K Number
K141669
Device Name
SURGIMAP
Manufacturer
Date Cleared
2014-09-19

(88 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Surgimap software assists healthcare professionals in viewing, and measuring images as well as planning orthopedic surgeries. The device allows service providers to perform generic as well as specialty measurements of the images, and to plan surgical procedures. The device also includes tools for measuring anatomical components for placement of surgical implants, and offer online synchronization of the database with the possibility to share data among Surgimap users. Clinical judgment and experience are required to properly use the software.
Device Description
Surgimap is software developed for the medical community. It is intended to be used to view, store and transport images as well as perform generic or specialty measurements and plan or simulate aspects of surgical procedures. The image formats supported encompasses the standard image formats (jpeg, tiff, png, ....) and also DICOM images. Images can be stored in the Surgimap database and measurements (generic or specialty specific) can be overlaid to each image. Surgimap also offers the ability for the end user to plan, or simulate, aspects of certain surgical procedures such as osteotomies and templating implants (including but not limited to screws, interbody cages, rods). Via internet connection during use of the software application, the database can be synchronized online. An optional feature consists in organizing patient information into cases with the possibility to share these cases among Surgimap users.
More Information

Not Found

No
The summary describes standard image viewing, measurement, and surgical planning tools without mentioning any AI or ML capabilities. The "Mentions AI, DNN, or ML" section explicitly states "Not Found".

No.
The device is for image viewing, measurement, and surgical planning, not for directly treating a disease or condition.

No

The device assists in viewing, measuring, and planning orthopedic surgeries, and it does not make a diagnosis.

Yes

The device description explicitly states "Surgimap is software developed for the medical community" and describes its functions as software-based operations on images and data. There is no mention of accompanying hardware components that are part of the device itself.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health. They are used outside the body.
  • Surgimap's Function: Surgimap is software that works with medical images (like X-rays, CT scans, etc.) to assist healthcare professionals in viewing, measuring, and planning orthopedic surgeries. It operates on images of the body, not on specimens taken from the body.
  • Intended Use: The intended use clearly states it assists in "viewing, and measuring images as well as planning orthopedic surgeries." This is a diagnostic and planning tool based on imaging, not an in vitro test.

Therefore, Surgimap falls under the category of medical imaging software or surgical planning software, not In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The Surgimap software assists healthcare professionals in viewing, and measuring images as well as planning orthopedic surgeries. The device allows service providers to perform generic as well as specialty measurements of the images, and to plan surgical procedures. The device also includes tools for measuring anatomical components for placement of surgical implants, and offer online synchronization of the database with the possibility to share data among Surgimap users. Clinical judgment and experience are required to properly use the software.

Product codes

LLZ

Device Description

Surgimap is software developed for the medical community. It is intended to be used to view, store and transport images as well as perform generic or specialty measurements and plan or simulate aspects of surgical procedures. The image formats supported encompasses the standard image formats (jpeg, tiff, png, ....) and also DICOM images. Images can be stored in the Surgimap database and measurements (generic or specialty specific) can be overlaid to each image. Surgimap also offers the ability for the end user to plan, or simulate, aspects of certain surgical procedures such as osteotomies and templating implants (including but not limited to screws, interbody cages, rods). Via internet connection during use of the software application, the database can be synchronized online. An optional feature consists in organizing patient information into cases with the possibility to share these cases among Surgimap users.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Local + PACS connectivity

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

healthcare professionals

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)

Performance data for Surgimap 2.0 consisted in verification activities.

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

Not Found

Predicate Device(s)

K111019, K073714

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).

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Image /page/0/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" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

September 19, 2014

Nemaris, Inc. % Mr. Keith Barritt Attorney Fish and Richardson P.C. 1425 K Street NW WASHINGTON DC 20005

Re: K141669

Trade/Device Name: Surgimap 2.0 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: August 13, 2014 Received: August 14, 2014

Dear Mr. Barritt:

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.

1

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

http://www.fda.gov/MedicalDevices/Resourcesfor You/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 Industry and Consumer Education 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.

Michael D. O'Hara
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) K141669

Device Name Surgimap

Indications for Use (Describe)

The Surgimap software assists healthcare professionals in viewing, and measuring images as well as planning orthopedic surgeries. The device allows service providers to perform generic as well as specialty measurements of the images, and to plan surgical procedures. The device also includes tools for measuring anatomical components for placement of surgical implants, and offer online synchronization of the database with the possibility to share data among Surgimap users. Clinical judgment and experience are required to properly use the software.

