(139 days)
No
The document describes image processing and segmentation tools, including "semi-automatic tools or fully automatic algorithms," but does not explicitly mention or provide details about the use of AI or ML technologies. The focus is on traditional image processing and 3D modeling techniques.
No.
The device is intended for measuring and treatment planning, and the physical replica can be used for diagnostic purposes. While it aids in treatment planning, it does not directly apply a therapeutic effect to a patient.
No
The device itself, Mimics Medical, is a software interface and image segmentation system used for transfer, measuring, and treatment planning. The intended use clearly states that "The physical replica can be used for diagnostic purposes," not the software itself.
Yes
The device description explicitly states "Mimics Medical is image processing software" and details its functionalities as software-based operations on medical images. While the output can be used for physical fabrication, the device itself is the software.
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 provide information for diagnosis, monitoring, or screening.
- Device Function: The description clearly states that Mimics Medical is image processing software. Its primary function is to process medical imaging data (like DICOM scans) to create 3D models, perform measurements, and aid in treatment planning.
- Output: While the output (physical replicas) can be used for diagnostic purposes, the software itself is not performing a test on a biological sample. It's manipulating and presenting existing imaging data.
- Intended Use: The intended use focuses on image segmentation, measurement, treatment planning, and facilitating the creation of physical replicas from imaging data. It does not mention analyzing biological samples.
Therefore, Mimics Medical falls under the category of medical imaging software and related tools, not in vitro diagnostics.
N/A
Intended Use / Indications for Use
Mimics Medical is intended for use as a software interface and image segmentation system for the transfer of medical imaging information to an output file. Mimics Medical is also intended for measuring and treatment planning. The Mimics Medical output can be used for the fabrication of the output file using traditional or additive manufacturing methods.
The physical replica can be used for diagnostic purposes in the field of orthopaedic, maxillofacial and cardiovascular applications.
Mimics Medical should be used in conjunction with expert clinical judgement.
Product codes
LLZ
Device Description
Mimics Medical is image processing software that allows the user to import, visualize and segment medical images, check and correct the segmentations, and create digital 3D models can be used in Mimics Medical for measuring, treatment planning and producing an output file to be used for additive manufacturing (3D printing). Mimics Medical also has functionality for linking to third party software packages. Mimics Medical is structured as a modular package. This includes the following functionality:
- Importing medical images in DICOM format and other formats (such as BMP, TIFF, JPG and raw images)
- Viewing images and DICOM data
- Selecting a region of interest using generic segmentation tools
- Segmenting specific anatomy using dedicated semi-automatic tools or fully automatic algorithms
- Verifying and editing a region of interest
- . Calculating a digital 3D model and editing the model
- Measuring on images and 3D models
- Exporting images, measurements and 3D models to third-party packages
- Planning treatments (surgical cuts etc.) on the 3D models
- Interfacing with packages for Finite Element Analysis
- Creating Python scripts to automate workflows
Mentions image processing
Yes
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
DICOM format and other formats (such as BMP, TIFF, JPG and raw images)
Anatomical Site
Not Found
Indicated Patient Age Range
Not Found
Intended User / Care Setting
used in conjunction with expert clinical judgement.
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
Software verification and validation were performed and documentation was provided following the "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices". This includes verification against defined requirements, and validation against user needs. Both end-user validation and bench testing were performed.
The geometric accuracy of virtual models created in the subject device Mimics Medical was assessed via bench testing. This was tested for cardiovascular, orthopedic and maxillofacial models. Accuracy of the virtual models was compared for the subject and predicate device. Deviations were within the acceptance criteria. This shows that for creating virtual models, Mimics Medical is substantially equivalent to the predicate device.
Apart from geometric accuracy of virtual models, also geometric accuracy of physical replicas (produced by 3D printing virtual models) was assessed. This was conducted for cardiovascular, orthopedic and maxillofacial models. The physical replicas were compared to the virtual models. Deviations were within the acceptance criteria, showing that virtual models can accurately be printed when using one of the compatible 3D printers.
In conclusion, all performance testing conducted device performance and substantial equivalence to the predicate device.
Key Metrics
Deviations were within the acceptance criteria
Predicate Device(s)
Reference Device(s)
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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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 is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
March 27, 2019
Materialise NV % Mieke Janssen Regulatory Affairs Manager Technologielaan 15 3001 Leuven BELGIUM
Re: K183105
Trade/Device Name: Mimics Medical Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ Dated: March 11, 2019 Received: March 14, 2019
Dear Mieke Janssen:
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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for
1
devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; 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 medical devices and radiation-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,
For
Thalia Mills, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K183105
Device Name Mimics Medical
Indications for Use (Describe)
Mimics Medical is intended for use as a software interface and image segmentation system for the transfer of medical imaging information to an output file. Mimics Medical is also intended for measuring and treatment planning. The Mimics Medical output can be used for the fabrication of the output file using traditional or additive manufacturing methods.
The physical replica can be used for diagnostic purposes in the field of orthopaedic, maxillofacial and cardiovascular applications.
Mimics Medical should be used in conjunction with expert clinical judgement.
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)
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510(k) Summary
K183105
The following section is included as required by the Safe Medical Devices Act (SMDA) of 1990 and 21CFR 807.92
| Company name | Materialise N.V. |
|---|---|
| Establishment registration number | 3003998208 |
| Street Address | Technologielaan 15 |
| City | Leuven |
| Postal code | 3001 |
| Country | Belgium |
| Phone number | +32 16 744 571 |
| Fax number | +32 16 39 66 06 |
| Principal Contact person | Mieke Janssen |
| Contact title | Regulatory Affairs Manager |
| Contact e-mail address | Regulatory. Affairs@materialise.be |
| Additional contact person | Ward Callens |
| Contact title | Director, Quality and Regulatory affairs |
| Contact e-mail address | Regulatory. Affairs@materialise.be |
Submission date
The date of the Traditional 510(k) submission is November 5th, 2018.
