(198 days)
SPINEL 12HD Surgical Mobile Fluoroscopic X-ray System is intended to provide fluoroscopic and radiographic imaging of the patient during diagnostic, surgical and interventional procedures. Clinical applications may include but are not limited to digital subtraction angiography, orthopedic, neurological, abdominal, vascular, cardiac, critical care and emergency room procedures.
The SPINEL 12HD Surgical Mobile Fluoroscopic X-ray 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. This device is not intended to be used for mammography applications. SPINEL 12HD 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 a flat panel detector. This system can be applied in emergency room, operation room, cast room or etc. of a hospital.
The provided document is a 510(k) premarket notification for the SPINEL 12HD Interventional Fluoroscopic Mobile X-ray System. It asserts substantial equivalence to a predicate device (KMC-950) rather than independently proving performance against specific acceptance criteria in a clinical study. Therefore, much of the requested information regarding acceptance criteria and clinical study details for the SPINEL 12HD is not explicitly stated in this document.
However, based on the information provided, I can infer some aspects and present what is available:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not present a formal table of acceptance criteria with corresponding performance results for the SPINEL 12HD itself. Instead, it argues for substantial equivalence by comparing its technical specifications and performance characteristics to a predicate device (KMC-950) and a reference device (Artis one Angiographic System for the FPD). The performance characteristics are mostly described in terms of technical specifications of components.
| Feature | Predicate Device (KMC-950) | Proposed Device (SPINEL 12HD) | Justification/Comment |
|---|---|---|---|
| X-ray tube | Varian (RAD-99) | Toshiba (E7833X) | "New X-ray tube was used for the subject device due to the aspect of cost and supply capacity of the manufacturer. Both X-ray tube have equivalent technical specification. There is no difference in the safety and effectiveness for both X-ray tubes." Risk factors considered. |
| Anode Type | Rotating | Rotating | Equivalent |
| Heat Capacity | 300,000 HU | 300,000 HU | Equivalent |
| Anode Heat Cooling | 70kHU/min | 70kHU/min | Equivalent |
| Focal size | 0.3mm / 0.6mm | 0.3mm / 0.6mm | Equivalent |
| X-ray Generator Power | 12 kW | 12 kW | Equivalent |
| Fluoroscopic kV range | 40 to 125 kV | 40 to 120 kV | "Changed X-ray control range to improve output stability and effectiveness compared to the predicate device. kV → Adjusted the kV range to be aligned with the X-ray exposure setting." |
| Fluoroscopic mA range | 0.5 to 5 mA | 0.2 to 10 mA | "mA → Adjusted and broadened the mA range for more stable X-ray exams of different human body parts." |
| Detector | Thales (TH9428HP2) Image Intensifier (9") | Pixium 2630S Flat Panel Detector (11.3 x 10.3") | "The new digital FPD of the subject device has better performance specification compared to the image intensifier of the predicate device in terms of image quality and resolution." FPD cleared under K133580. Risk factors considered. |
| Detector DQE | 65 | 70 (@ 0 lp/mm) | Improved. |
| Detector MTF | 92 (@ 2 lp/cm) | 59 (@ 1 lp/mm) | Note: Units differ (lp/cm vs lp/mm), making direct comparison difficult without conversion or further context. However, the document states generally improved performance for FPD. |
| Detector Resolution | 48 μm | 92 μm (184 μm in 2x2 binning) | The pixel size (1800x1500) of the subject device is stated to be "better than the active pixel (512x512) of the predicate device." This typically implies higher resolution in digital detectors. Note: The listed μm values represent pixel size, where a smaller number is typically better for resolution. The document's qualitative statement implies overall image quality improvement. |
| Monitor Size | 17" | 19" | "The monitor size has increased to provide better image viewing experience for the user." |
| Software functions | ABC function | IODC and MDC functions added | "Both IODC and MDC function are added to optimize (Check the type and position of the object and perform fast process speed and accurate processing.) the ABC function which is already included in the predicate." "images of before and after applying each function have been compared which validates the efficacy of both IODC and MC functions." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not describe a clinical test set in the traditional sense (e.g., patient cases). The evaluation for this 510(k) submission primarily relies on non-clinical testing, including:
- Engineering testing
- Standards compliance testing
- Verification and Validation (V&V) activities for software (IODC and MDC functions).
