K Number
K163286
Device Name
ARTIS pheno
Date Cleared
2017-03-09

(107 days)

Product Code
Regulation Number
892.1650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
ARTIS is a family of dedicated angiography systems developed for single and biplane diagnostic imaging and interventional procedures including, but not limited to, pediatric and obese patients. Procedures that can be performed with the ARTIS family include cardiac angiography, general angiography, rotational angiography, multipurpose angiography and whole body radiographic fluoroscopic procedures as well as procedures next to the table for i.e. patient extremities. Additional procedures that can be performed include angiography in the operating room, image-guided surgery by X-ray, by image fusion, and by navigation systems. The examination table as an integrated part of the system can be used for Xray imaging, surgery and interventions. ARTIS can also support the acquisition of position triggered imaging for spatial data synthesis. The ARTIS family include also the software option DynaCT with following indications for use: DynaCT is an X-ray imaging software option, which allows the reconstruction of two-dimensional images acquired with a standard angiographic C-arm device into a three-dimensional image format. DynaCT is intended for imaging both hard and soft tissues as well as other internal body structures for diagnosis, surgical planning, interventional procedures and treatment follow-up.
Device Description
The ARTIS pheno is a further development of the Artis Q and Artis Q.zen -Modular Angiography System. ARTIS pheno is equipped with C-arm, stand, flat panel detector, x-ray tube, high voltage generator, patient table, and image post processing. syngo Application Software is optional available for the support of dedicated clinical workflows.
More Information

No
The summary explicitly states "Mentions AI, DNN, or ML: Not Found" and the description focuses on hardware and standard image processing techniques like 3D reconstruction (DynaCT).

No.
The device is used for diagnostic imaging procedures, surgical planning, and treatment follow-up, not for directly treating a disease or condition.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is developed for "single and biplane diagnostic imaging" and that DynaCT, a software option within the ARTIS family, is "intended for imaging both hard and soft tissues as well as other internal body structures for diagnosis". This directly indicates its use for diagnostic purposes.

No

The device description explicitly lists hardware components such as a C-arm, stand, flat panel detector, x-ray tube, high voltage generator, and patient table, indicating it is a hardware system with integrated software.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use describes the device as an angiography system for diagnostic imaging and interventional procedures using X-ray. It focuses on imaging internal body structures for diagnosis, planning, and treatment follow-up.
  • Device Description: The device components are typical of an angiography system (C-arm, detector, X-ray tube, table, etc.).
  • Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device does not mention the analysis of such specimens.

The device is clearly an imaging system used directly on the patient, not for testing samples in a laboratory setting, which is the defining characteristic of an IVD.

N/A

Intended Use / Indications for Use

ARTIS is a family of dedicated angiography systems developed for single and biplane diagnostic imaging and interventional procedures including, but not limited to, pediatric and obese patients.

Procedures that can be performed with the ARTIS family include cardiac angiography, general angiography, rotational angiography, multipurpose angiography and whole body radiographic fluoroscopic procedures as well as procedures next to the table for i.e. patient extremities.

Additional procedures that can be performed include angiography in the operating room, image-guided surgery by X-ray, by image fusion, and by navigation systems. The examination table as an integrated part of the system can be used for Xray imaging, surgery and interventions.

ARTIS can also support the acquisition of position triggered imaging for spatial data synthesis.

The ARTIS family include also the software option DynaCT with following indications for use:

DynaCT is an X-ray imaging software option, which allows the reconstruction of two-dimensional images acquired with a standard angiographic C-arm device into a three-dimensional image format.

DynaCT is intended for imaging both hard and soft tissues as well as other internal body structures for diagnosis, surgical planning, interventional procedures and treatment follow-up.

Product codes

OWB, JAA

Device Description

The ARTIS pheno is a further development of the Artis Q and Artis Q.zen -Modular Angiography System. ARTIS pheno is equipped with C-arm, stand, flat panel detector, x-ray tube, high voltage generator, patient table, and image post processing. syngo Application Software is optional available for the support of dedicated clinical workflows.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

Not Found

Indicated Patient Age Range

pediatric and obese patients.

Intended User / Care Setting

healthcare professionals familiar with and responsible for the evaluating and post processing of X-ray images.

