Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography.

Device Description

This represents the straightforward combination of three devices: One of three cleared MinXray Portable HF X-ray generators: a) HF120/60H PowerPlus cleared in K040046, (and in K141885) OR b) HF100H+ cleared in K052721 OR c) HF1202 PowerPlus cleared in K153059. Plus: A 510(k) cleared (K150929) Digital X-Ray Receptor Panel CareView 1500Cw X-ray Flat Panel Detector. d) e) PLUS: the dicomPACS® software package (Same as our predicate). The x-ray generators are portable units which operate from 120/240V 50-60° AC. The generator unit utilizes a high frequency inverter and can be mounted to a tripod or support arm. The usual safety precautions regarding the use of x-rays must be observed by the operator. The digital panel features the Careray flat panel technology in a sleek and compact unit. The portable panel provides digital X-ray image capture for a wide range of applications. The lightweight design, generous imaging area, and fast processing times of the detector make it easy to capture high quality diagnostic images for routine diagnosis, as well as challenging trauma and bedside exams. It's a portable solution for a faster, more streamlined approach to digital radiography. The only difference between this modified device and our predicate devices is the supplier of the digital x-ray receptor panel.

AI/ML Overview

The provided text describes a 510(k) premarket notification for the MinXray CMDR 2CW (Multiple Models) mobile x-ray system. The submission aims to demonstrate substantial equivalence to a predicate device, the CMDR 2ST/CMDR 2SPE (Multiple Models).

Here's an analysis of the acceptance criteria and study information:

Acceptance Criteria and Reported Device Performance

The core of the acceptance criteria revolves around demonstrating substantial equivalence to the predicate device. This is primarily assessed by comparing the technological characteristics and showing that the new device is as safe and effective as the predicate, with the same indications for use.

The device performance is demonstrated through non-clinical testing, specifically focused on confirming proper system operation and diagnostic image quality.

Acceptance Criteria	Reported Device Performance
Intended Use	The new device, CMDR 2CW, has the SAME intended use: "Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography." This matches the predicate device.
Configuration	The new device has the SAME configuration: "Mobile System with digital x-ray panel and image acquisition computer."
X-ray Generators and Characteristics	The new device uses the SAME X-ray generators (HF120/60H PowerPlus, HF100H+, HF1202H PowerPlus) and basic generator characteristics (e.g., 120 VAC line operated, kVp, and kW peak values) as the predicate.
Collimator	The new device uses the SAME Collimare LED Collimator as the predicate.
PACS Software	The new device uses the SAME dicomPACS® software package as the predicate.
Power Source (System)	The new device uses the SAME 120 V 50/60 Hz AC 20 amp power source as the predicate.
Digital Panel Power Source	The new device uses the SAME DC Adapter or Lithium Ion rechargeable battery for the digital panel as the predicate.
Compliance with US Performance Standards	Both the predicate and the new device Meet US Performance Standard.
Diagnostic Image Quality	Bench testing using the i.b.a. Test Device DIGI-13 demonstrated that the new system produced diagnostic quality images "as good as our predicate generator/panel combination" and that "The images were evaluated and found to be of diagnostic quality."
Safety and Effectiveness (Overall)	"The results of bench testing indicate that the new devices are as safe and effective as the predicate devices." Risks and hazardous impacts were analyzed with FMEA methodology, and “all identified risks and hazardous conditions were successfully mitigated and accepted.”
Hardware/Software Modifications	"NO HARDWARE OR SOFTWARE MODIFICATIONS TO ALREADY CLEARED DEVICES WERE REQUIRED TO CREATE THESE NEW MODELS." The only difference is the digital x-ray receptor panel supplier.
Compliance with Electrical Safety Standards	The device was tested for compliance with UL 60601-1 (2005) (Electrical medical device safety) and IEC 60601-1-2 (2007) (Electromagnetic Compatibility). The HF1202H PowerPlus generator meets IEC 60601-2-54.
Cybersecurity	Cybersecurity precautions were added to labeling, and information was obtained from the DICOM software supplier.

The primary difference and therefore the key point of evaluation for substantial equivalence was the Digital X-ray Panel.

