K Number
K163423
Device Name
Orthopantomograph OP300
Manufacturer
Date Cleared
2017-08-31

(268 days)

Product Code
Regulation Number
892.1750
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Orthopantomograph OP300 panoramic, cephalometric and cone beam computed tomography x-ray device is intended to image the head and neck areas for diagnostic support. This includes temporomandibular Joints (TMJs) and dentomaxillofacial areas, and with the 13x15 cm field of view (FOV) this additionally includes the ear. nose and throat (ENT) regions. The x-ray device produces conventional 2D x-ray images and x-ray projection images for the reconstruction of a 3D view. The device is operated and used by qualified healthcare professionals.
Device Description
Orthopantomograph OP300 x-ray unit is a software controlled diagnostic dental X-ray equipment for producing panoramic, cephalometric and 3D images of the dentomaxillofacial complex, ENT and airway regions of the head and neck. The Orthopantomograph OP300 is available in different configurations (panoramic, cephalometric, 3D) with different 3D Field of View configurations (6X4 cm, 6X8 cm, 5X5 cm, 8X8 cm, 8X15 cm, and 13X15 cm). The components of the device include column, carriage, rotating unit (containing tube head, sensors and collimator), top-level hanger, patient head support, software for image reconstruction, and an optional software package for image reviewing. The proprietary name of the optional image reviewing software is CLINIVIEW. Cone Beam Volumetric Tomography is a medical imaging technique that uses X-rays to obtain crosssectional images of the head or neck. The proposed device utilizes cone beam X-ray technology, which generates conical x-ray beams that rotate around the patient's head and incident upon the receptor that generate sufficiently contrasted images. Quality of the images depends on the level and amount of X-ray energy delivered to the tissue. When interpreted by a trained physician, these images provide useful diagnostic information.
More Information

Not Found

No
The document describes a standard X-ray imaging device and its software for image reconstruction and review. There is no mention of AI, ML, or related concepts in the intended use, device description, or performance studies.

No
The device is described as a diagnostic imaging device used to image the head and neck for diagnostic support and produces conventional 2D and 3D x-ray images, not to provide therapy.

Yes
The "Intended Use / Indications for Use" states that the device is "intended to image the head and neck areas for diagnostic support," and the "Device Description" explicitly calls it "software controlled diagnostic dental X-ray equipment." Additionally, it mentions that "When interpreted by a trained physician, these images provide useful diagnostic information."

No

The device description explicitly lists hardware components such as a column, carriage, rotating unit (containing tube head, sensors, and collimator), top-level hanger, and patient head support. While it includes software for image reconstruction and reviewing, it is an integral part of a physical X-ray device.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The Orthopantomograph OP300 is an X-ray imaging device. It produces images of the head and neck areas using X-rays.
  • No Sample Analysis: The device does not analyze biological samples taken from the patient. It directly images the patient's anatomy.

Therefore, the Orthopantomograph OP300 falls under the category of medical imaging devices, not In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The Orthopantomograph OP300 panoramic, cephalometric and cone beam computed tomography x-ray device is intended to image the head and neck areas for diagnostic support. This includes temporomandibular Joints (TMJs) and dentomaxillofacial areas, and with the 13x15 cm field of view (FOV) this additionally includes the ear. nose and throat (ENT) regions. The x-ray device produces conventional 2D x-ray images and x-ray projection images for the reconstruction of a 3D view. The device is operated and used by qualified healthcare professionals.

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

OAS

Device Description

Orthopantomograph OP300 x-ray unit is a software controlled diagnostic dental X-ray equipment for producing panoramic, cephalometric and 3D images of the dentomaxillofacial complex, ENT and airway regions of the head and neck. The Orthopantomograph OP300 is available in different configurations (panoramic, cephalometric, 3D) with different 3D Field of View configurations (6X4 cm, 6X8 cm, 5X5 cm, 8X8 cm, 8X15 cm, and 13X15 cm). The components of the device include column, carriage, rotating unit (containing tube head, sensors and collimator), top-level hanger, patient head support, software for image reconstruction, and an optional software package for image reviewing. The proprietary name of the optional image reviewing software is CLINIVIEW.

