(55 days)
MuCheck is an independent computer based verification of the monitor unit or dose calculated by the primary radiation treatment planning system.
The intended use of the MuCheck software has been extended to include an optional module, MuCheck/TomoCheck to independently verify the dose for single point that has been previously calculated by the Tomotherapy Hi Art treatment planning system or other points as determined by the physicist.
The MU Check Program is a software program that is designed to operate on an-IBM compatible personal computer in a Windows environment. It has been designed to operate either in a stand alone mode independent of the treatment planning system or to import plans from the treamment planning system. It does not connect to or control any radiation hardware device. MUCheck performs dose calculations to verify the dose calculated by the primary radiation teament planning system. The functionality of the MUCheck program is being extended to include calculations for the Tomotherapy Hi Art system, by this submission.
The provided text describes the MuCheck V9 device, which is a software program designed for dose validation in radiation therapy. The submission specifically details the extension of its functionality to include calculations for the Tomotherapy Hi Art system, through an optional module called TomoCheck.
Here's an analysis of the acceptance criteria and study information:
1. Table of Acceptance Criteria and Reported Device Performance:
The document explicitly states: "All system specifications were met and testing performed to demonstrate substantial equivalence." It also mentions, "The non-clinical tests were conducted using the treatment planning system and MU Check TomoCheck module. The test results all matched very closely which supports the claim of substantial equivalence. See Figure 6.0 in section 6 for comparison summary."
Although the specific numerical acceptance criteria (e.g., maximum percentage difference in dose calculation) and the detailed reported performance are not directly provided in the text, the general statement indicates that the MuCheck TomoCheck module performed within acceptable limits when compared to the primary Tomotherapy Hi Art system's calculations. The "very closely matched" outcome implies a high degree of concordance.
2. Sample Size for Test Set and Data Provenance:
- Sample Size: The document does not specify the exact number of test cases or "plans" used for the non-clinical tests. It broadly refers to "the non-clinical tests were conducted using the treatment planning system and MU Check TomoCheck module."
- Data Provenance: The document does not provide details on the origin of the data used for testing (e.g., specific treatment plans, patient data, retrospective or prospective). It only states that the tests were conducted with the "treatment planning system."
3. Number of Experts Used to Establish Ground Truth and Their Qualifications:
- Number of Experts: Not applicable or not specified.
- Qualifications of Experts: Not applicable or not specified.
This device is a software for dose calculation verification, not an interpretation device requiring expert human evaluation to establish ground truth for image or clinical findings. The ground truth for its evaluation would be the calculations from the established primary treatment planning system (Tomotherapy Hi Art).
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable.
Similar to the previous point, this device's performance is gauged against a programmatic or calculated ground truth from another system, not against a ground truth established by human adjudicators.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- MRMC Study: No.
- Effect Size of Human Readers Improvement: Not applicable.
The MuCheck V9 is a standalone dose validation software. Its function is to provide a secondary, independent check of dose calculations, not to assist human readers in interpreting data or making diagnoses. Therefore, an MRMC study comparing human performance with and without AI assistance is not relevant to this device.
6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance:
- Standalone Performance: Yes. The entire "Non-clinical tests" section describes the evaluation of the MuCheck TomoCheck module's performance in calculating doses compared to the primary treatment planning system. This is an assessment of the algorithm's standalone capability. The software operates independently to perform these calculations.
7. Type of Ground Truth Used:
- Type of Ground Truth: The ground truth for evaluating MuCheck V9 (TomoCheck module) was the dose calculations performed by the primary radiation treatment planning system (specifically the Tomotherapy Hi Art system). The document states, "The non-clinical tests were conducted using the treatment planning system and MU Check TomoCheck module. The test results all matched very closely which supports the claim of substantial equivalence." This implies that the calculations from the Tomotherapy Hi Art system served as the reference standard.
8. Sample Size for the Training Set:
- Sample Size: Not specified.
The document focuses on the verification and validation of the software. While software like this would have undergone extensive internal development and testing, information about a specific "training set" in the context of machine learning, or a distinct training phase, is not provided. Given the nature of a dose calculation verification tool, its development likely involved rigorous algorithmic design and parameter tuning based on radiation physics principles rather than a traditional machine learning training set as might be found with image recognition AI.
9. How the Ground Truth for the Training Set Was Established:
- How Ground Truth Was Established: Not specified.
