K Number
K162971
Device Name
Multix Fusion Max
Date Cleared
2016-11-22

(28 days)

Product Code
Regulation Number
892.1680
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Multix Fusion Max system is a radiographic system used in hospitals, clinics, and medical practices. Multix Fusion Max enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatic, adult and bariatic patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The Multix Fusion Max system is not meant for mammography. Multix Fusion Max uses a mobile(wired), or a fixed (integrated) or wireless digital detector for generating diagnostic images by converting x-rays into image signals. The Multix Fusion Max is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.
Device Description
The Multix Fusion Max Radiography X-ray system is a modular system of x-ray components (ceiling suspension with X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless and integrated detectors) same as the predicate the Multix Fusion. This 510(k) submission describes modifications to the predicate device the Multix Fusion cleared via K142049.
More Information

No
The document does not mention AI, ML, deep learning, or any related terms, nor does it describe any features or performance metrics typically associated with AI/ML-powered devices. The focus is on hardware modifications and integration testing.

No
The device is described as a "radiographic system" used for "generating diagnostic images" by converting x-rays into image signals, which indicates it is used for diagnosis, not therapy.

Yes

Explanation: The "Intended Use / Indications for Use" section states that the device is used for "generating diagnostic images," which directly indicates its role in diagnosis.

No

The device description explicitly states it is a "modular system of x-ray components (ceiling suspension with X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless and integrated detectors)". This indicates it is a hardware system, not software-only.

Based on the provided information, the Multix Fusion Max system is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • Intended Use: The intended use clearly states that the system is a "radiographic system used in hospitals, clinics, and medical practices" for "radiographic exposures of the whole body". This describes an imaging device used to visualize internal structures of the body using X-rays.
  • Device Description: The description details components like an "X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless and integrated detectors". These are all components of an X-ray imaging system.
  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening. The Multix Fusion Max does not perform this function.

The Multix Fusion Max is a medical imaging device, specifically a radiographic X-ray system.

N/A

Intended Use / Indications for Use

Multix Fusion Max system is a radiographic system used in hospitals, clinics, and medical practices. Multix Fusion Max enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The Multix Fusion Max system is not meant for mammography.

Multix Fusion Max uses a mobile(wired), or a fixed (integrated) or wireless digital detector for generating diagnostic images by converting x-rays into image signals. The Multix Fusion Max is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.

Product codes (comma separated list FDA assigned to the subject device)

KPR

Device Description

The Multix Fusion Max Radiography X-ray system is a modular system of x-ray components (ceiling suspension with X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless and integrated detectors) same as the predicate the Multix Fusion. This 510(k) submission describes modifications to the predicate device the Multix Fusion cleared via K142049.

The following modifications have been made to the cleared predicate device and the system will be rebranded the Multix Fusion Max:

Hardware
The following components are being integrated into the system: the Pixium 3543 EZh wireless detector, the Pixium 2430 EZ wireless detector; the Pixium 4343RCE fixed detector, a new wireless Bucky wall stand with motorized height adjustment, a new table that has a charging tray and a manual Bucky tray, and a new 92-line grid with a 13:1 ratio.

Software
The operating system is being upgraded from Windows XP to Windows 7 and the software version will now be VE21.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

whole body including: skull, chest, abdomen, and extremities

Indicated Patient Age Range

pediatric, adult and bariatric patients

Intended User / Care Setting

hospitals, clinics, and medical practices.

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)

Non-clinical tests were conducted for the Multix Fusion Max during product development. The modifications described in this Premarket Notification are supported with verification and validation testing.
Detector integration testing consisted of functional and image quality tests. Functional tests included exposure workflow, detector sharing function and image resend functions. Image quality tests included flat field uniformity of the detector.
The testing results support that all the software specifications have met the acceptance criteria. Testing for verification and validation for the device was found acceptable to support the claims of substantial equivalence.

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

Not Found

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.

K142049

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.

K133259

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).

Not Found

§ 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.

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

November 22, 2016

Siemens Medical Solutions USA, Inc. % Ms. Denise Adams Regulatory Affairs Specialist 40 Liberty Boulevard, 65-1A MALVERN PA 19355

Re: K162971

Trade/Device Name: Multix Fusion Max Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: KPR Dated: October 21, 2016 Received: October 25, 2016

Dear Ms. Adams:

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,

Robert Oolo

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)

K162971

Device Name Multix Fusion Max

Indications for Use (Describe)

Multix Fusion Max system is a radiographic system used in hospitals, clinics, and medical practices. Multix Fusion Max enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatic, adult and bariatic patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The Multix Fusion Max system is not meant for mammography.

