(129 days)
Luminos Agile Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos Agile Max is not for mammography examinations.
Luminos dRF Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos dRF Max is not for mammography examinations.
Multitom Rax is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients
Multitom Rax is not for mammography examinations.
Uroskop Omnia Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system is designed primarily for urological diagnosis and the support of urological therapeutic applications such as examinations and small interventions of the urogenital tract. The table supports endourological and minimal invasive surgery in urology as there are transurethral interventions (e.g. ureterorenoscopy (URS), double stent placement, cystoscopy. transurethral resection of bladder tumors (TURB), transurethral resection of the prostate (TURP)), percutaneous urological procedures (e.g. percutaneous nephrostomy (PCN), percutaneous nephrolitholapaxy (PCNL)), urological X-ray diagnosis (e.g. survey imaging of the kidney, ureter, and bladder (KUB), intravenous pyelogram (IVP), retrograde pyelography), micturition cystourethrogram (MCU), videourodynamics, laparoscopic procedures and minor open urological interventions. The system may be used on pediatric, adult and bariatric patients.
Uroskop Omnia Max is not for mammography examinations.
All four radiology imaging devices are stationary X-ray systems for radiography and fluoroscopy. They use the same X-ray generator, the same X-ray tube and similar collimators. They also share the same imaging and system control device: The Fluorospot Compact. The reason for this submission is the upgrade of all systems to the software VF10. This new software will bring the following new features to the devices: IEC 4th for EMC, Windows 10, Cybersecurity package, Pediatric package, Use hospital IT (e.g. RIS) on modality, 16 fps mode for 3D (Multitom Rax only), SSXI update. The image processing algorithms (Diamond View Plus) will be used for exposures without grid and fluoroscopy image processing algorithms will be enhanced and called "Clearview". Also the name suffix "Max" is being established as an addition to the product name of Luminos Agile, Luminos dRF and Uroskop Omnia.
Here's an analysis of the provided text regarding the acceptance criteria and study for the Siemens Medical Solutions X-ray systems:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in a pass/fail quantifiable manner, but rather presents a comparison demonstrating that the updated devices (with VF10 software) are "substantially equivalent" to their predicate devices. The performance metrics revolve around various technical specifications, particularly for the detectors and compliance with regulatory standards.
| Feature / Metric | Acceptance Criteria (Implied) | Reported Device Performance (VF10 Software) |
|---|---|---|
| Detector Performance | ||
| Pixium 4343-F (Fluoroscopy) | DQE / MTF comparable to predicate | DQE: 65% at 0.05 lp/mm, 51% at 1 lp/mm, 41% at 2 lp/mm, 25% at 3 lp/mm, 16% at 3.4 lp/mm (Nyquist) (Same as predicate) |
| MTF: 66% at 1 lp/mm, 35% at 2 lp/mm, 19% at 3 lp/mm, 15% at 3.4 lp/mm (Nyquist) (Slight change from predicate's 16% at Nyquist, deemed acceptable) | ||
| MAX wi-D (Mobile Rad) | DQE / MTF comparable or improved over predicate | DQE: 70% at 0.05 lp/mm, 51% at 1 lp/mm, 42% at 2 lp/mm, 29% at 3 lp/mm, 19% at Nyquist (Improved over predicate) |
| MTF: 63% at 1 lp/mm, 35% at 2 lp/mm, 19% at 3 lp/mm, 12% at Nyquist (Improved/Same over predicate) | ||
| MAX mini (Mobile Rad) | DQE / MTF comparable to predicate | DQE: 66% at 0.05 lp/mm, 50% at 1 lp/mm, 40% at 2 lp/mm, 24% at 3 lp/mm, 17% at Nyquist (Same as predicate) |
| MTF: 61% at 1 lp/mm, 31% at 2 lp/mm, 15% at 3 lp/mm, 12% at Nyquist (Same as predicate) | ||
| Regulatory Compliance | Compliance with updated and relevant standards (e.g., IEC, ISO, NEMA, FDA CFR) | Complies with IEC 60601-1:2012 Ed 3.1, IEC 60601-1-2:2007 Ed 4.0, IEC 60601-1-3:2012 Ed 2.1, IEC 62366:2014 Ed 1.1, ISO 14971:2007, IEC 62304 Ed 1.0:2006, IEC 60601-2-28:2010 Ed 2.0, IEC 60601-2-54:2009 Ed 1.0, IEC 61910-1:2014, NEMA PS 3.1 - 3.20:2011, ISO 10993-1:2009, IEC 60601-2-43:2010 Ed 2.0. Complies with 21 CFR 1020.30-32. |
