(130 days)
PaX-P&P is a digital x-ray system that uses a high resolution CCD detector for real time digital image acquisition. The system allows lower radiation dose, simple user interface, and produces high quality images. It is intended for producing diagnostic x-ray radiographic images of skull, dentition, and oral structures. The device is operated and used by physicians, dentists, and x-ray technologists.
Vatech Model PaX-P&P is a digital panoramic dental imaging system. It uses high resolution CCD detector for real time digital image acquisition. It has lower radiation dose results, simple user interface and high quality producing capability.
The provided 510(k) summary for the Vatech PaX-P&P Digital X-Ray Imaging System does not contain the detailed information requested regarding specific acceptance criteria, a comprehensive study proving device performance against those criteria, or the methodology for establishing ground truth for training and test sets.
Instead, the document focuses on demonstrating substantial equivalence to predicate devices rather than a standalone clinical performance study with defined acceptance criteria. The approval is based on the device having similar use, capability, design, and performance characteristics to previously cleared devices.
However, I can extract what is stated and highlight what is missing based on your request.
Acceptance Criteria and Reported Device Performance
The 510(k) summary does not provide a table of specific numerical acceptance criteria (e.g., sensitivity, specificity, spatial resolution, contrast-to-noise ratio values) that the device was tested against. Instead, the "acceptance criteria" are implied by the claim of substantial equivalence to predicate devices, meaning the device performs equivalently well for its intended use.
The document states:
- "The Vatech system is technologically equivalent in concept, function and performance to the predicate devices."
- "Evaluations have proven that the system is safe and effective for the intended use."
Without specific numerical criteria, I cannot construct the requested table. The "reported device performance" is essentially a qualitative claim of equivalence and safety/effectiveness for its intended use, rather than quantified performance metrics.
Study Details (Information Not Provided in the Document)
The document does not describe a specific clinical study with a test set, ground truth, or a multi-reader multi-case comparison in the way requested. The 510(k) pathway for this device, being for a new digital X-ray imaging system, primarily relies on:
- Technical comparison: Demonstrating that the device's technical specifications and characteristics are similar to predicate devices.
- Safety and Effectiveness Claims: Asserting that the device is safe and effective through comparison and compliance with applicable standards, rather than through a detailed independent clinical performance study with quantifiable results.
Therefore, the following information is not available in the provided text:
- Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective): No dedicated test set described.
- 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): No ground truth for a test set described.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable as no such test set is described.
- 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 an imaging device, not an AI-assisted diagnostic tool for interpretation.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is an imaging device, not an algorithm being evaluated without human interaction.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc): No specific ground truth methodology for a performance study is described.
- The sample size for the training set: Not applicable, as this is hardware, not an AI model requiring a training set.
- How the ground truth for the training set was established: Not applicable.
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510(K) SUMMARY February 15, 2008 K073365
APR - 8 2008
SUBMITTER INFORMATION:
Vatech Co., Ltd. 75-11 Seogu-ri, Dongtan Myeon Hwaseong-si, Gyeonggi-do 445-811 Korea
APPLICANT/FDA AGENT/CORRESPONDING OFFICIAL INFORMATION:
North American Technical Services (NATS) Corp 30 Northport Rd Sound Beach, NY 11789 Tel: 631-744-0059 Fax: 631-744-0192 Email: natscorp@aol.com Contact: Stephen T. Mlcoch
DEVICE NAME:
Name: Digital X-Ray Imaging System Proprietary Model: PaX-P&P Classification: System, Xray Extraoral Source Digital (code MUH) Class 2 - 872.1800
PREDICATE DEVICES:
Sinora Dental Systems Digital Xray System Model Orthophos 3/3 Ceph/3DS - K990528 Intrumentarium Corp. Digital Xray System Model Orthoceph OC100D - K001439
DESCRIPTION:
Vatech Model PaX-P&P is a digital panoramic dental imaging system. It uses high resolution CCD detector for real time digital image acquisition. It has lower radiation dose results, simple user interface and high quality producing capability.
INTENDED USE:
The Vatech system is intended as an extraoral digital xray system that allows for panoramic tomographic imaging and teleradiography. It essentially has the same use as the predicate devices for X-ray computed tomography of the head and neck for dental, oral, and related medical use imaging.
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COMPARISON TO PREDICATE DEVICES:
The Vatech system has the same use and capability as both of the predicate devices named. The Vatech and Instrumentarium high voltage tubes are from the same Toshiba tube family and have the same fundamental electronic design. The CCD, radiographic, extraoral sensing and imaging methods are all similar characteristics used by these systems. They all have rotating image capability and similar chin rest positioning.
Small differences in methodology, technique, and cosmetic appearance offer no new concerns regarding safety and effectiveness. The Vatech system is technologically equivalent in concept, function and performance to the predicate devices.
CONCLUSION:
The Vatech model PaX-P&P has been developed and validated according to all applicable standards. Evaluations have proven that the system is safe and effective for the intended use. Risk analysis and safety certifications reveal that there are no new safety issues associated with this system as compared with the predicate devices.
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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the top half of the circle. Inside the circle is a stylized image of an abstract symbol, which is the main element of the logo.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR - 8 2008
Vatech Co., Ltd. c/o Mr. Stephen T. Mlcoch North American Technical Services Corporation 30 Northport Road SOUND BEACH NY 11789
Re: K073365
Trade/Device Name: Vatech Co., Ltd. Digital X-ray Imaging System Model PaX-P&P Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral source x-ray system Regulatory class: II Product Code: MUH Dated: February 18, 2008
Received: March 5, 2008
Dear Mr. Mlcoch:
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 Ant 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 vours.
Nancy C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
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Vatech Co., Ltd. Digital X-ray Imaging System Model PaX-P&P 510K Notification
INDICATIONS FOR USE
513(k) Number (if known):
Device Name:
Vatech Co., Ltd. Digital X-ray Imaging System Model PaX-P&P
Incications for Use:
PaX-P&P is a digital x-ray system that uses a high resolution CCD detector for real time digital image acquisition. The system allows lower radiation dose, simple user interface, and produces high quality images. It is intended for producing diagnostic x-ray radiographic images of skull, dentition, and oral structures. The device is operated and used by physicians, dentists, and x-ray technologists.
Prescription Use × (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
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Concurrence of CDRH, Office of Device Evaluation (ODE)
Page 1 of 1
Nancy C. Brogdon
.
(Division Division of Reproductive, Abdominal an Radiological Devices 510(k) Number
§ 872.1800 Extraoral source x-ray system.
(a)
Identification. An extraoral source x-ray system is an AC-powered device that produces x-rays and is intended for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures. The x-ray source (a tube) is located outside the mouth. This generic type of device may include patient and equipment supports and component parts.(b)
Classification. Class II.