K Number
K031385
Device Name
ANZAI AZ-733 RESPIRATORY GATING SYSTEM
Date Cleared
2003-11-10

(193 days)

Product Code
Regulation Number
892.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The AZ-733 Respiratory Gating System is intended to be used with diagnostic x-ray or radiation therapy systems to gate these devices on and off when target points of the patient's respiratory cycle are within preset limits.
Device Description
The AZ-733 Respiratory Gating System system employs a respiratory sensor which can be fixed directly to or nearly to a patient, and detects the respiratory motion changes according to the type of sensor, a load cell (standard) or laser sensor (optional). The Load Cell detects the mechanical expansion of the thoracic cavity resulting from the respiratory motion as the pressure changes of up/downward movement of the chest and abdomen. The Laser Sensor detects the distance change to the chest surface with the expansion of the thoracic cavity resulting from the respiratory motion of the chest and abdomen. The analog signals from the Respiratory Sensor are detected and transmitted to the Sensor Port. There those signals are amplified, converted into digital form, and then output through a cable to the Wave Deck. The Wave Deck processes the signals, changing them into serial format for transmission to the Personal Computer. The Personal Computer monitors the respiratory signals all the time and commands the Wave Deck to output the gating signals when those respiratory signals reach the preset phase of respiration. Those gating (TTL) signals are transmitted to diagnostic imaging apparatus like X-ray CT or radiation therapy equipment.
More Information

Not Found

No
The description details a system that uses sensors to detect respiratory motion and trigger gating signals based on preset limits. There is no mention of learning, adaptation, or complex pattern recognition that would indicate AI/ML. The processing described is signal amplification, conversion, and comparison to fixed thresholds.

No
The device is used to gate diagnostic x-ray or radiation therapy systems, which are therapeutic devices, but the device itself does not provide therapy.

No.

The device is described as a "Respiratory Gating System" that "gates" diagnostic x-ray or radiation therapy systems. It senses respiratory motion to control other diagnostic or therapy devices, but it does not independently diagnose any medical condition.

No

The device description explicitly details hardware components like a respiratory sensor (load cell or laser sensor), a Sensor Port for signal processing, a Wave Deck for further processing, and a Personal Computer. This indicates it is a system with significant hardware components, not solely software.

Based on the provided information, the AZ-733 Respiratory Gating System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly states it's used with diagnostic x-ray or radiation therapy systems to gate these devices based on the patient's respiratory cycle. This is a function related to controlling medical equipment based on physiological signals, not analyzing biological samples outside the body.
  • Device Description: The description details how it detects respiratory motion using sensors (load cell or laser) and processes these signals to generate gating signals for other medical devices. It does not mention any interaction with biological samples like blood, urine, or tissue.
  • Lack of IVD Characteristics: IVD devices are designed to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The AZ-733 does not perform any such analysis on biological samples.

Therefore, the AZ-733 Respiratory Gating System falls under the category of a medical device used in conjunction with imaging and therapy systems, but it is not an IVD.

N/A

Intended Use / Indications for Use

The AZ-733 Respiratory Gating System is intended to be used with diagnostic x-ray or radiation therapy systems to gate these devices on and off when target points of the patient's respiratory cycle are within preset limits.

Product codes

90 LHN

Device Description

The AZ-733 Respiratory Gating System system employs a respiratory sensor which can be fixed directly to or nearly to a patient, and detects the respiratory motion changes according to the type of sensor, a load cell (standard) or laser sensor (optional).

The Load Cell detects the mechanical expansion of the thoracic cavity resulting from the respiratory motion as the pressure changes of up/downward movement of the chest and abdomen. The Laser Sensor detects the distance change to the chest surface with the expansion of the thoracic cavity resulting from the respiratory motion of the chest and abdomen.

The analog signals from the Respiratory Sensor are detected and transmitted to the Sensor Port. There those signals are amplified, converted into digital form, and then output through a cable to the Wave Deck. The Wave Deck processes the signals, changing them into serial format for transmission to the Personal Computer. The Personal Computer monitors the respiratory signals all the time and commands the Wave Deck to output the gating signals when those respiratory signals reach the preset phase of respiration. Those gating (TTL) signals are transmitted to diagnostic imaging apparatus like X-ray CT or radiation therapy equipment.

Mentions image processing

No

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The device has been designed to the requirements of the EN-60601-1-1 for electrical safety and EN-60601-1-2 for electromagnetic compatibility. Testing is currently under way and the device will not be marketed in the U.S. until the testing has been successfully completed.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K983629

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.5050 Medical charged-particle radiation therapy system.

(a)
Identification. A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.(b)
Classification. Class II. When intended for use as a quality control system, the film dosimetry system (film scanning system) included as an accessory to the device described in paragraph (a) of this section, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

0

NOV 1 0 2003

K031385

510(k) Summary

AZ-733-V Respiratory Gating System

Common/Classification Name: Radiographic ECG/Respiratory Synchronizer 21 CFR 892.1970

Anzai Medical Company, Ltd. 3-6-25 Nishi-Shinagawa Shinagawa-ku Tokyo 141-0033 Japan

Contact: T. Kaneko, Prepared: April 28, 2003

LEGALLY MARKETED PREDICATE DEVICES A.

