K Number
K200787
Device Name
BSD3543W
Manufacturer
Date Cleared
2020-04-23

(28 days)

Product Code
Regulation Number
892.1680
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The BSD3543W (BT-DA22W/BT-DB22W) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all general-purpose diagnostic procedures. It is not to be used for mammography.

Device Description

BSD3543W (BT-DA22W/BT-DB22W) is a digital X-ray flat panel detector which intercepts x-ray photons and the scintillator (BT-DB22W(Gdos) / BT-DA22W(CsI)) emits visible spectrum photons that illuminate an array of photo (a-SI)-detector that creates electrical signals. After the electrical signals are generated, it is converted to digital values, and the images will be displayed on the monitor. This device should be integrated with an operating PC and an X-Ray generator. It can digitalize x-ray images and transfer them for radiography diagnostics. Advanced digital image processing allows considerably efficient diagnosis, all kinds of information management, and sharing of image information on network. The BSD3543W is a wireless version of the predicate device, the BSD3543.

AI/ML Overview

The provided document K200787 describes the BSD3543W digital flat panel X-ray detector. It is a 510(k) submission, comparing the device to a predicate device (BSD3543, K162487) and a reference device (ClearVision Exam Vue Flat Panel Detector, K160143) to demonstrate substantial equivalence.

Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

1. A table of acceptance criteria and the reported device performance

The document does not explicitly present a formal "acceptance criteria" table with pass/fail thresholds for clinical performance. Instead, it relies on demonstrating substantial equivalence to a predicate device (BSD3543) and a reference device (ClearVision ExamVue Flat Panel Detector). The performance criteria are implicitly defined by matching or exceeding the predicate device's specifications for various technical parameters and by demonstrating "similar quality overall" in clinical image comparison.

Here's a table summarizing the key comparative data presented, which serves as the basis for demonstrating equivalence and thus "meeting acceptance criteria" in a 510(k) context:

CharacteristicAcceptance Criteria (Implied by Predicate/Reference)Reported Device Performance (BSD3543W)
Indications for UseSame as predicate: General radiographic system for human anatomy, replacing film/screen; not for mammography.Same: Digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all general-purpose diagnostic procedures. It is not to be used for mammography. (Page 5)
Detector TypeAmorphous Silicon (a-Si), TFTAmorphous Silicon (a-Si), TFT
ScintillatorGdos (BT-DB22-IA) / CsI (BT-DA22-IA)Gdos (BT-DB22W) / CsI (BT-DA22W)
Imaging Area14 x 17 inches14 x 17 inches
Pixel matrix2500 x 3052 (Predicate), 2466 x 3040 (Reference)2500 x 3052 (Same as predicate), similar to reference (2500 x 3052 vs 2466 x 3040)
Pixel pitch140 μm140 μm
Resolution3.5 lp/mm3.5 lp/mm
A/D conversion16 bit16 bit
Grayscale65,536 (16bit)65,536 (16bit)
Data outputRAW (convertible to DICOM 3.0 by console S/W)RAW (convertible into DICOM 3.0 by console S/W)
Viewing SWRaw Image ViewerRaw Image Viewer (Version: 1.1)
Dimensions350 x 428 x 15 mm (Predicate)384 x 460 x 15 mm (Similar, noted as different but "similar")
MTF (Spatial Resolution)Predicate: Gdos (% @ 1lp/mm: 59, % @ 2lp/mm: 28, % @ 3.5lp/mm: 10), CsI (% @ 1lp/mm: 58, % @ 2lp/mm: 26, % @ 3.5lp/mm: 10)Reported: Gdos (% @ 1lp/mm: 60, % @ 2lp/mm: 29, % @ 3.5lp/mm: 12), CsI (% @ 1lp/mm: 60, % @ 2lp/mm: 28.2, % @ 3.5lp/mm: 10.6). Stated as "almost identical but superior imaging performance compared to BSD3543 at all spatial frequencies." (Page 6)
DQEPredicate: Gdos (% @ 0lp/mm: 39.2, % @ 1lp/mm: 29, % @ 2lp/mm: 24, % @ 3.5lp/mm: 14), CsI (% @ 0lp/mm: 68, % @ 1lp/mm: 57, % @ 2lp/mm: 51, % @ 3.5lp/mm: 27)Reported: Gdos (% @ 0lp/mm: 39.2, % @ 1lp/mm: 30.2, % @ 2lp/mm: 24.9, % @ 3.5lp/mm: 14.7), CsI (% @ 0lp/mm: 70.1, % @ 1lp/mm: 60.2, % @ 2lp/mm: 54.5, % @ 3.5lp/mm: 29.7). Stated as "almost identical but superior imaging performance compared to BSD3543 at all spatial frequencies" and "similar" ability to utilize input image signal. (Page 6)
Wireless capability/functionalityNone in predicate (wired only)Wireless (and wired) capability, compared to reference device (K160143) that also has wireless. (Page 7)
Overall Clinical Image QualityImplied equivalent to predicate for diagnostic purposes"Images taken from BSD3543W, the subject device, have similar quality overall compared with BSD3543, the predicate device. There are no other radiographic abnormalities and any issue with diagnostic images." (Page 9)
SafetyGeneral electrical safety and EMC standards complianceComplies with IEC 60601-1:2005 (Electrical Safety) and IEC 60601-1-2:2014 (EMC). (Page 8)
SoftwareFunctionality of predicate's viewing softwareIdentical to predicate device's viewing software. V&V testing conducted per FDA guidance. (Page 8)
Wireless QoSN/A (for predicate)Measured parameters (Image acquired, Receiving signal level, delay time, Through, signal strength) "passed the pre-defined acceptance criteria of quality of service (QoS) by the subject device." (Page 9)

