(80 days)
The EVS 3643 and EVS 3643G Digital X-ray detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. This device is intended to replace film or screen based radiographic systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The EVS 3643(G) is a wired/wireless flat-panel type digital X-ray detector that captures projection radiographic images in digital format within seconds, eliminating the need for an entire x-ray film or an image plate as an image capture medium. EVS 3643(G) differs from traditional X-ray systems in that, instead of exposing a film and chemically processing it to create a hard copy image, a device called a Detector is used to capture the image in electronic form.
The EVS 3643(G) Detector is an indirect conversion device in the form of a square plate in which converts the incoming X-rays into visible light. This visible light is then collected by an optical sensor, which generates an electric charges representation of the spatial distribution of the incoming X-ray quanta.
The charges are converted to a modulated electrical signal thin film transistors. The amplified signal is converted to a voltage signal and is then converted from an analog to digital signal which can be transmitted to a viewed image print out, transmitted to remote viewing or stored as an electronic data file for later viewing.
The provided text describes the acceptance criteria and a study conducted for the EVS 3643 and EVS 3643G Digital X-ray detectors.
Here's the breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
| Parameter | Acceptance Criteria (Predicate Devices - K151942 & K150766) | Reported Device Performance (EVS 3643, EVS 3643G) | Remark |
|---|---|---|---|
| DQE | 1 lp/mm: 36.8% (K151942), 29.7% (K150766) | EVS 3643: 36.8% at 1 lp/mm; EVS 3643G: 34.6% at 1 lp/mm | Same |
| 3 lp/mm: 25.56% (K151942), 5.0% (K150766) | EVS 3643: 25.56% at 3 lp/mm; EVS 3643G: 5% at 3 lp/mm | Same | |
| MTF | 2 lp/mm: 35% (K151942), 17.4% (K150766) | EVS 3643: 35% at 2 lp/mm; EVS 3643G: 30% at 2 lp/mm | Same |
| Resolution | 3.5 lp/mm (K151942 & K150766) | 3.5 lp/mm | Same |
| Wireless Charging | Non-available (K151942 & K150766) | Available (for EVS 3643 with EVS-WPCS) | Different |
| Intended Use | General radiographic diagnosis of human anatomy | General radiographic diagnosis of human anatomy (Not for mammography) | Same |
| Technological Characteristics | Consistent with predicate devices | Indirect conversion device, optical sensor, electrical signal conversion, digital transmission | Same |
| Operating Principle | Consistent with predicate devices | Same | Same |
| Materials Scintillator | CsI (K151942), GOS (K150766) | EVS 3643: CsI; EVS 3643G: GOS | Same |
| Design Features | Rectangular Panel, 13" X 17" Detector Size, 140µm Pixel Pitch | Rectangular Panel, 13" X 17" Detector Size, 140µm Pixel Pitch (EVS 3643G has 139µm pixel pitch in table and 140µm elsewhere, assumed to be negligible difference or typo) | Same |
2. Sample size used for the test set and the data provenance
The document mentions a "single-blinded concurrence study" and "Clinical images were provided". However, it does not specify the sample size for the test set (number of images or cases).
The data provenance is also not explicitly stated regarding country of origin or whether it was retrospective or prospective. It only notes that the study was conducted "according to CDRH's Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document does not specify the number of experts used or their qualifications for establishing ground truth in the clinical study. It refers to a "concurrence study," implying multiple readers, but provides no details.
4. Adjudication method for the test set
The document mentions a "single-blinded concurrence study," but does not describe the specific adjudication method used (e.g., 2+1, 3+1, none). The term "concurrence" suggests agreement among observers, but the process is not detailed.
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
The study described is a "single-blinded concurrence study" comparing the new x-ray detectors (EVS 3643G) to predicate devices to establish equivalent diagnostic capability. It is not an MRMC comparative effectiveness study evaluating the improvement of human readers with AI assistance. The device itself is a digital X-ray detector, not an AI-powered diagnostic tool. Therefore, there is no mention of effect size related to human reader improvement with AI.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The device is a digital X-ray detector, which captures images. It is not an algorithm that performs a diagnostic task independently. Therefore, a standalone algorithm-only performance study is not applicable to this device. The non-clinical data focuses on inherent device performance characteristics like DQE, MTF, and Resolution.
7. The type of ground truth used
The document states that the "concurrence study" confirmed that the new x-ray detectors "provide images of equivalent diagnostic capability." This implies that the ground truth for the clinical images was established through expert consensus on diagnostic capability, rather than pathology or specific disease outcomes.
