The AEQUALIS FLEX REVIVE Shoulder System is intended for replacement of the shoulder joint to reduce pain and improve shoulder mobility in comparison with preoperative status.
Device Story
Modular shoulder arthroplasty system; anatomic or reverse configuration; allows conversion from anatomic to reverse without humeral implant removal. Components: proximal body, stem, assembly screw, locking cap, spacers. Surgeon selects components to size construct for patient. Implanted in clinical setting. Provides increased mobility; relieves pain. Benefits patient by restoring joint function; addressing degenerative/traumatic conditions. Titanium alloy (Ti6Al4V) and CoCr construction. Single-use; sterile.
Clinical Evidence
Bench testing only. Fatigue testing (10 million cycles), range of motion (ASTM F1378-12), taper tensile/torque, press-fit/cemented preparation, biocompatibility (ISO 10993-1), endotoxin, and packaging distribution testing performed. No clinical data.
Technological Characteristics
Modular shoulder prosthesis. Materials: Ti6Al4V (ASTM F-136) for proximal body, stem, spacers; CoCr (ISO 5832-12) for assembly screw/locking cap. Titanium plasma coating. Gamma sterilization (min 25 KGy, SAL 1x10-6). Mechanical fixation (cemented or cementless).
Indications for Use
Indicated for patients with intact/reconstructable rotator cuff (anatomic) or functional deltoid (reverse) requiring shoulder joint replacement due to rheumatoid arthritis, non-inflammatory degenerative joint disease (osteoarthritis, avascular necrosis), functional deformity, humeral head fractures, traumatic arthritis, or revision of other devices with sufficient bone stock. Reverse configuration also indicated for massive/non-repairable rotator cuff tears.
Regulatory Classification
Identification
A shoulder joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. This generic type of device includes prostheses that have a humeral resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, and is limited to those prostheses intended for use with bone cement (§ 888.3027).
Special Controls
*Classification.* Class II. The special controls for this device are:(1) FDA's:
(i) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(ii) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),”
(iii) “Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement,”
(iv) “Guidance Document for the Preparation of Premarket Notification (510(k)) Application for Orthopedic Devices,” and
(v) “Guidance Document for Testing Non-articulating, ‘Mechanically Locked’ Modular Implant Components,”
(2) International Organization for Standardization's (ISO):
(i) ISO 5832-3:1996 “Implants for Surgery—Metallic Materials—Part 3: Wrought Titanium 6-aluminum 4-vandium Alloy,”
(ii) ISO 5832-4:1996 “Implants for Surgery—Metallic Materials—Part 4: Cobalt-chromium-molybdenum casting alloy,”
(iii) ISO 5832-12:1996 “Implants for Surgery—Metallic Materials—Part 12: Wrought Cobalt-chromium-molybdenum alloy,”
(iv) ISO 5833:1992 “Implants for Surgery—Acrylic Resin Cements,”
(v) ISO 5834-2:1998 “Implants for Surgery—Ultra-high Molecular Weight Polyethylene—Part 2: Moulded Forms,”
(vi) ISO 6018:1987 “Orthopaedic Implants—General Requirements for Marking, Packaging, and Labeling,” and
(vii) ISO 9001:1994 “Quality Systems—Model for Quality Assurance in Design/Development, Production, Installation, and Servicing,” and
(3) American Society for Testing and Materials':
(i) F 75-92 “Specification for Cast Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implant Material,”
(ii) F 648-98 “Specification for Ultra-High-Molecular-Weight Polyethylene Powder and Fabricated Form for Surgical Implants,”
(iii) F 799-96 “Specification for Cobalt-28 Chromium-6 Molybdenum Alloy Forgings for Surgical Implants,”
(iv) F 1044-95 “Test Method for Shear Testing of Porous Metal Coatings,”
(v) F 1108-97 “Specification for Titanium-6 Aluminum-4 Vanadium Alloy Castings for Surgical Implants,”
(vi) F 1147-95 “Test Method for Tension Testing of Porous Metal,”
(vii) F 1378-97 “Standard Specification for Shoulder Prosthesis,” and
(viii) F 1537-94 “Specification for Wrought Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implants.”
