The argument · idea-023

HOCl Wound Irrigation System, per-patient bag and single-use head (Aquaceso; variant)

For prescription use by or under the direction of a healthcare professional in; hospital, outpatient wound clinic, skilled nursing facility and home health settings, to; cleanse, irrigate and mechanically remove debris, exudate and foreign material from acute; and chronic dermal wounds in adults (Stage 2-4 pressure injuries, venous and arterial leg; ulcers, diabetic foot ulcers, post-surgical and traumatic wounds, and first- and; second-degree burns), at each dressing change. A sterile, hypochlorous acid-preserved saline; irrigation solution, supplied in a bag for multiple use within a single patient over its; labelled in-use period, is delivered at each irrigation session through a single-use,; three-nozzle spray head with an integral splash shield that is connected to the bag at the; point of use, at an irrigation pressure within 4-15 psi. The hypochlorous acid acts as a; preservative of the solution. No claim is made that it kills microorganisms in the wound or; treats or prevents wound infection.

converged shape: P1 per-patient HOCl bag opened 2026-10-04 updated 2026-10-04 Ask the chairs ↗

Where the argument stands

7/7
chairs have answered
1 abstains · 6 conditional
44
live register rows resting on a
refuted or unconfirmed claim
59
impact reviews
9 absorb · 50 commission
1
pivots — the shape is at
P1 per-patient HOCl bag
38
open requests between
departments

Chairs disagreeing in writing is the output here, not a problem to be resolved. A blocks verdict opens an impact review; it does not kill anything, and no department holds a veto. Killing is Stage 5 arithmetic over verified claims. converged is not an approval either — the only approval in this repo is a human's, at Stage 6.

Where one failure would move several chairs

The system's hypochlorous…A93 · claim 167 · unconfirmedAn HOCl-preserved saline bag ofthe…A100 · claim 174 · unconfirmedAn HOCl-preserved salineirrigation…A103 · claim 177 · unconfirmedIn simulated wound irrigation with…A117 · claim 191 · unconfirmedThe kit's three-nozzle head, fed…A69 · claim 145 · unconfirmedDuring simulated wound irrigation…A72 · claim 148 · unconfirmedIn a single-session clinical-use…A98 · claim 172 · unconfirmedAssumption, not a fact: the…A1 · claim 3 · unconfirmedFDA would classify the P1 head (a…A106 · claim 180 · unconfirmedUnder the P1 shape, at the annual…A114 · claim 188 · unconfirmedFor the P1 per-patient bag, the…A115 · claim 189 · unconfirmedOn 2026-10-04 the openFDA device…A116 · claim 190 · unconfirmedRegulatoryconditionalClinical & ScientificconditionalTechnology & R&DconditionalOperations & NPIconditionalLegal & IPabstainsCommercialconditional
Drag the diagram sideways to pan →
Only the shared dependencies. Left: register rows that two or more answered chairs are standing on, coloured by the tag the candidate file gives that claim. Right: those chairs, coloured by verdict. The 12 most exposed of 94 are drawn, worst tag first. Rows a single department depends on are a local risk and are listed in full under the register below; these are the ones where one refutation moves several chairs at once.
Mermaid source for this diagram
flowchart TD
    A93["The system's hypochlorous…<br><small>A93 · claim 167 · unconfirmed</small>"]
    A100["An HOCl-preserved saline bag of the…<br><small>A100 · claim 174 · unconfirmed</small>"]
    A103["An HOCl-preserved saline irrigation…<br><small>A103 · claim 177 · unconfirmed</small>"]
    A117["In simulated wound irrigation with…<br><small>A117 · claim 191 · unconfirmed</small>"]
    A69["The kit's three-nozzle head, fed…<br><small>A69 · claim 145 · unconfirmed</small>"]
    A72["During simulated wound irrigation…<br><small>A72 · claim 148 · unconfirmed</small>"]
    A98["In a single-session clinical-use…<br><small>A98 · claim 172 · unconfirmed</small>"]
    A1["Assumption, not a fact: the…<br><small>A1 · claim 3 · unconfirmed</small>"]
    A106["FDA would classify the P1 head (a…<br><small>A106 · claim 180 · unconfirmed</small>"]
    A114["Under the P1 shape, at the annual…<br><small>A114 · claim 188 · unconfirmed</small>"]
    A115["For the P1 per-patient bag, the…<br><small>A115 · claim 189 · unconfirmed</small>"]
    A116["On 2026-10-04 the openFDA device…<br><small>A116 · claim 190 · unconfirmed</small>"]
    d_regulatory["Regulatory<br><small>conditional</small>"]
    d_clinical["Clinical & Scientific<br><small>conditional</small>"]
    d_technology["Technology & R&D<br><small>conditional</small>"]
    d_operations-npi["Operations & NPI<br><small>conditional</small>"]
    d_legal-ip["Legal & IP<br><small>abstains</small>"]
    d_commercial["Commercial<br><small>conditional</small>"]
    A93 --> d_regulatory
    A93 --> d_clinical
    A93 --> d_technology
    A93 --> d_operations-npi
    A93 --> d_commercial
    A100 --> d_regulatory
    A100 --> d_clinical
    A100 --> d_technology
    A100 --> d_operations-npi
    A103 --> d_regulatory
    A103 --> d_clinical
    A103 --> d_technology
    A103 --> d_operations-npi
    A117 --> d_clinical
    A117 --> d_technology
    A117 --> d_operations-npi
    A117 --> d_commercial
    A69 --> d_regulatory
    A69 --> d_clinical
    A69 --> d_technology
    A69 --> d_operations-npi
    A72 --> d_clinical
    A72 --> d_technology
    A72 --> d_operations-npi
    A72 --> d_commercial
    A98 --> d_regulatory
    A98 --> d_clinical
    A98 --> d_technology
    A98 --> d_commercial
    A1 --> d_operations-npi
    A1 --> d_legal-ip
    A1 --> d_commercial
    A106 --> d_regulatory
    A106 --> d_operations-npi
    A106 --> d_legal-ip
    A114 --> d_technology
    A114 --> d_operations-npi
    A114 --> d_commercial
    A115 --> d_clinical
    A115 --> d_operations-npi
    A115 --> d_commercial
    A116 --> d_operations-npi
    A116 --> d_legal-ip
    A116 --> d_commercial
    class A93,A100,A103,A117,A69,A72,A98,A1,A106,A114,A115,A116,d_regulatory,d_clinical,d_technology,d_operations-npi,d_commercial t2;

The round table

Each chair answers cold, from its own field, without reading the others' position files. What it states is a verdict, the conditions that would change it, and the requests it raises. A condition bound to a claim is a load-bearing statement, which is why it shows up in the register below.

Regulatory

conditional

backs it only if its conditions hold

  • [C1] Proposed 21 CFR (Title 21 of the Code of Federal Regulations) 878.4019(a)(1) limits antimicrobial preservatives in liquid wound washes to nonsterile or multiple-use single-patient products. The P1 per-patient HOCl bag bag is therefore inside the proposed… claim 119 · verified
  • [C2] The proposed rule places hypochlorous acid in the low-level AMR concern tier, so the P1 per-patient HOCl bag bag inside proposed 878.4019(a) is Class II (FDA device class II) with special controls, not Class III (FDA device class III) PMA (premarket approval). claim 120 · verified
  • [C3] FDA (US Food and Drug Administration)'s proposal states that a use to deliver antimicrobials to the wound may fall outside CDRH (Center for Devices and Radiological Health)'s jurisdiction, and that a wound-treatment claim falls in Class III codes MGR or MDD. This… claim 121 · verified
  • [C4] The cleared HOCl irrigation bag, K232080 (an FDA 510(k) clearance number), is labelled for multiple use within a single patient, so the P1 per-patient HOCl bag bag copies a cleared configuration. claim 122 · verified
  • [C5] As of the latest eCFR issue, proposed 878.4019 has not been codified, so HOCl liquid wound washes remain clearable by 510(k) (premarket notification) under FRO. The bag's launch route rests on this today. Re-asked… claim 12 · verified
  • [C6] Proposed 878.4019(b)(2) would require, for a multiple-use liquid wound wash: continued low bioburden, stability and functionality over the identified use life; a period of preservative… claim 176 · verified
  • …and 6 more in the position file
stated 2026-10-04 against P1 per-patient HOCl bag

Clinical & Scientific

conditional

backs it only if its conditions hold

  • [C3] A randomized controlled trial of at least 100 adults with chronic VLU, DFU (diabetic foot ulcer) or pressure injuries has published a statistically significant improvement in the proportion completely healed at… claim 141 · unconfirmed
  • [C4] NCT07440797 (a ClinicalTrials.gov registration number) (Laboratoires URGO; Vashe vs saline in venous or mixed leg ulcers with inflammatory signs) is randomized and open-label, with an estimated n of 102 and a primary outcome of… claim 142 · verified
  • [C5] In a single-session clinical-use study in adults with chronic wounds, the P1 per-patient HOCl bag system, operated by at least five different clinicians, delivers wound-impact pressure within 4-15 psi in every… claim 172 · unconfirmed
  • [C6] In simulated or clinical use, the P1 per-patient HOCl bag head with its integral shield, driven at maximal grip, reduces splatter on the irrigator's face and chest compared with an unshielded syringe and… claim 173 · unconfirmed
  • [C7] An HOCl-preserved bag of the P1 per-patient HOCl bag formulation, stored between sessions at the upper limit of its labelled storage temperature with ambient light, is spiked with a new head at each of the… claim 174 · unconfirmed
  • [C8] Randomized trials of warmed against room-temperature saline wound irrigation report comfort benefits and, where wound outcomes were measured, no difference in them. One is a laceration… claim 175 · verified
stated 2026-10-04 against P1 per-patient HOCl bag

Market Access

conditional

backs it only if its conditions hold

  • [C4] It would have to be true that 42 CFR 414.22(b)(5) bases practice expense RVUs "entirely on relative practice expense resources". It would also have to be true that 414.22(b)(5)(i) applies… claim 164 · verified
  • [C5] It would have to be true that CMS (Centers for Medicare & Medicaid Services)'s CY (calendar year) 2026 PFS (physician fee schedule) direct practice expense input files list, for CPT (Current Procedural Terminology) 97597 in the nonfacility setting, at least one wound-irrigation or cleansing supply… claim 165 · unconfirmed
  • [C6] It would have to be true that HOCl wound irrigation fluid offered on its own, in a flexible bag labelled for multiple use within a single patient and with no applicator, is a conforming… claim 170 · unconfirmed
  • [C7] It would have to be true that the same tender contains at least one lot whose specification admits a single-use wound-irrigation spray head with an integral splash shield, offered without… claim 171 · unconfirmed
  • [C8] It would have to be true that Medicare Part B (Medicare Part B) makes no payment for an A6260 (a HCPCS code for a supply) wound cleanser dispensed to a beneficiary for use at home between outpatient wound-clinic visits, outside a… claim 166 · unconfirmed
stated 2026-10-04 against P1 per-patient HOCl bag

Technology & R&D

conditional

backs it only if its conditions hold

  • [C1] A hand-compressed flexible IV bag through a 19-gauge outlet reaches a median peak of only about 4 psi (range 2-5.5 psi). The same bag in a 400 mmHg (millimetres of mercury) cuff reaches 6-10 psi. This is why P1 per-patient HOCl bag's… claim 143 · verified
  • [C2] FDA has cleared antiseptic wound-irrigation systems supplied as a container plus applicator and joined by the user at the point of use (K080779, K253445). P1 per-patient HOCl bag's two-sub-assembly architecture… claim 144 · verified
  • [C3] The three-nozzle head, fed from the per-patient bag by its hand-squeezed chamber, delivers a measured impact pressure within 4-15 psi at its working distance, from the first to the last 10%… claim 145 · unconfirmed
  • [C5] The head's fluid path from spike to nozzle exit has no metal in contact with the solution, and solution held in it for one session's point-of-use dwell stays within its labelled FAC… claim 147 · unconfirmed
  • [C6] In simulated irrigation at the head's maximum delivered pressure, emptying one full bag inside the shield, airborne chlorine in the operator's breathing zone stays below the OSHA ceiling in… claim 148 · unconfirmed
  • [C7] (P1 per-patient HOCl bag-a)** The system's HOCl-preserved saline, in its flexible per-patient bag, stays within its labelled FAC and pH specification from the first connection of a head through the labelled… claim 167 · unconfirmed
  • …and 2 more in the position file
stated 2026-10-04 against P1 per-patient HOCl bag

Operations & NPI

conditional

backs it only if its conditions hold

  • [C1] Irrisept K240552 is manufactured as two separately sterilized sub-assemblies joined at the point of use, an aseptically filled Blow-Fill-Seal bottle and EO-sterilized pouched accessories.… claim 124 · verified
  • [C2] The cleared HOCl bag precedent (K232080) is sterile LLDPE film in a foil pouch, tested to ICH Q1A(R2), ISO (International Organization for Standardization) 10993-1, ISO 11607, ISO 11737 and USP <85>/<51>/<71>/<61>/<62>. The open half… claim 125 · verified
  • [C3] The unopened HOCl-preserved bag can be labelled for controlled room temperature through its shelf life on ICH long-term data, so no cold chain is needed. This is unchanged for P1 per-patient HOCl bag. Its… claim 126 · unconfirmed
  • [C4] Every material wetted by HOCl in storage keeps the solution in its FAC and USP <51> specification and sheds no metal. Under P1 per-patient HOCl bag that means the bag film, the port, and any re-entry part that… claim 127 · unconfirmed
  • [C5] Sterile HOCl in flexible bags can be sourced under ISO 13485 from at least two independent suppliers that do not sell HOCl wound cleansers in the US. Under P1 per-patient HOCl bag the requirement is harder: the… claim 128 · unconfirmed
  • [C6] Under P1 per-patient HOCl bag, the fully loaded cost of one session is below the per-session price. One session means one single-use head assembly plus one per-patient bag divided by the sessions it actually… claim 188 · unconfirmed
  • …and 6 more in the position file
stated 2026-10-04 against P1 per-patient HOCl bag

Commercial

conditional

backs it only if its conditions hold

  • [C1] The referrer, or a party it can bring in, holds or can license the right to make the Aquaceso hardware and to sell it with an HOCl solution. Under P1 per-patient HOCl bag this matters in a narrower way. P1 per-patient HOCl bag's… claim 3 · unconfirmed
  • [C2] US hospital, outpatient wound-clinic, SNF and home health purchasers pay more per irrigation session for P1 per-patient HOCl bag than their per-session cost with saline and a syringe, or with an HOCl bottle… claim 161 · unconfirmed
  • [C3] US facility and agency purchasers accept onto formulary a single-use irrigation head that connects only to its own maker's HOCl bag, without requiring it to fit the spike ports of bags they… claim 162 · unconfirmed
  • [C4] In US outpatient wound clinics, the interval between one chronic-wound patient's successive visits is no longer than the in-use period labelled on the one cleared HOCl irrigation bag… claim 163 · unconfirmed
  • [C5] The VA Federal Supply Schedule entry for contract V797D-50441 lists a per-unit Vashe contract price with a fill volume. Under P1 per-patient HOCl bag this is the contract-level price the bag would be… claim 131 · unconfirmed
  • [C6] Lot 50 of Region Nordjylland's joint wound tender (TED 549630-2024) awards on price plus at least one weighted non-price criterion. claim 132 · unconfirmed
  • …and 2 more in the position file
stated 2026-10-04 against P1 per-patient HOCl bag

How the shape changed

P1 — per-patient HOCl bag, single-use pressurised head joined at use, no warming — 2026-10-04 (a redesign, flagged)

Flag for the owner. This is the one pivot this /pursue run's budget allows, and it is now spent. It changes intended_use:. It was taken at loop turn 1 of 3. It makes all seven positions stale.

What failed, and what it cost

When a registered statement comes back refuted or unconfirmed, an impact review fires. It has exactly three available outcomes and check_loop.py refuses a record that invents a fourth. Open one for the reasoning.