2. Sample size used for the test set and the data provenance

  • Sample Size: The document does not specify a numerical sample size for the clinical image comparison. It generally states, "Images taken from the predicate and subject devices were reviewed and rated in comparison..."
  • Data Provenance: Not explicitly stated whether the images were retrospective or prospective, nor their country of origin. Given it's a 510(k) for a hardware device (X-ray detector), the emphasis is primarily on technical equivalence and image quality rather than efficacy in a clinical trial.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

  • Number of Experts: "an American board-certified radiologist" (singular, implied to be one).
  • Qualifications of Experts: "American board-certified radiologist." No mention of years of experience or subspecialty.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable/None. Only one radiologist reviewed the images, so no adjudication method was needed or performed.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

  • No, a multi-reader, multi-case (MRMC) comparative effectiveness study was not reported. This device is a digital X-ray detector, not an AI-based diagnostic tool. The clinical study was a qualitative comparison of image quality by a single radiologist.
  • Therefore, there's no discussion of human reader improvement with AI assistance.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

  • This question is more applicable to AI algorithms. For this device (an X-ray detector), "standalone performance" refers to its technical imaging specifications (MTF, DQE, resolution, pixel pitch, etc.) measured in a lab setting, independent of a human interpreter.
  • Yes, standalone performance was done. The document presents detailed technical specifications and performance results (MTF, DQE, resolution, pixel matrix, etc.) which are intrinsic to the detector itself, measured in a "non-clinical performance testing" environment (Page 8). These are direct measurements of the detector's physical and technical capabilities.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

For the clinical image comparison, the "ground truth" was implicitly expert opinion/qualitative comparison by a single American board-certified radiologist, who judged the images from the subject device to have "similar quality overall" with no "radiographic abnormalities and any issue with diagnostic images" compared to the predicate. There is no mention of pathology or outcomes data as "ground truth."

8. The sample size for the training set

  • Not applicable. This device is a digital X-ray detector (hardware), not a machine learning/AI model that requires a "training set" in the conventional sense.
  • The "viewing software" mentioned is described as identical to the predicate and undergoes standard software verification and validation, not machine learning training.

9. How the ground truth for the training set was established

  • Not applicable, as there is no training set for an AI model.
  • For the software, "ground truth" for its validation would be that it processes and displays images correctly according to specifications, which is established through standard software verification and validation testing, not clinical "ground truth" from a diagnostic perspective.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Bontech Co. Ltd. % Mr. Dave Kim President Mtech Group 7707 Fannin Street. Suite 200 HOUSTON TX 77054

Re: K200787

Trade/Device Name: BSD3543W Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: MOB Dated: March 24, 2020 Received: March 26, 2020

Dear Mr. Kim:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for

April 23, 2020

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

For

Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K200787

Device Name BSD3543W

Indications for Use (Describe)

The BSD3543W (BT-DA22W/BT-DB22W) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all generalpurpose diagnostic procedures. It is not to be used for mammography.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary K200787

This summary of 510(k) information is being submitted in accordance with requirements of 21 CFR Part 807.92.

