The SimpliShade Bulk Fill is indicated for: - Direct placement of anterior and posterior restorations. - Core build-ups. - Repair of defects in restorations. The SimpliShade Bulk Fill Flow is indicated for: - Base/liner under Class I and Class II direct restorations. - Pit and fissure sealant. - Restoration of small cavities. - Class III and V restorations. - Blocking out undercuts. - Small core build-ups. - Repair of resin and acrylic provisional restorations.
Device Story
SimpliShade Bulk Fill and Bulk Fill Flow are light-cured, resin-based nanohybrid dental restoratives. Used in dental clinics by practitioners for direct restorations. SimpliShade Bulk Fill (high viscosity) allows 5mm single-increment placement; SimpliShade Bulk Fill Flow (low viscosity) allows 4mm single-increment placement. Both utilize proprietary rheology modifiers and filler systems. Polymerization occurs via light-induced reaction (400-520 nm, min 650 mW/cm²) of methacrylate resins and fillers. Products are delivered via Unidose compules or syringes. Benefits include optical blending with VITA shade guides and structural support for tooth restoration. Clinical decision-making is supported by the material's physical properties (compressive strength, hardness, radio-opacity) ensuring durable, esthetic outcomes.
Clinical Evidence
No clinical data. Substantial equivalence established via bench testing, including ISO 4049 compliance (flexural strength, water sorption/solubility, depth of cure, radio-opacity, color stability) and comparative testing (compressive strength, diametral tensile strength, Rockwell hardness, volumetric shrinkage, wear, shrinkage stress).
Technological Characteristics
Resin-based nanohybrid dental restorative; methacrylate resins, photo-initiators, inorganic fillers. Curing: photo-polymerization (400-520 nm, ≥650 mW/cm²). Form factor: Unidose compules or syringes. Standards: ISO 4049:2019, ISO 10993 biocompatibility series. High viscosity (Bulk Fill) and low viscosity (Bulk Fill Flow) variants.
Indications for Use
Indicated for direct anterior/posterior restorations, core build-ups, and repair of defects (SimpliShade Bulk Fill); or as base/liner, pit/fissure sealant, small cavity restoration, Class III/V restorations, undercut blockout, and repair of provisional restorations (SimpliShade Bulk Fill Flow).
Regulatory Classification
Identification
Tooth shade resin material is a device composed of materials such as bisphenol-A glycidyl methacrylate (Bis-GMA) intended to restore carious lesions or structural defects in teeth.
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Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services logo. The logo on the right is the FDA logo, which stands for U.S. Food & Drug Administration. The FDA logo is in blue.
August 31, 2022
Kerr Corporation Haiyan Wei Senior Regulatory Affairs Specialist 1889 W Mission Blvd Pomona, California 91766
Re: K221255
Trade/Device Name: SimpliShade Bulk Fill, SimpliShade Bulk Fill Flow Regulation Number: 21 CFR 872.3690 Regulation Name: Tooth Shade Resin Material Regulatory Class: Class II Product Code: EBF Dated: August 5, 2022 Received: August 5, 2022
Dear Haiyan Wei:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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 (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For Michael E. Adjodha, M. ChE. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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) K221255
Device Name
SimpliShade Bulk Fill, SimpliShade Bulk Fill Flow
Indications for Use (Describe)
The SimpliShade Bulk Fill is indicated for:
- Direct placement of anterior and posterior restorations.
- Core build-ups.
- Repair of defects in restorations.
The SimpliShade Bulk Fill Flow is indicated for:
- Base/liner under Class I and Class II direct restorations.
- Pit and fissure sealant.
- Restoration of small cavities.
- Class III and V restorations.
- Blocking out undercuts.
- Small core build-ups.
- Repair of resin and acrylic provisional restorations.
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 word "Kerr" in a bold, blue font. The word is written in all lowercase letters, except for the "K", which is capitalized. There is a trademark symbol to the right of the second "r" in the word. The background of the image is white.