Therefore, there is no patient-based test set sample size described. The data provenance would be laboratory testing environments in the Republic of Korea (where GEMSS MEDICAL SYSTEMS CO., LTD. is located). The data is generated from prospective non-clinical testing designed to verify compliance with standards and functionality.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Since no clinical test set with patient data was used, no experts were used to establish ground truth in the context of clinical interpretation for this submission. The "ground truth" for the non-clinical tests would have been established by engineering specifications, calibration standards, and recognized international standards (e.g., IEC, NEMA).
4. Adjudication Method for the Test Set
Not applicable, as no clinical test set requiring expert adjudication was used.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC study was performed or described in this 510(k) submission. The document focuses on demonstrating substantial equivalence through technical comparisons and compliance with safety standards, not on clinical comparative effectiveness.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
The device is an X-ray imaging system, not an AI algorithm for image analysis. The "Intelligent Object Dose Control (IODC)" and "Metal Detected Control (MDC)" are described as software functions to optimize X-ray exposure, not to perform standalone diagnostic interpretation.
The V&V Report for IODC and MDC "contains the software quality and performance testing activities" and "The images of before and after applying each function have been compared which validates the efficacy of both IODC and MC functions." This implies some form of standalone performance evaluation for these specific software features in a technical context, showing they correctly adjust image brightness. However, it's not a diagnostic "algorithm only" study as one might see for an AI CADx device.
7. Type of Ground Truth Used
For the non-clinical testing and software V&V, the ground truth would be based on:
- Engineering specifications: Device performance parameters against designed specifications.
- Physical measurements and phantoms: For radiation output, image quality metrics (DQE, MTF), and resolution.
- Standard compliance: Adherence to recognized national and international safety and performance standards (e.g., IEC 60601 series, NEMA PS 3.1-3.20, ISO 14971, 21 CFR regulations).
- Comparison to predicate device's established performance.
8. Sample Size for the Training Set
Not applicable. This device is a medical imaging hardware system with integrated software, not a machine learning or AI model trained on a dataset of cases. Therefore, there is no "training set" in the context of AI model development.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 26, 2017
GEMSS MEDICAL SYSTEMS CO., LTD. % Dave Kim Medical Device Regulatory Affairs Mtech Group 8310 Buffalo Speedway Houston, Texas 77025
Re: K163140
Trade/Device Name: SPINEL 12HD Interventional Fluoroscopic Mobile X-ray System Regulation Number: 21 CFR 892.1650 Regulation Name: Image-Intensified Fluoroscopic X-Ray System Regulatory Class: Class II Product Code: OWB, OXO, JAA Dated: April 25, 2017 Received: April 28, 2017
Dear Dave 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 of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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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/ResourcesforYou/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.
Robert Ochs
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) K163140
Device Name SPINEL 12HD Interventional Fluoroscopic Mobile X-ray System
Indications for Use (Describe)
SPINEL 12HD Surgical Mobile Fluoroscopic X-ray System is intended to provide fluoroscopic and radiographic imaging of the patient during diagnostic, surgical and interventional procedures. Clinical applications may include but are not limited to digital subtraction angiography, orthopedic, neurological, abdominal, vascular, cardiac, critical care and emergency room procedures.
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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510(k) SUMMARY
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: May 18, 2016
- General Information:
Establishment: GEMSS MEDICAL SYSTEMS CO., LTD. 2nd Floor, 29, Dunchon-daero 541 beon-gil, Jungwon-gu, seongnam-si, KOREA, REPUBLIC OF 13216
GMESS MEDICAL SYSTEMS CO., LTD. is the holder/owner for this 510(k).
