K221121 · Fresenius Kabi · FPA · Jun 16, 2023 · General Hospital
Device Facts
Record ID
K221121
Device Name
Volumat Polyethylene I.V. Administration Set
Applicant
Fresenius Kabi
Product Code
FPA · General Hospital
Decision Date
Jun 16, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5440
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
Volumat Polyethylene I.V. Administration Sets are intended for the administration of drugs and solutions.
Device Story
I.V. administration set for delivering parenteral fluids, solutions, colloids, parenteral nutrition, and medications (including diluted drugs and chemotherapy). Device components include spike, drip chamber, roller clamp, upstream/downstream clamp, backcheck valve, pump segment, needle-free port, rotating male luer lock, and tubing. Operates via gravity flow or with Agilia VP MC/Volumat MC Agilia infusion pumps. Used in clinical settings by healthcare providers. The pump segment facilitates controlled delivery when used with compatible pumps. Benefits include reliable, sterile fluid/medication delivery to the patient's vascular system.
Clinical Evidence
No clinical data. Substantial equivalence demonstrated through bench testing, including functional performance (leakage, tensile strength, flow accuracy, microbial ingress), biocompatibility (cytotoxicity, sensitization, irritation, hemolysis, acute systemic toxicity, pyrogenicity), and sterilization validation.
Technological Characteristics
Materials: Polystyrene, styrene-butadiene-copolymer, polyamide, methylmethacrylate-acrylonitrile-butadiene-styrene, copolyester, polyvinyl chloride, ethylene-vinyl acetate, polyethylene. Standards: ISO 8536-4, ISO 8536-8, ISO 8536-14, ISO 80369-20, ISO 10993-1, USP 788. Sterilization: Ethylene oxide (SAL 10^-6) per DIN EN ISO 11135:2020. Form factor: Tubing set with pump segment, 75-105 inches length.
Indications for Use
Indicated for the infusion of parenteral fluids and medications from a container into the patient's vascular system through a vascular access device with Agilia VP MC/Volumat MC Agilia pump or gravity only. Intended for use in adult and pediatric patients.
Regulatory Classification
Identification
An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.
Special Controls
*Classification.* Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.
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June 16, 2023
Fresenius Kabi % Jason Ma Sr. Manager, Regulatory Affairs Fresenius Kabi USA,LLC 3 Corporate Dr Suite 300 Lake Zurich, Illinois 60047
Re: K221121
Trade/Device Name: Volumat Polyethylene I.V. Administration Set Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: FPA Dated: May 18, 2023 Received: May 18, 2023
Dear Jason Ma:
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
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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 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,
Porsche Bennett
For David Wolloscheck, Ph.D. Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices. and Human Factors OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology 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) K221121
Device Name
Volumat Polyethylene I.V. Administration Set
Indications for Use (Describe)
I.V. Administration Set for the infusion of parenteral fluids and medications from a container into the patient's vascular system through a vascular access device with Agilia VP MC/Volumat MC Agilia pump or gravity only.
Type of Use (Select one or both, as applicable)X 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 Fresenius Kabi logo. The logo consists of three blue wavy lines on the left and the words "FRESENIUS KABI" in blue on the right. The word "FRESENIUS" is on top of the word "KABI".