| New Software Features | New features (Windows 10, cybersecurity, pediatric package, hospital IT integration, 16 fps mode) implemented without compromising safety/effectiveness. | All new features are implemented. Cybersecurity improved, operating system updated, pediatric package increased variability, Multitom Rax has improved dynamic resolution (16 fps). Deemed safe and effective. |
| Mechanical Robustness | Improved mechanical robustness of mobile detectors. | Edges of mobile detectors reinforced with steel caps; MAX wi-D handle changed to black carbon fiber. |
| Indications for Use | Maintained or revised for clarity and alignment, equivalent to predicates. | Revised for clarity and alignment; no fundamental alteration to indications for use. Equivalent to predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance
The document explicitly states: "For the subject of this premarket submission, Siemens did not do an evaluation of the clinical image quality as x-ray technology; geometry and SSXI changes are minor."
This indicates there was no dedicated clinical test set in terms of patient images. The evaluation primarily relied on non-clinical performance data, engineering verification and validation testing, and compliance with standards. Therefore, information regarding sample size, country of origin, or retrospective/prospective nature of a clinical test set is not applicable.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
As there was no clinical evaluation with a dedicated test set evaluated by experts, this information is not applicable. The ground truth for the non-clinical performance data (e.g., DQE, MTF) would be derived from physical measurements and calibrated test equipment, not expert human assessment.
4. Adjudication Method for the Test Set
Since there was no clinical test set requiring human interpretation, an adjudication method is not applicable.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study was done. The submission explicitly states "Siemens did not do an evaluation of the clinical image quality." Therefore, no effect size of human readers improving with AI vs. without AI assistance can be reported. The device is an X-ray imaging system, not an AI-based diagnostic tool for interpretation.
6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance Study
No standalone performance study of an algorithm was done in the context of image interpretation or diagnostic accuracy. The "software update VF10" relates to the operating system, cybersecurity, feature enhancements, and control of the imaging hardware, not a new diagnostic algorithm that would operate in a standalone manner. The performance data presented (DQE, MTF) are intrinsic characteristics of the imaging detectors themselves, measured objectively, and not an "algorithm-only" performance in a diagnostic sense.
7. Type of Ground Truth Used
For the non-clinical performance evaluation, the ground truth was based on:
- Physical measurements and industry standards: For detector performance metrics like DQE and MTF. These are objectively measured using specified test conditions and equipment.
- Compliance with regulatory and consensus standards: For safety, electromagnetic compatibility, software life cycle, and radiation control.
- Engineering verification and validation: To confirm software requirements are met and system functionality aligns with user needs.
There was no "expert consensus, pathology, or outcomes data" used as ground truth for a clinical efficacy study.
8. Sample Size for the Training Set
The document primarily describes a software upgrade and associated hardware (detector) changes for existing X-ray systems. It does not refer to a machine learning or AI algorithm that would require a "training set" of data. Therefore, the sample size for a training set is not applicable.
9. How the Ground Truth for the Training Set Was Established
Since there was no training set for a machine learning algorithm, this information is not applicable.
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Siemens Medical Solutions USA, Inc. % Denise Adams, RAC Regulatory Affairs Specialist 40 Liberty Boulevard, 65-1A MALVERN PA 19355
April 2, 2018
Re: K173639
Trade/Device Name: Luminos Agile Max. Luminos dRF Max. Uroskop Omnia Max. Multitom Rax Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OWB, JAA Dated: March 9, 2018 Received: March 13, 2018
Dear Ms. Adams:
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.
