K190900 · Siemens Medical Solutions USA, Inc. · KPS · May 6, 2019 · Radiology
Device Facts
Record ID
K190900
Device Name
Biograph Vision
Applicant
Siemens Medical Solutions USA, Inc.
Product Code
KPS · Radiology
Decision Date
May 6, 2019
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.1200
Device Class
Class 2
Indications for Use
The Biograph Vision PET/CT systems are radiological imaging systems that are a combination of a positron emission tomography (PET) camera system for nuclear medicine images, and a computed tomography (CT) camera system for x-ray images. The nuclear medicine images and the x-ray images may be registered and displayed in a fused format (overlaid in the same orientation) for the anatomical localization of the nuclear medicine data (i.e., distribution of radiopharmaceuticals). The PET and CT portions of the system may be used independently or in combination. The PET and CT images may be transferred to other systems for radiation therapy planning or additional processing.
Device Story
Combined PET/CT scanner; utilizes X-ray transmission data for CT and radiopharmaceutical distribution for PET. PET subsystem uses CT for attenuation correction and anatomical reference. System provides registered/fused images for clinical evaluation. Used in clinical settings by trained professionals (physicians, technologists) for oncology, neurology, and cardiology. Output includes cross-sectional images for diagnosis, staging, and radiotherapy planning. New models (450/450 Edge) feature reduced axial PET field of view (200mm vs 263mm). Software manages patient data, scan control, image reconstruction, and archival. QualityGuard feature enables phantom-free daily calibration; Bad Block Correction compensates for detector issues. System supports independent CT or PET imaging.
Clinical Evidence
Bench testing only. Performance evaluated per NEMA NU2:2018 standards. Metrics included transverse/axial resolution, sensitivity, count rate (NECR/trues), scatter fraction, mean bias, co-registration accuracy, time-of-flight resolution, and image quality (contrast/variability). All results met predetermined acceptance criteria.
Technological Characteristics
Combined PET/CT system. PET: SiPM detectors with Lutetium Oxyorthosilicate (LSO) crystals. CT: SOMATOM Definition AS/AS+/Edge. Connectivity: DICOM compliant. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-44, NEMA XR 25/28/29, NEMA PS3.1-3.20. Software developed per IEC 62304. Risk management per ISO 14971.
Indications for Use
Indicated for use by trained healthcare professionals to aid in detecting, localizing, diagnosing, staging, and restaging of lesions, tumors, disease, and organ function for evaluation of diseases/disorders including cardiovascular disease, neurological disorders, and cancer. Includes low-dose lung cancer screening in high-risk populations.
Regulatory Classification
Identification
An emission computed tomography system is a device intended to detect the location and distribution of gamma ray- and positron-emitting radionuclides in the body and produce cross-sectional images through computer reconstruction of the data. This generic type of device may include signal analysis and display equipment, patient and equipment supports, radionuclide anatomical markers, component parts, and accessories.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Siemens Medical Solutions USA, Inc. % Alaine Medio PET Regulatory Projects Manager 810 Innovation Drive KNOXVILLE TN 37932
May 6, 2019
Re: K190900
Trade/Device Name: Biograph Vision PET/CT Regulation Number: 21 CFR 892.1200 Regulation Name: Emission computed tomography system Regulatory Class: Class II Product Code: KPS, JAK Dated: April 5, 2019 Received: April 8, 2019
Dear Alaine Medio:
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
{1}------------------------------------------------
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,
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
## Indications for Use
510(k) Number (if known)
K190900
Device Name Biograph Vision PET/CT
#### Indications for Use (Describe)
The Siemens Biograph Vision PET/CT systems are combined X-Ray Computed Tomography (CT) and Position Emission Tomography (PET) scanners that provide registration and fusion of high resolution physiologic and anatomic information.
The CT component produces cross-sectional images of the body by computer reconstruction of X-Ray wansmission data from either the same axial plane taken at different angles or spiral planes taken at different angles. The PET subsystem images and measures the distribution of PET radiopharmaceuticals in humans for the purpose of determining various metabolic (molecular) and physiologic functions within the human body and utilizes the CT for fast attenuation correction maps for PET studies and precise anatomical reference for the fused PET and CT images.
The system maintains independent functionality of the CT and PET devices, allowing for single modality CT and / or PET diagnostic imaging.
These systems are intended to be utilized by approxiately trained health care professionals to aid in detecting. diagnosing, staging and restaging of lesions, tumors, disease and organ function for the evaluation of diseases and disorders such as, but not limited to, cardiovascular disease, neurological disorders and cancer. The images produced by the system can also be used by the physician to aid in radiotherapy treatment planning and interventional radiology procedures.
