(138 days)
The device is designed to perform general radiography x-ray examinations on all pediatric and all adult patients, in all patient treatment areas.
Treatment areas are defined as professional health care facility environments where operators with medical training are continually present during patients' examinations.
The ModelOne mobile X-ray system is a diagnostic mobile x-ray system utilizing digital radiography technology. The device consists of a self-contained x-ray generator, image receptor(s), imaging display and software for acquiring medical diagnostic images both inside and outside of a standard stationary x-ray room. The ModelOne system incorporates a flat-panel(s) detector that can be used wirelessly for exams as in-bed projections. The system is intended to be marketed with two options with flat-panel digital images from Canon and Konica Minolta.
Based on the provided text, the device is an X-ray system, and the "study" described is a non-clinical performance evaluation rather than a traditional clinical study with human patients. The information provided is for regulatory clearance (510(k) summary) rather than a comprehensive research paper on AI performance.
Therefore, many of the typical acceptance criteria and study details for an AI/ML device (e.g., ground truth establishment for a test set, MRMC studies, standalone AI performance) are not applicable or not provided in this document. The device is a mobile X-ray system, not an AI-powered diagnostic tool. The focus is on the safety and performance of the hardware and integrated previously-cleared digital imagers, demonstrating substantial equivalence to a predicate device.
Here's an attempt to answer the questions based only on the provided text, noting where information is absent or not relevant for this type of device:
Acceptance Criteria and Device Performance (Non-AI X-ray System)
The document describes performance tests for a mobile X-ray system, NOT an AI/ML device. The acceptance criteria are implicit in the performance tests verifying the functionality and safety of the hardware. The "reported device performance" refers to the successful completion of these non-clinical tests.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Test/Evaluation | Reported Device Performance |
|---|---|---|
| Usability | Acceptance test on customer site | "Performance tests confirm that the device is as effective and performs as well as or better than the predicate device." (Implies meeting usability expectations) |
| Performance test at hospital by professional personnel | "Performance tests confirm that the device is as effective and performs as well as or better than the predicate device." (Implies meeting usability expectations) | |
| Battery Performance | Beginning of life/end of life test | "Performance tests confirm that the device is as effective and performs as well as or better than the predicate device." (Implies battery life meets operational needs) |
| Mobility | Driving distance test (full to empty battery) | "The driving distance test was performed to verify maximum distance of driving from full to empty battery." (Implies meeting or exceeding required driving distance for mobile operation) |
| Generator Performance | Comparison of exposure time with competitors | "The aim of generator performance test was to compare the time of exposure of !M1 and its competitors." (Implies competitive or equivalent exposure times, contributing to "performs as well as or better than the predicate device.") |
| System Integration | Integration test with previously cleared flat-panel imagers | "Integration test was performed on the previously cleared flat-panel digital imagers in order to demonstrate that all components of the device function in a reproductive way according to the design specifications." (Confirms successful integration and functional operation of the complete system) |
| Software Risk | Software risk classification | "The software risk is classified as moderate level of concern device according to the Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." (Acceptance is compliance with software risk guidelines, not a performance metric in this context, but a regulatory requirement met) |
| Safety | Overall safety assessment | "Technological differences do not raise questions of safety and the device is as safe as legally marketed DRX-Revolution by Carestream." (Overall safety acceptance based on non-clinical tests and comparison to predicate) |
2. Sample Size for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated in terms of number of "cases" or "patients" as this is a device performance test, not a clinical study on diagnostic accuracy. The tests involve the device itself and its components.
- Data Provenance: The tests are "non-clinical testing" and performed on the device hardware. Usability tests involved "professional personal" at a "hospital," but this is for evaluating the device's operation in a real-world setting, not an evaluation of diagnostic output. It's a "retrospective" view of testing results provided to the FDA.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Not Applicable / Not Provided. This document describes a mobile X-ray system, not an AI/ML diagnostic algorithm that requires expert-established ground truth for image interpretation. The "ground truth" here is the device's functional performance against its design specifications and compared to a predicate, not clinical diagnostic accuracy.
4. Adjudication Method for the Test Set
- Not Applicable / None. No adjudication method is mentioned as this is not a study assessing human or AI diagnostic performance based on image interpretation.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. "No clinical testing was performed on the subject device." Therefore, no MRMC study was conducted to evaluate human readers with or without AI assistance.
6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance
- Not Applicable / No. The device itself is an X-ray imaging system. It produces images, but the document does not describe a new AI algorithm for interpreting those images. The "software" mentioned is for acquiring and displaying images, and its risk is classified. The post-processing is defined by protocols from previously cleared Canon and Konica Minolta image software.
7. Type of Ground Truth Used
- Functional Performance Specifications and Predicate Comparison. The "ground truth" for this regulatory submission is that the device functions according to its design specifications (e.g., battery life, driving distance, exposure time) and performs "as well as or better than the predicate device" in non-clinical settings.