Date of Submission

April 17, 2020

I. SUBMITTER

Submitter's NameBONTECH Co., Ltd.
Submitter's AddressYoungtong-gu Youngtong-dong 980-3,Digital Empire D #1201,Suwon city, Gyeonggi-do, South Korea 443-702
Submitter's Telephone+82 (31) 303-5254
Contact personMr. Ki Chan Ahn / RA Manager
Official CorrespondentDave Kim (davekim@mtech-inc.net)
Address7707 Fannin St. Ste 200, Houston, TX 77054
Telephone+713-467-2607

II. DEVICE

Trade/proprietary NameBSD3543W
Digital Flat Panel X-ray Detector
Model No.BT-DA22W / BT-DB22W
Common or Usual NameSolid State X-ray Imager (Flat Panel/Digital Imager)
Regulation NameStationary X-ray System
Regulation Number21 CFR 892.1680
Product CodeMQB
Regulatory ClassClass II
Over the Counter Use

III. PREDICATE DEVICE

Primary ManufacturerBONTECH Inc.
Device NameBSD3543
Digital Flat Panel X-ray Detector
510(k) NumberK162487
Regulation NameStationary X-ray System
Regulation Number21 CFR 892.1680 (Product Code: MQB)
Regulatory ClassClass II

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IV. REFERENCE DEVICE

Trade/Device Name: 510(K) Number Regulation Name: Regulation Number Regulatory Class

ClearVision Exam Vue Flat Panel Detector K160143 stationary X-ray System 21 CFR 892.1680 (Product Code: MQB) Class II

V. DEVICE DESCRIPTION

BSD3543W (BT-DA22W/BT-DB22W) is a digital X-ray flat panel detector which intercepts x-ray photons and the scintillator (BT-DB22W(Gdos) / BT-DA22W(CsI)) emits visible spectrum photons that illuminate an array of photo (a-SI)-detector that creates electrical signals. After the electrical signals are generated, it is converted to digital values, and the images will be displayed on the monitor. This device should be integrated with an operating PC and an X-Ray generator. It can digitalize x-ray images and transfer them for radiography diagnostics. Advanced digital image processing allows considerably efficient diagnosis, all kinds of information management, and sharing of image information on network. The BSD3543W is a wireless version of the predicate device, the BSD3543.

VI. INDICATIONS FOR USE:

The BSD3543W (BT-DA22W/BT-DB22W) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all general-purpose diagnostic procedures. It is not to be used for mammography.

VII. PREDICATE COMPARISON

ProposedPredicateRemark
CharacteristicBONTECHBSD3543W(BT-DA22W/BT-DB22W)BONTECHBSD3543(BT-DA22-IA/BT-DB22-IA)
510(k)numberK200787K162487

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Indicationsfor UseThe BSD3543W (BT-DA22W/BT-DB22W) detectoris indicated for digital imagingsolution designed for generalradiographic system for humananatomy. It is intended to replacefilm or screen based radiographicsystem in all general-purposediagnostic procedures. It is not tobe used for mammography.The BSD3543(BT-DA22-IA/BT-DB22-IA) detector is indicated fordigital imaging solution designedfor general radiographic systemfor human anatomy. It is intendedto replace film or screen basedradiographic system in allgeneral-purpose diagnosticprocedures. It is not to be used formammography.Same
DetectorTypeAmorphous Silicon (a-Si), TFTAmorphous Silicon (a-Si), TFTSame
ScintillatorBT-DB22W(Gdos) / BT-DA22W(CsI)BT-DB22-IA(Gdos) / BT-DA22-IA(CsI)Same
Imaging Area14 x 17 inches14 x 17 inchesSame
Pixel matrix2500 x 30522500 x 3052Same
Pixel pitch140 μm140 μmSame
Resolution3.5 lp/mm3.5 lp/mmSame
A/Dconversion16 bit16 bitSame
Grayscale65,536 (16bit)65,536 (16bit)Same
Data outputRAW*The RAW files are convertibleinto DICOM 3.0 by console S/WRAW*The RAW files are convertibleinto DICOM 3.0 by console S/WSame
Viewing SWRaw Image ViewerRaw Image ViewerSame
Dimensions384 x 460 x 15 mm350 x 428 x 15 mmSimilar
MTF (SpatialResolution)GDOS% @ 1lp.mmCsI% @ 1lp.mmGDOS% @ 1lp.mmCsI% @ 1lp.mmSimilar
60605958

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% @2lp.mm29% @2lp.mm28.2% @2lp.mm28% @2lp.mm26
% @3.5lp.mm12% @3.5lp.mm10.6% @3.5lp.mm10% @3.5lp.mm10.
GDOSCsIGDOSCsISimilar
% @0lp.mm39.2% @0.lp.mm70.1% @0lp.mm39.2% @0lp.mm68
DQE% @ 1lp.mm30.2%@1lp.mm60.2% @ 1lp.mm29% @ 1lp.mm57
% @2lp.mm24.9%@2lp.mm54.5%@2lp.mm24%@2lp.mm51
% @3.5lp.mm14.7% @3.5lp.mm29.7% @3.5lp.mm14% @3.5lp.mm27
PowerSupplyInput: 100~240 V, 50/60 Hz,Output: 12 V, 3.75 AInput: 100~240 V, 50/60 Hz,Output: 12 V, 6 ASame
ApplicationGeneral Radiology systemAvailable with upright stand,table, universal standGeneral Radiology systemAvailable with upright stand,table, universal standSame
pictureImage: detectorImage: detector with cableSimilar
Proposed Device (K200787):Wireless, WiredPredicate Device (K162487): Wired
Wirelesscapability /functionalityThe Clear Vision ExamVue Flat Panel Detector, the reference device (K160143),uses the same detector type, aSi TFTD. Both, the subject and reference devices arewired and wireless cassette sized panel with the same function and intended use.They offer the same size: 14x17 (35x43cm), and similar pixel size: 2500 x 3052vs 2466 x 3040.