Multix Fusion Max uses a mobile(wired), or a fixed (integrated) or wireless digital detector for generating diagnostic images by converting x-rays into image signals. The Multix Fusion Max is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.

X Prescription Use (Part 21 CFR 801 Subpart D)

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

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Healthcare

510(k) Summary: Multix Fusion Max

Company: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355

Date Prepared: November 21, 2016

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

1. General Information

Importer / Distributor

Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 Establishment Registration Number 2240869

Location of Manufacturing Site

Siemens Shanghai Medical Equipment Ltd. 278 Zhou Zhu Road, Shanghai 201318, China Establishment Registration Number 3003202425

Siemens Healthcare GmbH, Business Unit XP Siemensstrasse 1 Forchheim, Germany 91301 Establishment Registration Number: 3004977335

2. Contact Person

Denise Adams, RAC Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 610-448-6139 adams.denise@siemens.com

40 Liberty Boulevard Malvern, PA 19355-9998 USA

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3. Device Name and Classification

Trade Name:Multix Fusion Max
Classification Name:Stationary X-Ray System
Classification Panel:Radiology
Classification Regulation:21 CFR §892.1680
Device Class:Class II
Product Code:KPR

4. Legally Marketed Predicate Devices

Primary Predicate
Trade Name:Multix Fusion
510(k) #:K142049
Clearance Date:December 18, 2014
Classification Name:Stationary X-Ray System
Classification Panel:Radiology
CFR Section:21 CFR §892.1680
Device Class:Class II
Product Code:KPR

Reference Predicate

|

Trade Name:YSIO Max
510(k) #:K133259
Clearance Date:January 24, 2014
Classification Name:Stationary X-Ray System
Classification Panel:Radiology
CFR Section:21 CFR §892.1680
Device Class:Class II
Product Code:KPR

5. Device Description

The Multix Fusion Max Radiography X-ray system is a modular system of x-ray components (ceiling suspension with X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless and integrated detectors) same as the predicate the Multix Fusion. This 510(k) submission describes modifications to the predicate device the Multix Fusion cleared via K142049.

The following modifications have been made to the cleared predicate device and the system will be rebranded the Multix Fusion Max:

5

Hardware

The following components are being integrated into the system: the Pixium 3543 EZh wireless detector, the Pixium 2430 EZ wireless detector; the Pixium 4343RCE fixed detector, a new wireless Bucky wall stand with motorized height adjustment, a new table that has a charging tray and a manual Bucky tray, and a new 92-line grid with a 13:1 ratio.

Software

The operating system is being upgraded from Windows XP to Windows 7 and the software version will now be VE21.

6. Indication for Use

Multix Fusion Max system is a radiographic system used in hospitals, clinics, and medical practices. Multix Fusion Max enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The Multix Fusion Max system is not meant for mammography.

Multix Fusion Max uses a mobile (wired), or a fixed (integrated) or wireless digital detector for generating diagnostic images by converting x-rays into image signals. The Multix Fusion Max is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.

7. Substantial Equivalence

The Multix Fusion Max is a modification to the primary predicate device the Multix Fusion cleared via K142049. The Multix Fusion Max utilizes the same wireless detectors as the reference device the Ysio Max cleared via K133259. It is within the same classification regulation for the same indications for use and the same mechanical design as the predicate devices. The Multix Fusion Max is substantially equivalent to the predicate devices and documentation is provided to support a claim of substantial equivalence.

| | Multix Fusion Max
(subject) | Multix Fusion K142049
(primary predicate) | Comparison
Results |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|
| Indications
for Use | The Multix Fusion Max
system is a radiographic
system used in hospitals,
clinics, and medical
practices. Multix Fusion Max
enables radiographic
exposures of the whole body
including: skull, chest,
abdomen, and extremities
and may be used on
pediatric, adult and bariatric
patients. Exposures may be
taken with the patient sitting. | The Multix Fusion system
is a radiographic system
used in hospitals, clinics,
and medical practices.
Multix Fusion enables
radiographic exposures of
the whole body including:
skull, chest, abdomen, and
extremities and may be
used on pediatric, adult and
bariatric patients.
Exposures may be taken
with the patient sitting. | Same |

