INSPIRE 7FM Hollow fiber oxygenator with integrated arterial filter, INSPIRE 7F Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir, INSPIRE 7F DUAL Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir
K200683 · Sorin Group Italia S.R.L. · DTZ · Jun 12, 2020 · Cardiovascular
Device Facts
Record ID
K200683
Device Name
INSPIRE 7FM Hollow fiber oxygenator with integrated arterial filter, INSPIRE 7F Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir, INSPIRE 7F DUAL Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir
Applicant
Sorin Group Italia S.R.L.
Product Code
DTZ · Cardiovascular
Decision Date
Jun 12, 2020
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.4350
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Inspire 7F M is intended for use in adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control. The integrated arterial filter provides additional protection against air and solid emboli. The Inspire 7F M is intended to be used for 6 hours or less. The Inspire 7F is intended for use in adult and small adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control. The integrated arterial filter provides additional protection against air and solid emboli. The Inspire 7F is intended to be used for 6 hours or less. The Inspire 7F Dual is intended for use in adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control. The integrated arterial filter provides additional protection against air and solid emboli. The Inspire 7F Dual is intended to be used for 6 hours or less.
Device Story
The INSPIRE 7F series are hollow fiber oxygenators with integrated heat exchangers and arterial filters; some models include a hardshell venous/cardiotomy reservoir. During cardiopulmonary bypass, venous blood enters the reservoir (if present) and flows through the oxygenator. The heat exchanger uses water flow inside polyurethane fibers to control blood temperature. The oxygenating module uses polypropylene microporous hollow fibers for gas exchange. The integrated 38 µm arterial filter provides protection against air and solid emboli. Used in clinical settings by perfusionists/surgeons to temporarily replace heart/lung function during surgery. Output is oxygenated, temperature-controlled blood returned to the patient. Benefits include stable physiological support and reduced embolic risk during cardiac procedures.
Clinical Evidence
No clinical data provided. Substantial equivalence is supported by non-clinical bench testing, including structural integrity, gas transfer performance, heat exchange efficiency, filtration efficiency, air handling capability, and blood compatibility (hemolysis) testing in accordance with ISO 7199 and relevant FDA guidance.
Technological Characteristics
Materials: Polyurethane (heat exchanger fibers), polypropylene (oxygenating fibers), polycarbonate (reservoir housing), polyester (38 µm filter screen). Principle: Gas exchange via microporous hollow fibers; heat exchange via water-to-blood conduction. Form factor: Integrated oxygenator, heat exchanger, and arterial filter; optional hardshell reservoir. Sterilization: Ethylene oxide. Single-use.
Indications for Use
Indicated for adult and small adult patients undergoing surgical procedures requiring cardiopulmonary bypass for gas exchange support, blood temperature control, and protection against air/solid emboli via integrated arterial filtration. Intended for use for 6 hours or less.
Regulatory Classification
Identification
A cardiopulmonary bypass oxygenator is a device used to exchange gases between blood and a gaseous environment to satisfy the gas exchange needs of a patient during open-heart surgery.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Guidance for Cardiopulmonary Bypass Oxygenators 510(k) Submissions.”
Predicate Devices
INSPIRE 8F Hollow Fiber Oxygenator with hardshell/venous cardiotomy reservoir (K130433)
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June 12, 2020
Sorin Group Italia S.R.L. Luigi Vecchi Director, Regulatory Affairs Via Statale 12 Nord, 86 Mirandola, Modena 41037 Italy
Re: K200683
Trade/Device Name: INSPIRE 7FM Hollow fiber oxygenator with integrated arterial filter, INSPIRE 7F Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir, INSPIRE 7F DUAL Hollow fiber oxygenator with integrated arterial filter and hardshell reservoir
Regulation Number: 21 CFR 870.4350 Regulation Name: Cardiopulmonary Bypass Oxygenator Regulatory Class: Class II Product Code: DTZ, DTM, DTR, DTN, DTP Dated: May 7, 2020 Received: May 8, 2020
Dear Luigi Vecchi:
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 (OS) 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 medical devices and radiation-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.
for 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) K200683
Device Name
INSPIRE 7F M Hollow Fiber Oxygenator with Integrated Arterial Filter
Indications for Use (Describe)
The Inspire 7F M is intended for use in adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control.
