Published clinical literature (case reports and case series)
A literature review of 21 publications involving 177 patients was used to demonstrate the device's ability to provide hydromechanical removal of infectious materials, non-viable tissue, and wound debris in a real-world clinical setting.
Literature review; Case series; Hydromechanical removal; Wound management
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Literature review of 21 reference publications; Retrospective case reports and case series; Follow-up/Duration: Based on wound size and patient factors
177 patients with chronic, acute, traumatic, sub-acute, dehisced wounds, partial-thickness burns, ulcers, flaps, and grafts; Sample Size: 177
Not applicable for this study
Reduction in non-viable wound tissue (slough, fibrotic, necrotic), decrease in need for surgical debridement, and granulation tissue formation
Indications for Use
The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ Veraflo™ Therapy, which consists of negative pressure wound therapy (3M™ V.A.C.® Therapy) with an instillation option. · 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material. · The instillation option is indicated for patients who would benefit from vacuum assisted drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing. The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehisced wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts. The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ Veraflo™ Therapy, which consists of negative pressure wound therapy (3M™ V.A.C.® Therapy) with an instillation option. · 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, reducing edema, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material. · The instillation option is indicated for patients who would benefit from vacuum assisted drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing. The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehised wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.
Device Story
Dressing kits for use with 3M V.A.C. Ulta Therapy Unit; provide negative pressure wound therapy (NPWT) and controlled instillation of topical solutions. Components include reticulated polyurethane foam dressing with 10mm diameter through-holes, occlusive drape, and tubing set. Holes facilitate mechanical stress/strain on wound bed; under negative pressure, fracture points form in wound debris, allowing solution penetration and hydromechanical removal of non-viable tissue/exudate. Used in acute and extended care settings by clinicians. Output is wound bed preparation and granulation tissue promotion. Benefits include reduced surgical debridement requirements and improved wound healing environment.
Clinical Evidence
Literature-based real-world evidence from 21 publications (177 patients) evaluating 3M V.A.C. Veraflo Therapy. Endpoints included reduction in non-viable tissue (slough, necrotic tissue) and granulation tissue formation. Results demonstrate hydromechanical removal of infectious materials/debris and promotion of granulation tissue in complex wounds.
Technological Characteristics
Sterile, single-use dressing kits. Materials: felted polyurethane ester foam (carbon black or blue/violet dye), polyurethane film drape with acrylic adhesive. Sensing/actuation: reticulated open-cell foam with 10mm diameter through-holes for pressure distribution and fluid instillation. Sterilization: Gamma irradiation or Ethylene Oxide (ETO). Connectivity: interfaces with 3M V.A.C. Ulta Therapy Unit.
Indications for Use
Indicated for patients with chronic, acute, traumatic, sub-acute, and dehisced wounds, partial-thickness burns, ulcers (diabetic, pressure, venous insufficiency), flaps, and grafts requiring negative pressure wound therapy with or without instillation.
Regulatory Classification
Identification
A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" underneath.
March 23, 2023
3M Health Care Business Group Margaret Marsh Regulatory Affairs Advanced Specialist 6203 Farinon Dr San Antonio, Texas 78249
Re: K221585
Trade/Device Name: 3M V.A.C. Veraflo Cleanse Choice Dressing Kit, 3M Veraflo Cleanse Choice Complete Dressing Kit Regulation Number: 21 CFR 878.4780 Regulation Name: Powered suction pump Regulatory Class: Class II Product Code: OMP Dated: January 20, 2023 Received: January 24, 2023
Dear Margaret Marsh:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (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 medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
# Julie A. Morabito -S
Julie Morabito, Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control 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) 510k K221585
#### Device Name
3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit
#### Indications for Use (Describe)
The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ Veraflo™ Therapy, which consists of negative pressure wound therapy (3M™ V.A.C.® Therapy) with an instillation option.
· 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material.
· The instillation option is indicated for patients who would benefit from vacuum assisted drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing.