Fresenius Kabi Three Corporate Drive
Lake Zurich, Illinois 60047
T 847-550-2300
T 847-550-2300
T 888-391-6300 www.fresenius-kabi.us
# 510(k) SUMMARY- K221121
| 1. Date Prepared: | June 16, 2023 |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 2. Submitter Information | |
| Name: | Fresenius Kabi |
| Address: | Fresenius Kabi AG<br>61346 Bad Homburg<br>Germany |
| Contact Person: | Jason Ma<br>Sr. Manager, Regulatory Affairs<br>Fresenius Kabi USA, LLC<br>Three Corporate Drive, 2nd Floor<br>Lake Zurich, IL 60047 USA<br>Phone: 224-817-4100<br>Fax: 847 550 2960<br>E-mail: Jason.ma01@fresenius-kabi.com |
| Secondary Contact Person: | Keith Dunn<br>Director, Regulatory Affairs<br>Fresenius Kabi USA, LLC<br>Three Corporate Drive, 2nd Floor<br>Lake Zurich, IL 60047 USA<br>Phone: 224-817-2430<br>Fax: 847 550 2960<br>E-mail: Keith.Dunn@fresenius-kabi.com |
## 3. Device Name and Classification
| Device Trade Name: | Volumat Polyethylene I.V. Administration Set |
|----------------------|----------------------------------------------|
| Common Name: | I.V. Administration Set |
| Classification Name: | Intravascular administration set |
| Regulation Number | 21 CFR 880.5440 |
| Regulatory Class: | Class II |
| Product Code: | FPA |
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Image /page/4/Picture/0 description: The image contains the logo for Fresenius Kabi. The logo consists of three blue, wavy lines on the left side. To the right of the lines, the words "FRESENIUS" and "KABI" are stacked on top of each other, also in blue. The logo is simple and modern, with a focus on the company name.
hree Cornorate Drive ke Zurich, Illinois 60047 847-550-2300 888-391-6300 ww.fresenius-kabi.us
### 4. Predicate Device
| Device Trade Name: | Intravascular Administration Sets |
|----------------------|-----------------------------------|
| Common Name: | Intravascular Administration Set |
| Classification Name: | 21 CFR 880.5440 |
| Regulatory Class: | Class II |
| Product Code: | FPA |
| 510(k) Number: | K203609 |
### 5. Device Description
The Volumat Polyethylene I.V. Administration Sets (PE Sets) are available for dedicated use with the Agilia Infusion Pump and the Agilia VP MC Pump, or they can administer parenteral fluids and medications by gravity flow. Both the Agilia Infusion Pump and the Volumat I.V. Administration Sets were cleared under K121613. The Agilia VP MC Pump was cleared under K210073. The PE Sets include a spike, drip chamber, roller clamp, upstream/downstream clamp, backcheck valve, pump segment, needle-free port, rotating male luer lock, and tubing.
| Set Number | Description |
|------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| M46441395 | Volumat Polyethylene I.V. Administration Set with spike, air vent, drip chamber, roller clamp, pump segment, rotating male luer |
| M46441995 | Volumat Polyethylene I.V. Administration Set with spike, air vent, drip chamber, roller clamp, pump segment, downstream clamp, downstream needle-free port, rotating male luer |
| M46444495 | Volumat Polyethylene I.V. Administration Set with spike, air vent, drip chamber, upstream clamp, backcheck valve, upstream needle-free port, roller clamp, pump segment, downstream clamp, downstream needle-free port, rotating male luer |
| M46445495 | Volumat Polyethylene I.V. Administration Set with spike, air vent, drip chamber, upstream clamp, backcheck valve, upstream needle-free port, roller clamp, pump segment, downstream clamp, downstream needle-free port, rotating male luer |
### 6. Principle of Operation
The range of sets provides options for intermittent or continuous delivery of parenteral fluids (solutions, colloids, parenteral nutrition) and medications (including but not limited to diluted drugs, chemotherapy) through clinically accepted intravenous (I.V.) routes of administration.
The device may be used for Adults and Pediatrics Patients.
### 7. Indication for Use/ Intended Use
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w.fresenius-kabi.us
#### Indication for Use:
I.V. Administration Set for the infusion of parenteral fluids and medications from a container into the patient's vascular system through a vascular access device with Agilia VP MC/Volumat MC Agilia pump or gravity only.
#### Intended Use:
Volumat Polyethylene I.V. Administration Sets are intended for the administration of drugs and solutions.
### 8. Comparison of the Technological Characteristics with the Predicate Device
The technological characteristics of the subject device are substantially equivalent to those of the predicate device in regard to the following technological characteristics:
- . Principle of operation and conditions of use of the subject device are the same as those of the predicate device.
- Materials of the proposed device do not raise new questions of safety and . effectiveness, as demonstrated by performance testing and biocompatibility evaluation.
- . Physical specifications of the subject device are equivalent to those of the predicate device.
