The DOUBLEFLO system represents an arthroscopy system using fluid from saline bags (0.9% NaCl). This arthroscopy system is intended to provide fluid distension and irrigation of the knee, shoulder, hip, elbow, ankle and wrist joint cavities, and fluid suction during arthroscopy procedures.
Device Story
Microprocessor-controlled peristaltic pump; transports sterile irrigation fluid to joint cavities; provides fluid aspiration. Used in arthroscopy procedures; operated by clinical staff. Connects to saline bags and various shaver systems via cable interfaces. System regulates pressure and flow; maintains constant pressure during flow rate changes. Provides fluid management to distend joints, improving visualization for surgeons. Benefits include controlled irrigation and suction, facilitating arthroscopic surgery.
Clinical Evidence
No clinical data. Bench testing only. Performance validated via functional, usability, electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), biocompatibility (ISO 10993), and sterilization (ISO 11135) testing.
Technological Characteristics
Microprocessor-controlled peristaltic roller pump. Materials: polymer tubing sets. Connectivity: cable interfaces for shaver systems. Sterilization: Ethylene Oxide (EO) per ISO 11135. Software: moderate level of concern. Standards: IEC 60601-1, IEC 60601-1-2, ISO 10993, ISO 11135, ISO 11607-1, ASTM F-1980.
Indications for Use
Indicated for fluid distension, irrigation, and suction of knee, shoulder, hip, elbow, ankle, and wrist joint cavities during arthroscopy procedures using 0.9% NaCl saline.
Regulatory Classification
Identification
An arthroscope is an electrically powered endoscope intended to make visible the interior of a joint. The arthroscope and accessories also is intended to perform surgery within a joint.
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April 5, 2021
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Hemodia SAS % Arne Briest Managing Director VISAMED GmbH Kastellstr. 8 Karlsruhe76227 Germany
Re: K203480/S001
Trade/Device Name: DOUBLEFLO system Regulation Number: 21 CFR 888.1100 Regulation Name: Arthroscope Regulatory Class: Class II Product Code: HRX Dated: March 5, 2021 Received: March 8, 2021
Dear Mr. Briest:
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/cdrl/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
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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 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.
# Laura C. Rose -S
Laura C. Rose, Ph.D. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
510(k) Number (if known) K203480
Device Name DOUBLEFLO system
### Indications for Use (Describe)
The DOUBLEFLO system represents an arthroscopy system using fluid from saline bags (0.9% NaCl). This arthroscopy system is intended to provide fluid distension and irrigation of the knee, shoulder, hip, elbow, ankle and wrist joint cavities, and fluid suction during arthroscopy procedures.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Hemodia Medical Partner. The logo features a green leaf-like shape with the letter 'H' inside it on the left side. To the right of the leaf shape, the word 'hemodia' is written in a sans-serif font, with the words 'Medical Partner' written in a smaller font size below it.
# 510(k) Summary
This 510(k) summary is submitted in accordance with the requirements of 21 C.F.R. Part §807.92 upon which substantial equivalence is based.
#### SUBMISSION SPONSOR and APPLICATION CORRESPONDANT -
# A. SUBMISSION SPONSOR
### HEMODIA SAS
85 rue du Chêne vert 31670 Labège - France www.hemodia.com Tel +33 (0) 5 61 00 03 50
# Contact Person :
Adeline Théron Regulatory Affairs Engineer adeline.theron@hemodia.com
# B. APPLICATION CORRESPONDANT
### VISAMED GmbH
Kastellstr. 8 D-76227 Karlsruhe-Germany www.visamed.com Tel +49 (0) 721 476 4847
# Contact Person :
Arne Briest CEO arne.briest@visamed.com
II. Dated prepared: April 5, 2021
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# III DEVICE IDENTIFICATION
| Name of Device: | DOUBLEFLO system |
|-----------------------|---------------------------------|
| Common Name: | Pump (Arthroscopy pump) |
| Classification Name: | Arthroscope (21 CFR § 888.1100) |
| Classification Panel: | Orthopedic |
| Regulatory Class: | II |
| Product Code: | HRX |
| 510k #: | K203480 |
- IV PREDICATE DEVICE
K192921 - ZEOS Aqua Vision Pump and tubing sets
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# V. DEVICE DESCRIPTION
The DOUBLEFLO system (pump) contains as a main component a microprocessor-controlled pump that functions according to the peristaltic principle. It transports sterile irrigation fluid to distend cavities and provides fluid aspiration for arthroscopic procedures. The pump connects via cable to various interfaces.