Cone Beam Volumetric Tomography is a medical imaging technique that uses X-rays to obtain crosssectional images of the head or neck. The proposed device utilizes cone beam X-ray technology, which generates conical x-ray beams that rotate around the patient's head and incident upon the receptor that generate sufficiently contrasted images. Quality of the images depends on the level and amount of X-ray energy delivered to the tissue. When interpreted by a trained physician, these images provide useful diagnostic information.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

head and neck areas, temporomandibular Joints (TMJs) and dentomaxillofacial areas, ear, nose and throat (ENT) regions.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

qualified healthcare professionals

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 Performance Data: As part of the design control activities, the Orthopantomograph OP300 device has successfully passed design verification and validation. The substantial equivalence of the proposed Orthopantomograph OP300 for the proposed indications for use has been substantiated via an image comparison study of predicate device Scanora 3D and proposed device Orthopantomograph OP300 images from ENT, airway and maxillofacial areas. Biocompatibility evaluation was conducted on patient contacting accessory parts and their material and found to be in conformance with ISO 10993-5 and ISO 10993-10. EMC and Electrical Safety testing were performed by 30 party test house and found to meet all the requirements in standards IEC 60601-1: 2005. IEC 60601-1-6:2013. IEC 62366:2014. IEC 60601-2-63:2012. IEC 60601-2-28:2010. IEC 60601-1-2:2007. and IEC 60601-1-3:2013.

Clinical Performance Data: Clinical images acquired using Orthopantomograph OP300 were reviewed by qualified clinicians to be of acceptable quality for the proposed indications for use.

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.

K110839, K133544

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.

Not Found

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

§ 892.1750 Computed tomography x-ray system.

(a)
Identification. A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.

0

Public Health Service

Image /page/0/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with a flowing, abstract design connecting them.

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

August 31, 2017

PaloDEx Group Oy % Mr. Eric Schwandt Regulatory Manager Nahkelantie 160 Tuusula. FI-04300 FINLAND

Re: K163423

Trade/Device Name: Orthopantomograph OP300 Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: II Product Code: OAS Dated: July 24, 2017 Received: August 3, 2017

Dear Mr. Schwandt:

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

1

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.

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 (DICE) 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 (DICE) 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,

Michael D. O'Hara

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

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K163423

Device Name Orthopantomograph OP300

Indications for Use (Describe)

The Orthopantomograph OP300 panoramic, cephalometric and cone beam computed tomography x-ray device is intended to image the head and neck areas for diagnostic support. This includes temporomandibular Joints (TMJs) and dentomaxillofacial areas, and with the 13x15 cm field of view (FOV) this additionally includes the ear. nose and throat (ENT) regions. The x-ray device produces conventional 2D x-ray images and x-ray projection images for the reconstruction of a 3D view. The device is operated and used by qualified healthcare professionals.

Type of Use (Select one or both, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Image /page/3/Picture/0 description: The image shows the words "Palodex Group" in a simple, sans-serif font. The word "Palodex" is in a larger font size and is positioned above the word "Group". The word "Group" is slightly offset to the right compared to "Palodex".

510(k) SUMMARY for Orthopantomograph OP300

Submitter Information:

Palodex Group Oy Nahkelantie 160 FI-04300 Tuusula Finland

Contact Person:Eric Schwandt
Telephone Number:+358 10 270 2000
Fax Number:+358-10-270 5263
Date Prepared:November 17, 2016
Updated:July 21, 2017

Device Name:

Proprietary Name:Orthopantomograph OP300
Common Name:X-ray, Tomography, Computed, Dental
Classification Name:Computed tomography x-ray system
CFR Number:892.1750
Device Class:II
Product Code:OAS

Predicate Devices:

Proprietary Name:Scanora 3D
510(k) NumberK110839
Common Name:X-ray, Tomography, Computed, Dental
Classification Name:Computed tomography x-ray system
CFR Number:892.1750
Device Class:II
Product Code:OAS
Proprietary Name:Orthopantomograph OP300
510(k) NumberK133544
Common Name:X-ray, Tomography, Computed, Denta
Classification Name:Computed tomography x-ray system
CFR Number:892.1750
Device Class:II
Product Code:OAS

PaloDEx Group Oy

. Street address
Nahkelantie 160 04300 Tuusula Finland

Postal address
P.O. Box 64 ● FI-04301 Tuusula
Finland

Phone
+358 10 270 2000 VAT

BI code FI19774137 1977413-7

Bank Nordea Bank SWIFT NDEAFIHH

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Image /page/4/Picture/0 description: The image shows the logo for Palodex Group. The word "Palodex" is in a large, bold, sans-serif font. The word "Group" is in a smaller, sans-serif font and is located below and to the right of "Palodex."

Description of Device

Orthopantomograph OP300 x-ray unit is a software controlled diagnostic dental X-ray equipment for producing panoramic, cephalometric and 3D images of the dentomaxillofacial complex, ENT and airway regions of the head and neck. The Orthopantomograph OP300 is available in different configurations (panoramic, cephalometric, 3D) with different 3D Field of View configurations (6X4 cm, 6X8 cm, 5X5 cm, 8X8 cm, 8X15 cm, and 13X15 cm). The components of the device include column, carriage, rotating unit (containing tube head, sensors and collimator), top-level hanger, patient head support, software for image reconstruction, and an optional software package for image reviewing. The proprietary name of the optional image reviewing software is CLINIVIEW.

