K Number
K172163
Date Cleared
2017-08-15

(28 days)

Product Code
Regulation Number
892.5050
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Eclipse Treatment Planning System (Eclipse TPS) is used to plan radiotherapy treatments with malignant or benign diseases. Eclipse TPS is used to plan external beam irradiation with photon, electron and proton beams, as well as for internal irradiation (brachytherapy) treatments. In addition, the Eclipse Proton Eye algorithm is specifically indicated for planning proton treatment of neoplasms of the eye.

Device Description

The Varian Eclipse™ Treatment Planning System (Eclipse TPS) provides software tools for planning the treatment of malignant or benign diseases with radiation. Eclipse TPS is a computer-based software device used by trained medical professionals to design and simulate radiation therapy treatments. Eclipse TPS is capable of planning treatments for external beam irradiation with photon, electron, and proton beams, as well as for internal irradiation (brachytherapy) treatments.

AI/ML Overview

This document is a 510(k) summary for the Eclipse Treatment Planning System (Eclipse TPS), specifically version 15.5, from Varian Medical Systems. It describes changes from a previous version (v15.1.1, K170969) and argues for substantial equivalence.

Here's an analysis of the provided information concerning acceptance criteria and supporting studies, particularly regarding the newly included "Smart Segmentation Knowledge Based Contouring (SS KBC)" module, which appears to be the most relevant AI/software feature:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not provide a formal table of explicit acceptance criteria with quantitative performance metrics for the entire Eclipse Treatment Planning System, nor for the specific new features. Instead, it states a general conclusion from non-clinical testing:

  • Acceptance Criteria/Goal (Inferred): The product conforms to defined user needs and intended uses, and there are no discrepancy reports (DRs) remaining with a priority of Safety Intolerable or Customer Intolerable. The device is considered safe and performs at least as well as the predicate device.
  • Reported Device Performance: "The outcome was that the product conformed to the defined user needs and intended uses and that there were no DRs (discrepancy reports) remaining which had a priority of Safety Intolerable or Customer Intolerable."

For the Smart Segmentation Knowledge Based Contouring (SS KBC) module, the document notes that it was previously cleared under K141248 (v2.2). This implies that the specific performance metrics and acceptance criteria for this module would have been detailed in that earlier submission. In this current submission (K172163), the SS KBC module is being integrated into the broader Eclipse TPS, and the claim is that its previously established safety and effectiveness hold.

2. Sample Size Used for the Test Set and Data Provenance

The document provides very limited detail on specific test sets for the current submission (K172163). It broadly refers to "Verification and Validation" being performed for all new features and "regression testing" for existing features.

  • Sample Size: Not explicitly stated for the overall V&V or for specific features.
  • Data Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). The document refers to "test outcomes" but doesn't specify data sources.

For the Smart Segmentation Knowledge Based Contouring (SS KBC) module, since it was previously cleared under K141248, the relevant test set details would be found in that earlier submission. This document only states that the feature "is included as a part of Eclipse Treatment Planning System (v15.5)" and references its prior clearance.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

This information is not provided in the current document. The document primarily focuses on software engineering V&V processes (tracing requirements to test outcomes, DRs). For the SS KBC module, this information would have been part of the K141248 submission where its performance as a standalone tool was assessed and ground truth established. Given it's a "Knowledge Based Contouring" system, human expert input for ground truth would be expected.

4. Adjudication Method for the Test Set

This information is not provided in the current document.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

  • No MRMC study is mentioned in this 510(k) summary. The summary focuses on comparing technical features with a predicate device and confirming software functionality, not on human-in-the-loop performance improvement with AI assistance.

6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

  • The document implies that standalone performance testing was done as part of the overall "Verification and Validation" process for the software features, as it addresses "product conformance to the defined user needs and intended uses." However, specific details or quantitative results of such standalone performance are not provided in this summary directly.
  • For the Smart Segmentation Knowledge Based Contouring (SS KBC) module, as it was previously cleared under K141248, it is highly probable that its standalone algorithmic performance (e.g., accuracy of auto-segmentation compared to ground truth) was evaluated in that prior submission. This document lists it as a feature of the Eclipse TPS v15.5, meaning its existing, cleared functionality is being integrated.

7. Type of Ground Truth Used

  • This information is not explicitly stated for the general V&V.
  • For the Smart Segmentation Knowledge Based Contouring (SS KBC) module, given its function ("Knowledge Based Contouring"), the ground truth for its original clearance (K141248) would typically involve expert delineation consensus (e.g., radiation oncologists, radiologists) as the gold standard for anatomical structures.

8. Sample Size for the Training Set

  • This information is not provided in the current document. Training set details would be most relevant for the knowledge-based/AI component (SS KBC).

