K Number
K121447
Device Name
ISCHEMA VIEW RAPID
Manufacturer
Date Cleared
2013-10-04

(507 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
iSchemaView's RAPID is an image processing software package to be used by trained professionals, including but not limited to physicians and medical technicians. The software runs on a standard "off-the-shelf" computer or a virtual platform, such as VMware, and can be used to perform image viewing, processing and analysis of brain images. Data and images are acquired through DICOM compliant imaging devices. iSchemaView's RAPID provides both viewing and analysis capabilities for functional and dynamic imaging datasets acquired with CT Perfusion and MRI including a Diffusion Weighted MRI (DWI) Module and a Dynamic Analysis Module (dynamic contrast enhanced imaging data for MRI and CT). The DWI Module is used to visualize local water diffusion properties from the analysis of diffusionweighted MRI data. The Dynamic Analysis Module is used for visualization and analysis of dynamic imaging data, showing properties of changes in contrast over time. This functionality includes calculation of parameters related to tissue flow (perfusion) and tissue blood volume.
Device Description
RAPID is a software package that provides for the visualization and study of changes of tissue perfusion and diffusion in digital images captured by CT (Computed Tomography) and MRI (Magnetic Image Resonance). RAPID can be installed on a customer PC or it can be accessed online as virtual system. It provides viewing, quantification, analysis and reporting capabilities. RAPID works with the following types of (DICOM compliant) medical image data: - · CT (Computed Tomography) - · MRI (Magnetic Image Resonance) RAPID acquires (DICOM compliant) medical image data from the following sources: - · DICOM file - · DICOM CD-R - · Network using DICOM protocol RAPID provides tools for performing the following types of analysis: - · volumetry of threshold maps - · time intensity plots for dynamic time courses - measurement of mismatch between labeled volumes on co-registered image volumes RAPID is a software-only device consisting of one or more RAPID Servers (dedicated or virtual and an iSchemaView Server). The RAPID Server is an image processing engine that connects to a hospital LAN, inside the Hospital Firewall. It can be a dedicated RAPID Server or a vmRAPID appliance, which is a virtualized RAPID Server that runs on a dedicated hospital server. Where available, the RAPID Server is placed logically in the demilitarized zone (DMZ) of the hospital's network to facilitate bidirectional secure connection between the (local) RAPID Server and the centralized iSchemaView Server. The RAPID Server is configured to connect to applicable DICOM devices (PACS, Imaging Modalities, Research Workstations) via the hospital LAN and to receive diffusion and perfusion (DICOM) data directly and automatically from imaging modalities as they become available. It processes acquired data and delivers postprocessed images directly back to imaging modalities, local PACS and/or workstations, again using DICOM communication. It also transmits data to the iSchemaView Server for storage, retrieval and viewing. The iSchemaView Server is a dedicated server that provides a central repository for RAPID data. All iSchemaView Server data is stored on encrypted hard disks. It also provides a user interface for accessing RAPID data. It connects to a firewalled Data Center Network and has its own firewall for additional data security. The iSchemaView Server connects to one or more RAPID Servers via WAN. Available types of connection include VPN (Virtual Private Network - RFC2401 and RFC4301 Standards) Tunnel and SSH (Secure Shell).
More Information

No
The summary describes image processing and analysis software for brain images (CT and MRI) focused on perfusion and diffusion parameters. It details data acquisition, processing steps (volumetry, time intensity plots, mismatch measurement), and system architecture. There is no mention of AI, ML, deep learning, or any related terms in the provided text. The performance studies described are focused on accuracy of parameter representation and software validation, not on the performance metrics typically associated with AI/ML models (like AUC, sensitivity, specificity from a classification or detection task).

No
The device is described as image processing software used for viewing, processing, and analysis of brain images. It does not provide therapy or treatment for a disease or condition.

Yes

The device is an "image processing software package" that performs "processing and analysis of brain images" for "trained professionals, including but not limited to physicians and medical technicians" to provide "visualization and study of changes of tissue perfusion and diffusion." This functional description indicates that it aids in diagnosis by processing medical images and providing actionable information for medical professionals.

Yes

The device description explicitly states, "RAPID is a software-only device consisting of one or more RAPID Servers (dedicated or virtual and an iSchemaView Server)." While it interacts with hardware (standard computers, virtual platforms, DICOM devices), the device itself, as described, is the software package.