Cone Beam Volumetric Tomography is a medical imaging technique that uses X-rays to obtain crosssectional images of the head or neck. The proposed device utilizes cone beam X-ray technology, which generates conical x-ray beams that rotate around the patient's head and incident upon the receptor that generate sufficiently contrasted images. Quality of the images depends on the level and amount of X-ray energy delivered to the tissue. When interpreted by a trained physician, these images provide useful diagnostic information.

Indications for Use:

| | Proposed Device
Orthopantomograph OP300 | Predicate Device
Scanora 3D
(K110839) | Predicate Device
Orthopantomograph
OP300 (K133544) |
|---------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for use | The Orthopantomograph
OP300 panoramic,
cephalometric and cone
beam computed tomography
x-ray device is intended to
image the head and neck
areas for diagnostic support.
This includes
temporomandibular Joints
(TMJs) and
dentomaxillofacial areas, and
with the 13x15 cm field of
view (FOV) this additionally
includes the ear, nose and
throat (ENT) regions. The x-
ray device produces
conventional 2D x-ray images
and x-ray projection images
for the reconstruction of a 3D
view. The device is operated
and used by qualified
healthcare professionals. | Scanora 3D is a Cone
Beam 3D x-ray system for
imaging the head and neck
areas, including the ENT
and dentomaxillofacial
areas, for use in diagnostic
support. Dedicated
panoramic imaging is an
option. A flat panel
detector is used to acquire
3D images and an optional
CCD sensor to acquire
panoramic images. The
device is operated and
used by qualified
healthcare professionals. | The OP300 dental
panoramic, cephalometric
and cone beam computed
tomography x-ray device
is intended for dental
radiographic examination
of teeth, jaw and TMJ
areas by producing
conventional 2D x-ray
images as well as x-ray
projection images of an
examined volume for the
reconstruction of a 3D
view. The device is
operated and used by
qualified healthcare
professionals. |

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Image /page/5/Picture/0 description: The image shows the text "Palodex Group". The word "Palodex" is in a larger font size and is placed above the word "Group". The word "Group" is in a smaller font size and is placed to the right of the word "Palodex".

Technological Characteristics Comparison

Proposed DevicePredicate DevicePredicate Device
Orthopantomograph OP300Scanora 3D (K110839)Orthopantomograph OP300 (K133544)
Imaging modesPanoramic, Cephalometric, TMJ 3DPanoramic, TMJ 3DPanoramic, Cephalometric TMJ 3D
x-ray source3D mode: 90kV
Pan mode: 57-90 kV
Ceph mode: 60-90 kV
kV accuracy: +/-5kV
mA range: 3.2-16 mA
3D power mode: pulsed3D mode: 85 kV
Pan mode: 60-81 kV
kV accuracy:+/-5 kV
mA range: 1-8 mA
Power mode: pulsed3D mode: 90kV
Pan mode: 57-90 kV
Ceph mode: 60-90 kV
kV accuracy: +/-5kV
mA range: 3.2-16 mA
3D power mode: pulsed
Focal spot0.5mm0.5 mm0.5mm
Image detector(s)CMOS Flat Panel + CMOS for pan/ceph imagingCMOS Flat Panel + CCD for panoramic imagingCMOS Flat Panel + CMOS for pan/ceph imaging
3D imaging techniqueReconstruction from 2D imagesReconstruction from 2D imagesReconstruction from 2D images
3D's Field Of View40 x 60 mm
50 x 50 mm
61 x 78 mm
78 x 78 mm
78 x 150 mm
130 x 150 mm50 x 50 mm
60 x 60 mm
75 x 100 mm
75 x 145 mm
130 x 145 mm40 x 60 mm
50 x 50 mm
61 x 78 mm
78 x 78 mm
78 x 150 mm
130 x 150 mm
Available 3D ProgramsField of ViewResolutionField of ViewResolutionField of ViewResolution
40 x 60 mm
50 x 50 mmLow Dose, Standard, High, Endo50 x 50 mm
60 x 60 mm
75 x 100 mm
75 x 145 mm
130 x 145 mmStandard, High40 x 60 mm
50 x 50 mmLow Dose, Standard, High, Endo
61 x 78 mm
78 x 78 mm
78 x 150 mm
130 x 150 mmLow Dose, Standard, High61 x 78 mm
78 x 78 mm
78 x 150 mm
130 x 150 mmLow Dose, Standard, High
3D's total viewing angle212 degrees360 degrees200 degrees
Pixel sizeCMOS flat panel for 3D: 200 μm
CMOS for panoramic imaging: 100 μmCMOS Flat panel for 3D: 200 μm
CCD for panoramic imaging: 96 μmCMOS flat panel for 3D: 200 μm
CMOS for panoramic imaging: 100 μm
Voxel size85-420 μm133-350 μm85-420 μm