The integrated arterial filter provides additional protection against air and solid emboli. The Inspire 7F M is intended to be used for 6 hours or less.
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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## Indications for Use
510(k) Number (if known)
information unless it displays a currently valid OMBnumber."
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
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## Indications for Use
510(k) Number (if known) K200683
Device Name
INSPIRE 7F Hollow Fiber Oxygenator with Integrated Hardshell Venous/Cardiotomy Reservoir and Interial Filter
Indications for Use (Describe)
The Inspire 7F is intended for use in adult and small adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control.
The integrated arterial filter provides additional protection against air and solid emboli.
The Inspire 7F is intended to be used for 6 hours or less.
| 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)
### 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
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
{5}------------------------------------------------
## Indications for Use
510(k) Number (if known)
information unless it displays a currently valid OMBnumber."
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
{6}------------------------------------------------
## Indications for Use
510(k) Number (if known)
K200683
Device Name
INSPIRE 7F Dual Hollow Fiber Oxygenator with Integrated Hardshell Venous/Cardiotomy Reservoir and Integrated Arterial Filter
Indications for Use (Describe)
The Inspire 7F Dual is intended for use in adult surgical procedures requiring cardiopulmonary bypass. It provides gas exchange support and blood temperature control.
The integrated arterial filter provides additional protection against air and solid emboli. The Inspire 7F Dual is intended to be used for 6 hours or less.
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)
## 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
{7}------------------------------------------------
## Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
"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 OMBnumber."
{8}------------------------------------------------
## 510(k) Summary
(in accordance with 21 CFR 807.92)
510(k) Number: K200683
#### l. Applicant Information
| Applicant: | SORIN GROUP ITALIA S.R.L.<br>Via Statale 12 Nord, 86<br>Mirandola (MO) 41037 Italy |
|----------------------------|-------------------------------------------------------------------------------------------|
| Contact Person: | Luigi Vecchi<br>RA Director<br>Tel: +39-346-391-0707<br>e-mail: luigi.vecchi@livanova.com |
| Application Correspondent: | SORIN GROUP ITALIA S.R.L.<br>Via Statale 12 Nord, 86<br>Mirandola (MO) 41037 Italy |
| Contact Person: | Luigi Vecchi<br>RA Director<br>Tel: +39-346-391-0707<br>e-mail: luigi.vecchi@livanova.com |
INSPIRE 7F
Date Prepared: March 13, 2020
# Subject Devices Identification
Proprietary Name:
II.
Common/Usual Name: Classification Name: Requlation Number: Product Code: Classification: Classification Panel:
Proprietary Name:
Classification Name:
Regulation Number:
Classification Panel:
Proprietary Name:
Product Code:
Classification:
Cardiopulmonary Bypass Oxygenator 21 CFR 870.4350 DTZ, DTM, DTR, DTN, DTP Class II Cardiovascular INSPIRE 7F M Hollow Fiber Oxygenator INSPIRE 7F M Common/Usual Name:
INSPIRE 7F Hollow Fiber Oxygenator with hardshell/venous cardiotomy reservoir
Cardiopulmonary Bypass Oxygenator 21 CFR 870.4350 DTZ, DTM, DTR Class II Cardiovascular
INSPIRE 7F Dual Hollow Fiber Oxygenator with hardshell/venous cardiotomy reservoir
Special 510(k) – Hollow Fiber Oxygenators
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| Common/Usual Name: | INSPIRE 7F Dual |
|-----------------------|-----------------------------------|
| Classification Name: | Cardiopulmonary Bypass Oxygenator |
| Regulation Number: | 21 CFR 870.4350 |
| Product Code: | DTZ, DTM, DTR, DTN, DTP |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
#### lll. Predicate Devices
The INSPIRE 7F Hollow Fiber Oxygenator with hardshell/venous cardiotomy reservoir is substantially equivalent to the following cleared predicate device. Both models have the same fundamental scientific technology and intended use:
| 510(k) Number: | K130433 |
|-----------------------|----------------------------------------------------------------------------------|
| Proprietary Name: | INSPIRE 8F Hollow Fiber Oxygenator with<br>hardshell/venous cardiotomy reservoir |
| Common/Usual Name: | INSPIRE 8F |
| Classification Name: | Cardiopulmonary Bypass Oxygenator |
| Regulation Number: | 21 CFR 870.4350 |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
The INSPIRE 7F M Hollow Fiber Oxygenator device is substantially equivalent to the following cleared predicate device. Both models have the same fundamental scientific technology and intended use:
