K Number
K063270
Device Name
RPM RESPIRATORY GATING SYSTEM
Date Cleared
2006-12-14

(45 days)

Product Code
Regulation Number
892.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The RPM Respiratory Gating System is used to obtain tracking of the subject respiratory pattern for respiratory synchronized image acquisition, and radiation therapy treatment. It can be also used to monitor the patient position during the image acquisition, simulation and treatment.
Device Description
The Varian RPM Respiratory Gating Device is an attachment to the Varian Clinac radiation therapy treatment systems, radiation therapy simulators, and image acquisition devices used for diagnostics and radiation therapy. The RPM system senses and records the respiratory motion and respiratory state of a patient using video tracking of an optical marker placed on the patient to a location indicated by the physician. Video camera is connected to a PC workstation is used for video tracking of markers.
More Information

Not Found

No
The description focuses on video tracking of an optical marker and does not mention AI or ML.

No
The device is used for tracking respiratory patterns to synchronize image acquisition and radiation therapy, and for monitoring patient position during treatment. It does not perform any therapeutic action itself; its function is purely for guidance and synchronization of other medical procedures.

Yes
The text states it is used with "image acquisition devices used for diagnostics" and can "monitor the patient position during the image acquisition". This indicates its use in a diagnostic context, although it's not solely a diagnostic device.

No

The device description explicitly states it includes a video camera and a PC workstation for video tracking, indicating hardware components are part of the system.

Based on the provided information, the RPM Respiratory Gating System is not an In Vitro Diagnostic (IVD).

Here's why:

  • IVDs are used to examine specimens from the human body. The RPM system works by tracking an optical marker placed on the patient's body using video. It does not involve the analysis of biological samples like blood, urine, or tissue.
  • The intended use is for respiratory synchronized image acquisition and radiation therapy treatment. This is a direct interaction with the patient for imaging and treatment purposes, not for diagnostic testing of a biological specimen.
  • The device description clearly states it senses and records respiratory motion using video tracking of an optical marker. This is a physical measurement of external movement, not an analysis of internal biological markers.

Therefore, the RPM Respiratory Gating System falls under the category of a medical device used for imaging and treatment support, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The RPM Respiratory Gating System is used to obtain tracking of the subject respiratory pattern for respiratory synchronized image acquisition, and radiation therapy treatment. It can be also used to monitor the patient position during the image acquisition, simulation and treatment.

Product codes

IYE

Device Description

The Varian RPM Respiratory Gating Device is an attachment to the Varian Clinac radiation therapy treatment systems, radiation therapy simulators, and image acquisition devices used for diagnostics and radiation therapy. The RPM system senses and records the respiratory motion and respiratory state of a patient using video tracking of an optical marker placed on the patient to a location indicated by the physician. Video camera is connected to a PC workstation is used for video tracking of markers.

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)

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

K063270
VARIAN
medical systems

510(k) Summary

DEC 1 4 2006

The following information is provided following the format of 21 CFR §807.92 for the RPM Respiratory Gating System.

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: October 25th, 2006

2. Name of the Device:RPM Respiratory Gating System
Trade/Proprietary Name:RPM Respiratory Gating System
Common or Usual Name:Respiratory Gating System
Classification Name:Medical Charged-particle radiation therapy system
21 CFR §892.5050
Class II
Product Code: IYE
    1. Predicate Device: RPM Respiratory Gating K983629
  1. Description of the Device: The Varian RPM Respiratory Gating Device is an attachment to the Varian Clinac radiation therapy treatment systems, radiation therapy simulators, and image acquisition devices used for diagnostics and radiation therapy. The RPM system senses and records the respiratory motion and respiratory state of a patient using video tracking of an optical marker placed on the patient to a location indicated by the physician. Video camera is connected to a PC workstation is used for video tracking of markers.

  2. Intended Use Statement: The RPM Respiratory Gating System is used to obtain tracking of the subject respiratory pattern for respiratory synchronized image acquisition, and radiation therapy treatment. It can be also used to monitor the patient position during the image acquisition, simulation and treatment.

  3. Summary of the Technological Characteristics: The Substantial Equivalence Comparison Chart provides a comparison of the technological characteristics to those of the predicate devices. The comparison chart demonstrates that the device is substantially equivalent to its predicate device cited in the table. This chart is located in Tab 7 of the submission.

1

Image /page/1/Picture/1 description: The image shows the address of the Food and Drug Administration. The address is 9200 Corporate Blvd., Rockville MD 20850. The text is in a simple, sans-serif font and is easy to read.

DEC 1 4 2006

Ms. Vy Tran Corporate Director, Regulatory Affairs Varian Medical Systems, Inc. 3100 Hansen Way PALO ALTO CA 94304-1038

Re: K063270

Trade/Device Name: RPM Respiratory Gating System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: IYE Dated: October 26, 2006 Received: October 30, 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/1/Picture/9 description: The image is a circular logo or emblem. The text "1906-2006" is at the top of the circle. The letters "FDA" are in the center of the circle in a bold, blocky font. Below the letters, the word "Centennial" is written in a cursive font. Three stars are at the bottom of the circle.

Protecting and Promoting Public Health.

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 product radiation control 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) 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 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/cdrl/industry/support/index.html.

Sincerely yours,

Nancy C. Hogdon

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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Indications for Use

510(k) Number (if known): K063270

Device Name: RPM Respiratory Gating System

Indications for Use:

The RPM Respiratory Gating System is used to obtain tracking of the subject respiratory pattern for respiratory synchronized image acquisition, and radiation therapy treatment. It can be also used to monitor the patient position during the image acquisition, simulation and treatment.

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use

Nancy C. Brogdon

(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Device 510(k) Number __