(119 days)
The Sync-Rx System is an image acquisition and processing system. It is indicated for use as follows:
- a) To provide quantitative information regarding the calculated dimensions of arterial segments.
- b) To enhance visualization of the stent deployment region.
- c) To be used in-procedure in the catheterization lab and off-line for post-procedural analysis.
- d) To obtain a co-registration of an angiographic x-ray image and IVUS images.
The modified Sync-Rx System is an image acquisition and processing workstation situated in the coronary catheterization lab and intended to be used during coronary catheterizations.
The modified Sync-Rx System captures the angiographic and intrasound (IVUS) image streams and performs the following display functions for assisting the interventional cardiologist.
- During lesion evaluation: Angiogram and IVUS image selection, quantitative coronary measurements (lesion diameters, length, % stenosis) and vessel region enhancement and vessel region stabilization are performed instantly and on-line.
- During device positioning, deployment: An on-line image stream derived from the native angiographic image stream that is enhanced and stabilized, is displayed side-by-side to the native angiographic and IVUS image streams.
- Display of native image / data streams used before or during trans-catheter cardiovascular interventions, leading to a joint display of images corresponding to the same selected vascular locations or segments (also known as co-registration).
All functions performed by the modified Sync-Rx System are presented, both in the procedure room and in the control room, on a computer display that is situated directly next to the existing display of native angiographic and IVUS image streams. The modified Sync-Rx System operates by means of multiple software modules and associated algorithms interacting with one another and responsible for the on-line acquisition, processing and display of coronary image frames.
The most significant change to the modified Sync-Rx System, and the reason for this 510(k) submission, is the addition of the capability to display and co-register another native image stream. IVUS. The addition of the co-registered IVUS image stream is intended to automate manual registration processes currently performed in the coronary catheterization lab and to provide a simple means to view both the angiographic and IVUS image streams on adjacent windows on a single computer display.
Here's an analysis of the provided text regarding the acceptance criteria and supporting study for the Volcano Corporation's modified Sync-Rx™ System:
Summary of Device Performance Study
The provided 510(k) summary for the modified Sync-Rx System (K132558) describes the device as an image acquisition and processing workstation for use in coronary catheterization labs. The most significant change in this modification is the addition of Intravascular Ultrasound (IVUS) image stream display and co-registration with angiographic images. The submission asserts substantial equivalence to predicate devices (Sync-Rx System, K100849, and Artis Q, K123529).
Regarding performance testing, the document states that the modified Sync-Rx System underwent safety, performance, verification, and validation testing. Specifically for the new IVUS co-registration and quantitative measurements, the submission claims that the same statistical methods used for the unmodified system's angiogram QCA measurements were applied to establish the accuracy and precision of the IVUS QCA measurements (length and diameter). It also mentions "Co-registration Validation - Phantom Based Simulated Environment."
However, the document does not explicitly state specific acceptance criteria or provide a detailed table of results for the device performance against such criteria. It generally asserts that "Performance data demonstrates that any differences in the available intra-luminal measurements between the modified Sync-Rx System and the Artis Q do not raise questions of substantial equivalence."
Detailed Information Extracted from the Document:
-
Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria (Inferred from general statements) Reported Device Performance Accuracy and precision of IVUS QCA measurements (length and diameter) "The same statistical methods that were employed in the unmodified System to establish the accuracy and precision of the angiogram QCA measurements were employed in the modified System to establish the accuracy and precision of the IVUS QCA measurements (length and diameter). Therefore, the accuracy and precision of the IVUS measurements do not raise questions of substantial equivalence." (No specific numerical values provided in this summary.) Functional requirements and intended uses fully met "Final testing of the modified Sync-Rx System included various performance tests and software validation tests, designed to ensure that the device met all of its functional requirements and intended uses." (Specific details of "functional requirements" and how they were met are not provided.) Compliance with applicable industry and safety standards (listed IEC/UL, ISO standards) "Tests have been performed to ensure that the device complies with all applicable industry and safety standards." (Compliance with specific standards like IEC/EN/UL 60601-1, IEC/EN 60601-1-2, IEC 60601-1-6, IEC 62366, IEC 62304, and ISO 15223 is asserted, but no test results are presented.) Co-registration accuracy "Co-registration Validation - Phantom Based Simulated Environment" was performed. (No specific accuracy metrics or results from this validation are given in the summary.) Usability "Sync-Rx System Usability Validation" was performed. (No specific outcomes or metrics from usability validation are presented.) Safety (Electrical Safety, Electromagnetic Compatibility) "Electrical Safety" and "Electromagnetic Compatibility" tests were performed. (No specific results or parameters for safety testing are provided.) No new questions of substantial equivalence The document repeatedly asserts that the modifications do not raise new questions of substantial equivalence based on the testing performed and comparison to predicate devices, particularly the Artis Q system's existing co-registration of angiogram and IVUS images. -
Sample sizes used for the test set and the data provenance:
- Test Set Sample Size: The document does not specify an exact sample size (e.g., number of patients, images, or phantom runs) for the tests. It mentions "phantom based simulated environment" for co-registration validation.