The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehisced wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.
The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ Veraflo™ Therapy, which consists of negative pressure wound therapy (3M™ V.A.C.® Therapy) with an instillation option.
· 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, reducing edema, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material.
· The instillation option is indicated for patients who would benefit from vacuum assisted drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing.
The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehised wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.
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)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
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Image /page/4/Picture/1 description: The image shows the 3M logo. The logo is in red and features the number "3" followed by the letter "M". The font is bold and sans-serif. The logo is simple and recognizable.
March 9, 2023 Date prepared
#### Submitter information [21 CFR 807.929(a)(1)]
| Name | 3M Health Care Business Group |
|-----------------------------------------|-----------------------------------------------------------------|
| Address | 6203 Farinon Dr, San Antonio TX 78249, United States of America |
| Establishment<br>Registration<br>Number | 3009897021 |
| Name of contact<br>person | Margaret Marsh, Regulatory Affairs Advanced Specialist |
| Contact E-mail | mlmarsh@mmm.com |
#### Name of the device [21 CFR 807.92(a)(2)]
| Trade or<br>proprietary name | 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit |
|------------------------------|----------------------------------------------------------------------------------------------------|
| Common or usual<br>name | Components of a negative pressure wound therapy system |
| Classification name | 878.4780 - Powered suction pump |
| Product code | OMP |
#### Legally marketed device(s) to which equivalence is claimed [21 CFR 807.92(a)(3)]
- 3MTM V.A.C. Veraflo Cleanse Choice™ Dressing Kit, cleared most recently under 510(k) . K200390
- 3MTM Veraflor™ Cleanse Choice Complete™ Dressing Kit, cleared under 510(k) K211521 .
#### Device description [21 CFR 807.92(a)(4)]
Both dressing kits are intended to be used with the 3M™ V.A.C.® Ulta Therapy Unit and its associated canisters and cassette for the delivery of 3M™ Veraflo™ Therapy that provides Negative Pressure Wound Therapy coupled with controlled delivery and drainage of topical wound treatment solutions and suspensions over the wound bed. The dressing kits provide sterile disposable components needed for delivery of 3MTM VerafloTM Therapy.
Each kit contains a wound dressing with 10 mm diameter holes specifically designed for use with 3M™ Veraflo™ Therapy (either the 3M™ V.A.C. Veraflo™ Cleanse Choice™ or the 3MTM Veraflo™ Cleanse Choice Complete™ Dressing), an occlusive drape covering the dressing (either the 3MTM V.A.C. Advanced Drape or the V.A.C. Dermatac™ Drape), a tubing set for connecting the dressing to the negative pressure and instillation pumps (either the 3M™ V.A.C. VeraT.R.A.C.TM Pad or the 3M™ VeraT.R.A.C. Duo™ Tube Set, depending on dressing size) and a wound measuring ruler.
The subject dressings differ only in the number of dressing pieces provided in the kit, in the drape materials of construction and in the method of sterilization:
- . The 3M™ V.A.C. Veraflo™ Cleanse Choice™ Dressing Kit is gray in color, has three dressing layers (one with holes, one thin cover layer and one thick cover layer without holes), has a drape constructed of a polyurethane film with acrylic adhesive and is sterilized by irradiation.
- The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit is blue in color, has only one ● dressing piece (which consists of a combination of the layer with holes and the thin cover layer without holes in the 3M™ V.A.C. Veraflo™ Cleanse Choice™ Dressing), has a drape constructed of a polyurethane film with acrylic adhesive and a perforated silicone layer, and is sterilized by ethylene oxide (ETO).
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Image /page/5/Picture/1 description: The image shows the 3M logo, which is a well-known brand. The logo consists of the number "3" followed by the letter "M", both in a bold, sans-serif font. The color of the text is a vibrant red, and the background is white, creating a strong contrast that makes the logo easily recognizable.
#### Indications for Use
The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ VerafloTM Therapy, which consists of negative pressure wound therapy (3MTM V.A.C. Therapy) with an instillation option.