As mentioned above, the concept of a "training set" with established ground truth in the typical machine learning sense is not explicitly discussed for this type of software. Its development would rely on accurate implementation of physics-based dose calculation algorithms.
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NOV - 2 2010
510(k) Safety and Effectiveness Summary
| Submitter: | Oncology Data Systems, Inc.1601 S.W 89th, Ste. E-100Oklahoma City, Ok. 73159tel. (405) 680-5222fax (405) 680-5444 |
|---|---|
| Contact:Date: | Vincent RuminerAugust 30, 2010 |
| Trade Name: | Mucheck V9.0 |
| Common Name: | Dose Validation Software |
| Classification Panel: | Radiology |
| Classification Name: | Medical Charged Particle Radiation TherapySystem(Accessory)21 CFR 892.5050 (class II) |
| Performance Standards: | none established under section 514 |
Substantial Equivalence:
| Device Name | 510(K) Number |
|---|---|
| MUCheck Monitor Unit Validation (V8 for GammaKnife) | K091602 |
Description:
The MU Check Program is a software program that is designed to operate on an-IBM compatible personal computer in a Windows environment. It has been designed to operate either in a stand alone mode independent of the treatment planning system or to import plans from the treamment planning system. It does not connect to or control any radiation hardware device. MUCheck performs dose calculations to verify the dose calculated by the primary radiation teament planning system. The functionality of the MUCheck program is being extended to include calculations for the Tomotherapy Hi Art system, by this submission.
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Substantial Equivalence Summary:
Intended Use:
The intended use for the MU Check program is the same as for the predicate devices: to calculate a dose for the purpose of validating a dose previously calculated by the primary treatment planning system. The functionality of the MUcheck program is being extended by adding an optional module(TomoCheck) by this submission. The TomoCheck module will allow the MUcheck program to perform point dose calculations for treatment plans created by the TomoTherapy Hi Art system. The intended use is as a quality assurance tool only and not as a treatment planning device.
In a radiation therapy department quality assurance is an important part of patient care. The ability to provide a secondary check for the primary dose calculation is part of good treatment protocol as well being a recommendation by Task Group 40. MU Check provides this very important quality assurance function.
Technological Characteristics:
The technological characteristics are the same as for the predicate devices. MUCheck was designed to operate in a windows environment using both mouse and keyboard.
Non-clinical tests:
Verification and validation test plans were completed in accordance with Oncology Data Systems procedures and GMP guidelines. A Hazard Analysis was completed and hazards were resolved as appropriate. All system specifications were met and testing performed to demonstrate substantial equivalence. The non-clinical tests were conducted using the treatment planning system and MU Check TomoCheck module. The test results all matched very closely which supports the claim of substantial equivalence. See Figure 6.0 in section 6 for comparison summary.
Summary of Clinical Testing:
Clinical testing was not required to demonstrate substantial equivalence or safety and effectiveness.
Conclusions:
Based upon the technological characteristics, intended use, and non-clinical tests, MUCheck is substantially equivalent to the predicate device. The documentation submitted for review supports this claim.
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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged in a circular fashion around the eagle.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002
Mr. Vincent Ruminer President Oncology Data Systems, Inc. 1601 SW 89th Street, Building E-100 OKLAHOMA CITY OK 73159
Re: K102583
NOV - ? 2180
Trade/Device Name: MuCheck V9 Regulation Number: 21 CFR 892.5050 Regulation Name: Medical image communications device Regulatory Class: II Product Code: IYE Dated: August 30, 2010 Received: September 8, 2010_
Dear Mr. Ruminer:
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 class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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 Parts 801 and 809); medical device reporting (reporting of
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medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). 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 Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Signature
David G. Brown, Ph.D. Acting Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): K102583
Device Name: MuCheck V9
NOV - 2 2010
Indications For Use:
MuCheck is an independent computer based verification of the monitor unit or dose calculated by the primary radiation treatment planning system.
The intended use of the MuCheck software has been extended to include an optional module, MuCheck/TomoCheck to independently verify the dose for single point that has been previously calculated by the Tomotherapy Hi Art treatment planning system or other points as determined by the physicist.
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 ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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Devices
(Division Sign Off)atton and Safety
Division of Radiological Devices
Office of In Vitro Diagnostic Device Evaluation and Safety
510K. K102583
§ 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.