K223826 · Drawbridge Health, Inc. · FMK · Feb 22, 2024 · General, Plastic Surgery
Device Facts
Record ID
K223826
Device Name
NanoDrop Lancet
Applicant
Drawbridge Health, Inc.
Product Code
FMK · General, Plastic Surgery
Decision Date
Feb 22, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4850
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The NanoDrop Lancet is intended for use to obtain a capillary blood sample. It does not collect or transport such samples.
Device Story
NanoDrop Lancet is a sterile, single-use, disposable device for capillary blood sampling from the upper arm. Device features a gray plastic housing with a bowl-shaped cavity, hydrogel adhesive for skin attachment, and two stainless steel needle blades. Operation involves: 1) attaching device to skin; 2) pressing button 'I' to apply controlled vacuum pressure; 3) pressing button 'II' to deploy needle blades through a septum and vacuum chamber foil. A yellow locking feature prevents accidental deployment. After use, blades automatically retract into the enclosure to prevent reuse and mitigate sharps injury. A permanent plug obstructs the port to prevent unintended connection to collection containers. Used in home or clinical settings by patients or healthcare providers. Output is a capillary blood sample for diagnostic testing. Benefits include safe, controlled, and simplified blood sampling.
Clinical Evidence
Clinical study evaluated safety, handling, and user opinion of the NanoDrop Lancet compared to the Acti-Lance (K220643). Study included 30 subjects, each providing 4 samples (2 per device). All acceptance criteria were met, supporting safe and effective unsupervised, self-administered use by adults on the upper arm.
Indicated for obtaining capillary blood samples in adults and pediatrics. If user is under 18, must be used by an adult or under adult supervision.
Regulatory Classification
Identification
The regulation covers four types of blood lancets: (a) Single use only blood lancet with an integral sharps injury prevention feature; (b) Single use only blood lancet without an integral sharps injury prevention feature; (c) Multiple use blood lancet for single patient use only; and (d) Multiple use blood lancet for multiple patient use. All are defined as disposable or reusable devices comprised of a blade attached to a base used to puncture the skin to obtain a drop of blood for diagnostic purposes.
Special Controls
*Classification.* Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and must include a sharps injury prevention feature.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use and that the integral sharps injury prevention feature will irreversibly disable the device after one use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
*e.g.,* blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device and its sharps injury prevention feature.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
*e.g.,* cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
*1* ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
*2* ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(b)
*Single use only blood lancet without an integral sharps injury prevention feature* —(1)*Identification.* A disposable blood lancet intended for a single use that is comprised of a single use blade attached to a solid, non-reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
*Classification.* Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
*e.g.,* blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
*e.g.,* cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
*1* ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
*2* ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(c)
*Multiple use blood lancet for single patient use only* —(1)*Identification.* A multiple use capable blood lancet intended for use on a single patient that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
*Classification.* Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that:
(A) The lancet blade can be changed with every use, either manually or by triggering a blade storage unit to discard the used blade and reload an unused blade into the reusable base; and
(B) The structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions and allow for validated cleaning and disinfection.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
*e.g.,* blade).(v) Validation testing must demonstrate that the cleaning and disinfection instructions are adequate to ensure that the reusable lancet base can be cleaned and low level disinfected.
(vi) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) The Environmental Protection Agency (EPA) registered disinfectant's contact time for disinfectant use.
(C) Handwashing instructions for the user before and after use of the device.
(D) Instructions on preparation (
*e.g.,* cleaning, disinfection) of the skin to be pierced.(E) Instructions on the cleaning and disinfection of the device.
(F) Instructions for the safe disposal of the device.
(G) Instructions for use must address the safe storage of the reusable blood lancet base between uses to minimize contamination or damage and the safe storage and disposal of the refill lancet blades.
(H) Labeling must be appropriate for the intended use environment.
(
*1* ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
*2* ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vii) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Disinfect reusable components according to manufacturer's instructions between each use.”
(B) “Used lancet blades must be safely discarded after a single use.”
(C) “Warning: Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested. The cleaning and disinfection instructions for this device are intended only to reduce the risk of local use site infection; they cannot render this device safe for use for more than one patient.”
