K Number
K150165
Device Name
GC85A
Date Cleared
2015-04-02

(66 days)

Product Code
Regulation Number
892.1680
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The GC85A Digital X-ray Imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.

Device Description

The GC85A digital X-ray imaging system consists of High voltage generator (HVG), Ceiling Suspension, X-ray tube, Collimator, Detector, AEC, DAP, CIB(Control Interface Box), Wall Stand, Patient Table, Collimator, Detector, Remote controller, Grid, Foot switch, Barcode scanner and Auto-stitching stand. This system is used to capture images by transmitting X-ray to a patient's body. The X-ray passing through a patient's body is sent to the detector and then converted into electrical signals. These signals go through the process of amplification and digital data conversion in the signal process device before being sent to the S-Station (Operation Software) and saved in DICOM file, a standard for medical imaging. The captured images are sent to the Picture Archiving & Communication System (PACS) server, and can be used for reading images.

AI/ML Overview

This is a 510(k) premarket notification for the Samsung Electronics Co., Ltd. GC85A Digital X-ray Imaging System. The submission aims to demonstrate substantial equivalence to a predicate device, the XGEO GC80 (K140334).

Here's an analysis of the provided information regarding acceptance criteria and the supporting study:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly present a formal "acceptance criteria" table with specific quantitative thresholds. Instead, the approach is to demonstrate substantial equivalence to the predicate device (XGEO GC80) by showing that the proposed device (GC85A) does not significantly differ in technical characteristics or performance in a way that would raise new questions of safety or effectiveness.

The document highlights differences and provides explanations for why these differences do not negatively impact safety or performance, and importantly, states that non-clinical and clinical data show equivalence.

Acceptance Criteria (Implied by Substantial Equivalence to Predicate)Reported Device PerformanceDiscussion (from document)
Image Quality (Non-clinical: MTF, DQE measurements) should be equivalent to or not inferior to the predicate device."The proposed detectors show curves and measurements of MTF and DQE that do not differ from the predicate device." (Page 8)"The proposed device shows no difference in non-clinical testing data such as MTF and DQE measurements from the predicate device." (Page 8)
Clinical Image Quality should be equivalent to the predicate device."Clinical images were obtained... They were evaluated by a professional radiologist and found to be equivalent to the predicate device." (Page 9)"These images were evaluated by a radiologist with equivalent U.S. board certification and found to be equivalent to the predicate device." (Page 9)
Safety (Electrical, mechanical, environmental) and EMC should meet relevant standards."Electrical, mechanical, environmental safety and performance testing according to standard ES 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, ISO14971, 21CFR1020.30 and 21CFR1020.31 were performed, and EMC testing was conducted in accordance with standard IEC 60601-1-2. Wireless function was tested and verified followed by guidance, Radio frequency Wireless Technology in Medical Devices. All test results were satisfying the standards." (Page 8)This demonstrates compliance with established safety and performance standards.

2. Sample Size Used for the Test Set and Data Provenance

  • Test Set (Clinical Data): The document states "clinical images were obtained" (Page 9) but does not specify the sample size (number of images or patients) used for the clinical evaluation.
  • Data Provenance: The document implies the data is prospective in the sense that the "proposed GC85A" was used to obtain the clinical images. The country of origin for the clinical data is not explicitly stated, but the manufacturer is based in the Republic of Korea.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

  • Number of Experts: One professional radiologist was used.
  • Qualifications: "a professional radiologist" and later specified as "a radiologist with equivalent U.S. board certification" (Page 9).

4. Adjudication Method for the Test Set

The document states that "They [clinical images] were evaluated by a professional radiologist" (Page 9). This indicates a single-reader evaluation. Therefore, there was no adjudication method (like 2+1 or 3+1 consensus) used for the clinical image evaluation described.

5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done

No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not done. The clinical evaluation involved a single radiologist assessing images from the proposed device against the predicate. This is not an MRMC study comparing human readers with and without AI assistance, as the device itself is an X-ray imaging system, not an AI-powered diagnostic tool. The document focuses on demonstrating that the system produces images equivalent to a predicate.

6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done

This question is not applicable in the context of this device. The GC85A is a digital X-ray imaging system, which means it produces images. Its performance is evaluated on the quality of these images and their equivalence to images from a predicate device, rather than the diagnostic output of an algorithm. Evaluation of "standalone" performance for such a device would pertain to its image acquisition and processing capabilities, which are covered by the MTF and DQE measurements (non-clinical data).

7. The Type of Ground Truth Used

For the clinical evaluation, the "ground truth" was established by expert consensus/opinion (though in this case, a single expert's opinion) comparing the general image quality of the proposed device's images to the predicate device's images. The radiologist "found [the images] to be equivalent to the predicate device."

