K Number
K160065
Date Cleared
2016-05-20

(128 days)

Product Code
Regulation Number
892.1650
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

KMC-650 Surgical Mobile Fluoroscopic X-ray System is indicated for use in generating fluoroscopic / radioscopic images of human anatomy. This device is not intended for interventional guided procedure & mammographic applications.

Device Description

The KMC-650 Surgical Mobile Fluoroscopic X-rav System consists of a high voltage (HV) inverter generator. a tube support unit, an X-ray beam limiting device, mobile cart, a detector, operating software, and a tube, and is primarily used in a hospital for diagnosis of diseases in skeletal, respiratory and urinary systems such as the skull, spinal column, chest, abdomen, extremities, and other body parts. Not to be used for mammography.

KMC-650 is a solution to produce radiological images of patient during medical operations. This inverter control X-ray unit visualizes the anatomical structure on screen, which is obtained by X-ray fluoroscopy and the image intensifier. This system can be applied in emergency room, operation room, cast room or etc. of hospital.

AI/ML Overview

This document is a 510(k) Summary for a medical device called the KMC-650 Surgical Mobile Fluoroscopic X-ray System. It asserts substantial equivalence to a predicate device (KMC-950) rather than providing a performance study against specific acceptance criteria for a novel device. Therefore, many of the requested elements for a detailed AI/model performance description are not applicable or cannot be extracted directly from this document.

However, I can extract information related to the device's technical specifications and safety/effectiveness concerns addressed to establish substantial equivalence.

Here's an attempt to answer your questions based on the provided text, noting where the information is not present or relevant to this type of submission:

  1. A table of acceptance criteria and the reported device performance

    This document does not present "acceptance criteria" in the typical sense of a novel device's performance targets (e.g., sensitivity, specificity for a diagnostic algorithm) and then report performance against those. Instead, it argues for "substantial equivalence" to a predicate device (KMC-950). The performance characteristics are compared to the predicate device.

    CharacteristicPredicate Device (KMC-950)Proposed Device (KMC-650)Acceptance Criteria (Implicit for Substantial Equivalence)Reported Performance (KMC-650)
    X-ray TubeVarian (RAD-99)Toshiba (DF-151SBR)Functionally equivalent; safe and effectiveDifferent manufacturer and model, but no new safety/effectiveness concerns raised.
    Anode TypeRotatingStationaryFunctionally equivalent; safe and effectiveStationary
    Heat Capacity300,000 HU45,000 HUSufficient for intended use (1 kW or less fluoro)45,000 HU. Stated as sufficient as typical fluoroscopy mode requires 1 kW or less.
    Anode Heat Cooling70 kHU/min47 kHU/minSufficient for intended use47 kHU/min
    Focal Size0.3mm / 0.6mm0.5mm / 1.5mmAppropriately sized for imaging0.5mm / 1.5mm
    X-ray GeneratorPOSKOM (HTC-120)POSKOM (C-650)Functionally equivalent; safe and effectiveDifferent model, but high frequency/inverter type for both.
    Power Output12.5 kW2.2 kWSufficient for intended use (1 kW or less fluoro)2.2 kW. Stated as sufficient as typical fluoroscopy mode requires 1 kW or less.
    Fluoro kV range40 to 125 kV40 to 110 kVWithin clinically acceptable range40 to 110 kV
    Fluoro mA range0.5 to 5 mA0.5 to 4 mAWithin clinically acceptable range0.5 to 4 mA
    Pulse FluoroYesYesPresentYes
    ABS functionYesYesPresentYes
    Snap Shot8.0 mA shot available8.0 mA shot availablePresent8.0 mA shot available
    Boost Shot20.0 mA shot available20.0 mA shot availablePresent20.0 mA shot available
    Image Intensifier Size9"9"Same size9"
    Magnification9" / 6" / 4.5"9" / 6" / 4.5"Same options9" / 6" / 4.5"
    Camera Type1/2" CCD1/2" CCDCCDCCD
    Active pixels512 x 5121,024 x 1,024Equivalent or improved (higher resolution shown)1,024 x 1,024
    SID950mm1000mmWithin acceptable range1000mm
    Range of C-arm Rail Rotation115° (90° / 25°)135° (90° / 45°)Clinically acceptable135° (90° / 45°)
    Image Storage CapacityDigitalDigitalDigital storageDigital
    Image Matrix Size5,000 images5,000 imagesAdequate storage5,000 images
    Monitor Size17"19"Adequate for display (larger shown)19"

    Note: The "acceptance criteria" here are implicitly that the proposed device is either equivalent to the predicate or that any differences do not raise new questions of safety or effectiveness. The device "performance" is the technical specification of the KMC-650.