- Data Provenance: Not explicitly stated for specific test data. The submission indicates that "Animal test data and clinical data were not required to demonstrate substantial equivalence." This implies that the validation primarily relied on bench testing, phantom studies, and possibly existing data or characterization of the algorithm's performance on a simulated or internal dataset.
-
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):
- The document does not provide information on the number or qualifications of experts used to establish ground truth for the test set.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- The document does not provide information on any adjudication method used for the test set.
-
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:
- No MRMC comparative effectiveness study is mentioned. The device is presented as an aid to interventional cardiologists ("assisting the interventional cardiologist") and simplifies workflow ("automate manual registration processes," "simple means to view both... on single computer display"), but no studies on improved human reader performance with the device compared to without it are presented or referenced. "Animal test data and clinical data were not required."
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The "Co-registration Validation - Phantom Based Simulated Environment" and "IVUS QCA measurements" accuracy and precision testing likely represent standalone algorithm performance checks, as they would assess the algorithm's output against a known or simulated ground truth without direct human interpretation being the primary variable. However, it's not explicitly framed as a "standalone study" in the common sense of an AI performance report.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the co-registration validation, a phantom-based simulated environment was used, implying a precisely known ground truth for validation.
- For IVUS QCA measurements, the ground truth source is not explicitly stated, but it would typically involve physical measurements of phantoms or carefully calibrated reference images, similar to how the unmodified system's angiogram QCA measurements were validated.
- No expert consensus, pathology, or outcomes data are mentioned as ground truth.
-
The sample size for the training set:
- The document does not provide information on a training set sample size. This is a 510(k) for a modified device, and while it uses algorithms, the submission focuses on verifying the modifications (primarily IVUS co-registration and QCA). The original algorithms would have been developed and "trained" prior to the initial K100849 submission, and that information is not part of this summary for the modified device. Also, the term "training set" is more common in machine learning or deep learning contexts, which may not have been the primary methodology for the underlying algorithms at the time of this submission (2013).
-
How the ground truth for the training set was established:
- As no training set information is provided, how its ground truth was established is also not documented in this 510(k) summary.
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K132558
DEC 12 2013
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Volcano Corporation - Traditional 510(k) - Modified Sync-Rx™ System 510(k) Summary
510(k) Summary
Introduction
This document contains the 510(k) Summary for the modified Sync-Rx™ System. The content of this summary is based on the requirements set forth in 21 CFR 807.92(c).
Applicant: Volcano Corporation
Establishment Registration Number: 2939520
Contact Information:
SPONSOR: Volcano Corporation 2870 Kilgore Road Rancho Cordova, CA 95670 Tel: (800) 228-4728
CONTACT/SUBMITTER: Elaine Alan Senior Regulatory Affairs Specialist 1 Fortune Drive Billerica, MA 01821
Email: ealan@volcanocorp.com Tel: (978) 439-3357 Fax: (978) 262-0035
Date Prepared: August 9, 2013
Device Trade Name: Sync-Rx™ System
Classification Name: Image-intensified Fluoroscopic X-ray System
Device Classification:
Classification: II Classification Panel: Radiology Requiation Number: 21 CFR 892.1650 Product Code: OWB
Predicate Devices:
The modified Sync-Rx System is claimed to be substantially equivalent to the following legally marketed predicate devices:
The Sync-Rx System (K100849) manufactured by Sync-Rx, Ltd.
The Artis Q (K123529) manufactured by Siemens Medical Systems, Inc.
Performance Standards:
This 510(k) submission was written in accordance with the FDA Guidance document "Guidance for the Submission of Premarket Notifications for Medical Image Management Devices- July 27, 2000" "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 11 2005", and "General Principles for Software Validation; January 2002". The design of the Sync-Rx System conforms to the following voluntary standards:
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Volcano Corporation - Traditional 510(k) - Modified Sync-Rx™ System 510(k) Summary
- IEC/EN/UL 60601-1:2005 (3rd Ed.) Medical electrical equipment Part 1: General requirements for basic safety and essential performance
- IEC/EN 60601-1-2:2007 Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility -Requirements and tests
- IEC 60601-1-6:2010 Medical electrical equipment Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
- IEC 62366:2007 Medical devices Application of usability engineering to medical devices
- IEC 62304:2006 Medical device software Software life cycle processes
- ISO 15223:2012 Medical devices Symbols to be used with medical device labels, labeling and information to be supplied - Part 1: General requirements
Device Description:
The modified Sync-Rx System is an image acquisition and processing workstation situated in the coronary catheterization lab and intended to be used during coronary catheterizations.
