K Number
K061582
Date Cleared
2006-07-25

(48 days)

Product Code
Regulation Number
892.5700
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The VariSource 200 System is a High Dose Rate Brachytherapy Afterloader used to treat lesions, tumors and conditions in the body where radiation is indicated.

Device Description

The VariSource 200 Series High Dose Rate Afterloader system is a computer controlled remote electro/mechanical system used for medical purposes, for placing a NiTiNol wire incorporating an irradiated iridium seed internally or close by, a malignant tumor or tumor bed in a practice known as brachytherapy.

AI/ML Overview

The provided document is a 510(k) summary for the VariSource 200 HDR Brachytherapy Afterloader, which is a medical device used for radiation therapy, specifically brachytherapy. It is not an AI/ML device, and thus the acceptance criteria and study information typically associated with AI/ML device performance (like sensitivity, specificity, MRMC studies, ground truth establishment by experts, training/test set sizes, etc.) are not applicable or provided in this document.

Instead, the document focuses on demonstrating substantial equivalence to a predicate device (VariSource K - K945383) by comparing technological characteristics and meeting relevant safety standards.

Therefore, I cannot provide the requested information regarding AI/ML device performance criteria.

However, I can extract the comparison chart that outlines the device's characteristics and how it compares to its predicate, essentially serving as a form of acceptance criteria for a non-AI medical device.

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

For a traditional medical device like the VariSource 200 HDR Brachytherapy Afterloader, "acceptance criteria" are typically defined by regulatory standards (like IEC 601-2-17) and by demonstrating substantial equivalence to a predicate device. The performance is assessed against these established characteristics and safety thresholds.

Characteristic / Acceptance Criteria (Predicate Device)Reported Device Performance (VariSource 200)
Intended UseHigh Dose Rate Brachytherapy
Safe (Maximum source strength)Tungsten Alloy 370GBq
Maximum Surface Dose (IEC 601-2-17: 1µGy/h @ 1m)<0.5 µGy/h @ 1m
Radiation DetectorInstalled in room, Built into unit - and connected to system interlocks
Dimension (Length)635mm
Dimension (Width)533 mm
Dimension (Height)1097 mm
Weight148Kg
Power Requirements110/220 V +/- 10%
Power Consumption550 VA, peak
UPSYes
Ambient Temperature15 - 35°C
Relative Humidity30% - 75%
Atmospheric Pressure70kPa - 110kPa
Rotation of headNo (rotate unit)
Variable Height headNo
Number of patient connection Channels20
Channel Indexer Locking MechanismMechanical
Method of Correct Catheter connection DetectionLED - Photo Transistor Pair
Treatment Length in Catheter70 cm to 150cm
Authorized AccessYes (Key Switch, Password - 3 levels)
Power FailUPS takes over, operator choice to continue/interrupt, can complete interrupted treatment, UPS powers safely for 30 min, new treatment cannot be initiated
Emergency Source Retraction (Battery Back-up)Yes
Emergency Source Retraction (Battery test prior to source extension)Yes
Emergency Source Retraction (DC Motor)Yes
Emergency Source Retraction (Separate Motor)Yes
Emergency Source Retraction (Manual Crank)Yes (On side of unit, handle on wheel)
Source Wire NoSL 777V
Source Capsule Length11mm
Source Active Length10mm
Source Diameter0.59mm
Source MaterialIridium
Source WireSolid Nickel-Titanium Alloy
Turning Radius17 mm in 4.7 Fr thick wall catheter, at 120 cm from turret
Source Mechanical LifeInterlocked at 500 extensions
QA Tool (Source Position Verification)Yes - External, allows daily QA of source positioning accuracy, including dummy positioning - recorded on a single sheet of paper
User Interface (Graphical User interface)DOS
Operating System(Not specified for predicate)
Prescription Record TransferFloppy disk
Standard PlansOn floppy disk
Prescription & ReportsPrinted on Paper
PC HardwareIntel 486 50MHz, IBM Compatible
Monitor15" CRT
PrinterLaser Printer
Independent Treatment Control PanelYes
Regulations (IEC 601-2-17)Yes

2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This information is not applicable to this type of device and is not provided in the document. The submission focuses on hardware and functional equivalence, not data-driven performance.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This information is not applicable to this type of device and is not provided. Ground truth establishment by experts is relevant for diagnostic or AI/ML devices, not for a brachytherapy afterloader.

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

This information is not applicable to this type of device and is not provided. Adjudication methods are typically used in clinical studies or for establishing ground truth for AI/ML algorithms.

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

This information is not applicable, as the VariSource 200 is a hardware device for delivering radiation therapy, not an AI-assisted diagnostic or treatment planning system. Therefore, no human readers or AI assistance are involved in its primary function as described in this submission.

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

This information is not applicable, as the VariSource 200 is a hardware device.