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 ARTIS pheno, during product development.
The ARTIS pheno was certified by Siemens Healthcare GmbH Corporate Testing Laboratory to comply with the following standards for Electrical safety, performance and Electromagnetic Compatibility:

  • ES60601-1:2005/(R)2012
  • 60601-1-2:2007
  • 60601-1-3:2008
  • 60601-1-6:2010/A1:2013
  • 60825-1:2007
  • TR 60878:2015
  • 62304:2006
  • 80001-1:2010
  • 60601-2-28:2010
  • 60601-2-43:2010
  • 60601-2-54:2009/A1:2015
  • 10993-1:2009
  • 14971:2007
    All tests were passed.
    The modifications described in this Premarket Notification were supported with verification and validation testing.
    Software Documentation for a Major 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 were conducted on ARTIS pheno during product development.
    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.
    ARTIS pheno was tested found to be safe and effective for intended users, uses and use environments through the design control verification and validation process. The Human Factor Usability Validation showed safety relevant functions that need to be revalidated. Further risk mitigations have been defined in a corrective action plan to inform and train the current users of Artis pheno VE10. Users understanding of warnings were founded during testing. Warnings were updated in the documentation and the summative usability validation with two different samples of representative users was performed.
    The ARTIS pheno VE10 has been found to be safe and effective for the intended users, uses and use environments, based on the results ascertained at the two clinical use test sites in Frankfurt and Hannover.
    Performance tests were conducted to test the functionality of ARTIS pheno. These tests have been performed to assess the functionality of the subject device. Results of all conducted testing and clinical assessment were found acceptable and do not raise any new issues of safety or effectiveness.

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

Not Found

Predicate Device(s)

K123529, K122644, K162541

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

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Image /page/0/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the edge. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines extending from the heads.

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

March 9, 2017

Siemens Medical Solution USA, Inc. % Ms. Patricia Jones Sr. Regulatory Affairs Specialist 40 Liberty Boulevard, 65-1A MALVERN PA 19355

Re: K163286

Trade/Device Name: ARTIS pheno Regulation Number: 21 CFR 892.1650 Regulation Name: Interventional fluoroscopic x-ray system Regulatory Class: II Product Code: OWB, JAA Dated: February 10, 2017 Received: February 13, 2017

Dear Ms. Jones:

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.

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

2

Indications for Use

510(k) Number (if known) K163286

Device Name ARTIS pheno

Indications for Use (Describe)

ARTIS is a family of dedicated angiography systems developed for single and biplane diagnostic imaging and interventional procedures including, but not limited to, pediatric and obese patients.

Procedures that can be performed with the ARTIS family include cardiac angiography, general angiography, rotational angiography, multipurpose angiography and whole body radiographic fluoroscopic procedures as well as procedures next to the table for i.e. patient extremities.

Additional procedures that can be performed include angiography in the operating room, image-guided surgery by X-ray, by image fusion, and by navigation systems. The examination table as an integrated part of the system can be used for Xray imaging, surgery and interventions.

ARTIS can also support the acquisition of position triggered imaging for spatial data synthesis.

The ARTIS family include also the software option DynaCT with following indications for use:

DynaCT is an X-ray imaging software option, which allows the reconstruction of two-dimensional images acquired with a standard angiographic C-arm device into a three-dimensional image format.

DynaCT is intended for imaging both hard and soft tissues as well as other internal body structures for diagnosis, surgical planning, interventional procedures and treatment follow-up.

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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3

510(k) Summary: ARTIS pheno

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

February 10, 2017 Date Prepared:

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 Systems USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 Establishment Registration Number: 2240869

Manufacturing Site: Siemens Healthcare GmbH Siemensstr. 1 91301 Forchheim, Germany Establishment Registration Number: 3004977335

2. Contact Person:

Ms. Patricia D Jones Technical Specialist, Regulatory Submissions Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 Phone: (610) 448-6474 Fax: (610) 640-4481 Email: patricia.d.jones@siemens.com

3. Device Name and Classification:

Trade Name:ARTIS pheno
Classification Name:Interventional fluoroscopic X-Ray
System
Classification Panel:Radiology
Classification Regulation:21 CFR §892.1650
Device Class:Class II
Primary Product Codes:OWB
Secondary Product Code:JAA
  • Legally Marketed Primary Predicate Device 4. Trade Name: Artis Q and Artis Q.zen - Modular Angiographic System K123529 510(k) Clearance

4

Clearance Date Classification Name:

Classification Panel: CFR Section: Device Class: Product Codes: Total Product Life Cycle: February 12, 2013 Interventional fluoroscopic X-Ray System Radiology 21 CFR §892.1650 Class II OWB, JAA, IZI All product Recall incidents are considered during the Design Input phase of development to ensure the latest models will not be affected by any of the applicable issues.

