K Number
K182213
Device Name
QT Ultrasound Breast Scanner - 1
Manufacturer
Date Cleared
2018-09-14

(30 days)

Product Code
Regulation Number
892.1560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The QT Ultrasound Breast Scanner - 1 is for use as an ultrasonic imaging system to provide reflection-mode and transmission-mode images of a patient's breast. The device is not intended to be used as a replacement for screening mammography. Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows: Small Organ (Breast) - Reflection, Transmission (Speed of Sound). QT Ultrasound Breast Scanner-1 is intended for ultrasonic breast exams.
Device Description
The QT Ultrasound Breast Scanner - 1 is an automated software-controlled ultrasonic imaging system that performs a standardized scan of the whole breast. The OT Ultrasound Breast Scanner - 1 is comprised of a Patient Scanning System, Operator Console and Viewer Console. The Patient Scanning System consists of a patient support table, scan tank, water management system, ultrasound transducer arrays and all associated image processing electronics. The scan tank is centered below a patient's breast and contains the ultrasound transducer arrays. The transducer arrays include a set of three reflection transducers that transmit pulsed ultrasound plane waves into targeted tissues using the water bath in the scan tank as a coupling medium. An additional transmitter and receiver array pair collect the ultrasound energy to provide speed of sound values. During scanning, a patient lies prone on the examination table with the breast suspended in a warm water bath maintained near skin temperature. Images are automatically acquired on a pendant breast positioned with the nipple as a point of reference. The transducer arrays rotate about a vertical axis to circle the breast in the coronal plane. The array is then translated vertically, and the scanning process is repeated until the entire breast is scanned, allowing B-scan images to be constructively combined into tomographic, speed of sound and reflection ultrasound images. The QT Ultrasound Breast Scanner – 1 outputs the images to the QTviewer™ which allows the images to be stored until they are reviewed on a Viewer Console. Coronal, axial and sagittal images are generated for review by the radiologist. Speed of sound images may be queried by the Probe and Region of Interest (ROI) tools provided in the Viewer Console. These tools provide speed of sound values in meters/sec. to aid in diagnostic evaluation of the breast.
More Information

Not Found

No
The summary describes image processing and reconstruction techniques but does not mention AI, ML, or related terms, nor does it describe any training or testing of algorithms on data.

No.
The device is described as an ultrasonic imaging system for diagnostic purposes, providing images of a patient's breast, and is not intended for therapeutic use.

Yes

The "Intended Use / Indications for Use" section explicitly states, "Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows: Small Organ (Breast) - Reflection, Transmission (Speed of Sound)." Additionally, the device output aids in "diagnostic evaluation of the breast" as stated in the "Device Description."

No

The device description clearly outlines hardware components such as a Patient Scanning System, Operator Console, Viewer Console, patient support table, scan tank, water management system, and ultrasound transducer arrays. While software controls the system and processes images, it is an integral part of a larger hardware system.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to examine these samples outside of the body ("in vitro").
  • Device Function: The QT Ultrasound Breast Scanner - 1 is an imaging system that uses ultrasound to create images of the breast within the patient's body. It does not analyze samples taken from the patient.
  • Intended Use: The intended use clearly states it's for providing "reflection-mode and transmission-mode images of a patient's breast" and for "ultrasonic breast exams." This is consistent with an in-vivo imaging device, not an in-vitro diagnostic test.

Therefore, the QT Ultrasound Breast Scanner - 1 is an in-vivo diagnostic imaging device, not an in-vitro diagnostic device.

N/A

Intended Use / Indications for Use

The QT Ultrasound Breast Scanner - 1 is for use as an ultrasonic imaging system to provide reflection-mode and transmission-mode images of a patient's breast. The device is not intended to be used as a replacement for screening mammography.

Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows: Small Organ (Breast) - Reflection, Transmission (Speed of Sound). QT Ultrasound Breast Scanner-1 is intended for ultrasonic breast exams.

Product codes

IYO, ITX

Device Description

The QT Ultrasound Breast Scanner - 1 is an automated software-controlled ultrasonic imaging system that performs a standardized scan of the whole breast. The OT Ultrasound Breast Scanner - 1 is comprised of a Patient Scanning System, Operator Console and Viewer Console.