9. How the Ground Truth for the Training Set Was Established

  • This information is not provided in the current document. For the SS KBC module, again, this would have been part of the K141248 submission. Typically, for knowledge-based contouring systems, ground truth for training data involves expert delineation and potentially review processes.

Summary of AI-Specific Information from the Provided Document:

The most AI-related component mentioned is the "Smart Segmentation Knowledge Based Contouring (SS KBC) as an Eclipse module." Crucially, the document states: "Smart Segmentation - Knowledge Based Contouring (SS KBC) v2.2 was cleared under K141248. The corresponding features above were cleared previously as a part of that submission."

This means that the current submission (K172163) does NOT provide the detailed acceptance criteria or study results for the SS KBC module itself. Instead, it incorporates a previously cleared module and relies on its prior clearance for safety and effectiveness. To find the specific details regarding the SS KBC's performance, a review of the K141248 submission would be necessary. This current document validates that the integration of this module into Eclipse TPS v15.5 maintains its intended functionality and does not introduce new safety or effectiveness concerns.

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

August 15, 2017

Varian Medical Systems, Inc. % Mr. Peter Coronado Director, Regulatory Affairs 911 Hansen Way PALO ALTO CA 94304

Re: K172163

Trade/Device Name: Eclipse Treatment Planning System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: MUJ Dated: July 17, 2017 Received: July 19, 2017

Dear Mr. Coronado:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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'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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Indications for Use

510(k) Number (if known)

K172163

Device Name Eclipse Treatment Planning System

Indications for Use (Describe)

The Eclipse Treatment Planning System (Eclipse TPS) is used to plan radiotherapy treatments with malignant or benign diseases. Eclipse TPS is used to plan external beam irradiation with photon, electron and proton beams, as well as for internal irradiation (brachytherapy) treatments. In addition, the Eclipse Proton Eye algorithm is specifically indicated for planning proton treatment of neoplasms of the eye.

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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PREMARKET NOTIFICATION

510(k) Summary

Eclipse Treatment Planning System

As required by 21 CFR 807.92

Submitter's Name:Varian Medical Systems3100 Hansen Way, m/s E110Palo Alto, CA 94304
Contact Name: Peter J. Coronado-Director Regulatory AffairsPhone: 650/424.6230Fax: 650/646.9200E-mail: submissions.support@varian.com
Proprietary Name:Eclipse Treatment Planning System
Classification Name:system, planning, radiation therapy treatment21CFR892.5050, MUJ, Class II
Common/Usual Name:Eclipse TPS, Eclipse, Treatment Planning System
Predicate Devices:Eclipse Treatment Planning System 15.1.1 (K170969).
Device Description:The Varian Eclipse™ Treatment Planning System (Eclipse TPS)provides software tools for planning the treatment of malignantor benign diseases with radiation. Eclipse TPS is a computer-basedsoftware device used by trained medical professionals todesign and simulate radiation therapy treatments. Eclipse TPS iscapable of planning treatments for external beam irradiation withphoton, electron, and proton beams, as well as for internalirradiation (brachytherapy) treatments.
Indications for Use:The Eclipse Treatment Planning System (Eclipse TPS) is used toplan radiotherapy treatments for patients with malignant orbenign diseases. Eclipse TPS is used to plan external beamirradiation with photon, electron and proton beams, as well as forinternal irradiation (brachytherapy) treatments. In addition, theEclipse Proton Eye algorithm is specifically indicated forplanning proton treatment of neoplasms of the eye.

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Changes in Technological Characteristics:

The significant changes compared with the predicate are associated with:

    1. Support for HyperArc Planning
    • Support for Encompass Fixation Device (Encompass Structures for HyperArc) a.
    1. Trade-Off Exploration based on Multi-Criteria Optimization (MCO)
    1. GPU-calculation capability for select optimization and dose calculations
    1. Updated handling for Numerical Input Values (NIV)
    1. Inclusion of Smart Segmentation Knowledge Based Contouring (SS KBC) as an Eclipse module
    • a. Updated Eclipse Image Registration and Segmentation IFU & Reference Guides

The complete list of Eclipse changes and their related requirements can be found in the document "Tracing Changed and New Features to System Requirements" in Section 18 of this submission; the indications for use and the intended use are the same in the subject device as for the predicate.

