K Number
K173635
Date Cleared
2018-01-12

(49 days)

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

syngo.via RT Image Suite is a 3D and 4D image visualization, multimodality manipulation and contouring tool that helps the preparation and response assessment of treatments such as, but not limited to those performed with radiation (for example, Brachytherapy, Particle Therapy, External Beam Radiation Therapy).

It provides tools to efficiently view existing contours, create, edit, modify, copy contours of the body, such as but not limited to, skin outline, targets and organs-at-risk. It also provides functionalities to create and modify simple treatment plans. Contours, images and treatment plans can subsequently be exported to a Treatment Planning System.

The software combines following digital image processing and visualization tools:

· Multi-modality viewing and contouring of anatomical, functional, and multi-parametric images such as but not limited to CT, PET, PET/CT, MRI. Linac Cone Beam CT (CBCT) images and dose distributions

· Multiplanar reconstruction (MPR) think minimum intensity projection (MIP), volume rendering technique (VRT)

  • · Freehand and semi-automatic contouring of regions-of-interest on any orientation including oblique
  • · Creation of contours on any type of images without prior assignment of a planning CT

· Manual and semi-automatic registration using rigid and deformable registration

· Supports the user in comparing, and adapting contours based on datasets acquired with different imaging modalities and at different time points

· Supports the user in comparing images and contours of different patients

  • · Supports multi-modality image fusion
  • · Visualization and contouring of moving tumors and organs
  • · Management of points of interest including but not limited to the isocenter
  • · Management of simple treatment plans
  • · Generation of a synthetic CT based on multiple pre-define MR acquisitions
Device Description

syngo.via RT Image Suite is an image analysis software for viewing, manipulation, 3D and 4D visualization, comparison of medical images from multiple imaging modalities and for the segmentation of tumors and organs-at-risk, prior to dosimetric planning and response assessment in radiation therapy. The subject device syngo.via RT Image Suite with software version SOMARIS/8 VB30 is a further extension of the previously cleared primary predicate device syngo.via RT Image Suite with software version SOMARIS/8 VB20 and supports the following modifications:

    1. Modified Indications for Use Statement
    1. Support of software version SOMARIS/8 VB30 which supports the following functionality:
    • a. Support of Beam Placement
      • Support of Synthetic CT b.
      • Support of modified contouring tools c.
        • i. Routine Contouring
        • ii. Advanced Contouring
        • iii. Rapid Results Technology
      • d. Support of modified structure management

syngo.via RT Image Suite combines routine and advanced digital image processing and visualization tools for easy manual and software assisted contouring of volumes of interest, identification of points of interest, sending isocenter points to an external laser system, registering images and exporting final results. syngo.via RT Image Suite supports the medical professional with tools to use during different steps in radiation therapy case preparation.

AI/ML Overview

The provided text is a 510(k) summary for the syngo.via RT Image Suite, which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a standalone study with detailed clinical performance metrics and acceptance criteria for a new device.

Therefore, the document does not contain the specific information requested in the prompt regarding acceptance criteria, a standalone study, sample sizes for test and training sets, number of experts for ground truth, adjudication methods, MRMC study results, or detailed ground truth establishment for a clinical performance evaluation of the device as if it were a new AI/CADx system.

The document details non-clinical testing and verification/validation activities to ensure the software functions as intended and meets safety and performance standards. It also mentions "supportive articles" for specific device functionality, including the "Synthetic CT feature," which "demonstrates the classification of tissues for brain acquisitions method used for the synthetic CT feature included in this submission." However, these are not presented as a standalone clinical study with the requested metrics.

Thus, I cannot populate the table or answer the specific questions directly from the provided text as it does not contain that information.

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

Siemens Medical Solutions USA, Inc. % Ms. Kimberly Mangum Regulatory Affairs Specialist 40 Libertv Blvd. MALVERN PA 19355

January 12, 2018

Re: K173635

Trade/Device Name: syngo.via RT Image Suite Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: MUJ, LLZ Dated: November 17, 2017 Received: November 24, 2017

Dear Ms. Mangum:

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 (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.