The Patient Scanning System consists of a patient support table, scan tank, water management system, ultrasound transducer arrays and all associated image processing electronics. The scan tank is centered below a patient's breast and contains the ultrasound transducer arrays. The transducer arrays include a set of three reflection transducers that transmit pulsed ultrasound plane waves into targeted tissues using the water bath in the scan tank as a coupling medium. An additional transmitter and receiver array pair collect the ultrasound energy to provide speed of sound values.

During scanning, a patient lies prone on the examination table with the breast suspended in a warm water bath maintained near skin temperature. Images are automatically acquired on a pendant breast positioned with the nipple as a point of reference. The transducer arrays rotate about a vertical axis to circle the breast in the coronal plane. The array is then translated vertically, and the scanning process is repeated until the entire breast is scanned, allowing B-scan images to be constructively combined into tomographic, speed of sound and reflection ultrasound images.

The QT Ultrasound Breast Scanner – 1 outputs the images to the QTviewer™ which allows the images to be stored until they are reviewed on a Viewer Console. Coronal, axial and sagittal images are generated for review by the radiologist. Speed of sound images may be queried by the Probe and Region of Interest (ROI) tools provided in the Viewer Console. These tools provide speed of sound values in meters/sec. to aid in diagnostic evaluation of the breast.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound

Anatomical Site

Breast

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The function and performance of the modified OT Ultrasound Breast Scanner - 1 has been evaluated through non-clinical design verification and validation testing. All necessary testing was conducted on the proposed QT Ultrasound Breast Scanner - 1 to support a determination of substantial equivalence to the unmodified predicate device. Specifically, the impacts of the design changes presented with the subject device were evaluated through Design Control, and a number of required testing accordingly determined and subsequently performed. Testing included system performance and simulated use tests. All necessary validation testing, including comprehensive software verification and validation, was performed, the results of which demonstrate that the modified QT Ultrasound Brast Scanner - 1 successfully meets design specification. As a part of design validation, a small usability investigation was conducted, which demonstrated the new user interface presented with Reseach Mode meets user requirements.

This testing confirms that the design changes presented with the subject device do not raise new questions of safety and effectivess, the subject device meets design specifications, and that the subject and predicate devices are substantially equivalent. The modified QT Ultrasound Breast Scanner – 1 is only different due to an updated version of the QTviewer Software Module.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K162372

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.1560 Ultrasonic pulsed echo imaging system.

(a)
Identification. An ultrasonic pulsed echo imaging system is a device intended to project a pulsed sound beam into body tissue to determine the depth or location of the tissue interfaces and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. 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). A biopsy needle guide kit intended for use with an ultrasonic pulsed echo imaging 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.

0

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

September 14, 2018

QT Ultrasound LLC Mark W. Lenox Chief Technology Officer 3 Hamilton Landing. Suite 160 NOVATO, CA 94949

Re: K182213

Trade/Device Name: OT Ultrasound Breast Scanner - 1 Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic pulsed echo imaging system Regulatory Class: Class II Product Code: IYO, ITX Dated: August 14, 2018 Received: August 15, 2018

Dear Mark Lenox:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

For 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,

Digitally signed by Jeffre
-S
DN: c=US, o=U.S. Govern
ou=HHS, ou=FDA, ou=Pe
0.9.2342.19200300.100.1
9725, cn=Jeffrey J. Ballym
Date: 2018.09.14 13:52:5

c=US, o=U.S. Government,
=HHS, ou=FDA, ou=People,
2342.19200300.100.1.1=200056
5, cn=Jeffrey J. Ballyns -S
e: 2018.09.14 13:52:52 -04'00'

for Robert A. Ochs. Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K182213

Device Name QT Ultrasound Breast Scanner - 1

Indications for Use (Describe)

The QT Ultrasound Breast Scanner - 1 is for use as an ultrasonic imaging system to provide reflection-mode and transmission-mode images of a patient's breast. The device is not intended to be used as a replacement for soreening mammography.