(d)
*Multiple use blood lancet for multiple patient use* —(1)*Identification.* A multiple use capable blood lancet intended for use on multiple patients that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
*Classification.* Class III (premarket approval).(3)
*Date PMA or notice of completion of a PDP is required:* A PMA or a notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before May 22, 2024, for any multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976, or that has, on or before May 22, 2024, been found to be substantially equivalent to a multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976. Any other multiple use blood lancet for multiple patient use shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food & Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
February 22, 2024
Drawbridge Health, Inc. Beth Thompson Sr. Regulatory Consultant, Lean RAQA 5949 Amberwood Dr. Naples, Florida 34110
Re: K223826
Trade/Device Name: NanoDrop Lancet Regulation Number: 21 CFR 878.4850 Regulation Name: Blood Lancets Regulatory Class: Class II Product Code: FMK Dated: January 26, 2024 Received: January 29, 2024
Dear Beth Thompson:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,
Digitally signed by Mark Mark Trumbore -S Trumbore -S Date: 2024.02.22 Mark Trumbore, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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#### Indications for Use
510(k) Number (if known) K223826
Device Name NanoDrop Lancet
Indications for Use (Describe)
The NanoDrop Lancet is intended for use to obtain a capillary blood sample. It does not collect or transport such samples.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Drawbridge Health. The logo consists of a red teardrop shape on the left, followed by the words "Drawbridge" and "Health" in black font. The word "Health" is located below the word "Drawbridge".
## 1. APPLICANT INFORMATION
| Submitter Information | |
|-----------------------------------|---------------------------------------------------|
| Company Name: | Drawbridge Health, Inc |
| Address: | 620 Omni Industrial Blvd<br>Summerville, SC 29486 |
| Phone Number: | 1-631-897-5215 |
| Establishment Registration Number | 3015798231 |
| Primary Company Contact | |
| Name: | Jerome Scelza |
| Title: | Co-CEO |
| Phone Number: | 1-631-897-5215 |
| Email: | jscelza@dbhealth.com |
| Official Correspondent | |
| Name: | Beth Thompson |
| Title: | Sr. Regulatory Consultant |
| Phone Number: | 1-224-656-3620 |
| Email: | betht@leanraqa.com |
#### 2. DATE OF PREPARATION
| Date of Preparation | January 26, 2024 |
|---------------------|------------------|
|---------------------|------------------|
#### 3. DEVICE INFORMATION
| Device Name: | NanoDrop Lancet device |
|----------------------|-----------------------------------------------------------------------------------|
| Common Name: | Blood Lancet |
| Classification Name: | Single use only blood lancet with an integral sharps<br>injury prevention feature |
| Model(s): | FD004 |
| Regulation Number: | 21 CFR 878.4850(a) |
| Product Code: | FMK |
| Class: | Class II |
#### 4. PREDICATE DEVICES
| Predicate Type | 510(k) Number | Name of Device | Name of Manufacturer |
|------------------|---------------|--------------------------------------|------------------------------------|
| Primary Device | K223208 | Safety Lancet | Suzhou Zhenwu Medical<br>Co., Ltd. |
| Reference Device | K220643 | DropSafe Acti-Lance Safety<br>Lancet | HTL-Strefa S.A. |
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Image /page/4/Picture/0 description: The image shows the logo for Drawbridge Health. The logo consists of a red teardrop shape on the left, followed by the words "Drawbridge" in a bold, sans-serif font. Below "Drawbridge" is the word "HEALTH" in a smaller, sans-serif font. The logo is simple and modern, and the red teardrop shape likely represents blood, which is relevant to the company's focus on health and diagnostics.
### 5. DEVICE DESCRIPTION
The Drawbridge Health NanoDrop Lancet Device is a sterile, single-use, disposable lancet for capillary blood sampling. The device incorporates two (2) stainless steel needles with blade tips to make two (2) small incisions in the skin. The device is made of a gray plastic housing base that has a molded outer rim and a bowl-shaped cavity. The outer rim is covered by a hydrogeladhesive to better attach the device to the skin, with a cover over the hydrogel adhesive pad for its protection. The bowl shape provides space for the skin to be drawn up as slight controlled vacuum pressure is applied, and for the needle blades to access the skin after piercing through a septum and vacuum chamber foil. There are two (2) clearly marked gray push buttons on the device:
- The gray button marked "I" is for activation of the vacuum; and
- The gray button marked "II" is for deployment of the needle blades.