- 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that . promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, reducing edema, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material.
- The instillation option is indicated for patients who would benefit from vacuum assisted ● drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing.
The 3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehisced wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.
The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit is used as part of an integrated wound management system that provides 3M™ VerafloTM Therapy, which consists of negative pressure wound therapy (3MTM V.A.C. 8 Therapy) with an instillation option.
- 3M™ V.A.C.® Therapy in the absence of instillation is intended to create an environment that . promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, reducing edema, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material.
- The instillation option is indicated for patients who would benefit from vacuum assisted . drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed. It provides hydromechanical removal of infectious materials, non-viable tissue and wound debris which reduces the number of surgical debridements required, while promoting granulation tissue formation, creating an environment that promotes wound healing.
The 3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit with and without instillation is indicated for patients with chronic, acute, traumatic, sub-acute and dehisced wounds, partial- thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.
# Comparison of the technological characteristics with the predicate device [21 CFR 807.92(a)(6)]
See Table on following pages.
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# 510(k) Summary
| | Comparison to Predicates Table | | | | |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------|
| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing<br>System | Subject Device<br>3MTM V.A.C. Veraflo Cleanse Choice™<br>Dressing Kit | Predicate Device (per K211521)<br>3MTM VerafloTM Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3MTM VerafloTM Cleanse Choice Complete™<br>Dressing Kit | Comparison |
| Indications<br>for Use | The V.A.C. Ulta™ Negative Pressure Wound<br>Therapy System is an integrated wound<br>management system that provides Negative<br>Pressure Wound Therapy with an instillation<br>option. | The 3M™ Veraflo™ Cleanse Choice Dressing<br>Kit is used as part of an integrated wound<br>management system that provides 3MTM<br>Veraflo™ Therapy, which consists of negative<br>pressure wound therapy (3MTM V.A.C.®<br>Therapy) with an instillation option. | The 3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit is used as part of an integrated<br>wound management system that provides 3MTM<br>Veraflo™ Therapy, which consists of negative<br>pressure wound therapy (3MTM V.A.C.® Therapy)<br>with an instillation option. | The 3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit is used as part of an integrated<br>wound management system that provides 3MTM<br>Veraflo™ Therapy, which consists of negative<br>pressure wound therapy (3MTM V.A.C.® Therapy)<br>with an instillation option. | Identical, except for<br>minor name<br>changes |
| | • Negative Pressure Wound Therapy in the<br>absence of instillation is intended to create an<br>environment that promotes wound healing by<br>secondary or tertiary (delayed primary)<br>intention by preparing the wound bed for<br>closure, reducing edema, promoting granulation<br>tissue formation and perfusion, and by<br>removing exudate and infectious material.<br>• The instillation option is indicated for patients<br>who would benefit from vacuum assisted<br>drainage and controlled delivery of topical<br>wound treatment solutions and suspensions over<br>the wound bed. | • 3MTM V.A.C.® Therapy in the absence of<br>instillation is intended to create an<br>environment that promotes wound healing by<br>secondary or tertiary (delayed primary)<br>intention by preparing the wound bed for<br>closure, reducing edema, promoting<br>granulation tissue formation and perfusion,<br>and by removing exudate and infectious<br>material.