Legally Marketed Secondary Predicate Device Trade Name:

510(k) Clearance Clearance Date Classification Name:

Classification Panel: CFR Section: Device Class: Product Code: Total Product Life Cycle:

Artis zee/zeego with CSX-10 Detector SW VC21 K122644 May 16, 2013 Interventional fluoroscopic X-Ray System Radiology 21 CFR §892.1650 Class II OWB Recall product incidents All are

considered during the Design Input phase of development to ensure the latest models will not be affected by any of the applicable issues.

Legally Marketed Secondary Predicate Device

Trade Name: 510(k) Clearance Clearance Date Classification Name: Classification Panel: CFR Section: Device Class: Product Code: Total Product Life Cycle: syngo Application Software K162541 November 16, 2016 System, Image processing, Radiological Radiology 21 CFR §892.2050 Class II LLZ There are no Recalls for this Predicate Device

5. Device Description:

The ARTIS pheno is a further development of the Artis Q and Artis Q.zen -Modular Angiography System. ARTIS pheno is equipped with C-arm, stand, flat panel detector, x-ray tube, high voltage generator, patient table, and image post processing. syngo Application Software is optional available for the support of dedicated clinical workflows.

5

The following modifications are made to the cleared Artis Q and Artis Q.zen - Modular Angiography System, software version VD10 which created the Subject Device.

Proposed Device Modifications:

  • Newly designed C-arm and stand. 1)
    1. Optional Anti-Microbial Coating on surface of C-arm, stand and table
  • Newly designed table. 3)
  • Newly designed tableside control modules (TCM) 4)
    1. New Flat Panel detector Canon CSX-30
  • Newly designed collimator for both angiography and cardiology 6)
  • New System Software Version VE10 7)
    1. Integration of the post-processing syngo Application Software VD20
    1. Preparation for ACUSON Freestyle Elite w. Artis Access
    1. Modified image processing
    1. Modified dose regulation
  • New Display EIZO MX242W 12)
  • Modified Display Ceiling Suspension 13)
    1. Proposed product claims associated with the above device modifications
  • Updated 510(k) information 15)

The ARTIS pheno is substantially equivalent to the Artis Q and Artis Q.zen - Modular Angiography System VD10 with all its components as described in the Device Description, and the Substantial Equivalence sections.

6. Indication for Use:

ARTIS is a family of dedicated angiography systems developed for single and biplane diagnostic imaging and interventional procedures including, but not limited to, pediatric and obese patients.

Procedures that can be performed with the ARTIS family include cardiac angiography, neuro-angiography, general angiography, rotational multipurpose angiography and www.whole angiography, an body radiographic/fluoroscopic procedures as well as procedures next to the table for i.e. patient extremities.

Additional procedures that can be performed include angiography in the operating room, image-guided surgery by X-ray, by image fusion, and by navigation systems. The examination table as an integrated part of the system can be used for X-ray imaging, surgery and interventions.

ARTIS can also support the acquisition of position triggered imaging for spatial data synthesis.

6

The ARTIS family include also the software option DynaCT with following indications for use:

DynaCT is an X-ray imaging software option, which allows the reconstruction of two-dimensional images acquired with a standard angiographic C-arm device into a three-dimensional image format.

DynaCT is intended for imaging both hard and soft tissues as well as other internal body structures for diagnosis, surgical planning, interventional procedures and treatment follow-up.