IR-1 claim 3unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 3unconfirmed. The referrer, or a party the referrer can bring in, holds or can license the right to make the Aquaceso hardware and to sell it co-packaged with an HOCl solution.
  • What the check found: Nothing was checked, because nothing can be. The Verifier recorded that no connector answers who holds or can license rights in a design, and no DK connector exists. Legal & IP's trade-name patent sweep for "aquaceso" matched nothing, which shows only that patents do not carry trade names (REQ-0224 Ask the referrer note). claim 2unconfirmed records that no regulatory record for Aquaceso has been found.
  • Who depended on it: A1 Assumption. Commercial (C1, its cheapest move), Legal & IP (C13) and Operations & NPI. Under P1 per-patient HOCl bag, Technology & R&D as well: whether Aquaceso's head already holds 4-15 psi decides whether P1 per-patient HOCl bag's pressurisation element is new design or existing hardware.
  • What it costs: If false, there is no existing head and shield to put on an HOCl bag. The P1 per-patient HOCl bag head assembly becomes a new hardware programme with its own design, tooling, verification and route, and Aquaceso turns from a dependency into prior art the new head must differ from.
  • Outcome: commission
  • Because: unconfirmed here is a gap that only the referrer can close. REQ-0224 Ask the referrer (Legal & IP → front end) and REQ-0208 Obtain from the referrer (Technology → front end) ask exactly this, and the front end accepted both at turn 1. They go to the referrer through the owner as one ask, a human act, carrying the questions only. P1 per-patient HOCl bag needs no new request: REQ-0208 Obtain from the referrer item (1) already asks how Aquaceso generates and holds pressure. The row is settled when the referrer's written answer is filed in the repo and named on both requests. Until then it stays live.
IR-2 claim 62unconfirmed came back unconfirmed — 2026-10-04 commission
IR-3 claim 40unconfirmed came back unconfirmed — 2026-10-04 absorb
IR-4 claim 44unconfirmed came back unconfirmed — 2026-10-04 commission
IR-5 claim 42unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 42unconfirmed. The IWII 2022 consensus discusses hypochlorous acid as an option for wound cleansing.
  • What the check found: At the first pass no connector retrieved the IWII document. The research lane has since fetched it, and claims 86 and 87 were verified on that PDF. claim 87verified carries a Verifier note that the same document lists HOCl-preserved super-oxidised solutions separately. No claim carries that passage.
  • Who depended on it: A12 International Wound Infection Institute. Clinical & Scientific (a consensus anchor for adoption) and Commercial (the quality criteria of a Danish tender).
  • What it costs: If false, clinician adoption has no consensus-document anchor, and A11 "The efficacy of combination of sodium… becomes the only clinical argument.
  • Outcome: commission
  • Because: The gap was retrieval, and the document is now in hand, so this is cheap to settle. Raised REQ-0231 From the IWII 2022 consensus PDF already… (front end → research): quote the HOCl passages verbatim with page numbers and any grading. The claim can then be restated on the text and verified.
IR-6 claim 47unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 47unconfirmed. Maragakis et al., JAMA 2004, report a multidrug-resistant A. baumannii outbreak at Johns Hopkins tied to pulsatile lavage, with the organism on disposable lavage parts and on surfaces of the treatment area.
  • What the check found: The citation matches (PMID (PubMed identifier) 15613669). The abstract reports 11 patients at a 1000-bed tertiary hospital in Baltimore, pulsatile lavage as a risk factor (OR 36), and the strain recovered "from multiple surfaces in the wound care area". Two details are not in it: the hospital's name, and the organism on disposable lavage parts. The restatement without them was checked separately and is claim 94verified.
  • Who depended on it: A13 Maragakis LL et al.. Clinical & Scientific, Operations & NPI and Commercial, for the splash shield's documented harm. Twin: A32 Restates claim 47 without the two… (claim 94verified).
  • What it costs: If false, the shield has no documented harm from irrigation spray to point to.
  • Outcome: absorb
  • Because: What depended on claim 47unconfirmed was one documented case of harm from irrigation spray. That survives on claim 94verified, the same paper without the two unsupported details, and claim 94verified is what the dependants should cite. The two dropped details carried nothing: neither the hospital's name nor where on the lavage set the organism was found changes what the shield is for. A32 Restates claim 47 without the two…'s caveat still applies. The outbreak was pulsatile lavage, not 4-15 psi irrigation. Row: absorbed by IR-6 claim 47 came back unconfirmed.
IR-7 claim 50unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 50unconfirmed. It is not established that HOCl can be warmed in the bag for an irrigation session and stay inside its free-chlorine and preservative-efficacy specification, or that the materials tolerate it.
  • What the check found: It is an open design question. The claim itself says no data exist, and no connector produces bench data. The verified findings around it point against warming: claim 96verified (200 ppm HOCl at pH 6 is unstable at 25 C and above; store below 10 C) and claim 97verified (neutral electrolysed water lost its chlorine at 25 C over 52 days). claim 98verified is a different, alkaline chemistry. And claim 154verified: every independent claim of CareFusion's US 12,178,977, which runs to about 2041, recites a warming component.
  • Who depended on it: A14 Open design question. Technology & R&D (intention item 4, the one item where it could not say the physics favours the design), Operations & NPI (whether the unit carries heating or needs a reusable warmer), Regulatory (point-of-use stability data), Legal & IP (A37 FTO field lead, the CareFusion threat), and the referred Aquaceso feature itself.
  • What it costs: If warming cannot be held, either warming is dropped, which changes the referred product, or the point-of-use specification fails the 510(k) stability data.
  • Outcome: absorb
  • Because: Every dependant listed needs warming to be in the kit. P0 the original shape's own mechanism: carried warming only "as an option to be proven, not as a feature", and Operations & NPI already read P0 the original shape as launching without it. So no element of the launch shape rested on claim
    1. What does not survive is the option, and with it the referred device's warming. That was not decided by this review. P1 per-patient HOCl bag removes warming from the scope as part of a redesign recorded below, on verified findings (claims 96, 97 and 154) and three chairs' convergence, not on this failing tag. Commissioning claim 50unconfirmed now (REQ-0209 Find published measurements of free…'s warm-storage half, A70 An HOCl-preserved saline irrigation…'s bench test) would pay to prove a feature no current shape has, so this review does not. If a later shape brings warming back, claim 50unconfirmed, REQ-0209 Find published measurements of free… and REQ-0210 Is warming the irrigant to about body… come back with it. Row: superseded by P1 per-patient HOCl bag, and claim 50unconfirmed carries the P1 per-patient HOCl bag note.
IR-8 claim 21unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 21unconfirmed. Under the MDR (medical device report), an HOCl wound irrigation solution or kit is Class IIb (Rule 4 or 21), or Class III under Rule 14 if HOCl is treated as a medicinal substance.
  • What the check found: The US connectors refuse an EU claim, and EUR-Lex returned HTTP 202 at that pass, so nothing was checked. Regulatory has since read the EUR-Lex text and found Rules 4, 14 and 21 as quoted. The legal text is in reach. How a notified body applies it to HOCl is not.
  • Who depended on it: A17 Generator's belief. Regulatory (EU) and Commercial. Twins: A41 Bears on claim 22 with an SEC filing rather… and A59 Under Regulation.
  • What it costs: If HOCl products land in Class III under Rule 14, the Danish route becomes a Class III programme with a medicinal-substance consultation and a heavier clinical evaluation.
  • Outcome: commission
  • Because: This is the jurisdiction gap the turn-1 routing said to commission. REQ-0217 Retrieve EU MDR notified-body certificates… (Regulatory → research) asks for notified-body certificates or EUDAMED records for HOCl irrigants, and for the MDCG text on Rule 14 against Rule 4 for a substance present only as a preservative. Reused. P1 per-patient HOCl bag does not change this, because the label is preservative-only in both shapes.
IR-9 claim 26unconfirmed came back unconfirmed — 2026-10-04 commission
IR-10 claim 116unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 116unconfirmed. Whether US wound clinicians believe HOCl cleansing is clinically superior to saline, the belief demand rests on.
  • What the check found: The adoption invocation returned unverifiable, because the claim asserts what clinicians would do. Evidence class 3. Its revealed-behaviour twins were checked in their own right: claim 93verified (no eligible HOCl RCT in the 2022 review), claim 107verified (one US burn centre used HOCl as the initial antiseptic in 11.3% of grafted patients), claim 87verified (the consensus line against older antiseptics, which does not cover HOCl). The nurse survey in claim 108verified is Canadian.
  • Who depended on it: A30 Stakeholder question. Clinical & Scientific and Commercial. Twins: A11 "The efficacy of combination of sodium… and A65 A randomized controlled trial of at least….
  • What it costs: If false, nothing gives a buyer a reason to pay for the HOCl half, and the product competes as a saline irrigation device with a splash shield. Under P1 per-patient HOCl bag HOCl has a job the label can state, preserving a bag that is entered more than once, but every incumbent HOCl bag has the same job, so it earns no premium over them.
  • Outcome: commission
  • Because: Class 3, so only primary research can settle it. Raised REQ-0226 Design the primary research that would… (front end → Commercial) to design that research and first check for a published US survey. The row stays live.
IR-11 claim 51unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 51unconfirmed. Spraying HOCl through three nozzles makes an aerosol, HOCl at acidic pH can release chlorine, and clinician inhalation exposure with this kit is uncharacterized.
  • What the check found: No exposure data exist and no connector produces them. The two analogies in the file are verified but distant: claim 99verified (no analogous damage in fibroblasts after 3 minutes of aerosolised 300 ppm HOCl; cytotoxicity after four 9-minute exposures at 500 ppm; dry fog on cultured cells) and claim 100verified (spraying sodium hypochlorite for surface disinfection kept chlorine gas below detection). The bench twins, A72 During simulated wound irrigation with the… (claim 148unconfirmed) and A64 In simulated or clinical use (claim 140unconfirmed), have not been run.
  • Who depended on it: A34 Open safety question. Operations & NPI, Regulatory and Commercial. Through the twins, Technology & R&D (A72 During simulated wound irrigation with the…) and Clinical & Scientific (A64 In simulated or clinical use).
  • What it costs: If exposure matters, the working-environment proposition inverts, because the shield gathers the aerosol at face height. Exposure data become part of the 510(k), and the shield or nozzles may change before tooling.
  • Outcome: commission
  • Because: The gap is in the world: no measurement exists. Two chairs have set different pass marks for the same measurement. Both say that what exposure means for staff belongs to Operations & NPI, and Operations bound no condition on it. Raised REQ-0227 Own the staff-exposure pass mark for HOCl… (front end → Operations & NPI): own the pass mark and specify the breathing-zone study. P1 per-patient HOCl bag's pressurisation element does not change the question. It sets the pressure the study must run at.
IR-12 claim 112unconfirmed came back unconfirmed — 2026-10-04 commission
IR-13 claim 113unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 113unconfirmed. Region Nordjylland's joint wound tender (TED 549630-2024) has a lot of its own, lot 50, for HOCl wound irrigation fluid, beside lots for non-HOCl fluid and NaCl.
  • What the check found: The content was re-retrieved cold from TED and matches: 83 lots, including lots 49, 50, 51 and 53 as named. It is held unconfirmed on jurisdiction alone.
  • Who depended on it: A42 Revealed-behaviour twin for claims 25-26. Commercial (DK) and Market Access.
  • What it costs: If false, the only counter-evidence to A18 Assumption is gone.
  • Outcome: commission
  • Because: The content matched; what is missing is a tag route for DK. REQ-0201 For Region Nordjylland's joint wound tender asks for the full notice and tender documents. Reused.
IR-14 claim 126unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 126unconfirmed. HOCl-preserved saline in a flexible bag can be labelled for room-temperature storage through its shelf life, so no cold chain is needed.
  • What the check found: A capability claim about a formulation and bag that do not exist, so no connector can answer it. The nearest record, claim 125verified, lists ICH Q1A stability testing for K232080 but does not state its labelled storage condition.
  • Who depended on it: A50 An HOCl-preserved saline of the kind the…. Operations & NPI (C3) and Technology & R&D (real-time stability is its long pole).
  • What it costs: If false, distribution needs a cold chain, and the stock-on-the-shelf model breaks in every setting, home health included. Under P1 per-patient HOCl bag the bag is also kept open on a ward or in a home for its in-use period, so the question gains an in-use half.
  • Outcome: commission
  • Because: It resolves only on the product's own long-term data, which takes calendar time. There is a cheaper first step: whether incumbents already label their HOCl bags for room temperature. Raised REQ-0228 Retrieve the labelled storage condition (front end → research): the labelled storage, shelf life and in-use period of every cleared HOCl bag or large container. REQ-0218 Can an HOCl-preserved saline irrigation bag… (Regulatory → Technology) carries the in-use half. The row stays live.
IR-15 claim 127unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 127unconfirmed. Every HOCl-wetted material keeps the solution in its free-chlorine specification, passes USP 51, sheds no metal ions, and includes no metal part of the kind recall Z-2275-2026 records.
  • What the check found: No product and no bench data exist, and the materials have not been chosen. The recall it names exists. Z-2275-2026 appears in a recall scan with the reason "corrosion of the internal metallic spring within the sprayer component".
  • Who depended on it: A51 Every HOCl-wetted material in the kit. Operations & NPI (C4), Technology & R&D and Regulatory. Twin: A71 The kit's fluid path from bag port to….
  • What it costs: The preservative fails in the product, the 510(k) stability section fails, and the part is redesigned and the stability clock restarted.
  • Outcome: commission
  • Because: REQ-0209 Find published measurements of free… (Technology → research) asks for published compatibility data at 100-500 ppm for the polymers, elastomers and steel in irrigation fluid paths. REQ-0199 For the P0 kit (Operations → Technology) item (c) asks for the wetted-materials list. Both reused. P1 per-patient HOCl bag narrows the question. The head is stored dry and joined at use, so shelf-life contact is limited to the bag film and port, and the head sees session-length contact. P1 per-patient HOCl bag's squeeze chamber needs a check valve, which is where a metal spring would sit, and that is the failure in Z-2275-2026. So "no metal in the wetted path" is written into P1 per-patient HOCl bag's mechanism:.
IR-16 claim 128unconfirmed came back unconfirmed — 2026-10-04 commission
IR-17 claim 129unconfirmed came back unconfirmed — 2026-10-04 commission
IR-18 claim 130unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 130unconfirmed. openFDA recalls from 2016 to 2026 number 57 under FRO, 6 under FQH and 14 under KYZ, and the named irrigant and kit recalls fall into four process-failure classes.
  • What the check found: The content matches. Counts were untruncated, and every named record and reason was found as stated. It is unconfirmed because a recall sweep returns a scan result that cannot carry a tag. Which records count as irrigants and kits is the drafter's selection.
  • Who depended on it: A54 openFDA device recalls initiated 2016-01-01…. Operations & NPI (C7), for the validation list it sets: sterility assurance, sterile-barrier integrity, distribution temperature excursion, and HOCl-to-component incompatibility.
  • What it costs: If false, that validation list loses its record.
  • Outcome: absorb
  • Because: Operations' list depends on the recall records existing with the stated reasons. The Verifier read them and found them as stated; the tag is unconfirmed only because a scan cannot carry one. A design-input list does not need a tag to be used as one, and nothing in P0 the original shape's or P1 per-patient HOCl bag's shape rests on the counts. The dependant survives. Row: absorbed by IR-18 claim 130 came back unconfirmed.
IR-19 claim 131unconfirmed came back unconfirmed — 2026-10-04 commission
IR-20 claim 132unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 132unconfirmed. Lot 50 is awarded on price together with at least one weighted non-price criterion.
  • What the check found: Held unconfirmed on jurisdiction alone. Nothing about the tender was checked.
  • Who depended on it: A56 Lot 50. Commercial (C4) and Market Access (DK).
  • What it costs: If false, the hardware's differentiation earns nothing in the one Danish HOCl lot.
  • Outcome: commission
  • Because: REQ-0201 For Region Nordjylland's joint wound tender part (b) asks for lot 50's award criteria and weightings verbatim. Reused.
IR-21 claim 133unconfirmed came back unconfirmed — 2026-10-04 commission
IR-22 claim 134unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 134unconfirmed. TED award notice 705177-2025 names lot 50's winner, and the lot's contract runs 48 months.
  • What the check found: Held unconfirmed on jurisdiction alone. claim 116unconfirmed's note already records that the award notice's API fields did not establish the winner. At turn 1 this row was listed among those where verified would be the bad news. It did not come back verified.
  • Who depended on it: A58 TED contract award notice 705177-2025 names…. Commercial (C6) and Market Access (DK).
  • What it costs: If true, the referrer's home market has a dated wait, possibly behind a Mölnlycke company, until about 2029.
  • Outcome: commission
  • Because: REQ-0201 For Region Nordjylland's joint wound tender parts (c) and (d) ask for the awardee and the framework term. Reused.
IR-23 claim 135unconfirmed came back unconfirmed — 2026-10-04 commission
IR-24 claim 136unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 136unconfirmed. Under 42 CFR 412.2 the IPPS payment is the total payment for inpatient operating costs, so a wound-cleansing supply on an inpatient is paid inside the MS-DRG and not separately.
  • What the check found: The cited text is right and the conclusion is not in it. Neither section names supplies. Whether such a supply is a routine or ancillary operating cost is Provider Reimbursement Manual material that no connector reads. 412.2(f)(9) also provides a new-technology add-on, so "not separately paid" holds only if the kit could never qualify.
  • Who depended on it: A60 Under 42 CFR 412.2. Market Access (C1) and Commercial (the single-buyer model).
  • What it costs: If false, inpatients have a payment route nobody has costed. Nothing stops working.
  • Outcome: absorb
  • Because: The only dependant is the completeness of Market Access's inpatient payment picture. Every way claim 136unconfirmed can be wrong adds money, a separately payable supply or a new-technology payment, and none removes any. The single-buyer model survives as the conservative case. The turn-1 routing said this row would owe an absorb, not a pivot. Row: absorbed by IR-24 claim 136 came back unconfirmed.
IR-25 claim 137unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 137unconfirmed. 42 CFR 419.66(b)(4)(ii) excludes "a material or supply furnished incident to a service" from device pass-through, so pass-through does not reach this kit.
  • What the check found: The quotation is exact and in force. The conclusion is a CMS determination the text does not make. 419.66(b)(3) itself contemplates a device "applied in or on a wound", and CMS's pass-through decision record is out of reach.
  • Who depended on it: A61 42 CFR 419.66. Market Access (C2), Commercial, and Clinical & Scientific (the substantial-clinical-improvement showing pass-through would need).
  • What it costs: If false, a time-limited separate OPPS payment becomes conceivable. Nothing breaks.
  • Outcome: absorb
  • Because: As with IR-24 claim 136 came back unconfirmed, every way this can be wrong gains a route. Using that route would need a substantial-clinical-improvement showing that the file cannot make (claim 93verified). Market Access's finding, that nothing on the payment side lifts the price ceiling above the bundle, survives as the conservative case. Row: absorbed by IR-25 claim 137 came back unconfirmed.
IR-26 claim 138unconfirmed came back unconfirmed — 2026-10-04 commission
IR-27 claim 139unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 139unconfirmed. In a single-session clinical-use study the kit delivered 4-15 psi and removed slough and debris no less than a 35 mL syringe with a 19G angiocatheter.
  • What the check found: The study has not been run, and it needs a built kit.
  • Who depended on it: A63 In a single-session clinical-use study in…. Clinical & Scientific (C1), Technology & R&D and Commercial.
  • What it costs: If false, the product is worse than the cheapest comparator at the one thing its label claims, and the performance clause in intended_use: reverses.
  • Outcome: commission
  • Because: The gap is in the world. The order is fixed: the bench measurement first, then this study. REQ-0203 For the P0 three-nozzle head fed from the… (Clinical → Technology) asks for the bench measurement. REQ-0204 Could an FRO 510 (Clinical → Regulatory) asks whether FDA needs the study for the 510(k), or only buyers do. Both reused. The study itself can be requested once a prototype exists. The claim says "the P0 the original shape kit". P1 per-patient HOCl bag keeps the head, the shield, the pressure clause and the comparator, so the proposition carries over. Clinical should reword it when it re-states.
IR-28 claim 140unconfirmed came back unconfirmed — 2026-10-04 commission
IR-29 claim 141unconfirmed came back unconfirmed — 2026-10-04 commission
IR-30 claim 145unconfirmed came back unconfirmed — 2026-10-04 commission
IR-31 claim 146unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 146unconfirmed. HOCl-preserved saline in the kit's bag at 37 C for 60 minutes stays inside its free-chlorine and pH specification.
  • What the check found: The bench test has not been run.
  • Who depended on it: A70 An HOCl-preserved saline irrigation…. Technology & R&D (C4), Operations & NPI and Regulatory.
  • What it costs: If false, in-session warming cannot be kept with an HOCl irrigant.
  • Outcome: absorb
  • Because: Each dependant needs warming to be in the kit, and P1 per-patient HOCl bag does not warm. The reasoning is IR-7 claim 50 came back unconfirmed's: this review does not commission a test of a feature no current shape has. The three dependants survive because none of them is needed by a kit that does not warm. If warming returns in a later shape, this row and its test return with it. Row: superseded by P1 per-patient HOCl bag, and claim 146unconfirmed carries the P1 per-patient HOCl bag note.
IR-32 claim 147unconfirmed came back unconfirmed — 2026-10-04 commission
IR-33 claim 148unconfirmed came back unconfirmed — 2026-10-04 commission
IR-34 claim 153refuted came back refuted — 2026-10-04 commission
  • The statement: claim 153refuted. Independent claim 19unconfirmed of US 11,083,835 and independent claim 38unconfirmed of US 12,208,226, as described, do not recite a squeeze bottle or a syringe as the irrigation source.
  • What the check found: The Verifier read both USPTO (United States Patent and Trademark Office) grants. US 11,083,835 has 20 claims and its independent claims are 1 and 8. Its claim 19unconfirmed is a dependent claim about nozzle-tip distance, with no dividing structure. US 12,208,226 has 20 claims, so there is no claim 38unconfirmed. Its independent claims are 1, 10 and 20. The numbers and descriptions seem to come from a different document, perhaps an application publication; that was not traced. What does hold, and it cuts against the kit: none of the real independent claims recites a squeeze bottle or a syringe. They recite a "fluid source" or an "irrigation source connector". So their scope is wider than a bottle.
  • Who depended on it: A77 Independent claim 19 of US 11,083,835 B2. Legal & IP (C5, and its named blocks trigger: A76 US 8,672,904 B1 past launch and a counsel read finding that the claims read on the kit) and Technology & R&D. Twin: A16 FTO, device: US 8,002,757, "Splash shield….
  • What it costs: The refutation removes the claims Legal pointed counsel at. It does not remove the threat A77 Independent claim 19 of US 11,083,835 B2 was registered for, because on the real claims the shield claims are not limited to bottles. Read with claim 152verified (the family's terms end about 2030-08 to 2032-04, none past 2032) and claim 151verified (US 8,002,757 ended about 2022-10), the hardware exposure is a window that closes around April 2032, not 2041. A US launch of the head and shield before then needs counsel to read the real independent claims, or a design-around, or a wait. P1 per-patient HOCl bag does not change this: its head still has an integral shield on a line from a fluid source.