A comparison between the predicate device and the subject device is provided in Table 1 and Table 2 below.
| Technological<br>Characteristics | Volumat Polyethylene<br>I.V. Administration<br>Sets (Subject Device) | Baxter Administration<br>Set K203609<br>(Predicate Device) | Assessment of<br>Differences |
|----------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indication for Use | IV Administration set<br>for the infusion of<br>parenteral fluids and<br>medications from a<br>container into the<br>patient's vascular<br>system through a<br>vascular access device<br>with Agilia VP MC<br>pumps/Volumat MC<br>Agilia pump or gravity<br>only. | For the administration of<br>fluids from a container<br>into the patients'<br>vascular system through<br>a vascular access device. | Similar. Both I.V.<br>administration sets are<br>used to administer fluids<br>from a container to a<br>patient. However, the<br>Subject Device<br>interoperates with<br>infusion systems that<br>have been cleared in<br>other 510(k) submissions<br>including K121613 and<br>K210073.. |
| Operating<br>Mechanism | The Volumat<br>administration sets<br>deliver the intravenous | The Baxter<br>administration sets can<br>be used to deliver | Similar, both devices can<br>be used with an infusion<br>pump or by gravity flow. |
| Technological<br>Characteristics | Volumat Polyethylene<br>I.V. Administration<br>Sets (Subject Device) | Baxter Administration<br>Set K203609<br>(Predicate Device) | Assessment of<br>Differences |
| | infusions via an infusion<br>pump through a<br>pumping mechanism<br>("cassette") or by<br>gravity flow. | solutions for gravity or<br>pump by infusion of I.V.<br>fluids. | The predicate device<br>does not have a pumping<br>mechanism ("cassette").<br>Difference has been<br>verified through<br>performance testing<br>including flow rate<br>accuracy under various<br>environmental conditions<br>(temperature, pressure,<br>humidity) which<br>demonstrate equivalence. |
| Sterile | Yes | Yes | Same |
| Non-Pyrogenic | Yes | Yes | Same |
| Single Use | Yes | Yes | Same |
| Length | 75-105 inches | 69-133.5 inches | Similar. The sets<br>included in the subject<br>device range in length<br>from 75 inches to 105<br>inches which is within<br>the range of the predicate<br>device.<br>Difference tested<br>according to ISO 8536-4<br>and flow rate accuracy to<br>demonstrate the subject<br>device performance. |
| Priming Volume | 21-27 ml | 6.1 to 21.2 mL | Similar. The Volumat set<br>requires more priming<br>volume than the<br>predicate. Bench testing<br>confirmed that the<br>differences in priming<br>volume do not impact<br>safety or effectiveness. |
| Internal Tube<br>Diameter | 0.122 inches | 0.102 to 133 inches | Similar internal and<br>external diameter and<br>approximate range of the<br>predicate device.<br>Difference tested to ISO<br>8536-8 has demonstrated<br>equivalence. |
| External Tube<br>Diameter | 0.164 inches | 0.140-0.209 inches | |
| Components | | | |
| Spike | Yes | Yes | Different. The subject<br>device includes an |
| Drip chamber | Yes | Yes | |
| Technological<br>Characteristics | Volumat Polyethylene<br>I.V. Administration<br>Sets (Subject Device) | Baxter Administration<br>Set K203609<br>(Predicate Device) | Assessment of<br>Differences |
| Backcheck Valve | Yes | Yes | additional pumping |
| Pump Segment | Yes | No | segment. However, no |
| Needle Free Port | Yes | Yes | significant difference |
| Male Luer | Yes | Yes | between the subject and |
| Roller Clamp | Yes | Yes | predicate administration |
| Connector Luer<br>Lock | Yes | Yes | sets that would raise new<br>issues of safety or<br>efficacy.<br>The differences have<br>been verified in various<br>aspects to demonstrate<br>the subject device's<br>safety and performance<br>including:<br>Biocompatibility testing<br>according to ISO 10993<br>collateral standards,<br>Microbial Ingress<br>Testing, and Particulate<br>Testing; Performance<br>Testing according to ISO<br>8536-4, ISO 80369-20,<br>ISO 8536-8 and ISO<br>8436-14. |
#### Table 1: Summary of Substantial Equivalence Comparison
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Image /page/6/Picture/0 description: The image shows the Fresenius Kabi logo. The logo consists of a blue abstract symbol on the left and the words "FRESENIUS KABI" in blue on the right. The abstract symbol is made up of three curved lines.
