K190650 · Sorin Group Italia S.R.L. · KFM · Aug 7, 2019 · Cardiovascular
Device Facts
Record ID
K190650
Device Name
Revolution Centrifugal Blood Pump
Applicant
Sorin Group Italia S.R.L.
Product Code
KFM · Cardiovascular
Decision Date
Aug 7, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.4360
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Revolution Centrifugal Blood Pump is intended to be used with a LivaNova Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vitro, in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO). The Revolution Centrifugal Blood Pump with PC Coating is intended for use only with a LivaNova Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vitro, in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
Device Story
Extracorporeal blood pump; utilizes rotating vained impeller within housing to move blood via centrifugal force. Input: blood flow from patient; Output: pressurized blood flow returned to patient. Operated in OR by perfusionists/clinicians using LivaNova Centrifugal Pump Console. Magnetically coupled drive unit rotates impeller; impeller design minimizes heat/hemolysis. PC-coated version includes phosphorylcholine coating to reduce platelet adhesion. Device provides flow/pressure responsive to resistance; supports cardiopulmonary bypass. Benefits: provides necessary circulatory support during bypass procedures.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by non-clinical verification and validation testing, including compliance with applicable voluntary standards for centrifugal blood pump systems.
Technological Characteristics
Nonroller-type centrifugal blood pump; rotating vained impeller; multi-pole magnetic coupling; 3/8" inlet/outlet ports. PC-coated version features phosphorylcholine blood-contact surface. Sterile, single-use, non-pyrogenic. Operates via magnetic coupling to LivaNova console drive unit.
Indications for Use
Indicated for use in cardiopulmonary bypass procedures for up to six hours. Not indicated for long-term use (>6 hours), bridge to transplant, recovery of natural heart, or ECMO.
Regulatory Classification
Identification
A nonroller-type cardiopulmonary and circulatory bypass blood pump is a prescription device that uses a method other than revolving rollers to pump the blood through an extracorporeal circuit for periods lasting less than 6 hours for the purpose of providing either:(i) Full or partial cardiopulmonary bypass (i.e., circuit includes an oxygenator) during open surgical procedures on the heart or great vessels; or(ii) Temporary circulatory bypass for diversion of flow around a planned disruption of the circulatory pathway necessary for open surgical procedures on the aorta or vena cava.
Special Controls
*Classification* —Class II (special controls). The special controls for this device are:(i) Non-clinical performance testing must perform as intended over the intended duration of use and demonstrate the following: Operating parameters, dynamic blood damage, heat generation, air entrapment, mechanical integrity, and durability/reliability;
(ii) The patient-contacting components of the device must be demonstrated to be biocompatible;
(iii) Sterility and shelf life testing must demonstrate the sterility of patient-contacting components and the shelf life of these components; and
(iv) Labeling must include information regarding the duration of use, and a detailed summary of the device- and procedure-related complications pertinent to use of the device.
(b)
*Nonroller-type temporary ventricular support blood pump* —(1)*Identification.* A nonroller-type temporary ventricular support blood pump is a prescription device that uses any method resulting in blood propulsion to provide the temporary ventricular assistance required for support of the systemic and/or pulmonary circulations during periods when there is ongoing or anticipated hemodynamic instability due to immediately reversible alterations in ventricular myocardial function resulting from mechanical or physiologic causes. Duration of use would be less than 6 hours.(2)
*Classification.* Class III (premarket approval).(c)
*Date premarket approval application (PMA) or notice of completion of product development protocol (PDP) is required.* A PMA or notice of completion of a PDP is required to be filed with FDA on or before September 8, 2015, for any nonroller-type temporary ventricular support blood pump that was in commercial distribution before May 28, 1976, or that has, on or before September 8, 2015, been found to be substantially equivalent to any nonroller-type temporary ventricular support blood pump that was in commercial distribution before May 28, 1976. Any other nonroller-type temporary ventricular support blood pump shall have an approved PMA or declared completed PDP in effect before being placed in commercial distribution.