Based on the provided information, this device is not an In Vitro Diagnostic (IVD).

Here's why:

  • IVDs analyze biological samples: In Vitro Diagnostics are designed to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information about a person's health.
  • RAPID analyzes medical images: RAPID processes and analyzes medical images (CT and MRI scans) of the brain. It does not interact with or analyze biological samples.

Therefore, RAPID falls under the category of medical imaging software or a medical device that processes imaging data, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

iSchemaView's RAPID is an image processing software package to be used by trained professionals, including but not limited to physicians and medical technicians. The software runs on a standard "off-the-shelf" computer or a virtual platform, such as VMware, and can be used to perform image viewing, processing and analysis of brain images. Data and images are acquired through DICOM compliant imaging devices.

iSchemaView's RAPID provides both viewing and analysis capabilities for functional and dynamic imaging datasets acquired with CT Perfusion and MRI including a Diffusion Weighted MRI (DWI) Module and a Dynamic Analysis Module (dynamic contrast enhanced imaging data for MRI and CT).

The DWI Module is used to visualize local water diffusion properties from the analysis of diffusionweighted MRI data.

The Dynamic Analysis Module is used for visualization and analysis of dynamic imaging data, showing properties of changes in contrast over time. This functionality includes calculation of parameters related to tissue flow (perfusion) and tissue blood volume.

Product codes

LLZ

Device Description

RAPID is a software package that provides for the visualization and study of changes of tissue perfusion and diffusion in digital images captured by CT (Computed Tomography) and MRI (Magnetic Image Resonance). RAPID can be installed on a customer PC or it can be accessed online as virtual system. It provides viewing, quantification, analysis and reporting capabilities.

RAPID works with the following types of (DICOM compliant) medical image data:

  • · CT (Computed Tomography)
  • · MRI (Magnetic Image Resonance)

RAPID acquires (DICOM compliant) medical image data from the following sources:

  • · DICOM file

  • · DICOM CD-R

  • · Network using DICOM protocol
    RAPID provides tools for performing the following types of analysis:

  • · volumetry of threshold maps

  • · time intensity plots for dynamic time courses

  • measurement of mismatch between labeled volumes on co-registered image volumes

RAPID is a software-only device consisting of one or more RAPID Servers (dedicated or virtual and an iSchemaView Server). The RAPID Server is an image processing engine that connects to a hospital LAN, inside the Hospital Firewall. It can be a dedicated RAPID Server or a vmRAPID appliance, which is a virtualized RAPID Server that runs on a dedicated hospital server. Where available, the RAPID Server is placed logically in the demilitarized zone (DMZ) of the hospital's network to facilitate bidirectional secure connection between the (local) RAPID Server and the centralized iSchemaView Server.

The RAPID Server is configured to connect to applicable DICOM devices (PACS, Imaging Modalities, Research Workstations) via the hospital LAN and to receive diffusion and perfusion (DICOM) data directly and automatically from imaging modalities as they become available. It processes acquired data and delivers postprocessed images directly back to imaging modalities, local PACS and/or workstations, again using DICOM communication. It also transmits data to the iSchemaView Server for storage, retrieval and viewing.

The iSchemaView Server is a dedicated server that provides a central repository for RAPID data. All iSchemaView Server data is stored on encrypted hard disks. It also provides a user interface for accessing RAPID data. It connects to a firewalled Data Center Network and has its own firewall for additional data security. The iSchemaView Server connects to one or more RAPID Servers via WAN. Available types of connection include VPN (Virtual Private Network - RFC2401 and RFC4301 Standards) Tunnel and SSH (Secure Shell).

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CT (Computed Tomography), MRI (Magnetic Image Resonance)

Anatomical Site

Brain

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Trained professionals, including but not limited to physicians and medical technicians.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

iSchemaView conducted extensive performance validation testing and software verification and validation testing of the RAPID system. This performance validation testing demonstrated that the RAPID system provides accurate representation of key diffusion and perfusion processing parameters under a range of clinically relevant parameters and perturbations associated with the intended use of the software. Software validation and verification testing demonstrated that the RAPID system met all design requirements and specifications.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K120196

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.2050 Medical image management and processing system.

(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).