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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,

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: 06/30/2020 See PRA Statement below.

510(k) Number (if known)

K173635

Device Name syngo.via RT Image Suite

Indications for Use (Describe)

syngo.via RT Image Suite is a 3D and 4D image visualization, multimodality manipulation and contouring tool that helps the preparation and response assessment of treatments such as, but not limited to those performed with radiation (for example, Brachytherapy, Particle Therapy, External Beam Radiation Therapy).

It provides tools to efficiently view existing contours, create, edit, modify, copy contours of the body, such as but not limited to, skin outline, targets and organs-at-risk. It also provides functionalities to create and modify simple treatment plans. Contours, images and treatment plans can subsequently be exported to a Treatment Planning System.

The software combines following digital image processing and visualization tools:

· Multi-modality viewing and contouring of anatomical, functional, and multi-parametric images such as but not limited to CT, PET, PET/CT, MRI. Linac Cone Beam CT (CBCT) images and dose distributions

· Multiplanar reconstruction (MPR) think minimum intensity projection (MIP), volume rendering technique (VRT)

  • · Freehand and semi-automatic contouring of regions-of-interest on any orientation including oblique
  • · Creation of contours on any type of images without prior assignment of a planning CT

· Manual and semi-automatic registration using rigid and deformable registration

· Supports the user in comparing, and adapting contours based on datasets acquired with different imaging modalities and at different time points

· Supports the user in comparing images and contours of different patients

  • · Supports multi-modality image fusion
  • · Visualization and contouring of moving tumors and organs
  • · Management of points of interest including but not limited to the isocenter
  • · Management of simple treatment plans
  • · Generation of a synthetic CT based on multiple pre-define MR acquisitions

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

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PSC Publishing Services (301) 443-6740

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510(K) SUMMARY FOR SYNGO.VIA RT IMAGE SUITE

Submitted by: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Date Prepared: November 17, 2017

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR §807.92.

I. Submitter

Importer/Distributor Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355

Establishment Registration Number 2240869

Manufacturing Site

Siemens Healthcare GmbH Siemensstr. 1 D-91301 Forchheim, Germany

Establishment Registration Number 3004977335

Contact Person

Kimberly Mangum Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Phone: (610) 448-6477 Fax: (610) 640-4481 Email: kimberly.mangum@siemens.com

II. Device Name and Classification

Product Name: Proprietv Trade Name: Classification Name: Classification Panel: CFR Section: Subsequent CFR Section: Device Class: Product Code: Subsequent Product Code: LLZ

syngo.via RT Image Suite syngo.via RT Image Suite System, Planning, Radiation Therapy Treatment Radiology 21 CFR §892.5050 21 CFR §892.2050 Class II MUJ

III. Predicate Device

Primary Predicate Device:

Trade Name: syngo.via RT Image Suite 510(k) Number: K162370 Clearance Date: 10/25/2016 Classification Name: System, Planning, Radiation Therapy Treatment Classification Panel: Radiology CFR Section: 21 CFR §892.5050 Subsequent CFR Section: 21 CFR §892.2050

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SIEMENS

Device Class: Class II Product Code: MUJ Subsequent Product Code: LLZ Recall Information: There have been no recalls for this device

Secondary Predicate Device:

Trade Name:syngo VSim
510(k) Number:K151887
Clearance Date:09/16/2015
Classification Name:System, Planning, Radiation Therapy Treatment
Classification Panel:Radiology
CFR Section:21 CFR § 892.5050
Device Class:Class II
Product Code:MUJ
Recall Information:There have been no recalls for this device

Secondary Predicate Device:

Trade Name:Biograph mMR with syngo MR E11P system software
510(k) Number:K163234
Clearance Date:02/28/2017
Classification Name:Tomographic Imager Combining Emission Computed Tomography withNuclear Magnetic Resonance
Classification Panel:Radiology
CFR Section:21 CFR § 892.1200
Device Class:Class II
Product Code:OUO
Subsequent Product Code:KPS, LNH, LNI
Recall Information:There have been no recalls for this device

