(38 days)
The RadPro ION Mobile Fluoroscopy Systems are designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, critical care and emergency room procedures The system may be used for other imaging applications at the physician's discretion
The RadPro ION Mobile Fluoroscopy Systems (Multiple Models) are mobile x-ray units which employ unage intensifier units and have various options for image display and storage The units are used to equip a radiological room of general surgery, orthopedic, traumatology and cardiology The CCD camera is characterized by high contrast and sensitivity and no persistence of image The camera head include a mage rotation and image reversal system The automatic dose control, which acts either on KV and mA values, allows the user to reduce step by step the x-ray radiation to the minimum value, in accordance with the thickness and the density of the screened part All the configurations can accept connection to a digital memory, which allows to store and display in real time the ımage on the monitor only with a very little x-ray dose The new control panel with an alphanumerical display permits a fast and easy use by a rational and simple symbology, this console by an extension cable, could be located on the patient support to enable the c-arm control by the operator itself The system employs a Dose Area Product (DAP) meter for compliance with the US performance standard requirements
The provided text is a 510(k) summary for the RadPro ION Mobile Fluoroscopy Systems. The document focuses on demonstrating substantial equivalence to a predicate device, rather than providing a detailed study proving performance against specific acceptance criteria.
The acceptance criteria discussed are primarily related to general device characteristics and compliance with regulatory standards, which are met by comparing the new device to a legally marketed predicate device.
Here's an analysis of the provided information in the context of your request:
1. Table of Acceptance Criteria and Reported Device Performance
The concept of "acceptance criteria" in this document is effectively the characteristics of the predicate device, which the new device aims to match or demonstrate equivalence to. "Reported device performance" refers to how the RadPro ION Mobile Fluoroscopy Systems compare to these characteristics.
| Acceptance Criteria (Predicate Device K073543 OEC 9900 Elite) | Reported Device Performance (RadPro ION Mobile Fluoroscopy Systems) |
|---|---|
| Intended Use: Designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures (e.g., cholangiography, endoscopy, urologic, orthopedic, neurologic, critical care, emergency room procedures). System may be used for other imaging applications at the physician's discretion. | SAME |
| Configuration: Mobile C-Arm | SAME |
| Performance Standard: 21 CFR 1020.30 | SAME |
| Generator: 15 kW | 18 kW (Higher, but acceptable in the context of substantial equivalence) |
| Power Source: 120 VAC 1 phase 20 amp | SAME |
| Image Intensifiers: 9" or 12" | 9" or 13" (Slight difference in maximum size, deemed acceptable) |
| Electrical safety: Electrical Safety per IEC-60601 UL listed | SAME |
2. Sample Size Used for the Test Set and Data Provenance
The document does not detail a specific "test set" in the way one would for an AI algorithm or a clinical trial with patient data. The evaluation is based on "bench and test laboratory testing" and "clinical images."
- Sample Size: Not specified for "clinical images." No specific number of cases or patients is mentioned.
- Data Provenance: Not specified. It's unclear if "clinical images" refer to retrospective data, prospective data, or from which country they originated.
- Retrospective/Prospective: Not specified.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided. The document states "clinical images" were analyzed but does not specify how "ground truth" was established for these images or if experts were involved in establishing it for the context of this 510(k). The evaluation leans heavily on engineering and regulatory compliance rather than expert image interpretation in a comparative setting.
4. Adjudication Method for the Test Set
Not applicable/Not specified. There is no mention of an adjudication process for clinical images or expert consensus within this 510(k) summary. The "Conclusion" indicates that Virtual Imaging, Inc. concluded the device's safety and effectiveness.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, a MRMC comparative effectiveness study was not done. The document describes a comparison to a predicate device for substantial equivalence, focusing on technical characteristics and intended use, not on the improvement of human readers with or without AI assistance.
- Effect size: Not applicable, as no such study was conducted.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- Not applicable. This device is a mobile fluoroscopy system, which is a hardware device that produces images, not an AI algorithm that operates standalone or assists in image interpretation without human intervention. Its performance is inherent in the image quality and system functionality for human use.
7. Type of Ground Truth Used
The concept of "ground truth" for image interpretation, as would be used for evaluating diagnostic accuracy, is not explicitly defined or used in this 510(k) summary. The evaluation relies on:
- Comparison of technical specifications (e.g., generator power, image intensifier size).
- Compliance with performance standards (21 CFR 1020.30).
- Results from "bench and test laboratory testing."
- Review of "clinical images" to support safety and effectiveness, likely focusing on image quality and proper function, but without defining a specific "ground truth" against which diagnostic accuracy was measured.
8. Sample Size for the Training Set
Not applicable. This device is a hardware system, not an AI algorithm requiring a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for a hardware fluoroscopy system.