The modified Sync-Rx System captures the angiographic and intrasound (IVUS) image streams and performs the following display functions for assisting the interventional cardiologist.
- During lesion evaluation: Angiogram and IVUS image selection, quantitative coronary measurements (lesion diameters, length, % stenosis) and vessel region enhancement and vessel region stabilization are performed instantly and on-line.
- During device positioning, deployment: An on-line image stream derived from the native angiographic image stream that is enhanced and stabilized, is displayed side-by-side to the native angiographic and IVUS image streams.
- Display of native image / data streams used before or during trans-catheter cardiovascular interventions, leading to a joint display of images corresponding to the same selected vascular locations or segments (also known as co-registration).
All functions performed by the modified Sync-Rx System are presented, both in the procedure room and in the control room, on a computer display that is situated directly next to the existing display of native angiographic and IVUS image streams. The modified Sync-Rx System operates by means of multiple software modules and associated algorithms interacting with one another and responsible for the on-line acquisition, processing and display of coronary image frames.
The most significant change to the modified Sync-Rx System, and the reason for this 510(k) submission, is the addition of the capability to display and co-register another native image stream. IVUS. The addition of the co-registered IVUS image stream is intended to automate manual registration processes currently performed in the coronary catheterization lab and to provide a simple means to view both the angiographic and IVUS image streams on adjacent windows on a single computer display.
Indication for Use:
The Sync-Rx System is an image acquisition and processing system. It is indicated for use as follows:
- To provide quantitative information reqarding the calculated dimensions of arterial segments.
- To enhance visualization of the stent deployment region.
- To be used in-procedure in the catheterization lab and off-line for post-procedural analysis.
- To obtain a co-registration of an angiographic x-ray image and IVUS images.
Comparison of Technological Characteristics:
The modified Sync-Rx System and its identified predicate devices have the same or similar technological characteristics. The most significant technological change in the modified Sync-Rx System is the addition
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Volcano Corporation - Traditional 510(k) - Modified Sync-Rx ™ System 510(k) Summary
of the IVUS image source and the corresponding co-registration of the angiogram and IVUS images. The additional ultrasound display and co-registration function are similar to the existing co-registration of the ECG signal with the angiogram images in the unmodified Sync-Rx System. The co-registration function is intended to simplify and automate what is done manually today in the catheterization lab when both X-Ray and IVUS images are available on individual displays. Furthermore, the addition of the IVUS image source to the System and co-registration of image streams to simplify work flow is a function currently included in the Artis Q System which also co-registers angiogram and IVUS images.
Application
Both the unmodified and the modified Sync-Rx Systems function as accessories to existing vessel imaging systems by providing QCA and image enhancement functions; the modified Sync-Rx System simply expands imaging sources to include IVUS images. No other functions of the System have been significantly modified. This addition of a second image source does not change how either angiography or IVUS imaging machines are used in the clinical setting, nor does it affect the QCA capability on the angiogram images as it was discussed in K100849. The modified Sync-Rx System will co-register the IVUS images with the X-Ray images in a substantially equivalent manner to the Artis Q.
The most notable technical difference between the modified Sync-Rx System and the Artis Q is that the Artis Q is primarily an imaging device that includes accessory software for image manipulation, including IVUS co-registration and QCA. Both the software component of the Artis Q and the modified Sync-Rx System are capable of acquiring angiogram and IVUS images for co-registration, QCA, and image enhancement options.
Image Source
The images used by the modified Sync-Rx System and its identified predicate devices are digital and analog video signals, and all aforementioned devices use native vascular images for all device functions. Both the modified Sync-Rx System and the Artis Q capture IVUS and X-Ray images of a patient's vasculature to improve visualization and to provide quantitative vessel measurements during guided procedures.
IVUS Measurements
The modified Sync-Rx System's application of QCA functionality to the added IVUS image stream to perform intra-luminal measurements (diameter and length) is substantially equivalent to that of the Artis Q. which was demonstrated to be safe and effective in K123529. The intra-luminal measurements performed by the modified Sync-Rx System are a subset of the intra-luminal measurements performed by the Artis Q. Performance data demonstrates that any differences in the available intra-luminal measurements between the modified Sync-Rx System and the Artis Q do not raise questions of substantial equivalence.
