(56 days)
These Radiographic Systems are intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position..
The Rad Vision E is a standard configuration fixed column diagnostic radiographic system. The column can move right or left on a track and the tube head can move up and down. Rad Vision eu is a universal swivel arm X-ray system. It is easy to operate and permits a swift radiographic procedure, a feature which applies to all conventional exposure techniques on all parts of the body. The system is composed of a floor-to-wall column and a turnable arm. On the arm is the tubehead with a collimator mounted to it. All components required for a complete system are supplied. With the patient table, the patient can be moved into any required position without the need for repositioning. Therefore it offers the same advantages as a bucky radiography table. Owing to the large vertical movement of the swivel arm patients in the standing position can be examined from head to feet.
The provided text is a 510(k) summary for the Rad Vision E and Rad Vision eu Diagnostic X-Ray Systems, along with the FDA's clearance letter. This document focuses on the substantial equivalence of the device to a predicate device, rather than a detailed study proving performance against specific acceptance criteria for a novel AI/software medical device.
Therefore, many of the requested elements (like a table of acceptance criteria and proven performance, sample sizes for test/training sets, expert qualifications, adjudication methods, MRMC study results, or detailed ground truth information) are not typically found in this type of 510(k) submission for a conventional X-ray system. These aspects are more central to the regulatory submission for AI/ML-driven or image-analysis software devices that require validation of diagnostic accuracy.
The document indicates "The results of bench, test laboratory and clinical testing indicates that the new device is as safe and effective as the predicate devices," but does not elaborate on the specifics of these tests or acceptance criteria beyond general safety and effectiveness in comparison to the predicate.
Here's an attempt to answer the questions based only on the provided text, acknowledging that much of the requested information is not present:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state specific quantitative acceptance criteria or detailed reported device performance metrics in the format of a table you'd expect for an AI/software device. The overarching "acceptance criterion" inferred is that the new device is as safe and effective as the predicate device.
| Acceptance Criterion | Reported Device Performance |
|---|---|
| Safety and Effectiveness equivalent to predicate device | "The results of bench, test laboratory and clinical testing indicates that the new device is as safe and effective as the predicate devices." (No specific metrics provided). |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not explicitly stated in the provided text. The document refers to "clinical testing" but does not provide details on sample size, data provenance, or study design (retrospective/prospective).
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)
Not applicable or not explicitly stated. For a conventional X-ray system submission, the "ground truth" relates more to the physical performance and image quality of the X-ray machine itself, typically evaluated through engineering tests, phantom studies, and possibly clinical trials (without needing a separate expert panel to establish "ground truth" for diagnostic images in the way an AI algorithm would).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable or not explicitly stated.
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 such MRMC comparative effectiveness study is mentioned. This type of study is relevant for AI-assisted diagnostic tools, not typically for the clearance of a conventional X-ray hardware system.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is not applicable as the device is a diagnostic X-ray system (hardware), not an algorithm or software-only device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For a conventional X-ray system, "ground truth" in terms of diagnostic images is less about establishing a definitive diagnosis on images and more about ensuring the system produces diagnostically acceptable images, measured by objective image quality metrics, dose, and clinical utility. The document does not specify the method for establishing ground truth for any "clinical testing" mentioned.
8. The sample size for the training set
Not applicable. The device is a hardware X-ray system; it does not involve a "training set" in the context of machine learning.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for this type of device.
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510(k) Summary 510(k) Number Ko72659 Almana Medical Imaging P.O. Box 3568 Alkhobar 31952 NOV 1 5 2007 Kingdom of Saudi Arabia T: +966 3 8679400 F: +966 3 8962421 Date Prepared: September 11, 2007 Mohammed Irfanullah Farooqui, Sales and Marketing Manager Contact:
- l . Identification of the Device: Proprietary-Trade Name: Rad Vision E and Rad Vision eu Diagnostic X-Ray Systems Classification Name: Stationary x-ray system, Product Code 90 KPR Common/Usual Name: Stationary Diagnostic X-Ray
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- Equivalent legally marketed device: "Optima URS" Universal Radiographic System K012546
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- Indications for Use (intended use) These Radiographic Systems are intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position ..
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- Description of the Device: The Rad Vision E is a standard configuration fixed column diagnostic radiographic system. The column can move right or left on a track and the tube head can move up and down. Rad Vision eu is a universal swivel arm X-ray system. It is easy to operate and permits a swift radiographic procedure, a feature which applies to all conventional exposure techniques on all parts of the body. The system is composed of a floor-to-wall column and a turnable arm. On the arm is the tubehead with a collimator mounted to it. All components required for a complete system are supplied. With the patient table, the patient can be moved into any required position without the need for repositioning. Therefore it offers the same advantages as a bucky radiography table. Owing to the large vertical movement of the swivel arm patients in the standing position can be examined from head to feet.
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- Safety and Effectiveness, comparison to predicate device. The results of bench, test laboratory and clinical testing indicates that the new device is as safe and effective as the predicate devices.
Image /page/0/Figure/6 description: The image shows two different models of Rad Vision machines. The model on the left is labeled "Rad Vision E" and the model on the right is labeled "Rad Vision eu". Both models appear to be X-ray machines with tables for patients to lie on. The "Rad Vision eu" model has a more complex design with a vertical column and a rotating arm.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles an eagle or bird in flight, composed of three curved lines.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Almana Medical Imaging % Mr. Daniel Kamm Principal Consultant Kamm & Associates PO Box 7007 DEERFIELD IL 60015
Re: K072659
Trade/Device Name: Rad Vision E and Rad Vision eu Diagnostic X-Ray System Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: KPR Dated: September 17, 2007 Received: September 24, 2007
Dear Mr. Kamm:
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.
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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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter.
| 21 CFR 876.xxxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|---|---|---|
| 21 CFR 884.xxxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 892.xxxx | (Radiology) | 240-276-0120 |
| Other | 240-276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 Brogdon
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): K072659
Device Name: Rad Vision E and Rad Vision eu Diagnostic X-Ray Systems
Indications For Use:
These Radiographic Systems are intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position..
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Lori M. Whing
Division of Reproductive, Abdominal an Radiological Devices 510(k) Number _
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§ 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.