PREDICATE DEVICEFEATURE/ SPECIFICATION510(к) K170969ECLIPSE TPS v15.1.1MODIFIED DEVICEFEATURE/ SPECIFICATIONECLIPSE TPS v15.5
1. Intended Use / Indications for Use
Statement of Intended Use and Indications for UseEclipse is intended to be used to plan radiotherapytreatments for patients with malignant or benigndiseases. Eclipse is used to plan external beamirradiation with photon, electron and proton beams,as well as for internal irradiation (brachytherapy)treatments. In addition, the Eclipse Proton Eyealgorithm is specifically indicated for planning protontreatment of neoplasms of the eye.Eclipse is intended to be used to plan radiotherapytreatments for patients with malignant or benigndiseases. Eclipse is used to plan external beamirradiation with photon, electron and proton beams,as well as for internal irradiation (brachytherapy)treatments. In addition, the Eclipse Proton Eyealgorithm is specifically indicated for planning protontreatment of neoplasms of the eye.
2. General Usage
External beam PHOTON planningYesYes
External beam PHOTON inverse planningYesYes
External beam ELECTRON planningYesYes
External beam PROTON planningYesYes
External beam OCULAR PROTON planning (EOPP)No *)No *)
Internal BRACHYTHERAPY planningYesYes
Stereotactic Frame LocalizationYesYes
Treatment Planning for Varian RDS (Halcyon)YesYes
Automated Structure Delineation based on ExpertCase Library**)No, feature was part ofSmart SegmentationKnowledge BasedContouring (v3.6)Yes, feature is includedas a part of EclipseTreatment PlanningSystem (v15.5)
3. Supported External Beams & Accessories
Photon beamsYesYes
Electron beamsYesYes
Proton beamsYesYes
Coplanar fieldsYesYes
Non-coplanar fieldsYesYes
Multi-leaf CollimatorsYesYes
Asymmetric collimatorsYesYes
Stereotactic Cone collimatorsYesYes
Arc fieldsYesYes
Poured BlocksYesYes
CompensatorsYesYes
Physical wedgesYesYes
Dynamic wedgesYesYes
Flattening filter free support (FFF)YesYes
Rotating treatment couchYesYes
Non-rotating RDS couchYesYes
Elekta 160 MLCYesYes
Varian SX1 MLCYesYes
4. Supported Brachytherapy Sources &Accessories
Plan for high dose rate afterloaderYesYes
Manual low dose rate brachytherapy: seeds, linesources, wireYesYes
Applicator libraryYesYes
Needle templatesYesYes
Seed templatesYesYes
5. Graphical User Interface
Multiple-instance applicationYesYes
Multiple-workspace layoutYesYes
Graphical display/editing of field parametersYesYes
Beam's-Eye-View displayYesYes
3D patient image displayYesYes
Model for human EyeNo *)No *)
SRS Localization applicationYesYes
SRS Planning applicationYesYes
Biological Optimization applicationYesYes
Biological Evaluation applicationYesYes
3D Conformal Optimization applicationYesYes
6. Image Processing
Orthogonal image displays (3)YesYes
Oblique image displayYesYes
Edge enhancement filtersYesYes
Image smoothing filtersYesYes
CT/MR/PET Image RegistrationYesYes
Image blending utilityYesYes
4D image display (registration of time series of 3Dimages)YesYes
Digitally reconstructed radiographsYesYes
Enclosed Volume measurementYesYes
Stereotactic Frame Coordinate transformationYesYes
7. Image Segmentation
Geometrical shapesYesYes
Manual editing and manipulation toolsYesYes
Automatic /semi-automatic toolsYesYes
Automatic/semi-automatic on-demand and post-processing tools for individual organs/structuresYesYes
Automatic on-demand and pre-processing tools formultiple organs/structuresYesYes
3D AutomarginYesYes
Logical operatorsYesYes
Enhanced 2D and 3D contouring toolsYesYes
Enhanced 4D functionality, including structurepropagation and display of respiratory amplitudedistributionYesYes
Expert Case Library**)No, feature was part ofSmart SegmentationKnowledge BasedContouring (v3.6)Yes, feature is includedas a part of EclipseTreatment PlanningSystem (v15.5)
Multi-atlas Segmentation
Expert cases: Nasopharynx, Tonsil, Base ofTongue, Hypopharynx, Larynx**)
Structure templates and dictionary with standardizelabels**)
Calypso segmentation **)
Segmentation of mandible **)
Semi-Automatic Segmentation of Lung Tumors**)(Lung Tumor Segmentation Tool)
Encompass Couch Model (Fixation Device)NoYes
8. Dose Calculation
Distributed Calculation FrameworkYesYes
Photon calculationYesYes
- Energy Range1 MV – 50 MV1 MV – 50 MV
- CT-based volumetric calculationYesYes
- Non-CT based IRREG calculationYesYes
- Convolution methodNoNo
- Combined electron/photon scatterYesYes
- Directional heterogeneity correctionYesYes
- Treatment head modellingYesYes
- Photon Monitor Unit calculationYesYes
- Compensator monitor unit calculationYesYes
- Beam Angle Optimization (GEOS)YesYes
- Leaf Motion SequencingYesYes
- Dose Dynamic Arc planningYesYes
- Cone Dose CalculationYesYes
- Biological optimizationYesYes
- 3D Conformal OptimizationYesYes
- IMRT optimizationYesYes (also GPU)
- AcurosXB dose calculation algorithmYesYes (also GPU)
- AAAYesYes
- Range Uncertainty feature for photonsYesYes
- Siemens mArcYesYes
- Siemens FFF (unflattened beam)YesYes
- Elekta Agility MLC 160YesYes
- RaySearch PlanConverterYesYes
- Varian SX1 MLCYesYes
- FTDC Imaging dose calculation for RDS machineYesYes (also GPU)
Electron calculationYesYes
- Energy Range1 MeV – 50 MeV1 MeV – 50 MeV
- Gaussian Pencil Beam ModelYesNo, obsoleted
- Electron Monte Carlo algorithmNoNo
- Electron Monte Carlo algorithm v2Yes(incl. Siemens, Elekta)Yes(incl. Siemens, Elekta)
- Electron Monitor Unit calculationYesYes
- Portal Dose Image PredictionYesYes
Proton calculationYesYes
- Energy Range50 MeV - 300 MeV50 MeV - 300 MeV
- Single scattering techniqueYesYes
- Double scattering techniqueYesYes
- Uniform scanning techniqueYesYes
- Modulated scanning techniqueYesYes
- Monitor unit calculation for modulated scanningYesYes
- Range uncertainty feature for ProtonsYesYes
- Robust Proton OptimizationYesYes
- AcurosPT Dose Calculation AlgorithmYesYes
Brachytherapy calculationYesYes
- AAPM TG 43 compliantYesYes
- Point Dose calculationYesYes
- Optimization to point dose constraintsYesYes
- Geometric optimizationYesYes
- AcurosBV dose calculation algorithmYes(w/ support for report thedose to medium)Yes(w/ support for report thedose to medium)
- Intermediate dose capability for AcurosBV algorithmYesYes
Eclipse Algorithm Application ProgrammingInterface (EAAPI)YesYes
RapidPlan - Dose Volume Histogram (DVH)EstimationYes(extended Dose VolumeHistogram (DVH)Estimation)Yes(extended Dose VolumeHistogram (DVH)Estimation)
9. Dose evaluation
Dose color wash2D, 3D2D, 3D
lsodose levels2D, 3D2D, 3D
Isodose Surface3D3D
Reference point dose summaryYesYes
Dose Volume Histogram plotYesYes
Plan summing toolYesYes
Plan comparison toolsYesYes
Evaluation using biological modelsYesYes
Evaluation using MCO (Multi-Criteria Optimization)NoYes
10. Plan Output - Hardcopy
Graphics window screen dumpYesYes
Patient administration dataYesYes
Plan parametersYesYes
Geometrical displays of plan dataYesYes
Dose distributionYesYes
DVH plotYesYes
BEV displayYesYes
Patient orientationYesYes
Patient orientationYesYes
11. Import/Export Interfaces
ARIA RadOnc integrationYesYes
DICOM RTYesYes
Other image formatsYesYes
Electromagnetic DigitizerImportImport
Film ScannerNoNo
Eclipse Scripting API (ESAPI) read only accessYes(includes BrachyVisionand Proton)Yes(includes BrachyVisionand Proton)
Eclipse Scripting API (ESAPI) write accessYes(in research database,only, with additionalproton planning support)Yes(in research database,only, with additionalproton planning support)
Eclipse AutomationYesYes
Export field coordinates to Laser SystemExportExport
Basic RT Prescription information availableYesYes