{1}------------------------------------------------
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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510(k) Number (if known)
Device Name Luminos Agile Max
Indications for Use (Describe)
Luminos Agile Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos Agile Max is not for mammography examinations.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{3}------------------------------------------------
510(k) Number (if known)
Device Name Luminos dRF Max
Indications for Use (Describe)
Luminos dRF Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos dRF Max is not for mammography 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) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{4}------------------------------------------------
510(k) Number (if known)
Device Name Multitom Rax
Indications for Use (Describe)
Multitom Rax is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Multitom Rax is not for mammography 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) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{5}------------------------------------------------
510(k) Number (if known)
Device Name Uroskop Omnia Max
Indications for Use (Describe)
Uroskop Omnia Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system is designed primarily for urological diagnosis and the support of urological therapeutic applications such as examinations and small interventions of the urogenital tract. The table supports endourological and minimal invasive surgery in urology as there are transurethral interventions (e.g. ureterorenoscopy (URS), double stent placement, cystoscopy, transurethral resection of bladder tumors (TURB), transurethral resection of the prostate (TURP)), percutaneous urological procedures (e.g. percutaneous nephrostomy (PCN), percutaneous nephrolitholapaxy (PCNL)), urological X-ray diagnosis (e.g. survey imaging of the kidney, ureter, and bladder (KUB), intravenous pyelogram (IVP), retrograde pyelography), micturition cystourethrogram (MCU), videourodynamics, laparoscopic procedures and minor open urological interventions. The system may be used on pediatric, adult and bariatric patients.
Uroskop Omnia Max is not for mammography 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) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{6}------------------------------------------------
K173639 510(k) Summary: Software Update VF10 for Luminos Agile Max, Luminos dRF Max, Multitom Rax, Uroskop Omnia Max
| Company: | Siemens Medical Solutions USA, Inc. |
|---|---|
| 40 Liberty Boulevard | |
| Malvern, PA 19355 |
March 9, 2018 Date Prepared:
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR § 807.92.
-
- General Information: Importer / Distributor: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Establishment Registration Number: 2240869
Location of Manufacturing Site: Siemens Healthcare GmbH Siemensstr. 1 91301 Forchheim, Germany Establishment Registration Number: 3004977335
- General Information: Importer / Distributor: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Establishment Registration Number: 2240869
2. Contact Person:
Denise Adams, RAC Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65 - 1A Malvern, PA 19355 adams.denise@siemens-healthineers.com
Alternate Contact Person:
Patricia D. Jones Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65 - 1A Malvern, PA 19355 patricia.d.jones@siemens-healthineers.com
{7}------------------------------------------------
3. Device Names and Classifications:
Trade Names: Luminos Agile Max Luminos dRF Max Uroskop Omnia Max Multitom Rax Product Code: OWB Secondary Product Code: JAA Classification Names: System, x-ray, fluoroscopic, image-intensified, Interventional fluoroscopic x-ray system Classification Panel: Radiology Regulation: 21 CFR §892.1650 Device Class: II
| Table 1: Legally Marketed Predicate Devices | ||||
|---|---|---|---|---|
| Trade Name | Luminos Agile | AXIOM Luminos dRF | Uroskop Omnia | Multitom Rax |
| 510(k) Number | K111292 | K062623 | K101491 | K152928 |
| Device Classification Name | System, x-ray, fluoroscopic, image-intensified | interventional fluoroscopic x-ray system | System, x-ray, fluoroscopic, image-intensified | interventional fluoroscopic x-ray system |
| Regulation Medical Specialty | Radiology | Radiology | Radiology | Radiology |
| Review Panel | Radiology | Radiology | Radiology | Radiology |
| Product Code | JAA | OWB | JAA | OWB |
| Subsequent Product Codes | IZI | JAA, OXO | MQB | JAA |
| Regulation Number | 892.1650 | 892.1650 | 892.1650 | 892.1650 |
| Device Class | 2 | 2 | 2 | 2 |
Table 1: Legally Marketed Predicate Devices 4.