The pump can be connected to various shaver systems.
The pump has to be used with the following tube sets:
| | Tubing Sets | |
|------------------|-------------------|-------------|
| Product Category | Model Designation | Part Number |
| Tubing Set | DAY TUBE Set | 72205353 |
| Tubing Set | Patient Tube Set | 72205354 |
| Tubing Set | Inflow Tube Set | 72205355 |
| Tubing Set | Outflow Tube Set | 72205356 |
# VI INDICATIONS FOR USE
The DOUBLEFLO system represents an arthroscopy system using fluid from saline bags (0.9%NaCl). This arthroscopy system is intended to provide fluid distension and irrigation of the knee, shoulder, hip, elbow, ankle and wrist joint cavities, and fluid suction during arthroscopy procedures.
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Image /page/6/Picture/0 description: The image shows the logo for Hemodia Medical Partner. The logo features a stylized green leaf shape with a white "H" inside it. To the right of the leaf is the word "hemodia" in a sans-serif font, and below that are the words "Medical Partner" in a smaller font size.
# VII COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The ZEOS Aqua Vision Pump is the predicate device for the DOUBLEFLO system (pump, tubing sets and accessories).
Both pump systems are designed, developed and manufactured using the same general design principles and similar mechanical and electrical components. They have the same intended use and incorporate the same basic design. Specifically, both the ZEOS Aqua Vision Pump and tubing sets and the DOUBLEFLO system are for use during arthroscopic procedures to provide fluid irrigation and aspiration. They are both roller pumps that function according to the peristaltic principle and are to be used with specially designed tube sets.
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| Device | Predicate Devices | Subject Device | Description and Indication for Use | Technical Characteristics | Comparison Analysis |
|---------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------|----------------------------------------------------|------------------------------------------------------------------------------------|
| | ZEOS Aqua Vision Pump<br>(K192921) | DOUBLEFLO system<br>(K203480) | | | |
| Illustration | Image: ZEOS Aqua Vision Pump | Image: DOUBLEFLO system | | | |
| General Device<br>Description | Dual Pump Arthroscopic System, the<br>irrigation/aspiration system has a common<br>control system with two separate pumps, one<br>pump dedicated to irrigation and one pump<br>dedicated to aspiration. | Dual Pump Arthroscopic System, the<br>irrigation/aspiration system has a common<br>control system with two separate pumps, one<br>pump dedicated to irrigation and one pump<br>dedicated to aspiration. | | | Similar overall set up and<br>user interface, identical<br>principle of operations |
| Principle of<br>operation | | | | Microprocessor controlled | Identical |
| | | | | Roller Pump and automatic fluid management | |
| Irrigation and<br>suction in one<br>unit:<br>Independent<br>inflow/outflow<br>control | | | | Yes, two separate irrigation / aspiration<br>pumps | Identical |
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Image /page/8/Picture/0 description: The image shows the logo for Hemodia Medical Partner. The logo features the letter 'H' in a stylized, green gradient design, with the word "hemodia" written vertically above it in a sans-serif font. Below "hemodia", the words "Medical Partner" are written in a smaller, lighter font.
