(239 days)
No
The summary describes a standard mobile C-arm X-ray system with image display, storage, and manipulation capabilities. There is no mention of AI, ML, deep learning, or any related concepts in the intended use, device description, or performance studies. The performance studies focus on standard electrical, radiation, and imaging performance metrics, not AI/ML performance metrics like AUC or sensitivity/specificity derived from an AI model.
No.
The device is used to provide images during diagnostic, surgical, and interventional procedures, but it does not directly provide therapy.
Yes
The "Intended Use / Indications for Use" section explicitly states that the device is "intended to provide Fluoroscopic and Radiographic images of the patient during Diagnostic, Surgical and Interventional procedures." The word "Diagnostic" directly indicates its use for diagnosis.
No
The device description explicitly states it is a "mobile X-Ray C-Arm fluoroscopic device" consisting of a "Mobile Image Intensified C-Arm unit with generator" and a "Work-Station for Image display, store and manipulation." This clearly indicates the presence of significant hardware components beyond just software.
Based on the provided information, the Skan-C is not an IVD (In Vitro Diagnostic) device.
Here's why:
- IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information about a person's health. This testing is done outside the body (in vitro).
- Skan-C Function: The Skan-C is an X-ray system that provides images of the patient's body during procedures. It uses radiation to create images of internal structures. This is an in vivo imaging technique, not an in vitro diagnostic test.
The description clearly states its purpose is to provide images of the patient during various medical procedures, which is the function of an imaging device, not an IVD.
N/A
Intended Use / Indications for Use
The Skan-C, a Mobile Surgical C-Arm X-Ray System, is intended to provide Fluoroscopic and Radiographic images of the patient during Diagnostic, Surgical and Interventional procedures.
Examples of Clinical Applications may include Orthopaedic. GI Procedure like Endoscopy and Cholenography. Neurology, Urology Procedures, Vascular, Critical Care and Emergency Room Procedures.
Skan-C is not recommended for Cardiac Applications.
Skan-C Surgical C-Arm is indication in real time and/or recording of surgical region of interest and anatomy, using X-ray imaging technique.
Product codes (comma separated list FDA assigned to the subject device)
OXO, OWB
Device Description
SKAN-C, is a mobile X-Ray C-Arm fluoroscopic device to assist in quiding medical intervention surgical procedures. The device can also be used for radiographic applications. The device is designed in such a way that it can be moved around and can be positioned for the required anatomical/clinical/procedural position.
SKAN-C, a Mobile Surgical C-Arm consists of two units, namely, Mobile Image Intensified C-Arm unit with generator, and a Work-Station for Image display, store and manipulation. C-Arm unit with generator is capable of movements which are essential for patient positioning, like horizontal travel, orbital movement, wig-wag movement and C rotation. The X-ray generator, X-Ray control system and collimator controls are housed in the C-Arm unit.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
X-ray
Anatomical Site
Not Found
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Diagnostic, Surgical and Interventional procedures; Critical Care and Emergency Room Procedures.
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:
The subject device has been evaluated and found to be compliant to safety and essential performance as per IEC 60601-1, accuracy of loading factors, reproducibility of radiation output and imaging performance as per IEC 60601-2-54, recovery management, patient data, last image hold, image measuring functions as per IEC 60601-2-43, half value layer, leakage radiation in loading and normal state and strav radiation as per IEC 60601-1-3, conducted emission, radiated emission, harmonics, voltage fluctuations, electrostatic discharge (ESD), electrical fast transients (EFT), radiated RF electromagnetic field, continuous conducted RF, surges, power frequency magnetic field, voltage dips and short interruption as per IEC 60601-1-2, detective quantum Efficiency (DQE), spatial resolution, dynamic range, beam alignment, recovery time, dose requirements, stability of device characteristics with time, frame rate, reuse rate as per FDA guidance document for solid state X-ray imaging devices. The device also complies with FDA performance standards 21CFR 1020.30-1020.32. The verification and validation testing performed demonstrated compliance to the design requirements and intended use of SKAN C.
Clinical Tests:
Usability aspects of the device were tested by the users and independent participants including the setting up device and the post imaging processes. The results of the study did not reveal any discomfort or complex user interfaces for the intended purpose of the device.
Independent views of Radiologists were obtained on the imaging performances and the acquired images were of adequate quality for the indicated use. The results of the validation activities confirmed that the device is safe and effective for its intended application.
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.
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.