5. Device Description:
All four radiology imaging devices are stationary X-ray systems for radiography and fluoroscopy. They use the same X-ray generator, the same X-ray tube and similar collimators. They also share the same imaging and system control device: The Fluorospot Compact. The reason for this submission is the upgrade of all systems to the software VF10. This new software will bring the following new features to the devices:
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| ProductName | IEC4thforEMC | Windows10 | Cyber-securitypackage | Pediatricpackage | UsehospitalIT (e.g.RIS) onmodality | 16fpsmodefor3D | SSXIupdate |
|---|---|---|---|---|---|---|---|
| LuminosAgile Max | √ | √ | √ | √ | √ | √ | |
| LuminosdRF Max | √ | √ | √ | √ | √ | √ | |
| UroskopOmniaMax | √ | √ | √ | √ | √ | √ | |
| MultitomRax | √ | √ | √ | √ | √ | √ | √ |
Table 2: New Features
The image processing algorithms (Diamond View Plus) will be used for exposures without grid and fluoroscopy image processing algorithms will be enhanced and called "Clearview"
Also the name suffix "Max" is being established as an addition to the product name of Luminos Agile, Luminos dRF and Uroskop Omnia.
6. Indications for Use:
The Indications for use have been revised for clarity and alignment.
Luminos Agile Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos Agile Max is not for mammography examinations.
Luminos dRF Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction
{9}------------------------------------------------
angiography (DSA). The system may be used on pediatric, adult and bariatric patients.
Luminos dRF Max is not for mammography examinations.
Multitom Rax is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography and digital subtraction angiography (DSA). The system may be used on pediatric, adult and bariatric patients
Multitom Rax is not for mammography examinations.
Uroskop Omnia Max is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system is designed primarily for urological diagnosis and the support of urological therapeutic applications such as examinations and small interventions of the urogenital tract. The table supports endourological and minimal invasive surgery in urology as there are transurethral interventions (e.g. ureterorenoscopy (URS), double stent placement, cystoscopy. transurethral resection of bladder tumors (TURB), transurethral resection of the prostate (TURP)), percutaneous urological procedures (e.g. percutaneous nephrostomy (PCN), percutaneous nephrolitholapaxy (PCNL)), urological X-ray diagnosis (e.g. survey imaging of the kidney, ureter, and bladder (KUB), intravenous pyelogram (IVP), retrograde pyelography), micturition cystourethrogram (MCU), videourodynamics, laparoscopic procedures and minor open urological interventions. The system may be used on pediatric, adult and bariatric patients.
Uroskop Omnia Max is not for mammography examinations.
7. Substantial Equivalence:
The new system software VF10 does not alter the fundamental indication for use nor does it change the technology being used for X-ray imaging. The devices remain within the same classification regulation for the same indication for use as the predicate devices. The new system software design was completed in accordance with Siemens Quality Management System Design Controls comparable to the processes available for the predicate devices. The scope of internationally recognized standards compliance was updated to the standards recognized at the time of the design of the new software. Verification and Validation testing were the same or similar to the testing being used with the predicate devices.
The new system software VF10 controls solid state X-ray imagers (SSXI) similar to the imagers being used with the predicate devices. The SSXIs have been improved for mechanical robustness.
{10}------------------------------------------------
- The edges of the mobile detectors were reinforced with steel caps to increase the ● mechanical robustness.
- The handle of the MAX wi-D will not be coated anymore with white film and will . appear in a black carbon fiber look.
The following tables compare the performance changes of the detectors being used with the VF10 to the predicate detectors. The changed data are highlighted in bold letters.