This CT system can be used for low dose lung cancer screening in high risk populations * * As defined by professional medical societies. Please refer to clinical literature, including the results of the National Lune Screening Trial (N Engl J Med 2011; 365:395-409) and subsequent literature, for further information.
| Type of Use (Select one or both, as applicable) | <table style="border:none"><tr><td><span> <b> <span style="font-size: 16px">☒</span> </b> Prescription Use (Part 21 CFR 801 Subpart D) </span></td><td><span> <b> <span style="font-size: 16px">☐</span> </b> Over-The-Counter Use (21 CFR 801 Subpart C) </span></td></tr></table> | <span> <b> <span style="font-size: 16px">☒</span> </b> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <b> <span style="font-size: 16px">☐</span> </b> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
|-------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------|
| <span> <b> <span style="font-size: 16px">☒</span> </b> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <b> <span style="font-size: 16px">☐</span> </b> Over-The-Counter Use (21 CFR 801 Subpart C) </span> | | |
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](mailto: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."*
{3}------------------------------------------------
# 510(k) Summary
as required by 21 CFR Part 807.87(h)
| Identification of the Submitter | |
|---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter: | Alaine Medio<br>Regulatory Affairs<br>Siemens Medical Solutions USA, Inc.<br>Molecular Imaging<br>810 Innovation Drive<br>Knoxville, TN 37932 |
| Alternative Contact: | Tabitha Estes<br>Regulatory Affairs |
| Manufacturer: | Siemens Medical Solutions USA, Inc.<br>Molecular Imaging<br>2501 North Barrington Road<br>Hoffman Estates, IL 60192 |
| Telephone Number: | (865)206-0337 |
| Fax Number: | (865)218-3019 |
| Date of Submission: | April 5, 2019 |
| Identification of the product | |
| Device Proprietary Name: | Biograph Vision PET/CT |
| Common Name: | Positron Emission Tomography (PET) System<br>Computed Tomography (CT) System |
| Classification Name: | Emission Computed Tomography System per 21 CFR<br>892.1200<br>Computed Tomography X-Ray System per 21 CFR 892.1750 |
| Product Code: | 90 KPS and 90 JAK |
| Classification Panel: | Radiology |
| Device Class: | Class II |
{4}------------------------------------------------
#### Marketed Devices to which Equivalence is claimed
#### Predicate:
| Device Proprietary Name: | Biograph Vision PET/CT |
|--------------------------|------------------------------------|
| Manufacturer: | Siemens Medical Solutions USA, Inc |
| Product Code: | 90 KPS and 90 JAK |
| Device Class: | Class II |
| 510(k) Number: | K180811 |
| Reference Devices: | |
| Device Name: | Biograph mCT |
| 510(k) Number: | K173578 |
#### Device Description:
The Biograph Vision systems are combined multi-slice X-Ray Computed Tomography (CT) and Positron Emission Tomography (PET) scanners. These systems are designed for whole body oncology, neurology and cardiology examinations.
The Biograph Vision systems provide registration and fusion of high-resolution metabolic and anatomic information from the two major components of each system (PET and CT). Additional components of the system include a patient handling system and acquisition and processing workstations with associated software.
Biograph Vision software is a command based program used for patient management, data management, scan control, image reconstruction and image archival and evaluation. All images conform to DICOM imaging format requirements.
The Biograph Vision PET/CT, which is the subject of this application, is substantially equivalent to the commercially available Biograph Vision PET/CT (K180811). The key differences between the current Biograph Vision (predicate device) and the Biograph Vision PET/CT that is the subject of this application is the addition of two new models (Biograph Vision 450 and Biograph Vision 450 Edge) with a smaller axial PET Field of View, as well as additional software modifications to daily / weekly Quality Control that is applicable to all models of the Biograph Vision.
{5}------------------------------------------------
## Intended Use:
The Biograph Vision PET/CT systems are radiological imaging systems that are a combination of a positron emission tomography (PET) camera system for nuclear medicine images, and a computed tomography (CT) camera system for x-ray images. The nuclear medicine images and the x-ray images may be registered and displayed in a fused format (overlaid in the same orientation) for the anatomical localization of the nuclear medicine data (i.e., distribution of radiopharmaceuticals). The PET and CT portions of the system may be used independently or in combination. The PET and CT images may be transferred to other systems for radiation therapy planning or additional processing.
## Indications for Use
The Siemens Biograph Vision PET/CT systems are combined X-Ray Computed Tomography (CT) and Positron Emission Tomography (PET) scanners that provide registration and fusion of high resolution physiologic and anatomic information.
The CT component produces cross-sectional images of the body by computer reconstruction of X-Ray transmission data from either the same axial plane taken at different angles or spiral planes taken at different angles. The PET subsystem images and measures the distribution of PET radiopharmaceuticals in humans for the purpose of determining various metabolic (molecular) and physiologic functions within the human body and utilizes the CT for fast attenuation correction maps for PET studies and precise anatomical reference for the fused PET and CT images.