- 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
- Device name and Classification
| Trade Name | : SPINEL 12HD Interventional Fluoroscopic Mobile X-ray System |
|---|---|
| Classification Name | : Image Intensified Fluoroscopic X-ray System |
| Classification Panel | : Radiology |
| Classification Regulation | : 21 CFR 892. 1650 |
| Device Classification | : Class II |
| Product Code | : OWB, OXO, JAA |
4. Legally Marketed Predicated Device
| Trade Name | : KMC-950 |
|---|---|
| 510(k) Clearance # | : K032761 |
| Clearance date | : 05/14/2004 |
| Classification Name | : Image Intensified Fluoroscopic X-ray System |
| Classification Panel | : Radiology |
| CFR Section | : 21CFR 892.1650 |
| Device Class | : Class II |
| Product Code | : JAA, OWB, OXO |
5. Reference Device
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| Trade Name | : Artis one Angiographic System |
|---|---|
| 510(k) Clearance # | : K133580 |
| Clearance date | : 04/28/2014 |
| Classification Name | : Image Intensified Fluoroscopic X-ray System |
| Classification Panel | : Radiology |
| CRF Section | : 21CFR 892.1650 |
| Device Class | : Class II |
| Product Code | : OWB, JAA, IZI |
6. Device Description
The SPINEL 12HD Surgical Mobile Fluoroscopic X-ray 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. This device is not intended to be used for mammography applications.
SPINEL 12HD 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 a flat panel detector. This system can be applied in emergency room, operation room, cast room or etc. of a hospital.
6. Indications for Use
SPINEL 12HD Surgical Mobile Fluoroscopic X-ray System is intended to provide fluoroscopic and radiographic imaging of the patient during diagnostic, surgical and interventional procedures. Clinical applications may include but are not limited to digital subtraction angiography, orthopedic, neurological, abdominal, vascular, cardiac, critical care and emergency room procedures.
7. Substantial Equivalence
SPINEL 12HD is substantially equivalent to the commercially available KMC-950 of GEMSS Medical System (K032761). The detailed SE discussion is provided in SECTION 12.
| Predicate device | Proposed device | |
|---|---|---|
| Model Name | KMC-950 | SPINEL 12HD |
| 510(k) Number | K032761 | |
| Indications for Use | The KMC-950 is intended to providefluoroscopic and radiographic imaging of thepatient during diagnostic, surgical andinterventional procedures. Clinicalapplications may include but are not limitedto digital subtraction angiography,orthopedic, neurological, abdominal,vascular, cardiac, critical care andemergency room procedures.The system may be used for other RFimaging application at physician's discretion. | SPINEL 12HD Surgical Mobile FluoroscopicX-ray System is intended to providefluoroscopic and radiographic imaging ofthe patient during diagnostic, surgical andinterventional procedures. Clinicalapplications may include but are notlimited to digital subtraction angiography,orthopedic, neurological, abdominal,vascular, cardiac, critical care andemergency room procedures. |
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| Predicate deviceKMC-950 (K032761) | Proposed deviceSPINEL 12HD | Justification | ||
|---|---|---|---|---|
| X-ray tube | Manufacturer | Varian (RAD-99) | Toshiba (E7833X) | New X-ray tube was used for thesubject device due to the aspectof cost and supply capacity of themanufacturer. Both X-ray tubehave equivalent technicalspecification. There is nodifference in the safety andeffectiveness for both X-raytubes. The following risk factorswere considered and reviewed※ |
| Anode Type | Rotating | Rotating | ||
| Heat Capacity | 300,000 HU | 300,000 HU | ||
| Anode HeatCooling | 70kHU/min | 70kHU/min | have equivalent technical | |
| Cooling | Hazard ID : RM-12HD-01 / RM-12HD-02 / RM-12HD-03 / RM-12HD-09 / RM-12HD-43 / RM-12HD-44 /RM-12HD-45 / RM-12HD-49 / RM-12HD-50 / RM-12HD-51 / RM-12HD-52 / RM-12HD-53 / RM-12HD-70 /RM-12HD-72 / RM-12HD-74 / RM-12HD-75 IEC60601-1, IEC60601-1-3 | |||
| Focal size | 0.3mm / 0.6mm | 0.3mm / 0.6mm | ||
| X-raygenerator | Manufacturer | POSKOM | POSKOM | |
| X-rayGenerator Type | High frequency /inverter type | High frequency /inverter type | ||
| Power Output | 12 kW | 12 kW | ||