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

This information is not applicable. The "ground truth" for this device relates to its engineering specifications, safety performance (e.g., maximum surface dose, emergency retraction functionality), and its ability to accurately deliver radiation as intended, rather than diagnostic accuracy against a clinical ground truth. Compliance with regulatory standards (e.g., IEC 601-2-17) serves as a primary form of "ground truth" for device safety and performance.

8. The sample size for the training set

This information is not applicable. This is a hardware device, not an AI/ML algorithm that requires a training set.

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

This information is not applicable.

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K061582 510(k) Summary

The following information is provided following the format of 21 CFR 807.92 for the VariSource 200 HDR Brachytherapy Afterloader.

  • Varian Medical Systems 1. Submitter: 3100 Hansen Way M/S E-110 Palo Alto, CA 94304-1129 Contact Name: Vy Tran Phone: (650) 424-5731 (650) 842-5040 Fax: Email: vy.tran@varian.com Date summary was prepared: June 1, 2006
2. Name of the Device:VariSource 200 HDR Afterloader
Trade/Proprietary Name:VariSource 200 HDR Afterloader
Common or Usual Name:
Classification Name:Radiological Image Processing System21 CFR §892.5700Class IIProduct Code: 90 JAQ
    1. Predicate Devices to claim substantial equivalence: a. VariSource K(945383)
    1. Description of the Device: The VariSource 200 Series High Dose Rate Afterloader system is a computer controlled remote electro/mechanical system used for medical purposes, for placing a NiTiNol wire incorporating an irradiated iridium seed internally or close by, a malignant tumor or tumor bed in a practice known as brachytherapy.

Hardware Platform and Operating System

The console control application runs on standard Intel PCs under a DOS operating systems. The firmware controlling the High Dose Rate Afterloader runs on an embedded Intel 188 processor.

Peripherals and Accessories

The 200 Series control console provides real time information of wire position and system status and interfaces with a printer in order to provide a hard copies of a treatment prescriptions and delivery records. In addition the 200 Series control

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console can receive treatment plans from a treatment planning application (not part of this submission), this information is transferred via a floppy disk.

  1. Intended Use Statement: The VariSource 200 System is a computer controlled remote HDR Afterloader used to place a high activity radioactive source within a needle(s) or applicator(s) which have previously been placed for a specified clinical purpose in a patient.

The radioactive source (enclosed within the wire/cable) is driven via coupling catheters ( Transfer Guide Tubes ) from the Afterloader into needles or applicators within or on the patient.

The length of time and position that the High Dose Rate source spends within the needle or applicator is controlled in accordance with an Irradiation Treatment Prescription.

Summary of the Technological Characteristics: The Substantial Equivalence 6. Comparison Chart provides a comparison of the technological characteristics to those of the predicate devices. This chart is located in Tab 9 of the submission.

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Image /page/2/Picture/0 description: The image shows the logo for Varian Medical Systems. The logo consists of the word "VARIAN" in bold, uppercase letters. The "I" in "VARIAN" is stylized with a curved line extending above the letter. Below the word "VARIAN" are the words "medical systems" in a smaller font.

61582

Varian Brachytherapy

HDR Product Comparison Chart

The following table represents information as known to Varian from a review of published information available about competing products and the predicate device.