Comparison of Indications for Use

6

| standing, or in the prone
position. The Multix Fusion
Max system is not meant for
mammography. | standing, or in the prone
position. The Multix
Fusion system is not meant
for mammography. |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| The Multix Fusion uses a
mobile (wired), or fixed
(integrated) or wireless
digital detector for
generating diagnostic images
by converting x-rays into
image signals. | The Multix Fusion uses a
mobile (wired), or fixed
(integrated) or wireless
digital detector for
generating diagnostic
images by converting x-
rays into image signals. |
| The Multix Fusion is also
designed to be used with
conventional film/ screen or
Computed Radiography
(CR) cassettes. | The Multix Fusion is also
designed to be used with
conventional film/ screen
or Computed Radiography
(CR) cassettes. |

Comparison of Subject Device to the Primary Predicate Device

AttributeMultix Fusion Max (subject)Multix Fusion K142049 (primary predicate)Comparison Results
Ceiling mounted support (unchanged)Semi-automatedSemi-automatedSame
X-ray tube assembly (unchanged)80 kW
Two-focus80 kW
Two-focusSame
Collimator (unchanged)Standard collimator(ACSS)Standard collimator(ACSS)Same
Patient TableRadiographic table motorized with floating table top (wireless detector)Radiographic table motorized with floating table top (wireless detector)Charging tray
Radiographic table motorized with floating table top (integrated detector)Radiographic table motorized with floating table top (integrated detector)Same
Bucky Wall StandBWS for integrated detector motorized height adjustment (vertical movement)BWS for integrated detector motorized height adjustment (vertical movement)Same
BWS for wireless detector
motorized height adjustment
(vertical movement)BWS for wireless detector
motorized or manual
height adjustment (vertical
movement)Only motorized
height
adjustment
Touch
Interface
(unchanged)Graphical user interfaceGraphical user interfaceSame
X-ray
generator
(unchanged)55kW, 65 kW or 80 kW55kW, 65 kW or 80 kWSame
Integrated
detector
TRIXELLPixium 4343RCE
43 cm x 43 cmPixium 4343RG
43 cm x 43 cm
Pixium 4343RC
43 cm x 43 cmCompared to
the predicate
Pixium
4343RC-the
active area is
smaller but the
performance
(e.g. DQE,
MTF) is similar
Portable
Wireless
Detector
(wi-D)
TRIXELLPixium 3543EZh
43 cm x 35 cm
Pixium 2430EZ
30 cm x 24 cmPaxScan 4336W
43cm x 36 cmSame
technology with
WIFI feature
Operating
modes
(unchanged)RAD Single ExposureRAD Single ExposureSame
Imaging
System
(unchanged)Fluorospot Compact PC
based,
high res digitalFluorospot Compact PC
based,
high res digitalSame
Display 19"
(unchanged)Black & White
or ColorBlack & White
or ColorSame
DICOM 3
Functions
(unchanged)Send, StC, Print,
Query/Retrieve, Get
Worklist, MPPSSend, StC, Print,
Query/Retrieve, Get
Worklist, MPPSSame
Radiographi
c
Grid92-line grid
(ratio 13:1)
85-line grid
(ratio 5:1) (optional)80-line grid (ratio10:1)
50-line grid (ratio10:1)More lines,
different ratio
Accessory
(unchanged)Remote ControlRemote ControlSame

7

8

consoleconsole
Fixed Subject Detector Compared to the Fixed Primary Predicate Detector
Technical
SpecificationsTrixell Pixium
4343RCE detector
(fixed) (subject)Trixell Pixium
4343RC detector
(fixed) (predicate)Comparison
Results
Dimensions423.3 mm x 425.4 mm424.6 mm x 425.5 mmDifference not
significant
Resolution2860 x 2874 pixels2869 x 2874 pixelsDifference not
significant
Pixel size148 um148 umSame
Semiconductor
MaterialAmorphous silicon, a-
SiAmorphous silicon, a-
SiSame
ScintillatorCesium iodide (CsI)Cesium iodide (CsI)Same
Acquisition depth16 bit16 bitSame
DQE (Detective
DuantinDOE @ 0.05 lp/mm (2
μGy), 67%DOE @ 0.05 lp/mm (2
uGy), 65%Difference not
significant
(Modulations
transfer function)MTF @ 1 lp/mm, 62%MTF @ 1 lp/mm, 63%Difference not
significant

