K Number
K170085
Device Name
SONON Ultrasound Imaging System, Model: 300L
Date Cleared
2017-10-12

(275 days)

Product Code
Regulation Number
892.1550
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The SONON Ultrasound Imaging System (Model: 300L) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including musculoskeletal (MSK), vascular, small parts (breast, thyroid), and thoracic/pleural motion and fluid detection imaging.
Device Description
The SONON Ultrasound Imaging System, Model: 300L, is a wireless ultrasound system that uses pulsed-echo/Doppler technology (Color Flow Doppler (CF Mode)/B Mode (2D): frequency: 5 MHz/7.5 MHz/10 MHz; module: linear; depth max: 10 cm) to transmit ultrasound images via wireless communication to a mobile device that utilizes the iOS or Android operating system. The SONON Ultrasound Imaging System is a portable, general-purpose, software-controlled, hand-held diagnostic ultrasound system that consists of (i) a commercial off-the-shelf iOS or Android mobile device, (ii) the SONON Ultrasound Imaging System software that runs as an app on the mobile device, (iii) the battery-operated, hand-held SONON Ultrasound Imaging System transducer that communicates wirelessly with iOS or Android mobile devices, and (iv) the instructions for use manual, battery, charger, and power cords. The SONON software can be downloaded to an iOS or Android mobile device and utilizes an icon touch-based user interface. The software enables ultrasound image capture and review, controls for time gain, dynamic range, display of mirror image, focal length, depth, brightness, contrast, linear/elliptical measurement, color flow, and image annotation, as well as storage and email transmission of images and videos. The SONON Ultrasound Imaging System allows the user to image in real time and review cine or freeze-frame images on the screen in a Color Flow Doppler/B-Mode, 2-dimensional scan format. The SONON Ultrasound Imaging System utilizes pulsed-echo/Doppler technology to determine the depth and location of tissue interfaces, and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. Ultrasound waves are emitted from the transducer, propagate through tissues, and return to the transducer as reflected echoes. The returned echoes are then converted into electrical impulses by transducer crystals and further processed in order to form the ultrasound image presented on the screen.
More Information

No
The summary describes standard ultrasound technology and image processing, with no mention of AI, ML, or related concepts like deep learning, neural networks, or algorithms that learn from data.

No
Explanation: The device is intended for diagnostic imaging, measurement, and analysis, not for treatment or therapy.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states, "The SONON Ultrasound Imaging System (Model: 300L) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications." Additionally, the "Device Description" states it is a "hand-held diagnostic ultrasound system."

No

The device description explicitly states that the system consists of a battery-operated, hand-held SONON Ultrasound Imaging System transducer, in addition to the software and mobile device. This transducer is a hardware component essential for the device's function of emitting and receiving ultrasound waves.

Based on the provided information, the SONON Ultrasound Imaging System (Model: 300L) is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: An IVD device is defined as a medical device intended for use in vitro for the examination of specimens, including blood, tissue, and urine, derived from the human body, solely or principally for the purpose of providing information concerning a physiological or pathological state, or concerning a congenital abnormality, or to determine the safety and compatibility with potential recipients, or to monitor therapeutic measures.
  • SONON's Intended Use: The SONON Ultrasound Imaging System is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body. This involves using ultrasound waves to create images of internal structures in vivo (within the living body), not examining specimens in vitro (outside the body).
  • Device Description: The description clearly outlines a system that uses a transducer to transmit and receive ultrasound waves directly from the patient's body.
  • Anatomical Sites: The indicated anatomical sites (musculoskeletal, vascular, small parts, thoracic/pleural) are all internal structures within the human body.

Therefore, the SONON Ultrasound Imaging System is a diagnostic imaging device that operates in vivo, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The SONON Ultrasound Imaging System (Model: 300L) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including musculoskeletal (MSK), vascular, small parts (breast, thyroid), and thoracic/pleural motion and fluid detection imaging.