  2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This document describes a 510(k) submission for a fluoroscopic X-ray system, which is hardware. It does not mention any "test set" in the context of evaluation of an AI or algorithm. The "studies" referenced are non-clinical engineering and compliance tests.

  3. 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)

    Not applicable. This is not an AI/algorithm submission that requires expert-established ground truth for a test set.

  4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable.

  5. 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

    Not applicable. This device is an X-ray system, not an AI-assisted diagnostic tool.

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

    Not applicable.

  7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    Not applicable. The ground truth for this device's performance validation would be based on physical measurements of radiation output, image quality metrics (resolution, contrast, noise), electrical safety, EMC compliance, etc., according to recognized standards.

  8. The sample size for the training set

    Not applicable. There is no training set for this hardware device.

  9. How the ground truth for the training set was established

    Not applicable.

Summary of Device Safety and Effectiveness from the Document:

The document primarily focuses on establishing Substantial Equivalence between the KMC-650 and its predicate device, KMC-950. The safety and effectiveness of the KMC-650 are asserted through:

  • Comparison of technological characteristics: A detailed table comparing specifications like X-ray tube, generator, fluoroscopic modes, image intensifier, camera, and C-arm mechanics. Differences (e.g., tube's heat capacity, power output, kV/mA ranges, camera active pixels) are addressed by explaining that the proposed device's lower specifications are still sufficient for typical fluoroscopy modes (e.g., 1 kW or less) or that higher specifications (e.g., camera resolution) represent an improvement.
  • Compliance with recognized standards: The device adheres to a robust set of international and FDA recognized standards, including:
    • IEC 60601-1:2005 (General requirements for basic safety and essential performance)
    • IEC 60601-1-2:2007 (Electromagnetic compatibility)
    • IEC 60601-1-3:2008 (Radiation protection in diagnostic X-ray equipment)
    • IEC 60601-2-28:2010 (Medical diagnostic X-ray equipment for radiography and radioscopy)
    • IEC 60601-2-43:2010 (X-ray equipment for interventional procedures)
    • IEC 60601-2-54:2009 (X-ray equipment for radiography and radioscopy)
    • NEMA PS 3.1-3.20 (DICOM standard)
    • ISO 14971:2012 (Application of risk management for medical devices)
    • 21 CFR 1020.32 (Electronic product radiation control)
  • Verification and Validation Activities: Stated that "Engineering testing and standards compliance testing were successfully conducted and did not raise any new safety questions or concerns or identify new risks."
  • Instructions for Use: Labeling includes information for safe and effective operation.

The conclusion is that despite some differences in components and specifications, these differences "do not raise any new questions of safety and effectiveness."

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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 symbol 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

May 20, 2016

GEMSS MEDICAL SYSTEMS CO., LTD % Mr. Dave Kim Medical Device Regulatory Affairs Mtech Group 8310 Buffalo Speedway HOUSTON TX 77025

Re: K160065

Trade/Device Name: KMC-650 GEMSS Medical System Surgical Mobile Fluoroscopic X-ray System Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OXO, JAA Dated: April 13, 2016 Received: April 18, 2016

Dear Mr. 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

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forth in the quality systems (OS) 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 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.'Hara

For

Robert Ochs, Ph.D. 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) K160065

Device Name KMC-650 GEMSS Medical System Surgical Mobile Fluoroscopic X-ray System

Indications for Use (Describe)

KMC-650 Surgical Mobile Fluoroscopic X-ray System is indicated for use in generating fluoroscopic / radioscopic images of human anatomy. This device is not intended for interventional guided procedure & 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)

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SECTION 07

510(k) SUMMARY

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510(k) SUMMARY For KMC-650

Submitted by:

GEMSS MEDICAL SYSTEMS CO., LTD. Address - 2nd Floor, 29, Dunchon-daero 541 beon-gil, Jungwon-gu, Seongnam-si, Gyeonggi-do, Korea Telephone -- +82-31-764-7321~3 Fax - +82-31-764-7324 Contact - Mr. Sangwoo Lee Internet - http://www.gemss-medical.com

This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of SMDA 1990 and 21 CFR Part 807.92.