8. The sample size for the training set
The document does not mention a training set or its sample size. This device is a hardware component (digital X-ray detector) and not a machine learning algorithm that requires a training set for model development.
9. How the ground truth for the training set was established
As there is no mention of a training set, the method for establishing its ground truth is also not applicable.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 2, 2016
DRTECH Corporation % Mr. Choul-Woo Shin Suite no. 2, 3td floor, 29, Dunchon-daero 541 beon-gil Jungwon-gu. Seongnam-si. Gyeonggi-do. 13230 REPUBLIC OF KOREA
Re: K162552
Trade/Device Name: EVS 3643, EVS 3643G Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: MOB Dated: October 31, 2016 Received: November 2, 2016
Dear Mr. Choul-Woo Shin:
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) K162552
Device Name EVS 3643, EVS 3643G
Indications for Use (Describe)
The EVS 3643 and EVS 3643G Digital X-ray detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. This device is intended to replace film or screen based radiographic systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
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)
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DRIECH
510(k) Summary
[As required by 21 CFR 807.92]
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR 807.92
1. Date Prepared [21 CFR 807.92(a) (1)]
10/28/2016
2. Submitter's Information [21 CFR 807.92(a) (1)]
| Name of Sponsor: | DRTECH Corporation | |
|---|---|---|
| • | Address: | Suit No. 2, 3 Floor, 29, Dunchon-daero541 beon-gil,Jungwon-gu, Seongnam-si, Gyeonggi-do, 13230, Republic of Korea |
| • | Contact Name: | Choul-Woo Shin |
| • | Telephone No.: | + 82-31-779-7783 |
| • | Fax No.: | + 82-31-779-7790 |
| • | Email Address : | cwshin@drtech.co.kr |
| • | Registration Number: | 3005172103 |
| • | Name of Manufacturer: | Same as Sponsor |
3. Trade Name, Common Name, Classification [21 CFR 807.92(a) (2)]
| ● | Trade Name: | EVS 3643, EVS 3643G |
|---|---|---|
| ● | Common Name: | Digital Flat Panel X-ray Detector |
| ● | Classification Name: | Stationary X-ray System |
| ● | Classification Panel: | Radiology |
| ● | Classification Regulation: | 21 CFR 892.1680 |
| ● | Product Code: | MQB |
| ● | Device Class: | II |
| ● | 501(k) Number: | K162552 |
4. Identification of Predicate Device(s) [21 CFR 807.92(a) (3)]
| Parameter | Predicate Device |
|---|---|
| • 510(k) Number: | K150766 |
| • Applicant: | Carestream Health, Inc. |
| • Trade Name: | Carestream DRX-1 System w/ DRXPlus Detectors |
| • Classification Name: | |
| • Classification Panel: | |
| • Classification Regulation: | |
| • Product Code: | |
| • Device Class: |
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5. Description of the Modified Device [21 CFR 807.92(a) (4)]
- A wireless charging function and accessories (EVS-WPCS) were added to EVS 3643(G) for wireless charging.
- Addition of EVS 3643G: This is to notify that modified EVS 3643 / EVS 3643G are same Hardware, Software and components. But scintillator layer are different. Scintillator is a phosphor that produces scintillations.
| Model Name | Scintillator layer |
|---|---|
| EVS 3643 | CsI (Cesium Iodide) |
| EVS 3643G | GoS (Gadolinium Oxysulfide) |
The EVS 3643(G) is a wired/wireless flat-panel type digital X-ray detector that captures projection radiographic images in digital format within seconds, eliminating the need for an entire x-ray film or an image plate as an image capture medium. EVS 3643(G) differs from traditional X-ray systems in that, instead of exposing a film and chemically processing it to create a hard copy image, a device called a Detector is used to capture the image in electronic form.
6. Intended Use [21 CFR 807.92(a)(5)]
The intended use has not changed as a result of the modification and is as follows:
The EVS 3643 and EVS 3643G Digital X-ray detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. This device is intended to replace film or screen based radiographic systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
7. Technological Characteristics [21 CFR 807.92(a)(6)]
The EVS 3643(G) Detector is an indirect conversion device in the form of a square plate in which converts the incoming X-rays into visible light. This visible light is then collected by an optical sensor, which generates an electric charges representation of the spatial distribution of the incoming X-ray quanta.
The charges are converted to a modulated electrical signal thin film transistors. The amplified signal is converted to a voltage signal and is then converted from an analog to digital signal which can be transmitted to a viewed image print out, transmitted to remote viewing or stored as an electronic data file for later viewing.