<br>• The instillation option is indicated for patients<br>who would benefit from vacuum assisted<br>drainage and controlled delivery of topical<br>wound treatment solutions and suspensions<br>over the wound bed. It provides<br>hydromechanical removal of infectious<br>materials, non-viable tissue and wound debris<br>which reduces the number of surgical<br>debridements required, while promoting<br>granulation tissue formation, creating an<br>environment that promotes wound healing. | • 3MTM V.A.C.® Therapy in the absence of<br>instillation is intended to create an<br>environment that promotes wound healing by<br>secondary or tertiary (delayed primary)<br>intention by preparing the wound bed for<br>closure, reducing edema, promoting<br>granulation tissue formation and perfusion,<br>and by removing exudate and infectious<br>material.<br>• The instillation option is indicated for patients<br>who would benefit from vacuum assisted<br>drainage and controlled delivery of topical<br>wound treatment solutions and suspensions<br>over the wound bed. | • 3MTM V.A.C.® Therapy in the absence of<br>instillation is intended to create an<br>environment that promotes wound healing by<br>secondary or tertiary (delayed primary)<br>intention by preparing the wound bed for<br>closure, reducing edema, promoting<br>granulation tissue formation and perfusion,<br>and by removing exudate and infectious<br>material.<br>• The instillation option is indicated for patients<br>who would benefit from vacuum assisted<br>drainage and controlled delivery of topical<br>wound treatment solutions and suspensions<br>over the wound bed. It provides<br>hydromechanical removal of infectious<br>materials, non-viable tissue and wound debris<br>which reduces the number of surgical<br>debridements required, while promoting<br>granulation tissue formation, creating an<br>environment that promotes wound healing. | Identical, except for<br>minor name<br>changes, and<br>addition of the new<br>hydromechanical<br>indication text |
| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing<br>System | Subject Device<br>3M™ V.A.C. Veraflo Cleanse Choice™<br>Dressing Kit | Predicate Device (per K211521)<br>3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Comparison |
| | The V.A.C.ULTA™ Negative Pressure Wound<br>Therapy System with and without instillation is<br>indicated for patients with chronic, acute,<br>traumatic, sub-acute and dehisced wounds, partial-<br>thickness burns, ulcers (such as diabetic, pressure<br>and venous insufficiency), flaps and grafts. | The 3M™ Veraflo™ Cleanse Choice<br>Dressing Kit with and without instillation is<br>indicated for patients with chronic, acute,<br>traumatic, sub-acute and dehisced wounds,<br>partial- thickness burns, ulcers (such as diabetic,<br>pressure and venous insufficiency), flaps and<br>grafts. | The Veraflo™ Cleanse Choice Complete™<br>Dressing Kit with and without instillation is<br>indicated for patients with chronic, acute,<br>traumatic, sub-acute and dehisced wounds,<br>partial- thickness burns, ulcers (such as diabetic,<br>pressure and venous insufficiency), flaps and<br>grafts. | The Veraflo™ Cleanse Choice Complete™<br>Dressing Kit with and without instillation is<br>indicated for patients with chronic, acute,<br>traumatic, sub-acute and dehisced wounds,<br>partial- thickness burns, ulcers (such as diabetic,<br>pressure and venous insufficiency), flaps and<br>grafts. | Except for minor<br>name changes, text<br>is identical. |
| Wound<br>Types | Chronic, acute, traumatic, sub-acute and dehisced<br>wounds, partial-thickness burns, ulcers (such as<br>diabetic, pressure and venous insufficiency), flaps<br>and grafts. | Same as predicate | Chronic, acute, traumatic, sub-acute and dehisced<br>wounds, partial-thickness burns, ulcers (such as<br>diabetic, pressure and venous insufficiency), flaps<br>and grafts. | Same as predicate | Identical |
| Care Setting | Acute and extended care settings | Same as predicate | Acute and extended care settings | Same as predicate | Identical |
Image /page/6/Picture/3 description: The image shows the 3M logo. The logo is red and features the number 3 followed by the letter M. The logo is simple and recognizable.
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Image /page/7/Picture/3 description: The image shows the 3M logo. The logo is red and consists of the number "3" followed by the letter "M". The logo is simple and recognizable.