Acceptance Criteria	Reported Device Performance
Digital X-ray Panel	The new device uses the K150929 CareView 1500Cw X-ray Flat Panel Detector manufactured by CareRay, which replaces the Toshiba FDX3543RPW or PerkinElmer XRpad 4336 panels used in the predicate.
Panel Performance (Pixel Pitch, Matrix, Size)	CMDR 2CW Panel Performance: Pixel Pitch 154 μm, 2304 × 2816 pixels, Size 14" x 17". Predicate Panel Performance: Pixel Pitch 140 μm, 2466 (H) x 3040 (V) (Toshiba) OR Pixel Pitch 100 x 100μm, Matrix size 3556 × 4320 (PerkinElmer).

Study Information

Sample size used for the test set and the data provenance:
- The test set consisted of "several test exposures" using a radiographic phantom.
- The data provenance is not explicitly stated in terms of country of origin, but it was generated during non-clinical bench testing by MinXray, Inc. This was a prospective test conducted for the purpose of this submission.
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The text does not specify the number or qualifications of experts who evaluated the images during the bench testing. It only states that "The images were evaluated and found to be of diagnostic quality."
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- An adjudication method is not described. The evaluation was likely performed internally as part of the bench testing.
If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No MRMC or AI-assisted study was performed. The device is a mobile x-ray system, not an AI diagnostic tool.
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable, as this is an x-ray imaging system, not a diagnostic algorithm.
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The ground truth for the non-clinical testing was based on the expected diagnostic quality of images produced from a radiographic phantom, as assessed by comparison to images from the predicate device and general standards of diagnostic quality for x-ray imaging.
The sample size for the training set:
- Not applicable, as this is not a machine learning device. The "training" here refers to the development and testing of the x-ray system components and their integration.
How the ground truth for the training set was established:
- Not applicable in the context of a machine learning training set. For the development and verification of the x-ray system, the "ground truth" was established through engineering specifications, regulatory standards (e.g., UL, IEC, DHHS radiation safety), and the performance characteristics of previously cleared predicate/reference devices (generators, panels, software).

Summary

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Image /page/0/Picture/0 description: The image shows 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, with the letters "FDA" in a blue square. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

July 3, 2019

MinXray, Inc. % Daniel Kamm, P.E. Principal Engineer Kamm & Associates 8870 Ravello Ct NAPLES FL 34114

Re: K191451

Trade/Device Name: CMDR 2CW (Multiple Models) Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: Class II Product Code: IZL, MQB, LLZ Dated: May 28, 2019 Received: May 31, 2019

Dear Mr. Kamm:

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

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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 T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K191451

Device Name CMDR 2CW (Multiple Models)

Indications for Use (Describe)

Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography.

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: 510(k) Number K191451 MinXray, Inc. 3611 Commercial Avenue Northbrook. Illinois 60062. USA Toll Free 1-800-221-2245 (USA & Canada) Date Prepared: June 17, 2019 Contact: Keith Kretchmer, President

Identification of the Device: 1) Trade/Device Name: CMDR 2CW (Multiple Models) Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Codes: IZL, MQB, and LLZ. Common/Usual Name: Digital Mobile Diagnostic X-Ray System
1. Equivalent legally marketed device: K171353 Trade/Device Name: CMDR 2ST (Multiple Models), CMDR 2SPE (Multiple Models), Integris Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Codes: IZL, MQB, and LLZ. Common/Usual Name: Digital Mobile Diagnostic X-Ray System
1. Reference device (We employ these cleared devices without modification): Trade/Device Name: K150929 CareView 1500Cw X-ray Flat Panel Detector made by CareRay. Regulation Number: 21 CFR 892. 1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: MQB
Indications for Use (intended use): These digital radiographic systems are intended for use by a qualified/trained 4) physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammographic use.
1. Description of the Device: This represents the straightforward combination of three devices: One of three cleared MinXray Portable HF X-ray generators:
- a) HF120/60H PowerPlus cleared in K040046, (and in K141885) OR
- b) HF100H+ cleared in K052721 OR
- c) HF1202 PowerPlus cleared in K153059.
- Plus: A 510(k) cleared (K150929) Digital X-Ray Receptor Panel CareView 1500Cw X-ray Flat Panel Detector. d)
- e) PLUS: the dicomPACS® software package (Same as our predicate).