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When compared to the predicate device (K162487), the subject device, BSD3543W (BT-DA22W/BT-DB22W), presented in this submission has demonstrated equal or superior performances in terms of the following characteristics:

  • . Intended Use
  • Pixel pitch ●
  • Resolution ●
  • MTF, DQE performance
  • Operating principle ●
  • Basic design
  • . Viewing software

The imaging area and pixel matrix of BSD3543W (BT-DA22W/BT-DB22W) and the predicate device are same. The subject device and the reference device are substantially equivalent in basic design, function, operational principles and intended use.

The Clear Vision ExamVue Flat Panel Detector, the reference device (K160143), uses the same detector type, aSi TFTD, for the collection of light generated by a CsI scintillator, for the purpose of creating a digital X-ray image.

The subject device and the reference device offer the same size, 14x17 (35x43cm), similar pixel size, 2500x 3052 vs 2466 x 3040, both wired and wireless cassette sized panel, function and intended use.

VIII. SUMMARY OF NON-CLINICAL TESTS

The following FDA guidance documents were used in the development of BSD3543W.

  • . "Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices"
  • . "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices"
  • . "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices"
  • . "Radio Frequency Wireless Technology in Medical Devices"

To minimize electrical and mechanical hazards, BONTECH adheres to recognized and established industry practice, and all equipment complies with the relevant FDA and international standards.

Through verification and validation activities, engineering testing and standards compliance testing were successfully conducted and did not raise any new safety questions or concerns or identify new risks.

The instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner :

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Electrical Safety:

Testing was conducted in accordance with IEC 60601-1:2005, COR1:2006, COR2:2007, AMD1:2012 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2012 reprint))

Electromagnetic Compatibility:

Testing was conducted in accordance with IEC 60601-1-2:2014 Medical Electrical Equipment - Part 1-2: General Requirements for basic safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility - Requirements And Tests

Software:

The viewing software for the subject device is identical to the predicate device. Software verification and validation testing as recommended in FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." (May 11, 2005)

Performance testing was conducted to show that the subject device performs as intended and equally or superior than the performance of the predicate device.

The non-clinical performance testing constrains that the main physical values for performance of X-ray detectors such as DOE and MTF. The performance test results show that the subject device, BSD3543W (BT-DA22W/BT-DB22W), offers almost identical but superior imaging performance compared to BSD3543 at all spatial frequencies. The ability of BSD3543W (BT-DA22W/BT-DB22W) to utilize the input image signal are similar to BSD3543 at same patient exposure levels as shown in the detective quantum efficiency graph.

The detector is tested for the integration to a generator and viewing software as below. -Generator:

  • kV Range: 40125kV, 1kV step (Optional 40150kV)

  • mA Range: 10 to 500mA

  • Timer Range: 0.001 to 10 sec, 38 steps

-Viewing Software:

S/W name: Raw Image Viewer, Version: 1.1

  • Data format: raw
    The subject device's wireless transmission parameters were evaluated using E.U.T for radio frequency wireless coexistence test. These parameters are used to assess the quality of service (OoS) provided by the subject device wireless function.

To characterize the wireless medical telemetry system for this QoS study, the measured parameters consisted of 1) Image acquired, 2) Receiving signal level, 3) delay time, 4)Through, and 5) signal strength and the outcomes passed the pre-defined acceptance criteria of quality of service (OoS) by the subject device.

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IX. SUMMARY OF CLINICAL TESTS

Images taken from the predicate and subject devices were reviewed and rated in comparison by an American board-certified radiologist. Based on image comparison test and data analysis, images taken from BSD3543W, the subject device, have similar quality overall compared with BSD3543, the predicate device. There are no other radiographic abnormalities and any issue with diagnostic images.

X. CONCLUSIONS

Based on the information above, BSD3543W (BT-DA22W/BT-DB22W) digital flat panel detector is substantially equivalent to the predicate device.

§ 892.1680 Stationary x-ray system.

(a)
Identification. A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.