| Table 3: Comparison of Detector 4343-F Subject and Predicate | ||
|---|---|---|
| VE 20 / K152928 | VF 10 K173639 | |
| Fluoroscopy detector | Pixium 4343-F | Pixium 4343-F |
| Field of view (Max) | 42 cm x 42.6cm | 42.0 cm x 42.5 cm |
| Matrix size | Up to 2840 x 2874 pixel | Up to 2840 x 2874 pixel |
| DQE; 200 nGy | 65 % at 0.05 lp/mm | 65 % at 0.05 lp/mm |
| 51 % at 1 lp/mm | 51 % at 1 lp/mm | |
| 41 % at 2 lp/mm | 41 % at 2 lp/mm | |
| 25 % at 3 lp/mm | 25 % at 3 lp/mm | |
| 16 % at 3.4 lp/mm (Nyquist) | 16 % at 3.4 lp/mm (Nyquist) | |
| MTF | 66 % at 1 lp/mm | 66 % at 1 lp/mm |
| 35 % at 2 lp/mm | 35 % at 2 lp/mm | |
| 19 % at 3 lp/mm | 19 % at 3 lp/mm | |
| 16 % at 3.4 lp/mm (Nyquist) | 15 % at 3.4 lp/mm (Nyquist) |
Table 3: Comparison of Dotoctor 4343-F Subject and Prodicate
Table 4: Comparison of Detector MAX wi-D Subject and Predicate
| Mobil Rad detector | VE 20 / K152928 | VF 10 |
|---|---|---|
| Siemens Name | MAX wi-D | MAX wi-D |
| Trixell name | Pixium 3543 EZh | Pixium 3543 EZh |
| Dimensions | 34.9 cm x 42.5 cm | 34.8 cm x 42.4 cm |
| Matrix size | 2356 x 2872 | 2350 x 2866 |
| DQE; 2 μ Gy | 66 % at 0.05 lp/mm | 70 % at 0.05 lp/mm |
| 50 % at 1 lp/mm | 51 % at 1 lp/mm | |
| 40 % at 2 lp/mm | 42 % at 2 lp/mm | |
| 24 % at 3 lp/mm | 29 % at 3 lp/mm | |
| 17 % at Nyquist | 19 % at Nyquist | |
| MTF | 61 % at 1 lp/mm | 63 % at 1 lp/mm |
| 31 % at 2 lp/mm | 35 % at 2 lp/mm | |
| 15 % at 3 lp/mm | 19 % at 3 lp/mm | |
| 12 % at Nyquist | 12 % at Nyquist |
Table 5: Comparison of Detector MAX mini Subject and Predicate
| Mobil Rad detector | VE 20 / K152928 | VF 10 |
|---|---|---|
| Siemens Name | MAX mini | MAX mini |
| Trixell name | Pixium 2430EZ | Pixium 2430EZ |
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| Dimensions (activearea) | 28.4 cm x 22.8 cm | 28.4 cm x 22.5 cm |
|---|---|---|
| Matrix size | 1920 x 1538 | 1920 x 1520 |
| DQE; 2 $\mu$ Gy | 66 % at 0.05 lp/mm | 66 % at 0.05 lp/mm |
| 50 % at 1 lp/mm | 50 % at 1 lp/mm | |
| 40 % at 2 lp/mm | 40 % at 2 lp/mm | |
| 24 % at 3 lp/mm | 24 % at 3 lp/mm | |
| 17 % at Nyquist | 17 % at Nyquist | |
| MTF | 61 % at 1 lp/mm | 61 % at 1 lp/mm |
| 31 % at 2 lp/mm | 31 % at 2 lp/mm | |
| 15 % at 3 lp/mm | 15 % at 3 lp/mm | |
| 12 % at Nyquist | 12 % at Nyquist |
Summary of Technological Characteristics of the Subject Device as Compared 8. with the Predicate Devices:
The subject devices with the new software VF10 use the same X-ray generator, the same X-ray tube and the similar SSXI with the same digital imaging system and similar image processing software as the predicate devices. There are no changes in the patient environment or the type of user interface.
The following table compares the main performance data of the subject devices with the predicate devices to substantiate equivalence of the subject device and predicate devices.