Aequalis Adjustable Reversed Shoulder System (K141029)
Submission Summary (Full Text)
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September 20, 2018
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Tornier, Inc. Laurie Lewandowski Regulatory Associate, Consultant 10801 Nesbitt Ave South Bloomington, Minnesota 55437
Re: K181420
Trade/Device Name: Aequalis Flex Revive Shoulder System Regulation Number: 21 CFR 888.3660 Regulation Name: Shoulder Joint Metal/Polymer Semi-Constrained Cemented Prosthesis Regulatory Class: Class II Product Code: KWS, PHX, HSD Dated: August 30, 2018 Received: August 31, 2018
Dear Laurie Lewandowski:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination. product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
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https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,
| Vesa | Digitally signed by Vesa Vuniqi -S |
|-----------|------------------------------------|
| Vuniqi -S | Date: 2018.09.20 |
| | 16:24:14 -04'00' |
Mark N. Melkerson For: Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
#### K181420
Device Name Aequalis Flex Revive Shoulder System
Indications for Use (Describe) IN ANATOMIC:
The proximal body, stem, assembly screw, locking cap, optional spacer(s), and humeral head may be used together, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with the glenoid, as a total replacement.
The AEQUALIS FLEX REVIVE Shoulder System is to be used only in patients with an intact or reconstructable rotator cuff, where it is intended to provide increased mobility and to relieve pain. The AEQUALIS FLEX REVIVE Shoulder System is indicated for use as a replacement of shoulder joints disabled by:
- Rheumatoid arthritis with pain
- · Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis)
- · Correction of functional deformity
- · Fractures of the humeral head
- · Traumatic arthritis
- · Revision of other devices if sufficient bone stock remains
#### IN REVERSE:
The AEQUALIS FLEX REVIVE Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle with pain disabled by:
- Rheumatoid arthritis
- · Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis)
- · Correction of functional deformity
- · Fractures of the humeral head
- · Traumatic arthritis
- · Massive and non-repairable rotator cuff tear
- · Revision of the devices if sufficient bone stock remains
The reversed tray and polyethylene insert are in the conversion from an anatomic to reversed shoulder arthroplasty without the removal of the humeral assembly during revision surgery for patients with a functional deltoid muscle.
#### Notes:
- All components are single use.
- · The coated humeral stem is intended for cemented or cementless use.
- · The all-poly glenoid components are intended for cemented use only
- · The glenoid sphere implant is anchored to the bone with screws and is for non-cemented fixation.
· Titanium humeral heads are intents with suspected cobalt alloy material sensitivity. The wear properties of Titanium and Titanium alloys are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack a suspected material sensitivity to cobalt alloy.
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Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/4/Picture/0 description: The image shows the word "TORNIER" in a blue serif font, followed by a blue hexagon containing a stylized letter "T" inside. The letter "T" in the hexagon is also in a blue serif font and has a smaller hexagon inside of it. The logo is simple and clean, with a focus on the company name and a unique symbol.
Date Prepared: May 30, 2018
#### Administrative Information
| Name: | Tornier, Inc. |
|-----------------|---------------------------------------------------------------------------------|
| Address: | 10801 Nesbitt Avenue South<br>Bloomington, MN 55437<br>United States of America |
| Contact Person: | Laurie Lewandowski |
| Title: | Regulatory Associate, Contract |
| Phone: | 612-770-4038 |
| Fax: | 952-426-7601 |
## Device Information
Name of Device: AEQUALIS FLEX REVIVE Shoulder System Common Name (s): Classification Name: Prosthesis, Shoulder, Semi-Constrained, Metal/ Polymer Cemented Regulatory Class: II Regulation Number: 888.3660, 888.3690 Product Code: KWS, PHX, HSD
## Predicate Device Information
| Predicate Device: | Aequalis Ascend Flex Shoulder System |
|-------------------|----------------------------------------------|
| 510K number: | K140082 |
| Reference Device: | Aequalis Adjustable Reversed Shoulder System |
| 510K Number: | K141029 |
## Device Description
AEQUALIS FLEX REVIVE Shoulder System (AFR) is a fully convertible anatomic and reversed shoulder arthroplasty system that is designed to be used with existing Tornier implant systems. It is a non-constrained system intended for total or partial replacement of the glenohumeral articulation. AFR includes a proximal body (metaphysis), spacer(s), a stem, assembly screw, and locking cap. The proximal body has a female taper that is compatible with Ascend Flex Humeral Head and Ascend Flex reversed trays and poly inserts.