There is a yellow removable plastic locking feature to prevent accidental activation of the button that deploys the needle blades(gray button marked "II"). There is also a white vacuum chamber lid securely attached on top of the base, over the gray lancet enclosure, where the two needle blades are held in a clear plastic needle holder, along with the main spring and retraction spring, and into which they automatically retract after use, with no access to this gray lancet enclosure possible. This prevents the lancet from being used more than once, and it keeps the blades retracted for sharps injury prevention safety and for disposal. A permanent plug obstructs the port and mitigates unintended connection of a collection container.
The single model number is FD004.
#### 6. INDICATIONS FOR USE
The NanoDrop Lancet device is intended for use to obtain a capillary blood sample. It does not collect or transport such samples.
| Device | Subject Device | Predicate Device | Remark | Reference<br>Device | Discussion |
|----------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-------------------------------------------------------------------|------------|
| Device | Blood Lancet | Blood Lancet | Same | Blood Lancet | Same |
| Manufacturer | Drawbridge Health,<br>Inc | Suzhou Zhenwu<br>Medical Co. | Different | HTL-Strefa<br>S.A. | Different |
| 510(k) Number | K223826 | K223208 | Different | K220643 | Different |
| Product Code | FMK | FMK | Same | FMK | Same |
| Classification | Class II | Class II | Same | Class II | Same |
| Intended Use | Intended for capillary<br>blood sampling | Intended for capillary<br>blood sampling | Same | Intended for<br>capillary blood<br>sampling | Same |
| HEALTH | | | 510(k) Summary | | |
| Intended<br>Population | Adults and Pediatrics.<br>If user is under the<br>age of 18, the lancet<br>must be used by an<br>adult or under the<br>supervision of an<br>adult | Adults and Pediatrics. If<br>user is under the age of<br>18, the lancet must be<br>used by an adult or<br>under the supervision<br>of an adult | Same | Not stated | N/A |
| Number of Uses | Single use on one<br>person; no more than<br>one use | Single use on one<br>person; no more than<br>one use | Same | Single use on<br>one patient | Same |
| Prescription or<br>OTC Use | Over-the-counter | Over-the-counter | Same | Over-the<br>counter | Same |
| Needle Blade<br>gauge | 17G blades | Available in 21G and<br>18G blades | Similar | 17G blades | Same |
| Needle Blade<br>Diameter | 0.060in +/- 0.001in<br>(1.52mm +/-<br>0.025mm) | 21G: 0.800mm-<br>0.830mm<br>18G: 1.200mm-<br>1.300mm | Similar | Not stated | N/A |
| Needle Blade<br>Length | 0.500in +/- 0.002in | Unknown | Unknown | Not stated | N/A |
| Needle Blade<br>Penetration<br>Depth | 1.9-2.0 mm | 21G: 1.8, 2.0, 2.2, 2.4<br>mm<br>18G: 2.0, 2.2, 2.4 mm | Similar | Not stated | N/A |
| Usage | Single use only | Single use only | Same | Single use only | Same |
| Sterilization | Gamma radiation | Gamma radiation | Same | ISO 10993 | Same |
| Sharps Injury<br>Prevention<br>Feature | Only one puncture can<br>be made after the<br>protective lock and<br>adhesive cover are<br>removed and the push<br>buttons are activated<br>to start the vacuum<br>and to release the<br>blades. Both lancet<br>blades automatically<br>retract into the device<br>after activation. | The puncture function<br>can only be used after<br>the cap is pulled off.<br>Lancet retracts into the<br>device after activation. | Similar | Sharps Injury<br>Prevention<br>Feature and<br>Blade<br>Retraction | Similar |
| Biocompatibility | No cytotoxicity<br>No irritation<br>No skin sensitization<br>No acute systemic<br>toxicity<br>No pyrogens | No cytotoxicity<br>No irritation<br>No skin sensitization<br>No acute systemic<br>toxicity<br>No pyrogens | Same | ISO 10993 | Same |
| Clinical<br>Testing | Safety and<br>Performance study | None | Different | None | Different |
| Shelf life | 19 months | 5 years | Similar | 5 years | Similar |
## 7. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS
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# Drawbridge
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The characteristics of the devices present no material differences in substantial equivalence as the gauge size and number of blades does not affect performance, the difference in method of activation does not affect performance, the penetration depth falls within the range of the predicate device, and the difference in shelf life does not affect performance. The devices are substantially equivalent to each other.