Revolution Centrifugal Blood Pump with PC Coating (K030462)
Submission Summary (Full Text)
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August 7, 2019
Sorin Group Italia S.r.1. % Scott Light Senior Manager, Regulatory Affairs LivaNova USA, Inc. 14401 West 65th Way Arvada, Colorado 80004
Re: K190650
Trade/Device Name: Revolution Centrifugal Blood Pump and Revolution Centrifugal Blood Pump with PC Coating Regulation Number: 21 CFR 870.4360 Regulation Name: Nonroller-Type Blood Pump Regulatory Class: Class II Product Code: KFM Dated: January 29, 2019 Received: March 13, 2019
Dear Scott Light:
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.
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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 https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Fernando Aguel Assistant Director DHT2B: Division of Circulatory Support, Structural and Vascular Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known)
### K190650
Device Name Revolution Centrifugal Blood Pump
Indications for Use (Describe)
The Revolution Centrifugal Blood Pump is intended to be used with a LivaNova Centrifygal Pump Console in cardiopulmonary bypass procedures for periods of us to six hours. Refer to the console operator's manual for console operating procedures.
The pump has not been qualified through in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
| Type of Use (Select one or both, as applicable) |
|-----------------------------------------------------------------------------------------------------|
| <span style="font-family: Arial, sans-serif;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
| <span style="font-family: Arial, sans-serif;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
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# Indications for Use
510(k) Number (if known)
### K190650
Device Name Revolution Centrifugal Blood Pump with PC Coating
Indications for Use (Describe)
The Revolution Centrifugal Blood Pump with PC Coating is intended to be used with a LivaNova Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of us to six hours. Refer to the console operator's manual for console operating procedures.
The pump has not been qualified through in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
Type of Use (Select one or both, as applicable)
| <span style="font-family: Arial;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|-----------------------------------------------------------------------------------------|
| <span style="font-family: Arial;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
## *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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## 510(k) Summary
(in accordance with 21 CFR 807.92)
510(k) Number: K190650
#### l. Applicant Information
Applicant:
## SORIN GROUP ITALIA S.R.L. Via Statale 12 Nord, 86 Mirandola (MO) 41037 Italy
Contact Person:
Luigi Vecchi RA Director Tel: +39-346-391-0707 e-mail: luigi.vecchi@livanova.com
Application Correspondent:
Same as Applicant
Date Prepared: August 6, 2019
#### II. Devices Identification
Proprietary Name: Revolution Centrifuqal Blood Pump Common/Usual Name: Nonroller-type cardiopulmonary bypass blood pump Classification Name: Nonroller-type blood pump 21 CFR 870.4360 Regulation Number: Product Code: KFM Classification: Class II Classification Panel: Cardiovascular Proprietary Name: Revolution Centrifuqal Blood Pump with PC Coating
Common/Usual Name: Classification Name: Regulation Number: Product Code: Classification: Classification Panel:
Nonroller-type cardiopulmonary bypass blood pump Nonroller-type blood pump 21 CFR 870.4360 KFM Class II Cardiovascular
#### lll. Predicate Devices
The Revolution Centrifugal Blood Pump device is substantially equivalent to the following cleared predicate device. Both models have the same fundamental scientific technology and intended use:
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| 510(k) Number: | K011835 |
|-----------------------|--------------------------------------------------|
| Proprietary Name: | Revolution Centrifugal Blood Pump |
| Common/Usual Name: | Nonroller-type cardiopulmonary bypass blood pump |
| Classification Name: | Nonroller-type blood pump |
| Regulation Number: | 21 CFR 870.4360 |
| Product Code: | KFM |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
The Revolution Centrifuqal Blood Pump with PC Coating device is substantially equivalent to the following cleared predicate device. Both models have the same fundamental scientific technology and intended use:
| 510(k) Number: | K030462 |
|-----------------------|------------------------------------------------------|
| Proprietary Name: | Revolution Centrifugal Blood Pump with PC<br>Coating |
| Common/Usual Name: | Nonroller-type cardiopulmonary bypass blood pump |
| Classification Name: | Nonroller-type blood pump |
| Regulation Number: | 21 CFR 870.4360 |
| Product Code: | KFM |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
#### IV. Devices Description
## Revolution Centrifuqal Blood Pump
The Revolution Centrifyaal Blood Pump is an extracorporeal blood pump that utilizes a rotating vained impeller design to move blood by centrifygal force. The device is provided sterile with a non-pyrogenic fluid pathway, and is for single use only. It is indicated for use only with a LivaNova centrifugal pump console in cardiopulmonary bypass procedures for periods of up to six hours. The device has not been qualified for long term use (greater than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
The Revolution Pump consists of a rotating vained impeller within a pump housing. The pump housing has two components, a top and bottom case, and features a central, single -barbed, 3/8" inlet port and tangential, doublebarbed, 3/8" outlet port. The vained impeller is molded onto steel shaft that supports it at its axis of rotation, with the shaft rotating on a bearing at each end. The device contains a multi-pole magnet that is fully enclosed within the magnet housing and impeller, and thus does not contact the blood pathway. The magnet is designed to magnetically couple with the pump drive unit of the centrifugal pump console. Rotation of the magnet causes the impeller to rotate and pump blood via centrifugal force.