  • Outcome: commission
  • Because: This is the exception the protocol names. The refutation is about our lookup: the claim numbers and descriptions came from a document other than the grants. It is not about the world, where the Verifier's finding points the same way the claim did. So it is commissioned once, under REQ-0221 For each named in-force family (Legal & IP → research), which already asks for the granted independent claims of US 11,083,835, 12,208,226 and 8,672,904 verbatim. When Legal & IP re-states for P1 per-patient HOCl bag, it should rebind C5 to the real claim numbers ('835 claims 1 and 8; '226 claims 1, 10 and 20). Legal's blocks trigger now turns on the launch date against about 2032-04, not on a 2041 term. There will be no second commission: if the rebound claim comes back refuted, that is a finding.
IR-35 claim 155unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 155unconfirmed. Apart from the named families, no in-force US patent or published application claims a bag-fed multi-nozzle wound spray head, a shield integral with one, or an HOCl-plus-applicator kit.
  • What the check found: A negative landscape claim, and sweeps cannot verify an absence. The sweeps run are recorded as leads, and one of them shows the vocabulary limit: "splash shield" under A61M3/02 missed the known Schultz family.
  • Who depended on it: A79 Apart from the patent families named in…. Legal & IP (C7), Technology & R&D and Commercial.
  • What it costs: If false, FTO (freedom to operate) is blocked on the hardware or the combination by a holder nobody has named.
  • Outcome: commission
  • Because: Expected back unconfirmed, and routed in advance to REQ-0212 Run a recorded, the recorded landscape search. Reused. P1 per-patient HOCl bag adds two elements for that search to cover: the squeeze chamber with its check valve in the head, and a head made to fit only one bag.
IR-36 claim 158unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 158unconfirmed. openFDA lists 35 FRO clearances, 2 FQH (both BD Surgiphor) and no KYZ clearances from 2024-10-04 to 2026-10-04.
  • What the check found: The content matches exactly, untruncated. It is unconfirmed because a clearance sweep returns a scan result that cannot carry a tag.
  • Who depended on it: A82 openFDA lists 35 510. Legal & IP (C10, the fast-follower rate) and Commercial (defensibility).
  • What it costs: If false, Legal's reading that IP is a thin part of defensibility loses its measured basis.
  • Outcome: absorb
  • Because: Legal's reading needs the clearance record to exist as stated, and the Verifier found it as stated. claim 76verified and claim 77verified show the same continuing entry independently. Nothing in the shape rests on the count. Row: absorbed by IR-36 claim 158 came back unconfirmed.
IR-37 claim 159unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 159unconfirmed. No European patent in force in Denmark, and no pending EP application, claims the head, an integral shield, the HOCl solution or the kit.
  • What the check found: No connector reports EP or DK validation or in-force status, and no EP landscape search exists. Expected back unconfirmed.
  • Who depended on it: A83 No granted European patent in force in…. Legal & IP (C11, EU/DK) and Commercial (DK).
  • What it costs: If false, the referrer's home market has an FTO block that the US work says nothing about.
  • Outcome: commission
  • Because: REQ-0222 EP/DK counterpart search for the referrer's… (Legal & IP → research) asks for the EP/DK counterpart search, including the 2026 Heraeus applications. Reused.
IR-38 claim 160unconfirmed came back unconfirmed — 2026-10-04 absorb
  • The statement: claim 160unconfirmed. EPC Article 54 defines novelty against everything made public before filing, and Article 55 disregards only an evident abuse or an officially recognised exhibition in the six months before filing.
  • What the check found: Not checked. The EPC is not an EU legal act, so EUR-Lex does not hold it, and no connector reads EPO (European Patent Office) texts.
  • Who depended on it: A84 Under Article 54 EPC an invention is new…. Legal & IP (C12, the warning that a non-confidential disclosure of the HOCl variant may already have cost European novelty) and Commercial (what the referrer could own).
  • What it costs: If false, for example if the EPC had a grace period for the inventor's own disclosure, Legal's warning would soften.
  • Outcome: absorb
  • Because: The row bears on what the referrer could own, not on whether P1 per-patient HOCl bag can be sold. Every way the claim could be wrong softens a warning, which is a gain. The dependant that actually matters is the referrer's disclosure history, a fact only the referrer holds, and REQ-0224 Ask the referrer asks for it (IR-1 claim 3 came back unconfirmed). Row: absorbed by IR-38 claim 160 came back unconfirmed.
IR-39 claim 161unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 161unconfirmed. US hospital, wound-clinic, SNF and home health purchasers pay more per session for P1 per-patient HOCl bag (one head plus a share of a bag) than for saline and a 35 mL syringe, or an HOCl bottle, when it saves set-up time, PPE and splash clean-up.
  • What the check found: The adoption connector returned "unverifiable", by design. The Verifier found no purchasing study, survey or interview attached. This is evidence class 3, and no record exists to retrieve. The PPE leg has a further gap: whether a shield relieves the OSHA mask-and-eye-protection requirement is unanswered (REQ-0216 Does 29 CFR 1910.1030, carried as REQ-0241 Carried from REQ-0216).
  • Who depended on it: A87 US hospital. Commercial (C2, the revenue premise of P1 per-patient HOCl bag), Market Access (the bundle sets the ceiling) and Operations & NPI (the price side of A114). Unregistered twin: claim 117unconfirmed.
  • What it costs: If false, the head, which is P1 per-patient HOCl bag's only per-session revenue, is priced as a commodity accessory. The per-session margin rests on nothing, and A114's inequality has no price to be tested against.
  • Outcome: commission
  • Because: unconfirmed here is a gap no connector will ever close. Only primary buyer research settles it. REQ-0225 Design is answered: Commercial's position holds the study design (strata, sample, instrument, a pre-fixed yes criterion) for claims 161 and 162. Fielding it contacts buyers outside the organisation, so it is the owner's decision. REQ-0244 For P1 (the price and volumes the money model assumes) and REQ-0241 Carried from REQ-0216 (the PPE leg) are open and reused. The row stays live.
IR-40 claim 162unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 162unconfirmed. US value-analysis committees and GPO buyers accept onto formulary a single-use head that connects only to its own maker's HOCl bag, without requiring it to fit the spike ports of bags they already stock. This is P1 per-patient HOCl bag-b.
  • What the check found: The adoption connector returned "unverifiable", by design, and no formulary, value-analysis or GPO evidence is attached. This is evidence class 3.
  • Who depended on it: A88 US facility and agency purchasers. Commercial (C3), Operations & NPI (the keyed port makes the bag a custom part, A52 Sterile HOCl wound-irrigation solution… and A116), Technology & R&D (keying and reclosure share one connector, A94 The per-patient bag's access port accepts a…) and Legal & IP (the keyed connector may be P1 per-patient HOCl bag's one ownable feature, A119).
  • What it costs: If false, buyers want a head that fits any bag. Then the bag is not pulled through, the head is sold for any bag (neighbour (a)), and the bag must win alone as a parity HOCl solution. The reason P1 per-patient HOCl bag keeps the head single-use and keyed is gone.
  • Outcome: commission
  • Because: A gap, not a finding: nobody has asked a buyer. REQ-0225 Design's study design covers this claim, and fielding it is the owner's decision. Two further parts are open. REQ-0234 In the P1 reference design (Commercial → Technology) asks whether a keyed connector can be built at all. REQ-0255 P1's mechanism makes the single-use head…, raised this turn, asks Regulatory whether FDA would accept one; that is P1 per-patient HOCl bag-c, owed to /assess. The condition under which this changes: if the fielded study answers no, the honest answer is a change of shape toward neighbour (a). Under the spent budget that review would be recorded as commission, and the owner would decide the next shape. It has not failed. It has not been asked.
IR-41 claim 163unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 163unconfirmed. In US outpatient wound clinics, the median interval between one chronic-wound patient's visits, in a published US study, is no longer than the in-use period labelled on Puracyn Plus (K232080).
  • What the check found: Neither half was resolved. The Verifier read the K232080 510(k) summary (6 pages, text layer), which states no in-use period, discard time or day count. claim 169verified records the same absence in K251757. No connector holds either product's label or IFU (instructions for use). The visit-interval half names no study, so there was nothing to re-retrieve, and a literature sweep carries no tag.
  • Who depended on it: A89 In US outpatient wound clinics the interval…. Commercial (C4), Operations & NPI (C8, A115, the four-setting version) and Market Access (where the bag sits between visits decides who pays for it, A92 Medicare Part B makes no payment for a…).
  • What it costs: If false, in the outpatient clinic each session costs a head plus a whole bag. That is P0 the original shape's economics with the waste made visible, in the setting where most Medicare FFS (fee-for-service) selective debridement happens.
  • Outcome: commission
  • Because: A gap in the check. With both summaries silent, the comparator can come only from a label or IFU. REQ-0228 Retrieve the labelled storage condition (front end → research) asks for exactly that for every cleared HOCl bag, and is reused. REQ-0245 For each intended-use setting (Operations → Clinical) asks for published session intervals by setting, and is reused. Commercial needs to name the US study in the claim's own terms. Context, not evidence for P1 per-patient HOCl bag's period: claim 178verified shows Vashe Plus tested a simulated 7-day multi-use period, in bottles. Whether this setting appears in the bag's label at all depends on the owner's custody decision.
IR-42 claim 165unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 165unconfirmed. The CMS CY 2026 PFS direct practice-expense inputs list, for CPT 97597 in the nonfacility setting, at least one irrigation or cleansing supply with a CMS price.
  • What the check found: No connector reads the direct PE input files. The cached RVU (relative value unit) file shows 97597 active (status A) with nonfacility PE of 2.24 RVUs ($75.19 at CF 33.5675). That is an aggregate allowance, not its supply items.
  • Who depended on it: A91 The CMS calendar-year 2026 Physician Fee…. Market Access (C5) and Commercial (the cost-in-use comparison).
  • What it costs: On the row's own column, nothing in P1 per-patient HOCl bag breaks. If false, P1 per-patient HOCl bag displaces a supply line CMS never itemised, and the comparator price becomes less visible.
  • Outcome: commission
  • Because: Routed before the tag as a tooling gap, and the routing is applied. An absorb would also fit the row's column, and that is recorded here, not acted on. The check is one public CMS file. Raised REQ-0251 Retrieve the CMS calendar-year 2026… (front end → research) to quote the 97597 nonfacility supply inputs.
IR-43 claim 166unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 166unconfirmed. Medicare Part B makes no payment for an A6260 wound cleanser dispensed for home use between outpatient wound-clinic visits, outside a SNF Part A stay or a home health plan of care.
  • What the check found: Half of it holds. Policy article A54563 (version 54, effective 2024-12-05), re-retrieved from the CMS coverage API, lists "Wound cleansers (A6260)" among items non-covered under the surgical dressing benefit. A6260 exists, and it has no row in the cached payment or DMEPOS (durable medical equipment, prosthetics, orthotics and supplies) fee files. The other half, that no other Part B benefit covers A6260, is a negative across every benefit, and no connector answers it. The coverage lookup's refuted reflects a cache-linkage gap, not a search of every benefit.
  • Who depended on it: A92 Medicare Part B makes no payment for a…. Market Access (C8), Commercial (C4's outpatient reading) and Operations & NPI (custody, REQ-0235 For the P1 per-patient HOCl bag).
  • What it costs: A threat row. If true, a P1 per-patient HOCl bag bag that goes home with an outpatient leaves both provider budgets, and the patient pays, or a non-Medicare plan if one does (REQ-0202 Outside Medicare). It bites only under the "dispensed" custody option.
  • Outcome: commission
  • Because: A gap in the check, on a cheap records question. Raised REQ-0252 Apart from the surgical dressing benefit (front end → research) for the other Part B benefits, by document. REQ-0202 Outside Medicare is reused for non-Medicare payers. The decision this informs, opened-bag custody, is the owner's.
IR-44 claim 167unconfirmed came back unconfirmed — 2026-10-04 commission
IR-45 claim 168unconfirmed came back unconfirmed — 2026-10-04 commission
IR-46 claim 170unconfirmed came back unconfirmed — 2026-10-04 commission
IR-47 claim 171unconfirmed came back unconfirmed — 2026-10-04 commission
IR-48 claim 172unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 172unconfirmed. In a single-session clinical-use study, P1 per-patient HOCl bag's head held 4-15 psi in the hands of each of at least five clinicians, including at maximal grip, and removed slough and debris no less than a 35 mL syringe with a 19G angiocatheter.
  • What the check found: It is the result of a clinical study that has not been run, on a head that does not exist. Context: claim 179verified. IRRIGO, a hand-squeezed 60 mL prefilled bottle, is described as reaching "upto 15 psi" and was cleared on bench pressure curves. That shows a hand-squeezed source can reach the window. It says nothing about the spread between operators on P1 per-patient HOCl bag's chamber.
  • Who depended on it: A98 In a single-session clinical-use study in…. Clinical & Scientific (C5), Technology & R&D, Regulatory (its C11) and Commercial. Bench twin: A69 The kit's three-nozzle head (claim 145unconfirmed).
  • What it costs: If false, the pressure clause in intended_use: is a property of the hand, not of the device. P1 per-patient HOCl bag is then worse than its cheapest comparator at the one thing its label claims.
  • Outcome: commission
  • Because: A gap in the world. REQ-0239 For the P1 reference head (Clinical → Technology) asks for the pressure range across grips and for any pressure-limiting element, and it is reused. It now also carries A69 The kit's three-nozzle head, whose IR-30 claim 145 came back unconfirmed requests have closed. On precedent the study is an adoption requirement, not a clearance one (REQ-0204 Could an FRO 510). It needs a built head, and it contacts clinicians and patients, so it is the owner's decision and a Stage 7 sign-off.
IR-49 claim 173unconfirmed came back unconfirmed — 2026-10-04 commission
IR-50 claim 174unconfirmed came back unconfirmed — 2026-10-04 commission
IR-51 claim 177unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 177unconfirmed. Solution from at least three lots, aged to the end of shelf life and then put through worst-case simulated use over the labelled in-use period, stays within its FAC and pH specification and meets USP <51>. This is P1 per-patient HOCl bag-a, in Regulatory's form.
  • What the check found: It is the result of a study that has not been run. The test it describes is now confirmed as the proposed requirement: claim 176verified. That claim covers three lots real-time aged, and a period of preservative effectiveness under worst-case simulated use, where the multiple-use conditioning is a "should". It applies to medium- or low-AMR-concern antimicrobials. The rule is proposed, not final.
  • Who depended on it: A103. Regulatory (C7, what its verdict turns on), Technology & R&D, Operations & NPI and Clinical & Scientific.
  • What it costs: If false, the bag cannot carry a multiple-use label, and Regulatory moves to blocks on P1 per-patient HOCl bag's bag. The calendar stacks on shelf life, at more than 13 months from the first filled batch on Technology's arithmetic.
  • Outcome: commission
  • Because: A gap in the world, with IR-44 claim 167 came back unconfirmed's inputs. REQ-0242 What labelled in-use period is the P1 bag… (Regulatory → Technology) asks for the design-target in-use period, connection count and storage. REQ-0223 Specify the P0 kit's solution and hardware…, REQ-0238 (1) How is a cleared HOCl irrigation bag… and REQ-0228 Retrieve the labelled storage condition are reused as well. Three aged lots need a filler and filled bags, which is the owner's spend. The condition under which this changes: as at IR-44 claim 167 came back unconfirmed. A failure here would make a change of shape the likely honest answer. Under the constraint it would be recorded as commission, and the owner would decide.
IR-52 claim 180unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 180unconfirmed. FDA would place the P1 per-patient HOCl bag head in 21 CFR 880.5475 (FQH, Class II) or 880.6960 (KYZ, Class I), so its route is a 510(k) or an exemption, not a De Novo.
  • What the check found: The Verifier read both identifications in eCFR. 880.5475 describes "a pulsatile jet of sterile fluid ... the pulsing head, tubing to connect to a container of sterile fluid, and a means of propelling the fluid ... such as an electric roller pump". 880.6960 describes "a bulb or a piston syringe with an integral or a detachable tube". It also read the openFDA classification records. Whether a hand-squeezed chamber with a check valve, three nozzles and a shield, sold to fit one HOCl bag, falls within either is an FDA determination. claim 179verified adds that the file's only hand-squeezed FQH precedent, IRRIGO, is a prefilled solution product, not a separately sold head.
  • Who depended on it: A106. Regulatory (C10; it blocks the head as framed if this is false), Operations & NPI (A120's schedule) and Legal & IP (its launch-date trigger).
  • What it costs: If false, the head needs a De Novo (De Novo classification request): a new classification, its own special controls and calendar. A120 slips, and Regulatory blocks the head as framed.
  • Outcome: commission
  • Because: Only FDA settles this, through a 513(g) request or a Pre-Submission. Either one discloses the opportunity outside the organisation, so the settling act is the owner's (decision 3). Records can reach part of it. Raised REQ-0254 Search openFDA 510 (front end → research) to find any separately sold, hand-operated, container-fed head already under FQH or KYZ. A precedent found or not found informs the claim and does not settle it.
IR-53 claim 188unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 188unconfirmed. At the business case's session volume and at a tenth of it, the fully loaded cost of one session (a head assembly, plus a bag divided by the sessions it actually serves) is below the per-session price. This holds even where a bag serves only one session.
  • What the check found: There is no bill of materials, quote or business-case price, and no connector holds manufacturing cost.
  • Who depended on it: A114. Operations & NPI (C6), Commercial (REQ-0244 For P1) and Technology & R&D (the bill of materials).
  • What it costs: If false, P1 per-patient HOCl bag loses money per irrigation somewhere it is meant to sell. Where a bag serves one session, P1 per-patient HOCl bag costs more than P0 the original shape did, because the head now carries a pressure element.
  • Outcome: commission
  • Because: A gap in the world. REQ-0243 For the P1 head and bag (the BOM (bill of materials) inputs: materials, sterilization, port) and REQ-0244 For P1 (price, volumes, sessions per bag) are reused, with REQ-0200 What per-kit price does the money model…, its accepted P0 the original shape predecessor. Supplier quotes are RFQs outside the organisation, which is decision 5. The custody decision moves which setting is the worst case.
IR-54 claim 189unconfirmed came back unconfirmed — 2026-10-04 commission
IR-55 claim 190unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 190unconfirmed. On 2026-10-04 the openFDA registration-and- listing endpoint, searched as recorded, returned one contract manufacturer with an HOCl wound solution (Biomed Laboratories LLC, Vashe for Urgo), and no contract manufacturer listing sterile HOCl in a flexible bag.
  • What the check found: No typed connector queries device/registrationlisting, so the search could not be replayed, and it was not re-run by hand. Its last sentence is also a negative over those results.
  • Who depended on it: A116. Operations & NPI (C9), Commercial (the shape-(c) supply route) and Legal & IP (supply from a licensed incumbent turns FTO into a contract term).
  • What it costs: A threat row. If true, A52 Sterile HOCl wound-irrigation solution…'s two independent fillers have nothing under them in the public record, and P1 per-patient HOCl bag's bag, now with a custom keyed port, is sourced from an incumbent or made in-house.
  • Outcome: commission
  • Because: A tooling gap on a public endpoint. Raised REQ-0253 Replay (front end → research) to replay the search query by query. Even a clean replay would show a listing gap, not a capability finding (REQ-0229 From public records first's note). Supplier RFIs remain decision 5.
IR-56 claim 191unconfirmed came back unconfirmed — 2026-10-04 commission
IR-57 claim 192unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 192unconfirmed. After production sterilization and ageing, P1 per-patient HOCl bag's squeeze chamber and check valves complete twice a full session's squeeze-and-refill cycles without cracking, leaking, valve failure or particulate.
  • What the check found: It is the result of a durability test that has not been run.
  • Who depended on it: A118. Operations & NPI (C11) and Technology & R&D.
  • What it costs: If false, the head fails in use as the Surgiphor squeeze containers did, the valved assembly is redesigned and re-verified, and the delivered pressure (A69 The kit's three-nozzle head) cannot be relied on late in a session.
  • Outcome: commission
  • Because: A gap in the world. REQ-0243 For the P1 head and bag items 1 and 2 (chamber and valve materials, the sterilization modality and whether those materials tolerate it) are reused. The test needs a built, sterilized head, which is the owner's spend.
IR-58 claim 193unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 193unconfirmed. Outside the named families, no in-force US patent or pending published application claims a single-use head with a hand-squeezed chamber refilled through a check valve, or a head-to-bag connector keyed to one maker's bag.
  • What the check found: A negative landscape claim, and a sweep cannot verify an absence. The Verifier ran three CPC sweeps for the record as leads (A61M3/0279 "check valve", A61M3/0258 "squeeze", A61M3/0233 "irrigation"). They were mostly off-topic and truncated, and no family was put through the patent connector. claim 186verified shows separately that earlier sweeps missed two in-force wound-irrigation patents.
  • Who depended on it: A119. Legal & IP (C20), Technology & R&D and Commercial.
  • What it costs: If false, FTO for the two elements P1 per-patient HOCl bag added is blocked by an unnamed holder until a licence or a design-around, and the keyed connector that P1 per-patient HOCl bag-b rests on may belong to someone else.
  • Outcome: commission
  • Because: Expected back unconfirmed, and routed to REQ-0248 Run a recorded US landscape, the recorded landscape on exactly these two elements. It is reused, with REQ-0212 Run a recorded for the wider head, shield and combination field. A clean result is a lead list for counsel, never a clearance.
IR-59 claim 194unconfirmed came back unconfirmed — 2026-10-04 commission
  • The statement: claim 194unconfirmed. A critical-path schedule, built from the chosen filler's quoted lead times, the stability and in-use data, head verification and FDA review time, puts the first US sale of the P1 per-patient HOCl bag head before 2032-03-14.
  • What the check found: There is no chosen filler, no quote and no stability data. The FDA review time for an unsettled route (claim 180unconfirmed) cannot be checked.
  • Who depended on it: A120. Operations & NPI (C12), Legal & IP (its blocks trigger turns on the launch date) and Regulatory (the head's route, A106).
  • What it costs: As registered, both directions break something. This turn's verified tags change what that means. claim 182verified keeps the Schultz utility window at about 2032-04. But claim 183verified (design terms to about 2037-07 and 2040-07), claim 185verified (Medaxis to about 2038-09) and claim 186verified (two unread leads to about 2037 and 2040) mean that a sale after 2032-03-14 no longer clears the head on its own. The date now decides which holders' terms are live at launch, not whether any is.
  • Outcome: commission
  • Because: A gap in the world. REQ-0243 For the P1 head and bag and REQ-0242 What labelled in-use period is the P1 bag… are reused as inputs. A quoted plan needs the chosen filler's lead times, which means an RFQ outside the organisation (decision 5). The condition under which this changes: under "Loop turn 2, reviews", the response to any launch date is counsel's read of the named holders against a defined head (REQ-0249 For the P1 head assembly, REQ-0247 For the US leads the P1 re-statement…), and that is decision 4. If that read finds a live claim or design on every geometry P1 per-patient HOCl bag can use, the honest answer is a change of shape: shape (c), or a licensed head. Under the constraint that would be recorded as commission, and the owner would decide.
What this opportunity rests on the assumption register — 101 live of 121 rows, 44 resting on a refuted or unconfirmed claim