The AZ-733 Respiratory Gating System is substantially equivalent to the Varian RPM Respiratory Gating System, which was cleared for marketing by FDA on June 8, 1999 under K983629.

DEVICE DESCRIPTION B.

The AZ-733 Respiratory Gating System system employs a respiratory sensor which can be fixed directly to or nearly to a patient, and detects the respiratory motion changes according to the type of sensor, a load cell (standard) or laser sensor (optional).

The Load Cell detects the mechanical expansion of the thoracic cavity resulting from the respiratory motion as the pressure changes of up/downward movement of the chest and abdomen. The Laser Sensor detects the distance change to the chest surface with the expansion of the thoracic cavity resulting from the respiratory motion of the chest and abdomen.

The analog signals from the Respiratory Sensor are detected and transmitted to the Sensor Port. There those signals are amplified, converted into digital form, and then output through a cable to the Wave Deck. The Wave Deck processes the signals, changing them into serial format for transmission to the Personal Computer. The Personal Computer monitors the respiratory signals all the time and commands the Wave Deck to output the gating signals when those respiratory signals reach the preset phase of respiration. Those gating (TTL) signals are transmitted to diagnostic imaging apparatus like X-ray CT or radiation

000036

1

therapy equipment.

K03/385

C. INTENDED USE

The AZ-733 Respiratory Gating System is intended to be used with diagnostic x-ray or radiation therapy systems to gate these devices on and off when target points of the patient's respiratory cycle are within preset limits.

D. SUBSTANTIAL EQUIVALENCE SUMMARY

The AZ-733 Respiratory Gating System has similar, but not identical, indications for use as the currently marketed Varian RPM Respiratory Gating System. The differences relate only to the specific characteristics of each device and do not change the intended diagnostic or therapeutic effect. The devices clearly have the same intended use the gating of radiation therapy devices through analysis of respiratory waveforms from The AZ-733 Respiratory Gating System has the "same the patient. technological characteristics" as the currently marketed Varian RPM device. The descriptive characteristics are sufficiently precise to assure substantial equivalence except in a few cases where performance data are provided. A comparison of these characteristics demonstrates substantial equivalence.1

TECHNOLOGICAL CHARACTERISTICS E.

The technological characteristics of the sensors of the AZ-733 is somewhat different from the predicate device. The processing of the detected signals uses very similar technology.

The sensor of the AZ-733 can be either a strain gauge or a laser sensor. The predicate device uses a video camera and image processing to follow movement.

F. TESTING

The device has been designed to the requirements of the EN-60601-1-1 for electrical safety and EN-60601-1-2 for electromagnetic compatibility. Testing is currently under way and the device will not be marketed in the U.S. until the testing has been successfully completed.

1 The meaning of the terms "substantial equivalence" and "substantially equivalent" as used in this 510(k) is limited to the way they are defined in, and used by FDA in accordance with, Sections 513(f)(1) and 513(l)(1) of the Federal Food, Drug, and Cosmetic Act.

2

K031385

CONCLUSIONS G.

This pre-market notification has demonstrated Substantial Equivalence as defined and understood in Sections 513(f)(1) and 513(i)(1) of the Federal Food Drug and Cosmetic Act and various guidance documents issued by the Center for Devices and Radiological Health.

3

Image /page/3/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized image of an eagle with three lines forming its body and head. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the eagle.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 1 0 2003

Anzai Medical Co., Ltd. % T. Whit Athey, Ph.D. Senior Consultant The Health Policy Resources Group, LLC 2305 Gold Mine Road, Suite 200 BROOKVILLE MD 20833-2233

Re: K031385 Trade/Device Name: AZ-733 Respiratory Gating System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: 90 LHN Dated: October 2, 2003 Received: October 2, 2003

Dear Dr. Athey:

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. 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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050,

4

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of the letter:

8xx. 1xxx(301) 594-4591
876.2xxx, 3xxx, 4xxx, 5xxx(301) 594-4616
884.2xxx, 3xxx, 4xxx, 5xxx, 6xxx(301) 594-4616
892.2xxx, 3xxx, 4xxx, 5xxx(301) 594-4654
Other(301) 594-4692

Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (2.1CFR Part 807.97) you may obtain. Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.

Sincerely yours,

Nancy C. Brogdon

Nancy C. Brogdon Director, Division of Reproductive, Abdominal and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

STATEMENT OF INDICATIONS FOR USE

6031385 510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________

Device Name:

Indications For Use:

The AZ-733 Respiratory Gating System is intended to be used with diagnostic x-ray or radiation therapy systems to gate these devices on and off when target points of the patient's respiratory cycle are within preset limits.

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use (Per 21 CFR 801.109)

OR

Over-The-Counter Use

Nancy C Brogdon

(Division Sign-Off) Division of Reproductive, and Radiological Devices 510(k) Number

000040