#### 8. PERFORMANCE TESTING
- 8.1 Non-clinical performance
The following performance testing met all acceptance criteria.
- Pain levels and preferred method of obtaining blood - User Study
- Lancet Cut (Penetration) Depth ●
- Applied Vacuum Lower Bound Test ●
- Lancet Needle Blade Diameter ●
- Device Length and Width
- Device Redeployment Testing
- Lancet Retraction Distance
- Pull Force Testing of Needle from Holder
- Sharps Injury Prevention Feature Drop Testing
- Pull Force and Mechanical Testing of Permanent Plug
- Permanent Plug Leak Test
- . Hydrogel Ring and Bloodborne Pathogen Barrier
- USP-NF: 2020 Chapter <788> Testing for Particulates in Solutions or Medical Devices
#### 8.2 Biocompatibility
The following biocompatibility testing was successfully completed:
| 10993-1:<br>2009 | ISO | Biological Evaluation of Medical Devices-Part 1 :<br>Evaluation and testing within a risk management process |
|-------------------|-----------|--------------------------------------------------------------------------------------------------------------------------|
| 10993-3:<br>2014 | ISO | Biological Evaluation of Medical Devices- Part 3 : Tests for genotoxicity,<br>carcinogenicity, and reproductive toxicity |
| 10993-4:<br>2006 | ISO | Biological Evaluation of Medical Devices-Part 4 :<br>Selection of tests for interaction with blood |
| 10993-5:<br>2009 | ISO | Biological Evaluation of Medical Devices-Part 5 :<br>Test for invitro cytotoxicty |
| 10993-10:<br>2010 | ISO | Biological Evaluation of Medical Devices-Part 10:<br>Test for irritation and skin sensitization |
| 10993-<br>11:2006 | ISO | Biological Evaluation of Medical Devices-Part 11 :<br>Test for systemic toxicity; Material-mediated Pyrogenicity |
| USP-NF<br>2018 | USP <161> | USP Limulus Amebocyte Lysate (LAL) Test - Kinetic-Turbidimetric Method |
#### Sterilization/Shelf-life Testing/Shipping Testing 8.3
| Sterilization Method | Radiation (electron beam) |
|-------------------------------|---------------------------|
| NEW YORK | drawbridgehealth.com |
| 152 W 57th Street, 10th Floor | Info@dbhealth.com |
| New York NY 10017 | |
{7}------------------------------------------------
Sterility Assurance Level
| 11137-<br>1:2006/(R)15;<br>A1:2013 | ANSI/AAMI/ISO | Sterilization of Healthcare Products-Radiation-Part 1 : Requirements for<br>development, validation and routine control of a sterilization process for<br>medical devices |
|------------------------------------|---------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 11137-2: 2013 | ANSI/AAMI/ISO | Sterilization of Healthcare Products-Radiation-Part 2 : Establishing the<br>radiation dose |
| 11137-3: 2017 | ANSI/AAMI/ISO | Sterilization of Healthcare Products-Radiation-Part 3 : Guidance on<br>dosimetric aspects |
| F1980-16 | ASTM | Standard Guide for Accelerated Aging of Sterile Medical Device Packages |
| 4169-16 | ASTM | Standard Practice for Performance Testing of Shipping Containers and<br>System |
| F2096-11 | ASTM | Standard Test Method for Detecting Gross Leaks in Medical Packaging by<br>Internal Pressurization (bubble test) |
| F88/F88M-15 | ASTM | Standard Test Method for Seal Strength of Flexible Barrier Materials |
SAL 10-6
#### 8.4 Animal and Clinical performance data
No animal study is included in this submission.
A clinical study was performed with the aim to evaluate the safety and use of the NanoDrop Lancet Device and to evaluate the user's opinion with regards to handling characteristics of the device as compared to a comparable cleared OTC FMK fingerstick lancet (Acti-Lance K220643). The study included thirty subject with two samples for each device (four samples per subject). All acceptance criteria were met, supporting safe and effective use of the NanoDrop Device unsupervised and self-administered by adults on the upper arm.
## 9. CONCLUSION
The conclusions drawn from the clinical and nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well as or better than the legally marketed predicate device. They are substantially equivalent to each other.
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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.