The subset of claims that are load-bearing, each with who depends on it and what breaks if it is false. Rows arrive two ways — the front end writes one, or a chair binds a condition to a claim, which is the definition of load-bearing.

A1 rests on claim 3unconfirmed

If it is false: Neither the referrer nor any party it can bring in holds or can license the Aquaceso hardware. Then there is no existing head, shield and bag to co-pack with an HOCl solution. The kit becomes a new-hardware development programme (design, tooling, verification, its own regulatory route), and the referred premise — adding HOCl to a system already on the market — no longer exists.

Depends on it: Commercial, Legal & IP, Operations & NPI

A2 rests on claim 4verified

If it is false: K123072 is not an FRO clearance describing HOCl as a preservative, with cleansing, irrigation and debridement indications for acute and chronic wounds. Then the launch route (device_class row 1) loses its primary predicate and the preservative framing the intended use copies. The solution needs another predicate, or a De Novo.

Depends on it: Regulatory

A3 rests on claim 6verified

If it is false: No cleared HOCl solution is supplied in bulk irrigation bags (1-3 L) for irrigation. The bag format then has no precedent, and stability and preservative-effectiveness data for HOCl in a flexible irrigation bag must be generated without a predicate to bridge to.

Depends on it: Regulatory, Technology & R&D

A4 rests on claim 12verified

If it is false: Proposed rule 2023-26209 has been finalized. If HOCl sits in the high-AMR-concern tier, liquid wound washes containing it are Class III: the FRO 510(k) launch route closes and a PMA replaces it, and the P0 the original shape calendar and capital do not fit. If HOCl sits in the Class II tier, the route survives but must meet special controls nobody here has read.

Depends on it: Regulatory, Commercial

A5 rests on claim 14verified superseded by p1

If it is false: K240552 did not clear a self-contained solution-plus-applicator system as one FRO device. The co-packaged kit then has no precedent for review as a single device. It splits into a solution 510(k) plus a separate hardware route, and the closed-system pull-through has to be enforced by labeling and commerce rather than by what was cleared.

Depends on it: Regulatory, Commercial

A6 rests on claim 17verified

If it is false: 880.6960 is not Class I and exempt, or does not reach a spray head with a splash shield. The hardware half then has no low-burden route of its own. If FDA reads the kit as two parts, the head and shield need their own clearance, and the neighbouring shape (hardware for third-party HOCl) is no longer the cheap fallback.

Depends on it: Regulatory, Operations & NPI

A7 rests on claim 13verified

If it is false: IRRISEPT K080779 was not cleared as a solution-dispensing irrigation system under jet lavage FQH. The alternative reading in device_class row 2 then has no precedent for a non-powered antimicrobial-preserved system in that regulation, and the kit is left with the FRO route alone, fully exposed to A4 Generator's belief.

Depends on it: Regulatory

A8 rests on claim 62unconfirmed superseded by p1; restated for p1 as a87 (claim 161unconfirmed) at loop turn 2

If it is false: US facilities and agencies will not pay more per irrigation for a closed kit than for saline with a syringe or an HOCl bottle. There is no separate payment (claim 33unconfirmed), so the kit is then priced as a commodity. The head and shield earn no margin, and consumable pull-through, the reason the closed-kit shape was chosen over hardware for third-party HOCl, earns nothing.

Depends on it: Commercial, Market Access

A9 rests on claim 34verified

If it is false: Carter et al. 2023 does not report about 10.5 million Medicare beneficiaries with a wound. The TAM chain then loses its only population figure. The three components (claims 36-38) already carry no number, so TAM has no denominator and stays unscored as a core factor.

Depends on it: Commercial

A10 rests on claim 40unconfirmed absorbed by IR-3 claim 40 came back unconfirmed

If it is false: The 4-15 psi range is not sourced to the 1994 AHCPR guideline. The spray head's "controlled irrigation pressure" then has no accepted target. The performance claim in intended_use: and the bench comparison with IRRIGO's "up to 15 psi" (claim 16verified) have nothing to be specified or verified against.

Depends on it: Clinical & Scientific, Technology & R&D, Regulatory

A11 rests on claim 44unconfirmed

If it is false: The 2024 network meta-analysis does not rank NaOCl/HOCl highest for healing. The strongest pooled comparative evidence for choosing HOCl over saline or water then disappears, and the reason a buyer would pay for HOCl rather than tap water (Aquaceso's default irrigant) has no comparative evidence under it. The label cannot make this claim either way (claim 10unconfirmed); demand depends on clinicians believing it.

Depends on it: Clinical & Scientific, Commercial

A12 rests on claim 42unconfirmed

If it is false: The IWII 2022 consensus does not discuss HOCl as a wound-cleansing option. Clinician adoption, and the quality criteria of a Danish tender, then have no consensus-document anchor. A11 "The efficacy of combination of sodium… becomes the only clinical argument, and it is a single meta-analysis with known limits.

Depends on it: Clinical & Scientific, Commercial

A13 rests on claim 47unconfirmed absorbed by IR-6 claim 47 came back unconfirmed

If it is false: The 2004 JAMA outbreak did not tie a multidrug-resistant Acinetobacter outbreak to wound-irrigation spray and environmental contamination. The splash-shield differentiator then has no documented harm to point to. With claim 49unconfirmed already recording no quantified splash reduction, the "better working environment" half of the proposition has no evidence.

Depends on it: Clinical & Scientific, Operations & NPI, Commercial

A14 rests on claim 50unconfirmed superseded by p1

If it is false: HOCl cannot be warmed in the bag for an irrigation session and stay inside its labeled free available chlorine and preservative-efficacy specification, or the bag and nozzle materials do not tolerate it. Then the referred device's temperature control and the HOCl irrigant conflict. Either warming is dropped, which changes the referred product, or the solution's point-of-use specification cannot be held, which fails the stability data a 510(k) needs.

Depends on it: Technology & R&D, Operations & NPI, Regulatory

A15 rests on claim 52verified

If it is false: A live claim in the US 8,871,278 stabilized-hypohalous-acid family, believed held by Urgo, reads on the HOCl solution the kit would use. The solution half then needs a licence from Urgo, or supply from a licensed source, or a formulation design-around. Without one of those, FTO for the solution is blocked, and that is the rubric's automatic kill. This row is what would force the shape toward neighbouring shape (c), co-branding with an incumbent.

Depends on it: Legal & IP, Commercial

A16 rests on claim 56verified

If it is false: A live claim in the Schultz / Splash Medical Devices family (US 8,002,757 and continuations) reads on a splash shield mounted on an irrigation fluid source. The head-and-shield hardware then needs a licence or a design-around before US sale, and FTO for the hardware half is blocked until expiry.

Depends on it: Legal & IP, Technology & R&D

A17 rests on claim 21unconfirmed

If it is false: The HOCl solution or kit is not Class IIb under the MDR. If it is Class III under Rule 14, the EU route needs a notified body plus a medicinal-substance consultation and a heavier clinical evaluation. The referrer's Danish home market then moves from a IIb certification, with precedent (claim 22unconfirmed), to a Class III programme.

Depends on it: Regulatory (EU), Commercial

A18 rests on claim 26unconfirmed

If it is false: Danish regional and municipal wound-care tenders award on price, not on quality and working environment. In the referrer's home market the kit then competes against sterile NaCl at commodity price, and the premium that the closed-kit shape needs (A8 Assumption, US) has no Danish counterpart either.

Depends on it: Commercial (DK), Market Access

A19 rests on claim 65verified

If it is false: 42 CFR 419.2(b)(4) does not package medical and surgical supplies into the hospital outpatient prospective payment. P0 the original shape's buyer in that setting is the facility, paying from a supply budget that the bundled rate funds. That buyer then has no Medicare money behind the purchase. No other Medicare line replaces it, because A6260 is non-covered under Part B (claim 29verified). The hospital outpatient setting in intended_use: keeps its users and loses its payer. Market Access would need a separate-payment route, and P0 the original shape has none.

Depends on it: Market Access, Commercial

A20 rests on claim 66verified

If it is false: The SNF Part A per diem does not pay in full for ancillary supplies, or 411.15(p) does not pull an outside supplier's item into the SNF's own payment. During a Part A stay the SNF is then not the economic buyer P0 the original shape sells to. The kit would fall to Part B as A6260, which is non-covered (claim 29verified). The SNF setting in intended_use: then has no payer.

Depends on it: Market Access, Commercial

A21 rests on claim 67verified

If it is false: The home health episode payment does not cover medical supplies, or 409.100(a)(2) does not route their payment to the agency. The home health agency is then not the buyer. The kit falls to Part B as A6260 and is non-covered (claim 29verified), so the home health setting in intended_use: has no payer except the patient.

Depends on it: Market Access, Commercial

A22 rests on claim 69verified

If it is false: The July 2026 DMEPOS amounts for 500 mL sterile saline (A4217) and an irrigation syringe (A4322) are not as stated. Then the only published price in the file for the cheapest comparator, saline with a syringe, is gone. A8 Assumption's cost-in-use case has no number on its low side. These are Medicare allowed amounts, not facility purchase prices, and neither code is paid separately in the settings of A19 Restates the OPPS part of claim 30 on its…-A21 42 CFR 484.205.

Depends on it: Commercial, Market Access

A23 rests on claim 105verified

If it is false: The online list prices for a 34 oz (1 L) Vashe bottle (case of 6 at $849.98) and a 32 oz Puracyn Plus bottle (case of 6 at $440.98) are not as listed. Then A8 Assumption's second comparator, an HOCl bottle, has no observed price at all. The band the kit has to price inside, from saline with a syringe (A22 Price anchor for the saline comparator) up to an HOCl bottle, has no upper edge. This is one retailer's list price on one day, not a contract price, and it does not fill the TAM price leg (claim 37unconfirmed).

Depends on it: Commercial

A24 rests on claim 103verified

If it is false: Urgo did not announce a Premier GPO agreement that covers Vashe. Then the file holds no evidence that US facilities buy HOCl wound cleansers through GPO contracting. That is the channel to the supply budgets of A19 Restates the OPPS part of claim 30 on its…-A21 42 CFR 484.205 that P0 the original shape's facility-buyer model assumes. Its federal counterpart is the Vashe FSS contract (claim 104verified). Neither discloses a price.

Depends on it: Commercial, Market Access

A25 rests on claim 68verified

If it is false: The CMS 2024 national service counts for 97597, 11042, 11043 and 11045 are not as stated. Then the TAM loses its only verified volume figure. The volume component (claim 36unconfirmed) asserts no number, and A9 TAM denominator is a count of people, not encounters. These are Medicare fee-for-service debridement services: a floor on volume, not a count of irrigations.

Depends on it: Commercial

A26 rests on claim 86verified

If it is false: The IWII 2022 consensus does not recommend mechanical irrigation at 4-15 psi. The spray head's pressure specification then has no retrievable clinical source. The 1994 AHCPR guideline it was written against is out of reach (A10 The 1994 AHCPR Clinical Practice Guideline…). The 4-15 psi in intended_use: would then rest only on a predicate submitter quoting that guideline (A27 FDA 510). This is the retrievable source A10 The 1994 AHCPR Clinical Practice Guideline… lacked. Whether it carries A10 The 1994 AHCPR Clinical Practice Guideline…'s dependants is for A10 The 1994 AHCPR Clinical Practice Guideline…'s impact review to decide, not this row.

Depends on it: Clinical & Scientific, Technology & R&D, Regulatory

A27 rests on claim 70verified

If it is false: The K210987 summary does not describe 4-15 psi as its predicate's delivered pressure. Then no cleared wound-irrigation summary in the file states the range this kit's intended_use: claims. The 510(k) bench comparison for the three-nozzle head would have no predicate statement of a target, only IRRIGO's "up to 15 psi" ceiling (claim 16verified).

Depends on it: Regulatory, Technology & R&D

A28 rests on claim 89verified

If it is false: Experimental low-pressure (asepto syringe) irrigation does cleanse bacterial contaminants as well as high-pressure syringe irrigation does. P0 the original shape claims to beat pouring, soaking or swabbing from an HOCl bottle (A8 Assumption's second comparator) because a pressure-controlled head cleanses better than low-pressure flow. Nothing in the file would then show that. The head's pressure floor would be left with Rodeheaver's 15 psi efficacy figure alone (claim 88verified).

Depends on it: Clinical & Scientific, Commercial

A29 rests on claim 87verified

If it is false: The IWII 2022 consensus does not say that hydrogen peroxide, traditional hypochlorite (Dakin's, EUSOL) and chlorhexidine are no longer recommended in open wounds. The kit then loses the one consensus line that separates its irrigant from the CHG in the only cleared closed irrigation kit, IRRISEPT (claim 14verified), and from Dakin's, a cheap hypochlorite that buyers could otherwise treat as equivalent. The line does not cover HOCl. The Verifier's note records that the same document lists HOCl-preserved super-oxidised solutions separately.

Depends on it: Clinical & Scientific, Commercial

A30 rests on claim 116unconfirmed

If it is false: US wound clinicians do not believe HOCl cleansing beats saline. The label cannot say HOCl acts in the wound (claim 10unconfirmed). The pooled comparative evidence is either unretrieved (A11 "The efficacy of combination of sodium…) or absent: the 2022 systematic review found no eligible HOCl RCT (claim 93verified). So nothing would then give a buyer a reason to pay for the HOCl half of the kit. The kit would compete as a saline irrigation device with a splash shield. At framing this was the proposition that "no claim states". Research has since written it as claim 116unconfirmed, evidence class 3, and it stays unconfirmed unless primary research is attached.

Depends on it: Clinical & Scientific, Commercial

A31 rests on claim 107verified

If it is false: The burn-centre cohort did not record HOCl as the initial antiseptic in 11.3% of grafted patients. Then the file holds no observed US clinical use of HOCl at any site, and A30 Stakeholder question has no revealed-behaviour evidence from the US. The study covers one site and burns only.

Depends on it: Clinical & Scientific, Commercial

A32 rests on claim 94verified

If it is false: Maragakis et al. did not tie a multidrug-resistant A. baumannii outbreak to pulsatile lavage, with the strain recovered from surfaces in the wound care area. The splash shield then has no documented harm from irrigation spray to point to, and that is what A13 Maragakis LL et al. was registered for. This restatement drops the two details claim 47unconfirmed could not support. The outbreak was pulsatile lavage, not 4-15 psi irrigation. It shows that irrigation spray can cause harm. It does not show that this kit's spray is a comparable hazard.

Depends on it: Clinical & Scientific, Operations & NPI, Commercial

A33 rests on claim 101verified

If it is false: The 1993 beef-wound study did not find less face-and-chest splatter with Irrijet or Zerowet shields than with a bare angiocatheter. The splash-shield differentiator then has no measurement anywhere in the file; claim 49unconfirmed had disclosed none. The "better working environment" half of the proposition would then rest on the referrer's description alone (claim 1unconfirmed). The study used syringe irrigation and existing shields. It did not test this kit's shield.