Type of Use (Select one or both, as applicable)
-------------------------------------------------
For Evaluation Use (Per 21 CFR 201.66, Subpart D)
For Compassionate Use (21 CFR 312.300)

X | Prescription Use (Part 21 CFR 801 Subpart D)

| | Over-The-Counter Use (21 CFR 801 Subpart C)

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3

Diagnostic Ultrasound Indications for Use

System: QT Ultrasound Breast Scanner-1

Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:

Clinical ApplicationMode of Operation
General
(Track 1 only)Specific (Tracks 1 & 3)BMPWDCWDColor
DopplerCombinedOther
OphthalmicOphthalmic
Fetal
Abdominal
Intra-operative (Specify)
Intra-operative (Neuro)
Laparoscopic
Pediatric
Small Organ (Breast)N1N2
Neonatal Cephalic
Fetal Imaging
& OtherAdult Cephalic
Trans-rectal
Trans-vaginal
Trans-urethral
Trans-esoph. (non-Card.)
Musculo-skeletal
(Conventional)
Musculo-skeletal
(Superficial)
Intravascular
Other (Specify)
Cardiac Adult
Cardiac Pediatric
CardiacIntravascular (Cardiac)
Trans-esoph. (Cardiac)
Intra-cardiac
Other (Specify)
PeripheralPeripheral vessel
VesselOther (Specify)

N=New Indication; P = previously cleared by FDA; E = added under this appendix

1 – Reflection

2 – Transmission (Speed of Sound)

Additional Comments: QT Ultrasound Breast Scanner-1 is intended for ultrasonic breast exams

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Image /page/4/Picture/0 description: The image shows the logo for QT Ultrasound. The logo features the letters "QT" in a light green color, with the word "ultrasound" in a light gray color next to it. The font is sans-serif and modern.

510(K) SUMMARY

In accordance with 21 CFR 807.92 the following summary of information is provided:

1.0 SUBMITTER INFORMATION

| Submitted By | QT Ultrasound® LLC
3 Hamilton Landing, Suite 160
Novato, CA 94949 |
|----------------------------------------------|-----------------------------------------------------------------------------------------------------------|
| Contact Information | Mark W. Lenox, PhD
Phone: (865) 382-2649
Fax: (415) 234-6511
Email: mark.lenox@qtultrasound.com |
| Date of Submission | September 12, 2018 |
| Type of Submission | Special 510(k)
Modification to QT Ultrasound Breast Scanner – 1(K162372) |
| DEVICE INFORMATION | |
| Trade / Proprietary Name | QT Ultrasound Breast Scanner – 1 |
| Common Name | System, Imaging, Pulsed Echo Ultrasonic
Transducer, Ultrasonic, Diagnostic |
| Classification Name and
Regulation Number | 21CFR §892.1560 Ultrasonic pulsed echo imaging system
21CFR §892.1570 Diagnostic ultrasonic transducer |

Product Codes IYO, ITX

3.0 PREDICATE DEVICE

2.0

The predicate device is the QT Ultrasound Breast Scanner - 1, also manufactured by QT Ultrasound, LLC. QT Ultrasound Breast Scanner - 1 received market clearance under 510(k) number K162372.

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Image /page/5/Picture/0 description: The image shows the logo for QT Ultrasound. The logo consists of the letters "QT" in a light green color, with the word "ultrasound" in a light gray color next to it. The font is sans-serif and the overall design is simple and modern.

4.0 DEVICE DESCRIPTION

The QT Ultrasound Breast Scanner - 1 is an automated software-controlled ultrasonic imaging system that performs a standardized scan of the whole breast. The OT Ultrasound Breast Scanner - 1 is comprised of a Patient Scanning System, Operator Console and Viewer Console.

The Patient Scanning System consists of a patient support table, scan tank, water management system, ultrasound transducer arrays and all associated image processing electronics. The scan tank is centered below a patient's breast and contains the ultrasound transducer arrays. The transducer arrays include a set of three reflection transducers that transmit pulsed ultrasound plane waves into targeted tissues using the water bath in the scan tank as a coupling medium. An additional transmitter and receiver array pair collect the ultrasound energy to provide speed of sound values.

During scanning, a patient lies prone on the examination table with the breast suspended in a warm water bath maintained near skin temperature. Images are automatically acquired on a pendant breast positioned with the nipple as a point of reference. The transducer arrays rotate about a vertical axis to circle the breast in the coronal plane. The array is then translated vertically, and the scanning process is repeated until the entire breast is scanned, allowing B-scan images to be constructively combined into tomographic, speed of sound and reflection ultrasound images.