**Fresenius Kabi**
Fresemius Kabi
Thresemius Italia Drive
Lake Zurion atabile Drive
Lake Zurion 223000
T 888-3991-233000
www.fresenius-kabil.us
{7}------------------------------------------------
Image /page/7/Picture/0 description: The image shows the Fresenius Kabi logo. The logo consists of three blue, wavy lines on the left side. To the right of the lines, the words "FRESENIUS" and "KABI" are written in blue, with "FRESENIUS" on top of "KABI".
Fresenius Kabi
Theo Corporation Drive
Lake Zunich, Illinois 60047
Take Zunich, Illinois 60047
Trad47-5550-2300
www.fresenius-kabi.us
#### Table 2: Summary of Material Comparison
| Component | Modified Volumat I.V.<br>Administration Set<br>(Subject Device) | Baxter<br>Administration Set<br>K203609<br>(Predicate Device) | Assessment of Differences |
|-----------------|-----------------------------------------------------------------|---------------------------------------------------------------|----------------------------------------------------------------------------------------------------|
| Spike | Polystyrene | Acrylonitrile<br>Butadiene Styrene | Similar, testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
| Drip chamber | Polystyrene, styrene-<br>butadiene-copolymer,<br>Polyamide | Polyvinyl Chloride | Different, testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
| Backcheck Valve | Methylmethacrylate-<br>Acrylonitrile-Butadiene-<br>Styrene) | Polymethyl<br>methacrylate (acrylic)<br><br>Silicone Rubber | Similar, testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
| Pump Segment | Methylmethacrylate-<br>Acrylonitrile-Butadiene-<br>Styrene | N/A – predicate<br>device does not have<br>a pump segment | Testing to biocompatibility<br>and performance standards<br>demonstrated equivalence |
{8}------------------------------------------------
Image /page/8/Picture/0 description: The image shows the Fresenius Kabi logo. The logo consists of three blue, curved lines on the left side. To the right of the lines, the words "FRESENIUS" and "KABI" are written in blue, with "FRESENIUS" on top of "KABI".
888-391-6300 ww.fresenius-kabi.us
| Component | Modified Volumat I.V.<br>Administration Set<br>(Subject Device) | Baxter<br>Administration Set<br>K203609<br>(Predicate Device) | Assessment of Differences |
|----------------------------|-------------------------------------------------------------------------|---------------------------------------------------------------|--------------------------------------------------------------------------------------------------|
| Needle Free Port | Methylmethacrylate-<br>Acrylonitrile-Butadiene-<br>Styrene, Copolyester | Polyester | Similar, Testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
| Rotating Male Luer<br>Lock | Polyvinylchloride,<br>Acrylonitrile butadiene<br>styrene | Acrylonitrile<br>butadiene styrene | Similar, Testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
| Tubing | Polyvinyl chloride,<br>ethylene-vinyl acetate,<br>polyethylene | Polyvinyl chloride | Similar, Testing to<br>biocompatibility and<br>performance standards<br>demonstrated equivalence |
### 9. Substantial Equivalence
#### Intended Use/Indication for Use-Discussion of Differences
Both the subject and predicate device have the same intended use and similar indication for use. Both I.V. administration sets are used to administer fluids.
#### Technological Characteristics—Discussion of Differences
- Both the subject and predicate device can be used with an infusion pump or by gravity flow. The subject device delivers the intravenous infusions via an infusion pump through a pumping mechanism ("cassette") or by gravity flow, and the predicate device does not have a pumping mechanism ("cassette").
- The subject device ranges in length from 75 inches to 105 inches, which is within . the length range of the predicate device.
- . The subject device carries more priming volume than the predicate. Bench testing confirmed that the differences in priming volume do not impact safety or effectiveness.
- . The subject device includes an additional pumping segment. However, no significant difference between the subject and predicate administration sets that would raise new issues of safety or efficacy.