| Subject Devices | Predicate Devices | Comparison/Comments | |
|---|---|---|---|
| Feature | Luminos Agile MaxLuminos dRF MaxUroskop Omnia MaxMultitom Rax | Luminos AgileAXIOM Luminos dRFUroskop OmniaMultitom Rax | |
| X-ray | |||
| Generator | Polydoros65/80 kW | Polydoros65/80 kW | |
| X-ray tube | OPTITOP150/40/80/HC-100 | OPTITOP150/40/80/HC-100 | X-ray |
| Collimator | Digital MultileafCollimator N | Digital MultileafCollimator N | Imaging |
| Air kerma | Kerma X | Kerma X | |
| X-ray techniques | RadiographyPulsed fluoroscopyDSA and seriesexposure | RadiographyPulsed fluoroscopyDSA and seriesexposure | componentsare the same |
| Organ programs | X-ray parametersImaging processingparameters | X-ray parametersImaging processingparameters | |
| Testing | |||
| IEC Compliancefor 60601-1-2EMC | IEC 4th edition | IEC 3rd edition | Testingaccording tocurrent IECtest scope |
| Digital Imaging | |||
| FluoroscopicSSXI integratedinto system | Trixell Pixium 5100Max Dynamic =4343F-4 | Trixell Pixium 5100Max Dynamic =4343F-3 | Image Chainis similar topredicatedevices. |
| SSXI for Radimaging | Trixell PixiumMAX wi-D =3543EZhMAX mini = 2430EZ | Trixell PixiumMAX wi-D =3543EZhMAX mini = 2430EZ | DetectorPerformancedataaccording ToSSXI |
| Digital imagingsystem | Fluorospot Compact | Fluorospot Compact | guidance areprovided |
| Image processing | Diamond View PlusClearview | Diamond View PlusApplication specificorgan programs | Sameprocessingmade userfriendly |
| MS Operatingsystem | Windows 10 | Windows 7 | NewOperatingsystem |
| Cybersecurity | Security packagebased on MS Win 10 | Security packagebased on MS Win 7 | Improved |
| Integration ofhospital IT | Hospital/RadiologyInformation System | Hospital/RadiologyInformation System | Improved |
| Maximum Framerate (acquisition) | 16 Frames/second* | 8 Frames/second | Improveddynamicresolution |
| *For Multitom Rax only | |||
| Pediatric package | Increased number oforgan programs | Organ programs | Increasednumber andvariability |
Table 6: Technical Comparison with the Predicates
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9. Summary of Non-Clinical Test Data:
The devices operating with software VF10 comply with the voluntary standards as listed in the following table:
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Table 7: Compliance with Standards
| DevelopmentOrganization andReference Number | Standard Title |
|---|---|
| IEC 60601-1:2012,Edition 3.1 | Medical Electrical Equipment - Part 1: GeneralRequirements for Safety |
| IEC 60601-1-2:2007Edition 4.0 | Medical Electrical Equipment - Part 1-2: Generalrequirements for basic safety and essential performance -Collateral Standard: Electromagnetic Compatibility --Requirements and Tests |
| IEC 60601-1-3: 2012,Edition 2.1 | Medical electrical equipment - Part 1-3: Generalrequirements for basic safety and essential performance -Collateral Standard: Radiation protection in diagnostic X-ray equipment |
| IEC 62366:2014Edition 1.1 | Medical devices – Application of usability engineering tomedical devices |
| ISO 14971, 2007 | medical devices – application of risk management tomedical devices |
| IEC 62304 Ed. 1.0, 2006 | Medical device software - Software life cycle processes |
| IEC 60601-2-28:2010Edition 2.0 | Medical electrical equipment - Part 2-28: Particularrequirements for the basic safety and essential performanceof X-ray tube assemblies for medical diagnosis |
| IEC 60601-2-54, 2009Edition 1.0 | Medical electrical equipment - Part 2-54: Particularrequirements for the basicsafety and essential performance of X-ray equipment forradiography andradioscopy |
| IEC 61910-1, 2014 | Medical electrical equipment - Radiation dosedocumentation - Part 1: Radiation dose structured reportsfor radiography and radioscopy (IEC 61910-1:2014) |
| NEMA PS 3.1 - 3.20,2011 | Digital Imaging and Communications in Medicine(DICOM) Set |
| ISO 10993-1, 2009 | Biological evaluation of medical devices -- Part 1:Evaluation and testing within a risk management process |
| IEC 60601-2-43:2010Edition 2.0 | Medical electrical equipment - Part 2-43: Particularrequirements for the safety of X-ray equipment forinterventional procedures |
The following international standards were used in the development of the VF10:
The Software VF10 design was completed in accordance with Siemens Quality Management System Design Controls and verification and validation testing were successfully conducted. Non-clinical performance data are provided for the updated detectors. All radiology and fluoroscopy systems use the same software. Certain
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features of the software are enabled or disabled depending on the system and its indications for use (i.e. 16 frames per second for Multitom Rax versus 8 frames per second for all other systems. The new IEC 4th edition has been applied for the compliance to the IEC 60601-1-2 electromagnetic compatibility standard.