## Revolution Centrifuqal Blood Pump with PC Coating
The Revolution Centrifugal Blood Pump is an extracorporeal blood pump that utilizes a rotating vained impeller design to move blood by centrifugal force.
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The device is provided sterile with a non-pyrogenic fluid pathway, and is for single use only. It is indicated for use only with a LivaNova centrifugal pump console in cardiopulmonary bypass procedures for periods of up to six hours. The device has not been qualified for long term use (greater than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
The Revolution Pump consists of a rotating vained impeller within a pump housing. The pump housing has two components, a top and bottom case, and features a central, single-barbed, 3/8" inlet port and tangential, double-barbed, 3/8" outlet port. The vained impeller is molded onto steel shaft that supports it at its axis of rotation, with the shaft rotating on a bearing at each end. The device contains a multi-pole magnet that is fully enclosed within the magnet housing and impeller, and thus does not contact the blood pathway. The magnet is designed to magnetically couple with the pump drive unit of the centrifugal pump console. Rotation of the magnet causes the impeller to rotate and pump blood via centrifugal force.
Blood contact surfaces of the PC coated Revolution have been coated with phosphorylcholine to improve blood compatibility, resulting in reduced platelet adhesion on the coated surfaces.
#### V. Indications for Use
The Revolution Centrifugal Blood Pump is intended to be used with a LivaNova Centrifuqal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vitro, in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
The Revolution Centrifugal Blood Pump with PC Coating is intended for use only with a LivaNova Centrifuqal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO).
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#### VI. Summary of Technical Characteristics
## Revolution Centrifuqal Blood Pump
Nonroller-type cardiopulmonary bypass blood pumps are designed to deliver blood at certain flow and pressure by use of centrifugal forces.
The device contains a multi-pole magnet that is fully enclosed within the magnet housing and impeller, and thus does not contact the blood pathway. The magnet is designed to magnetically couple with the pump driver unit of LivaNova centrifugal pump consoles. Rotation of the magnet causes the impeller to rotate and pump blood via centrifugal force.
The blood flow from the Revolution Centrifugal Blood Pump responds to the resistance against which it is pumping and to the amount of fluid returned from the pump, with corresponding changes in flow and pressure. The flow is slowly accelerated from a point of relatively low tangential velocity to a maximum tangential velocity that occurs when the blood reaches the outer blade end. This unique design of the impeller vanes minimizes heat generation, hence hemolysis, while providing adequate blood flow and pressure.
These technical characteristics are identical to the predicate device, the Revolution Centrifugal Blood Pump.
## Revolution Centrifuqal Blood Pump with PC Coating
Nonroller-type cardiopulmonary bypass blood pumps are designed to deliver blood at certain flow and pressure by use of centrifugal forces.
The device contains a multi-pole magnet that is fully enclosed within the maqnet housing and impeller, and thus does not contact the blood pathway. The magnet is designed to magnetically couple with the pump driver unit of LivaNova centrifugal pump consoles. Rotation of the magnet causes the impeller to rotate and pump blood via centrifugal force.
The blood flow from the Revolution Centrifugal Blood Pump with PC coating responds to the resistance against which it is pumping and to the amount of fluid returned from the pump, with corresponding changes in flow and pressure. The flow is slowly accelerated from a point of relatively low tangential velocity to a maximum tangential velocity that occurs when the blood reaches the outer blade end. This unique design of the impeller vanes minimizes heat generation, hence hemolysis, while providing adequate blood flow and pressure.