Depends on it: Commercial, Operations & NPI, Clinical & Scientific

A34 rests on claim 51unconfirmed

If it is false: Spraying the kit's HOCl through three nozzles may produce a clinician inhalation exposure that matters: an oxidant aerosol, or chlorine released at acidic pH. If it does, the "better working environment" proposition inverts, because the shield sits in the user's breathing zone. Exposure data become part of the 510(k) and of the OSHA case (claim 48verified), and the shield or nozzle design may have to change. The candidate's design note says this claim is "on the register", but it was left out at framing. It is registered now, with the tag visible.

Depends on it: Operations & NPI, Regulatory, Commercial

A35 rests on claim 99verified

If it is false: The 2024 study did not find "no analogous damage" in fibroblasts exposed to aerosolised HOCl from a 300 ppm solution for 3 minutes. That is the only exposure datum in the file near the kit's working concentration; Vashe is 150-330 ppm AFC (claim 4verified). A34 Open safety question would then have no measurement on either side. The same study found cytotoxicity after four 9-minute exposures at 500 ppm. It used dry fog on cultured cells, so it applies to the kit by analogy only.

Depends on it: Operations & NPI, Clinical & Scientific

A36 rests on claim 100verified

If it is false: Spraying sodium hypochlorite did not keep chlorine gas below detection limits in the controlled study. Then the one measurement in the file on whether spraying a hypochlorite solution releases chlorine is gone. A34 Open safety question's chlorine-release concern would have nothing against it. The study was surface disinfection with NaOCl, so it applies by analogy only.

Depends on it: Operations & NPI, Regulatory

A37 rests on claim 80verified superseded by p1

If it is false: A threat row, written the way A15 FTO, solution: US 8,871,278, "Stabilized… and A16 FTO, device: US 8,002,757, "Splash shield… are. If the claim itself is false (the patent is not in force), this lead closes and nothing breaks. The row is here for the other direction. Suppose a live claim of US 12,178,977 (CareFusion, lavage systems with a warming component, naive term to 2041, continuation pending) reads on an irrigation bag-and-head system that warms its irrigant. Then the warming the referred device has (claim 1unconfirmed) needs a licence or a design-around until about 2041. That is on top of the chemistry question in A14 Open design question, so the warming option would have two independent ways to fail. Its claims have not been read.

Depends on it: Legal & IP, Technology & R&D

A38 rests on claim 81verified

If it is false: A threat row, like A37 FTO field lead. Suppose a live claim of US 10,391,207 (irrigation fluid containment systems) reads on a splash shield or containment around a wound-irrigation stream. Then the shield needs a licence or a design-around before US sale. The term is open. INPADOC gives a naive 2037, but the priority chain back to a 2004 non-provisional may mean it ended about 2024. So the first thing to settle is which date applies, before anyone reads its claims.

Depends on it: Legal & IP, Operations & NPI

A39 rests on claim 83verified

If it is false: Suppose either US member of PuriCore's WO 2008/040020 family is not abandoned, or a member INPADOC does not link survives. Then the closest lead in the file to the kit's own concept is live: an HOCl solution plus a wound-delivery apparatus, from the company that originated Vashe. FTO for the combination, not just the solution (A15 FTO, solution: US 8,871,278, "Stabilized…) or the hardware (A16 FTO, device: US 8,002,757, "Splash shield…), would then turn on its claims. INPADOC last exchanged this record in 2019.

Depends on it: Legal & IP, Technology & R&D

A40 rests on claim 85verified

If it is false: A threat row, like A37 FTO field lead. Suppose a live claim of Sonoma's US 10,342,825 ("Solution containing hypochlorous acid and methods of using same", naive term to 2030) reads on the kit's HOCl-preserved saline. Then the solution half needs a licence, licensed supply or a formulation design-around until about 2030. That is the consequence A15 FTO, solution: US 8,871,278, "Stabilized… carries for the Urgo family, from a second holder. The other three patents in the claim are peritonitis, inflammation and hypersensitivity methods. Their terms may end about 2027 if their 2007 priority claims are benefit claims.

Depends on it: Legal & IP, Commercial

A41 rests on claim 112unconfirmed

If it is false: Sonoma's 10-K does not state that Microdacyn60 Wound Care is Class IIb under the MDR. A17 Generator's belief's IIb reading then loses its second statement of an MDR IIb HOCl wound solution; the press-release version is claim 22unconfirmed. The precedent the EU route is planned against is then unestablished. The 10-K is a company statement, not a notified-body certificate. The claim is held unconfirmed because it is an EU claim, not because of anything the check found.

Depends on it: Regulatory (EU), Commercial (DK)

A42 rests on claim 113unconfirmed

If it is false: The Region Nordjylland joint wound tender does not buy HOCl wound irrigation fluid as a lot of its own (lot 50), separate from non-HOCl irrigation fluid (lot 49) and NaCl (lot 53). Then the only counter-evidence to A18 Assumption is gone, and in the referrer's home market the kit meets sterile NaCl in the same lot at commodity price. If the claim is true, it has a second side. Lot 50 is a 48-month contract, and its winner was not established: the award notice's tenderers include Mölnlycke (claim 115unconfirmed), and Mölnlycke owns Granudacyn's maker (claim 110verified). Whoever holds lot 50 holds Nordjylland's HOCl irrigation business for the contract term. The claim is held unconfirmed because it is a DK claim, not because of anything the check found.

Depends on it: Commercial (DK), Market Access

A43 rests on claim 119verified superseded by p1; the same claim is registered live for p1 as a85

If it is false: A threat row, read the way A37 FTO field lead is. If the claim is false, the proposed rule says nothing against preservatives in sterile single-use products. The exposure Regulatory found then does not exist, its cheapest move (a per-patient multiple-use bag, A46 The FDA 510) is unnecessary, and nothing in P0 the original shape breaks. The row is here for the other direction. If the claim is true, and the rule is finalized as proposed, P0 the original shape falls outside proposed 878.4019, because P0 the original shape is a sterile, single-use kit whose intended_use: calls HOCl a preservative. Its HOCl then has no purpose the regulation accepts. Or it reads as an antimicrobial delivered to the wound, which A45 Proposed rule FR Doc 2023-26209 states that… says may fall outside CDRH. The bad news on this row is verified, and a verified tag fires no impact review. See the routing below the table.

Depends on it: Regulatory (C1, bound); Clinical & Scientific (REQ-0205 Would FDA accept HOCl described as a… asks the same question from its side); Commercial (answered REQ-0220 Does the closed-kit consumable pull-through… on the reconfiguration this row prompts)

A44 rests on claim 120verified

If it is false: The proposed rule does not put HOCl in its low-level AMR concern tier. Then A4 Generator's belief's worst case comes back. Once the rule is finalized, an HOCl wound wash may land in a tier FDA proposes to classify as Class III. The FRO 510(k) launch route then closes and a PMA replaces it, and the P0 the original shape calendar and capital do not fit. This is the tier reading that A4 Generator's belief's claim 12verified recorded as unread.

Depends on it: Regulatory (C2, bound); Commercial

A45 rests on claim 121verified

If it is false: FDA's proposal does not say that delivering antimicrobials to the wound may fall outside CDRH, or does not map wound-treatment claims to the Class III codes MGR or MDD. Then Regulatory's cost for the "HOCl as antimicrobial" rungs loses its FDA source: a drug or combination programme for rung 2, a PMA for rung 3. A43 Proposed rule FR Doc 2023-26209's consequence also changes. If HOCl can no longer be called a preservative, nobody knows where its other reading lands; this row is the only basis for saying it leaves the device route. This is the FDA text that claims 10 and 20 lacked. At framing those two were left off the register, because their falsity only makes the antimicrobial claim cheaper. A chair has now bound the FDA statement under them, and a binding outranks that exclusion.

Depends on it: Regulatory (C3, bound); Clinical & Scientific (REQ-0219 What adequate and well-controlled clinical… prices rung 2 in evidence)

A46 rests on claim 122verified

If it is false: K232080 is not labelled for multiple use within a single patient. Then the way out of A43 Proposed rule FR Doc 2023-26209 that Regulatory calls cheapest has no cleared HOCl precedent to copy. A per-patient bag would be a new configuration, needing its own in-use stability and preservative-effectiveness case. If A43 Proposed rule FR Doc 2023-26209 is also true, sterile saline with no HOCl is the only low-burden shape left in Regulatory's field. Twin: A49 FDA 510, the same summary read by Operations & NPI for different facts.

Depends on it: Regulatory (C4, bound); Commercial (REQ-0220 Does the closed-kit consumable pull-through…, answered in its position); Technology & R&D (REQ-0218 Can an HOCl-preserved saline irrigation bag…)

A47 rests on claim 123verified superseded by p1

If it is false: A threat row. If the claim is false, K240552 did co-package a spray head or shield under FRO. The kit then has the exact precedent A5 FDA 510 assumed, and the question whether FDA splits the kit gets smaller. The row is here for the other direction. If the claim is true, the precedent A5 FDA 510 relies on ("kit cleared as one FRO device") covers a bottle with a cap and hangers, not a head and a shield. FDA may then split the kit into a solution 510(k) plus a separate hardware route, most likely FQH (Regulatory's reading). Pull-through would then rest on labelling and commerce, not on what was cleared. Twin: A48 FDA 510, the same summary read by Operations & NPI.

Depends on it: Regulatory (C5, bound); Commercial

A48 rests on claim 124verified

If it is false: Irrisept K240552 is not built as two separately sterilized sub-assemblies joined at the point of use. Then the one architecture Operations & NPI says P0 the original shape can be made on today has no precedent in the only cleared self-contained antiseptic irrigation kit. What is left is the pre-connected, wetted assembly sterilized as one. Operations moves toward blocks on that version until shelf-life materials data exist. Twins: A47 The FDA 510 (the same summary, Regulatory's reading) and A68 FDA has cleared antiseptic wound-irrigation… (the same architecture, from K080779 and K253445).

Depends on it: Operations & NPI (C1, bound); Technology & R&D (its connect-at-use reading, A68 FDA has cleared antiseptic wound-irrigation…)

A49 rests on claim 125verified

If it is false: The K232080 summary does not show sterile HOCl in foil-pouched flexible LLDPE bags, backed by ICH stability, USP 51 and ISO 11607 testing. Then the feasibility precedent for the hardest half of the kit, sterile HOCl in a bag, is gone. A3 FDA 510's bag-format precedent becomes a product listing with no test basis anyone can follow. The claim's second half points the other way. If the summary does name its sterilization method, a new entrant learns which process works, and P0 the original shape gets easier. Twins: A3 FDA 510 and A46 The FDA 510.

Depends on it: Operations & NPI (C2, bound); Technology & R&D

A50 rests on claim 126unconfirmed

If it is false: HOCl-preserved saline in a flexible bag cannot be labelled for room-temperature storage through its shelf life. Then the kit needs cool or cold-chain storage. That changes distribution cost, and it breaks the stock-on-the-shelf consumable model P0 the original shape assumes in every setting, home health included. The heat-stability findings (claims 96-97), listed under A14 Open design question, point this way. This row is about shelf storage. A14 Open design question is about warming at the point of use.

Depends on it: Operations & NPI (C3, bound); Technology & R&D (item 2: real-time stability is the long pole)

A51 rests on claim 127unconfirmed

If it is false: Some HOCl-wetted part of the kit consumes free chlorine, fails USP 51 or sheds metal ions over its shelf life. Then the preservative fails in the product, the failure recall Z-0890-2013 records (claim 72unconfirmed). The 510(k) stability section fails, and the part has to be redesigned and the stability clock restarted. A head stored pre-connected and wetted is inside this row in full. Twins: A71 The kit's fluid path from bag port to… (Technology's C5, the same fluid path) and the materials half of A14 Open design question.

Depends on it: Operations & NPI (C4, bound); Technology & R&D; Regulatory (the stability and biocompatibility data a 510(k) needs)

A52 rests on claim 128unconfirmed

If it is false: Fewer than two independent fillers can supply sterile HOCl in bags, counting only fillers that do not sell HOCl wound cleansers in the US themselves. Then the hardest half of the kit is sole-sourced, probably from a competitor, or the programme builds HOCl generation and sterile filling itself. Either way P0 the original shape moves toward neighbouring shape (c) because it has to, not because anyone chose it, and every kit inherits its filler's recalls. Read with A73 Independent claim 1 of US 8,871,278 B2 and A74 Independent claim 1 of US 10,342,825 B2: an independent filler's formulation still faces the Urgo and Sonoma claims. A licensed incumbent's would not.

Depends on it: Operations & NPI (C5, bound); Commercial

A53 rests on claim 129unconfirmed superseded by p1

If it is false: Fully loaded cost per kit is above the per-kit price, at the business case's volume or at a tenth of it. Then the closed single-use shape loses money on every irrigation. It throws away a head and a shield each time and has no reusable part to spread that over. This cannot be attempted today, because no price exists (claim 37unconfirmed) and no bill of materials exists. It stays unchecked until /business-case runs and Technology answers REQ-0199 For the P0 kit. Twin: A8 Assumption (claim 62unconfirmed), the revenue side of the same margin.

Depends on it: Operations & NPI (C6, bound); Commercial

A54 rests on claim 130unconfirmed absorbed by IR-18 claim 130 came back unconfirmed

If it is false: The openFDA recall counts or recorded reasons under FRO, FQH and KYZ are not as stated. Then the four process-failure classes that Operations & NPI draws from the analog pool lose their record: sterility assurance, sterile-barrier integrity, distribution temperature excursion, and HOCl-to-component incompatibility. The validation list it sets for P0 the original shape has nothing under it. What breaks is a design-input list, not the shape. It is registered because it is bound.

Depends on it: Operations & NPI (C7, bound)

A55 rests on claim 131unconfirmed

If it is false: The VA FSS entry for V797D-50441 gives no per-unit Vashe price with a fill volume. Then the upper edge of the band the kit must price inside stays one retailer's list price on one day (A23 Price observation for claim 37), and neither side of A8 Assumption has a contract price.

Depends on it: Commercial (C3, bound)

A56 rests on claim 132unconfirmed

If it is false: Lot 50 in Region Nordjylland awards on price alone. Lot 50 is the one Danish tender lot that exists for HOCl irrigation. The kit's hardware differentiation (closed, pressure-ranged, shielded) then earns nothing in its award, and A18 Assumption's commodity reading holds for that lot. Twins: A18 Assumption (claim 26unconfirmed), A42 Revealed-behaviour twin for claims 25-26 (claim 113unconfirmed) and claim 118unconfirmed.

Depends on it: Commercial (C4, bound); Market Access (DK)

A57 rests on claim 133unconfirmed

If it is false: Lot 50's specification does not accept HOCl fluid co-packaged with an applicator and shield as one product. Then the kit cannot bid into the only Danish HOCl lot as a kit, and its hardware half has no priced home in that tender. The Danish route waits for a re-tender or a new lot. Twin: A62 A co-packaged HOCl wound irrigation kit (Market Access C3), in effect the same proposition.

Depends on it: Commercial (C5, bound); Market Access (DK)

A58 rests on claim 134unconfirmed

If it is false: A threat row on timing. If the claim is false, the award notice names no lot-50 winner or no 48-month term. The Danish timing is then unknown rather than known to be late, and nothing in P0 the original shape breaks. If the claim is true, a named supplier holds Nordjylland's HOCl irrigation business until about 2029, possibly a Mölnlycke company (A42 Revealed-behaviour twin for claims 25-26). The referrer's home market then has a dated wait before first revenue.

Depends on it: Commercial (C6, bound); Market Access (DK)

A59 rests on claim 135unconfirmed

If it is false: No notified body has certified an HOCl wound irrigation solution as Class IIb under Rule 4 with HOCl as a preservative. Then the EU planning case is Class III under Rule 14, with a medicinal-substance consultation and a heavier clinical evaluation. The referrer's Danish home market moves from a precedented IIb route to a Class III programme. Twins: A17 Generator's belief (claim 21unconfirmed) and A41 Bears on claim 22 with an SEC filing rather… (claim 112unconfirmed). Expected back unconfirmed, because no connector reaches notified-body certificates.

Depends on it: Regulatory (C6, bound, EU); Commercial (DK)

A60 rests on claim 136unconfirmed absorbed by IR-24 claim 136 came back unconfirmed

If it is false: The IPPS per-discharge payment is not the total payment for inpatient operating costs, including routine and ancillary services. Then the inpatient setting has a payment route outside the MS-DRG that P0 the original shape has not costed, and the single-buyer model (a facility supply budget) does not cover inpatients. Nothing in P0 the original shape stops working. This is the direction the framing exclusion of claims 28-32 describes, where falsity gains a route. The row is here only because it is bound, and any review it is owed should be read against that exclusion. Twin: claim 30unconfirmed (not registered).

Depends on it: Market Access (C1, bound); Commercial

A61 rests on claim 137unconfirmed absorbed by IR-25 claim 137 came back unconfirmed

If it is false: 419.66(b)(4)(ii) does not exclude a supply furnished incident to a service from device pass-through. Then a separate, time-limited OPPS payment for the kit becomes conceivable. Market Access's finding that nothing on the payment side raises the price ceiling above the bundle no longer holds. Here P0 the original shape gains and nothing breaks. Using the route would need a substantial-clinical-improvement showing, which the file cannot make (claim 93verified). Same direction as A60 Under 42 CFR 412.2.

Depends on it: Market Access (C2, bound); Commercial; Clinical & Scientific (the substantial-clinical-improvement showing that pass-through needs)

A62 rests on claim 138unconfirmed superseded by p1; replaced by a96 and a97 at loop turn 2

If it is false: The co-packaged kit is not a conforming offer under lot 50's specification. Then Danish public money for HOCl irrigation in Nordjylland does not reach the kit through any lot that exists today. It can come only through a new lot at the next re-tender. Twin: A57 The technical specification of lot 50. Expected back unconfirmed while no connector serves DK.

Depends on it: Market Access (C3, bound, DK); Commercial (DK)

A63 rests on claim 139unconfirmed superseded by p1; restated for p1 as a98 at loop turn 2

If it is false: In clinical use the kit does not deliver 4-15 psi, or it removes less slough and debris than a 35 mL syringe with a 19G angiocatheter. Then P0 the original shape is worse than A8 Assumption's cheapest comparator at the one thing its label claims. The cost-in-use case reverses, and so does the performance clause in intended_use:. The study needs a built kit (claim 63unconfirmed), so it stays unchecked until a prototype exists. Twins: A69 The kit's three-nozzle head (the bench version), and A10 The 1994 AHCPR Clinical Practice Guideline…, A26 Bears on claim 40 with a retrievable source and A27 FDA 510 (where the target comes from, not whether the kit delivers it).

Depends on it: Clinical & Scientific (C1, bound); Technology & R&D; Commercial

A64 rests on claim 140unconfirmed superseded by p1; restated for p1 as a99 at loop turn 2

If it is false: The shield does not reduce splatter on the irrigator's face and chest compared with an unshielded syringe, or breathing-zone chlorine is detectable during HOCl irrigation. Clinical calls "better working environment" the only clinical advantage P0 the original shape can put on its label. That claim then has no measurement under it, or it reverses. Twins: A72 During simulated wound irrigation with the… (the same measurement against a looser pass mark: the OSHA ceiling, not detection), A34 Open safety question (claim 51unconfirmed), and A13 Maragakis LL et al., A32 Restates claim 47 without the two… and A33 Bears on claim 49 (the harm, and the syringe-shield analog).