Product codes

IYN, IYO, ITX

Device Description

The SONON Ultrasound Imaging System, Model: 300L, is a wireless ultrasound system that uses pulsed-echo/Doppler technology (Color Flow Doppler (CF Mode)/B Mode (2D): frequency: 5 MHz/7.5 MHz/10 MHz; module: linear; depth max: 10 cm) to transmit ultrasound images via wireless communication to a mobile device that utilizes the iOS or Android operating system.

The minimum requirements for the mobile devices that utilize the iOS or Android operating system for use with the SONON Ultrasound Imaging System. Model: 300L are as follows:
Item: Target Device
Minimum requirements: iPad Air / iPad Air 2/ iPad Mini 2 / iPad Mini 3 / iPad Mini 4; iPhone 5S, 6, 6 plus, 6S, 6S plus; Galaxy S5 / S6 / Note 3, Note 4 or later; Galaxy Note Tablet 10.1 2013 version or later; Galaxy Tab Pro 8.4 2014 version or later
Item: Mobile OS Version
Minimum requirements: iOS 9.0 or later; Android 4.3 or later

The SONON Ultrasound Imaging System is a portable, general-purpose, software-controlled, hand-held diagnostic ultrasound system that consists of (i) a commercial off-the-shelf iOS or Android mobile device, (ii) the SONON Ultrasound Imaging System software that runs as an app on the mobile device, (iii) the battery-operated, hand-held SONON Ultrasound Imaging System transducer that communicates wirelessly with iOS or Android mobile devices, and (iv) the instructions for use manual, battery, charger, and power cords.

The SONON software can be downloaded to an iOS or Android mobile device and utilizes an icon touch-based user interface. The software enables ultrasound image capture and review, controls for time gain, dynamic range, display of mirror image, focal length, depth, brightness, contrast, linear/elliptical measurement, color flow, and image annotation, as well as storage and email transmission of images and videos. The SONON Ultrasound Imaging System allows the user to image in real time and review cine or freeze-frame images on the screen in a Color Flow Doppler/B-Mode, 2-dimensional scan format. All images and data collected are stored in the mobile app. If the app is removed and reinstalled, all stored information is lost and cannot be recovered.

The SONON Ultrasound Imaging System utilizes pulsed-echo/Doppler technology to determine the depth and location of tissue interfaces, and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. Ultrasound waves are emitted from the transducer, propagate through tissues, and return to the transducer as reflected echoes. The returned echoes are then converted into electrical impulses by transducer crystals and further processed in order to form the ultrasound image presented on the screen.

The device components are not supplied sterile and do not require sterilization prior to use.

Mentions image processing

Yes, "The returned echoes are then converted into electrical impulses by transducer crystals and further processed in order to form the ultrasound image presented on the screen."

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound pulsed-echo/Doppler technology

Anatomical Site

Musculoskeletal (MSK), vascular, small parts (breast, thyroid), and thoracic/pleural motion and fluid detection

Indicated Patient Age Range

For use in all patients

Intended User / Care Setting

Healthcare professionals; Hospital, clinic, and medical office settings.

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

Non-clinical performance data was relied upon. Testing for compliance with electrical safety, EMC, and RF Wireless Capabilities was conducted per international standards (IEC 60601-1, IEC 60601-1-6, IEC 60601-1-2, IEC 60601-2-37, IEC 62366, IEC 62359). Acoustic output levels were measured and calculated following NEMA UD3 and met FDA levels. Clinical Measurement Range and Accuracies were tested using a phantom, and resolutions were evaluated and met performance criteria. Display performance was assessed using various mobile devices and met specifications. A Usability Report found the product safe and effective. Failure Mode and Effects Analysis and risk analysis were conducted in accordance with ISO 14971, with all identified hazards reduced to acceptable levels. Biocompatibility testing was conducted in accordance with ISO 10993-1, and patient-contacting surfaces were found to be biocompatible. Software evaluation and cybersecurity management were conducted, and the software met performance requirements and specifications per IEC 62304. No clinical tests or animal studies were conducted.