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Image /page/6/Picture/0 description: The image shows the words "Palodex Group" in black font. The word "Palodex" is on the top line and is in a larger font than the word "Group" which is on the second line. The word "Group" is slightly offset to the right.

| Reconstruction
technique | Filtered Back Projection
(FBP) or
Algebraic Reconstruction
Technique (ART) | Filtered Back Projection
(FBP) or
Algebraic Reconstruction
Technique (ART) | Filtered Back Projection
(FBP) or
Algebraic Reconstruction
Technique (ART) |
|---------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|
| 3D's effective
exposure time | 1.2 - 12.6 sec | 2.25 - 6 sec | 1.2 - 12.5 sec |
| 3D reconstruction
time | 1-3 min | 1 - 5 min | 1-3 min |
| Software Version | OP300 Firmware: 1.28
OP300 GUI: 1.9 | Not Known | OP300 Firmware: 1.21
OP300 GUI: 1.9 |
| Patient's position | Standing and wheelchair | Sitting | Standing and wheelchair |
| System footprint | H161-241cm x D1390cm x
W97-193 cm | H 196 cm
D 110 cm
W 154 cm | H161-241cm x D1390cm x
W97-193 cm |

The proposed Orthopantomograph OP300 also shares the same architectural components and principle of operation as the predicate device Scanora 3D (K110839) including:

  • An X-ray source on a motorized rotating unit a.
  • b. Collimation of X-ray
  • 2D and 3D image detection C.
  • Image reconstruction techniques ರ.
  • Interfaces to 2D and 3D (3rd party) image acquisition software e.

The technical characteristics of the proposed device and predicate devices, including imaging technology, available Field of Views, technical resolution and other basic technological characteristics are substantially equivalent. Differences in technical characteristics are so small that they do not have any effect on the device performance in practice. As evidenced through the design verification and validation, the proposed Orthopantomograph OP300 can produce 3D images of the maxillofacial (including ENT and airway) areas and the images are of equivalent diagnostic quality as the images with the predicate device Scanora 3D. The slightly bigger Field-of-View of the proposed Orthopantomograph OP300 compared to predicate device Scanora 3D does not neqatively affect imaging of the intended anatomical structures and does not affect substantial equivalence of the device.

Non-Clinical Performance Data

As part of the design control activities, the Orthopantomograph OP300 device has successfully passed design verification and validation. The substantial equivalence of the proposed Orthopantomograph OP300 for the proposed indications for use has been substantiated via an image comparison study of predicate device Scanora 3D and proposed device Orthopantomograph OP300 images from ENT, airway and maxillofacial areas.

Biocompatibility evaluation was conducted on patient contacting accessory parts and their material and found to be in conformance with ISO 10993-5 and ISO 10993-10.

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Image /page/7/Picture/0 description: The image shows the words "Palodex Group" in black font. The word "Palodex" is on the top line and is in a larger font than the word "Group" which is on the second line. The word "Group" is slightly offset to the right compared to the word "Palodex".

EMC and Electrical Safety testing were performed by 30 party test house and found to meet all the requirements in standards IEC 60601-1: 2005. IEC 60601-1-6:2013. IEC 62366:2014. IEC 60601-2-63:2012. IEC 60601-2-28:2010. IEC 60601-1-2:2007. and IEC 60601-1-3:2013.

Clinical Performance Data:

Clinical images acquired using Orthopantomograph OP300 were reviewed by qualified clinicians to be of acceptable quality for the proposed indications for use.

Conclusion as to Substantial Equivalence

The indications for use for the proposed device Orthopantomograph OP300 include imaging of head and neck, and ENT. The proposed device has been verified and validated to satisfy the requirements derived from the proposed indications for use. Indications for use of proposed device Orthopantomograph OP300 including imaging of head and neck, and ENT are similar to predicate device Scanora 3D (K110839). As evidenced through the design verification and validation, the proposed Orthopantomograph OP300 can produce 3D images of the maxillofacial (including ENT) areas and the images are of equivalent diagnostic quality as the images with the predicate device Scanora 3D.

Based on the comparison of intended use, principles of operation, technological characteristics, nonclinical and clinical performance data, the minor differences between the proposed Orthopantomograph OP300 with expanded indications for use, and the predicate devices. Scanora 3D (K110839) and Orthopantomograph OP300 (K133544), do not raise new concerns regarding safety and effectiveness for the proposed indications of use. We conclude that the proposed device Orthopantomograph OP300 is substantially equivalent to the predicate devices.