8. Sample Size for the Training Set
- Not Applicable. This is not an AI/ML algorithm that requires a training set of data.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As above, no AI/ML training set is mentioned or implied.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 17, 2017
Solutions for tomorrow AB % Mr. Martin Yngvesson COO Saxagardsv. 4 Vackelsang, 36251 Kronoberg SWEDEN
Re: K170607
Trade/Device Name: !M1 Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Code: IZL Dated: June 19, 2017 Received: June 19, 2017
Dear Mr. Yngvesson:
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
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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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
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
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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)
Device Name !M1
(
Indications for Use (Describe)
The device is designed to perform general radiography x-ray examinations on all pediatric and all adult patients, in all patient treatment areas.
Treatment areas are defined as professional health care facility environments where operators with medical training are continually present during patients' examinations.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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"510(k) Summary"
| 510(k) Owner Name: | Solutions for tomorrow AB |
|---|---|
| 510(k) Owner Address: | Saxagårdsvägen 4362 51 Väckelsång |
| 510(k) Owner Phone: | +46-(0)10 4564500 |
| Contact Person & Info: | Mattias GuldstrandCEOmattias@solutionsfortomorrow.se+46 70 299 6943 |
| Date Summary Prepared: | January 31, 2017 |
| Device Trade Name: | !M1 |
| Device Common Name: | mobile x-ray system |
| Classification Name: | System, X-ray, Mobile |
| Regulation Number: | 21 CFR 892.1720 |
| Device Class: | Class II |
| Product Code: | IZL |
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| Predicate Device: | Carestream DRX-Revolution |
|---|---|
| Manufactured by: | Carestream Health, Inc. |
| 510(k) Number: | K120062 (January 5, 2011) |
| Device Trade Name: | DRX-Revolution Mobile X-ray System |
| Device Common Name: | mobile x-ray system |
| Classification Name: | System, X-ray, Mobile |
| Regulation Number: | 21 CFR 892.1720 |
| Device Class: | Class II |
| Product Code: | IZL |
Device Description
The ModelOne mobile X-ray system is a diagnostic mobile x-ray system utilizing digital radiography technology. The device consists of a self-contained x-ray generator, image receptor(s), imaging display and software for acquiring medical diagnostic images both inside and outside of a standard stationary x-ray room. The ModelOne system incorporates a flat-panel(s) detector that can be used wirelessly for exams as in-bed projections. The system is intended to be marketed with two options with flat-panel digital images from Canon and Konica Minolta. The flat-panel digital imagers have been previously cleared with the following:
- K133693 Digital Radiography CXDI-401C Wireless (Canon)
- K131106 Digital Radiography CXDI-701C Wireless (Canon)
Digital Radiography CXDI-701G Wireless
Digital Radiography CXDI-801C Wireless
Digital Radiography CXDI-801G Wireless
- K102349 AeroDR SYSTEM (Konica Minolta)
- K113248 AeroDR SYSTEM with P-21 (Konica Minolta)
- K130936 AeroDR SYSTEM with P-31 (Konica Minolta)
- K141271 AeroDR SYSTEM 2 (Konica Minolta)
- K162504 -SKR 3000 (Konica Minolta)
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Indications for Use / Intended Use:
The Indications for Use for the device, as described in its labeling, are:
"The device is designed to perform general radiography X-ray examinations on all paediatric and all adult patients, in all patient treatment areas".
Note
The patient subpopulations are identified by weight. The equipment settings for routinely performed examinations for those populations can be found in User Manual, section Exposure parameters. However, the image post-processing is defined in protocols from Konica Minolta and Canon image software that have been already approved by FDA.
Comparison of Technological Characteristics
The !M1 Mobile X-ray System is substantially equivalent to the predicate device, the DRX-Revolution Mobile X-ray System manufactured by Carestream Health, Inc. The !M1 and DRX-Revolution system both consist of an x-ray generator, x-ray tube, collimator and graphical user interface on an operator console with touch screen monitor. These components are mounted on a motorized cart that is battery powered to enable the device to be moved from location to location. Both systems utilize digital flat panel detector for image capture.
Discussion of Testing
Non-clinical testing
The performance characteristics and operation of !M1 were evaluated in non-clinical testing. Performance tests include the following: usability test, battery performance, driving distance and generator performance test. The usability test includes the acceptance test performed on the customer site and performance test that has been done at the hospital by professional personal. Battery performance tests consists of beginning of life/end of life test. The driving distance test was performed to verify maximum distance of driving from full to empty battery. The aim of generator performance test was to compare the time of exposure of !M1 and its competitors.
Integration test was performed on the previously cleared flat-panel digital imagers in order to demonstrate that all components of the device function in a reproductive way according to the design specifications.
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Performance tests confirm that the device is as effective and performs as well as or better than the predicate device. The software risk is classified as moderate level of concern device according to the Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices. Technological differences do not raise questions of safety and the device is as safe as legally marketed DRX-Revolution by Carestream.
Clinical testing
No clinical testing was performed on the subject device, and performance testing listed in the "Non-Clinical Testing" section was sufficient to demonstrate substantial equivalence.
§ 892.1720 Mobile x-ray system.
(a)
Identification. A mobile x-ray system is a transportable device system intended to be used to generate and control x-ray for diagnostic procedures. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.