0

510(k) SUMMARY iSchemaView, Inc.'s RAPID

| Applicant's name: | iSchemaView, Inc.
323 Olmsted Road
Stanford, CA 94305 |
|-------------------|-------------------------------------------------------------------------------------------------------------------|
| Contact Person: | John J. Smith, M.D., J.D.
Partner
Hogan Lovells US LLP
555 Thirteenth Street, NW
Washington, DC 20004 |

OCT 04 2013

Date Prepared: September 13, 2013

Name of Device: RAPID

PACS - Picture Archiving Communications System Common or Usual Name:

Classification: Product Code: LLZ Regulation No: 21 C.F.R. §892.2050 Class: Il Classification Panel: Radiology Devices

Tel. (202) 637-3638 Fax (202) 637-5910

Predicate Devices

OLEA MEDICAL's Olea Sphere (K120196)

Device Description

RAPID is a software package that provides for the visualization and study of changes of tissue perfusion and diffusion in digital images captured by CT (Computed Tomography) and MRI (Magnetic Image Resonance). RAPID can be installed on a customer PC or it can be accessed online as virtual system. It provides viewing, quantification, analysis and reporting capabilities.

RAPID works with the following types of (DICOM compliant) medical image data:

  • · CT (Computed Tomography)
  • · MRI (Magnetic Image Resonance)

RAPID acquires (DICOM compliant) medical image data from the following sources:

  • · DICOM file
  • · DICOM CD-R
  • · Network using DICOM protocol

1

RAPID provides tools for performing the following types of analysis:

  • · volumetry of threshold maps
  • · time intensity plots for dynamic time courses
  • measurement of mismatch between labeled volumes on co-registered image volumes

RAPID is a software-only device consisting of one or more RAPID Servers (dedicated or virtual and an iSchemaView Server). The RAPID Server is an image processing engine that connects to a hospital LAN, inside the Hospital Firewall. It can be a dedicated RAPID Server or a vmRAPID appliance, which is a virtualized RAPID Server that runs on a dedicated hospital server. Where available, the RAPID Server is placed logically in the demilitarized zone (DMZ) of the hospital's network to facilitate bidirectional secure connection between the (local) RAPID Server and the centralized iSchemaView Server.

The RAPID Server is configured to connect to applicable DICOM devices (PACS, Imaging Modalities, Research Workstations) via the hospital LAN and to receive diffusion and perfusion (DICOM) data directly and automatically from imaging modalities as they become available. It processes acquired data and delivers postprocessed images directly back to imaging modalities, local PACS and/or workstations, again using DICOM communication. It also transmits data to the iSchemaView Server for storage, retrieval and viewing.

The iSchemaView Server is a dedicated server that provides a central repository for RAPID data. All iSchemaView Server data is stored on encrypted hard disks. It also provides a user interface for accessing RAPID data. It connects to a firewalled Data Center Network and has its own firewall for additional data security. The iSchemaView Server connects to one or more RAPID Servers via WAN. Available types of connection include VPN (Virtual Private Network - RFC2401 and RFC4301 Standards) Tunnel and SSH (Secure Shell).

Intended Use / Indications for Use

iSchemaView's RAPID is an image processing software package to be used by trained professionals, including but not limited to physicians and medical technicians. The software runs on a standard "off-the-shelf" computer or a virtual platform, such as VMware, and can be used to perform image viewing, processing and analysis of brain images. Data and images are acquired through DICOM compliant imaging devices.

iSchemaView's RAPID provides both viewing and analysis capabilities for functional and dynamic imaging datasets acquired with CT Perfusion and MRI including a Diffusion Weighted MRI (DWI) Module and a Dynamic Analysis Module (dynamic contrast enhanced imaging data for MRI and CT).

The DWI Module is used to visualize local water diffusion properties from the analysis of diffusionweighted MRI data.

The Dynamic Analysis Module is used for visualization and analysis of dynamic imaging data. showing properties of changes in contrast over time. This functionality includes calculation of parameters related to tissue flow (perfusion) and tissue blood volume.

2

Technological Characteristics

RAPID performs the following functions:

  • processes DICOM images from multiple sources to provide visualization of changes of . tissue perfusion and diffusion
  • receives DICOM images from external DICOM image providers (modalities (CT/MRI . Scanners), PACS and Workstations) and sends DICOM images to external image consumers
  • processes requests, statuses and results, and references therein, which are stored in a . queryable database
  • processing status is available through a web browser using HTTP, HTML and PHP. .
  • can send summary results to the user over email. For this, RAPID generally connects to the . infrastructure of the medical partner (e.g., the hospital). In particular, RAPID uses a SMTP protocol with security extensions to provide secure emailing.