| FluoroscopicMode | kV range | 40 to 125 kV See belowdiscussion fordifferences | 40 to 120 kV See belowdiscussion fordifferences | Changed X-ray control range toimprove output stability andeffectiveness compared to thepredicate device. |
| kV → Adjusted the kV range tobe aligned with the X-rayexposure setting. | ||||
| mA range | 0.5 to 5 mA. See belowdiscussion fordifferences | 0.2 to 10 mA. Seebelow discussion fordifferences | mA → Adjusted and broadenedthe mA range for more stable X-ray exams of different humanbody parts. | |
| Pulse Fluoro | Yes | Yes | ※Hazard ID : RM-12HD-01 / RM-12HD-02 / RM-12HD-03 / RM-12HD-43 / RM-12HD-49 / RM-12HD-50 /RM-12HD-51 / RM-12HD-52 / RM-12HD-53 / RM-12HD-70 / RM-12HD-74 / RM-12HD-75 | |
| ABS function | Yes | Yes | ||
| Snap Shot | 8.0 mA shot available | 6 mA shot available | ||
| Boost Shot | 20.0 mA shot available | 8mA / 20.0 mA shotavailable | ||
| Detector | Manufacturer | Thales (TH9428HP2)Image Intensifier | Pixium 2630S FlatPanel Detector (clearedunder K133580) | The new digital FPD of thesubject device has betterperformance specificationcompared to the image intensifierof the predicate device in termsof image quality and resolution.The following risk factors havebeen considered and reviewed. |
| Size | 9" | 11.3 x 10.3 " | ||
| Magnification | 9" / 6" / 4.5" | 10 " / 9" / 7-7/8" / 4.5"(square) | ||
| DQE | 65 | 70 (@ 0 lp/mm) | ||
| MTF | 92 (@ 2 lp/cm) | 59 (@ 1 lp/mm) | ||
| Centralresolution | 48 μm | 92 μm (184 μm in 2x2binning) | ※Hazard ID : RM-12HD-04 / RM-12HD-16 / RM-12HD-17 / RM-12HD-18 / RM-12HD-19 / RM-12HD-20 /RM-12HD-21 / RM-12HD-22 / RM-12HD-23 / RM-12HD-37 / RM-12HD-54 / RM-12HD-64 / RM-12HD-65 /RM-12HD-71 / RM-12HD-73 | |
| Pixel size | 1800 (h) x 1500 (v) | |||
| Camera | Manufacturer | |||
| Manufacturer | RAYSIS | N/A | N/A | |
| Type | ½" CCD | N/A | N/A | |
| Active pixels | 512 x 512 | N/A | N/A | |
| C-arm | Manufacturer | The range of C-arm movementhas been broadened to result thecoverage of larger region ofinterest during a patient exam.The following risk factors havebeen considered an reviewed.※Hazard ID : RM-12HD-10 / RM-12HD-25 / RM-12HD-28 / RM-12HD-29 / RM-12HD-30 / RM-12HD-32 /RM-12HD-33 / RM-12HD-34 / RM-12HD-35 / RM-12HD-36 / RM-12HD-37 / RM-12HD-38 / RM-12HD-39 /RM-12HD-40 / RM-12HD-41 / RM-12HD-42 / RM-12HD-56 / RM-12HD-57 / RM-12HD-58 / RM-12HD-67 /RM-12HD-68 / RM-12HD-69 | ||
| Manufacturer | GEMSS medicalSystems Co., Ltd | GEMSS medicalSystems Co., Ltd | ||
| SID | 950mm | 1000mm | ||
| Range of C-ramRail Rotation | 115° (90° / 25°) | 165° (120° / 45°) | ||
| Range of theLiner FR-armMovement | 200 mm | 220 mm | ||
| Range of theLinear T-armMovement | 500 mm | 500 mm | ||
| Range ofSwing-armRotation | ± 12.5° | ± 12.5° | ||
| Range of Stay-arm Rotation | 360° | 225° | ||
| ImageProcessing | StorageCapacity | Digital | Digital | The monitor size has increased toprovide better image viewingexperience for the user.※Hazard ID : RM-12HD-04 / RM-12HD-65 |
| Image MatrixSize | 5,000 images | 5,000 images | ||
| Monitor Size | 17" | 19" | ||
| Collimator | Model Name | KMC-950CM | SPINEL 12HDCMR |
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- Summary of technological characteristics of the device compared to the predicate device
The indications for use, operating principle, technical specifications such as X-ray tube head and generator as well as safety characteristics of SPINEL 12HD are identical to those of the predicate device. SPINEL 12HD is designed as a set of components (X-ray tube and housing, detector, digital imaging system, collimator, qenerator etc.) similar to the predicate device KMC-950 (K032761). Based on the recognized standard conformity evidences related to electro-, mechanical-, software-, and risk management, GEMSS Medical System certifies that technological characteristics of SPINEL 12HD are substantially equivalent to KMC-950, the predicate device. SPINEL 12HD consists of many critical parts same as KMC-950, the predicate device (Collimator, X-ray imager, digital image processing and viewing program, C-arm, etc.),
Even though the hardware specification of X-ray generator is the same, the operating ranges of KV and mA setting of SPINEL 12HD are different compared to KMC-950 to improve the effectiveness of the fluoroscopic exam of different human body type.