Although IVUS QCA measurements are not available in the unmodified Sync-Rx System, because the unmodified System does not capture IVUS as an image stream, the same statistical methods that were employed in the unmodified System to establish the accuracy and precision of the angiogram QCA measurements were employed in the modified System to establish the accuracy and precision of the IVUS QCA measurements (length and diameter). Therefore, the accuracy and precision of the WUS measurements do not raise questions of substantial equivalence.
Comparison of Indications for Use / Intended Use
The intended use of the modified Sync-Rx System remains unchanged from that of the unmodified Sync-Rx System. The modified Sync-Rx System and its identified predicate devices are all intended for capturing native vascular images of patients with cardiovascular diseases for image processing and enhancement. Further, the modified Sync-Rx System and its predicate devices are capable of off-line use for immediate post-procedural analysis.
The Indications for Use for the modified Sync-Rx System is expanded to include the Co-Registration functionality compared to the cleared unmodified Sync-Rx System. Although the indications for use of the Artis Q focus on its intended use as an angiography system. the intended use and functionality of the image processing software component of the Artis Q are nearly identical to that of the modified Sync-Rx
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K132558
Page. 4 of 4
Volcano Corporation - Traditional 510(k) - Modified Sync-Rx™ System 510(k) Summary
System. Both the modified Sync-Rx System and the Artis Q image processing software component are accessories to vascular imaging systems intended to acquire and co-register native X-Ray and IVUS images for image manipulation and processing to provide calculated vessel measurements. The unmodified Sync-Rx System functions in a similar manner, with the only exception of being a software accessory exclusively for anaiography systems. The minor differences in the application between the modified Sync-Rx System and the predicate devices do not impart new intended uses or change the therapeutic effects of the device.
Target User and Patient Population
The intended target user group for the modified Sync-Rx System and its predicate devices is experienced and qualified medical personnel, such as clinicians, technicians and research personnel.
The modified Sync-Rx System is also intended for use for the same patient population as all of the identified predicate devices, which are patients with cardiovascular diseases whom would benefit from such treatment.
Use Environment
The environment of use of the modified Sync-Rx System and its predicate devices are identical. The modified Sync-Rx System and its predicate devices are all intended to be used in the catheterization lab on-line during the procedure, as well as off-line for immediate post-procedural analysis.
Performance Test Data:
The modified Sync-Rx System has been subjected to safety, performance, verification and validation testing before its release. Final testing of the modified Sync-Rx System included various performance tests and software validation tests, designed to ensure that the device met all of its functional requirements and intended uses. Tests have been performed to ensure that the device complies with all applicable industry and safety standards. The following list summarizes the testing performed on the modified System:
Software Unit Tests
Software Verification Tests
Software Validation Tests
Co-registration Validation - Phantom Based Simulated Environment
Sync-Rx System Usability Validation
Sync-Rx System Design Verification
Electrical Safety
- Electromagnetic Compatibility
Animal test data and clinical data were not required to demonstrate substantial equivalence of the modified Sync-Rx System in this 510(k) submission.
Substantial Equivalence:
The modified Sync-Rx System is substantially equivalent with respect to the intended use, technological characteristics, performance characteristics, target user and patient population, and use environment to the following the legally marketed predicate devices:
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized symbol that resembles an abstract eagle or bird in flight, composed of three curved lines.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G Silver Spring, MD 20993-0002
December 12, 2013
Volcano Corporation % Ms. Elaine Alan Senior Regulatory Affairs Specialist 1 Fortune Drive BILLERICA MA 01821
Re: K132558
Trade/Device Name: Sync-Rx" System Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OWB Dated: September 13, 2013 Received: September 16, 2013
Dear Ms Alan:
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. 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.
If your device is classified (see above) into either 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 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
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Page 2 - Ms. Elaine Alan
. . . . ..
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/Industry/default.htm. 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/MedicalDevices/ResourcesforYou/Industrv/default.htm.
Sincerely yours,
Smh.P.
for
Janine M. Morris Director, Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): K132558
Device Name: Sync-Rx System
Indications for Use:
The Sync-Rx System is an image acquisition and processing system. It is indicated for use as follows:
- a) To provide quantitative information regarding the calculated dimensions of arterial segments.
- b) To enhance visualization of the stent deployment region.
- c) To be used in-procedure in the catheterization lab and off-line for post-procedural analysis.
- d) To obtain a co-registration of an angiographic x-ray image and IVUS images.
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-CONTINUEON ANOTHER PAGE IF NEEDED)
Concurrence of Center for Devices and Radiological Health (CDRH)
Sm.7)
(Division Sign-Off) Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health 510(k) _ K132558
Page I of
§ 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.