The system maintains independent functionality of the CT and PET devices, allowing for single modality CT and / or PET diagnostic imaging.
These systems are intended to be utilized by appropriately trained health care professionals to aid in detecting, localizing, diagnosing, staging of lesions, tumors, disease and organ function for the evaluation of diseases and disorders such as, but not limited to, cardiovascular disease, neurological disorders and cancer. The images produced by the system can also be used by the physician to aid in radiotherapy treatment planning and interventional radiology procedures.
This CT system can be used for low dose lung cancer screening in high risk populations.*
*As defined by professional medical societies. Please refer to clinical literature, including the results of the National Lung Screening Trial (N Engl J Med 2011; 365:395-409) and subsequent literature, for further information.
{6}------------------------------------------------
## Summary of the Technological Characteristics of the Biograph Vision compared to the predicate device:
The Biograph Vision PET/CT, which is the subject of this application, is substantially equivalent to the commercially available Biograph Vision PET/CT (K180811). The key differences between the current Biograph Vision (predicate device) and the Biograph Vision PET/CT that is the subject of this application is the addition of two new models (Biograph Vision 450 and Biograph Vision 450 Edge) with a smaller axial PET Field of View:
| Feature | Biograph Vision 450<br>/ 450 Edge | Biograph Vision<br>600 / 600 Edge<br>(K180811) | Comparison to Predicate<br>Device - K180811 |
|---------------------------------|------------------------------------------------------------------|------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| General Specifications | | | |
| Height | 203.6 cm (80.2 in) | 203.6 cm (80.2 in) | No Change |
| Width | 234.4 cm (92.3in) | 234.4 cm (92.3in) | No Change |
| Depth | 136 cm (53.6 in) | 136 cm (53.6 in) | No Change |
| Weight | 3734 kg (8231 lbs) | 3759kg (8287 lbs) | Reduction of detectors for new<br>models. |
| Patient Port Diameter | 78 cm (30.7 in) | 78 cm (30.7 in) | No Change |
| Power Requirements | 380-480V~, 50/60Hz,<br>10 kVA Continuous,<br>150kVA Intermittent | 380-480V~, 50/60Hz,<br>10 kVA Continuous,<br>150kVA Intermittent | No Change |
| PET System | | | |
| Detectors | SiPM with Lutetium<br>Oxyorthosilicate (LSO)<br>crystals | SiPM with Lutetium<br>Oxyorthosilicate<br>(LSO) crystals | No Change |
| PET Axial FOV | 200 mm | 263 mm | Reduction of detectors for new<br>models with smaller PET Axial<br>Field of View. |
| Performance<br>Specifications | Tested in Accordance<br>with NEMA NU2 2018 | Tested in Accordance<br>with NEMA NU2 2018 | See below for PET Performance<br>specifications. Changes in<br>Count Rate peak NECR, Count<br>Rate peak Trues and Sensitivity<br>due to difference in Axial Field<br>of View for new models. |
| CT System | | | |
| CT subcomponent<br>incorporated | SOMATOM Definition<br>AS / AS+ and<br>SOMATOM Definition<br>Edge | SOMATOM Definition<br>AS / AS+ and<br>SOMATOM Definition<br>Edge | No Change |
Additional changes include updates to the quality control software to implement:
- . QualityGuard (a feature previously cleared with the Biograph mCT K173578) that provides for phantom-free daily calibration activities; and
- . Bad Block Correction, where the system compensates for bad blocks in the reconstructed image without affecting image quality.
{7}------------------------------------------------
Both features are provided for all models of Biograph Vision, and are designed to improve quality control workflow while minimizing system downtime.
#### Performance Testing / Safety and Effectiveness:
PET Testing in accordance with NEMA NU2:2018 was conducted on the various Biograph Vision models.