For the non-clinical data, the ground truth or reference points were standardized measurements (MTF and DQE) as defined by IEC 62220-1.

8. The Sample Size for the Training Set

The document does not mention a training set sample size. This is because the device described is an X-ray imaging system, not an AI/machine learning device that typically requires a large training set for algorithm development. The development process would involve engineering design and physical testing rather than algorithmic training on vast datasets.

9. How the Ground Truth for the Training Set Was Established

As no training set is described for this type of device, this question is not applicable.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and 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

April 2, 2015

Samsung Electronics Co., Ltd. % Chulsin Kim Regulatory Affairs Manager 129, Samsung-ro, Yeongtong-gu Suwon-si, Gyeonggi-do 443-742 REPUBLIC OF KOREA

Re: K150165

Trade/Device Name: GC85A Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: KPR Dated: January 23, 2015 Received: January 26, 2015

Dear Chulsin Kim:

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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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,

Robert A Ochs

Robert Ochs. Ph.D. Acting Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K150165

Device Name GC85A

Indications for Use (Describe)

The GC85A Digital X-ray Imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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Image /page/3/Picture/1 description: The image shows the Samsung logo. The logo consists of the word "SAMSUNG" in white, bold, sans-serif font. The word is set against a blue, oval-shaped background that is tilted slightly. The logo is simple and modern, and it is easily recognizable.

510(k) Premarket Notification - Traditional

Section 5: 510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted accordance with requirements of 21 CFR 807.92

    1. Date: January 23, 2015
    1. Submitter
    • Company Name: SAMSUNG ELECTRONICS Co., Ltd. A.
    • B. Address: 129, Samsung-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do, 443-742, Republic of Korea

3. Primary Contact Person

  • A. Name: KIM, CHULSIN
  • B. Title: Regulatory Affairs Manager
  • C. Phone Number: +82-31-200-7661
  • FAX Number: +82-31-200-1199 D. E-Mail: chulsin.kim@samsung.com

4. Secondary Contact Person

  • Name: Ninad Gujar A.
  • B. Title: Regulatory Affairs Manager
  • C. Phone Number: 978-564-8503
  • D. FAX Number: 978-750-6677 E-Mail: ngujar@samsungneurologica.com

5. Proposed Device

  • A. Trade Name: GC85A
  • B. Device Name: GC85A
  • C. Common Name: Digital Diagnostic X-ray System
  • Classification Name: System, X-ray, Stationary D.
  • Product Code: KPR ட்.
  • F. Regulation: 21 CFR 892.1680

6. Predicate Device

  • A. Manufacturer: SAMSUNG ELECTRONICS Co., Ltd.
  • B. Trade Name: XGEO GC80
  • C. Classification Name: System, X-ray, Stationary
  • D. Product Code: KPR
  • E. 510(k) Number: K140334
  • 510(k) Decision Date: May 28, 2014 F.

7. Device Description

The GC85A digital X-ray imaging system consists of High voltage generator (HVG), Ceiling

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Image /page/4/Picture/1 description: The image shows the Samsung logo. The word "SAMSUNG" is written in white, bold, sans-serif font. The text is set against a blue, rounded, rectangular background.

510(k) Premarket Notification - Traditional

Suspension, X-ray tube, Collimator, Detector, AEC, DAP, CIB(Control Interface Box), Wall Stand, Patient Table, Collimator, Detector, Remote controller, Grid, Foot switch, Barcode scanner and Auto-stitching stand.

This system is used to capture images by transmitting X-ray to a patient's body.

The X-ray passing through a patient's body is sent to the detector and then converted into electrical signals. These signals go through the process of amplification and digital data conversion in the signal process device before being sent to the S-Station (Operation Software) and saved in DICOM file, a standard for medical imaging. The captured images are sent to the Picture Archiving & Communication System (PACS) server, and can be used for reading images.

8. Intended Use

The GC85A Digital X-ray Imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.

9. Summary of Technological characteristic of the proposed device compared with the predicate device

The proposed GC85A adds new detectors and modify wall stand to the predicate device, and it does not have significant change in materials, energy source or technological characteristics compared to the predicate device, XGEO GC80 (K140334). Comparisons of the following technological characteristics were assessed and the results demonstrate the substantial equivalence to the predicates.

SpecificationPredicate DeviceProposed DeviceDiscussion
Device NameXGEO GC80GC85A
ManufacturerSAMSUNG ELECTRONICSSAMSUNG ELECTRONICS
510(k) NumberK140334N/A
AppearancesSame
Intended UseThe XGEO GC80 digital X-rayThe GC85A digital X-raySame
imaging system is intended forimaging system is intended for
use in generating radiographicuse in generating radiographic
images of human anatomy by aimages of human anatomy by
qualified/trained doctor ora qualified/trained doctor or
technician. This device is nottechnician. This device is not
intended for mammographicintended for mammographic
applications.applications.
Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
---------------------------------------------------------------

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Image /page/5/Picture/1 description: The image features the SAMSUNG logo. The logo is displayed in white text against a blue background. The text is bold and slightly angled.