Key Metrics

Not Found

Predicate Device(s)

K151339, K163138

Reference Device(s)

K092756

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.1550 Ultrasonic pulsed doppler imaging system.

(a)
Identification. An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. 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

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The FDA logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text. The Department of Health & Human Services logo is a stylized image of a human figure.

October 12, 2017

Healcerion Co., Ltd % Ms. Carmelina Allis Official Correspondent The Allis Law Firm, Pllc 2437 Bay Area Blvd., #30 HOUSTON TX 77058

Re: K170085

Trade/Device Name: SONON Ultrasound Imaging System (Model: 300L) Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic pulsed doppler imaging system Regulatory Class: II Product Code: IYN, IYO, ITX Dated: September 8, 2017 Received: September 13, 2017

Dear Ms. Allis:

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 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.

U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.qov

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 (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 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)

K170085

Device Name SONON Ultrasound Imaging System (Model: 300L)

Indications for Use (Describe)

The SONON Ultrasound Imaging System (Model: 300L) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including musculoskeletal (MSK), vascular, small parts (breast, thyroid), and thoracic/pleural motion and fluid detection imaging.

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)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

3

Diagnostic Ultrasound Indications for Use Form

510(k) Number: K170085
Device Name: SONON Ultrasound Imaging System (Model: 300L)
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
Clinical ApplicationMode of Operation
General
(Track 1 Only)Specific
(Tracks 1 & 3)BMPWDCWDColor
DopplerCombined
(Specify)Other*
(Specify)
OphthalmicOphthalmic
Fetal
Abdominal
Intra-operative (Specify)
Intra-operative (Neuro)
Laparoscopic
Fetal Imaging
& OtherPediatric
Small Organ (Thyroid, Breast))NN
Neonatal Cephalic
Adult Cephalic
Trans-rectal
Trans-vaginal
Trans-urethral
Trans-esoph. (non-Card.)
Musculo-skeletal
(Conventional)NN
Musculo-skeletal (Superficial)NN
IntravascularNN
Other [1]NN
Cardiac Adult
CardiacCardiac Pediatric
Intravascular (Cardiac)
Trans-esoph. (Cardiac)
Intra-cardiac
Other (Specify)
Peripheral
VesselPeripheral vesselNN
Other (Carotid)NN

N = new indication; P = previously cleared by FDA; E = added under this appendix

[1] Thoracic/Pleural Motion and Fluid Detection

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of Center for Devices and Radiological Health, Office of In Vitro Diagnostics and Radiological Health XX Prescription Use -- Yes

(Part 21 CFR 801 Subpart D)

4

510(k) Summary of Safety and Effectiveness Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

1) Submitter's name, address, telephone number; Contact person

Submitter: Jaeyeob JungContact Person: Carmelina G. Allis
RA ManagerThe Allis Law Firm, PLLC
HEALCERION Co., Ltd.2437 Bay Area Blvd., #30
804ho, 38-21, Digital-ro 31-gil,Houston, TX 77058
Guro-gu, Seoul, KoreaPh: 281-819-0216
Ph: +82 70-7569-6326Email: CAllis@TheAllisLawFirm.com
Email: onair0816@healcerion.com

October 6, 2017 Date prepared:

2) Name of the device, including the trade or proprietary name, if applicable, the common or usual name, and the classification name, if known

Device Common/Usual Name:Diagnostic Ultrasound System and Transducer
Device Proprietary Name:SONON Ultrasound Imaging System, Model: 300L
Device Classification:Class II
21 C.F.R. SectionClassification NameProduct Code
892.1550System, Imaging, Pulsed Doppler, Ultrasonic90-IYN
892.1560System, Imaging, Pulsed Echo, Ultrasonic90-IYO
892.1570Transducer, Ultrasonic, Diagnostic90-ITX

3) Substantially Equivalent Devices

Device Name510(k)
Number
SONON Ultrasound Imaging System, Model: 300C (Healcerion Co., Ltd.)K151339
Clarius Ultrasound System (Clarius Mobile Health Corp.)K163138

Healcerion is not aware of any design-related recalls regarding the predicate devices.

