of this comparison demonstrates that the minor differences in the technological characteristics do not affect the safety or effectiveness of the ProxiDiagnost N90 when compared to the currently marketed and predicate EasyDiagnost Eleva.
# Summary of technological characteristics:
The ProxiDiagnost N90 has similar indications for use and technological characteristics as the predicate device, EasyDiagnost Eleva. Comparisons of the technological characteristics demonstrate the substantial equivalence to the predicate device.
| | Primary Predicate Device:<br><i>EasyDiagnost Eleva</i><br>( <i>K031535</i> ) | Proposed Device:<br><i>ProxiDiagnost R90</i><br>( <i>K173433</i> ) | Discussion |
|-----------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Table Features | | | |
| Working height<br>(table top center<br>to floorplate) | 83cm | 83.3cm | Similar; the range of working<br>height does not affect the<br>safety or effectiveness of the<br>device. |
| Table tilt<br>movement | -20° to +90°<br>Optional:<br>-30° to +90°<br>-45° to +90°<br>-85° to +90° | -90° to +90°<br>movement speed with<br>variable 1 to 6°/s | Similar: The table tilt<br>movement does not affect the<br>safety or effectiveness of the<br>device. |
| Table top<br>suspension | Two sides suspensions | Two sides suspensions | Equivalent; No impact to<br>safety or effectiveness of the<br>device. |
| Table top | Plastic laminate or carbon | Sandwich of laminate, | Similar: The table top |
| | Primary Predicate Device:<br>EasyDiagnost Eleva<br>(K031535) | Proposed Device:<br>ProxiDiagnost R90<br>(K173433) | Discussion |
| material | fiber | carbon and foam | material movement does not affect the safety or effectiveness of the device. |
| Table top<br>movement | Lateral: -10 cm to + 9 cm<br>Longitudinal: ± 83 cm | Lateral: -10 cm to + 9 cm<br>Longitudinal: ± 83.5 cm | Equivalent; No impact to safety or effectiveness of the device. |
| Table top<br>absorption | 0.7mm typical (@ 100kV,<br>2.7mm Al HVL) | 0.6mm Al typical @<br>100kV | Similar: Minor differences in the table top absorption does not affect the safety or effectiveness of the device. |
| Maximum<br>patient weight | 180 kg | static: 300 kg<br>tilt: 250 kg<br>all movements: 185 kg | The proposed ProxiDiagnost N90 is able to hold more patient weight; this does not affect the safety or effectiveness of the device. |
| Lateral scan<br>distance | 22 cm | 22 cm | Equivalent; No impact to safety or effectiveness of the device. |
| Lateral scan<br>speed | Manual Movement | Manual Movement | Equivalent; No impact to safety or effectiveness of the device. |
| Longitudinal<br>scan distance | 75 cm mechanical range | 75 cm mechanical range | Equivalent; No impact to safety or effectiveness of the device. |
| Table column<br>angulation | -85° to +90° | -85° to +90° | Equivalent; No impact to safety or effectiveness of the device. |
| Source image<br>distance | 73 cm – 103 cm,<br>88 cm – 118 cm with<br>Geomat in extended<br>position | 81 cm – 130 cm | Similar: The source image distance provided with the proposed ProxiDiagnost N90 does not affect the safety or effectiveness of the device. |
| Collimator | Square / rectangular plus<br>Iris | rectangular collimation | The rectangular collimator provided with the proposed ProxiDiagnost N90 does not affect the safety or effectiveness of the device. It is the same collimator used in the currently marketed and reference device, CombiDiagnost R90 (K163210) |
| Grid | Parkable | Parkable | Equivalent; No impact to safety or effectiveness of the device. |
| Picture archiving<br>and<br>communication<br>system | Yes | Yes | Equivalent; No impact to safety or effectiveness of the device. |
| Image chain<br>(fluoroscopy) | Philips Image Intensifier /<br>CCD TV / Digital Imaging | Philips Dynamic Eleva<br>Image Chain | The proposed ProxiDiagnost N90 includes the currently marketed and reference |
| | Primary Predicate Device:<br>EasyDiagnost Eleva<br>(K031535) | Proposed Device:<br>ProxiDiagnost R90<br>(K173433) | Discussion |
| Detector | Image Intensifier 23 cm, 31<br>cm or 38 cm | Pixium FE 4343F | (K153318) as part of the<br>image chain. In addition, this<br>same image chain is used in<br>the currently marketed and<br>reference device,<br>CombiDiagnost R90<br>(K163210). Therefore, there<br>is no impact on the safety or<br>effectiveness of the device.<br>The proposed ProxiDiagnost<br>N90 includes the fixed<br>detector Pixium FE 4343F<br>used in the currently<br>marketed and reference<br>device, CombiDiagnost R90<br>(K163210). Therefore, there<br>is no impact on the safety or<br>effectiveness of the device. |
| Modulation<br>Transfer<br>Function (MTF)<br>(according to IEC<br>62220-1-3 standard) | Not available | lp/mm<br>%<br>1 66<br>2 35<br>3 19<br>3.4 15 | The proposed ProxiDiagnost<br>N90 includes the fixed<br>detector Pixium FE 4343F<br>used in the currently<br>marketed and reference<br>device, CombiDiagnost R90<br>(K163210). Therefore, there<br>is no impact on the safety or<br>effectiveness of the device. |
| Detective<br>Quantum<br>Efficiency<br>(DQE)<br>(according to IEC<br>62220-1-3 standard) | Not available | DQE at 1 µGy<br>lp/mm %<br>0.05 65<br>1 51<br>2 41<br>3 27<br>3.4 18 | The proposed ProxiDiagnost<br>N90 includes the fixed<br>detector Pixium FE 4343F<br>used in the currently<br>marketed and reference<br>device, CombiDiagnost R90<br>(K163210). Therefore, there<br>is no impact on the safety or<br>effectiveness of the device. |
| Wireless Static<br>Detector for<br>Radiographic<br>Exams | Wireless Portable Detector<br>Pixium4600 (previous<br>version of SkyPlate<br>Detector) | SkyPlate Detector | The proposed ProxiDiagnost<br>N90 includes the currently<br>marketed and reference<br>device, SkyPlate Detectors<br>for R/F Systems (K171461).<br>Therefore, there is no impact<br>on the safety or effectiveness<br>of the device. |