# K221255 - 510(k) Summary
for
SimpliShade™ Bulk Fill, SimpliShade™ Bulk Fill Flow
#### 1. Submitter Information:
Kerr Corporation 1889 W Mission Blvd Pomona, CA 91766 USA
| Contact Person: | Haiyan Wei |
|-------------------|-------------------------|
| Telephone Number: | (714) 516-7710 |
| Email: | haiyan.wei@kavokerr.com |
June 27, 2022 Date Prepared:
#### 2. Device Name:
| Proprietary Name: | SimpliShade™ Bulk Fill, SimpliShade™ Bulk Fill Flow |
|----------------------|-----------------------------------------------------|
| Manufacturer: | Kerr Corporation |
| Common Name: | Tooth Shade Resin Material Restorative |
| Classification Name: | Tooth Shade Resin Material |
| CFR Number: | 872.3690 |
| Device Class: | II |
| Product Code: | EBF |
### 3. Predicate Device (Primary):
| Proprietary Name: | Filtek™ One Bulk Fill Restorative (K163207) |
|----------------------|---------------------------------------------|
| Manufacturer: | 3M ESPE Dental Products |
| Common Name: | Tooth Shade Resin Material Restorative |
| Classification Name: | Tooth Shade Resin Material |
| CFR Number: | 872.3690 |
| Device Class: | II |
| Product Code: | EBF |
### Predicate Device #2:
| Proprietary Name: | Filtek™ Bulk Fill Flowable Restorative (K120453) |
|----------------------|--------------------------------------------------|
| Manufacturer: | 3M ESPE Dental Products |
| Common Name: | Tooth Shade Resin Material |
| Classification Name: | Tooth Shade Resin Material |
| CFR Number: | 872.3690 |
| Device Class: | II |
| Product Code: | EBF |
#### 4. Device Description:
SimpliShade™ Bulk Fill Composite is offered in two types of viscosities: the high viscosity formula will be branded as SimpliShade™ Bulk Fill; the low viscosity formula will be branded as SimpliShade™ Bulk Fill Flow.
### SimpliShade™ Bulk Fill:
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Image /page/4/Picture/0 description: The image shows the logo for Kerr, a dental equipment and supplies manufacturer. The logo is in blue and features the company name in a bold, sans-serif font. A trademark symbol is located to the right of the company name. The logo is simple and modern, and the blue color gives it a professional look.
SimpliShade Bulk Fill is an intra-oral, light-cured, esthetic, resin-based nanohybrid dental restorative that is designed for the placement of direct restorations. SimpliShade Bulk Fill is designed to be used after placement of a dental adhesive, such as a product from the Kerr OptiBond™ family.
SimpliShade Bulk Fill is available in Unidose™ compules and syringe delivery systems that are suitable for occlusal surfaces. The product offers allows a technique in which a cavity up to 5 mm in depth can be filled and cured in a single increment. SimpliShade Bulk Fill is offered in one universal shade to optically blend with a range of VITA™ shade guide equivalents. This composite can be polished with a wide variety of polishing discs, rubber cups, and brushes.
### SimpliShade™ Bulk Fill Flow:
SimpliShade Bulk Fill Flow is an intra-oral, light-cured, esthetic, resin-based nanohybrid dental restorative that is designed to be used as a base or liner in Class I and II restorations and must be overlayed with a composite resin to replace the occlusal surfaces. It is also suitable to be used on nonocclusal-contact surfaces, such as pit and fissures, core build-ups and Class III and V restorations.
SimpliShade Bulk Fill Flow is available in Unidose™ compules and syringe delivery systems. The product allows a technique in which a cavity up to 4 mm in depth can be filled and cured in a single increment. SimpliShade Bulk Fill Flow is offered in one universal shade to optically blend with a range of VITAM shade guide equivalents. Once light cured, the composite can be finished and polished using conventional finishing and polishing instruments.