#### Conclusion on Substantial Equivalence
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Image /page/9/Picture/0 description: The image contains the logo for Fresenius Kabi. On the left side of the logo are three blue, vertical, wavy lines. To the right of the lines is the text "FRESENIUS KABI" in blue, with "FRESENIUS" on top of "KABI".
ee Cornorate Drive Zurich, Illinois 60047 888-391-6300 ww.fresenius-kabi.us
The Volumat Polyethylene I.V. Administration Set has the same intended use and equivalent indication for use as the predicate device. The subject device has similar technological characteristics to the predicate, and the descriptive and performance information provided within this premarket notification demonstrates that:
- any differences do not raise different questions of safety and . effectiveness compared to the predicate device; and
- . the proposed device is at least as safe and effective as the legally marketed predicate device.
Based on the comparison of the intended use and the technological characteristics, the subject device is substantially equivalent to the currently marketed predicate device.
### 10.Performance Testing
### Performance Testing-Bench
Functional performance bench testing was conducted to demonstrate that the Volumat Polyethylene I.V. Administration Set performs as intended.
The following performance testing was conducted to support the substantial equivalence determination:
- ISO 8536-8 .
- o Leakage
- o Tensile Strength
- o Storage Tube Volume
- ISO 80369-20 ●
- o Luer Fittings
- Stress Cracking о
- Resistance to Separation from Axial Loading o
- Resistance to Separation from Unscrewing O
- o Resistance to Overriding
- ISO 8536-4 ●
- o Closure-piercing Device Testing
- Air-inlet Device Testing о
- Tubing Testing O
- Flow Requirements of the Infusion Pump O
- Drip Chamber Testing O
- Clamp Opening and Closing O
- Protective Cap Testing о
- Chemical Compatibility Testing O
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Image /page/10/Picture/0 description: The image shows the Fresenius Kabi logo. The logo consists of a blue abstract symbol on the left and the words "FRESENIUS KABI" in blue on the right. The abstract symbol is made up of three curved lines that are parallel to each other.
w.fresenius-kabi.us
- ISO 8536-14 ●
- 0 Clamps and Flow Regulators Testing
- ISO 11607-1 & 2 and ASTM D4169 ● O Sterile Barrier and Packaging Systems and Simulated Shipping
- Particulate USP<788> Particulate Matter in Injections ●
- o Particulate Testing
- Pump Segment Compatibility Testing with Infusion Pump
- Operation under Temperature, Pressure and Humidity
- Microbial Ingress Testing ●
- . Usability Testing
# 11.Biocompatibility Testing
Following the FDA Guidance: "Use of International Standard ISO 10993-1, Biological evaluation of medical devices-Part 1: Evaluation and testing within a risk management process", the tests selected were for prolonged, blood path indirect, externally communicating devices. The following biocompatibility tests were successfully conducted on the Volumat Polyethylene I.V. Administration Set:
- Acute Systemic Toxicity
- Hemolysis ●
- Irritation ●
- Sensitization ●
- Cytotoxicity ●
- Pyrogens ●
- Subacute/subchronic toxicity ●
### 12. Sterilization Validation
Sterilization was achieved by ethylene oxide and meets the requirements of DIN EN ISO 11135:2020, which is equivalent to ISO 11135 (2014-7) + AMD 1 (2018-10). The ethylene oxide sterilization method achieves a Sterilization Assurance Level (SAL) of 10-6.
### 13. Clinical Testing
No clinical testing was performed as this device does not require clinical studies to demonstrate substantial equivalence with the predicate device.
{11}------------------------------------------------
Image /page/11/Picture/0 description: The image shows the Fresenius Kabi logo. The logo consists of three blue wavy lines on the left and the words "FRESENIUS KABI" in blue on the right. The word "FRESENIUS" is on top of the word "KABI".
Fresenius Kabi Three Corporate Drive Lake Zurich, Illinois 60047 T 847-550-2300 T 888-391-6300 www.fresenius-kabi.us
# 14. Conclusion
The differences between the predicate and the subject device do not raise any new or different questions of safety or effectiveness. The subject device, Volumat Polyethylene I.V. Administration Set is substantially equivalent to the predicate device, I.V. Administration Set, cleared under K203609.
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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.