- The X-ray Generator for the subject and predicate device have the identical specification. The dose difference is small under the same irradiation conditions.
The SID and the location of ISO center is different for the subject device compared to the predicate
device which results a difference in the dose measurement. The measurement was done 150mm away from the ISO center toward the tube.
→ The measurement distance from the X-ray tube for SPINEL 12HD is longer than the distance
between the measurement position of the tube of the KMC-950 resulting the dose of slightly lower overall.
The viewing software of the subject device is an updated version of CXV viewing software also used for the The subject device is equipped with a digital flat panel detector with higher DQE and predicate device. MTF performance characteristics compared to the predicate device. The pixel size (1800x1500) of the subject device is better than the active pixel (512x512) of the predicate device. The safety and effectiveness of Pixium 2630S flat panel detector equipped for SPINEL 12HD has been reviewed and cleared by FDA under 510k No: K133580.
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The V&V Report for Intelligent object dose control (IODC) and Metal Detected Control (MDC) for SPINEL 12HD contains the software quality and performance testing activities.
The Intelligent Object Dose Control (IODC) is a function to adjust the intensity of the X-ray using the detected object, and the brightness of the desired image can be obtained by optimizing the function of ABC (Auto Brightness Control) according to the distribution of the detected object.
With metal detected control, the brightness of the image is adjusted by distinquishing the attributes of the human body and the attributes of the metal, and reflecting only the attributes of the human body except for the metal part
Both IODC and MDC function are added to optimize (Check the type and position of the object and perform fast process speed and accurate processing.) the ABC function which is already included in the predicate.
The report also contains the device hazard analysis related to IODC and MDC. The images of before and after applying each function have been compared which validates the efficacy of both IODC and MC functions.
The differences between the subject and predicate device do not introduce any new safety or effectiveness concerns for SPINEL 12HD and the sponsor concludes that SPINEL 12HD is substantially equivalent with KMC-950, the predicated device.
-
- General Safety and Effectiveness Concern
To minimize electrical, mechanical, and radiation hazards, GEMSS MEDICAL SYSTEMS CO., LTD. adheres to established industry practice and all equipment are in compliance with the relevant FDA and international standards.
- General Safety and Effectiveness Concern
Electrical, EMC, mechanical safety and performance testing according to FDA recognized standards were performed as verification and validation activities to verify the safety and effectiveness of SPINEL 12HD. Engineering testing and standards compliance testing were successfully conducted and did not raise any new safety questions or concerns or identify new risks. The instruction for use is included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner.
. All test results were satisfactory. Applied standards are as follows:
-
IEC60601-1:2005
- A IEC60601-1-2:2007
- A IEC60601-1-3:2008
- ▲ IEC60601-2-43: 2010
- IEC60601-2-54:2009 A
- A NEMA PS 3.1-3.20
- A ISO14971:2012
The subject device meets EPRC regulation requirements.
- A 21CFR1020.30
- A 21CFR1020.32
FDA quidance documents:
-
FDA quidance for SSXI devices,
- A FDA guidance for the Content of Premarket Submissions for Software Contained in Medical Devices
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Based on the robust set of results from the non-clinical studies that have been performed, SPINEL 12HD 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
SPINEL 12HD is substantially equivalent to the predicate device KMC-950 (K032761). These two devices are same or very similar in the intended use, the design principle, the performance and the applicable standards. Some characteristics, for example, capacity of X-ray tube housing and generators, X-ray imager as well as user interfaces are different. However, the compliance reports and descriptions in this submission STED provide demonstration that these differences do not raise any new questions of safety and effectiveness. Therefore, it is the sponsor's opinion that SPINEL 12HD is substantially equivalent with 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.