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| Comparator<br>Dressing Kit<br>Components | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing System | | Subject Device<br>3M™ V.A.C. Veraflo Cleanse<br>Choice™ Dressing Kit | Predicate Device (per K211521)<br>3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice<br>Complete™ Dressing Kit | Comparison | |
|----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|-----------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|------------------------------------------------------------------------------------------------|
| V.A.C. Veraflo Cleanse Choice Dressing<br>(3 piece design) V.A.C. Advanced Drape VeraT.R.A.C. or VeraT.R.A.C. Duo Tube Set Ruler 3M ™ Cavilon™ Skin Prep | Same as predicate | | Veraflo Cleanse Choice Dressing<br>(1 piece design) Dermatac Drape VeraT.R.A.C. or VeraT.R.A.C. Duo Tube Set Ruler | Same as predicate | Identical type of<br>components, except<br>for Cavilon Skin<br>Prep | | |
| Dressing<br>Dimensions/<br>Geometry | Medium<br>Dressing | Component | Description | Same as predicate | Medium Dressing: single piece consisting of an<br>oval shaped, 180 x 125 x 16mm foam with holes (10<br>mm in diameter and 8 mm deep)<br><br>Large Dressing: single piece consisting of an oval<br>shaped, 256 x 150 x 16mm foam with holes (10 mm<br>in diameter and 8 mm deep)<br><br>Note: holes in the dressing penetrate one-half the<br>thickness of the dressing. | Same as predicate | Identical. There is<br>no change between<br>each subject device<br>and its predicate<br>device |
| | Large<br>Dressing | Perforated<br>Contact<br>Layer<br><br>Thin Cover<br>Layer | Oval shaped layer, 256<br>x 150 x 8 mm, with<br>holes (10 mm in<br>diameter through holes)<br><br>Oval shaped layer, 256<br>x 150 x 8 mm, without<br>holes | | | | |
Image /page/8/Picture/3 description: The image shows the 3M logo. The logo is red and features the number "3" followed by the letter "M". The logo is simple and recognizable, and it is often used on 3M products and marketing materials. The logo is slightly blurry.
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| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing System | Subject Device<br>3M™ V.A.C. Veraflo Cleanse<br>Choice™ Dressing Kit | Predicate Device (per K211521)<br>3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice<br>Complete™ Dressing Kit | Comparison |
|--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------|------------------------------------------------------------------------------------|
| | Thick Cover<br>Layer Oval shaped layer, 256 x 150 x 16 mm, without holes | | | | |
| Dressing<br>Drawing | Image: Dressing | Same as predicate | Image: Dressing | Same as predicate | Identical. There is no change between each subject device and its predicate device |
| Patient<br>Contacting<br>Materials | The dressing is constructed of a felted polyurethane ester foam colored with carbon black. | Same as predicate | The dressing is constructed of the same felted polyurethane ester foam as in 3M V.A.C. Veraflo Cleanse Choice Dressing, except that it is colored with blue and violet dyes. | Same as predicate. | Identical. There is no change between each subject device and its predicate device |
| | The drape is constructed of a polyurethane film with acrylic adhesive<br>Note: Optionally, the user can apply the drape constructed of polyurethane film with acrylic adhesive and a perforated silicone layer (provided separately) | Same as predicate | The drape is constructed of a polyurethane film with acrylic adhesive and a perforated silicone layer. | Same as predicate | device |
| NPWT<br>System Design | The V.A.C. Veraflo Cleanse Choice™ Dressing System is intended for use with the V.A.C. Ulta NPWT system.<br>The NPWT system consists of: | Same as predicate | The Veraflo Cleanse Choice Complete Dressing System is intended for use with the 3M™ V.A.C.® Ulta NPWT system.<br>The NPWT System consists of: | Same as predicate | Identical, except for the subject dressing name. |
| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing System | Subject Device<br>3M™ V.A.C. Veraflo Cleanse Choice™ Dressing Kit | Predicate Device (per K211521)<br>3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice Complete™ Dressing Kit | Comparison |