The QT Ultrasound Breast Scanner – 1 outputs the images to the QTviewer™ which allows the images to be stored until they are reviewed on a Viewer Console. Coronal, axial and sagittal images are generated for review by the radiologist. Speed of sound images may be queried by the Probe and Region of Interest (ROI) tools provided in the Viewer Console. These tools provide speed of sound values in meters/sec. to aid in diagnostic evaluation of the breast.

INTENDED USE 5.0

The OT Ultrasound Breast Scanner - 1 is for use as an ultrasonic imaging system to provide reflection-mode and transmission-mode images of a patient's breast. The device is not intended to be used as a replacement for screening mammography.

6.0 PREDICATE DEVICE COMPARISON

The modified QT Ultrasound Breast Scanner - 1 is substantially equivalent to the predicate device, the OT Ultrasound Breast Scanner - 1 cleared by the FDA in K162372. QT Ultrasound claims substantial equivalence because the proposed device has an equivalent intended use, operating principles, fundamental scientific technology, technological characteristics, and physical and operational specifications as compared to

6

Image /page/6/Picture/0 description: The image shows the logo for QT ultrasound. The logo consists of the letters "QT" in a light green color, followed by the word "ultrasound" in a light gray color. The logo is simple and modern, and it is likely used to represent a medical imaging company or service.

the predicate device. The modified QT Ultrasound Breast Scanner - 1 and the predicate device utilize B-mode grayscale ultrasound images to achieve their intended use. Both the modified QT Ultrasound Breast Scanner - 1 and the predicate device are table-top systems that have automatic scanning transducers to image breast tissue.

A brief summary of the similarities and differences between the modified QT Ultrasound Breast Scanner – 1 and the QT Ultrasound Breast Scanner – 1 (K162372) is included below:

Similarities

The fundament scientific technology and all Technological Characteristics are the same for both the modified QT Ultrasound Breast Scanner – 1 and the QT Ultrasound Breast Scanner - 1 (K162372); all technological characteristics and are listed below:

  • Both systems use an automated transducer to acquire images of a patient's breast. ●
  • o Both systems use broadband transducers.
  • Both systems acquire and process B-mode grayscale images of a patient's breast.
  • Both systems acquire and process grayscale speed of sound images of a patient's breast.
  • . Both systems position the patient in a prone position lying on their examination table with the patient's breast in a pendulous position within an imaging chamber.
  • Both systems position the patient's breast in a fluid environment to eliminate the need for breast compression and to facilitate the transmission of ultrasound waves.
  • . Both systems display of speed of sound Information is the same. Both provide grayscale speed of sound images that may be acquired by Probe and/or ROI tools available in the OTviewer. Both systems use this information as an aid/reference information for diagnostic evaluation of the breast.
  • . Both systems display 3-D volume image acquisition.
  • . Both systems perform image reconstruction in 3-D.

Differences

The differences between the modified QT Ultrasound Breast Scanner - 1 and the QT Ultrasound Breast Scanner – 1 (K162372) are the modifications made to the QTviewer Software Module. The summary of the differences between the modified QT Ultrasound Breast Scanner - 1 and the QT Ultrasound Breast Scanner - 1 (K162372) are listed in Table 2-1.

7

| Table 2-1. Differences Between the Modified QT Ultrasound Breast Scanner – 1 and the

QT Ultrasound Breast Scanner – 1 (K162372)
ModificationDiscussion
Modified
QTviewer
Software ModuleVarious bug fixes, cosmetic changes, addition of annotation features,
snapshot feature and research mode, along with enhancements were made
to the QTviewer Software Module that was part of the FDA cleared QT
Ultrasound Breast Scanner – 1 (K162372).

The differences noted between the modified QT Ultrasound Breast Scanner - 1 and the predicate device, the QT Ultrasound Breast Scanner - 1 (K162372), do not present any new or different questions related to safety and effectiveness.