Date: April 12, 2016

  1. General Information:

Establishment: GEMSS MEDICAL SYSTEMS CO., LTD. 2nd Floor, 29, Dunchon-daero 541 beon-gil, Jungwon-gu, seongnam-si, KOREA, REPUBLIC OF 13216 Registration Number: 3003384390

GMESS MEDICAL SYSTEMS CO., LTD. is the holder/owner for this 510(k).

  1. Official Correspondent Contact:

Dave Kim Mtech Group 8310 Buffalo Speedway Houston, TX 77025 TEL : 713-467-2607

FAX : 713-583-8988

E-mail : davekim@mtech-inc.net

  1. Device name and Classification

Trade Name : KMC-650 Classification Name : Image-intensified Fluoroscopic Mobile X-ray System Classification Panel : Radiology Classification Regulation : 21 CFR 892. 1650

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Device Classification: Class II
Primary product code: OXO
Secondary product code: JAA
  1. Legally Marketed Predicated Device
Trade Name: KMC-950
510(k) Clearance #: K032761
Clearance date: 05/14/2004
Classification Name: Image Intensified Fluoroscopic Mobile X-ray System
Classification Panel: Radiology
CFR Section: 21CFR 892.1650
Device Class: Class II
Product Code: JAA, OWB, OXO

5. Device Description

The KMC-650 Surgical Mobile Fluoroscopic X-rav System consists of a high voltage (HV) inverter generator. a tube support unit, an X-ray beam limiting device, mobile cart, a detector, operating software, and a tube, and is primarily used in a hospital for diagnosis of diseases in skeletal, respiratory and urinary systems such as the skull, spinal column, chest, abdomen, extremities, and other body parts. Not to be used for mammography.

KMC-650 is a solution to produce radiological images of patient during medical operations. This inverter control X-ray unit visualizes the anatomical structure on screen, which is obtained by X-ray fluoroscopy and the image intensifier. This system can be applied in emergency room, operation room, cast room or etc. of hospital.

6. Indications for Use

KMC-650 Surgical Mobile Fluoroscopic X-ray System is indicated for use in generating fluoroscopic / radioscopic images of human anatomy. This device is not interventional guided procedure & mammographic applications

7. Substantial Equivalence

KMC-650 is substantially equivalent to the commercially available KMC-950 of GEMSS Medical System (K032761). The detailed SE discussion is provided in SECTION 12.

Predicate deviceProposed device
Model NameKMC-950KMC-650
510(k) NumberK032761
ManufacturerGEMSS Medical System Co., LtdGEMSS Medical System Co., Ltd
X-ray tubeManufacturerVarian (RAD-99)Toshiba (DF-151SBR)
Anode TypeRotatingStationary
Heat Capacity300,000 HU45,000 HU
Anode Heat Cooling70kHU/min47kHU/min
Focal size0.3mm / 0.6mm0.5mm/1.5mm
X-rayManufacturerPOSKOM (HTC-120)POSKOM (C-650)
generatorX-ray Generator TypeHigh frequency / inverter typeHigh frequency / inverter type

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Power Output12.5 kW2.2 kW
FluoroscopickV range40 to 125 kV See belowdiscussion for differences40 to 110 kV See belowdiscussion for differences
ModemA range0.5 to 5 mA. See belowdiscussion for differences0.5 to 4 mA. See belowdiscussion for differences
Pulse FluoroYesYes
ABS functionYesYes
Snap Shot8.0 mA shot available8.0 mA shot available
Boost Shot20.0 mA shot available20.0 mA shot available
ImageManufacturerThales / ToshibaThales / Toshiba
IntensifierSize9"9"
Magnification9" / 6" / 4.5"9" / 6" / 4.5"
CameraManufacturerRAYSISGEMSS
Type1/2" CCD1/2" CCD
Active pixels512 x 5121,024 x 1,024
C-armManufacturerGEMSS medical Systems Co.,LtdGEMSS medical Systems Co.,Ltd
SID950mm1000mm
Range of C-ram Rail115° (90° / 25°)135° (90° / 45°)
Rotation
Range of the LinerFR-arm Movement200 mm200 mm
Range of the LinearT-arm Movement500 mm500 mm
Range of Swing-armRotation$\pm$ 12.5°$\pm$ 12.5°
Range of Stay-armRotation360°360°
ImageStorage CapacityDigitalDigital
ProcessingImage Matrix Size5,000 images5,000 images
Monitor Size17"19"
CollimatorModel NameKMC-950CMKMC-650CMR
ManufacturerGEMSS medical Systems Co.,LtdGEMSS medical Systems Co.,Ltd
CollimatorMotor control / rotationMotor control / rotation
  1. Summary of technological characteristics of the device compared to the predicate device