| | Predicate Devices | Subject Device | Comparison Analysis |
|------------------------------------------------|-------------------|----------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulates<br>pressure and<br>flow | yes | yes | Substantially<br>equivalent, the only<br>difference is that the<br>subject device maintains<br>the pressure constant<br>when the flow rate is<br>changed. |
| Maximum<br>allowable<br>pressure | 280 mmHg | 150 mmHg | The maximum preset<br>pressure allowable by the<br>DOUBLEFLO system<br>software is lower than that<br>of the ZEOS AQUA<br>VISION pump.<br>Substantially<br>equivalent. |
| Minimum<br>allowable<br>pressure | 20 mmHg | 5 mmHg | |
| Default pressure<br>at<br>start of the<br>pump | 60 mmHg | 50 mmHg | Substantially<br>equivalent.<br>The default pressures<br>defined by the<br>DOUBLEFLO system<br>software is lower than<br>that of the ZEOS<br>AQUA VISION<br>pump |
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| | Predicate Devices | | | Subject Device | | Comparison Analysis | | | | | | | |
|----------------------------------------------------|-------------------|-----------------------------------|-----------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|-------------------|---------------------|-----------------------------------|-----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|-------------------|------------|-------------|--------------------------------------------------------------------------------------------------------|
| Recommended<br>Initial<br>pressure setting | Joint | Pressure level<br>with tourniquet | Pressure level<br>without<br>tourniquet | FLUSH RATE | Shaver<br>suction | Joint | Pressure level with<br>tourniquet | Pressure level<br>without<br>tourniquet | RINSE SUCTION | SHAVER<br>SUCTION | | | |
| | | mmHg | LH2O | mmHg | LH2O | | mmHg | mmHg | | | | | |
| | Shoulder joint | / | / | 60 | 30 | Low or Med | Low or Med | Shoulder joint | / | 60 | Low or Med | Low or Med | Identical |
| | Acromioplasty | / | / | 60 | 30 | Low or Med | Med or High | Acromioplasty | / | 60 | Low or Med | Med or High | |
| | Knee scope | 30 | 10 | 65 | 30 | Low or Med | Low or Med | Knee scope | 30 | 65 | Low or Med | Low or Med | Substantially equivalent |
| | Wrist | 50-60 | 20-30 | 50-60 | 20-30 | Low or Med | Med or High | Wrist | 30 | 65 | Low or Med | Low or Med | |
| | Elbow, ankle | 30 | 10 | 65 | 30 | Low or Med | Low or Med | Elbow, ankle | 40 | 65 | Low or Med | Low or Med | Substantially equivalent |
| | Hip | 40 | 20 | 65 | 30 | Low or Med | Low or Med | Hip | / | 65 | Low or Med | Low or Med | |
| | / | / | / | 65 | 30 | Low or Med | Low or Med | / | / | 65 | Low or Med | Low or Med | |
| Pressure Rate<br>Security<br>Hardware<br>Flow Rate | | | | $375 \text{mmHg}$ | | | | | $280 \pm 10 \text{mmHg}$ | | | | Substantially equivalent |
| | | | | There are 4 flow rates for the Cannula<br>suction and 4 flow rates for the Shaver<br>Suction -> displayed by LED (MIN,<br>LOW, MED and HIGH) | | | | | There are 3 flow rates for the Cannula<br>suction and 3 flow rates for the Shaver<br>Suction -> displayed by LED<br>(LOW, MED and HIGH) | | | | |
| Minimum flow<br>rate | | | | Cannula 100 mL/min<br>Shaver: 200 mL/min | | | | | Cannula flow rates: 100 mL/min<br>Shaver flow rates: 200 mL/min | | | | Identical |
| Maximum flow<br>rate | | | | Cannula 600 mL/min<br>Shaver: 800mL/min | | | | | Cannula flow rates: 600 mL/min<br>Shaver flow rates: 800 mL/min | | | | Identical |
| Interfaces | | | | Interface with various shaver systems and<br>various footswitches | | | | | Interface with a Shaver Interface Cable | | | | Substantially<br>equivalent, subject<br>device has additional<br>interfaces no more<br>functionalities |
hemodia
11
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Image /page/10/Picture/4 description: The image shows a logo for Hemodia Medical Partner. The logo features a stylized green letter "H" with a gradient effect, resembling a leaf or a drop. To the right of the "H", the word "hemodia" is written vertically, and below it, the words "Medical Partner" are written in a smaller font size.
| | Predicate Devices | Subject Device | Comparison Analysis |
|----------------------------|-------------------------|----------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Control with<br>Footswitch | Yes, Footswitch (wired) | No | Substantially equivalent, subject<br>device has other control<br>such as keyboard (front<br>panel interface, and foot<br>switch from the shaver<br>when connected via<br>Shaver Interface Cable) |
| Control with<br>Remote | No | No | Identical |
| Consumable | Polymer Tubing | Polymer Tubing | Substantially equivalent |
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Image /page/11/Picture/0 description: The image contains the logo for "hemodia Medical Partner". The logo features a stylized green leaf with the letter "H" cut out of the leaf. To the right of the leaf is the word "hemodia" in a sans-serif font. Below "hemodia" is the phrase "Medical Partner" in a smaller font.
The differences in the technological characteristics of both the proposed device ZEOS Aqua Vision Pump and tubing sets and the DOUBLEFLO system is minor and do not raise new questions of safety and effectiveness.