7.0 SUMMARY OF NON-CLINICAL TESTING

The function and performance of the modified OT Ultrasound Breast Scanner - 1 has been evaluated through non-clinical design verification and validation testing. All necessary testing was conducted on the proposed QT Ultrasound Breast Scanner - 1 to support a determination of substantial equivalence to the unmodified predicate device. Specifically, the impacts of the design changes presented with the subject device were evaluated through Design Control, and a number of required testing accordingly determined and subsequently performed. Testing included system performance and simulated use tests. When applicable, non-clinical testing was conducted per the standards listed in Table 2-2. All necessary validation testing, including comprehensive software verification and validation, was performed, the results of which demonstrate that the modified QT Ultrasound Brast Scanner - 1 successfully meets design specification. As a part of design validation, a small usability investigation was conducted, which demonstrated the new user interface presented with Reseach Mode meets user requirements.

This testing confirms that the design changes presented with the subject device do not raise new questions of safety and effectivess, the subject device meets design specifications, and that the subject and predicate devices are substantially equivalent. The modified QT Ultrasound Breast Scanner – 1 is only different due to an updated version of the QTviewer Software Module; therefore, not all testing was applicable since the original submission. A comparsion of all testing between the modified OT Ultrasound Breast Scanner - 1 and the predicate, QT Ultrasound Breast Scanner - 1 (K162372) is shown in Table 2-2.

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Table 2-2. Testing Performed
Type of TestingTests PerformedQT Ultrasound
Breast Scanner – 1
(K162372)Modified QT
Ultrasound Breast
Scanner – 1
(This submission)
Electrical Safety
AAMI ES60601-
1:2005/(R)2012 And
A1:2012 Medical
electrical equipment -
Part 1: General
requirements for basic
safety and essential
performanceAll applicable electrical,
basic safety and
essential performance
tests.
Testing was conducted
by Intertek, an
independent testing
laboratory, located in
Menlo Park, CA.PerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.
Electromagnetic
Compatibility
IEC 60601-1-2 Edition
3: 2007-03 Medical
electrical equipment -
Part 1-2: General
requirements for basic
safety and essential
performance - Collateral
Standard:
Electromagnetic
disturbances -
Requirements and testsAll applicable testing
pertaining to
electromagnetic
compatibility.
Testing was conducted
by Intertek, an
independent testing
laboratory, located in
Menlo Park, CA.PerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.
Usability
IEC 62366 Edition 1.1
2014-01 - Medical
devices- Application of
usability engineering to
medical devices
IEC 60601-1-6 Edition
3.1 2013-10 - Medical
electrical equipment Part
1-6 General
requirements for safety -
Collateral Standard:
UsabilityAll applicable testing
pertaining to usability.
Testing was conducted
by Intertek, an
independent testing
laboratory, located in
Menlo Park, CA.PerformedPerformed
Table 2-2. Testing Performed
Type of TestingTests PerformedQT Ultrasound
Breast Scanner – 1
(K162372)Modified QT
Ultrasound Breast
Scanner – 1
(This submission)
Acoustic Output
IEC 60601-2-37 Edition
2.0 2007 Medical
electrical equipment –
Part 2-37: Particular
requirements for the
basic safety and
essential performance of
ultrasonic medical
diagnostic and
monitoring equipment.
NEMA UD 2-2004
(R2009) Acoustic
Output Measurement
Standard for Diagnostic
Ultrasound Equipment –
Revision 3All applicable testing
pertaining to the
requirements for the
safety of ultrasonic
medical diagnostic and
monitoring equipment
and to demonstrate
compliance with the
"Acoustic Output
Measurement Standard
for Diagnostic
Ultrasound Equipment".
Testing was conducted
by QT Ultrasound and
witnessed by Intertek,
an independent testing
laboratory, located in
Menlo Park, CA. The
QT Ultrasound Breast
Scanner – 1 meets all
Track 1 acoustic output
requirements. The
results of acoustic
output testing are listed
in Table 2-3 below.PerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.
Software Development
IEC 62304:2006 (First
Edition) – Medical
device software –
Software life cycle
processesInternal procedures for
software life cycle
management were used
for software
development,
verification / validation
and configuration
controlPerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated viewer
Software Module.
Table 2-2. Testing Performed
Type of TestingTests PerformedQT Ultrasound
Breast Scanner – 1
(K162372)Modified QT
Ultrasound Breast
Scanner – 1
(This submission)
Software Verification
and ValidationSoftware was tested at
the module and system
levels to ensure that it
met the software's
design and intended use
requirements. All
requirements were met,
and no new issues of
safety or effectiveness
compared to the
predicate device were
raised.PerformedPerformed
System Verification and
PerformanceSystem verification
testing was conducted to
ensure that the QT
Ultrasound Breast
Scanner – 1 met design
requirements. In
addition, the following
system performance
characteristics are
reported:
• Measurement Range /
Accuracy
• Spatial Resolution
• Contrast Resolution /
Contrast to Noise
Ratio
• Speed of Sound
Uniformity and
Accuracy
All requirements were
met, and no new issues
of safety or
effectiveness compared
to the predicate devicePerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.
Table 2-2. Testing Performed
Type of TestingTests PerformedQT Ultrasound
Breast Scanner – 1
(K162372)Modified QT
Ultrasound Breast
Scanner – 1
(This submission)
Biocompatibility
ISO 10993-
1:2009/(R)2013 -
Biological evaluation of
medical devices - Part 1:
Evaluation and testing
within a risk
management processBiocompatibility testing
was conducted to ensure
that the patient
contacting materials in
the QT Ultrasound
Breast Scanner - 1 met
design requirements. All
requirements were met,
and no new issues of
safety or effectiveness
compared to the
predicate device were
raised.PerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.
ISO 10993-
5:2009/(R)2014 -
Biological evaluation of
medical devices - Part 5:
Tests for in vitro
cytotoxicity
ISO 10993-
10:2010/(R)2014 -
Biological evaluation of
medical devices - Part
10: Tests for irritation
and skin sensitization
ISO 10993-
11:2006/(R)2010 -
Biological evaluation of
medical devices - Part
11: Tests for systemic
toxicity
Cleaning Procedures
Scan TankMicrobial analysis and
particulate testing of the
water in the scan tank
was conducted. All
requirements were met,
and no new issues of
safety or effectiveness
compared to the
predicate device were
raised.PerformedNot Applicable; the
only modification
made to the QT
Ultrasound Breast
Scanner – 1 is an
updated QTviewer
Software Module.