Submission information
| Trade Name | Mimics Medical, Materialise Mimics Medical |
|---|---|
| Common Name | Image processing system |
| Classification Name | System, Image processing, Radiological |
| Classification product code | LLZ (892.2050) |
Predicate Devices
The primary predicate device to which substantial equivalence is claimed:
| Trade or proprietary or model name | Mimics |
|---|---|
| 510(k) number | K073468 |
| Decision date | April 2, 2008 |
| Classification product code | LLZ (892.2050) |
| Manufacturer | Materialise N.V. |
The reference device:
| Trade or proprietary or model name | Mimics inPrint |
|---|---|
| 510(k) number | K173619 |
| Decision date | March 21, 2018 |
| Classification product code | LLZ (892.2050) |
| Manufacturer | Materialise N.V. |
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Description and functioning of the device
Mimics Medical is image processing software that allows the user to import, visualize and segment medical images, check and correct the segmentations, and create digital 3D models can be used in Mimics Medical for measuring, treatment planning and producing an output file to be used for additive manufacturing (3D printing). Mimics Medical also has functionality for linking to third party software packages. Mimics Medical is structured as a modular package. This includes the following functionality:
- Importing medical images in DICOM format and other formats (such as BMP, TIFF, JPG and raw images)
- Viewing images and DICOM data
- Selecting a region of interest using generic segmentation tools
- Segmenting specific anatomy using dedicated semi-automatic tools or fully automatic algorithms
- Verifying and editing a region of interest
- . Calculating a digital 3D model and editing the model
- Measuring on images and 3D models
- Exporting images, measurements and 3D models to third-party packages
- Planning treatments (surgical cuts etc.) on the 3D models
- Interfacing with packages for Finite Element Analysis
- Creating Python scripts to automate workflows
Intended Use
Mimics Medical is intended for use as a software interface and image segmentation system for the transfer of medical imaging information to an output file. Mimics Medical is also intended for measuring and treatment planning.
The Mimics Medical output can be used for the fabrication of physical replicas of the output file using traditional or additive manufacturing methods. The physical replica can be used for diagnostic purposes in the field of orthopedic, maxillofacial and cardiovascular applications. Mimics Medical should be used in conjunction with expert clinical judgement.
Comparison of Technological Characteristics with the Predicate Device
The subject device Mimics Medical employs similar fundamental technologies as the predicate device. Technological similarities include:
- . Device functionality:
- O Image segmentation: The subject and predicate device share image segmentation functionalities.
- o Processing to output file: The subject and predicate device both generate an output file.
- O Measuring and planning: The subject and predicate device both have functionalities to perform measurements and pre-surgical planning.
- . Device design: The subject device originated from the same code base as the predicate device.
The following technological differences exist between the subject device and the predicate device:
- Imaging information: Whereas the predicate device is intended to import imaging information from a medical scanner such as CT or MRI scanner, the subject device is intended to import DICOM compliant types
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of imaging information and also supports import of standard imaging formats (such as RAW, TIFF, BMP and ipeg format).
- . Device functionality: The subject device shares the technology and functionality of the predicate device. However, for the subject device, functionality was extended to improve the usability for the user.
Comparison of technological characteristics with the Reference Device (Mimics inPrint, K173619):
The subject device employs similar fundamental technologies as the reference device. Technological similarities include:
- Device functionality:
- Image segmentation: The subject and reference device share image segmentation O functionalities.
- Processing to output file: The subject and reference device both generate an output file. O
- . Device design: The subject device and reference device originate from the same code base (being the code base of the predicate device).
The following technological differences exist between the subject device and the reference device:
- . Imaging information: The reference device is intended to import DICOM imaging information from a medical scanner. The subject device is more generally intended to import imaging information of a medical scanner, allowing both DICOM compatible images and standard imaging formats (such as RAW, TIFF, BMP and jpeg format).
- Device functionality: The subject device shares the technology and functionality of the reference device, but is organized differently (graphical user interface of the software). The functionality of the predicate device is organized in a toolbox fashion, whereas the interface of the reference device specifically guides the user through a few predefined steps for obtaining a 3D printable output file.
Performance Data
Software verification and validation were performed and documentation was provided following the "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices". This includes verification against defined requirements, and validation against user needs. Both end-user validation and bench testing were performed.
The geometric accuracy of virtual models created in the subject device Mimics Medical was assessed via bench testing. This was tested for cardiovascular, orthopedic and maxillofacial models. Accuracy of the virtual models was compared for the subject and predicate device. Deviations were within the acceptance criteria. This shows that for creating virtual models, Mimics Medical is substantially equivalent to the predicate device.
Apart from geometric accuracy of virtual models, also geometric accuracy of physical replicas (produced by 3D printing virtual models) was assessed. This was conducted for cardiovascular, orthopedic and maxillofacial models. The physical replicas were compared to the virtual models. Deviations were within the acceptance criteria, showing that virtual models can accurately be printed when using one of the compatible 3D printers.
In conclusion, all performance testing conducted device performance and substantial equivalence to the predicate device.
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Summary
A comparison of intended use and technological characteristics combined with performance data demonstrates that Mimics Medical is substantially equivalent to the predicate device Mimics (K073468). Minor differences in intended use and technological characteristics exist, but performance data demonstrates that Mimics Medical is as safe and effective, and performs as well as the predicate device.