7. Substantial Equivalence:

The ARTIS pheno is substantial equivalent to the legally marketed predicates listed in the table below:

| Predicate Device Name

and Manufacturer510(k) NumberClearance DateComparable Properties
Primary Predicate
Artis Q and Q.zen -
Modular Angiographic
SystemK12352902/12/2013• Indications for use
• System for Image Acquisition
• System for post processing
Secondary Predicates
Artis zee/zeego
w/CSX10
syngo Application
SoftwareK122644
K16254105/16/2013
11/16/2016• Detector CSX-10
• VD11 Post-Processing
Software Features

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

ARTIS pheno is designed as a set of components (C-arm, X-ray tube and housing, flat panel detector, digital imaging system, collimator, generator, etc.) that may be combined into different configurations to provide specialized angiography systems. Components used with ARTIS pheno are either commercially available with current Siemens systems or include modifications to existing components. Technological differences between the Subject Device and the Predicate Device is provided in the table below for all modifications.

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| Modification | Subject Device
ARTIS pheno
with SW VE10 | Predicate Device
Artis Q and Artis
Q.zen Modular
Angiography System
VD10 (K123529) | Comparison
Results |
|------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Newly
designed C-
arm and stand | Stand with C-arm
diameter 100-130cm | Stand with C-arm
diameter 90-110cm | Increased C-arm
diameter for
steeper
angulations |
| Optional Anti-
Microbial
Coating on
surface of C-
arm, stand
and table | Surface of C-arm,
stand and table with
Anti-Microbial Paint
additive | Surface of C-arm, stand
and table without Anti-
Microbial Paint additive | Less risks of
infection due to
Anti-Microbial
Paint additive |
| Newly
designed
table | Improved patient table
up to 280kg / 617lbs
patient weight motor-
assisted longitudinal
and transversal travel
in leveled and tilted
position | Standard patient table
up to 250kg / 550lbs
patient weight motor-
assisted longitudinal
travel in tilted position | Improved patient
table due to
increased patient
load and higher
flexibility in
positioning |
| Newly
designed
tableside
control
modules | TCM (Table Control
Module)
PCM (Pilot Control
Module)
CCM (Collimator
Control Module)
Consolidation of
tableside controls
resulting in reduced
distance for operation
Hygienic optimization
due to sealed joysticks,
inner dead man
switches and less
corrugated gaiters. | TCM (Table Control
Module)
ECC (Examination
Control Console)
CCM (Collimator
Control Module) | Newly designed
with similar
functionality
Consolidation of
tableside controls
resulting in
reduced distance
for operation
Hygienic
optimization due
to sealed
joysticks, inner
dead man
switches and less
corrugated
gaiters. |
| New flat panel
detector
Canon CSX-
30 | CSX-30
2496 x 1856 pixels for
Live 2k imaging
1024 x 1024 pixels for
1k imaging
Input fields 50 cm, 42
cm, 32 cm, 22 cm, 16
cm, 11 cm | CSX-10
1792 x 1632 pixels
896 x 816 pixels with
2x2 binning
Input fields 39 cm, 32
cm, 26 cm, 20 cm, 16
cm, 10 cm | Similar resolution
with similar input
fields |
| Newly
designed
collimator for
both
angiography
and
cardiology | One collimator for both
angiography and
cardiology | One dedicated
angiography and one
dedicated cardiology
collimator | The newly
designed
collimator
combines the
functionality of
both the |
| | | | angiography and
cardiology |
| New Software
Version VE10 | Communication
platform for C-Arm,
table movements,
tableside control
modules, detector,
collimator, Integration
of the syngo
Application Software
VD20, image
processing, dose
processing via Profinet
protocol (industrial
standard) | Communication
platform for C-Arm,
table movements,
tableside control
modules, detector,
collimator, Interface to
the syngo Application
Software, image
processing, dose
processing via CAN
protocol (Controller
Area Network) | CAN protocol
(Controller Area
Network) has
changed to the
Profinet protocol
(industrial
standard) |
| Integration of
the post-
processing
syngo
Application
Software
VD20 | syngo Application
Software available on
ARTIS pheno PC
hardware | syngo Application
Software available on
separate syngo X
Workplace or on
separate PC hardware | Functionality of
syngo Application
Software
remains the same
and runs on one
PC hardware |
| Preparation
for ACUSON
Freestyle
Ultrasound
System
Artis
Freestyle
Access | Preparation for
ACUSON Freestyle
Ultrasound System
Artis Freestyle Access.
The interface will allow
for viewing of
ultrasound images at
the Large Display of
the Artis system | Preparation for
ACUSON Freestyle
Ultrasound System
Artis Freestyle Access
filed via NFJ. The
interface will allow for
viewing of ultrasound
images at the Large
Display of the Artis
system | Mechanical
adaptation for
ACUSON
Freestyle. Use of
existing interface
of the ARTIS
system |
| Modified
image
processing | -2k image matrix with
up to 15f/s

