This is likely to be considered "not a medical device", which would make it exempt from all medical devices regulations.
- I would consider changing "medical use" to "clinical use", as the former is a bit more vague. Training medical personnel might be considered a medical use. Clinical use means use for treating (etc.) human patients.
- Intended use (which is what the FDA considers when ruling whether something is a medical device or not) is not determined solely by labeling, so make sure that your org's entire conduct (including sales force verbal statements, website contents etc.) supports a conclusion/impression that no clinical use is intended.