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
§ 892.1650 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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November 24, 2017
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Skanray Technologies Private Limited % Parul Chansoria Regulatory Consultant Elexes Medical Consulting Pvt Ltd. #6494. Tralee Village Dr. Dr Dublin, California 94568
Re: K170946
Trade/Device Name: Skan C Mobile C-Arm X-Ray system - 230V Variant (303-000187-1), Skan C Mobile C-Arm X-Ray system - 110V Variant (303-000187-2) Regulation Number: 21 CFR 892.1650 Regulation Name: Image-Intensified Fluoroscopic X-Ray System Regulatory Class: Class II Product Code: OXO, OWB Dated: October 17, 2017 Received: November 9, 2017
Dear Parul Chansoria:
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);
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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Robert Oals
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K170946
Device Name
Skan C Mobile C-Arm X-Ray system - 230V Variant (303-000187-1), Skan C Mobile C-Arm X-Ray system - 110V (303000187-2)
Indications for Use (Describe)
The Skan-C, a Mobile Surgical C-Arm X-Ray System, is intended to provide Fluoroscopic and Radiographic images of the patient during Diagnostic, Surgical and Interventional procedures.
Examples of Clinical Applications may include Orthopaedic. GI Procedure like Endoscopy and Cholenography. Neurology, Urology Procedures, Vascular, Critical Care and Emergency Room Procedures.
Skan-C is not recommended for Cardiac Applications.
Skan-C Surgical C-Arm is indication in real time and/or recording of surgical region of interest and anatomy, using X-ray imaging technique.
| 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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Section.5- 510K Summary 1
5.1. Sponsor
| Date: | September 28, 2017 |
|---|---|
| Applicant: | Skanray Technologies Private Limited, |
| Plot # 15-17, Hebbal Industrial Area | |
| Mysore-570016, India | |
| Contact Person: | Parul Chansoria, Regulatory Consultant, Elexes |
| Email Id: | parul@elexes.com |
| Phone: | 650-528-2445 |
5.2. Establishment Registration Number
| FDA | 3009001657 |
|---|---|
| establishment | |
| registration | |
| number: |
5.3. Device Name
| Trade Name: | Skan C |
|---|---|
| Variants: | Skan C Mobile C-Arm X-Ray system-230V Variant |
| (303-000187-1) | |
| Skan C Mobile C-Arm X-Ray system-110V Variant | |
| (303-000187-2) | |
| Regulation Name: | lmage-Intensified Fluoroscopic X-Ray System |
| Regulation Number: | 892.1650 |
| Product Code: | OXO -Primary & OWB-Secondary |
5.4. Predicate Device
| GE | OEC Fluorostar - K043076 |
|---|---|
| Regulation Name: | Image-intensified fluoroscopic x-ray system |
| Regulation number: | 892.1650 |
| Product Code: | OWB |
| Subsequent Product Codes: | JAA, OXO |
5.5. Reference Device
| Genoray | ZEN-2090 Pro - K091918 |
|---|---|
| Regulation Name: | Image-intensified fluoroscopic x-ray system |
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| Regulation number: | 892.1650 |
|---|---|
| Product Code: | OWB |
| Subsequent Product Codes: | JAA, OXO |
5.6. Product Description
SKAN-C, is a mobile X-Ray C-Arm fluoroscopic device to assist in quiding medical intervention surgical procedures. The device can also be used for radiographic applications. The device is designed in such a way that it can be moved around and can be positioned for the required anatomical/clinical/procedural position.
SKAN-C, a Mobile Surgical C-Arm consists of two units, namely, Mobile Image Intensified C-Arm unit with generator, and a Work-Station for Image display, store and manipulation. C-Arm unit with generator is capable of movements which are essential for patient positioning, like horizontal travel, orbital movement, wig-wag movement and C rotation. The X-ray generator, X-Ray control system and collimator controls are housed in the C-Arm unit.
5.7. Indications for Use
The Skan-C, a Mobile Surgical C-Arm X-Ray System, is intended to provide Fluoroscopic and Radiographic images of the patient during diagnostic, surgical and interventional procedures.
Examples of clinical applications may include orthopaedic, GI procedures like endoscopy and cholenography, neurology, urology, vascular, critical care and emergency room procedures.
Skan-C is not recommended for cardiac applications.
Skan-C Surgical C-Arm is indicated for visualization in real time and/or recording of surgical region of interest and anatomy, using X-ray imaging technique.