| | Software controlled therapy unit: 3M™ V.A.C.® Ulta Therapy Unit Exudate canister (either 500 or 1000 mL capacity) Negative pressure tubing and sensing pad Instillation cassette, tubing and pad Foam wound dressing Occlusive drape | | Software controlled therapy unit: 3M™ V.A.C.® Ulta Therapy Unit Exudate canister (either 500 or 1000 mL capacity) Negative pressure tubing and sensing pad Instillation cassette, tubing and pad Foam wound dressing Occlusive drape | | |
| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing System | Subject Device<br>3MTM V.A.C. Veraflo Cleanse<br>Choice™ Dressing Kit | Predicate Device (per K211521)<br>3MTM Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice<br>Complete™ Dressing Kit | Comparison |
| Operating<br>Principle | At a system level (with which the kit is used):<br>The 3M™ V.A.C.® Ulta Therapy System delivers<br>software controlled negative pressure to the wound<br>site during the negative pressure cycle. It also<br>provides automated delivery of user selected topical<br>wound solutions into the wound bed between negative<br>pressure therapy cycles. | Same as predicate | At a system level (with which the kit is used):<br>The 3M™ V.A.C.® Ulta Therapy System delivers<br>software controlled negative pressure to the wound<br>site during the negative pressure cycle. It also<br>provides automated delivery of user selected topical<br>wound solutions into the wound bed between<br>negative pressure therapy cycles. | Same as predicate | Identical |
| | At the kit component level:<br>• The reticulated open cells of the foam dressing to<br>which the therapy unit is connected enable<br>distribution of the negative pressure across the<br>surface of the wound and allows for instillation<br>solution to contact the wound bed. The 10 mm<br>diameter and 8 mm through holes in the dressing<br>facilitate removal of thick wound exudate during<br>the negative pressure cycle.<br>• The tubing set allows for delivery of negative<br>pressure and instillation solutions to the wound<br>bed and for transfer of accumulated fluids to the<br>canister in the negative pressure cycle.<br>• The drape provides a sealed environment for<br>delivery of negative pressure wound therapy and<br>protects from fluid leakage during instillation<br>therapy. | | At the kit component level:<br>• The reticulated open cells of the foam dressing<br>to which the therapy unit is connected enable<br>distribution of the negative pressure across the<br>surface of the wound and allows for instillation<br>solution to contact the wound bed. The 10 mm<br>diameter and 8 mm deep holes in the dressing<br>facilitate removal of thick wound exudate during<br>the negative pressure cycle.<br>• The tubing set allows for delivery of negative<br>pressure and instillation solutions to the wound<br>bed and for transfer of accumulated fluids to the<br>canister in the negative pressure cycle.<br>• The drape provides a sealed environment for<br>delivery of negative pressure wound therapy and<br>protects from fluid leakage during instillation<br>therapy. | | |
| Comparator | Predicate Device (per K200390)<br>V.A.C. Veraflo Cleanse Choice™ Dressing System | Subject Device<br>3MTM V.A.C. Veraflo Cleanse<br>Choice™ Dressing Kit | Predicate Device (per K211521)<br>3M™ Veraflo™ Cleanse Choice Complete™<br>Dressing Kit | Subject Device<br>3M™ Veraflo™ Cleanse Choice<br>Complete™ Dressing Kit | Comparison |
| Operating<br>Principle,<br>continued | At the dressing level:<br>• The unique structure of the dressing with 10 mm<br>diameter through holes in the contact layer<br>facilitate removal of thick wound exudate during<br>the negative pressure cycle. The holes induce<br>mechanical stress and strain on the wound tissue<br>and wound debris layer. Under negative pressure,<br>fracture points are created as the wound materials<br>are drawn up into the holes in the dressing,<br>allowing topical solution penetration as shown<br>below.<br>Image: V.A.C. Veraflo Cleanse Choice Dressing System<br>• Hydromechanical removal of infectious<br>materials, non-viable tissue and wound debris<br>is achieved through the dressing's mechanical<br>action in conjunction with the process of<br>instilling and allowing topical solutions to soak<br>in the wound bed for up to 30 minutes during<br>the Instillation Cycle of Veraflo Therapy. The<br>instillation and soaking action allows for<br>diluting, softening, and solubilizing infectious<br>material…
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.