#### న్. Principle of Operation / Mechanism of Action:
### SimpliShade™ Bulk Fill:
SimpliShade Bulk Fill is a high viscosity resin-based nano-hybrid dental restorative that can be lightcured. It is designed to be used after placement of a dental adhesive. Once the bonding procedure is completed, a liner using a low viscosity flowable composite may optionally be placed and light cured according to the manufacturer's instructions prior to placing SimpliShade Bulk Fill. SimpliShade Bulk Fill is intended to be cured by exposure to light waves with a minimum light intensity of 650 mW/cm² and a light wavelength output within the 400-520 nm range, in incremental layers up to 5 mm. The handling behavior of the material is achieved through the addition of a proprietary rheology modifier as well as an optimized balance of the concentration of the filler system with the resin concentration. When irradiated by light, the methacrylate functionalities of the resins and fillers undergo, in conjunction with the photoinitiator system, a light-induced polymerization to form a hard composite that is bonded to the tooth structure with a permanent dental adhesive.
### SimpliShade™ Bulk Fill Flow:
SimpliShade Bulk Fill Flow is a low viscosity resin-based nano-hybrid dental restorative that can be light-cured. It is designed to be used after placement of a dental adhesive. Once the bonding procedure is completed, a layer of SimpliShade Bulk Fill Flow is placed directly onto the prepared site along the axial and gingival margins. With a brushing action, the material can flow into the marginal interfaces and recesses of the preparation in up to 4mm increments; SimpliShade Bulk Fill Flow is intended to be cured by exposure to light waves with a minimum light intensity of 650 mW/cm² and a light wavelength output within the 400-520 nm range. The handling behavior of the material is achieved through the addition of a proprietary rheology modifier as well as an optimized balance of the concentration of the filler system with the resin concentration. When irradiated by light, the methacrylate functionalities of the resins and fillers undergo, in conjunction with the photoinitiator system, a light-induced polymerization to form a hard composite that is bonded to the tooth structure with a permanent dental adhesive.
#### 6. Indications for Use:
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Image /page/5/Picture/0 description: The image shows the word "Kerr" in a bold, blue font. The letters are large and spaced closely together. A small trademark symbol is located to the upper right of the word.
SimpliShade™ Bulk Fill is indicated for:
- Direct placement of anterior and posterior restorations.
- Core build-ups.
- Repair of defects in restorations.
SimpliShade™ Bulk Fill Flow is indicated for:
- Base/liner under direct restorations.
- Pit and fissure sealant.
- Restoration of small cavities.
- Class III and V restorations.
- Blocking out undercuts.
- Small core build-ups.
- Repair of resin and acrylic provisional restorations.
#### 7. Description of Substantial Equivalence:
The similarities between the SimpliShade™ Bulk Fill, SimpliShade™ Bulk Fill Flow (Subject Device) and the Primary Predicate Device Filtek™ One Bulk Fill Restorative (K163207), Predicate Device #2 Filtek™ Bulk Fill Flowable Restorative (K120453), include the Regulatory Classification, Intended Use of the device, Indications for Use, Mode of Action, Device description, and Clinical condition of use. Furthermore, Technological Characteristics and Performance testing including Biocompatibility testing are similar.
There are no major differences but only minor differences between the SimpliShade™ Bulk Fill, SimpliShade™ Bulk Fill Flow (Subject Device) and the Primary Predicate Device Filtek™ One Bulk Fill Restorative (K163207), Predicate Device #2 Filtek™ Bulk Fill Flowable Restorative (K120453). The formulation composition slightly varies and performance test results have slightly different values; however, these minor differences have no impact on the device performances which demonstrate subject devices are substantially equivalent as predicate devices.
Table 1 below compares the SimpliShade™ Bulk Fill, SimpliShade™ Bulk Fill Flow (Subject Devices) and the Primary Predicate Device Filtek™ One Bulk Fill Restorative (K163207), Predicate Device #2 Filtek™ Bulk Fill Flowable Restorative (K120453) with respect to intended use, technological characteristics and performance testing.