Reference Device:

Trade Name:syngo.CT Single Source Dual Energy (twin beam)
510(k) Number:K163289
Clearance Date:02/09/2017
Classification Name:System, X-ray, Tomography, Computed
Classification Panel:Radiology
CFR Section:21 CFR § 892.1750
Device Class:Class II
Product Code:JAK

IV. Device Description

syngo.via RT Image Suite is an image analysis software for viewing, manipulation, 3D and 4D visualization, comparison of medical images from multiple imaging modalities and for the segmentation of tumors and organs-at-risk, prior to dosimetric planning and response assessment in radiation therapy. The subject device syngo.via RT Image Suite with software version SOMARIS/8 VB30 is a further extension of the previously cleared primary predicate device syngo.via RT Image Suite with software version SOMARIS/8 VB20 and supports the following modifications:

    1. Modified Indications for Use Statement
    1. Support of software version SOMARIS/8 VB30 which supports the following functionality:
    • a. Support of Beam Placement
      • Support of Synthetic CT b.
      • Support of modified contouring tools c.
        • i. Routine Contouring
        • ii. Advanced Contouring
        • iii. Rapid Results Technology
      • d. Support of modified structure management

syngo.via RT Image Suite combines routine and advanced digital image processing and visualization tools for easy manual and software assisted contouring of volumes of interest, identification of points of interest, sending isocenter points to an external laser system, registering images and exporting final results. syngo.via RT Image Suite supports the medical professional with tools to use during different steps in radiation therapy case preparation.

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SIEMENS

syngo.via RT Image Suite provides dedicated tools, which help the medical professional in contouring and evaluating volumes of interest, for example gross target volumes, or organs-at-risk. The software application works in a similar fashion on any officially supported imaging modality, for example, native contouring is supported on CT but also on MR or PET images.

V. Indications for Use

syngo.via RT Image Suite is a 3D and 4D image visualization, multimodality manipulation and contouring tool that helps the preparation and response assessment of treatments such as, but not limited to those performed with radiation (for example, Brachytherapy, Particle Therapy, External Beam Radiation Therapy).

It provides tools to efficiently view existing contours, create, edit, modify, copy contours of regions of the body, such as but not limited to, skin outline, targets and organs-at-risk. It also provides functionalities to create and modify simple treatment plans. Contours, images and treatment plans can subsequently be exported to a Treatment Planning System.

The software combines following digital image processing and visualization tools:

  • Multi-modality viewing and contouring of anatomical, functional, and multi-parametric ● images such as but not limited to CT, PET, PET/CT, MRI, Linac Cone Beam CT (CBCT) images and dose distributions
  • Multiplanar reconstruction (MPR) thin/thick, minimum intensity projection (MIP), volume ● rendering technique (VRT)
  • . Freehand and semi-automatic contouring of regions-of-interest on any orientation including oblique
  • Creation of contours on any type of images without prior assignment of a planning CT
  • . Manual and semi-automatic registration using rigid and deformable registration
  • Supports the user in comparing, contouring, and adapting contours based on datasets acquired ● with different imaging modalities and at different time points
  • Supports the user in comparing images and contours of different patients
  • Supports multi-modality image fusion ●
  • Visualization and contouring of moving tumors and organs ●
  • Management of points of interest including but not limited to the isocenter ●
  • Management of simple treatment plans
  • Generation of a synthetic CT based on multiple pre-define MR acquisitions .

VI. Comparison of Technological Characteristics with the Predicate Device

As with the primary predicate device, the subject device supports: viewing, manipulation, 3D and 4D visualization, comparison of medical images from multiple imaging modalities and the segmentation of tumors and organs-at-risk, prior to dosimetric planning and response assessment in radiation therapy. Software version SOMARIS/8 VB30 supports additional beam placement, synthetic CT, and modified contouring tools and structure management tools.