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Image /page/9/Picture/0 description: The image shows the logo for "QT ultrasound". The letters "QT" are in a light green color, with the "Q" being larger than the "T". The word "ultrasound" is in a light gray color and is placed to the right of the "QT".

10

Image /page/10/Picture/0 description: The image shows the logo for "QT ultrasound". The logo is in a light green color. The letters "QT" are larger than the word "ultrasound".

11

Image /page/11/Picture/0 description: The image contains the text "QT ultrasound". The letters "QT" are larger and in a different color than the word "ultrasound". The text appears to be a logo or branding element.

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Image /page/12/Picture/0 description: The image shows the logo for QT Ultrasound. The logo consists of the letters "QT" in a light green color, with the word "ultrasound" in a light gray color next to it. The logo is simple and modern, and it is likely used to represent a medical imaging company.

8.0 SUMMARY OF CLINICAL TESTING

The modified QT Ultrasound Breast Scanner - 1 is a class II device, and has the same equivalent intended use, operating principles, fundamental scientific technology, technological characteristics, physical and operational specifications as predicate, QT Ultrasound Breast Scanner - 1 (K162372); clinical data is not required for substantial equivalence.

9.0 CONCLUSION

The submission device is a modification to the QT Ultrasound Breast Scanner - 1. The modified QT Ultrasound Breast Scanner - 1 is substantially equivalent to the QT Ultrasound Breast Scanner - 1 as previously cleared in K162372, with respect to intended use, principle of operation, design, performance, method of display and safety features. Both devices are intended as an adjunct to mammography and are not intended for screening purposes. The primary difference between modified device and the OT Ultrasound Breast Scanner - 1 (K162372) is the newer version of the QTviewer software.

QT Ultrasound has demonstrated through verification and validation testing that the modifications made to the QTviewer software as part of the QT Ultrasound Breast Scanner - 1 (K162372) do not raise new or different questions of safety and effectiveness. Therefore, it is the opinion of QT Ultrasound LLC that the modified QT Ultrasound Breast Scanner - 1 is substantially equivalent to the predicate device identified in this submission that is currently cleared for market in the United States.