RAPID is available in the following configurations:

  • Standard RAPID, which is installed directly on a customer's Linux-based PC and integrated . with medical image processing software such as commercial PACS.
  • . Virtual RAPID, wherein the user accesses RAPID online and uses it to process DICOM images otherwise available on his/her computer.

RAPID is a DICOM-compliant PACS software that provides comprehensive functionality to transfer, process, and display diffusion-weighted MRI (DWI) and dynamically acquired CT and MR imaging data (following the administration of a bolus of contrast media). RAPID runs on standard "off-theshelf" computer and networking hardware. RAPID is entirely independent from CT, MRI, or PACS platforms. It supports secure VPN (Virtual Private Network) networking or encapsulated Secure Shell (SSH), and seamlessly integrates into an existing radiological data network.

The primary users of RAPID PACS software are medical imaging professionals who analyze diffusion MRI and/or dynamic CT or MRI images. The images generated by RAPID provide additional diagnostic information, which is derived from the temporal/diffusion features of the native CT or MRI images.

Performance Data

RAPID complies with DICOM (Digital Imaging and Communications in Medicine) - Developed by the American College of Radiology and the National Electrical Manufacturers Association. NEMA PS 3.1 - 3.20 (2011).

Additionally. iSchemaView conducted extensive performance validation testing and software verification and validation testing of the RAPID system. This performance validation testing demonstrated that the RAPID system provides accurate representation of key diffusion and perfusion processing parameters under a range of clinically relevant parameters and perturbations associated with the intended use of the software. Software validation and verification testing demonstrated that the RAPID system met all design requirements and specifications.

3

Substantial Equivalence

RAPID is as safe and effective as the Olea Sphere. RAPID has the same intended use and similar indications, technological characteristics and principles of operation as its predicate device. The minor technological differences between the RAPID and its predicate raise no new issues of safety or effectiveness as demonstrated by the testing conducted with RAPID that confirms that the software reliably processes CT diffusion and MRI diffusion and perfusion medical images. Thus, the RAPID software is substantially equivalent.

4

ParameterRAPIDOlea Sphere (K120196)
Product CodeLLZLLZ
Regulation21 CFR §892.205021 CFR §892.2050
Intended Use/ Indications for useiSchemaView's RAPID is an image processing
software package to be used by trained
professionals, including but not limited to physicians
and medical technicians. The software runs on a
standard "off-the-shelf" computer or a virtual
platform, such as VMware, and can be used to
perform image viewing, processing and analysis of
brain images. Data and images are acquired
through DICOM compliant imaging devices.Olea Sphere is an image processing software package to be used by
trained professionals including but not limited to physicians and
medical technicians. The software runs on a standard "off-the-shelf"
workstation and can be used to perform image viewing, processing
and analysis of medical images. Data and images are acquired
through DICOM compliant imaging devices and modalities.
The iSchemaView RAPID provides both viewing and
analysis capabilities for functional and dynamic
imaging datasets acquired with CT Perfusion and
MRI including a Diffusion Weighted MRI (DWI)
Module and a Dynamic Analysis Module (dynamic
contrast-enhanced imaging data for MRI and CT).Olea Sphere provides both viewing and analysis capabilities of
functional and dynamic imaging datasets acquired with MRI or other
relevant modalities, including a Diffusion Weighted MRI (DWI) / Fiber
Tracking Module and a Dynamic Analysis Module (dynamic contrast
enhanced imaging data for MRI and CT).
The DWI Module is used to visualize local water
diffusion properties from the analysis of diffusion-
weighted MRI data.The DWI Module is used to visualize local water diffusion properties
from the analysis of diffusion-weighted MRI data. The Fiber Tracking
feature utilizes the directional dependency of the diffusion to display
the white matter Structure in the brain or more generally the central
nervous system.
The Dynamic Analysis Module is used for
visualization and analysis of dynamic imaging data,
showing properties of changes in contrast over time.
This functionality includes calculation of parameters
related to tissue flow (perfusion) and tissue blood
volume.The Dynamic Analysis Module is used for visualization and analysis
of dynamic imaging data, showing properties of changes in contrast
over time where such techniques are useful or necessary. This
functionality is referred to as:
Perfusion Module - the calculation of parameters related to
tissue flow (perfusion) and tissue blood volume.
Permeability Module - the calculation of parameters related
to leakage of injected contrast material from intravascular to
extracellular space.
PACS Functionality
Basic PACS FunctionsView, process and analyze medical images.
Performs standard PACS functions with respect to
querying and listing.Same
Computer PlatformStandard "off-the-shelf" PC workstationSame
DICOM ComplianceYes
Funcional OverviewRAPID is a software package that provides for the
visualization and study of changes of tissue
perfusion and diffusion in digital images captured by
CT and MRI. RAPID provides viewing and
quantification.Same
Data AcquisitionAcquires medical image data from DICOM compliant
imaging devices and modalitiesSame
Data/Image TypesComputed Tomography (CT)
Magnetic Image Resonance (MRI)Same
Acquisition and Modalities Features
MRIDiffusion Weighted Image (DWI)
Perfusion Weighted Image (PWI)Yes
CTCT Perfusion (CTP)Yes
Computed Parameter MapsIsotropic DWI (isoDWI)Yes
Exponential apparent diffusion coefficient (eADC)Yes
ADCYes
Diffusion MRITrace of diffusion tensor (Trace)Yes
Fractional Anisotropy (FA) and color FAYes
EigenvectorYes
EigenvalueYes
Perfusion MRI and Perfusion
CTCerebral blood flow (CBF)Yes
Cerebral blood volume (CBV)Yes
Mean transit time (MTT)Yes
Tissue residue function time to peak (Tmax)Yes
Measurements/ToolsArterial input function (AIF)/Venous output function
(VOF)Yes
Time-courseYes
Brain maskYes
MRI and CT ToolsRegion of interest (ROI) and VolumetryYes
Volumetric comparison between 2 ROIsYes
Motion correctionYes
Export perfusion and diffusion files to PACS and
DICOM file systemsYes
Acquire, transmit, process, and store medical
imagesYes