| 510(k) Number: | K180448 |
|-----------------------|--------------------------------------|
| Proprietary Name: | INSPIRE 8F M Hollow Fiber Oxygenator |
| Common/Usual Name: | INSPIRE 8F M |
| Classification Name: | Cardiopulmonary Bypass Oxygenator |
| Regulation Number: | 21 CFR 870.4350 |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
The INSPIRE 7F Dual Hollow Fiber Oxygenator with hardshell/venous cardiotomy reservoir device is substantially equivalent to the following cleared predicate device. Both models have the same fundamental scientific technology and intended use:
| 510(k) Number: | K122844 |
|-----------------------|----------------------------------------------|
| Proprietary Name: | INSPIRE 8F Dual Hollow Fiber Oxygenator with |
| | hardshell/venous cardiotomy reservoir |
| Common/Usual Name: | INSPIRE 8F Dual |
| Classification Name: | Cardiopulmonary Bypass Oxygenator |
| Regulation Number: | 21 CFR 870.4350 |
| Classification: | Class II |
| Classification Panel: | Cardiovascular |
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#### IV. Devices Description
### The INSPIRE 7F M, INSPIRE 7F and INSPIRE 7F Dual
oxygenators (hereinafter identified as INSPIRE 7F) are intended for use in adult and small adult surgical procedures requiring cardiopulmonary bypass (CPB). It provides gas exchange support and blood temperature control.
The INSPIRE 7F consist of the following main components:
- . a heat exchanger consisting of a bundle of polyurethane hollow fibers that are wound on a cylindrical core.
- an oxygenating module element made of a coiled bundle of . polypropylene microporous hollow fibers rolled on the heat exchanger sub assembly.
- Hardshell venous/cardiotomy reservoir to collect, filter, . and send venous blood and suction blood to the oxygenator (only models INSPIRE 7F/ 7F DUAL)
- Arterial filter: the integrated arterial filter surrounds the . oxygenating module and has been designed with a specific geometry that provides protection against air and solid emboli.
The heat exchanger consists of a bundle of polyurethane hollow fibers rolled on a cylindrical core. The heat transfer is obtained through the flow of water inside the fibers and the flow of blood outside them. The heat exchanger is inserted in the gas exchanger and surrounded by the oxygenating module element, which is constructed of a coiled bundle of polypropylene microporous hollow fibers rolled on the heat exchanger sub assembly. The blood path is around the outside of the fibers, while the gas path is through the lumen of the fibers. For the versions 7F/ 7F DUAL the oxygenator module is integrated with a hardshell/venous reservoir via a molded fitting joint.
The hardshell/venous reservoir is comprised of rigid polycarbonate housing. Venous and cardiotomy filtering systems are physically distinct to allow a good filtration efficiency of venous and
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suction blood (one filters venous blood, the other filters suction blood).
The reservoir is provided with a vent/vacuum port together with an over- underll valve, that prevents excess of negative or positive pressure avoiding implosion and over pressurization of the reservoir itself. The blood enters the reservoir through the cardiotomy section through the rotating turret equipped with 3/8ll, 1/4ll and female luer inlet connectors and through the venous inlet 1/2ll connector provided with female luer connector. Both cardiotomy turret and venous inlet connectors can rotate 360°. The reservoir lid also has additional unfiltered luer ports
The integrated arterial filter has a toroidal shape and a 38 um linear filter screen. It is molded to the shell of the oxygenator. It has been designed with a specific geometry that provides protection against air and solid emboli. The arterial filter has a twocompartment design, including pre- and post- filter chambers. Each one of the two compartments is provided with a dedicated purge site that enhances air purging. The pre-filter chamber removes air bubbles trapped by the filter screen. The post-filter collection chamber is located at the top of the filter and allows air bubble collection of the air dragged through the filter screen. In case of massive air embolism, the air bubbles can be removed through the purge sites located both in the pre- and post- filter collection chamber
The oxygenating module of all the INSPIRE oxygenators include a dedicated outlet with a one-way valve that provides access to arterial blood throughout the procedure for cardioplegia, perfusion or blood concentration. The outlet is placed close to the arterial outlet of the oxygenator and opposite to the temperature probe port. Arterial and venous temperature probe sites are also provided: the former is located close to the arterial blood outlet, while the latter is placed on the venous inlet of the reservoir. Figure 1 shows the oxygenating modules with the visible ports identified.