The AFR Shoulder System is implanted by a surgeon and is designed to allow the surgeon to select the components to size the shoulder system for the patient. It allows the shoulder to be constructed in an anatomical or reversed configuration using cleared Ascend Flex humeral heads or Ascend Flex reversed trays and inserts. In addition, the AFR Shoulder System can be transformed from anatomic to reverse shoulder prosthesis without the removal of the humeral implant assembly during revision surgery.
Tornier AEQUALIS FLEX REVIVE Shoulder System
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Image /page/5/Picture/0 description: The image shows the word "TORNIER" in large, blue, serif font. To the right of the word is a blue hexagon with a stylized letter "T" inside. The letter "T" is also blue and has a smaller hexagon inside of it.
The humeral length is measured to determine the overall humeral implant construct length. The length is assembled from 120 mm (using the short proximal body and stem) to 180 mm (using the standard proximal body, spacers, and stem) in 10mm increments with the spacers as needed and either of the two available lengths of the proximal body for patient specificity.
The proximal body, stem, and spacers are made from Ti6Al4V per ASTM F-136. The proximal body and stem have a Titanium plasma coating. The assembly screw and locking cap are made from of CoCr per ISO 5832-121. They are single use and packaged sterile, using gamma radiation at a minimum dose of 25 KGy to an SAL of 1x10-6.
The AFR Shoulder System is comprised of the component in Table 5.1.
| Catalog # | Description | Diameter (mm) | Effective Length (mm) | Angle (°) |
|---------------|---------------------|----------------------------|-----------------------|-----------|
| Proximal Body | | | | |
| ARS741701 | Proximal Body | Ø9 | 40 | 132.5 |
| ARS741702 | Proximal Body | Ø11 | 40 | 132.5 |
| ARS741703 | Proximal Body | Ø13 | 40 | 132.5 |
| ARS741704 | Proximal Body | Ø15 | 40 | 132.5 |
| ARS741705 | Proximal Body | Ø17 | 40 | 132.5 |
| ARS741706 | Proximal Body | Ø19 | 40 | 132.5 |
| ARS741707 | Short Proximal Body | Ø9 | 30 | 132.5 |
| ARS741708 | Short Proximal Body | Ø11 | 30 | 132.5 |
| ARS741709 | Short Proximal Body | Ø13 | 30 | 132.5 |
| ARS741710 | Short Proximal Body | Ø15 | 30 | 132.5 |
| ARS741711 | Short Proximal Body | Ø17 | 30 | 132.5 |
| ARS741712 | Short Proximal Body | Ø19 | 30 | 132.5 |
| Spacers | | | | |
| Catalog # | Description | Size (diam. and length mm) | | |
| ARS342001 | Spacer | Ø9 x 20 | | |
| ARS342002 | Spacer | Ø11 x 20 | | |
| ARS342003 | Spacer | Ø13 x 20 | | |
| ARS342004 | Spacer | Ø15 x 20 | | |
| ARS342005 | Spacer | Ø17 x 20 | | |
| ARS342006 | Spacer | Ø19 x 20 | | |
| ARS342007 | Spacer | Ø9 x 30 | | |
| ARS342008 | Spacer | Ø11 x 30 | | |
| ARS342009 | Spacer | Ø13 x 30 | | |
| ARS342010 | Spacer | Ø15 x 30 | | |
| ARS342011 | Spacer | Ø17 x 30 | | |
| ARS342012 | Spacer | Ø19 x 30 | | |
## Table 5. 1 AFR Shoulder System Components
Tornier AEQUALIS FLEX REVIVE Shoulder System
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| Distal Stem | | | |
|----------------|-----------------------|-----------------------|-------------|
| Catalog # | Description | Diameter (mm) | Length (mm) |
| ARS741801 | Distal Stem | Ø9 | 90 |
| ARS741802 | Distal Stem | Ø11 | 90 |
| ARS741803 | Distal Stem | Ø13 | 90 |