510(k) Premarket Notification - Traditional

Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
(1)High Voltage Generator
TypeHigh FrequencyHigh FrequencySame
Max. Power80kW82kWDifference(1)
OutputRANGETube Voltage40-150kV40-150kVSame
Tube Current10-1000mA10-1000mASame
ExposureTime1msec-6.3sec1msec-10secDifference(2)
AEC(Automatic Exposure Control)YesYes
APR (AnatomicallyProgrammed Radiography)YesYesSame
Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
(2)Ceiling Suspension
MovingRange(mm)Longitudinal1680~4180(Varies with room size)1680~4180(Varies with roomsize)Same
Lateral1030~3030(Varies with room size)1030~3030(Varies with roomsize)Same
Vertical18401800Difference(3)
Vertical Tube Moving methodMotorizedMotorizedSame
Tube Assembly Rotation-157 ~ +183-157 ~ +183Same
Brake locking MethodElectromagneticElectromagneticSame
Automatic CenteringOOSame
Moving Rail TypeAl ExtrusionAl ExtrusionSame
Image PreviewOOSame
Display TypeColor LCDColor LCDSame
Control Switch TypeButton+ Touch ScreenButton+ Touch ScreenSame
With TableOOSame
Vertical Sync.With StandOOSame
Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
(3) Wall Stand
VerticalMovementMechanismMotorized/ManualMotorizedDifference(4)
Range(mm)400~1800280~1850Difference(5)
Detector/tube servo couplingYesYesSame
DetectorTiltingMechanismMotorizedMotorizedSame

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Image /page/6/Picture/1 description: The image shows the SAMSUNG logo in white text on a blue background. The logo is stylized with a slightly italicized font. The blue background is in the shape of an oval.

510(k) Premarket Notification - Traditional

Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
Range-20~+90-20~+90Same
AECConventionalConventionalSame
GridLines/cm84.685/92Difference(6)
Grid mechanismStationaryStationarySame
RemovabilityRemovableRemovableSame
Detector Support MountingFloorFloorSame
Patient Support DevicePatient handgrips, lateral support barPatient handgrips, lateral support barSame
Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
(4)Patient Table
Table TopSize(mm)2410 X 8122410 X 812Same
RangLateral±140±140Same
e(mm)Longitudinal+480+480Same
Table heightMechanismDC Motor, Ball screwDC Motor, Ball screwSame
Range(mm)545 ~ 900545 ~ 900Same
Horizontal range of detector(mm)590688Difference(7)
AECConventionalConventionalSame
GridLines/cm84.685/92Difference(8)
Grid mechanismStationaryStationarySame
RemovabilityRemovableRemovableSame
Vertical Sync.OOSame
Control Switch TypeFoot switchFoot switchSame
Maximum Patient Weight(kg)350(Static, Center load)350(Static, Center load)Same
Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
(5)Collimator
Overall Size(mm)H212 X W300X D179H212 X W300X D179Same
Beam Limiting BladeMoving MethodMotorized/ManualMotorized/ManualSame
Manual Operation MethodVolumeVolumeSame
Collimator Rotation±45±45Same
Beam Light SourceLEDLEDSame
Light Field Indicator TimerOOSame
Side LampOOSame

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Image /page/7/Picture/1 description: The image shows the word "SAMSUNG" in white letters against a blue background. The font is bold and sans-serif. The logo is simple and recognizable, and the blue color is a signature of the brand.