Depends on it: Clinical & Scientific (C2, bound); Operations & NPI; Commercial (the staff-protection leg of A8 Assumption)

A65 rests on claim 141unconfirmed

If it is false: No RCT of at least 100 chronic-wound patients has shown HOCl cleansing beating saline, water or placebo on complete healing at 12 weeks or later. Then the HOCl half of the kit has no healing result under it, and a buyer pays for it on belief (A30 Stakeholder question) and surrogate endpoints. Under P0 the original shape's label the result could not be claimed anyway (claim 10unconfirmed). Clinical expects this claim to come back false. A refuted or unconfirmed tag here confirms the chair's prediction, and it bears on the referrer's question (HOCl or water?) more than on P0 the original shape's label. Read with A43 Proposed rule FR Doc 2023-26209, it is where HOCl may have neither a claimable clinical role nor a preservative one (REQ-0205 Would FDA accept HOCl described as a…). Twins: A11 "The efficacy of combination of sodium… (claim 44unconfirmed), A30 Stakeholder question (claim 116unconfirmed) and claim 93verified.

Depends on it: Clinical & Scientific (C3, bound); Commercial

A66 rests on claim 142verified

If it is false: NCT07440797 is not as registered: it is not randomized, or not Vashe against saline, or its size or endpoint differs, or it is already recruiting or reporting. Then Clinical's timing has no record under it. Clinical names this readout, perhaps two years away, as the event most likely to move clinician belief. If results are already posted, the evidence under A30 Stakeholder question has moved and nobody here has read it.

Depends on it: Clinical & Scientific (C4, bound); Commercial

A67 rests on claim 143verified superseded by p1; the same claim is registered live for p1 as a86

If it is false: A threat row against mechanism: as written. If the claim is false, a hand-squeezed flexible bag reliably reaches 8-15 psi. No pressurisation element is then needed, and the head is a matter of sizing nozzles. The row is here for the other direction. If the claim is true, a hand-squeezed bag peaks at about 4 psi. Gravity cannot reach the window either: Technology's arithmetic needs about 2.8 m of height for 4 psi. So "the bag's head or squeeze pressure" in mechanism: cannot deliver the 4-15 psi intended_use: promises. The head then needs a squeeze chamber, a pressure cuff or a pump, and a pump changes the route (REQ-0211 The kit's bag cannot reach 4-15 psi by…). No claim states the premise this row threatens. It lives only in mechanism:. As with A43 Proposed rule FR Doc 2023-26209, the bad news is verified, and no review fires on it.

Depends on it: Technology & R&D (C1, bound); Operations & NPI (nozzle tooling); Regulatory (REQ-0211 The kit's bag cannot reach 4-15 psi by…); Clinical & Scientific (A63 In a single-session clinical-use study in… needs the head to work)

A68 rests on claim 144verified

If it is false: FDA has not cleared an antiseptic irrigation system supplied as a container plus an applicator in one package and joined at the point of use. Then connect-at-use has no clearance precedent. Integration becomes a development item whichever configuration is chosen. And the sterilization and shelf-life materials problems of a pre-connected assembly cannot be designed out by copying a cleared kit. Twin: A48 FDA 510.

Depends on it: Technology & R&D (C2, bound); Operations & NPI (its C1 reading, A48 FDA 510)

A69 rests on claim 145unconfirmed

If it is false: The kit's head, fed by its own pressurisation means, does not hold 4-15 psi at its working distance from the first 10% of the bag to the last. Then the device misses the performance clause in its own intended_use:, the 510(k) bench comparison with K210987 (IRRIGO) fails, and production tooling cannot be frozen. Twins: A10 The 1994 AHCPR Clinical Practice Guideline…, A26 Bears on claim 40 with a retrievable source and A27 FDA 510. Those rows say where the 4-15 psi target comes from; this row says whether the kit hits it. A10 The 1994 AHCPR Clinical Practice Guideline…'s review must not let a verified source stand in for a delivery nobody has measured. Expected back unconfirmed until a prototype is tested.

Depends on it: Technology & R&D (C3, bound); Clinical & Scientific (the bench step before A63 In a single-session clinical-use study in…, REQ-0203 For the P0 three-nozzle head fed from the…); Regulatory (the 510(k) bench comparison); Operations & NPI (tooling freeze)

A70 rests on claim 146unconfirmed superseded by p1

If it is false: HOCl-preserved saline in the kit's bag at 37 C for 60 minutes drifts out of its free-chlorine or pH specification. Then the referred device's in-session warming cannot be kept with an HOCl irrigant, and the referred product changes. Twin: A14 Open design question (claim 50unconfirmed). A verified 146 does not close A14 Open design question. It tests one 60-minute session. Technology's own arithmetic says a session is unlikely to be what fails, and days of warm storage in a cabinet could be. A14 Open design question's warm-storage half stays open whatever this row returns.

Depends on it: Technology & R&D (C4, bound); Operations & NPI; Regulatory

A71 rests on claim 147unconfirmed

If it is false: Metal touches the solution somewhere between the bag port and the nozzle exit. Or solution held in that path for the longest contact the configuration allows drifts out of free-chlorine specification. Then the head repeats recall Z-2275-2026, a sprayer spring corroded by HOCl (claim 71unconfirmed). The wetted path is redesigned before tooling, and a pre-connected configuration fails outright. Twin: A51 Every HOCl-wetted material in the kit, the same path as Operations & NPI specifies it, with USP 51 and metals tests.

Depends on it: Technology & R&D (C5, bound); Operations & NPI

A72 rests on claim 148unconfirmed

If it is false: Emptying a full bag inside the shield at maximum pressure puts airborne chlorine in the operator's breathing zone above the OSHA ceiling in 29 CFR 1910.1000 Table Z-1. Then the shield gathers an above-limit exposure at face height, and the working-environment proposition reverses. The kit cannot be used without respiratory controls, and the shield and nozzles are redesigned before tooling. Twins: A34 Open safety question (claim 51unconfirmed), A35 Bears on claim 51 and A36 Bears on claim 51 by analogy only (the analogies), and A64 In simulated or clinical use (Clinical's stricter pass mark).

Depends on it: Technology & R&D (C6, bound); Operations & NPI (owns what the exposure means for staff); Clinical & Scientific (A64 In simulated or clinical use); Commercial

A73 rests on claim 149verified

If it is false: Independent claim 1unconfirmed of US 8,871,278 is broader than an added-DIC solution in a gas-barrier container. Then A15 FTO, solution: US 8,871,278, "Stabilized…'s exposure widens, because HOCl saline without an added stabiliser may sit inside Urgo's claim. The solution half needs a licence, licensed supply or a design-around, which pushes toward shape (c). A52 Sterile HOCl wound-irrigation solution…'s independent filler then becomes an FTO problem as well as a supply one. Twin: A15 FTO, solution: US 8,871,278, "Stabilized… (claim 52verified).

Depends on it: Legal & IP (C1, bound); Technology & R&D (REQ-0223 Specify the P0 kit's solution and hardware…, the formulation spec); Operations & NPI (A52 Sterile HOCl wound-irrigation solution…)

A74 rests on claim 150verified

If it is false: Independent claim 1unconfirmed of US 10,342,825 is broader than pH 5.6, very low chloride and a phosphate buffer. Then A40 Bears on claim 53's exposure widens to saline-based HOCl until about 2030, and the solution needs a licence, licensed supply or a formulation design-around. Twin: A40 Bears on claim 53 (claim 85verified).

Depends on it: Legal & IP (C2, bound); Technology & R&D

A75 rests on claim 151verified

If it is false: US 8,002,757 is still in force. Then the base Schultz shield patent is live alongside its continuations, to about 2027 on INPADOC's naive term, and A16 FTO, device: US 8,002,757, "Splash shield…'s exposure includes it. Twin: A16 FTO, device: US 8,002,757, "Splash shield… (claim 56verified).

Depends on it: Legal & IP (C3, bound); Technology & R&D

A76 rests on claim 152verified

If it is false: At least one of US 8,672,904, 11,083,835 and 12,208,226 has a term running past 2032. Then A16 FTO, device: US 8,002,757, "Splash shield…'s hardware exposure runs toward INPADOC's naive 2041, past any plausible launch, and a shield licence or design-around becomes a launch item rather than a wait. Twin: A16 FTO, device: US 8,002,757, "Splash shield…. Legal names this term check as the cheapest move in its field.

Depends on it: Legal & IP (C4, bound); Technology & R&D; Commercial

A77 rests on claim 153refuted superseded by p1; rebound by legal & ip as a107 (claim 181verified), per IR-34 claim 153 came back refuted

If it is false: A threat row. If the claim is false, claims 19 and 38 do recite a squeeze bottle or a syringe as the irrigation source. A bag-fed head may then sit outside them on their face, and the Schultz question gets smaller. The row is here for the other direction. If the claim is true, the claims are not limited to bottle-mounted shields. Reading them against the kit's head and shield is then real counsel work, needed before US launch if A76 US 8,672,904 B1 puts the family past launch. Legal says that case (true, and past launch) moves it to blocks on the hardware half. Twin: A16 FTO, device: US 8,002,757, "Splash shield….

Depends on it: Legal & IP (C5, bound); Technology & R&D

A78 rests on claim 154verified

If it is false: Some independent claim of CareFusion's US 12,178,977 does not recite a warming component. Then dropping warming does not take the kit out of a family that runs to about 2041, though three chairs name dropping it as a simplification. A37 FTO field lead's threat reaches the unwarmed kit too. Twin: A37 FTO field lead (claim 80verified).

Depends on it: Legal & IP (C6, bound); Technology & R&D (its "drop warming" pivot rests on it)

A79 rests on claim 155unconfirmed

If it is false: An in-force US patent or published application outside the named families claims one of three things: a bag-fed multi-nozzle wound spray head, a shield integral with one, or an HOCl-plus-applicator kit. Then FTO is blocked, on the hardware half or on the combination, by a holder nobody has named, until a licence or a design-around exists. That is the input to the rubric's automatic kill. The landscape has not been run (REQ-0212 Run a recorded), so this is expected back unconfirmed. It is claim 58unconfirmed's unexamined field, now stated as a proposition.

Depends on it: Legal & IP (C7, bound); Technology & R&D; Commercial

A80 rests on claim 156verified

If it is false: A threat row, like A37 FTO field lead. If the claim is false, both leads have lapsed. They close, and nothing breaks. The row is here for the other direction. If the claim is true, US 12,642,907 (to about 2044) and US 10,568,785 (to about 2036) are live leads on wound-washing hardware whose claims nobody has read. The head and shield then have two more possible holders to clear.

Depends on it: Legal & IP (C8, bound); Technology & R&D

A81 rests on claim 157verified

If it is false: WO 2008/040020 does not disclose an apparatus for delivering HOCl to a wound. Then Legal's reading that nobody can own the HOCl-plus-applicator concept loses its earliest document, and more of the combination may be patentable. This is patentability, not FTO. If the claim is false, P0 the original shape gains something it could own, and nothing breaks. Registered because it is bound. Twin: A39 FTO field lead closed (claim 83verified).

Depends on it: Legal & IP (C9, bound); Commercial (defensibility)

A82 rests on claim 158unconfirmed absorbed by IR-36 claim 158 came back unconfirmed

If it is false: The FRO, FQH and KYZ clearance counts for 2024-10 to 2026-10 are not as stated. Then the fast-follower rate Legal tests any moat against has no record. Its conclusion that IP is a thin part of defensibility loses its measured basis. Nothing in P0 the original shape's shape breaks, and claims 76-77 already show entry continuing.

Depends on it: Legal & IP (C10, bound); Commercial

A83 rests on claim 159unconfirmed

If it is false: An EP patent in force in Denmark, or a pending EP application, claims the head, an integral shield, the HOCl solution or the kit. Then the referrer's home market has an FTO block that the US work says nothing about. The nearest lead is the Heraeus applications EP4806473A1-76A1 (2026-09). Expected back unconfirmed, because no connector tags a non-US patent.

Depends on it: Legal & IP (C11, bound, EU/DK); Commercial (DK)

A84 rests on claim 160unconfirmed absorbed by IR-38 claim 160 came back unconfirmed

If it is false: EPC Articles 54 and 55 do not say what the claim says, for example because Article 55 gives inventors a grace period for their own disclosures. Then the referrer's disclosure history (REQ-0224 Ask the referrer) matters less in Europe than Legal's position says. Legal's position warns that a non-confidential disclosure of the HOCl variant may already have cost European novelty, and that warning would no longer hold. The row bears on what the referrer could own. It does not bear on whether P0 the original shape can be sold.

Depends on it: Legal & IP (C12, bound)

A85 rests on claim 119verified

If it is false: If false, the proposed rule does not limit antimicrobial preservatives to nonsterile or multiple-use single-patient washes. Then the P1 per-patient HOCl bag bag loses the text that places it inside proposed 878.4019(a)(1). The reason P1 per-patient HOCl bag moved from a single-use bag to a per-patient bag, and took on an in-use stability and preservative-effectiveness programme (A102, A103), has no regulatory basis, and the single-use bag returns as a lower-burden option the record set aside. A separate event, not this claim being false: Regulatory moves toward blocks if a final rule narrows (a)(1) to exclude sterile multiple-use washes. claim 12verified (A4 Generator's belief) is where finalization would show. A43 Proposed rule FR Doc 2023-26209 is this claim's P0 the original shape row, read as a threat. This row is the same claim read as something P1 per-patient HOCl bag rests on. Registered with the tag visible.

Depends on it: Regulatory (C1, bound, re-stated against P1 per-patient HOCl bag); Clinical & Scientific (its verdict reads the bag's preservative job from this claim and claim 122verified); Commercial (the bag's one job on the label)

A86 rests on claim 143verified

If it is false: If false, a hand-squeezed flexible bag reaches 4-15 psi on its own, and P1 per-patient HOCl bag's squeeze chamber and check valves are not needed. The head shrinks back to nozzles and a shield, with fewer parts, fewer tests (A118) and a lower unit cost (A114). Nothing in P1 per-patient HOCl bag breaks; it gets simpler. Registered because it is bound, and because it is the stated reason for P1 per-patient HOCl bag's mechanism:. A67 Published bench measurement is the same claim read as a threat to P0 the original shape's mechanism:. Registered with the tag visible.

Depends on it: Technology & R&D (C1, bound); Operations & NPI (the valved head assembly and its tests exist because of it); Commercial (the head's added hardware cost)

A87 rests on claim 161unconfirmed

If it is false: If false, US facilities and agencies pay no more per session for one P1 per-patient HOCl bag head plus a share of a bag than for saline and a syringe, or an HOCl bottle. The head is P1 per-patient HOCl bag's only per-irrigation revenue, so it is then priced as a commodity accessory, and the per-session margin rests on nothing. Successor to A8 Assumption (claim 62unconfirmed, the P0 the original shape kit). Twin: claim 117unconfirmed. Evidence class 3: no connector reaches buyer behaviour, so it is expected back unconfirmed.

Depends on it: Commercial (C2, bound: the revenue premise of P1 per-patient HOCl bag); Market Access (the bundle sets the ceiling any premium must fit under); Operations & NPI (C6's per-session price, A114)

A88 rests on claim 162unconfirmed

If it is false: P1 per-patient HOCl bag-b, now a claim. If false, buyers refuse a head that fits only its own maker's bag, or require one that fits the spike ports of bags they already stock. Then the bag is not pulled through. The head is sold for any bag, which is neighbouring shape (a), and the bag has to win alone as a parity HOCl solution. The reason P1 per-patient HOCl bag keeps the head single-use and keyed is gone. Evidence class 3, expected back unconfirmed.

Depends on it: Commercial (C3, bound); Operations & NPI (keying makes the bag a custom part a filler must accept, A52 Sterile HOCl wound-irrigation solution…); Technology & R&D (keying and reclosure sit on one connector, A94 The per-patient bag's access port accepts a…)

A89 rests on claim 163unconfirmed

If it is false: If false, the usual interval between visits in a US outpatient wound clinic is longer than the in-use period labelled on the cleared HOCl bag. In that setting each session then costs a head plus a whole bag. That is P0 the original shape's economics with the waste shown, in the setting where most Medicare FFS selective debridement happens. Checkable from two public retrievals (REQ-0228 Retrieve the labelled storage condition, and a published US visit interval). Twin: A115 (claim 189unconfirmed).

Depends on it: Commercial (C4, bound); Operations & NPI (its C8, A115, is the four-setting version); Market Access (where the bag sits between visits decides its payer, A92 Medicare Part B makes no payment for a…)

A90 rests on claim 164verified

If it is false: If false, 414.22(b)(5) does not split practice expense into facility and nonfacility RVUs as stated. Then Market Access's reading of who buys in an outpatient wound clinic (the hospital in a hospital-based clinic, the practice in an office-based one) loses its regulation text, and the clinic's buyer goes back to unstated. Market Access says falsity here clarifies or gains a line rather than losing a route. Registered because it is bound.

Depends on it: Market Access (C4, bound); Commercial

A91 rests on claim 165unconfirmed

If it is false: If false, CMS's CY 2026 practice-expense inputs list no irrigation supply for 97597 in the office setting. The office still buys the product, but out of practice expense CMS never itemised for irrigation. P1 per-patient HOCl bag then displaces an unpriced line rather than a known saline-and-syringe cost. Nothing in P1 per-patient HOCl bag breaks; the comparator price becomes less visible. Registered because it is bound. Expected back unconfirmed while no connector reads the input files.

Depends on it: Market Access (C5, bound); Commercial (the cost-in-use comparison)

A92 rests on claim 166unconfirmed

If it is false: A threat row. If false, some Part B benefit pays for an A6260 wound cleanser dispensed for home use between clinic visits. A bag that goes home then gains a payer, and nothing breaks. The row is here for the other direction. If true, a P1 per-patient HOCl bag bag that leaves the clinic with an outpatient leaves both provider budgets, and the patient, or a non-Medicare plan if one pays (REQ-0202 Outside Medicare), pays for it. Bad news here arrives as verified, which fires no review.

Depends on it: Market Access (C8, bound); Commercial (C4's outpatient reading); Operations & NPI (REQ-0235 For the P1 per-patient HOCl bag, where the opened bag sits)

A93 rests on claim 167unconfirmed

If it is false: P1 per-patient HOCl bag-a, now a claim (Technology's form). If false, the HOCl-preserved saline in the per-patient bag drifts out of its FAC or pH specification, or fails USP <51>, within its in-use period, on fresh or end-of-shelf-life bags. Then the bag cannot carry a multiple-use label. The proposed rule leaves a preserved wash two configurations, nonsterile or this one (claim 119verified), so P1 per-patient HOCl bag's bag has no clearable labelling. Technology and Regulatory both say they move to blocks on the bag. Twins: A103 (claim 177unconfirmed, the same premise in Regulatory's three-lot form), A94 The per-patient bag's access port accepts a… (claim 168unconfirmed, the port), A100 (claim 174unconfirmed, wound organisms at the port) and A115 (claim 189unconfirmed, the period against the session interval). Needs a built bag, so expected back unconfirmed.

Depends on it: Technology & R&D (C7, bound); Regulatory (its twin, A103, is what its verdict turns on); Operations & NPI (C8, A115); Clinical & Scientific (the bag must stay clean across reuse, A100); Commercial (the bag spread over sessions)

A94 rests on claim 168unconfirmed

If it is false: If false, the bag's port does not reclose when the head is removed, fails a container-closure or microbial-ingress challenge after the maximum connect-and-disconnect cycles, or has metal in its wetted path. Then an opened bag is open to air and organisms between sessions, and P1 per-patient HOCl bag-a (A93 The system's hypochlorous acid-preserved…) fails for a mechanical reason. A metal part would repeat recall Z-2275-2026 (claim 71unconfirmed) on the part with the longest HOCl contact in the system. The keyed connector P1 per-patient HOCl bag-b (A88 US facility and agency purchasers) needs sits on this same interface, so a redesign here restarts both. Twin of P1 per-patient HOCl bag-a.

