K Number
K031975
Device Name
IMSURE
Manufacturer
Date Cleared
2003-08-29

(64 days)

Product Code
Regulation Number
892.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
IMSure is indicated for use as a quality assurance tool to verify IMRT treatment plans developed on any radiation therapy treatment planning system with the appropriate transfer format. IMSure will also perform primary monitor unit calculations from measured physics data for plans of known geometry.
Device Description
IMSure is a software program designed to provide a second, independent verification of IMRT plans created on primary radiation therapy treatment planning systems. After independently calculating the imported plan and fluence maps, IMSure compares results with the imported plan and maps, and calculates the differences. This second check provides an effective QA tool for verification of the original IMRT treatment plan. IMSure also may be used to compute primary monitor unit calculations for single and multiple beams with open, blocked, and wedged fields.
More Information

Not Found

No
The summary describes a software program for independent verification of IMRT plans and monitor unit calculations based on physics data. There is no mention of AI, ML, or related concepts, and the description of its function aligns with deterministic calculation methods rather than learning algorithms.

No.
This device is a quality assurance tool used to verify IMRT treatment plans and calculate monitor units; it does not directly treat or diagnose patients.

No
The device is described as a "quality assurance tool" and a "second, independent verification of IMRT plans," which explicitly states its function as a QA tool, not for directly diagnosing a medical condition in a patient.

Yes

The device description explicitly states "IMSure is a software program" and describes its function as a calculation and comparison tool for radiation therapy plans, without mentioning any associated hardware components.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health.
  • IMSure's Function: IMSure is described as a software program used for quality assurance of radiation therapy treatment plans. It verifies calculations and compares results from existing treatment plans.
  • No Specimen Analysis: There is no mention of IMSure analyzing any biological specimens from a patient. Its input is radiation therapy plan data, not patient samples.

Therefore, IMSure falls under the category of a medical device used in the planning and quality control of medical treatments, but it does not meet the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

IMSure is intended for use as a quality assurance tool to verify IMRT treatment plans developed on any radiation therapy treatment planning system with the appropriate transfer format. IMSure will also perform primary monitor unit calculations from measured physics for plans of known geometry.

Product codes

90 IYE

Device Description

IMSure is a software program designed to provide a second, independent verification of IMRT plans created on primary radiation therapy treatment planning systems. After independently calculating the imported plan and fluence maps, IMSure compares results with the imported plan and maps, and calculates the differences. This second check provides an effective QA tool for verification of the original IMRT treatment plan.

IMSure also may be used to compute primary monitor unit calculations for single and multiple beams with open, blocked, and wedged fields.

Mentions image processing

Not Found

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)

Not Found

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

Not Found

Predicate Device(s)

K010464 RadCalc V4.0

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

KO31975

AUG 2 9 2003

Premarket Notification [510(k)] Summary Tab 4

Date Prepared:

April 24, 2003

IMSure Trade Name:

IMRT QA Device and Monitor Unit Calculator Common Name:

Classification Name: Medical Linear Accelerator

Manufacturer's Name: Address:

Prodiam. Inc. 585 Manzanita Ave. Chico, CA 95926

Suzanne Wild

Corresponding Official: Title: Telephone: Fax:

Director of Quality Assurance/ Regulatory Affairs 530-897-0937 530-897-0934

Predicate:

K010464 RadCalc V4.0

Device Description:

IMSure is a software program designed to provide a second, independent verification of IMRT plans created on primary radiation therapy treatment planning systems. After independently calculating the imported plan and fluence maps, IMSure compares results with the imported plan and maps, and calculates the differences. This second check provides an effective QA tool for verification of the original IMRT treatment plan.

IMSure also may be used to compute primary monitor unit calculations for single and multiple beams with open, blocked, and wedged fields.

Intended Use:

IMSure is intended for use as a quality assurance tool to verify IMRT treatment plans developed on any radiation therapy treatment planning system with the appropriate transfer format. IMSure will also perform primary monitor unit calculations from measured physics for plans of known geometry.