These technical characteristics are identical to the predicate device, the Revolution Centrifugal Blood Pump with PC coating.
#### VII. Substantial Equivalence Discussion
The following tables compare the features of the Revolution Centrifyigal Blood Pump to its predicate the Revolution Centrifugal Blood Pump cleared under K011835 and the features of the Revolution Centrifugal Blood
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Pump with PC Coating to its predicate Revolution Centrifugal Blood Pump with PC Coating cleared under K030462, with respect to indications for use, environment of use, intended use, limitations of use, principles of operation and main performance characteristics.
Both subject devices have the same fundamental scientific technology and intended use as their respective predicate devices.
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| Device Name | Subject Device:<br>Revolution Centrifugal Blood Pump | Predicate Device:<br>(K011835)<br>Revolution Centrifugal Blood Pump | Significant Differences | | |
|-------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|---------------------------------------------------------------------------------------------------------------------|-------------------------|
| Product Code | KFM | KFM | | | |
| Regulation # | 870.4360 | 870.4360 | No difference. | | |
| Class | II | II | No difference. | | |
| Indications<br>for Use | The Revolution Centrifugal Blood Pump is<br>intended to be used with a LivaNova<br>Centrifugal Pump Console in<br>cardiopulmonary bypass procedures for<br>periods of up to six hours. Refer to the<br>console operator's manual for console<br>operating procedures. The pump has not<br>been qualified through in vitro, in vivo, or<br>clinical studies for long term use (i.e.,<br>longer than six hours) as a bridge to<br>transplant, for pending recovery of the<br>natural heart or extracorporeal membrane<br>oxygenation (ECMO). | The Revolution Centrifugal Blood Pump is<br>intended to be used with a Stockert<br>Instrumente Centrifugal Pump Console in<br>cardiopulmonary bypass procedures for<br>periods of up to six hours. The pump has<br>not been qualified through in vitro, in vivo,<br>or clinical studies for long term use (i.e.,<br>longer than six hours) as a bridge to<br>transplant, for pending recovery of the<br>natural heart or extracorporeal membrane<br>oxygenation (ECMO) procedures. | No difference. | | |
| Environment | Operating room. | Operating room. | No difference. | | |
| of Use<br>Limitations of<br>Use/Intended<br>Use | The pump can only be used with a<br>LivaNova Centrifugal Pump Console in<br>cardiopulmonary bypass procedures for<br>periods of up to six hours. The pump has<br>not been qualified through in vitro, in vivo, | The pump can only be used with a Stockert<br>Instrumente Centrifugal Pump Console in<br>cardiopulmonary bypass procedures for<br>periods of up to six hours. The pump has<br>not been qualified through in vitro, in vivo, | No difference. | | |
| | or clinical studies for long term use (i.e.,<br>longer than six hours) as a bridge to<br>transplant, for pending recovery of the<br>natural heart or extracorporeal membrane<br>oxygenation (ECMO) procedures. | or clinical studies for long term use (i.e.,<br>longer than six hours) as a bridge to<br>transplant, for pending recovery of the<br>natural heart or extracorporeal membrane<br>oxygenation (ECMO) procedures. | | | |
| | Principles of<br>Operation | The Pump utilizes a rotating, vained<br>impeller designed to move blood by<br>centrifugal force. | | The Pump utilizes a rotating, vained<br>impeller designed to move blood by<br>centrifugal force. | No difference. |
| | Main<br>Performance<br>Features | Nonroller-type cardiopulmonary bypass<br>blood pumps are designed to deliver blood<br>at certain flow and pressure. | | Nonroller-type cardiopulmonary bypass<br>blood pumps are designed to deliver blood<br>at certain flow and pressure. | No difference. |
| | Device Name | Subject Device:<br>Revolution Centrifugal Blood Pump with PC Coating | | Predicate Device: (K030462)<br>Revolution Centrifugal Blood Pump with PC Coating | Significant Differences |
| | Product Code | KFM | | KFM | No difference. |
| Regulation # | 870.4360 | 870.4360 | No difference. | | |
| Class | II | II | No difference. | | |