| Performance Criteria | Biograph Vision 450 / 450 Edge | | Biograph Vision 600 / 650 Edge | | |
|----------------------------------------------------------------|--------------------------------|-------------------------|--------------------------------|--------------------------|--|
| Resolution - Full Size | Results | Acceptance | Results | Acceptance | |
| Transverse Resolution<br>FWHM @ 1 cm | Pass | ≤ 4.0 mm | Pass | ≤ 4.0 mm | |
| Transverse Resolution<br>FWHM @ 10 cm | Pass | ≤ 4.8 mm | Pass | ≤ 4.8 mm | |
| Transverse Resolution<br>FWHM @ 20 cm | Pass | ≤ 5.2 mm | Pass | ≤ 5.2 mm | |
| Axial Resolution<br>FWHM @ 1 cm | Pass | ≤ 4.3 mm | Pass | ≤ 4.3 mm | |
| Axial Resolution<br>FWHM @ 10 cm | Pass | ≤ 5.4 mm | Pass | ≤ 5.4 mm | |
| Axial Resolution<br>FWHM @ 20 cm | Pass | ≤ 5.4 mm | Pass | ≤ 5.4 mm | |
| Count Rate / Scatter / Sensitivity / etc. | | | | | |
| Sensitivity @435 keV<br>LLD | Pass | ≥ 8.0 cps/kBq | Pass | ≥ 15.0 cps/kBq | |
| Count Rate peak NECR | Pass | ≥140 kcps @ ≤ 32 kBq/cc | Pass | ≥250 kcps @ ≤ 32 kBq/cc | |
| Count Rate peak trues | Pass | ≥600 kcps @ ≤ 56 kBq/cc | Pass | ≥1100 kcps @ ≤ 56 kBq/cc | |
| Scatter Fraction at<br>peak NECR | Pass | ≤43% | Pass | ≤43% | |
| Mean bias (%) at peak<br>NEC | Pass | ≤ 6% | Pass | ≤ 6% | |
| Co-Registration<br>Accuracy | Pass | ≤ 5 mm | Pass | ≤ 5 mm | |
| Time of Flight<br>Resolution at peak NEC | Pass | ≤249 ps | Pass | ≤249 ps | |
| Image Quality (4 to 1) - (% Contrast / Background Variability) | | | | | |
| 10mm sphere | Pass | ≥ 55% / ≤ 10% | Pass | ≥ 55% / ≤ 10% | |
| 13mm sphere | Pass | ≥ 60% / ≤ 9% | Pass | ≥ 60% / ≤ 9% | |
| 17mm sphere | Pass | ≥ 65% / ≤ 8% | Pass | ≥ 65% / ≤ 8% | |
| 22mm sphere | Pass | ≥ 70% / ≤ 7% | Pass | ≥ 70% / ≤ 7% | |
| 28mm sphere | Pass | ≥ 75% / ≤ 6% | Pass | ≥ 75% / ≤ 6% | |
| 37mm sphere | Pass | > 80% /<5% | Pass | > 80% /<5% | |
Performance testing for the CT subsystem was included in the original premarket notification for the CT subsystems and there have been no changes affecting this testing.
{8}------------------------------------------------
Risk Management is ensured via a risk analysis in compliance with ISO 14971 to identify and provide mitigation to potential hazards beginning early in the design cycle and continuing throughout the development of the product. Siemens Medical Solutions, USA Inc. adheres to recognized and established industry standards such as IEC 60601-1 series and 21 CFR 1020.30 and 21 CFR 1020.33 to minimize electrical, mechanical and radiation hazards.
Siemens claims compliance with the following product standards for the Biograph Vision:
- IEC 60601-1: 2005+ A1:2012
- IEC 60601-1-2: 2014
- IEC 60601-1-3: 2013
- IEC 60601-1-6:2010 +A1:2013
- IEC 60601-2-28:2010 ●
- IEC 60601-2-44: 2009 + A1:2012 + A2:2016
- IEC 62366-1:2015
- IEC 61223-2-6:2006
- IEC 61223-3-5:2004
- NEMA XR 25: 2010
- NEMA XR 28: 2013
- NEMA XR 29: 2013
- NEMA PS3.1-3.20
Additionally, the Biograph Vision has been developed in accordance with the requirements of the following standards:
- IEC 62304:2006 +A1:2015
- ISO 14971:2012 (ISO 14971:2007)
The device labeling contains instructions for use and any necessary cautions and warnings to provide for safe and effective use of the device.
Cybersecurity information in accordance with FDA Guidance documents issued October 2, 2014 has been provided. The Biograph Vision software has specific cybersecurity controls to prevent unauthorized access, modifications, misuse or denial of use. Additionally, controls are enabled to prevent the unauthorized use of information that is stored, accessed or transferred between the Biograph Vision and external devices.
Verification and validation of Siemens systems is performed in accordance with documented procedures, design and code reviews, test plans and specifications. Traceability of the requirements specified in the requirement specifications and functional specifications is ensured during component integration, software validation and system testing.
{9}------------------------------------------------
All Performance testing met the predetermined acceptance values. This, coupled with the successful verification and validation testing demonstrates that the Biograph Vision functions as intended and that performance is comparable to the predicate devices.
#### Statement regarding Substantial Equivalence:
There have been no changes implemented in the Biograph Vision that impact either the fundamental scientific technology or the indications for use. The Biograph Vision described in this Premarket Notification is substantially equivalent to the currently commercially available Biograph Vision predicate device.
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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.