There is no technical characteristics that differs between these devices when considering the clinical and technical support of the intended use.
Both the ZEOS Aqua Vision Pump and tubing sets and the DOUBLEFLO system are designed to be used with compatible shaver systems.
### VIII PERFORMANCE DATA
The following performance data were provided in support of the substantial equivalence determination.
### Software
The software was developed, tested, and verified in accordance with the FDA quidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" and in accordance with the following standard:
· IEC62304- Medical Device Software - Software Life Cycle Processes.
Software tests were conducted to satisfy the requirements of the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices and IEC 62304 Standard (Medical Device Software - Life Cycle Process). The software was considered as a "moderate" level of concern, since a failure or latent design flaw could directly result in minor injury to the patient or operator or could indirectly result in minor injury to the patient or operator through incorrect or delayed information or through the action of a care provider.
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Image /page/12/Picture/0 description: The image shows the logo for Hemodia Medical Partner. The logo features a green stylized leaf shape with the letter 'H' inside. To the right of the leaf is the word 'hemodia' in a smaller font, and below that are the words 'Medical Partner' in an even smaller font.
Software verification activities were performed during the "Design, coding & testing" and "Verification" phases of software lifecycle. Outputs generated during these phases include:
- · Unit test reports
- · Integration test reports
- · System test reports
- · Overall software test report
- · Verification test reports
- · Overall software validation report
The software tests at the unit, integration and system levels were performed according to the Software Test Plan. Verification tests were performed for each software requirement according to the Software Verification Plan.
Conformity of software with the user needs and intended use of the device were performed through the "Validation" phase of the DOUBLEFLO system.
Design verification testing of the DOUBLEFLO system demonstrates that the device performs as intended and that the performance does not raise new questions of safety and effectiveness.
# Electrical safety and electromagnetic compatibility
Electrical safety and electromagnetic compatibility (EMC) testing were conducted on the DOUBLEFLO system.
The device complies with recognized electrical safety standards:
- IEC 60601-1 standard for electrical safety o
- . IEC 60601-1-2 standard for electromagnetic compatibility.
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Image /page/13/Picture/1 description: The image shows the logo for Hemodia Medical Partner. The logo features a stylized green letter 'H' with a leaf-like shape extending from the top right. To the right of the 'H' is the word 'hemodia' in a sans-serif font, with the words 'Medical Partner' in a smaller font size below it.
# Biocompatibility testing
The biocompatibility evaluation for DOUBLEFLO system tubing sets has been conducted in accordance with FDA Guidance Document: Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" and ISO 10993-1 -"Biological evaluation of medical devices - Evaluation and testing within a risk management system". These tubing sets are categorized as externally communicating devices in indirect contact with tissue/bone for a limited time (<24h) per ISO 10993-1. The evaluation reveals that biocompatibility requirements are met by the DOUBLEFLO system tubing sets.
Biocompatibility testing was performed on the tube sets in accordance with:
· ISO 10993-1 - Biological evaluation of medical devices- Evaluation and testing within a risk management system;
• ISO 10993-5 - Biological evaluation of medical devices – Part 5: Tests for in vitro cytotoxicity; and
· ISO 10993-10 - Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization:
· ISO 10993-11 - Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity.
# Sterilization Validation
In addition, the sterilization validation on the tube sets has been performed in accordance with:
- · ISO 11135 Sterilization of health care products Ethylene Oxide -Requirements for the development, validation and routine control of a sterilization process for medical device
- · ISO 11135-1 Sterilization of health care products Ethylene oxide Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices;
- · ISO 14937 Sterilization of health care products General criteria for characterization of a sterilizing agent and the development, validation and routine control of a sterilization process for medical devices; and
- · ISO 10993-7 Biological evaluation of medical devices Part 7: Ethylene oxide sterilization residuals.
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Image /page/14/Picture/1 description: The image shows the logo for Hemodia Medical Partner. The logo features a stylized green leaf shape with a white "H" inside it, followed by the word "hemodia" in a sans-serif font. Below "hemodia" are the words "Medical Partner" in a smaller, lighter font.
Residual ethylene oxide (EO) and ethylene chlorohydrin (ECH) data shows that the limit of EO < 4 mg and ECH < 5 mg after 3 days of aeration (gas release) that remain on the tube set will not be exceeded. The sterility assurance level (SAL) was 10-6. Package and product integrity of the tube sets were tested in accordance with ISO11607-1 - Packaging for terminally sterilized medical devices and ASTM-F- 1980:2002 - Standard for accelerated aging of sterile medical device packages.