At a high level, the subject and predicate devices are based on the following same technological characteristics:

  • . Software operating platform SOMARIS/8
  • Multi-modality Image Manipulation
  • Multi-modality 3D and 4D visualization of images
  • . Comparison of medical images from multiple imaging modalities and the segmentation of tumors and organs-at-risk prior to dosimetric planning and response assessment in radiation therapy

The following technological differences exist between the subject device and the primary predicate device:

  • Software version SOMARIS/8 VB30
  • . Support of synthetic CT feature
  • Support of beam placement ●
  • Support of modified contouring tools ●
  • . Support of additional structure management tools
  • Rapid Results Technology 0

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Image /page/6/Picture/0 description: The image shows the word "SIEMENS" in a sans-serif font. The text is a light blue color. The background is white, which makes the text stand out.

A tabular summary of the subject and predicate device technological differences is provided as Table 4 below:

Table 1 Differences and Similarities in Technical Characteristics

FeatureSubject Devicesyngo.via RT ImageSuitePrimary Predicate Devicesyngo.via RT ImageSuiteSecondary PredicateDevicesyngo VSimSecondaryPredicate DeviceBiograph mMRwith syngo MRE11P systemsoftwareComparisonResults
SoftwareSOMARIS/8 VB30SOMARIS/8 VB20syngo VSim VA10AN/AModified from theprimary predicatedevice to supportadditionalfunctionality
BeamPlacementCreation of newgeometric treatmentplans for photonradiotherapyN/ACreation of newgeometric treatmentplans for photon andelectron radiotherapyN/AModified from thesecondarypredicate device tobe more userintuitive
Synthetic CTGeneration of CT-density image series outof multiple MR-imageseriesN/AN/AGeneration of MR-density imageseries out ofmultiple MR-imageseriesModified form thesecondarypredicate device tosupport generationof CT densityimages
ContouringRoutine Contouring,Advanced Contouring,Contouring on 4D ImageData, Routine StructureOperations, Duplicationof Structures and POIs.Rapid ResultsTechnologyRoutine Contouring,Advanced Contouring,Contouring on 4D ImageData, Routine StructureOperations, Duplicationof Structures and POIsRoutine Contouring,Advanced Contouring,Routine StructureOperations, Duplicationof Structures and POIsN/AModified from theprimary predicatedevice to supportmodified routineand advancedcontouring tools
Structure SetManagementLoading and storing ofDICOM RT structuresets, creating, editingand deletion of structuresand POIs.Creating, editing anddeletion of structuretemplates.Customize predefinedstructure database withmapping to internationalnomenclature schemes.Loading and storing ofDICOM RT structuresets, creating, editingand deletion of structuresand POIs.Creating, editing anddeletion of structuretemplates.Loading and storing ofDICOM RT structuresets, creating, editingand deletion of structuresand POIs.Creating, editing anddeletion of structuretemplates.Customize predefinedstructure database.N/AModified from thepredicate devices tosupport additionaltools for contouringand structuremanagement
ReferencePointManagementReference point creationand managementReference point creationand managementReference point creationand managementN/ASame as thepredicate devices
BasicFeaturesRoutine ReadingFunctionality, ParallelImage Display, RoutineAnnotation FunctionalityRoutine ReadingFunctionality, ParallelImage Display, RoutineAnnotation FunctionalityRoutine ReadingFunctionalityN/ASame as theprimary predicatedevice
PatientMarkingSending of referencepoints with offset detailsto a laser systemSending of referencepoints with offset detailsto a laser systemSending of referencepoints with offset detailsto a laser systemN/ASame as theprimary predicatedevice
AlignmentToolsRigid Alignment,Deformable AlignmentRigid Alignment,Deformable AlignmentRigid AlignmentN/ASame as theprimary predicatedevice
FeatureSubject Devicesyngo.via RT ImageSuitePrimary Predicate Devicesyngo.via RT ImageSuiteSecondary PredicateDevicesyngo VSimSecondaryPredicate DeviceBiograph mMRwith syngo MRE11P systemsoftwareComparisonResults
DoseEvaluationLoading of any existingdose files; addition orsubtraction of two dose;shows Dose VolumeHistogramsLoading of any existingdose files; addition orsubtraction of two dose;shows Dose VolumeHistogramsN/AN/ASame as theprimary predicatedevice