|

Wireless Subject Detector Compared to the Wireless Primary Predicate Detector

| Technical
Specifications | Trixell Pixium 3543
EZh detector
(wireless) (subject) | Varian PaxScan
4336W detector
(wireless)
(predicate) | Comparison
Results |
|-------------------------------------------|-----------------------------------------------------------------------------------|---------------------------------------------------------------|-------------------------------|
| Dimensions | 349 mm x 425 mm | 356 mm x 427 mm | Smaller |
| Resolution | 2356 x 2872 pixels | 3032 x 2520 pixels | Difference not
significant |
| Pixel size | 148 139 Larger | | |
| Semiconductor
Material | Amorphous silicon, a-
Si | Amorphous silicon, a-
Si | Same |
| Scintillator | Cesium iodide (CsI) | Cesium iodide (CsI) | Same |
| Acquisition depth | 16 bit | 16 bit | Same |
| DQE (Detective
Quantum
Efficiency) | DQE @ 1 lp/mm (2 DQE @ 1 lp/mm (2 Difference not
significant | | |
| MTF
(Modulations
transfer function) | MTF @ 1 lp/mm, 61% | MTF @ 1 lp/mm, 57% | Difference not
significant |

Wireless Subject Detector Compared to the Wireless Reference Predicate Detector

| Technical
Specifications | Trixell Pixium 3543
EZh detector
(wireless) (subject) | Trixell Pixium 3543
EZh detector
(wireless)
(reference predicate) | Comparison
Results |
|-----------------------------|-------------------------------------------------------------|----------------------------------------------------------------------------|-----------------------|
| Dimensions | 349 mm x 425 mm | 349 mm x 425 mm | Same |

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Resolution2356 x 2872 pixels2356 x 2872 pixelsSame
Pixel size148 μm148 μmSame
Semiconductor
MaterialAmorphous silicon, a-SiAmorphous silicon, a-SiSame
ScintillatorCesium iodide (CsI)Cesium iodide (CsI)Same
Acquisition depth16 bit16 bitSame
DQE (Detective
Quantum
Efficiency)DQE @ 1 lp/mm (2 μGy), 50%DQE @ 1 lp/mm (2 μGy), 50%Same
MTF
(Modulations
transfer function)MTF @ 1 lp/mm, 61%MTF @ 1 lp/mm, 61%Same

Wireless Subject Detector Compared to the Wireless Primary Predicate Detector

| Technical
Specifications | Trixell Pixium
2430EZ detector
(wireless) (subject) | Varian PaxScan
4336W detector
(wireless) (primary predicate) | Comparison
Results |
|-------------------------------------------|-----------------------------------------------------------|--------------------------------------------------------------------|-------------------------------|
| Dimensions | 228 mm x 284 mm | 356 mm x 427 mm | Smaller |
| Resolution | 1560 x 1920 pixels | 3032 x 2520 pixels | Difference not
significant |
| Pixel size | 148 μm | 139 μm | Larger |
| Semiconductor
Material | Amorphous silicon, a-
Si | Amorphous silicon, a-
Si | Same |
| Scintillator | Cesium iodide (CsI) | Cesium iodide (CsI) | Same |
| Acquisition depth | 16 bit | 16 bit | Same |
| DQE (Detective
Quantum
Efficiency) | DQE @ 1 lp/mm (2
μGy), 50% | DQE @ 1 lp/mm (2
μGy), 54% | Difference not
significant |
| MTF
(Modulations
transfer function) | MTF @ 1 lp/mm,61% | MTF @ 1 lp/mm,57% | Difference not
significant |