| Wireless Static<br>Detector for<br>Radiographic<br>Exams | N/A | Pixium RCE | The proposed ProxiDiagnost<br>N90 includes the currently<br>marketed and reference<br>device, Pixium RCE<br>(K170113). Therefore, there<br>is no impact on the safety or<br>effectiveness of the device. |
| Generator | Philips Velara GCF/RF, | Philips Velara GCF/RF, | Equivalent; No impact to |
| | 50kW.65kW or 80kW | 65 kW, optional 80 kW | safety or effectiveness of the |
| | Primary Predicate Device:<br>EasyDiagnost Eleva<br>(K031535) | Proposed Device:<br>ProxiDiagnost R90<br>(K173433) | Discussion |
| | | | device. |
| Tube | Philips SRO 2550 or SRM<br>2250 GS | Philips SRM 2250 ROT-<br>GS 504 or<br>SRO 2550 ROT380 or<br>SRO 33100 ROT380<br>(optional in CSM) | Equivalent; No impact to<br>safety or effectiveness of the<br>device. |
| System Control | Near by | Nearby | Equivalent; No impact to<br>safety or effectiveness of the<br>device. |
| Indications for<br>Use | The Philips EasyDiagnost<br>Eleva intended use is for the<br>following applications: As a<br>multi-functional/ universal<br>system, general R/F, Fluoro-<br>scopy, Radiography and<br>Angiography can be<br>performed along with<br>pediatric examinations and<br>some more specialized<br>interventional applications. | ProxiDiagnost N90 is a<br>multi-functional general<br>R/F system. It is suitable<br>for all routine radiography<br>and fluoroscopy exams,<br>including specialist areas<br>like angiography or<br>pediatric work, excluding<br>mammography. | Equivalent; The Indications<br>for Use for the proposed<br>ProxiDiagnost N90 is more<br>general in nature and exactly<br>the same as the currently<br>marketed and reference<br>device, CombiDiagnost R90<br>(K163210). |
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Based on the information provided above, the ProxiDiagnost N90 is considered substantially equivalent to the currently marketed and predicate device, EasyDiagnost Eleva (K031535, June 17, 2003) in terms of fundamental scientific technology.
# Summary of Non-Clinical Data:
This 510(k) premarket notification contains technical documentation which includes nonclinical verification and validation tests as well as image quality tests were performed on the proposed ProxiDiagnost N90 according to the following international and FDA-recognized consensus standards:
- ISO 14971, Medical devices. Application of risk management to medical devices
- IEC 60601-1, Medical electrical equipment. General requirements for safety. . Collateral standard. Safety requirements for medical electrical systems
- IEC 60601-1-2, Medical electrical equipment. General requirements for basic safety ● and essential performance. Collateral standard. Electromagnetic compatibility. Requirements and tests
- IEC 60601-1-3. Medical electrical equipment. General requirements for basic safety . and essential performance. Collateral Standard: Radiation protection in diagnostic Xray equipment
- . IEC 60601-2-54. Medical electrical equipment. Particular requirements for the basic safety and essential performance of X-ray equipment for radiography and radioscopy
- IEC 6220-1, Medical electrical equipment. Characteristics of digital X-ray imaging devices. Determination of the detective quantum efficiency
- IEC 62304, Medical device software. Software life-cycle processes ●
- Guidance for the Submission of 510(k)s for Solid State X-Ray Imaging Devices, issued September 1, 2016
ProxiDiagnost N90 Premarket Notification – Traditional 510(k) Page 49 of 135
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- . Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, issued May 11, 2005
- Pediatric Information for X-ray Imaging Device Premarket Notifications, Draft, issued May 10, 2012
- Guidance for the Submission of Premarket Notifications for Medical Image ● Management Device, issued July 27, 2000
- Guidance for Radio Frequency Wireless Technology in Medical Devices, issued August 14, 2013
- . Guidance for Management of Cybersecurity in Medical Devices, issued October 2, 2014
The test results demonstrate that the proposed ProxiDiagnost N90 meets the acceptance criteria and is adequate for its intended use.
Based upon the same intended use, similar technology, software functionalities, same product configuration and administration, and similarity of materials, it can be concluded the proposed ProxiDiagnost N90 is substantially equivalent to the predicate device, Philips EasyDiagnost Eleva, in terms of intended use, design characteristics, and safety and effectiveness.
#### Summary of Clinical Data:
The proposed ProxiDiagnost N90 did not require a clinical study since substantial equivalence to the currently marketed and predicate device was demonstrated with the following attributes:
- Design features:
- . Indication for use;
- Fundamental scientific technology; ●
- Non-clinical performance testing including validation; and
- Safety and effectiveness.
#### Substantial Equivalence Conclusion:
The comparison of technological characteristics, non-clinical performance data, safety testing, software validation, and clinical image concurrence data demonstrates that the device is as safe and effective as the predicate device. Philips Medical Systems concludes that the proposed ProxiDiagnost N90 is substantially equivalent to the legally marketed predicate device, EasyDiagnost Eleva.
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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.