Type of Use (Select one or both, as applicable)

2 Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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510(k) Summary of Safety and Effectiveness Nemaris Inc. Surgimap

The following information is provided pursuant to 21 CFR 807.92

807.92(a)(1)

(i) Submitter

Nemaris Inc 306 East 15th Street | Suite 1R New York, NY 10003 Phone: (646)-794-8650 Fax: (646)-602-6925

(ii) Submitter Contact

Virginie Lafage, PhD Vice President and Chief Technology Officer Nemaris Inc 306 East 15th Street | Suite 1R New York, NY 10003 Phone: (646)-794-8650 Email: vlafage(@surgimap.com

(iii) Preparation Date May 05, 2014

807.92(a)(2)

Trade Name:Surgimap
Common Name:Picture Archiving and Communication System (PACS)
Section:892.2050
ClassII
Product Code:LLZ

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807.92(a)(3)

Surgimap Spine
Manufacturer:Nemaris Inc
Tradename:Surgimap Spine
510K #:K111019 (September 30, 2011)
Common NamePicture Archiving and Communication System (PACS)
Class:II
Product Code:LLZ
Traumacad
Manufacturer:Voyant Health formerly known as Orthocrat
Tradename:TraumaCad Release 2.0
510K #:K073714 (March 19, 2008)
Common NamePicture Archiving and Communication System (PACS)
Class:II
Product Code:LLZ

807.92(a)(4)

Surgimap is software developed for the medical community. It is intended to be used to view, store and transport images as well as perform generic or specialty measurements and plan or simulate aspects of surgical procedures. The image formats supported encompasses the standard image formats (jpeg, tiff, png, ....) and also DICOM images. Images can be stored in the Surgimap database and measurements (generic or specialty specific) can be overlaid to each image. Surgimap also offers the ability for the end user to plan, or simulate, aspects of certain surgical procedures such as osteotomies and templating implants (including but not limited to screws, interbody cages, rods). Via internet connection during use of the software application, the database can be synchronized online. An optional feature consists in organizing patient information into cases with the possibility to share these cases among Surgimap users.

807.92(a)(5)

The Surgimap software assists healthcare professionals in viewing, storing, and measuring images as well as planning orthopedic surgeries. The device allows service providers to perform generic as well as specialty measurements of the images, and to plan surgical procedures. The device also includes tools for measuring anatomical components for placement of surgical implants, and offer online synchronization of the database with the possibility to share data among Surgimap users. Clinical judgment and experience are required to properly use the software.

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The Indications for Use statement for Surgimap 2.0 device is not identical to the predicate devices; however, the differences do not affect the safety and effectiveness of the device relative to the predicates. The subject and predicate devices have the same intended use for local images, and in both cases, the mitigation of hazard analysis demonstrates an acceptable level of residual risks.

807.92(a)(6)

The tabulated comparison of technological characteristics between Surgimap Spine and its predicated devices is outlined in the table hereafter:

FeatureTraumaCad 2.0Surgimap SpineSurgimap 2.0
ComputerPC CompatiblePC CompatiblePC Compatible
Operating SystemWindowsWindowsWindows + MAC
Image InputLocal + PACS
connectivityLocalLocal + PACS
connectivity
Scout featureYesNoYes
Runs on ServerYesnono
Trauma ModuleYesNoNo
Osteotomy ModuleYesYesYes
Generic MeasurementsYesYesYes
Spine measurementsYesYesYes
Lower Limbs measurementsYesNoYes
Pre-operative planningYesYesYes
Templating (custom implant)YesYesYes
Templating (vendor specific
implant)YesNoYes
DatabaseYesYesYes
Online synchronization of
databaseYesNoYes
Case SharingYesNoYes
Control of life-saving devicesNoneNoneNone
Human Intervention for
interpretation and
manipulation of imagesRequiredRequiredRequired
Ability to add additional
Modules when availableYesYesYes
Web ContentYesYesYes

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807.92(b)

Performance data for Surgimap 2.0 consisted in verification activities. The following guidelines and standards were used throughout the software development process:

| EN ISO 14971:2012 | Medical Devices - Application of risk management to
medical devices |
|-----------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 62304:2006 | Medical device software - Software life cycle processes |
| ANSI/IEEE Standard 829-2008 | IEEE Standard for Software and System Test Documentation |
| FDA Guidance | Guidance for Industry and FDA Staff - Guidance for the
content of premarket submissions for software contained in
medical devices (May 11, 2005) |

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered to be at a "Moderate" level of concern, since a latent design flaw might lead the user to inadequately plan a surgery and thus indirectly injure patients.