Wireless Subject Detector Compared to the Wireless Reference Predicate Detector

| Technical
Specifications | Trixell Pixium
2430EZ detector
(wireless) (subject) | Trixell Pixium
2430EZ detector
(wireless) (reference
predicate) | Comparison
Results |
|------------------------------------------|-----------------------------------------------------------|--------------------------------------------------------------------------|-----------------------|
| Dimensions | 228 mm x 284 mm | 228 mm x 284 mm | Same |
| Resolution | 1560 x 1920 pixels | 1560 x 1920 pixels | Same |
| Pixel size | 148 µm | 148 µm | Same |
| Semiconductor
Material | Amorphous silicon, a-
Si | Amorphous silicon, a-
Si | Same |
| Scintillator | Cesium iodide (CsI) | Cesium iodide (CsI) | Same |
| Acquisition depth | 16 bit | 16 bit | Same |
| DQE (Detective
Quantum
Efficiency) | DQE @ 1 lp/mm (2 µGy), 50% | DQE @ 1 lp/mm (2 µGy), 50% | Same |
| MTF (Modulations
transfer function) | MTF @ 1 lp/mm,61% | MTF @ 1 lp/mm,61% | Same |

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8. Summary of Technological Characteristics of the Subject Device as Compared with the Predicate Device

The Multix Fusion Max is comparable in indications for use, design, material, functionality, technology, energy source and is substantially equivalent to the commercially available predicates. It uses the same or similar components cleared in the Multix Fusion (e.g. tube, generator, ceiling-mounted tube support, table, Bucky wall stand and imaging system) and the Ysio Max (wireless detectors).

The components of the subject device have many of the same technological characteristics as the ones from the predicate devices. There are some technological characteristics that differ slightly as shown in the comparison tables.

Testing and validation have been successfully completed and test results show that the subject device Multix Fusion Max with all of its components are comparable to the predicate devices and therefore is substantially equivalent to the predicate devices.

The modifications made to the subject device Multix Fusion Max do not affect the intended use of the device nor do they alter its fundamental scientific technology from the 510(k) cleared predicate devices.

9. Nonclinical Performance Testing

Non-clinical tests were conducted for the Multix Fusion Max during product development. The modifications described in this Premarket Notification are supported with verification and validation testing.

Multix Fusion Max conforms to the following standards: IEC 60601-1:2012, ed.3.1; IEC 60601-1-2 3rd 2007; IEC 60601-1-3:2008+A1:2013; IEC 62366: 2014; ISO 14971:2007; IEC 62304 Ed. 1.1 2015; IEC 60601-2-28 Edition 2.0 (2010); IEC 60601-2-54 Edition 1.1 2015; PS 3.1 - 3.20 (2011); IEC 60601-1-6: 2013 and ISO 10993-1:2009.

Software Documentation for a Moderate Level of Concern software per FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" issued on May 11, 2005 is also included as part of this submission. The performance data demonstrates continued conformance with special controls for medical devices containing software. Non-clinical tests (integration and functional) were conducted on the Multix Fusion Max during product development.

Detector integration testing consisted of functional and image quality tests. Functional tests included exposure workflow, detector sharing function and image resend functions. Image quality tests included flat field uniformity of the detector.

The Risk analysis was completed and risk control implemented to mitigate identified hazards. The testing results support that all the software specifications have met the acceptance criteria. Testing for verification and validation for the device was found acceptable to support the claims of substantial equivalence.

10. General Safety and Effectiveness Concerns

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. Several safety features including visual and audible warnings are incorporated into the system design. In addition, the

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Multix Fusion Max Radiography X-ray system is continually monitored, and if an error occurs, the system functions will be blocked and an error message will be displayed. Risk management is ensured via a hazard analysis which is used to identify potential hazards. These potential hazards are controlled via software development, verification and validation testing. To minimize electrical, mechanical, and radiation hazards, Siemens adheres to recognized and established industry practice, and all equipment is subject to final performance testing. Furthermore the operators are health care professionals familiar with and responsible for the X-ray examinations to be performed.

11. Conclusion as to Substantial Equivalence

The Multix Fusion Max has the same indications for use as the predicate Multix Fusion. The operating environment and mechanical design are similar. It is Siemens opinion, that the Multix Fusion Max is substantially equivalent to the Multix Fusion, cleared 12/18/2014 in K142049.

The predicate device was cleared based on non-clinical supportive information. Therefore, the subject device non-clinical data supports the safety of software with verification and validation testing. Verification and validation testing demonstrates that the Multix Fusion Max should perform as intended. The non-clinical test data demonstrate that the Multix Fusion Max device performance is comparable to the predicate device that is currently marketed for the same intended use.

In summary, Siemens is of the opinion that the Multix Fusion Max does not introduce any new potential safety risk and is substantially equivalent to and performs as well as the predicate device.