Comparisons with the predicate, devices show the technological characteristics of the EVS 3643(G) to be same to the predicate devices. The EVS 3643(G) is functionally identical to the predicate devices.
The subject device integrates with X-ray system through three modes such as Auto Trigger mode (AT), Sync. Trigger mode and USB SW mode. The Auto Trigger Mode (AT) is available for acquiring images without any connection to X-ray generator interface cable is not required. The Sync. Trigger mode is the most common and recommended exposure mode at B2B scopes. User can achieve the high quality images with Sync. Tigger Mode. The USB SW Mode is the most common and recommended exposure mode at a retrofit scope. User can achieve high quality images with USB SW Mode.
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8. Hardware and Software Requirements
- X-ray System Requirement
| Contents | Requirements | |
|---|---|---|
| Generator | Power frequency | 30kHz ~ 240kHz |
| KV | 40kVp ~ 150kVp | |
| mA Range | 10mA ~ 1000mA | |
| Exposure Time | 0.001~10sec | |
| mAs Range | 0.1~1000mAs | |
| Accuracy | $\pm$ 5% | |
| Bucky | Operating Type | moving: Stepping MotorSpringCAM Motor type |
| Static(Fixed) | ||
| Trey size (mm) | 386 x 460 x 15 or higher | |
| Grid | Ratio | 5:1, 6:1, 8:1, 10:1, 12:1, 15:1 |
| Line | 85 ~ 215 Line | |
| SID | 100 ~ 180 cm |
- The EVS 3643(G) detector is not compatible with trays that are less than 386 mm x 15 mm.
- Software Requirement
The EVS 3643(G) detector is compatible with Econsole1 (K152172).
9. Substantial Equivalence [21 CFR 807.92(b)]
| Parameter | Subject Device | Predicate Device | Remark | ||
|---|---|---|---|---|---|
| 510(K) Number | K162552 | K151942 | K150766 | - | |
| Manufacturer | DRTECHCorporation | DRTECHCorporation | CarestreamHealth, Inc. | - | |
| Model Name | EVS 3643, EVS3643G | EVS 3643 | Carestream DRX-1System w/ DRXPlus Detectors | - | |
| Classification Name | Stationary X-ray System | same | |||
| Classification Panel | Radiology | same | |||
| ClassificationRegulation | 21 CFR 892.1680 | same | |||
| Product Code | MQB | same | |||
| Device Class | Class II | same | |||
| Intended Use | The EVS 3643,EVS 3643G DigitalX-ray detector isindicatedfor digital imagingsolution designedfor providinggeneral | The EVS 3643Digital X-raydetector isindicatedfor digital imagingsolution designedfor providinggeneral | The device isintended tocapture fordisplayradiographicimages of humananatomy | same | |
| radiographicdiagnosis of humananatomy. Thisdevice is intendedto replace film orscreen basedradiographicsystems in allgeneral purposediagnosticprocedures. Thisdevice is notintended formammographyapplications | radiographicdiagnosis of humananatomy. Thisdevice is intendedto replace film orscreen basedradiographicsystems in allgeneral purposediagnosticprocedures. Thisdevice is notintended formammographyapplications | including bothpediatric andadult patients.The device isintended for usein generalprojectionradiographicapplicationswhereverconventionalscreen-filmsystems or CRsystems may beused. Excludedfrom theindications foruse aremammography,fluoroscopy, andangiographyapplications. | |||
| Design | PanelShape | Rectangular Panel | Rectangular Panel | Rectangular Panel | same |
| DetectorSize | 13" X 17" | 13" X 17" | 13" X 17" | same | |
| Pixel Pitch | $140μm$ | $140µm$ | $139μm$ | same | |
| Materials Scintillator | TFT -amorphousSiliconEVS 3643: CsIEVS 3643G: GOS | TFT -amorphousSiliconEVS 3643: CsI | TFT -amorphousSiliconGOS | same | |
| Performance | DQE | EVS 3643:36.8 % at 1 lp/mm25.56 % at 3 lp/mmEVS 3643G:34.6 % at 1 lp/mm5 % at 3 lp/mm | 36.8 % at 1 lp/mm25.56 % at 3 lp/mm | 29.7 % at 1 lp/mm5.0 % at 3 lp/mm | same |
| MTF | EVS 3643:37.8 % at 2 lp/mmEVS 3643G:34 % at 2 lp/mm | 37.8 % at 2 lp/mm | 17.4% at 2 lp/mm | same | |
| Resolution | 3.5 lp/mm | 3.5 lp/mm | 3.5 lp/mm | same | |
| WirelessCharging | available | non-available | non-available | different | |
| Anatomical Sites | GeneralRadiography | GeneralRadiography | GeneralRadiography | same | |
| Power Supply | 100 | 100 | 100 | same | |
| Communication | Wire | Wire | same |
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002-4/6
510(k) Summary
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DR TECH
| Method | |||
|---|---|---|---|
| Wireless• IEEE802.11a//g/n(2.4 GHz / 5 GHz)• Security:WEP/WPA/WPA2 | Wireless• IEEE802.11a//g/n(2.4 GHz / 5 GHz)• Security:WEP/WPA/WPA2 | - | |
| Exposure Mode | USB SW ModeSync Trigger ModeAuto Trigger Mode | USB SW ModeSync Trigger ModeAuto Trigger Mode | same |
When compared to the predicate devices (K151942 and K150766), the EVS 3643(G) presented in this submission has the same:
- Intended Use
- Technological characteristics
- · Operating principle
- Materials Scintillator
- · Design features
- · Performance (DQE, MTF, Resolution)
A few differences are as follows
- · Performance (Wireless charging)
There are no significant differences between the EVS 3643(G) and the predicate devices that would adversely affect the use of the product. It is substantially equivalent to these devices in design, function, materials, operational principles and intended use.