| Descriptive<br>Information | Subject Device 1 | Subject Device 2 | Predicate Device<br>(Primary) | Predicte<br>Device #2 | Comparison |
|------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
| | SimpliShade™<br>Bulk Fill<br>(K221255) | SimpliShade™<br>Bulk Fill Flow<br>(K221255) | Filtek™ One Bulk<br>Fill Restorative<br>(K163207) | Filtek™ Bulk Fill<br>Flowable Restorative<br>(K120453) | |
| Manufacturer | Kerr Corporation | Kerr Corporation | 3M ESPE<br>Dental Products | 3M ESPE<br>Dental Products | N/A |
| Regulatory Classification | | | | | |
| Regulation # | 21 CFR 872.3690 | 21 CFR 872.3690 | 21 CFR 872.3690 | 21 CFR 872.3690 | Same as<br>Predicates. |
| Regulation<br>Title | Tooth Shade Resin<br>Material | Tooth Shade Resin<br>Material | Tooth Shade Resin<br>Material | Tooth Shade Resin<br>Material | Same as<br>Predicates. |
| Regulation<br>Class | Class II | Class II | Class II | Class II | Same as<br>Predicates. |
| Product Code | EBF | EBF | EBF | EBF | Same as<br>Predicates. |
| Indications for Use/Intended Use | | | | | |
| Intended Use | Material, Tooth<br>Shade, Resin | Material, Tooth<br>Shade, Resin | Material, Tooth<br>Shade, Resin | Material, Tooth<br>Shade, Resin | Same as<br>Predicates. |
| Indications<br>for Use | 1.Direct placement<br>of anterior and<br>posterior<br>restorations.<br>2.Core build-ups.<br>3.Repair of defects<br>in restorations. | 1.Base/liner under<br>direct restorations.<br>2.Pit and fissure<br>sealant.<br>3.Restoration of<br>small cavities.<br>4.Class III and V<br>restorations.<br>5.Blocking out<br>undercuts.<br>6.Small core build-<br>ups.<br>7.Repair of resin<br>and acrylic<br>provisional<br>restorations. | 1.Direct anterior<br>and posterior<br>restorations<br>(including occlusal<br>surfaces).<br>2.Base/liner under<br>direct restorations.<br>3.Core build-ups.<br>4.Splinting.<br>5.Indirect<br>restorations<br>including inlays,<br>onlays and veneers.<br>6.Restorations of<br>deciduous teeth.<br>7.Extended fissure<br>sealing in molars<br>and premolars.<br>8.Repair of defects<br>in porcelain<br>restorations,<br>enamel, and<br>temporaries. | 1.Base under Class I<br>and II direct<br>restorations.<br>2.Liner under direct<br>restorative materials.<br>3.Pit and fissure<br>sealant.<br>4.Restoration of<br>minimally invasive<br>cavity preparations<br>(including small, non<br>stress-bearing<br>occlusal restorations).<br>5.Class III and V<br>restorations.<br>6.Undercut blockout.<br>7.Repair of small<br>enamel defects.<br>8.Repair of small<br>defects in esthetic<br>indirect restorations.<br>9.Repair of resin and<br>acrylic temporary<br>materials.<br>10.As a core build-up<br>where at least half the<br>coronal tooth<br>structure is remaining<br>to provide structural<br>support for the<br>crown. | Same<br>Indication for<br>Use as<br>Predicate<br>Devices and<br>expressed<br>through<br>similar choice<br>of wording. |
| Technological Characteristics | | | | | |
| Clinical<br>condition of<br>use | Dental clinics or<br>similar healthcare<br>settings. | Dental clinics or<br>similar healthcare<br>settings. | Dental clinics or<br>similar healthcare<br>settings. | Dental clinics or<br>similar healthcare<br>settings. | Same as<br>Predicate<br>Devices. |
| Anatomical<br>location of<br>use | Oral, teeth | Oral, teeth | Oral, teeth | Oral, teeth | Same as<br>Predicate<br>Devices. |
| Principles of<br>Operation | Tooth shade resin-<br>based dental<br>restorative that can<br>be light-cured by | Tooth shade resin-<br>based dental<br>restorative that can<br>be light-cured by | Tooth shade resin-<br>based dental<br>restorative that can<br>be light-cured by | Tooth shade resin-<br>based dental<br>restorative that can<br>be light-cured by | Same as<br>Predicate<br>Devices. |