Reference Device:

Device Name GE Vscan-Compact Diagnostic Ultrasound System 510(k) Number K092756

None of the predicate devices include a thoracic/pleural motion and fluid detection indication. The GE Vscan device was used by Healcerion to support this indication. The performance

5

510(k) Summary of Safety and Effectiveness

Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

characteristics of the SONON 300L are comparable to those of the Vscan for this particular indication and raise no new or different questions of safety and effectiveness.

4) Device Description

The SONON Ultrasound Imaging System, Model: 300L, is a wireless ultrasound system that uses pulsed-echo/Doppler technology (Color Flow Doppler (CF Mode)/B Mode (2D): frequency: 5 MHz/7.5 MHz/10 MHz; module: linear; depth max: 10 cm) to transmit ultrasound images via wireless communication to a mobile device that utilizes the iOS or Android operating system.

The minimum requirements for the mobile devices that utilize the iOS or Android operating system for use with the SONON Ultrasound Imaging System. Model: 300L are as follows:

ItemMinimum requirements
iPad Air / iPad Air 2/ iPad Mini 2 / iPad Mini 3 / iPad Mini 4
iPhone 5S, 6, 6 plus, 6S, 6S plus
Target DeviceGalaxy S5 / S6 / Note 3, Note 4 or later
Galaxy Note Tablet 10.1 2013 version or later
Galaxy Tab Pro 8.4 2014 version or later
Mobile OS VersioniOS 9.0 or later
Android 4.3 or later

The SONON Ultrasound Imaging System is a portable, general-purpose, software-controlled, hand-held diagnostic ultrasound system that consists of (i) a commercial off-the-shelf iOS or Android mobile device, (ii) the SONON Ultrasound Imaging System software that runs as an app on the mobile device, (iii) the battery-operated, hand-held SONON Ultrasound Imaging System transducer that communicates wirelessly with iOS or Android mobile devices, and (iv) the instructions for use manual, battery, charger, and power cords.

The SONON software can be downloaded to an iOS or Android mobile device and utilizes an icon touch-based user interface. The software enables ultrasound image capture and review, controls for time gain, dynamic range, display of mirror image, focal length, depth, brightness, contrast, linear/elliptical measurement, color flow, and image annotation, as well as storage and email transmission of images and videos. The SONON Ultrasound Imaging System allows the user to image in real time and review cine or freeze-frame images on the screen in a Color Flow Doppler/B-Mode, 2-dimensional scan format. All images and data collected are stored in the mobile app. If the app is removed and reinstalled, all stored information is lost and cannot be recovered.

6

510(k) Summary of Safety and Effectiveness Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

The SONON Ultrasound Imaging System utilizes pulsed-echo/Doppler technology to determine the depth and location of tissue interfaces, and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. Ultrasound waves are emitted from the transducer, propagate through tissues, and return to the transducer as reflected echoes. The returned echoes are then converted into electrical impulses by transducer crystals and further processed in order to form the ultrasound image presented on the screen.

The device components are not supplied sterile and do not require sterilization prior to use.

5) Indications for Use

The SONON Ultrasound Imaging System (Model: 300L) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including musculoskeletal (MSK), vascular, small parts (breast, thyroid), and thoracic/pleural motion and fluid detection imaging.

6) Technological Comparison to Predicate Devices

The SONON Ultrasound Imaging System and its predicate devices, the 300C and Clarius ultrasound systems, are Track 3 systems that employ the same basic scientific technology for the acquisition and display of ultrasound images. They all operate in the same manner in that piezoelectric material in the transducer is used as a source to transmit sound waves into the body. Sound waves are reflected back to the transducer and converted to electrical signals that are processed and displayed as 2-dimensional images. The SONON Ultrasound Imaging System and the predicate devices allow for the visualization and measurement of body structures. All devices are intended to be used in clinical environments, including hospitals, clinics, and medical office settings, for the diagnosis of patients.