The tests were performed on the new software VF10 demonstrating that the devices are safe and effective, perform comparably to the predicate devices, and are substantially equivalent to the predicate devices.
Documentation provided demonstrates compliance of the subject devices to all FDA requirements stated in the Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, including results of verification/validation tests of software requirements and software risk hazards.
Performance testing confirmed that the five devices comply with 21 CFR 1020.30-32 Federal Performance Standards for X-Ray Fluoroscopic equipment. The applicable sections include:
| 1020.30(c) | Manufacturer's Responsibility (Certification) |
|---|---|
| 1020.30(e) | Identification of X-ray components |
| 1020.30(g) | Information to be provided to assemblers |
| 1020.30(h) | Information to be provided to users |
| 1020.31(k) | Leakage Radiation |
| 1020.30(m) | Beam Quality |
| 1020.32(d) | Fluoroscopic Entrance exposure rate |
| 1020.32 (a) | Primary Protective Barrier Transmission |
| 1020.31(a) | Peak Tube Potential |
| 1020.32(b) | Alignment of edges of the X-ray field with the edges |
| of the fluoroscopic image receptor | |
| 1020.32(k) | Display of values of AKR and cumulative air kerma |
| 1040.10 | Laser products |
The software VF10 controls solid state X-ray imagers (SSXI) that are similar in performance to the predicates. Performance data are provided according to the "Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices, issued on: September 1, 2016".
Together, the verification/validation activities successfully confirmed that the software requirements have been fulfilled and that system functionality is consistent with the user needs and intended uses. The VF10 software correctly performs as designed and raises no new questions regarding safety or effectiveness. Therefore, when compared to the predicate devices the devices with the new software VF10 support a determination of substantial equivalence.
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10. Summary of Clinical Tests:
For the subject of this premarket submission, Siemens did not do an evaluation of the clinical image quality as x-ray technology; geometry and SSXI changes are minor.
General Safety and Effectiveness Concerns: 11.
Instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner. Several safety features including visual and audible warnings are incorporated into the system design. In addition the devices are continually monitored, and if an error occurs, the system functions will be blocked and an error message will be displayed.
Furthermore the operators are health care professionals familiar with and responsible for the x-ray examinations to be performed. To minimize electrical, mechanical and radiation hazards, Siemens adheres to recognized and established industry practice, and all equipment is subject to final performance testing.
12. Conclusion as to Substantial Equivalence:
The radiology and fluoroscopy devices with VF10 software are intended for the same indications for use as the predicate devices. The operating environment is the same and the technology is effectively unchanged. Siemens concludes via the documentation provided in this 510(k) submission that the radiology and fluoroscopy devices Luminos Agile Max, Luminos dRF Max, Uroskop Omnia Max and Multitom Rax with VF10 software are substantially equivalent to the predicate devices Luminos Agile, AXIOM Luminos dRF, Uroskop Omnia, Multitom Rax.
13. Guidance documents
The following FDA guidance documents were utilized in the documentation of this Premarket Notification:
- Guidance for Industry and FDA Staff . Bundling Multiple Devices or Multiple Indications in a Single Submission Document issued on: June 22, 2007
- . Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014
- Information to Support a Claim of Electromagnetic Compatibility (EMC) of Electrically-Powered Medical Devices Guidance for Industry and Food and Drug Administration Staff Document issued on July 11, 2016. The draft of this document was issued on November 2, 2015.
- Pediatric Information for X-ray . Imaging Device Premarket Notifications Guidance for Industry and Food and Drug Administration Staff
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Document issued on November 28, 2017.
- . Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices 1 Guidance for Industry and Food and Drug Administration Staff Document issued on: September 1, 2016
- Guidance for Industry and FDA Staff ● Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005
- Guidance for Industry and FDA Staff Recognition and Use of Consensus Standards Document issued on: September 17, 2007
- . The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)] Guidance for Industry and Food and Drug Administration Staff Document issued on: July 28, 2014
- Radio Frequency Wireless Technology in Medical Devices ● Guidance for Industry and Food and Drug Administration Staff Document issued on: August 14, 2013
§ 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.