1

Technological Characteristics: The New Device has the same intended use and safety characteristics as the predicate device.

| System

ComponentDevice
LifeLine Software, Inc.
RadCalc, Model V.4.0Prodigm, Inc.
IMSure
K numberK010464This filing.
Application (Use)Utilized for determination of
monitor units or dose. Serves
to validate those monitor units
computed by the primary
radiation therapy planning
system. Primary means of
calculating monitor units in
situations where the physician
does not order the user of a
radiation therapy treatment
plan.Independent dose and
fluence map verification
software for Intensity
Modulated Radiation Therapy
based on Linear accelerator
plans containing multi-leaf
collimator leaf sequence data
and fluence maps from
primary IMRT treatment
planning systems.
Independent dose
computation software for
standard, simple geometry
radiation therapy treatment
planning and verification of
monitor units based on Linear
Accelerator parameters and
physician prescribed dose
information.
PlatformMinimum Pentium II processor,
MFS network enabledMinimum Pentium III
processor, MFS network
enabled
Operating systemAny MS WindowsWindows 2000 and XP
Algorithm - map
verificationSingle Source modelSingle source model
Algorithm - IMRT
dose CalculationSingle Source model, Clarkson
scatter algorithm based on
University of Chicago methodThree Source model,
Clarkson scatter algorithm
based on Stanford University
method
MU Calculation
Dose AlgorithmKhan (classical)Khan (classical)
Patient Geometry
SpecificationsTwo dimensional, graphical
user interface based, basedTwo dimensional, graphical
user interface based
Machines
supportedCommercially available Linear
Accelerators with multi-modality
energies and both photon and
electron particles, including
field blocking and linear wedge
applicators for photon fluence
modulation, and with 52,80 and
120 leaf Multi-leaf collimatorsCommercially available
Linear Accelerators with
multi-modality energies and
photon and electron particles,
including field blocking and
linear wedge applicators for
photon fluence modulation,
and with 52,80 and 120 leaf
Multi-leaf collimators
System
ComponentDevice
LifeLine Software, Inc.
RadCalc, Model V.4.0Prodigm, Inc.
IMSure
Calculation point
for IMRT QAFixed, iso-centricOff-Axis calculation points
incorporating modeled head
scatter information and
measured fluence
perturbations
Calculation point
for MU
CalculationsOff-Axis and depth specified
calculation points using
measured physical dataOff-Axis and depth specified
calculation points using
measured physical data
Physics DataMeasured, tabular database
stored, multiple linear
accelerators allowedMeasured, tabular, flat file
storage, multiple linear
accelerators allowed
Scatter tableMeasuredMeasured and modeled (3-
source model, Yang, et. al )
Import dataRTP link, Dicom RT for IMRT
QA and MU CalculationsRTP link for IMRT QA
Graphical User Interface for
MU Calculations
Calibration
method(s)Iso-centric or fixed Calibration
DistanceIso-centric or fixed Calibration
Distance
Export dataRTP link, Dicom RT, Paper
documentationPaper or Word
documentation
User securityTwo levels of user, password
enabledThree levels of user,
password enabled

·

.

·

.

2

.

.

.

:

  1. 19

.

.

.

:

Page 3 of 3

and the control control control of the control of

:

3

Image /page/3/Picture/1 description: The image shows a logo with a stylized bird in flight, composed of three parallel lines that curve upwards and to the right. The bird is enclosed within a circle, and the words "U.S. Department of Health & Human Services" are arranged around the circumference of the circle. The logo is rendered in black and white, with a simple and clean design.

Food and Drug Administration 0 Corporate Boulevard kville MD 20850

AUG 2 9 2003

Prodigm, Inc. % Mr. Juergen Welte Program Manager TUV Rheinland of North America 1279 Quarry Lane, Suite A Pleasanton, CA 94566

Re: K031975

Trade/Device Name: IMSure (IMRT QA Device and Monitor Unit Calculator) Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: 90 IYE Dated: August 15, 2003 Received: August 18, 2003

Dear Mr. Welte:

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 enactnient 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 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" (21CFR 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/dsmaldsmamain.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

Tab 3

Indications For Use

510(k) Number (if known): Ko31975

Device Name: IMSure

Indications for Use:

IMSure is indicated for use as a quality assurance tool to verify IMRT treatment plans developed on any radiation therapy treatment planning system with the appropriate transfer format. IMSure will also perform primary monitor unit calculations from measured physics data for plans of known geometry.

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Nancy Brogdon

(Division Sign-Off)
Division of Reproductive, Abdominal,
and Radiological Devices
510(k) Number K031975

Prescription Use Y (per 21 CFR 801.109)

OR

Over-The-Counter Use