Substantial Equivalence

Note: RAPID also may be used with a virtual platform such as VMware

NDC - 038926/00001 - 4886242 v2

5

NDC: 03892600001-4886242 V2

K121442
page 6 of 6
0137

6

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-0609 Silver Spring, MD 20993-0002

October 4, 2013

iSchemaView, Inc. % John J. Smith, M.D., J.D. Pariner Hogan Lovells US L.LP Columbia Square 555 Thirtcenth Street. NW WASHINGTON DC 20004

Re: K121447

Trade/Device Name: RAPID Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ. Dated: September 16, 2013 Received: September 16, 2013

Dear Dr. Smith:

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 for too May 28, 1976. the enactment date of the Medical Device Amendments, or 10 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). and Cosmetic North the device, subject to the general controls provisions of the Act. The rou may, merely provisions of the Act include requirements for annual registration. Ilisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

ff your device is classified (see above) into cither class II (Special Controls) or class III (PMA), it may be subject to 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.

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 mat I DA has made a devel regulations administered by other Federal agencies. You must or any roothall the Act s requirements. including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

7

Page 2-Dr. Smith

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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638 2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industrv/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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/ReportalProblem/default.hum 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/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

for

Janine M. Morris Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

8

Indications for Use

510(k) Number (if known): K121447

Device Name: iSchemaView's RAPID

Indications for Use:

iSchemaView's RAPID is an image processing software package to be used by trained professionals, including but not limited to physicians and medical technicians. The software runs on a standard "off-the-shelf" computer or a virtual platform, such as VMware, and can be used to perform image viewing, processing and analysis of brain images. Data and images are acquired through DICOM compliant imaging devices.

iSchemaView's RAPID provides both viewing and analysis capabilities for functional and dynamic Imaging datasets acquired with CT Perfusion and MRI including a Diffusion Weighted MRI (DVM) Module and a Dynamic Analysis Module (dynamic contrast enhanced imaging data for MRI and CT).

The DWI Module is used to visualize local water diffusion properties from the analysis of diffusionweighted MRI data.

The Dynamic Analysis Module is used for visualization and analysis of dynamic imaging data, showing properties of changes in contrast over time. This functionality includes calculation of parameters related to tissue flow (perfusion) and tissue blood volume.

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 In Vitro Diagnostics and Radiological Health (OIR)

$\sin(7)$

(Division Sign-Off) Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health

长121447 510(k)

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