(13 days)
The Atomlab dose calibrators are used in Nuclear Medicine Departments, clinics and nuclear pharmacies for calibrating radioactive doses for administration to patients. The instrument is used to verify the radioactivity of a radionuclide before administration to the patient.
The Atomlab dose calibrator is comprised of a display unit and one or more connected argon gas filled pressurized jonization chamber detector unit. The calibration for the dose calibrator is contained in the chamber has a callbration certificate with it when it is shipped. Any of the Atomlab 400 and 500 displays can be connected to the chamber and will work correctly with the chamber since the calibration is stored in the chamber.
Based on the provided text, the Atomlab 400 and Atomlab 500 Radionuclide Dose Calibrators are Class II devices used in Nuclear Medicine departments, clinics, and nuclear pharmacies for calibrating radioactive doses. The submission focuses on substantial equivalence to predicate devices rather than establishing novel acceptance criteria through a new clinical study.
Here's an analysis based on the information provided:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't explicitly state specific quantitative acceptance criteria (e.g., a certain percentage accuracy or linearity range) for the Atomlab 400 and 500. Instead, it relies on demonstrating substantial equivalence to predicate devices and compliance with established performance standards.
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Substantial Equivalence to Predicate Devices: Basic detection, measurement process, design concepts, functions, and algorithms remain the same as predicate devices (Atomlab 100, Atomlab 200, Capintec 25). | "device accuracy, linearity, constancy, and geometry to device performance is substantially equivalent to the predicate devices." |
| Compliance with Performance Standards: IEC 1303 and IEC 61145. | "The Atomilab dose calibrators comply with Performance Standard IEC 1303 and IEC 61145." |
| Safety Standards Compliance: UL6060101, CAN/CSA C22.2 No .: 601-1-1-190, IEC 60601-1-4, IEC 60601-1. | "ETL listed for the Medical Device Safety Standards UL6060101, CAN/CSA C22.2 No .: 601-1-1-190, IEC 60601-1-4, IEC 60601-1." |
| EMC Medical Standard Compliance: IEC 60601-1-2. | "Retlif Certified to the EMC Medical Standard IEC 60601-1-2." |
| Functionality upon Installation: User or consulting physicist performs acceptance testing for accuracy, linearity, constancy, and geometry. | "The dose calibrators were independently tested and verified that they function correctly." |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not explicitly stated as a numerical value for "test set" in terms of patient data or a specific number of doses measured. The text mentions "Testing has been done by physicists at Northwestern Memorial Hospital and Stony Brook University Hospital of device accuracy, linearity, constancy, and geometry." This implies a series of tests performed on the physical devices themselves, likely involving multiple measurements of various radionuclides.
- Data Provenance: The testing was conducted at "Northwestern Memorial Hospital and Stony Brook University Hospital." This indicates the data was gathered in a prospective manner, as physicists actively performed tests on the devices. The country of origin for the data is the USA.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:
- Number of Experts: "Physicists" (plural) from Northwestern Memorial Hospital and Stony Brook University Hospital performed the testing. A specific number is not given.
- Qualifications of Experts: They are identified as "physicists." While general "physicist" is mentioned, in the context of nuclear medicine dose calibrators, these would typically be medical physicists with expertise in radiation measurement, quality assurance, and nuclear medicine instrumentation. Their experience level is not specified, but it's implied they are qualified professionals in their field.
4. Adjudication Method for the Test Set:
Not applicable. This was not a study involving human reader interpretation of medical images or data requiring adjudication of subjective findings. The testing described focuses on objective measurements of device performance (accuracy, linearity, constancy, geometry).
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
No, an MRMC comparative effectiveness study was not done. The device is a measurement instrument, not an AI intended to assist human readers in interpreting medical cases. No human-in-the-loop performance or effect size of AI improvement is discussed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Yes, a form of standalone performance assessment was conducted. The "device accuracy, linearity, constancy, and geometry" were tested by independent physicists. This represents the direct, objective performance of the dose calibrator itself, independent of a human interpreting its output for clinical decision-making.
7. The Type of Ground Truth Used:
The ground truth for the device's performance (accuracy, linearity, constancy, geometry) was established through reference standards and established physical principles. For example:
- Accuracy: The device's measurements would be compared against known activities of calibrated radioactive sources (e.g., sources traceable to NIST).
- Linearity: Measurements across a range of activities would be compared to the expected linear response.
- Constancy: Repeat measurements of a stable source over time would confirm consistent readings.
- Geometry: Measurements with the same source in different geometries would be compared to expected values.
These are objective physical measurements, not subjective expert consensus, pathology, or outcomes data in the traditional sense of diagnostic imaging.