All devices are compact, portable, general-purpose, software-controlled diagnostic ultrasound imaging systems with hand-held probes. The SONON Ultrasound Imaging System and all predicates utilize wireless network connectivity to run software and display images. All devices have the same intended use.

The patient-contacting surfaces of the subject and predicate devices have been found to be biocompatible for their intended application. The SONON Ultrasound Imaging System is manufactured and designed to the same electrical and safety standards as the predicate devices.

7

510(k) Summary of Safety and Effectiveness

Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

The SONON Ultrasound Imaging System display ranges from 4 to 10 inches depending on whether a mobile phone or tablet is used. This is similar to the range of display options available for the predicate devices.

Comparison of Technological Characteristics with Predicate Devices
New DevicePredicate DevicePredicate Device
CharacteristicHealcerion Co., Ltd.
SONON Ultrasound Imaging
System (Model 300L)
K170085Healcerion Co., Ltd.
SONON Ultrasound Imaging
System (Model 300C)
K151339Clarius Mobile Health Corp.
Clarius Ultrasound System
K163138
Intended
Use/Indications for
UseIntended for ultrasound echo
imaging, measurement, and
analysis of the human body for
general clinical applications
including musculoskeletal
(MSK), vascular, small parts
(breast, thyroid), and
thoracic/pleural motion and fluid
detection imaging.Intended for diagnostic ultrasound
echo imaging, measurement, and
analysis of the human body for
general clinical applications
including obstetrics (OB),
gynecology (GY) and general
(abdominal) imaging.Indicated for use in point-of-care
imaging of medical conditions on the
general public, including: emergency
triage exam to look at trauma
conditions; procedure guidance to
guide needles into the body; and other
applications (fetal, fetal echo,
abdominal, small organ, musculo-
skeletal (conventional), musculo-
skeletal (superficial), urology,
gynecology, cardiac adult, cardiac
pediatric, peripheral vessel, pediatric,
carotid). Not intended for emergency
medical service, ambulance or aircraft;
only for use by trained professionals.
Environment of UseHospital, clinic, and medical
office settingsHospital, clinic, and medical
office settingsHospital, clinic, and medical office
settings
Acoustic Output
LevelsBelow Track 3 FDA limits in
accordance with Sept. 2008
ultrasound systems guidance
documentBelow Track 3 FDA limits in
accordance with Sept. 2008
ultrasound systems guidance
documentBelow Track 3 FDA limits in
accordance with Sept. 2008 ultrasound
systems guidance document
Imaging Capabilities• pulsed-echo and Doppler
ultrasound
• Mode B (2D), Color scan• pulsed-echo ultrasound
• Mode B (2D) scan• pulsed-echo and Doppler
ultrasound
• Mode B (2D) scan
Patient PopulationFor use in all patientsFor use in all patientsFor use in all patients
Anatomic
Structures/Clinical
applicationsGeneral clinical applications,
including musculoskeletal
(MSK), vascular, small parts
(breast, thyroid) and
thoracic/pleural motion and fluid
detectionGeneral clinical applications,
including fetal/obstetrics,
gynecology, abdominalGeneral clinical applications,
including, but not limited to fetal,
abdominal, small organ, musculo-
skeletal (conventional, superficial),
urology, gynecology, cardiac
adult/pediatric, peripheral vessel,
pediatric, carotid
UsersHealthcare professionalsHealthcare professionalsHealthcare professionals
Principle/Method of
OperationPiezoelectric material in the
transducer is used as an
ultrasound source to transmit
sound waves into the body.
Sound waves are reflected back
to the transducer and converted
to electrical signals that are
processed and displayed as
images of anatomic structures.Piezoelectric material in the
transducer is used as an ultrasound
source to transmit sound waves
into the body. Sound waves are
reflected back to the transducer
and converted to electrical signals
that are processed and displayed
as images of anatomic structures.Piezoelectric material in the transducer
is used as an ultrasound source to
transmit sound waves into the body.
Sound waves are reflected back to the
transducer and converted to electrical
signals that are processed and
displayed as images of anatomic
structures.
New DevicePredicate DevicePredicate Device
CharacteristicHealcerion Co., Ltd.
SONON Ultrasound Imaging
System (Model 300L)
K170085Healcerion Co., Ltd.
SONON Ultrasound Imaging
System (Model 300C)
K151339Clarius Mobile Health Corp.
Clarius Ultrasound System
K163138
Image Display UnitMobile device (4 to 10 inches
approximately)Mobile device (4 to 10 inches
approximately)Mobile device (4 to 10 inches
approximately)
Probe CharacteristicsLinear, 5MHz / 7.5MHz /
10MHz frequencyConvex, 3.5 MHz frequencyC3 convex (Frequency: 2-6 MHz;
Depth: 3-30 cm), L7 linear (Frequency:
4-13 MHz; Depth: 1-7 cm)
Probe Connection to
DisplayWirelessWirelessWireless
Off-the-shelf
operating systemiOS / AndroidiOS / AndroidiOS / Android
SoftwareRuns as an app on off-the-shelf
mobile deviceRuns as an app on off-the-shelf
mobile deviceRuns as an app on off-the-shelf mobile
device
System ComponentsCommercial off-the-shelf iOS or Android mobile device SONON Ultrasound Imaging System software that runs as an app on the mobile device SONON Ultrasound Imaging System battery-operated, hand-held ultrasound diagnostic transducer that communicates wirelessly with iOS or Android mobile devicesCommercial off-the-shelf iOS or Android mobile device SONON Ultrasound Imaging System software that runs as an app on the mobile device SONON Ultrasound Imaging System battery-operated, hand-held ultrasound diagnostic transducer that communicates wirelessly with iOS or Android mobile devicesCommercial off-the-shelf iOS or Android mobile device Imaging software that runs as an app on the mobile device Battery-operated, hand-held ultrasound diagnostic transducer that communicates wirelessly with iOS or Android mobile devices
Patient-Contacting
MaterialsAll patient-contact materials are
biocompatible and can be
disinfectedAll patient-contact materials are
biocompatible and can be
disinfectedAll patient-contact materials are
biocompatible and can be disinfected