| Indications<br>for Use | The Revolution Centrifugal Blood Pump with PC Coating is intended for use only with a LivaNova Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vitro, in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO). | The Revolution Centrifugal Blood Pump with PC Coating is intended for use only with Stockert Instrumente Centrifugal Pump Consoles in cardiopulmonary bypass procedures for periods of up to six hours. Refer to the console operator's manual for console operating procedures. The pump has not been qualified through in vitro, in vivo, or clinical studies for long term use (i.e., longer than six hours) as a bridge to transplant, for pending recovery of the natural heart or extracorporeal membrane oxygenation (ECMO). | No difference. | | |
| Environment<br>of Use | Operating room. | Operating room. | No difference. | | |
| Limitations of<br>Use/Intended<br>Use | The pump can only be used with a LivaNova Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. The pump has | The pump can only be used with a Stockert Instrumente Centrifugal Pump Console in cardiopulmonary bypass procedures for periods of up to six hours. The pump has | No difference. | | |
| | not been qualified through in vitro, in vivo, | not been qualified through in vitro, in vivo, | | | |
| | or clinical studies for long term use (i.e., | or clinical studies for long term use (i.e., | | | |
| | longer than six hours) as a bridge to | longer than six hours) as a bridge to | | | |
| | transplant, for pending recovery of the | transplant, for pending recovery of the | | | |
| | natural heart or extracorporeal membrane | natural heart or extracorporeal membrane | | | |
| | oxygenation (ECMO) procedures. | oxygenation (ECMO) procedures. | | | |
| Principles of<br>Operation | The pump utilizes a rotating, vained<br>impeller designed to move blood by<br>centrifugal force. | The pump utilizes a rotating, vained<br>impeller designed to move blood by<br>centrifugal force. | No difference. | | |
| Main<br>Performance<br>Features | Nonroller-type cardiopulmonary bypass<br>blood pumps are designed to deliver blood<br>at certain flow and pressure. | Nonroller-type cardiopulmonary bypass<br>blood pumps are designed to deliver blood<br>at certain flow and pressure. | No difference. | | |
# Predicate Device Comparison Table for the Revolution Centrifugal Blood Pump
Special 510(k) – Centrifugal Blood Pumps
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# Predicate Device Comparison Table for the Revolution Centrifugal Blood Pump with PC Coating
Special 510(k) – Centrifugal Blood Pumps
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#### VIII. Non-Clinical Performance Data
SORIN GROUP ITALIA S.R.L. has conducted extensive verification and validation testing of the Revolution Centrifuqal Blood Pump and Revolution Centrifygal Blood Pump with PC Coating, as centrifygal blood pumps capable of delivering blood to the patient at certain reliable flow and pressure rate. The modified component of the Revolution Centrifugal Blood Pump and Revolution Centrifugal Blood Pump with PC Coating was tested to ensure that the systems as a whole can provide all the capabilities necessary to operate safely and effectively.
The Revolution Centrifuqal Blood Pump and Revolution Centrifyqal Blood Pump with PC Coating comply with all the applicable voluntary standards related to centrifugal blood pump systems. The devices passed all the testing in accordance with national and international standards.
#### IX. Clinical Performance Data
No clinical testing was conducted in support of the Revolution Centrifyugal Blood Pump and Revolution Centrifugal Blood Pump with PC Coating, as the indications for use are equivalent to those of their respective predicates. which have been on the market for many years with proven safety and efficacy of use. The non-clinical testing detailed in this submission supports the substantial equivalence of these devices with their respective predicates in relation to the change subject of this submission.
#### X. Statement of Substantial Equivalence
Based on identical intended use and technological characteristics, as well as on identical performance testing, the Revolution Centrifugal Blood Pump and Revolution Centrifuqal Blood Pump with PC Coating can be deemed to be substantially equivalent to their predicate devices, the Revolution Centrifuqal Blood Pump and Revolution Centrifuqal Blood Pump with PC Coating cleared under K011835 and K030462, respectively.
The Revolution Centrifugal Blood Pump and Revolution Centrifugal Blood Pump with PC Coating, as designed and manufactured, do not raise new questions regarding their safety and effectiveness as compared to their predicates devices and are determined to be substantially equivalent to the predicate devices.
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Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.