※ Performance Differences in the Generator

ItemsKMC-950KMC-650
GeneratorMODELHTC-120C-650
Max Power12.5 kW2.2 kW
DeviceSpecificationskVFluoro : 40 - 125 kVFluoro : 40 - 110 kV
mAFluoro : 0.5~ 5 mAFluoro : 0.5 - 4 mA,

→ The generator capacity must be sufficient to meet the fluoroscopy and Radiography exposure requirements. The power requirement for a generator depends on the size, length and thickness of X-ray Tube (Anode) Filament. The generator's mA output also depends on the focal spot sizes.

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A typical fluoroscopy mode for KMC-950 and KMC-650 requires the power of 1 kW or less. Therefore, the generator outputs for KMC-650 and KMC-950 in fluoroscopy mode is not significantly different.

KMC-650/950 Firmware Comparison Table

ItemsKMC-650KMC-950Remarks
Camera Board650CAMB950CAMBCamera specifications are different.(activepixels)
Main Board650MCB950MCBGenerator Control, Key Input functionoperates differently.
OP Control Board650OPCB-A separate OP Board exists for KMC-650whereas KMC-950 has the main controlboard only without a separate OP board

KMC-650 is designed as a set of components (X-ray tube and housing, imaging intensifier, collimator, generator). KMC-650 and components conform to the FDA recognized standards. Based on the recognized standard conformity evidences related to electro-, mechanical-, software-, clinical-, and risk management, it is confirmed that the all technological characteristics of KMC-650 is substantially equivalent to the predicate device.

9. General Safety and Effectiveness Concern

To minimize electrical, mechanical, and radiation hazards, GEMSS MEDICAL SYSTEMS CO., LTD. adheres to recognized and established industry practice, and all equipment complies with the relevant FDA and international standards.

Through verification and validation activities, the safety and effectiveness of KMC-650 is verified and validated. Engineering testing and standards compliance testing were successfully conducted and did not raise any new safety questions or concerns or identify new risks. And instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner.

Electrical, EMC, mechanical safety and performance testing according to FDA recognized standards were performed. All test results were satisfactory. Applied standards are as follows:

  • IEC60601-1:2005

  • A IEC60601-1-2:2007
  • A IEC60601-1-3:2008
  • A IEC60601-2-28:2010
  • A IEC60601-2-43:2010
  • A IEC60601-2-54:2009
  • A NEMA PS 3.1-3.20
  • A ISO14971:2012

And, EPRC regulation was satisfactory.

  • 21CFR1020.32 A
    In addition, FDA quidance were satisfactorily considered.

  • Guidance for the Submissions of 510(k)s for Solid State X-ray Imaging Devices

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Based on the robust set of results from the non-clinical and clinical studies that have been performed, KMC-650 has been found to be substantially equivalent to the predicate device as well as found to be a safe and effective surgical mobile fluoroscopic X-ray imaging system.

10. Conclusion as to Substantial Equivalence

KMC-650 is substantially equivalent to the predicate device KMC-950 (K032761). These devices are very similar in the intended use, the design principle, the performance and the applicable standards. Some characteristics, for example, their appearance, the user interfaces are different. However the compliance reports, demonstrations and descriptions in this submission STED provide demonstration that these small and minor differences do not raise any new questions of safety and effectiveness. So GEMSS MEDICAL SYSTEMS CO., LTD. concludes KMC-650 is substantially equivalent to the predicate device KMC-950 (K0327618).

§ 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.