| | photo<br>polymerization. | photo<br>polymerization. | photo<br>polymerization. | photo<br>polymerization. | |
| Storage | Store at room<br>temperature 2-28°C<br>(36-82°F). | Store at room<br>temperature 2-28°C<br>(36-82°F). | Store at room<br>temperature 2-<br>27°C. | Store at room<br>temperature 2-27°C. | Similar to<br>Predicate<br>devices. |
| Compatible<br>with<br>methacrylate-<br>based dental<br>adhesives | Yes | Yes | Yes | Yes | Same as<br>Predicate<br>Devices. |
| Recommende<br>d for load-<br>bearing<br>occlusal<br>surfaces | Yes | No | Yes | No | Same as<br>Predicate<br>Devices. |
| Primary<br>Packaging | Syringe and<br>Capsule | Syringe and<br>Capsule | Syringe and<br>Capsule | Syringe and Capsule | Same as<br>Predicate<br>Devices. |
| Material<br>Composition | Methacrylate<br>resins, Photo-<br>initiators,<br>Inorganic fillers | Methacrylate<br>resins, Photo-<br>initiators,<br>Inorganic fillers | Methacrylate<br>resins, Photo-<br>initiators,<br>Inorganic fillers | Methacrylate resins,<br>Photo-initiators,<br>Inorganic fillers | Similar to<br>Predicate<br>devices. |
| Containing<br>Inorganic<br>Fillers | Yes | Yes | Yes | Yes | Same as<br>Predicate<br>Devices. |
| Primary<br>Filler particle<br>size range | 40 nm - 0.4 µm | 40 nm - 0.1 µm | 4 nm - 100 nm | 10 nm - 5.0 µm | Similar to<br>Predicate<br>devices. |
| Curing<br>Mechanism | Photo-initiation | Photo-initiation | Photo-initiation | Photo-initiation | Same as<br>Predicate<br>Devices. |
| Intensity<br>(mW/cm²) for<br>curing | ≥ 650 mW/cm² | ≥ 650 mW/cm² | ≥ 550 mW/cm² | ≥ 550 mW/cm² | Similar to<br>Predicate<br>devices. |
| Wavelength<br>(nm) for<br>curing | 400 - 520 nm | 400 - 520 nm | 400 - 500 nm | 400 - 500 nm | Similar to<br>Predicate<br>Devices. |
| Curing Time<br>(sec) | 20 sec (≥ 650<br>mW/cm²) | 20 sec (≥ 650<br>mW/cm²) | At least 20 sec (≥<br>550 mW/cm²) | 20 sec (≥ 550<br>mW/cm²) | Similar to<br>Predicate<br>Devices. |
| Depth of<br>Cure (mm) | Up to 5mm | Up to 4mm | Up to 5mm | Up to 4mm | Similar to<br>Predicate<br>Devices. |
| Compressive<br>Strength<br>(MPa) | Meet the criteria<br>per internal<br>standard | Meet the criteria<br>per internal<br>standard | Meet the criteria<br>per internal<br>standard | Meet the criteria per<br>internal standard | Similar to<br>Predicate<br>Devices. |
| Internal<br>standard<br>>260 Mpa | | | | | |
| Rockwell<br>Hardness<br>(RHN)<br>Internal<br>Standard<br>>65 RHN | Meet the criteria<br>per internal<br>standard | Meet the criteria<br>per internal<br>standard | Meet the criteria<br>per internal<br>standard | Meet the criteria per<br>internal standard | Similar to<br>Predicate<br>Devices. |
| Flexural<br>Strength<br>(Mpa) | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO 4049<br>requirement | Similar to<br>Predicate<br>Devices. |
| Radio-opacity<br>(mm of AI) | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO 4049<br>requirement | Similar to<br>Predicate<br>Devices. |
| Water<br>Sorption<br>(µg/mm³) | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO 4049<br>requirement | Similar to<br>Predicate<br>Devices. |
| Water<br>Solubility<br>(µg/mm³) | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO 4049<br>requirement | Similar to<br>Predicate<br>Devices. |
| Sensitivity to<br>ambient light | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement | Conform to ISO<br>4049 requirement…
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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.