(41 days)
Hitachi's PROBEAT with DSSS is a medical device designed to produce and deliver a proton beam for the treatment of patients with localized tumors and other conditions susceptible to treatment by radiation.
The PROBEAT with DSSS is a proton beam irradiation system, which provides a therapeutic proton beam for clinical treatment. It is designed to deliver a proton beam with the prescribed dose, dose distribution and directed to the prescribed patient treatment site. The PBTS is designed to be safe and reliable. The equipment to perform the above work is comprised of two main components. One is a beam delivery system whose primary responsibility is to ensure that the desired prescription parameters are properly delivered. The other is the equipment necessary to generate the proton beam and direct it to the beam delivery system.
The provided text describes a Special 510(k) submission for the PROBEAT with DSSS, a modification to an existing proton beam therapy system. This type of submission is used for devices that are substantially equivalent to a predicate device and have only minor modifications that do not raise new questions of safety or effectiveness. As such, the submission primarily focuses on demonstrating substantial equivalence rather than presenting extensive new performance data or clinical studies like those for novel devices.
Therefore, many of the typical acceptance criteria and study details you requested for AI/software-based medical devices are not explicitly mentioned in this document. The document states that performance testing was conducted, but it does not detail specific acceptance criteria in terms of quantitative metrics, sample sizes, or expert involvement as one would expect for an AI algorithm.
Here's an attempt to answer your questions based on the provided text, indicating where information is not available:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not explicitly defined in terms of specific measurable clinical or analytical performance metrics for a novel technology. The focus is on demonstrating that the added DSSS feature performs as intended within the context of the device's overall function and does not negatively impact safety or effectiveness. | The submission includes a summary of performance testing that Hitachi conducted to demonstrate that the device meets its performance specifications. (Specific results or metrics are not detailed in this summary.) |
| The DSSS feature should not alter the intended use or indications of the PROBEAT system. | The PROBEAT with DSSS has the same intended use and indications as the cleared PROBEAT. |
| The DSSS feature should maintain the safe and reliable operation of the proton beam therapy system. | The PBTS (Proton Beam Therapy System) is designed to be safe and reliable. The DSSS is a component of this system. |
| The DSSS feature should properly deliver the desired prescription parameters (dose, dose distribution, and directed to the treatment site). | The PROBEAT with DSSS is designed to deliver a proton beam with the prescribed dose, dose distribution, and directed to the prescribed patient treatment site. |
2. Sample size used for the test set and the data provenance
Not applicable in the context of this 510(k) summary for a hardware modification to an existing proton therapy system. The "test set" would likely refer to engineering and system validation tests rather than a clinical dataset in the AI sense. The document does not specify details of these tests, their sample sizes, or data provenance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This information is not provided. Ground truth in this context would likely be based on physical measurements and engineering specifications, not expert interpretation of data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This information is not provided.
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
Not applicable. This is a hardware modification for a proton beam therapy system, not an AI-based diagnostic or assistive device that would involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This refers to the performance of the overall Proton Beam Therapy System with the added DSSS component, which is a physical beam delivery system, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not explicitly stated. For a proton beam therapy system, ground truth for performance testing would typically involve:
- Physical measurements: Verifying beam parameters (dose, energy, shape, position) using phantoms, dosimeters, and other radiation detectors.
- Engineering specifications: Comparing actual performance against designed specifications.
- Pre-clinical verification: Potentially using biological samples or animal models to assess beam effects (though not explicitly mentioned here for this modification).
8. The sample size for the training set
Not applicable. This is a hardware modification to an existing proton therapy system. The concept of a "training set" is relevant for machine learning algorithms, which is not the primary subject of this 510(k) summary.
9. How the ground truth for the training set was established
Not applicable for the same reasons as above.
{0}------------------------------------------------
Attachment 6
510(k) SUMMARY PROBEAT with DSSS
Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Hitachi, Ltd., Power Systems Group Advanced Medical Technology and Solutions Division, Proton Therapy 18-13, Sotokanda 1-chome, Chiyoda-ku Tokyo, 101-8608 DEC 1 0 2007 Japan
Phone : 011-81-3-4564-3565 Facsimile: 011-81-3-4564-2882
Contact Person: Naoya Nishimura
Date Prepared: 30 October, 2007
Name of Device and Name/Address of Sponsor
PROBEAT
Hitachi, Ltd., Power Systems Group Advanced Medical Technology and Solutions Division, Proton Therapy 18-13, Sotokanda 1-chome, Chivoda-ku Tokyo, 101-8608 Japan
Common or Usual Name: Proton Beam Therapy System ("PBTS") Classification Name: Medical Charged-Particle Radiation Therapy System Predicate Device: Hitachi's PROBEAT (K053280) Purpose of the Special 510(k) notice.
The PROBEAT with DSSS is a modification to Hitachi's cleared PROBEAT.
Intended Use
The PROBEAT with DSSS is a medical device designed to produce and deliver a proton beam for the treatment of patients with localized tumors and other conditions susceptible to treatment by radiation.
{1}------------------------------------------------
Technological Characteristics
The PROBEAT with DSSS is a proton beam irradiation system, which provides a therapeutic proton beam for clinical treatment. It is designed to deliver a proton beam with the prescribed dose, dose distribution and directed to the prescribed patient treatment site. The PBTS is designed to be safe and reliable. The equipment to perform the above work is comprised of two main components. One is a beam delivery system whose primary responsibility is to ensure that the desired prescription parameters are properly delivered. The other is the equipment necessary to generate the proton beam and direct it to the beam delivery system.
Performance Data
The submission includes a summary of the performance testing that Hitachi conducted to demonstrate that the device meets its performance specifications.
Substantial Equivalence
PROBEAT with DSSS has the same intended use and indications, as well as substantially similar principles of operation and technological characteristics, as compared to Hitachi's cleared PROBEAT (K053280), PROBEAT with MGCS (060834), and IBA Proton Therapy System - Proteus 235 (K060695). The only difference between the PROBEAT with DSSS and the cleared PROBEAT is the addition of the Discrete Spot Scanning System ("DSSS"). Thus, the PROBEAT with DSSS is substantially equivalent to its predicate devices.
{2}------------------------------------------------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the United States of America. The seal features a stylized caduceus-like symbol with three lines representing human profiles, enclosed within a circle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged around the upper portion of the circle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 1 0 2007
Hitachi, Ltd., Power Systems Group % Jonathan S. Kahan, Esq. Regulatory Counsel Hogan & Hartson L.L.P. 555 Thirteenth Street NW WASHINGTON DC 20004
Re: K073059
Trade/Device Name: PROBEAT with DSSS Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: LHN Dated: October 30, 2007 Received: October 30, 2007
Dear Mr. Kahan:
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.
{3}------------------------------------------------
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 C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{4}------------------------------------------------
Attachment 7
Indications for Use Statement
073059 510(k) Number (if known):
Device Name: PROBEAT with DSSS
Indications for Use: Hitachi's PROBEAT with DSSS is a medical device designed to produce and deliver a proton beam for the treatment of patients with localized tumors and other conditions susceptible to treatment by radiation.
Prescription Use I (Per 21 C.F.R. 801.109)
AND/OR
Over-The-Counter Use (Per 21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of Reproductive, Abdominal and
Radiological Devices
510(k) Number KD/3059
§ 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.