Depends on it: Technology & R&D (C8, bound); Operations & NPI (the re-entry part joins the bag's bill of materials); Clinical & Scientific (the port is the ingress route its C7 challenges)

A95 rests on claim 169verified

If it is false: If false, K251757 does not show an aseptically made, foil-pouched HOCl bag labelled for multiple use within one patient and tested feeding separate jet-lavage hardware. Then P1 per-patient HOCl bag's bag loses its nearest model, an aseptically filled HOCl bag feeding hardware that is not its own, and Operations' aseptic-fill planning case loses its precedent. A49 FDA 510 (claim 125verified) remains as the sterile-bag precedent, with no named process.

Depends on it: Technology & R&D (C9, bound); Operations & NPI (its aseptic-fill planning case); Legal & IP (the precedent's formulation, for REQ-0223 Specify the P0 kit's solution and hardware…)

A96 rests on claim 170unconfirmed

If it is false: If false, an HOCl irrigation bag offered alone is not a conforming offer under lot 50. Then Danish public money for HOCl irrigation in Region Nordjylland reaches neither half of P1 per-patient HOCl bag through any existing lot, and the Danish route waits for a re-tender or a new lot. Successor to A62 A co-packaged HOCl wound irrigation kit (claim 138unconfirmed, the co-packaged P0 the original shape offer). Expected back unconfirmed while no connector serves DK.

Depends on it: Market Access (C6, bound, DK); Commercial (DK)

A97 rests on claim 171unconfirmed

If it is false: If false, no lot in the Nordjylland tender admits a spray head with an integral shield offered without fluid. The P1 per-patient HOCl bag head, P1 per-patient HOCl bag's only per-session revenue, then has no public-money route in that region until a re-tender creates one, even if the bag wins lot 50. Twin: A57 The technical specification of lot 50 (claim 133unconfirmed, the head offered with the fluid). Expected back unconfirmed.

Depends on it: Market Access (C7, bound, DK); Commercial (DK: whether the head has a priced home in the tender)

A98 rests on claim 172unconfirmed

If it is false: If false, in clinicians' hands the P1 per-patient HOCl bag head does not hold 4-15 psi for every operator, including at maximal grip, or it removes less slough and debris than a 35 mL syringe with a 19G angiocatheter. Then the performance clause in intended_use: is a property of the hand, not the device, and P1 per-patient HOCl bag is worse than its cheapest comparator at the one thing its label claims. Successor to A63 In a single-session clinical-use study in… (claim 139unconfirmed, the P0 the original shape kit). Twins: A69 The kit's three-nozzle head (claim 145unconfirmed, the bench version), and A26 Bears on claim 40 with a retrievable source and A27 FDA 510 (where the target comes from). Needs a built head, so expected back unconfirmed.

Depends on it: Clinical & Scientific (C5, bound); Technology & R&D; Regulatory (its C11 names this the in-hand version of claim 145unconfirmed); Commercial

A99 rests on claim 173unconfirmed

If it is false: If false, the P1 per-patient HOCl bag shield, driven at maximal grip, does not reduce splatter on the irrigator against an unshielded syringe, or breathing-zone chlorine is detectable. "Better working environment", which Clinical calls the one advantage P1 per-patient HOCl bag can put on its label as its own, then has no measurement under it, or it reverses. Successor to A64 In simulated or clinical use (claim 140unconfirmed). Twins: A117 (claim 191unconfirmed, Operations' pass mark), A72 During simulated wound irrigation with the… (claim 148unconfirmed, Technology's) and A34 Open safety question (claim 51unconfirmed). The pass marks still differ: this row says below detection, and A117 says at or below 1 ppm.

Depends on it: Clinical & Scientific (C6, bound); Operations & NPI; Commercial (its staff-protection positioning)

A100 rests on claim 174unconfirmed

If it is false: If false, S. aureus, P. aeruginosa or A. baumannii introduced at the port in a protein soil survive in a repeatedly spiked bag to the end of its in-use period, or FAC leaves specification. Then the per-patient bag carries a contamination hazard the single-use P0 the original shape bag did not have, and Clinical moves toward blocks on the multiple-use bag. It is the one clinical-safety question P1 per-patient HOCl bag created. Twin of P1 per-patient HOCl bag-a (A93 The system's hypochlorous acid-preserved…). USP <51> does not test it.

Depends on it: Clinical & Scientific (C7, bound: the result its verdict moves on); Technology & R&D (owns the method); Regulatory (REQ-0240 For a sterile HOCl-preserved wound wash in… asks whether this is a clearance requirement); Operations & NPI (the in-use regimen)

A101 rests on claim 175verified

If it is false: If false, the randomized evidence on warmed against room-temperature saline irrigation shows an outcome difference, not only comfort. Then P1 per-patient HOCl bag's room-temperature irrigant carries a clinical cost nobody has priced, and the decision to drop warming loses its clinical footing. Bringing warming back would also bring back the HOCl heat-stability findings (claims 96 and 97) and the CareFusion warming family (A78 Every independent claim of US 12,178,977 B2, A113). Neither trial is in chronic wounds.

Depends on it: Clinical & Scientific (C8, bound: its answer to REQ-0210 Is warming the irrigant to about body…); Technology & R&D, Legal & IP and Operations & NPI (each named dropping warming)

A102 rests on claim 176verified

If it is false: If false, proposed 878.4019(b)(2) does not require continued low bioburden, stability and preservative effectiveness over the use life, tested on three real-time-aged lots under worst-case simulated use. The P1 per-patient HOCl bag bag's evidence burden would then be lighter than Regulatory prices it, and nothing breaks. Registered because it is bound, and because it sets the test A103 must pass.

Depends on it: Regulatory (C6, bound: the evidence package the bag is priced against); Technology & R&D and Operations & NPI (the in-use study's design and calendar)

A103 rests on claim 177unconfirmed

If it is false: P1 per-patient HOCl bag-a, now a claim (Regulatory's form). If false, solution from three lots aged to the end of shelf life, then put through worst-case simulated use over the labelled in-use period, leaves its FAC or pH specification or fails USP <51>. Then the bag cannot carry a multiple-use label, and Regulatory moves to blocks on P1 per-patient HOCl bag's bag, because the proposed rule leaves a preserved wash only nonsterile or this configuration (claim 119verified). Its calendar stacks on shelf life: on Technology's arithmetic, more than 13 months from the first filled batch at the 12-month precedent. Twin: A93 The system's hypochlorous acid-preserved… (claim 167unconfirmed); also A94 The per-patient bag's access port accepts a…, A100 and A115. Needs a built bag, so expected back unconfirmed.

Depends on it: Regulatory (C7, bound: what its verdict turns on); Technology & R&D; Operations & NPI; Clinical & Scientific

A104 rests on claim 178verified

If it is false: If false, the K253665 summary does not show USP <51> on aged samples through a simulated 7-day multi-use period, spike-adapter compatibility testing, a GLP porcine study, and no clinical data. Then the most recent HOCl multi-use precedent no longer sets the bag's evidence floor at bench plus an animal study with no clinical data. Regulatory's answer to REQ-0204 Could an FRO 510, that clearance needs no clinical data on precedent, loses half its basis.

Depends on it: Regulatory (C8, bound; its answer to REQ-0204 Could an FRO 510 rests on it); Operations & NPI (the vented spike adapter as a re-entry precedent); Clinical & Scientific (whether its studies are regulatory)

A105 rests on claim 179verified

If it is false: If false, the IRRIGO summary does not rest on bench, pressure, sterilization and biocompatibility testing with no clinical testing. Then the hand-squeezed head's evidence floor is unknown, and a clinical study such as A98 In a single-session clinical-use study in…'s may be a clearance requirement for the head, not only an adoption one.

Depends on it: Regulatory (C9, bound); Clinical & Scientific (REQ-0204 Could an FRO 510)

A106 rests on claim 180unconfirmed

If it is false: If false, FDA would not place the P1 per-patient HOCl bag head in 880.5475 or 880.6960, and its route is a De Novo. The head then needs a new classification, with its own special controls and calendar. The schedule in A120 slips, and Regulatory blocks the head as framed. Only FDA can settle this, through a 513(g) request or a Pre-Submission, and either one discloses the opportunity outside the organisation, which is a human decision. Expected back unconfirmed.

Depends on it: Regulatory (C10, bound; moves to blocks for the head as framed if false); Operations & NPI (C12's schedule assumes this route, A120); Legal & IP (its launch-date trigger)

A107 rests on claim 181verified

If it is false: A threat row. If false, the real independent claims of US 11,083,835 and 12,208,226 are not as described, and the Schultz question changes size in a direction this file cannot predict. The row is here for the other direction. If true, five independent claims recite a fluid or irrigation source connector, a nozzle and a shield, not a bottle or a syringe. Reading them against a defined P1 per-patient HOCl bag head is then counsel's work, needed before any US launch inside the term window: about 2032-04 on A76 US 8,672,904 B1, later if A108 or A109 says so. Successor to A77 Independent claim 19 of US 11,083,835 B2 (claim 153refuted). Per IR-34 claim 153 came back refuted there is no second commission: a refuted here is a finding. Bad news arrives as verified.

Depends on it: Legal & IP (C5, rebound per IR-34 claim 153 came back refuted; part of its named blocks trigger); Technology & R&D (REQ-0249 For the P1 head assembly, the head geometry); Operations & NPI (REQ-0250 What is the earliest plausible date the P1…, the launch date)

A108 rests on claim 182verified

If it is false: If false, US 10,363,356's 2000 benefit claim does not count, its term runs from 2010-08-05, and it ends about 2033-05-15. The Schultz utility window then runs about a year past the 2032-04 that IR-34 claim 153 came back refuted and A120 use, and a US head launch before 2033-05 needs counsel's read or a design-around.

Depends on it: Legal & IP (C14, bound); Operations & NPI (A120's date)

A109 rests on claim 183verified

If it is false: A threat row. If false, the Schultz design patents are bounded by the family's utility terms, and the window closes with them. The row is here for the other direction. If true, D956,963 and D1,085,409 each run 15 years from their own grant, past 2032. The Schultz family then has a design-right clock on an ornamental shield design nobody here has compared with the P1 per-patient HOCl bag shield, and launching after 2032-04 no longer clears the shield by itself. Bad news arrives as verified.

Depends on it: Legal & IP (C15, bound; part of its named blocks trigger)

A110 rests on claim 184verified

If it is false: If false, US 12,642,907's only independent claim does not require a battery and a battery-driven pump. The nearest manual-gun lead (to about 2044, A80 US 12,642,907 B2) then stands as wide as its title, "manual and battery powered", and may reach a hand-pressurised P1 per-patient HOCl bag head. That is a hardware FTO question running to about 2044, which P1 per-patient HOCl bag's no-pump design was assumed to avoid.

Depends on it: Legal & IP (C16, bound); Technology & R&D (P1 per-patient HOCl bag excludes a pump)

A111 rests on claim 185verified

If it is false: If false on the limitations, Medaxis's independent claims are wider than a flexible, fluid-tight cover with a stiffening element and a transparent plate, and the P1 per-patient HOCl bag shield faces a broader second holder. If false on the term, the window is shorter than computed. Either way the shield's clearance date moves. If true, Medaxis's US 10,568,785 is a second shield holder to about 2038-09-30, six years past the Schultz window, with specific limitations for counsel to test against REQ-0249 For the P1 head assembly's geometry.

Depends on it: Legal & IP (C17, bound; part of its named blocks trigger); Technology & R&D (REQ-0249 For the P1 head assembly)

A112 rests on claim 186verified

If it is false: A threat row, like A80 US 12,642,907 B2. If false, the two leads have lapsed, and nothing breaks. If true, US 10,398,811 (to about 2037) and US 11,504,457 (to about 2040) are two more in-force wound-irrigation patents whose claims nobody has read, and they show that the earlier sweeps under-reached. Bad news arrives as verified.

Depends on it: Legal & IP (C18, bound); Technology & R&D

A113 rests on claim 187verified

If it is false: A threat row. If false, neither CareFusion application is pending, and the warming family closes for P1 per-patient HOCl bag with its grant (A78 Every independent claim of US 12,178,977 B2). If true, the continuation US 2025/0082838 and the flow-interface application US 2025/0375566 are pending and unread. Either could issue with claims that do not recite warming and that read on an unwarmed, bag-fed head. This is what is left of A37 FTO field lead's exposure once P1 per-patient HOCl bag dropped warming. Read with A78 Every independent claim of US 12,178,977 B2 (claim 154verified), which takes the grant out of P1 per-patient HOCl bag's way. Bad news arrives as verified.

Depends on it: Legal & IP (C19, bound); Technology & R&D

A114 rests on claim 188unconfirmed

If it is false: If false, one P1 per-patient HOCl bag session costs more than the per-session price. A session is a head assembly with its chamber and valves, plus a bag divided by the sessions it really serves. The test fails at the business case's volume, at a tenth of it, or in the setting where a bag serves the fewest sessions. Then P1 per-patient HOCl bag loses money per irrigation somewhere it is meant to sell. Where a bag serves one session, P1 per-patient HOCl bag costs more than P0 the original shape did, because the head now has a pump in it. Successor to A53 At the annual kit volume the business case… (claim 129unconfirmed). It cannot be attempted until a price and a bill of materials exist, so it is expected back unconfirmed.

Depends on it: Operations & NPI (C6, bound; rebinds superseded claim 129unconfirmed); Commercial (REQ-0244 For P1: the price and the volumes); Technology & R&D (the bill of materials)

A115 rests on claim 189unconfirmed

If it is false: If false, in at least one of the four settings the in-use period the data support is shorter than the usual gap between sessions, or the opened bag needs refrigeration. In that setting one bag serves one session, so a session costs a head plus a full bag (A114). A refrigerated opened bag also breaks home health, where storage is uncontrolled. Twins: A89 In US outpatient wound clinics the interval… (claim 163unconfirmed), and P1 per-patient HOCl bag-a (A93 The system's hypochlorous acid-preserved…, A103), which supplies the period this row compares.

Depends on it: Operations & NPI (C8, bound); Commercial (its C4, A89 In US outpatient wound clinics the interval…, is the outpatient half); Clinical & Scientific (REQ-0245 For each intended-use setting, the session intervals)

A116 rests on claim 190unconfirmed

If it is false: A threat row. If false, the registry read missed contract fillers of sterile HOCl in bags, and the supply concern shrinks. The row is here for the other direction. If true, the only contract maker listing an HOCl wound solution makes it for Urgo, and no contract maker lists sterile HOCl in a flexible bag. Then A52 Sterile HOCl wound-irrigation solution… (claim 128unconfirmed, two independent fillers) has nothing under it in the public record. P1 per-patient HOCl bag's bag is then sourced from an incumbent or made in-house, now with a custom keyed port (A88 US facility and agency purchasers). Bad news arrives as verified.

Depends on it: Operations & NPI (C9, bound: its answer to REQ-0229 From public records first); Commercial (the shape-(c) supply route); Legal & IP (supply from a licensed incumbent turns FTO into a contract term)

A117 rests on claim 191unconfirmed

If it is false: If false, under worst-case use a direct-reading monitor in the operator's breathing zone reads chlorine above the 1 ppm Table Z-1 ceiling, or droplet concentration is higher with the shield fitted than without it. Then the working-environment proposition reverses. The shield gathers an above-limit exposure at face height, the system needs respiratory controls, and shield and nozzle tooling waits on a redesign. Twins: A72 During simulated wound irrigation with the… (claim 148unconfirmed), A99 In simulated or clinical use (claim 173unconfirmed, a stricter pass mark) and A34 Open safety question (claim 51unconfirmed). Needs a built head, so expected back unconfirmed.

Depends on it: Operations & NPI (C10, bound; it owns the pass mark under REQ-0227 Own the staff-exposure pass mark for HOCl…); Technology & R&D (A72 During simulated wound irrigation with the…); Clinical & Scientific (A99 In simulated or clinical use); Commercial

A118 rests on claim 192unconfirmed

If it is false: If false, after production sterilization and ageing, the chamber and check valves crack, leak, fail or shed particulate within twice a full session's squeeze cycles. Then the head fails in use the way the Surgiphor squeeze containers did, the valved assembly is redesigned and re-verified, and delivered pressure (A69 The kit's three-nozzle head) cannot be relied on late in a session.

Depends on it: Operations & NPI (C11, bound); Technology & R&D

A119 rests on claim 193unconfirmed

If it is false: If false, an in-force US patent or pending application outside the named families claims a single-use head with a hand-squeezed chamber refilled through a check valve, or a head-to-bag connector keyed to one maker's bag. Then FTO for the two elements P1 per-patient HOCl bag added is blocked by an unnamed holder until a licence or a design-around exists, and the keyed connector that P1 per-patient HOCl bag-b rests on may be someone else's. Extends A79 Apart from the patent families named in… (claim 155unconfirmed) to P1 per-patient HOCl bag's new elements. A sweep cannot verify an absence, so it is expected back unconfirmed.

Depends on it: Legal & IP (C20, bound); Technology & R&D; Commercial

A120 rests on claim 194unconfirmed

If it is false: Both directions break something. If false, the first US sale of the P1 per-patient HOCl bag head comes after 2032-03-14. That is more than five years out, and the calendar to first revenue runs past early 2032. If true, the head launches inside a live Schultz term (about 2032-04 on A76 US 8,672,904 B1, later on A108 or A109). Counsel's read of A107's claims against the defined head, or a design-around, then becomes a launch item rather than a wait. Operations' own declared estimate, which is not a claim, is late 2028 to late 2030. It needs a supplier and a confirmed route, so it is expected back unconfirmed.

Depends on it: Operations & NPI (C12, bound: its answer to REQ-0250 What is the earliest plausible date the P1…); Legal & IP (its blocks trigger turns on the launch date); Regulatory (the head's route, A106)

A121 rests on claim 195unverified

If it is false: If false, no single connector on the per-patient bag both accepts only this maker's head and reseals between sessions, or FDA would not accept a maker-keyed port on a wound-irrigation bag inside a 510(k) or exempt route. Then the head cannot be made to fit only this bag. It is sold for any bag, which is neighbour (a), and the bag has to win alone as a parity HOCl solution. That is the same consequence as P1 per-patient HOCl bag-b (A88 US facility and agency purchasers) failing, reached from the engineering and clearance side rather than from the buyer's. If keying survives and resealing does not, A94 The per-patient bag's access port accepts a… (claim 168unconfirmed) fails with it and so does the opened bag (A93 The system's hypochlorous acid-preserved…, A103). Under the spent pivot budget, a failure here is recorded as commission, and the next shape is the owner's decision. Twins: A88 US facility and agency purchasers (claim 162unconfirmed, buyers accept the keyed head) and A94 The per-patient bag's access port accepts a… (claim 168unconfirmed, the port recloses).