DescriptionVarian VariSourceRemote High Dose RateAfterloader(Predicate Device)VariSource 200
510(k) NumberK945383
Intended UseHigh Dose RateBrachytherapyHigh Dose RateBrachytherapy
Safe(Maximum source strength)Tungsten Alloy370GBqTungsten Alloy407GBq. Safe and Unittested to meet SurfaceDose Requirement
Maximum Surface Dose(IEC 601-2-17: 1µGy/h @ 1m)<0.5 µGy/h @ 1m<0.5 µGy/h @ 1m
Radiation DetectorInstalled in roomBuilt into unit - andconnected to systeminterlocksInstalled in roomBuilt into unit - andconnected to systeminterlocks
DimensionLengthWidthHeight635mm533 mm1097 mm610 mm560 mm1070 mm
Weight148Kg142 kg
Power Requirements110/220 V +/- 10%110/220 V +/- 10%
Power Consumption550 VA, peak550 VA, peak
UPSYesYes
Ambient Temperature15 - 35°C15 - 35°C
Relative Humidity30% - 75%30% - 75%
Atmospheric Pressure70kPa - 110kPa70kPa - 110kPa
Rotation of headNo (rotate unit)No (rotate unit)
Variable Height headNoNo
Number of patientconnection Channels2020
Channel Indexer LockingMechanismMechanicalElectro-Mechanical
Method of Correct Catheterconnection DetectionLED - Photo Transistor PairLED - Photo Transistor Pair
Treatment Length inCatheter70 cm to 150cm70 cm to 150cm
Authorized Access:YesYes
Key SwitchYesYes
PasswordYes - 3 levelsYes - 3 levels
Power FailUPS takes over - operatorcan choose to continue orinterrupt treatment.An interrupted treatmentmay be completed atoperator option at any time.UPS will power unit safelyfor 30 minutes - new patienttreatment may not beinitiated during power failUPS takes over - operatorcan choose to continue orinterrupt treatment.An interrupted treatmentmay be completed atoperator option at any time.UPS will power unit safelyfor 30 minutes - new patienttreatment may not beinitiated during power fail
DescriptionVarian VariSourceRemote High Dose RateAfterloader(Predicate Device)VariSource 200
Emergency Source Retraction:
Battery Back-upYesYes
Battery test prior to sourceextensionYesYes
DC MotorYesYes
Separate MotorYesYes
Manual CrankYesYes
Manual Crank AccessOn side of unitOn side of unit
Crank methodHandle on wheelHandle on wheel
Source:
Source Wire NoSL 777VVS2000
Source Capsule Length11mm6 mm
Source Active Length10mm5 mm
Source Diameter0.59mm0.59 mm
Source MaterialIridiumEnriched Iridium
Source WireSolid Nickel-Titanium AlloySolid Nickel-Titanium Alloy
Turning Radius17 mm in 4.7 Fr thick wallcatheter, at 120 cm fromturret17 mm in 4.7 Fr thick wallcatheter, at 120 cm fromturret
Source Mechanical LifeInterlocked at 500extensionsInterlocked at 1000extensions
QA Tool
Source PositionVerification. Video imagevia frame grabber with plainpaper print out.Yes - External, allows dailyQA of source positioningaccuracy, including dummypositioning - recorded on asingle sheet of paper.Yes - Internal, allows dailyQA of source positioningaccuracy, including dummypositioning - recorded on asingle sheet of paper.
User Interface
Graphical User interfaceDOSDOS
Operating System
Prescription RecordTransferFloppy diskFloppy disk
Standard PlansOn floppy diskOn floppy disk
Prescription & ReportsPrinted on PaperPrinted on Paper
PC Hardware*Intel 486 50MHz, IBMCompatibleIntel 486 50MHz, IBMCompatible
Monitor*15" CRT15" CRT
Printer*Laser PrinterLaser Printer
Independent TreatmentControl PanelYesYes
Regulations:IEC 601-2-17YesYes

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HDR Product Comparison Chart

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DepartmentVBT Project ManagerDate:16th December 2005
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Image /page/4/Picture/1 description: The image is a black and white logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of what appears to be a human figure embracing or protecting another figure, possibly representing care or support.

Food and Drug Administration 9200 Corporate Blvd. Rockville MD 20850

JUL 25 2006

Ms. Vy Tran Director, Corporate Regulatory Affairs Varian Medical Systems, Inc. 3100 Hansen Way M/S E-110 PALO ALTO CA 94304-1129

Re: K061582

Trade/Device Name: VariSource 200 HDR Brachytherapy Afterloader Regulation Number: 21 CFR 892.5700 Regulation Name: Remote controlled radio-nuclide applicator system Regulatory Class: II Product Code: JAQ Dated: June 2, 2006 Received: June 7, 2006

Dear Ms. Tran:

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 (Premarket Approval), 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.

Image /page/4/Picture/10 description: The image is a black and white circular logo. The logo contains the letters "FDA" in a bold, sans-serif font. Above the letters, the numbers "1906 - 2006" are printed. Below the letters, the word "Centennial" is printed in a cursive font. The logo is surrounded by a circular border with small stars and text.

roting Public J

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Page 2 -

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 form in the quind provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

This letter will allow you to begin marketing your device as described in your Section 510(k) I mo loket notification. The FDA finding of substantial equivalence of your device to a legally premaince modicate 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 this letter:

21 CFR 876.xxx(Gastroenterology/Renal/Urology)240-276-0115
21 CFR 884.xxx(Obstetrics/Gynecology)240-276-0115
21 CFR 894.xxx(Radiology)240-276-0120
Other240-276-0100

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 from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150

or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Nancy C. Hogden

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

Enclosure

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PAGE 1 of 1

K061582 510(k) Number (if known): Device Name: VariSource 200 HDR Brachytherapy Afterloader

Indications For Use:

The VariSource 200 System is a High Dose Rate Brachytherapy Afterloader used to treat lesions, tumors and conditions in the body where radiation is indicated.

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Optional Format 3-10-98)

Tamye Snugden
(Division Sign-Off)

Division of Reproductive, Abdominal, and Radiological Devices

510(k) Number K061582

Prescription Use _ (Per 21 CFR 801.109)

§ 892.5700 Remote controlled radionuclide applicator system.

(a)
Identification. A remote controlled radionuclide applicator system is an electromechanical or pneumatic device intended to enable an operator to apply, by remote control, a radionuclide source into the body or to the surface of the body for radiation therapy. This generic type of device may include patient and equipment supports, component parts, treatment planning computer programs, and accessories.(b)
Classification. Class II.