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Image /page/12/Figure/0 description: The image shows two diagrams, labeled A and B, of a device with various ports and connectors. Both diagrams depict the same device but from slightly different angles, highlighting different features. The device includes ports for gas inlet and outlet, water ports, and connectors for arterial sampling and temperature probes, among other components like the oxygenator interface/joint.
Figure 1: Oxygenating module integrated with heat exchanger and Arterial filter
The respective predicates devices Inspire 8F M, Inspire 8F and Inspire 8F Dual have the same main components of the three subject devices. CPB circuits mimic and temporarily replace the function of the heart and lungs while the heart is arrested to provide a bloodless and stable surgical field, while maintaining physiological support to the rest of the body in which venous blood is drained to a reservoir, oxygenated and sent back to the body through a pump.
The clinical need for the devices under evaluation is to provide a safe and well- functioning alternative to the patient circulation for the entire duration of a cardiopulmonary bypass procedure. The devices can be used to temporarily support pulmonary function of a patient immediately after a Cardiac surgery Operation within the maximum time allowed of 6 hours.
An overview of functional and performance characteristics of Inspire 7F is summarized in Table 1 below.
### Table 1. Inspire 7F Performance Characteristics
| CHARACTERISTICS | INSPIRE 7F |
|--------------------------------|------------|
| Maximum recommended blood flow | 7.0 l/min |
| Minimum recommended blood flow | 2.0 l/min |
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| Minimum blood flow | | 0.5 l/min |
|---------------------------------------------------------------|-----------------------------------------|-------------------------------------------------------|
| (up to 2 hours max. duration time) | | |
| Maximum suggested gas/blood flow ratio | | 2 :1 |
| Blood path pressure drop<br>(Hb 12 g/dl and temperature 37°C) | | @Qb=6 LPM<br>174 mmHg<br>(23.2 KPa /0.23 bar/3,4 psi) |
| Heat exchange performance factor | (at Qb = 6 I/min) | |
| (Qw = 11.5 = 0.2 l/min) | 0.59 | |
| Integrated Arterial filter: Filtration<br>Efficiency | | 100% |
| Maximum operating | Blood path | 750 mm Hg<br>(100 kPa/ 1 bar / 14.5 psi |
| pressure | Water path | 1500 mm Hg<br>(200 kPa/ 2 bar / 29 PSI |
| GAS MODULE + HEAT<br>EXCHANGER | Priming<br>volume<br>Residual<br>volume | 366 ml<br>169 ml |
| GAS EXCHANGE<br>MEMBRANE | Fiber<br>surface | 1.78 m² |
| HEAT EXCHANGE<br>MEMBRANE | Fiber<br>surface | 0.4 m² |
| INTEGRATED ARTERIAL<br>FILTER | Filtering<br>surface<br>Type | 0.0097<br>Polyester screen 38 um |
#### V. Indications for Use
The three subject devices (i.e., the INSPIRE 7F Hollow Fiber Oxygenator with integrated hard shell venous/cardiotomy reservoir, the INSPIRE 7F M Hollow Fiber Oxygenator and the INSPIRE 7F Dual Hollow Fiber Oxygenator with integrated hard shell venous/cardiotomy reservoir), - are intended for use in adult and small adult surgical procedures requiring cardiopulmonary bypass. They all provide gas exchange support and blood temperature control. The integrated arterial filter provides additional protection against air and solid emboli. All the devices
{14}------------------------------------------------
are intended to be used for 6 hours or less. Note: The intended use of the three subject devices is identical to the intended use of the three respective predicates devices
#### VI. Summary of Technical Characteristics
The INSPIRE 7F has the same principles of operation and control mechanisms as the INSPIRE 8F unmodified device. The INSPIRE 7F and the INSPIRE 8F unmodified device share the same fundamental technological characteristics except for some modifications that do not affect the basic device function. These differences are summarized below and do not raise any new issues of safety and effectiveness. The density of the hollow fiber in the oxygenating bundle has been decreased from 16.3 to 15.3
The diameter of the oxygenator bundle has been increased from 82.9 -85.6 mm to 85.1-86.4 mm. The diameter of the oxygenating body has been increased from 83.85 mm to 84.41 mm (max) No change to the intended use has been made as a result of these modifications.