# Performance Testing - Bench
The following performance tests were conducted:
- Functional tests of the DOUBLEFLO system 9
- Functional tests of the DOUBLEFLO system accessories .
- . Usability Tests of the DOUBLEFLO system
- Functional tests of the tubing sets at to and after 3 years of accelerated . aqing
- . Leak and Tensile (Strength) tests of the tubing sets at to and after 3 years of accelerated aging
### Animal studies
Data from animal studies were not required to support the safety and effectiveness of the DOUBLEFLO system.
### Clinical Studies
Clinical data were not required to support the safety and effectiveness of the DOUBLEFLO system. All validation was performed based on non-clinical performance tests.
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Image /page/15/Picture/1 description: The image shows the logo for Hemodia Medical Partner. The logo features a stylized green leaf shape with a white "H" inside it. To the right of the leaf is the word "hemodia" in a sans-serif font, with the words "Medical Partner" in a smaller font size underneath.
# IX SUMMARY OF NON CLINICAL PERFORMANCE TESTING - Bench
| Test | Test Method Summary | Results |
|--------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electrical safety and<br>electromagnetic<br>compatibility<br>(EMC) | Testing in compliance<br>with the IEC 60601-1<br>and IEC 60601-1-2 | Evaluation and testing were<br>performed on the subject device<br>and demonstrated to be<br>substantially equivalent to the<br>predicate device. |
| Biocompatibility<br>testing | Testing in compliance<br>with FDA Guidance<br>"Use of International<br>Standard ISO 10993,<br>Biological evaluation of<br>medical Devices Part 1"<br>and ISO 10993-1 | The following non clinical tests<br>were performed on the subject or<br>equivalent devices: Cytotoxicity,<br>Sensitization, Irritation and Acute<br>systemic toxicity and<br>demonstrated to be substantially<br>equivalent to the predicate<br>device. |
| Software Verification<br>and<br>Validation Testing | Software verification<br>testing in compliance<br>with FDA guidance<br>"General Principles of<br>Software Validation"<br>and IEC 62304 | Evaluation and testing were<br>performed on the subject device<br>and demonstrated substantially<br>equivalent performance to<br>identified predicate device |
| Sterilization<br>Validation | The sterilization<br>validation was<br>performed according to<br>ISO 11135 and ISO<br>11135-1 Sterilization of<br>health care products –<br>Ethylene oxide - Part 1:<br>Requirements for the<br>development, validation<br>and routine control of a<br>sterilization<br>process for medical<br>devices; and<br>• ISO 10993-7 -<br>Biological evaluation of<br>medical devices - Part<br>7: Ethylene oxide<br>sterilization residuals. | Validation was performed on the<br>subject device and demonstrated<br>to be substantially equivalent to<br>the identified predicate devices. |
| Bench Tests | The functional and<br>usability tests on the<br>DOUBLEFLO system<br>was performed<br>according to IEC 62366<br>– Medical Devices – | Evaluation and testing were<br>performed on the subject device<br>and demonstrated substantially<br>equivalent performance to<br>identified predicate device. |
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Image /page/16/Picture/0 description: The image contains a logo for a company called "hemodia Medical Partner". The logo features a stylized letter "H" in green, with the word "hemodia" written in a sans-serif font to the right of the "H". Below "hemodia", the words "Medical Partner" are written in a smaller font size. The overall design is clean and professional, suggesting a company in the healthcare or medical field.
| | Part 1: Application of<br>Usability Engineering to<br>Medical to Medical<br>Devices. The functional<br>test included test on the<br>strength of the tubing<br>sets at t₀ and following<br>three years and 3<br>months of accelerated<br>aging. | |
|------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|
| Animal studies | Not applicable | Not applicable |
| Clinical Studies | Not applicable | Not applicable |
#### CONCLUSIONS ×
Based on the similar intended use, the same basic technological characteristics and performance testing, the DOUBLEFLO system (pump, tubing sets and accessories) is substantially equivalent to the predicate device ZEOS Aqua Vision Pump and tubing sets (K192921). The differences between the proposed device and the predicate device do not raise new questions of safety and effectiveness.
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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.