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510(k) Summary 510(k) Number KOS3 725 Virtual Imaging, Inc. 720 S. Powerline Road, Suite E Deerfield Beach, FL 33442 954-428-6191 (Office) 954-428-6195 (Fax) Chris Duca, Chief Operating Officer Contact: Date Prepared: November 6, 2008
- l Identification of the Device: Proprietary-Trade Name: RadPro ION Mobile Fluoroscopy Systems (Multiple Models) Classification Name/Product Codes: Image Intensified Fluoroscopic System, JAA, Mobile X-Ray, IZL Common/Usual Name: Mobile Fluoroscopic X-Ray System
- Equivalent legally marketed device K073543 OEC 9900 Elite, GE Healthcare 2
- Indications for Use (intended use) The RadPro ION Mobile Fluoroscopy Systems are 3 designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, critical care and emergency room procedures The system may be used for other imaging applications at the physician's dıscretion
- Description of the Device The RadPro ION Mobile Fluoroscopy Systems (Multiple 4 Models) are mobile x-ray units which employ unage intensifier units and have various options for image display and storage The units are used to equip a radiological room of general surgery, orthopedic, traumatology and cardiology The CCD camera is characterized by high contrast and sensitivity and no persistence of image The camera head include a mage rotation and image reversal system The automatic dose control, which acts either on KV and mA values, allows the user to reduce step by step the x-ray radiation to the minimum value, in accordance with the thickness and the density of the screened part All the configurations can accept connection to a digital memory, which allows to store and display in real time the ımage on the monitor only with a very little x-ray dose The new control panel with an alphanumerical display permits a fast and easy use by a rational and simple symbology, this console by an extension cable, could be located on the patient support to enable the c-arm control by the operator itself The system employs a Dose Area Product (DAP) meter for compliance with the US performance standard requirements
- ર Safety and Effectiveness, comparison to predicate device The results of bench and test laboratory testing indicate that the new device is as safe and effective as the predicate devices
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| 6. Substantial Equivalence Chart | ||
|---|---|---|
| Characteristic | K073543 OEC 9900 Elite, GE Healthcare | RadPro ION Mobile Fluoroscopy Systems |
| Intended Use | The OEC 9900 Elite Mobile FluoroscopySystems are designed to provide fluoroscopicand spot-film images of the patient duringdiagnostic, surgical and interventionalprocedures Examples of clinical applicationmay include cholangiography, endoscopy,urologic, orthopedic, neurologic, critical careand emergency room procedures The systemmay be used for other imaging applications atthe physician's discretion | SAME |
| Configuration | Mobile C-Arm | SAME |
| Performance Standard | 21 CFR 1020 30 | SAME |
| Generator | 15 kW | 18 kW |
| Power Source | 120 VAC 1 phase 20 amp | SAME |
| Image Intensifiers | 9" or 12" | 9" or 13" |
| Electrical safety | Electrical Safety per IEC-60601 UL listed | SAME |
Substantial Equivalonco Cha
7. Conclusion
1
After analyzing bench and external laboratory testing to applicable standards, as well as clinical ımages, it is the conclusion of Virtual Imaging, Inc that the RadPro ION Mobile Fluoroscopy Systems are as safe and effective as the predicate device, have few technological differences, and has no new indications for use, thus rendering them substantially equivalent to the predicate devices
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or bird-like figure with three stylized lines representing wings or feathers.
Food and Drug Admınıstration 9200 Corporate Boulevard Rockville MD 20850
JAN 2 2 2009
Virtual Imaging, Inc % Daniel Kamm, P E Kamm & Associates PO Box 7007 DEERFIELD IL 60015
Re K083725
Trade/Device Name RadPro ION Mobile Fluoroscopy Systems (Multiple Models) Regulation Number 21 CFR 892 1650 Regulation Name Image-intensified fluoroscopic x-ray system Regulatory Class II Product Code JAA Dated December 12, 2008 Received December 16, 2008
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 adulterat10n
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 os 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 892 xxx | (Radiology) | (240) 276-0120 |
| Other | (240) 276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807 97) For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometrics' (OSB's) Division of Postmarket Surveyllance 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 Manufactures, 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 suppot/index html
Sincerely yours,
Janine M. Norris
anıne M N Acting 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) K08372-5
Device Name RadPro ION Mobile Fluoroscopy Systems (Multiple Models)
Indications For Use
The RadPro ION Mobile Fluoroscopy Systems are designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures Examples of clinical application may include cholangrography, endoscopy, urologic, orthopedic, neurologic, crtical care and emergency room procedures The system may be used for other imaging applications at the physician's discretion
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (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)
Division Sign-Off
(Division Sian-Off) Division of Reproductive, Abdominal and Radiological Devices 510(k) Number _
Page 1 of 1
§ 892.1650 Image-intensified fluoroscopic x-ray system.
(a)
Identification. An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. 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). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic 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. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.