Depends on it: Front end, through /assess (pillar B2 The single-use head is keyed to this…: P1 per-patient HOCl bag-c, the unstated premise named at loop turn 2); Technology & R&D (REQ-0234 In the P1 reference design: whether keying and resealing can share one connector); Regulatory (REQ-0255 P1's mechanism makes the single-use head…: whether FDA accepts a non-standard, maker-keyed port); Commercial (the head's fit is P1 per-patient HOCl bag's pull-through, A88 US facility and agency purchasers); Operations & NPI (a keyed port makes the bag a custom part, A52 Sterile HOCl wound-irrigation solution…, A116); Legal & IP (the keyed connector is unsearched, A119)

Open questions between departments 38 open of 57

Any department may ask any other what it cannot answer itself. The answer must name an artifact that exists — a research report, a position, a dossier — never a summary.

RequestFrom → toQuestionState
REQ-0199 operations-npi → technology For the P0 the original shape kit: (a) the fill volume of the bag per kit, against the volume one irrigation uses; (b) whether the line and three-nozzle head are pre-connected to the bag and wetted with HOCl in storage, or stored dry and connected at the point of use (the… answered
REQ-0200 operations-npi → commercial What per-kit price does the money model assume, at what annual kit volume in years 1 and 3, and does that price assume the head and shield are discarded at every irrigation? accepted
REQ-0201 market-access → research For Region Nordjylland's joint wound tender (TED contract notice 549630-2024, corrected 572935-2024; award notice 705177-2025), retrieve the full notice XML or the EU-Supply tender documents and quote verbatim: (a) the product specification of lot 50… open
REQ-0202 market-access → research Outside Medicare, does any US payer pay separately for HCPCS (Healthcare Common Procedure Coding System) A6260 (wound cleansers, any type, any size)? Retrieve, by document, the A6260 line of the Medicaid DME (durable medical equipment)/medical-supply fee schedules of at least five large state programmes (for example CA, NY, TX… open
REQ-0203 clinical → technology For the P0 the original shape three-nozzle head fed from the prefilled bag: what wound-impact pressure does it deliver, measured at the labelled working distance, at full, half and near-empty bag (head height or squeeze), with each nozzle open? Is the 4-15 psi in intended_use a… withdrawn
REQ-0204 clinical → regulatory Could an FRO 510(k) for the co-packaged P0 the original shape kit be supported by non-clinical performance data alone (bench pressure, preservative effectiveness, stability, biocompatibility), as K142592 was (claim 7verified), or would FDA expect clinical performance data for a new… answered
REQ-0205 clinical → regulatory Would FDA accept HOCl described as a preservative of the solution in a sterile, single-use bag consumed in one irrigation session, where there is no repeated-entry contamination risk for a preservative to address? Are the 1000 and 3000 mL Puracyn Plus bags… withdrawn
REQ-0206 clinical → research Retrieve and quote what the current graded guidelines say about cleansing solutions, and about HOCl specifically, for the P0 the original shape indications: NPIAP/EPUAP/PPPIA 2019 pressure-injury guideline, IWGDF 2023 wound-healing guideline, WHS guidelines, WOCN guidance, and… open
REQ-0207 clinical → research Two comparative-evidence retrievals no connector reaches: (a) the status and any results of Factorial4VLU, ACTRN12620000116921 (HOCl wound solution vs placebo solution in venous leg ulcers, target n=380, primary healed at 12 weeks; protocol PMID 33602710), on… open
REQ-0208 technology → front-end Obtain from the referrer, in writing, Aquaceso's technical description: (1) how irrigation pressure is generated and held (gravity, hand squeeze of the bag, pressure cuff, squeeze chamber in the head, or a pump) and what pressure the three-nozzle head… accepted
REQ-0209 technology → research Find published measurements of free available chlorine (or HOCl concentration) in hypochlorous acid or hypochlorite wound-care or medical solutions at 100-500 ppm and pH 3.5-7, held at 35-40 C, at short times (up to 60 minutes) and over multi-day warm… open
REQ-0210 technology → clinical Is warming the irrigant to about body temperature a clinical requirement, or an evidence-backed expectation of clinicians, for cleansing and irrigation of acute and chronic dermal wounds at dressing change in the settings in intended_use, and if so what… answered
REQ-0211 technology → regulatory The kit's bag cannot reach 4-15 psi by gravity and reaches only about 4 psi by hand compression (condition C1), so the head needs a pressurisation element. Three architectures are feasible: (a) a hand-squeezed chamber in the head refilled from the bag through… answered
REQ-0212 legal-ip → research Run a recorded, query-by-query US patent landscape over the parts of the idea-023 FTO question nobody has searched: (a) hand-held multi-nozzle wound-irrigation spray heads fed through a line from a flexible bag, setting irrigation pressure without a pump; (b)… open
REQ-0213 commercial → operations-npi What is the landed unit cost range of one P0 the original shape kit (prefilled sterile HOCl-preserved saline irrigation bag, three-nozzle spray head, integral splash shield, all single-use) at launch volume, and which component dominates it? withdrawn
REQ-0214 commercial → market-access For an outpatient wound clinic billing 97597/11042 in the non-facility (physician-office) setting, are irrigation supplies used during the visit funded inside the practitioner's practice-expense RVU (97597 non-facility PE portion $75.19, 2026), so that the… answered
REQ-0215 commercial → clinical Is there any measurement, bench or clinical, of face-and-chest splash or aerosol reduction from a splash shield on a bag-fed, multi-nozzle irrigation head at 4-15 psi, as opposed to the syringe-type shields measured in claim 101verified; and if not, what bench study… answered
REQ-0216 commercial → regulatory Does 29 CFR 1910.1030(d)(3)(x) continue to require masks with eye protection or face shields during wound irrigation when an integral splash shield is in place, or does an OSHA interpretation recognise such a shield as an engineering control that reduces that… open
REQ-0217 regulatory → research Retrieve EU MDR notified-body certificates or EUDAMED device records for HOCl wound irrigation solutions (Microdacyn60 Wound Care, Granudacyn, any Vashe EU equivalent), reading class, classification rule and intended purpose; and retrieve the MDCG… open
REQ-0218 regulatory → technology Can an HOCl-preserved saline irrigation bag hold its free available chlorine specification and pass USP <51> preservative effectiveness over a defined in-use period after first spike, for multiple uses within a single patient (the K232080 configuration)? answered
REQ-0219 regulatory → clinical What adequate and well-controlled clinical evidence would support a label claim that HOCl irrigation reduces wound infection or bioburden versus saline in chronic wounds, and does any such trial exist? answered
REQ-0220 regulatory → commercial Does the closed-kit consumable pull-through still hold if the HOCl bag becomes a multiple-use, single-patient item (spiked once, used across several dressing changes for one patient) while the spray head and shield stay single-use per session or per patient? answered
REQ-0221 legal-ip → research For each named in-force family, retrieve the granted independent claims verbatim and the statutory term (earliest US non-provisional benefit date, PTA, terminal disclaimers, maintenance-fee state) from USPTO Patent Center or the granted text: US 8,871,278 and… open
REQ-0222 legal-ip → research EP/DK counterpart search for the referrer's home market: (a) EP members and Danish validations (or unitary effect) of the US families in claims 52, 56, 80, 81 and 85 and of US 12,642,907; (b) status and claims of Heraeus Medical EP4806473A1, EP4806474A1… open
REQ-0223 legal-ip → technology Specify the P0 the original shape kit's solution and hardware precisely enough to run an FTO search against: (1) own formulation, or supply from a named cleared maker; (2) for the solution: available free chlorine (ppm), pH, chloride or salinity, buffer, and whether a… open
REQ-0224 legal-ip → front-end Ask the referrer, through the owner: who manufactures Aquaceso; who holds the rights in its design; what patent, utility-model, registered-design or trademark numbers, if any, appear on its product, IFU, packaging or marketing material; and whether the… accepted
REQ-0225 front-end → commercial Design, and say who would run, the primary buyer research that would settle claim 62unconfirmed for the P1 per-patient HOCl bag shape: would US hospital, outpatient wound-clinic, SNF and home-health value-analysis or supply-chain buyers pay more per irrigation session for a single-use… answered
REQ-0226 front-end → commercial Design the primary research that would settle claim 116unconfirmed: do US wound clinicians (wound-care nurses, wound-clinic physicians, podiatrists) believe HOCl cleansing is clinically superior to saline for chronic wounds, and does that belief decide what their… answered
REQ-0227 front-end → operations-npi Own the staff-exposure pass mark for HOCl spray irrigation inside the integral shield, and specify the breathing-zone study that would test it. Clinical's C2 (claim 140unconfirmed) sets 'below detection limits'; Technology's C6 (claim 148unconfirmed) sets 'below the OSHA ceiling… answered
REQ-0228 front-end → research Retrieve the labelled storage condition, unopened shelf life and in-use period after first opening of each FDA-cleared HOCl wound irrigation solution supplied in a flexible bag or a container of 1 L or more: Puracyn Plus (K232080, K251757), Vashe (K123072… open
REQ-0229 front-end → operations-npi From public records first (FDA establishment registration and device listing, 510(k) summaries that name a manufacturer, contract-manufacturer directories), list the contract manufacturers that fill sterile HOCl or other oxidising wound-irrigation solutions… answered
REQ-0230 front-end → research Retrieve the VA Federal Supply Schedule catalogue entry for contract V797D-50441 (Urgo Medical North America, Vashe line) from the VA National Acquisition Center contract catalog, and quote every Vashe presentation listed with its fill volume, unit of sale… open
REQ-0231 front-end → research From the IWII 2022 consensus PDF already retrieved for claim 86verified (Wounds International, 'Wound Infection in Clinical Practice', International Consensus Update 2022), quote verbatim, with page numbers, every passage that names hypochlorous acid, super-oxidised… open
REQ-0232 front-end → research Retrieve the granted independent claims verbatim and the statutory term (earliest US non-provisional benefit date, PTA, terminal disclaimers, maintenance-fee state) of US 10,568,785 B2 The single-use head is keyed to this… (Medaxis AG, 'Protective cover', family of US 2017/0049641 A1 Assumption), in the… open
REQ-0233 commercial → operations-npi For the P1 per-patient HOCl bag shape, what is the landed unit cost range at launch volume of (a) one single-use head assembly (spike and short line, three-nozzle head, hand-squeezed chamber with check valve, integral splash shield; stored dry, sterilized separately) and (b) one… answered
REQ-0234 commercial → technology In the P1 per-patient HOCl bag reference design, is the head-to-bag connection a proprietary interface that will not accept other manufacturers' irrigation bags, or a standard spike that fits any spikeable irrigation bag or bottle (for example the Puracyn Plus spikeable… open
REQ-0235 market-access → operations-npi For the P1 per-patient HOCl bag per-patient HOCl bag, in each setting in intended_use (hospital inpatient, hospital outpatient wound clinic, physician-office wound clinic, SNF, home health): between irrigation sessions, does the opened bag stay in the custody of the facility… answered
REQ-0236 market-access → research For Region Nordjylland's joint wound tender (TED contract notice 549630-2024, corrected 572935-2024; EU-Supply U397-25; award notice 705177-2025), retrieve the tender documents and quote verbatim the product specification of lot 51 'Sårskyllekapsel' and of… open
REQ-0237 technology → clinical For each wound type and setting in idea-023's intended_use, what volume of irrigant is used in one irrigation session at a dressing change (median and range, in mL, from published practice data or guidance), and how many sessions a day or a week does one… open
REQ-0238 technology → research (1) How is a cleared HOCl irrigation bag labelled for multiple use within a single patient (Puracyn Plus K232080 and K251757) accessed between uses? Quote the IFU, label or manufacturer text on port type (spike port, needle-free or luer-activated valve… open
REQ-0239 clinical → technology For the P1 per-patient HOCl bag reference head (hand-squeezed chamber refilled from the per-patient bag through a check valve, three nozzles, integral shield): (a) is there a one-way outlet valve, or an equivalent, so that releasing the chamber cannot draw wound fluid, debris or… open
REQ-0240 clinical → regulatory For a sterile HOCl-preserved wound wash in a flexible bag labelled for multiple use within a single patient (the K232080 and K251757 Puracyn Plus configuration), what in-use evidence did FDA accept to support the labelled in-use period after first opening… open
REQ-0241 regulatory → research Carried from REQ-0216 Does 29 CFR 1910.1030, which is outside the regulatory chair's field (OSHA workplace-safety compliance is the employer's obligation, not the device's premarket route). Retrieve OSHA letters of interpretation, compliance directives (e.g. CPL 02-02-069) or… open
REQ-0242 regulatory → technology What labelled in-use period is the P1 per-patient HOCl bag bag designed to: the number of days after first spike, the maximum number of head connect-and-disconnect cycles, and the storage conditions between sessions (temperature, light, and whether the bag stays in its foil… open
REQ-0243 operations-npi → technology For the P1 per-patient HOCl bag head and bag: (1) the materials of the hand-squeezed chamber and of each check valve (elastomer, housing, any spring), confirming no metal in the wetted path; (2) the intended sterilization modality for the dry head assembly (EO or radiation) and… open
REQ-0244 operations-npi → commercial For P1 per-patient HOCl bag: what per-session price for the single-use head assembly and what per-bag price does the money model assume; what annual head-assembly and bag volumes in years 1 and 3; how many sessions per bag in each of the four settings; and is 'made to fit only… open
REQ-0245 operations-npi → clinical For each intended-use setting (hospital, outpatient wound clinic, skilled nursing facility, home health) and the main indications in intended_use, what is the usual interval between two consecutive irrigation sessions for one patient (dressing-change… open
REQ-0246 operations-npi → regulatory Under FDA's use of ISO 10993-1, should the biological evaluation of the P1 per-patient HOCl bag per-patient bag's solution and of the single-use head's fluid path be categorised by cumulative contact across repeated irrigation sessions in one patient over weeks (prolonged or… open
REQ-0247 legal-ip → research For the US leads the P1 per-patient HOCl bag re-statement surfaced, retrieve from USPTO Patent Center and the grant documents: (i) for US 10,363,356 B2 The single-use head is keyed to this…, whether the benefit claim printed on its face (continuation of 12/851,476, itself a CIP chain back to 09/484,666 filed… open
REQ-0248 legal-ip → research Run a recorded US landscape, query by query, over the two head elements P1 per-patient HOCl bag added: (a) a single-use hand-held wound-irrigation head carrying a hand-squeezed pressurisation chamber refilled from a bag through a check valve (start from CPC A61M3/0262… open
REQ-0249 legal-ip → technology For the P1 per-patient HOCl bag head assembly, state as design inputs (or say they are not yet fixed): whether the splash shield is integral and non-removable or attaches by a connector, and whether alternative shields attach; where each nozzle orifice's distal tip sits relative… open
REQ-0250 legal-ip → operations-npi What is the earliest plausible date the P1 per-patient HOCl bag head could be on sale in the US, given Regulatory's route for it (claim 180unconfirmed) and the design, verification and industrialisation steps still ahead? A range with its stated basis is enough. answered
REQ-0251 front-end → research Retrieve the CMS calendar-year 2026 Physician Fee Schedule final-rule direct practice expense input files (the supply, equipment and clinical-labour inputs by CPT code, published with the CY 2026 PFS final rule) and quote every supply input listed for CPT… open
REQ-0252 front-end → research Apart from the surgical dressing benefit (policy article A54563 lists A6260 as non-covered there), does any Medicare Part B benefit category pay for a wound cleanser billed as HCPCS A6260 that is dispensed to a beneficiary for home use between outpatient… open
REQ-0253 front-end → research Replay, query by query and with the retrieval date, the openFDA device registration-and-listing search recorded in claim 190unconfirmed: api.fda.gov/device/registrationlisting.json searched by proprietary name for Vashe, Puracyn, Microcyn, Granudacyn, Microdacyn… open
REQ-0254 front-end → research Search openFDA 510(k) and classification records, and the 510(k) summaries of the hits, for any cleared or listed device under product code FQH (21 CFR 880.5475) or KYZ (21 CFR 880.6960) that is a non-powered, hand-operated wound-irrigation applicator or… open
REQ-0255 front-end → regulatory P1 per-patient HOCl bag's mechanism makes the single-use head 'fit only this bag': a non-standard, keyed head-to-bag connector that must also reclose between sessions (claim 168unconfirmed). In your field: does any FDA guidance, special control, recognised consensus standard (for example… open
What this is waiting on 38 open item(s), rebuilt from the files

python3 engine/scripts/check_loop.py --candidate idea-023 --open

Elsewhere

The packet All claims How the loop works

Nothing on this page is a recommendation, and no verdict here is a decision. This is a compilation of what the loop record, the position files and the request ledger say. Shortlist review and every decision past it are human-only.

Words on this page35 abbreviation(s) and code(s), with what each stands for — copied from _shared/plain-language.md
21 CFR
Title 21 of the Code of Federal Regulations — the US food-and-drug rulebook; a number after it is one regulation, often the one that classifies a device type
510(k)
premarket notification — the FDA route for a device shown to be as safe and effective as one already on the market; months, no clinical trial as a rule
A####
a HCPCS code for a supply — one billing code for a supply or an accessory; the letter A and four digits
BOM
bill of materials — the list of parts in a product and what each costs
CDRH
Center for Devices and Radiological Health — the part of the FDA that handles devices
Class II
FDA device class II — moderate-risk devices, usually cleared by 510(k)
Class III
FDA device class III — the highest-risk devices, usually approved by PMA
CMS
Centers for Medicare & Medicaid Services — the US agency that runs Medicare, and so decides what Medicare pays for
CPT
Current Procedural Terminology — the US billing codes for what a clinician does; owned by the American Medical Association
CY
calendar year — the year a Medicare rule or fee schedule applies to
De Novo
De Novo classification request — the FDA route for a new, lower-risk device with no comparable product to point at; longer than a 510(k), usually needs clinical data
DFU
diabetic foot ulcer — a slow-healing wound on the foot of a person with diabetes
DME
durable medical equipment — equipment a patient uses at home, such as a pump or a stimulator, that Medicare pays for under its own rules
DMEPOS
durable medical equipment, prosthetics, orthotics and supplies — the Medicare benefit and fee schedule that home equipment is paid under
EPO
European Patent Office — the European patent office
FDA
US Food and Drug Administration — the US regulator that clears or approves a device before it can be sold
FFS
fee-for-service — the traditional form of Medicare that pays per item or service
FTO
freedom to operate — whether a product can be sold without infringing someone else's live patent
HCPCS
Healthcare Common Procedure Coding System — the US billing codes for equipment, supplies and some services; a code is how a payer recognises what to pay for
IFU
instructions for use — the labelling that says what a device is for and how to use it
IP
intellectual property — patents and the other rights that let a company stop others copying it
ISO
International Organization for Standardization — the body whose numbered standards devices and laboratories are tested against
K######
an FDA 510(k) clearance number — the public record of one cleared device; the letter K and six digits
MDR
medical device report — a report to the FDA of a device problem
Medicare Part B
Medicare Part B — the part of Medicare that pays for outpatient care and equipment used at home
mmHg
millimetres of mercury — the unit blood pressure, and the suction of a wound pump, are measured in
NCT########
a ClinicalTrials.gov registration number — the public id of one registered clinical trial
NPI
new product introduction — taking a design into manufacture: tooling, suppliers, first production
PFS
physician fee schedule — the Medicare price list for what clinicians do
PMA
premarket approval — the FDA route for the highest-risk devices; years and clinical trials
PMID
PubMed identifier — the public id of one published medical paper
RCT
randomised controlled trial — the kind of clinical study that compares a treatment against an alternative by chance assignment
RVU
relative value unit — the unit Medicare uses to price a clinician's work
TAM
total addressable market — how much money the whole market would be worth if every possible buyer bought
USPTO
United States Patent and Trademark Office — the US patent office