5.8. Technology Characteristics
Major similarities between subject and predicate device.
| | | Skanray
Skan-C | GE OEC
Fluorostar | SE
Remark/Comment |
|-------------------------------|--------------------------------------------------------------|-------------------------------|-------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|
| X-Ray Tube | Type | Stationary | Stationary | Same |
| | Focal Spot | 0.6/1.8 | 0.5/1.5 | Similar, slightly higher focal spot is to improve the thermal performance of the generator. |
| | Anode Heat capacity | 45KHU | 46KHU | Similar, Is the characteristic of X-Ray Tube. Meets the criteria of 10min continuous |
| | | Skanray
Skan-C | GE OEC
Fluorostar | SE
Remark/Comment |
| | | | | exposure |
| Image
Intensifier | Make | Thales | Thales/Thomson | |
| | Modes | Triple Mode,
9", 6" & 4.5" | Triple Mode, 9",
6" & 4.5" | Same |
| | DQE (%) | 65 | 65 | Same |
| Camera | Technology | CCD | CCD | Same |
| | Resolution | 1k x 1k | 1k x 1k | Same |
| Max
Radiographi
c Power | | 2.2 kW | 2.2 kW | Same |
| Loading
Factors | Radiography
KV Range | 40-110 kV | 36-110 kV | Better Stability within the
range specified. |
| | mAs Range | 200 mAs | 52 mAs | Better mAs range for
dense anatomy due to
higher Focal Spot size. |
| | Fluoroscopy kV
Range | 40-110 kV | 36-110 kV | Better Stability within the
range specified |
| | Fluoroscopy
mA Range
(Normal and
boost Mode) | 0.2-8 mA | 0.2-8 mA | Same |
| Physical
Parameters | Free Space
Available
between
Source and
Detector | 75 Cm | 76 Cm | The minor difference in
the physical parameters
in terms of dimensions
does not have any impact
on the claimed indications
for use. |
| | SID | 95 Cm | 98 Cm | |
| | C-Arm Depth | 65 Cm | 66 Cm | |
| | Horizontal
Travel | 20 Cm | 20 Cm | |
| | Vertical
Movement | 40 Cm | 43 Cm | |
| | Orbital Rotation | (125°)90°/- | (120°)90°/- | |
| | | Skanray
Skan-C | GE OEC
Fluorostar | SE
Remark/Comment |
| | | 35° | 30° | |
| | Angulation | $180° (+/- 180°)$ | $450° (+225°/- 225°)$ | |
| | Wig-Wag | +-12,5° | +-10° | |
| Operating
Environment | Input Energy
Source | 100-110 VAC,
50/60 Hz | 100-110 VAC,
50/60 Hz | Same |
| | Operating
Temperature
Range | 10deg C to
40deg C | 10deg C to
40deg C | Same |
| | Operating
Humidity
Range | 20- 80 % Non-
Condensing | 20- 80 % Non-
Condensing | Same |
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Table 1: Technological characteristics
With the above comparison, the subject device, Skan C, is equivalent in technological and other characteristics to the predicate device. GE OEC Fluorostar.
5.9. FDA Guidance Documents
The following guidance documents were referred during development of the subject device:
-
- Content of Premarket Submissions for Management of Cybersecurity in Medical Devices.
-
- Off-The-Shelf Software Use in Medical Devices.
-
- Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.
-
- Draft Guidance for Industry and Food and Drug Administration Staff -Paediatric Information for X-ray Imaging Device Premarket Notifications
-
- Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices - Guidance for Industry and Food and Drug Administration Staff.
5.10. Non-Clinical Tests:
The subject device has been evaluated and found to be compliant to safety and essential performance as per IEC 60601-1, accuracy of loading factors, reproducibility
7
of radiation output and imaging performance as per IEC 60601-2-54, recovery management, patient data, last image hold, image measuring functions as per IEC 60601-2-43, half value layer, leakage radiation in loading and normal state and strav radiation as per IEC 60601-1-3, conducted emission, radiated emission, harmonics, voltage fluctuations, electrostatic discharge (ESD), electrical fast transients (EFT), radiated RF electromagnetic field, continuous conducted RF, surges, power frequency magnetic field, voltage dips and short interruption as per IEC 60601-1-2, detective quantum Efficiency (DQE), spatial resolution, dynamic range, beam alignment, recovery time, dose requirements, stability of device characteristics with time, frame rate, reuse rate as per FDA guidance document for solid state X-ray imaging devices. The device also complies with FDA performance standards 21CFR 1020.30-1020.32. The verification and validation testing performed demonstrated compliance to the design requirements and intended use of SKAN C.
5.11. Clinical Tests:
Usability aspects of the device were tested by the users and independent participants including the setting up device and the post imaging processes. The results of the study did not reveal any discomfort or complex user interfaces for the intended purpose of the device.
Independent views of Radiologists were obtained on the imaging performances and the acquired images were of adequate quality for the indicated use. The results of the validation activities confirmed that the device is safe and effective for its intended application.
5.12. Conclusion
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the non-clinical tests, clinical tests and relative information provided in this premarket notification, we conclude that SKAN C Mobile C-arm X-ray system is substantially equivalent to predicate device with regard to safety and performance.
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