(327 days)
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No
The document describes a standard PACS system for image archiving, viewing, and reporting, with no mention of AI or ML capabilities.
No.
The device is a PACS software product used for archiving and viewing medical images, and generating reports. Its intended use is as a primary diagnostic and analysis tool for diagnostic images, not for treatment or therapy.
Yes
The "Intended Use / Indications for Use" section explicitly states that "LifeSys™ PACS software is intended for use as a primary diagnostic and analysis tool for diagnostic images."
Yes
The device is explicitly described as a "PACS software product" and a "single piece of software" with functional modules. The description focuses solely on software functionalities like archiving, reporting, viewing, and integration, without mentioning any associated hardware components that are part of the medical device itself.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use clearly states that LifeSys™ PACS is a software product used to receive, archive, and display medical images (CT, MRI, etc.) and generate radiology reports. It is intended for use as a primary diagnostic and analysis tool for diagnostic images.
- Device Description: The description reinforces that it's a PACS software for archiving and reporting on patient imaging studies.
- Lack of In Vitro Activity: IVD devices are used to examine specimens (like blood, urine, tissue) outside of the body to provide information about a patient's health. LifeSys™ PACS deals with images generated from within the body.
The device is a medical image management and viewing system, which falls under a different regulatory category than IVD devices.
N/A
Intended Use / Indications for Use
LifeSys™ PACS is a Picture Archive and Communications software product used to receive pertinent radiology patient information and DICOM images and allow easy generation of a Radiology Report for distribution over a network.
LifeSys™ PACS software is intended for use as a primary diagnostic and analysis tool for diagnostic images. LifeSys™ PACS is for hospitals, imaging centers, radiology professional services providers and any user who requires and is granted access to patient image, demographic and report information.
The LifeSys™ PACS viewer displays images from CT, computed radiography, MRI, nuclear medicine, PET, ultrasound, x-ray angiography, and x-ray fluoroscopy.
Product codes (comma separated list FDA assigned to the subject device)
LLZ
Device Description
LifeSys™ PACS is a PACS software product that provides medical imaging departments of all types (Hospitals, Imaging Centers, and Clinics) with the capability to archive patient imaging studies and generate reports on said studies. LifeSys™ PACS is a single piece of software which includes the following functional modules: LifePACS™, which includes a Worklist, Tech Page, Image acquisition, receipt and archive, Report Editor, and tools for integration; and LifeView™, which includes a DICOM image viewer, rapid loading for fast and efficient reading and reporting and multiple monitor support.
Mentions image processing
System, Image Processing, Radiological
Mentions AI, DNN, or ML
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Input Imaging Modality
CT, computed radiography, MRI, nuclear medicine, PET, ultrasound, x-ray angiography, and x-ray fluoroscopy.
Anatomical Site
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Indicated Patient Age Range
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Intended User / Care Setting
hospitals, imaging centers, radiology professional services providers and any user who requires and is granted access to patient image, demographic and report information.
Description of the training set, sample size, data source, and annotation protocol
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Description of the test set, sample size, data source, and annotation protocol
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Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Thorough non-clinical system verification and validation testing was conducted in accordance with applicable international standards and internal design requirement to verify that LifeSys™ PACS software product meets user needs and indications for use. The Verification & Validation Test Plan was designed to evaluate all input functions, output functions, and actions performed in each operational mode. LifeSys™ PACS software passed all in-house testing criteria.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
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Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
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Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
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§ 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" arranged around the perimeter. Inside the circle is a stylized symbol that resembles a caduceus, which is a traditional symbol of medicine and healthcare. The symbol is composed of three abstract, curved lines that suggest the wings of a bird or the serpents of a caduceus.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 5, 2017
Lifetrack Medical Systems, Inc. % Mr. Keith Barritt Attorney Fish & Richardson 1425 K Street NW WASHINGTON DC 20005
Re: K161341
Trade/Device Name: Lifesys™ PACS Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: March 21, 2017 Received: March 22, 2017
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.
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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.
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) K161341
Device Name LifeSys™ PACS
Indications for Use (Describe)
LifeSys™ PACS is a Picture Archive and Communications software product used to receive pertinent radiology patient information and DICOM images and allow easy generation of a Radiology Report for distribution over a network.
LifeSys™ PACS software is intended for use as a primary diagnostic and analysis tool for diagnostic images. LifeSys™ PACS is for hospitals, imaging centers, radiology professional services providers and any user who requires and is granted access to patient image, demographic and report information.