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VII. Performance Data

Non-Clinical Testing Summary

Non-clinical tests (integration and functional) were conducted for syngo.via RT Image Suite during product development. Performance tests were conducted to test the functionality of the syngo.via RT Image Suite. The modifications described in this Premarket Notification were supported with verification/validation testing. These tests have been performed to test the ability of the included features of the subject device. The results of these tests demonstrate that the subject device performs as intended. The result of all conducted testing was found acceptable to support the claim of substantial equivalence. Supportive articles were provided to support specific device functionality and claims, including the Synthetic CT feature. The supportive articles provided for the synthetic CT feature demonstrates the classification of tissues for brain acquisitions method used for the synthetic CT feature included in this submission.

Siemens claims conformance to the following performance standards:

ProductAreaTitle of StandardReferenceNumber and DatePublicationDateStandardsDevelopmentOrganization
RadiologyDigital Imaging and Communications inMedicine (DICOM) SetPS 3.1 - 3.2006/27/2016NEMA
SoftwareMedical device software - Software lifecycle processes62304 First edition2006-0508/20/2012IEC
GeneralMedical devices – Application of riskmanagement to medical devices14971 SecondEdition 2007-03-0106/27/2016ISO
GeneralMedical electrical equipment - Part 1-6:General requirements for basic safetyand essential performance - CollateralStandard: Usability60601-1-6 Edition3.007/09/2014IEC
GeneralMedical electrical equipment - Part 1-4:General requirements for safety -Collateral standard Programmableelectrical medical systems, Edition 1.160601-1-4:2000,Consol. Ed. 1.109/08/2009IEC

Software Verification and Validation

Software Documentation for a Moderate Level of Concern software per FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" May 11, 2005 is also included as part of this submission. issued on The performance data demonstrates continued conformance with special controls for medical devices containing software. The Risk Analysis was completed and risk control implemented to mitigate identified hazards. The testing supports that all software specifications have met the acceptance criteria. Testing for verification and validation support the claim of substantial equivalence.

Siemens Healthcare conforms to the Cybersecurity requirementing a process of preventing unauthorized access, modifications, misuse or the unauthorized use of information that is stored, accessed, or transferred from a medical device to an external recipient. Cybersecurity information in accordance with guidance document "Content of Premarket Submissions

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for Management of Cybersecurity Medical Devices issues on October 2, 2014" is included within this submission.

Summary

This subject device provides tool designed help the medical professional in contouring and evaluating volumes of interest, for example gross target volumes, or organs-at-risk. The fundamental software technology which is provided within the scope of the subject device is already cleared and remains unchanged in comparison to the predicate devices. The Indications for Use for the subject device has been adapted to provide a more specific description of the subject device syngo.via RT Image Suite functionality, but does not represent a new intended use. The modifications described in this Premarket Notification were supported with verification and validation testing. The Risk analysis was completed and risk control implemented to mitigate identified hazards.

General Safety and Effectiveness Concerns

The device labeling contains instructions for use and any necessary cautions and warnings to provide for safe and effective use of the device. Risk management is ensured via a hazard analysis, which is used to identify potential hazards. These potential hazards are controlled during development, verification and validation testing. syngo.via RT Image Suite is designed to fulfill the requirements of the applicable safety and performance standards as listed above.

VIII. Conclusions

The predicate devices were cleared based on non-clinical testing including verification and validation. phantom tests, and supportive literature. The results of these tests demonstrate that the predicate devices are adequate for the intended use. The subject device is also tested using the same methods as used for the predicate devices. The comparison of technological characteristics, non-clinical performance data, and software validation included in this submission demonstrates that the subject device is as safe and effective when compared to the predicate devices that are currently marketed for the same intended use. Since both devices were tested using the same methods, Siemens believes that the data generated from the syngo.via RT Image Suite testing supports a finding of substantial equivalence.

§ 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.