8. The Sample Size for the Training Set:
Not applicable. This device is a physical instrument for measurement, not an algorithm trained on a dataset of images or clinical outcomes. There is no "training set" in the context of machine learning. The device's calibration is "contained in the chamber has a calibration certificate with it when it is shipped."
9. How the Ground Truth for the Training Set was Established:
Not applicable, as there is no training set for this type of device. The accuracy of the device is inherent in its design, manufacturing ("manufactured to the product's specifications"), and initial calibration, which is "contained in the chamber" and comes with a "calibration certificate." Further verification is done by users or physicists upon installation through acceptance testing.
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510K SUMMARY
ATOMLAB 400 AND ATOMLAB 500, MODELS #086-330, 086-335, 086-336, 086-332
The Atomlab 400 and Atomlab 500 Radionuclide Dose Calibrator series from Biodex Medical Systems, Inc. is ETL listed for the Medical Device Safety Standards UL6060101, CAN/CSA C22.2 No .: 601-1-1-190, IEC 60601-1-4, IEC 60601-1 and is Retlif Certified to the EMC Medical Standard IEC 60601-1-2.
The radionuclide dose calibrators are Class II devices. Classification #: 90 KPT, 21 CFR #892.1360
The Atomilab dose calibrators comply with Performance Standard IEC 1303 and IEC 61145.
Predicate Devices: Atomlab 100 (K884312/A), Atomlab 200 (K884312/A), Capinter 25 (K071396),
The basic detection, measurement process, design concepts, functions and algorithms remain the same as the predicate devices. Testing has been done by physicists at Northwestern Memorial Hospital and Stony Brook University Hospital of device accuracy, linearity, constancy, and geometry to device performance is substantially equivalent to the predicate devices.
The intended use: The Atomlab dose calibrators are used in Nuclear Medicine departments, clinics and nuclear pharmacies for calibrating radioactive doses for administration to patients. The instrument is used to verify the radioactivity of a radionuclide before administration to the patient. The Atomlab dose calibrator is comprised of a display unit and one or more connected argon gas filled pressurized jonization chamber detector unit. The calibration for the dose calibrator is contained in the chamber has a callbration certificate with it when it is shipped. Any of the Atomlab 400 and 500 displays can be connected to the chamber and will work correctly with the chamber since the calibration is stored in the chamber. The dose calibrators were independently tested and verified that they function correctly.
Dose calibrators have been used in Nuclear Medicine departments and nuclear pharmacies for many years. When a dose calibrator is received, upon installation there is a series of tests that are performed by the user or a consulting physicist for acceptance testing of the dose calibrator.
The Atomlab 400 and Atomlab 500 will be manufactured to the product's specifications.
CERTIFICATION:
I hereby certify that this summary of safety and effectiveness applies for the above indicated Atomlab dose calibrators.
Date: Jan 6, 2009
Name:
Clyde Schlein
Director of Regulatory Affairs & Compliance Biodex Medical Systems, Inc. 20 Ramsay Road Shirley, New York USA 11967-4704 Phone: (631) 924-9000 ext. 2343 Fax: (631) 924-9502 Email: cschlein@biodex.com
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Image /page/1/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three lines extending from its head, representing the department's commitment to health, services, and people. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Biodex Medical Systems, Inc. % Mr. Jay Y. Kogoma Responsible Third Party Official Intertek Testing Services 2307 E. Aurora Rd., Unit B7 TWINSBURG OH 44087 ·
FEB 1 9 2009
Re: K090296
Trade/Device Name: Atomlab 400 and Atomlab 500 Regulation Number: 21 CFR 892.1360 Regulation Name: Radionuclide dose calibrator Regulatory Class: II Product Code: KPT Dated: February 5, 2009 Received: February 6, 2009
Dear Mr. Kogoma:
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 unay, there interes market the device, subject to the general controls prossisions 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 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 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 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.suppor/index.html.
Sincerely yours,
Janine M. Morris
anine M. Morris Acting Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
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Indications for Use
| 510(k) Number (if known): | K090296 |
|---|---|
| --------------------------- | --------- |
Device Name:
Atomlab 400 Atomlab 500
Indications For Use:
The Atomlab dose calibrators are used in Nuclear Medicine Departments, clinics and nuclear pharmacies for calibrating radioactive doses for administration to patients.
The instrument is used to verify the radioactivity of a radionuclide before administration to the patient.
Prescription Use . X (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 ANDRIGER.PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Torzal Martin
(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Devices 510(k) Number
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§ 892.1360 Radionuclide dose calibrator.
(a)
Identification. A radionuclide dose calibrator is a radiation detection device intended to assay radionuclides before their administration to patients.(b)
Classification. Class II.