No different materials were introduced / changed as a result of these modifications.
There are no differences in packaging type and material between INSPIRE 7F and INSPIRE 8F unmodified device. Both modified and unmodified device are for single use only, ethylene oxide sterilized and has a non-pyrogenic fluid path.
#### VII. Substantial Equivalence Discussion
Based on equivalent intended use and technological characteristics, as well as on equivalent performance testing, the INSPIRE 7F can be deemed to be substantially equivalent to its predicate device, the Unmodified INSPIRE 8F The INSPIRE 7F as designed and manufactured, does not raise new questions regarding safety and effectiveness as compared to its predicate device and is determined to be substantially equivalent to its predicate device, the Unmodified INSPIRE 8F.
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#### Non-Clinical Performance Data VIII.
The subject devices were tested to ensure that they can provide all the capabilities necessary to operate safely and effectively. Applicable tests were carried out in accordance with the requirements of ISO 10993-1, the FDA May 1st, 1995 Memorandum on the use of the ISO 10993 standard for biocompatibility testing of materials, and the relevant requirements of "Guidance for Cardiopulmonary Bypass Oxygenators 510(k) Submissions: Final Guidance for Industry and FDA Staff" issued on November 13, 2000, "Guidance for Cardiopulmonary Bypass Arterial Line Blood Filter 510(k) Submissions; Final Guidance for Industry and FDA" issued on November 29, 2000; and ISO 7199 "Cardiovascular implants and artificial organs - Blood-gas exchangers (oxygenators)".
In vitro testing was carried out to demonstrate both the substantial equivalence with the predicate device and also to comply with safety and effectiveness requirements.
Testing includes performance tests and physical/mechanical integrity tests that demonstrate compliance with performance specifications.
The INSPIRE 7F met all acceptance criteria for each of the tests listed in the table below.
| TEST | TEST<br>CLASSIFICATION | TEST TITLE |
|------|------------------------|--------------------------------------------------------------------------|
| 1 | Physical/Mechanical | Oxygenating module structural integrity |
| 2 | Physical/Mechanical | Oxygenating module blood, water, gas<br>pathway integrity |
| 3 | Functional/Performance | Oxygenating module blood volume<br>capacity |
| 4 | Functional/Performance | Oxygenating module heat exchange<br>performance/water side pressure drop |
| 5 | Functional/Performance | Oxygenating module gas transfer<br>performance/blood side pressure drop |
| 6 | Functional/Performance | Oxygenating module air handling<br>capability |
| 7 | Functional/Performance | Oxygenating module filtration efficiency |
| 8 | Functional/Performance | Oxygenating module blood trauma<br>(hemolysis and blood compatibility) |
| 9 | Functional/Performance | Oxygenating module leaching of coating |
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| 10 | Functional/Performance | Integrated device flaking of coating |
|----|------------------------|---------------------------------------------|
| 11 | Functional/Performance | Oxygenating module uniformity of<br>coating |
| 12 | Functional/Performance | Flow rate capacity |
The results of in vitro studies demonstrate that the INSPIRE 7F performs in a manner substantially equivalent to the INSPIRE 8F predicate device with respect to the relevant functional parameters.
#### IX. Clinical Performance Data
No clinical testing was conducted in support of the INSPIRE 7F Hollow Fiber Oxygenator with integrated hardshell venous/cardiotomy reservoir r, the INSPIRE 7F M Hollow Fiber Oxygenator and the INSPIRE 7F Dual Hollow Fiber Oxygenator with integrated hardshell venous/cardiotomy reservoir, as the indications for use are equivalent to those of their respective predicates, which have been on the market for many years. The non-clinical testing summarized in this submission supports the substantial equivalence of these devices with their respective predicates in relation to the changes subject of this submission.
#### Statement of Substantial Equivalence X.
As designed and manufactured and based on the intended use, technological characteristics, and performance testing, the INSPIRE 7F Hollow Fiber Oxygenator with integrated hardshell venous/cardiotomy reservoir, the INSPIRE 7F M Hollow Fiber Oxygenator and the INSPIRE 7F Dual Hollow Fiber Oxygenator with integrated hardshell venous/cardiotomy reservoir 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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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.