The LifeSys™ PACS viewer displays images from CT, computed radiography, MRI, nuclear medicine, PET, ultrasound, x-ray angiography, and x-ray fluoroscopy.
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Section 5: 510(k) Summary
Date Prepared: February 21, 2017
Submitter: Lifetrack Medical Systems, Inc. 1007 One World Place, 32nd Street, BGC Taguig City, Metro Manila, 1634, Philippines
Contact Person: Eric Schulze, MD, PhD Chief Executive Officer O: +632 802 9980 F: +632 802 9980
Official Correspondent: Eric Schulze, MD, PhD Chief Executive Officer
O: +632 802 9980 F: +632 802 9980 eric.schulze@lifetrackmed.com
Trade Name: LifeSys™ PACS Classification Name: System, Image Processing, Radiological Picture, archive and communications system (PACS) Common Name: Product Code: LLZ
Predicate Device:
Device Classification Name: System, Image Processing, Radiological 510(k) Number: K120995 Device Name: eRAD PACS and eRAD RIS/PACS Original Applicant: eRAD, Inc., 9 Pilgrim Road, Greenville, SC 29607 Product Code: LLZ Decision Date:December 3, 2012 Decision: Substantial equivalent (SE) Type: Traditional
Device Description:
LifeSys™ PACS is a PACS software product that provides medical imaging departments of all types (Hospitals, Imaging Centers, and Clinics) with the capability to archive patient imaging studies and generate reports on said studies. LifeSys™ PACS is a single piece of software which includes the following functional modules: LifePACS™, which includes a Worklist, Tech Page, Image acquisition, receipt and archive, Report Editor, and tools for integration; and LifeView™, which includes a DICOM image viewer, rapid loading for fast and efficient reading and reporting and multiple monitor support.
Indications for Use:
LifeSys™ PACS is a Picture Archive and Communications software product used to receive pertinent radiology patient information and DICOM images and allow easy generation of a Radiology Report for distribution over a network.
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LifeSys™ PACS software is intended for use as a primary diagnostic and analysis tool for diagnostic images. LifeSys™ PACS is for hospitals, imaging centers, radiologists, radiology professional services providers and any user who requires and is granted access to patient image, demographic and report information.
The LifeSys™ PACS viewer displays images from CT, computed radiography, MRI, nuclear medicine. PET. ultrasound. x-rav angiography. and x-ray fluoroscopy.
Technological Characteristics:
LifeSys™ PACS is a device that does not contact the patient, nor does it control any life sustaining devices. A physician, providing ample opportunity for competent human intervention interprets images and information being displayed.
The LifeSys™ PACS device labeling contains instructions for use and any warnings or cautions to provide for the safe and effective use of the device. Users of the device are responsible to imonsure that display quality, environmental lighting and other possible distractions are consistent with a clinical environment. The hardware components specified are all "off the shelf" computer components.
It is our conclusion that there is no software or hardware component in the LifeSys™ PACS device whose failure or latent design flaw would be expected to result in death or injury to a patient. The "level of concern" on the LifeSys™ PACS device is "moderate".
Substantial Equivalence:
The new device (LifeSys™ PACS) and predicate device (eRAD PACS and eRAD RIS/PACS) are substantially equivalent in the areas of technical characteristics, general function, application, and intended use. The new device does not raise any new potential safety risks and is equivalent in performance to the predicate device. The two devices are substantially equivalent in the areas of design, architecture, general function, application, and intended use.
Non-Clinical Testing:
Thorough non-clinical system verification and validation testing was conducted in accordance with applicable international standards and internal design requirement to verify that LifeSys™ PACS software product meets user needs and indications for use. The Verification & Validation Test Plan was designed to evaluate all input functions, output functions, and actions performed in each operational mode. LifeSys™ PACS software passed all in-house testing criteria.
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Conclusion
The 510(k) Pre-Market Notification for LifeSys™ PACS contains adequate information and data to enable FDA - CDRH to determine substantial equivalence to the predicate device. The subject device and predicate device are substantially equivalent in the areas of technical characteristics, general function, application, intended use, and does not raise any new potential safety risks and is equivalent in performance to existing legally marketed devices. LifeSys™ PACS is substantially equivalent with respect to safety and effectiveness to the predicate device.