Comparison of Technological Characteristics with Predicate Devices

8

510(k) Summary of Safety and Effectiveness

Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

7) Determination of Substantial Equivalence

The SONON Ultrasound Imaging System is substantially equivalent to the predicate devices identified above with respect to intended use, principles of operation, and technological characteristics. As described below, the system has been evaluated for acoustic output, biocompatibility, cleaning and disinfection effectiveness, and thermal, electrical, and mechanical safety, and has been found to conform to applicable standards and product specifications that demonstrate that the SONON Ultrasound Imaging System is substantially equivalent to the predicate devices.

The GE Vscan device was used by Healcerion as a reference device to support the thoracic/pleural motion and fluid detection indication. The performance characteristics of the SONON 300L are comparable to those of the Vscan for this particular indication and raise no new or different questions of safety and effectiveness.

9

510(k) Summary of Safety and Effectiveness

Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

Non-clinical performance data

Non-clinical tests relied on this premarket notification submission for a determination of substantial equivalence include testing showing compliance with the following standards.

Electrical safety, EMC, and RF Wireless Capabilities

Electrical safety, electromagnetic compatibility, and RF wireless capabilities were evaluated per international standards and the device complies with the following standards:

  • . IEC 60601-1: Medical Electrical Equipment - General Requirements for Basic Safety and Essential Performance
  • I IEC 60601-1-6: Medical Electrical Equipment - General Requirements for Safety -Collateral Standard: Usability
  • 트 IEC 60601-1-2: Medical Electrical Equipment - Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Compatibility -Requirements and Tests
  • IEC 60601-2-37: Medical electrical equipment - Part 2-37: Particular requirements for the basic safety and essential performance of ultrasonic medical diagnostic and monitoring equipment
  • 트 IEC 62366: Medical devices - Application of usability engineering to medical devices
  • 트 IEC 62359: Ultrasonics – Field Characterization – Test Methods for the Determination of Thermal and Mechanical Indices Related to Medical Diagnostic Ultrasonic Fields

Acoustic Output Levels

The acoustic output exposure levels were measured and calculated following the NEMA UD3, Acoustic Output Measurement Standard for Diagnostic Ultrasound Equipment Revision 3 and met FDA levels.