| ARS741804 | Distal Stem | Ø15 | 90 |
| ARS741805 | Distal Stem | Ø17 | 90 |
| ARS741806 | Distal Stem | Ø19 | 90 |
| Assembly Screw | | | |
| Catalog # | Description | Effective Length (mm) | |
| ARS655101 | Assembly Screw | 0 | |
| ARS655102 | Assembly Screw | 20 | |
| ARS655103 | Assembly Screw | 30 | |
| ARS655104 | Assembly Screw | 40 | |
| ARS655105 | Assembly Screw | 50 | |
| ARS655118 | Assembly Screw, Short | 0 | |
| ARS655119 | Assembly Screw, Short | 20 | |
| Locking Cap | | | |
| Catalog # | Description | | |
| ARS655200 | Locking Cap | | |
## Intended Use
The AEQUALIS FLEX REVIVE Shoulder System is intended for replacement of the shoulder joint to reduce pain and improve shoulder mobility in comparison with preoperative status.
# Indications for Use
## IN ANATOMIC:
The proximal body, stem, assembly screw, locking cap, optional spacer(s), and humeral head may be used together, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with the glenoid, as a total replacement.
The AEQUALIS FLEX REVIVE Shoulder System is to be used only in patients with an intact or reconstructable rotator cuff, where it is intended to provide increased mobility and to relieve pain. The AEQUALIS FLEX REVIVE Shoulder System is indicated for use as a replacement of shoulder joints disabled by:
- Rheumatoid arthritis with pain
- · Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis)
- · Correction of functional deformity
Tornier AEQUALIS FLEX REVIVE Shoulder System
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Image /page/7/Picture/0 description: The image shows the word "TORNIER" in a large, sans-serif font, colored in blue. To the right of the word is a logo consisting of a hexagon with a stylized letter "T" inside. The logo is also colored in blue and has a modern, geometric design.
- Fractures of the humeral head
- Traumatic arthritis
- · Revision of other devices if sufficient bone stock remains
# IN REVERSE:
The AEQUALIS FLEX REVIVE Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle with pain disabled by:
- . Rheumatoid arthritis
- Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis) .
- Correction of functional deformity .
- Fractures of the humeral head .
- Traumatic arthritis .
- Massive and non repairable rotator cuff tear .
- . Revision of the devices if sufficient bone stock remains
The reversed tray and polyethylene insert are indicated for use in the conversion from an anatomic to reversed shoulder arthroplasty without the removal of the humeral assembly during revision surgery for patients with a functional deltoid muscle.
## Notes:
- · All components are single use.
- · The coated humeral stem is intended for cemented or cementless use.
- · The all-poly glenoid components are intended for cemented use only
- · The glenoid sphere implant is anchored to the bone with screws and is for non-cemented fixation.
- Titanium humeral heads are intended for patients with suspected cobalt alloy material sensitivity. The wear properties of Titanium and Titanium allovs are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack a suspected material sensitivity to cobalt alloy.
# Comparison of Technological Characteristics with the Predicate Device
Table 5.2 compares the technological characteristics of the AFR shoulder System to the predicate. Aequalis Ascend Flex and the reference device. Aequalis Adiustable Reversed as applicable.