Device Comparison Table

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*) A compatible feature has not been released and using the feature is blocked either by not including it in the distribution media for the indicated version(s) or by licensing.

**) Smart Segmentation - Knowledge Based Contouring (SS KBC) v2.2 was cleared under K141248. The corresponding features above were cleared previously as a part of that submission.

Non-clinical Testing

Verification and Validation were performed for all the new features and regression testing was performed against the existing features of Eclipse. System requirements created or affected by the changes can be traced to the test outcomes.

Conclusion of Non-Clinical testing

The outcome was that the product conformed to the defined user needs and intended uses and that there were no DRs (discrepancy reports) remaining which had a priority of Safety Intolerable or Customer Intolerable. Varian therefore considers Eclipse 15.5 to be safe and to perform at least as well as the predicate device.

Argument for Substantial Equivalence to the Predicate Device

A subset of features of the current device is different to the predicate. These changes are all considered by Varian to be enhancements of the predicate. The Indications for Use and the Intended Use remain unchanged. There are no changes in the principle of operation of the software. The Verification and Validation demonstrates that the device is as safe and effective as the predicate. Varian therefore believes that Eclipse Treatment Planning System is substantially equivalent to the predicate.

§ 892.5050 Medical charged-particle radiation therapy system.

(a)
Identification. A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.(b)
Classification. Class II. When intended for use as a quality control system, the film dosimetry system (film scanning system) included as an accessory to the device described in paragraph (a) of this section, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.