Clinical Measurement Range and Accuracies

Clinical Measurement Range and Accuracies were tested using a phantom. Resolutions were evaluated and results met performance criteria.

Display Performance Testing

The SONON Ultrasound Imaging System (Model: 300L) displays ranges from 4 to 10 inches depending on whether a mobile phone or tablet is used. This is similar to the range of display options available for the predicate devices. The display performance of the device was assessed using various mobile devices, and the test results demonstrate that the device meets performance specifications.

Usability Report

The usability engineering process was conducted by Healcerion to assess and mitigate risks caused by usability problems associated with the correct use of the device as well as user errors. The test results demonstrate that the product has been found to be reasonably safe and effective for the intended users, intended uses, and intended use environments through usability engineering process.

10

510(k) Summary of Safety and Effectiveness Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

Failure Mode and Risk Analyses

Healcerion conducted a Failure Mode and Effects Analysis and a risk analysis in accordance with ISO 14971. The risk analysis of 300L was performed by taking into account the risks of the device, such as design, production, storage, related international standards, state of art of risk management, and the foreseeable risks related to the intended use of the device. The hazards were identified, the risks were estimated, and procedures were implemented to control them. All identified hazards were reduced to acceptable levels.

Biocompatibility

Biocompatibility testing was conducted in accordance with the international standard below. The patient-contacting surfaces of the device (probe nosepiece and lens) were evaluated for cytotoxicity, skin irritation and skin sensitization and are all identical to the predicate device 300C. Test results demonstrate that the patient-contacting surfaces of the probe are biocompatible in accordance with the following standard:

  • 트 ISO 10993-1: Biological Evaluation of Medical Devices

Software Evaluation and Cybersecurity Management

Furthermore, Healcerion conducted validation and verification activities on the SONON Ultrasound Imaging System software. Cybersecurity evaluation was also conducted. The software passed its performance requirements and met specifications per the following standard:

  • IEC 62304: Medical Device Software Software Life-Cycle Processes ■

Additional Standards

Healcerion also relied on the following standards to ensure the substantial equivalence of the SONON Ultrasound Imaging System to predicate devices:

  • I ISO 14971: Application of Risk Management to Medical Devices
  • 트 ISO 15223-1: Symbols to be used with Medical Device Labels

Healcerion applied quality assurance measures to the system design and development, including, but not limited to:

  • 트 Risk Analysis
  • Product Specifications
  • Design Reviews
  • 트 Verification and Validation Activities

Clinical tests and animal studies - not conducted

The Healcerion SONON Ultrasound Imaging System ultrasound system does not introduce new indications for use, modes, features, or technologies relative to the predicate devices that would require evaluation through clinical or animal testing. The clinical safety and effectiveness of

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510(k) Summary of Safety and Effectiveness

Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: 300L

ultrasound systems with characteristics similar to those of the 300L are well accepted for the predicate and subject devices.

8) Conclusion

In conclusion, the tests conducted, as well as all verification and validation activities. demonstrate that the design specifications and technological characteristics of the SONON Ultrasound Imaging System (Model: 300L) meet applicable requirements and standards for the safety and effectiveness of the device for its intended use. There are some differences in technological characteristics between the predicate, reference, and proposed devices, but those differences only indicate that the predicate and reference devices may have secondary or different functionalities as compared to the SONON Ultrasound Imaging System, such as additional probe models or imaging capabilities. The testing and validation activities conducted demonstrate that any differences between the devices do not raise new or different questions of safety or effectiveness as compared to the predicate and reference devices. Therefore, the SONON Ultrasound Imaging System (Model: 300L) is substantially equivalent to legally marketed devices.