510(k) Premarket Notification - Traditional

Manufacturer ContentsXGEO GC80 (K140334)GC85ADiscussion
Laser ModuleLaser ModuleSame
Field Size / SID DisplayColor LCDColor LCDSame
ManufacturerContentsXGEO GC80 (K140334)GC85ADiscussion
(6) Detector*NOTE: S4335-W, S4343-W were cleared with K140334.
NameS4335-WS4343-WS4335-WS4343-WS3025-W
Detector TypeCsICsICsICsICsISame
IndirectIndirectIndirectIndirectIndirectSame
Detector Area14"X17"(345mmX425mm)17"X17"(425mmX425mm)14"X17"(345mmX425mm)17"X17"(425mmX425mm)10"X12"(245mmX295mm)Difference(9)
Number of pixels2466X30403036X30402466X30403036X30401750X2108
Pixel Pitch(um)140140140140140
High ContrastLimitingResolution(LP/mm)3.573.573.573.573.57Difference(10)
CommunicationWired /WirelessWired /WirelessWired /WirelessWired /WirelessWired /WirelessSame
NoDifferencesExplanation
(1)HVG Max PowerProposed medical device's HVG has higher max power than the predicate device's max power, and the higher max power does not contribute any adverse impacts to the device's safety and performance.
(2)HVG Exposure Time RangeProposed medical device's HVG maximum exposure time longer than the predicate device's one, and the longer exposure time does not contribute any adverse impacts to the device's safety and performance.
(3)Vertical moving range of Ceiling SuspensionProposed medical device's Vertical moving range of Ceiling Suspension has shorter than the predicate device's moving range, but the shorter moving range does not contribute any adverse impacts to the device's safety and performance.
(4)Vertical Movement Mechanism of Wall StandProposed medical device's Vertical Movement Mechanism of Wall Stand has a motorized method, while the predicate device's Vertical Movement Mechanism of Wall Stand has two methods as manual & motorized. The movement mechanism does not contribute any adverse impacts to the device's safety and performance.
(5)Vertical Moving range ofProposed medical device's Vertical Moving range of Wall Stand has

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Image /page/8/Picture/1 description: The image shows the Samsung logo. The logo consists of the word "SAMSUNG" in white, set against a blue, rounded rectangular background. The font is sans-serif and bold, giving the logo a clean and modern appearance. The blue background provides a strong contrast, making the white text stand out.

510(k) Premarket Notification - Traditional

Wall Standlonger than the predicate device's one, and the longer moving rangedoes not contribute any adverse impacts to the device's safety andperformance.
(6)Grid line ( Wall stand )Proposed medical device's Line Pair of Grid installed in Wall Standhas higher than the predicate device's one, and the higher line pair ofgrid does not contribute any adverse impacts to the device's safetyand performance.
(7)Horizontal range ofdetector (Patient Table)Proposed medical device's Horizontal Moving range of Detectorinstalled Patient Table has longer than the predicate device's one,and the longer moving range does not contribute any adverse impactsto the device's safety and performance.
(8)Grid line (Patient Table)Proposed medical device's Line Pair of Grid installed in Patient Tablehas higher than the predicate device's one, and the higher line pair ofgrid does not contribute any adverse impacts to the device's safetyand performance.
(9)Detector AreaProposed medical device's S3025-W detector has smaller area thanthe predicate device's detectors while technical specification isidentical among them such as type & pixel pitch, and the smaller areadoes not contribute any adverse impacts to the device's safety andperformance.
(10)Number of pixelsResolution and pixel pitchof detectorProposed medical device's S3025-W detector has smaller detectorarea. Therefore, the proposed medical device's numbers of pixels issmaller than the predicate device's detectors while pixel pitch isidentical among them, and the smaller number of pixels does notcontribute any adverse impacts to the device's safety andperformance.

In non-clinical data, the proposed detectors show curves and measurements of MTF and DQE that do not differ from the predicate device. In clinical data, the proposed GC85A has been shown a substantially equivalent to the predicate device.

10. Safety, EMC and Performance Data

Electrical, mechanical, environmental safety and performance testing according to standard ES 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, ISO14971, 21CFR1020.30 and 21CFR1020.31 were performed, and EMC testing was conducted in accordance with standard IEC 60601-1-2. Wireless function was tested and verified followed by guidance, Radio frequency Wireless Technology in Medical Devices. All test results were satisfying the standards.

11. Non-clinical data

Non-clinical testing data was provided in conformance to the FDA "Guidance for the Submission of 510(k)'s for Solid-State X-ray Imaging Devices", which includes MTF and DQE measurements as tested by IEC 62220-1. The proposed device shows no difference in non-clinical testing data such as MTF and DQE measurements from the predicate device.

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Image /page/9/Picture/1 description: The image shows the Samsung logo. The logo consists of the word "SAMSUNG" in white, sans-serif font, set against a blue, elliptical background. The ellipse is tilted slightly, giving the logo a dynamic appearance.

510(k) Premarket Notification - Traditional

12. Clinical data

In clinical data, clinical images were obtained in accordance with FDA guidance for the submission of 510(k)'s for Solid State X-ray Imaging Devices. They were evaluated by a professional radiologist and found to be equivalent to the predicate device.

13. Conclusions

Clinical images were provided; these images were not necessary to establish substantial equivalence based on the modifications to the device but they provide further evidence in addition to the laboratory performance data to show that the complete system works as intended. These images were evaluated by a radiologist with equivalent U.S. board certification and found to be equivalent to the predicate device.

    1. Samsung Electronics Co., Ltd. will update and include in this summary any other information deemed seasonably necessary by the FDA

§ 892.1680 Stationary x-ray system.

(a)
Identification. A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. 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). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary 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.