  • Advanced noise
    reduction algorithm
  • Automated contrast
    and brightness
    adjustment
    -spatial modulation
    transfer function up to
    16 frequency hands | -1k image matrix with
    up to 15f/s
  • noise reduction
    algorithm
  • Manual contrast and
    brightness adjustment
    (windowing)
    --spatial modulation
    transfer function up to 3
    frequency bands | Increased image
    matrix
    More precise
    control of the final
    image
    presentation |
    | Modified Dose
    regulation | constant signal to noise
    ratio (image quality) | constant system dose
    (entrance dose to the
    detector) | Optimized
    composition of X-
    ray spectrum in
    dependency of
    water values |
    | New Display
    EIZO MX242W | Use of 24" display | Use of 19", 21", 22"
    displays | Increased size of
    display |
    | Modified
    Display
    Ceiling
    Suspension | DCS pivot mounted
    DCS rail mounted | DCS rail mounted | Enhanced
    positioning range |

8

9

SIER

9. Nonclinical Performance Testing:

Non-clinical tests were conducted for ARTIS pheno, during product development.

The ARTIS pheno was certified by Siemens Healthcare GmbH Corporate Testing Laboratory to comply with the following standards for Electrical safety, performance and Electromagnetic Compatibility:

  • ES60601-1:2005/(R)2012 ●
  • 60601-1-2:2007 ●
  • 60601-1-3:2008 ●
  • 60601-1-6:2010/A1:2013
  • 60825-1:2007 ●
  • TR 60878:2015 ●
  • 62304:2006 ●
  • 80001-1:2010 ●
  • 60601-2-28:2010 ●
  • 60601-2-43:2010 ●
  • 60601-2-54:2009/A1:2015
  • 10993-1:2009
  • 14971:2007 ●

All tests were passed.

The modifications described in this Premarket Notification were supported with verification and validation testing.

Verification and Validation:

Software Documentation for a Major 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 were conducted on ARTIS pheno during product development.

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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.

ARTIS pheno was tested found to be safe and effective for intended users, uses and use environments through the design control verification and validation process. The Human Factor Usability Validation showed safety relevant functions that need to be revalidated. Further risk mitigations have been defined in a corrective action plan to inform and train the current users of Artis pheno VE10. Users understanding of warnings were founded during testing. Warnings were updated in the documentation and the summative usability validation with two different samples of representative users was performed.

The ARTIS pheno VE10 has been found to be safe and effective for the intended users, uses and use environments, based on the results ascertained at the two clinical use test sites in Frankfurt and Hannover.

Siemens conforms to the Cybersecurity requirements by implementing a process of preventing unauthorized access, modifications, misuse or denial of use, or the unauthorized use of information that is stored, accessed, or transferred from a medical device to an external recipient. Provided in this submission is a cybersecurity statement that considers IEC 80001-1:2010. The responsibility for compliance with IEC 80001-1-2010 is the hospital. Provided in the Software Section, is the required cybersecurity information.

Summary:

Performance tests were conducted to test the functionality of ARTIS pheno. These tests have been performed to assess the functionality of the subject device. Results of all conducted testing and clinical assessment were found acceptable and do not raise any new issues of safety or effectiveness.

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.

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

11

to final performance testing. Furthermore the operators are health care professionals familiar with and responsible for the evaluating and post processing of X-ray images.

11. Conclusion as to Substantial Equivalence:

The predicate device was cleared based on non-clinical supportive information and clinical images and data. Similar non-clinical test results demonstrrates that the ARTIS pheno acceptance criteria are adequate for the intended use of the device. The comparison of technological characteristics, non-clinical performance data, clinical images and software validation data demonstrates that the Subject Device is as safe and effective when compared to the Predicate Devices that is currently marketed for the same intended use.