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| | | Table 5. 2 Comparison of Technological Characteristics | |
|--|--|--------------------------------------------------------|--|
|--|--|--------------------------------------------------------|--|
| | Aequalis Flex Revive<br>Shoulder System (AFR) | Predicate Ascend Flex (K140082)<br>Reference Device Adjustable Reversed<br>(K141029) |
|---------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Design Principal | Modular design to allow the<br>surgeon to select the<br>components to size the shoulder<br>system for the patient;<br>convertible from anatomic to<br>reversed without removing the<br>implant assembly | Ascend Flex – multiple sizes for surgeon<br>selection; convertible from anatomic to<br>reversed without removing the implant<br>assembly.<br>Adjustable Reverse - modular design to<br>allow surgeon to select the components<br>to size the shoulder system for the<br>patient. |
| Overall lengths | Adjustable total lengths from<br>120mm to 180mm (10mm<br>increments) | Ascend Flex -<br>66mm to 98mm (standard coated)<br>88mm to 130mm (long coated)<br>66mm to 94mm (standard non-coated)<br>88mm to 125mm (long non-coated)<br>Adjustable Reverse - adjustable length,<br>using spacers, up to 210mm |
| Stem and Spacer<br>Diameters<br>(diaphysis) | 9, 11, 13, 15, 17, 19 mm | Ascend Flex-<br>Standard Stems: 9 – 20mm<br>Long Stems: 9 – 20mm<br>Adjustable Reverse - 9, 11, 13, 15, 17mm |
| Spacer length | 20, 30 mm | Ascend Flex - N/A<br>Adjustable Reversed - 15, 20, 25, 50, and<br>100mm |
| Materials | Proximal body, spacers, distal<br>stems: Titanium alloy<br>(Ti6Al4V) and commercially<br>pure Ti (coating)<br>Assembly Screw and Locking<br>Cap: CoCr | Titanium alloy (Ti6Al4V) and<br>commercially pure Ti (coating) |
| Sterility Assurance<br>Level (SAL) | 1x10-6 | Identical |
| Sterilization<br>Method | Gamma | Identical |
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Image /page/9/Picture/0 description: The image shows the word "TORNIER" in a large, sans-serif font, colored in blue. To the right of the word is a blue hexagon containing a stylized letter "T" inside. The letter "T" is also blue and has a unique design, with a smaller hexagon shape incorporated into its structure.
# Non-clinical Performance Testing
Table 5.3 is a summary of the testing performed on the AEQUALIS FLEX REVIVE Shoulder System.
| Table 5. 3 Summary of the Testing Performed on the AFR Shoulder System | | |
|------------------------------------------------------------------------|--|--|
| | | |
| Test Performed | Acceptance Criteria |
|-----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Fatigue Testing | The humeral stems were tested to 10 million cycles (5 million<br>in each configuration) without failure, fracture, or dislocation<br>when inspected after each tested configuration at a<br>magnification of 50X. |
| Range of Motion | The Aequalis Flex Revive Shoulder System met the range of<br>motion requirements in ASTM F1378-12. |
| Taper Tensile | Taper resultant force were not significantly lower than those of<br>the Ascend Flex taper connections when analyzed with a 2-<br>sample T-test. |
| Tensile Static Torque | The disassociation torque of the male taper from the female<br>taper was not statistically lower than 1.72Nm, or two times the<br>anticipated frictional torque between glenoid sphere and the<br>reversed insert. |
| Press Fit Preparation | The AFR Shoulder System achieved a press-fit for the proximal<br>body and distal stem allowing the implant to attain proper<br>seating and acceptable fixation. |
| Cemented Preparation | The AFR Humeral Stem cement mantle thickness met or<br>exceeded the Ascend Flex cement mantle thickness. |
| Biocompatibility | Biocompatibility requirements per ISO 10993-1 were met |
| Endotoxin | Endotoxin results per ST72 demonstrated <20EU/device |
| Packaging | Distribution testing met requirements per ASTM D4169-16 |
# Conclusions
The AEQUALIS FLEX REVIVE Shoulder System has similar intended use and indications for use as the predicate, Ascend Flex Shoulder System (K140082). The reference device supports the use of the spacers to allow the surgeon to select the implant construct length for the patient. Testing demonstrated the AFR met the test requirements and compares favorably to the predicate. The AFR Shoulder System is substantially equivalent to the Ascend Flex Shoulder System.
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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.