10. Summary of Non-Clinical Data [21 CFR 807.92(b)(1)]
The non-clinical performance testing constrains that the main physical values for comparison of Xray devices like DQE and MTF are basically equal or higher the predicate device as following table:
| Parameter | Modified Device | Predicate Device | Remark | |
|---|---|---|---|---|
| K151942 | K150766 | |||
| DQE | EVS 3643:36.8 % at 1 lp/mm25.56% at 3 lp/mmEVS 3643G:34.6 % at 1 lp/mm5 % at 3 lp/mm | 36.8 % at 1 lp/mm25.56 % at 3 lp/mm | 29.7 % at 1 lp/mm5.0 % at 3 lp/mm | Same |
| MTF | EVS 3643:35 % at 2 lp/mmEVS 3643G:30 % at 2 lp/mm | 35 % at 2.0 lp/mm | 17.4% at 2.0 lp/mm | Same |
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The EVS 3643(G) complies with the following international and FDA-recognized consensus standards:
| AAMI ANSI ES60601-1: | Medical Electrical Equipment -- Part 1: General Requirements for BasicSafety And Essential Performance (IEC 60601-1:2005, Mod) |
|---|---|
| IEC 60601-1-2: | Medical Electrical Equipment - Part 1-2: General Requirements For BasicSafety And Essential Performance – Collateral Standard: ElectromagneticCompatibility - Requirements And Tests (Edition 3) |
| ISO 14971: | Medical Devices - Application of Risk Management to Medical Devices.(General I (QS/RM)) |
| IEC 62220-1: | Medical electrical equipment - Characteristics of digital X-ray imagingdevices - Part 1: Determination of the detective quantum efficiency |
| NEMA PS 3.1 - 3.20: | Digital Imaging and Communications in Medicine (DICOM) Set |
11. Summary of Clinical Data [21 CFR 807.92(b)(2)]
A single-blinded concurrence study according to CDRH's Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices was conducted, and the study confirmed that the new x-ray detectors EVS 3643G provide images of equivalent diagnostic capability to the predicate devices (K151942 and K150766) and its results demonstrate substantial equivalence.
Clinical images were provided; these images were not necessary to establish substantial equivalence based on the modifications to the device (note X-ray detector technology that is identical to the predicate device) but they provide further evidence in addition to the laboratory performance data to show that the subject device works as intended.
12. Conclusion [21 CFR 807.92(b)(3)]
The modified EVS 3643(G) is substantially equivalent to the currently marketed and predicate device (EVS 3643(K151942) and Carestream DRX-1 System w/ DRX Plus Detectors(K150766)) in terms of design features, fundamental scientific technology, indications for use, and safety and effectiveness.
Additionally, Substantial equivalence was demonstrated through the non-clinical performance, which complied with the requirements specified in the international and FDA-recognized consensus standards, IEC60601-1, IEC 60601-1-2, IEC6220-1 and IEC 62133 and the clinical test, which complied with the requirements specified in the CDRH's Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices.
The results of these tests demonstrate that EVS 3643(G) meets the acceptance criteria and is adequate for this intended use. The comparison of technological characteristics, non-clinical performance data, safety testing, and clinical image concurrence data demonstrates that the device is as safe, as effective, and performs as well or better than the predicate devices.
§ 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.