The x-ray generators are portable units which operate from 120/240V 50-60° AC. The generator unit utilizes a high frequency inverter and can be mounted to a tripod or support arm. The usual safety precautions regarding the use of x-rays must be observed by the operator. The digital panel features the Careray flat panel technology in a sleek and compact unit. The portable panel provides digital X-ray image capture for a wide range of applications. The lightweight design, generous imaging area, and fast processing times of the detector make it easy to capture high quality diagnostic images for routine diagnosis, as well as challenging trauma and bedside exams. It's a portable solution for a faster, more streamlined approach to digital radiography. The only difference between this modified device and our predicate devices is the supplier of the digital x-ray receptor panel.

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6) Substantial Equivalence Chart

Characteristic	Predicate: K171353 CMDR 2ST (MultipleModels) CMDR 2SPE (Multiple Models)	CMDR 2CW (Multiple Models)
Intended Use:	Intended for use by a qualified/trainedphysician or technician on both adult andpediatric subjects for taking diagnostic x-rays.Not for mammography	SAME
Configuration	Mobile System with digital x-ray panel andimage acquisition computer	SAME
Computer	Dell Precision M3510 or Dell Latitude 14	Dell Precision M3530 or Dell Latitude 7424(ruggedized)
X-rayGenerator(s)(All made byMikasa X-Ray)	HF120/60H PowerPlus (K040046) orHF100H+ (K052721) orHF1202H PowerPlus (K153059)	SAME
BasicGeneratorCharacteristics	120 VAC Line operated:HF120/60H PowerPlus™ produces up to 120kVP and 2.4 kW peakHF100H+: up to 100 kVp and 2 kW peakHF1202H PowerPlus: up to 120 kVp up to 3.0kW peak	SAME
Collimator	Collimare LED Collimator	Collimare LED Collimator
GeneratorPhoto(s)The samegenerators willbe used for themodified device	Image: HF120/60HPPWV	HF100H+HF1202 H
Digital X-rayPanelSupplied	Toshiba FDX3543RPW. Note: this panel wascleared in K143257 OR PerkinElmer XRpad4336 (Cleared in K140551)	K150929 CareView 1500Cw X-ray Flat PanelDetector manufactured by CareRay
PanelPerformance	Pixel Pitch 140 μmPixel Matrix 2466 (H) x 3040 (V)Size 14" x 17" ORPixel Pitch 100 x 100μmMatrix size 3556 × 4320Size 14" x 17" (Cleared in K140551)	Pixel Pitch 154 μm2304 × 2816 pixelsSize 14" x 17"(Cleared in K150929)
Panel PowerSource	DC Adapter or Lithium Ion rechargeablebattery	DC Adapter or Lithium Ion rechargeablebattery
Characteristic	Predicate: K171353 CMDR 2ST (MultipleModels) CMDR 2SPE (Multiple Models)	CMDR 2CW (Multiple Models)
Meets USPerformanceStandard	YES	YES
PACS software	dicomPACS® (Cleared with the Toshiba panelsin K141440)	SAME
Power Source	120 V 50/60 Hz AC 20 amp	SAME
Digital PanelPower Source	120 V 50/60 Hz AC or Lithium Ion RechargeableBattery.	SAME
Digital Panel	Image: Digital Panel	Image: Digital Panel
Model Details	(All models use O&R Imaging Software, andeither a wired or wireless Toshiba panel) (FiveModels)	(All models use O&R Imaging Software with theCareray Digital Panel and a Dell Laptop) (FiveModels) Model Details:
	HF120/60HPPWV Generator with ToshibaFDX3543RPCMDR 2ST 100+/ DP for Dell Precision or a /DL forDell Latitude Computer: Uses HF100H+ Generatorwith Toshiba FDX3543RPCMDR 2STW 100H+/DP for Dell Precision or a /DLfor Dell Latitude Computer: Uses HF100H+Generator with Toshiba FDX3543RPWCMDR 2STW 1202/DP for Dell Precision or a /DL forDell Latitude Computer: Uses HF1202 Generatorwith Toshiba FDX3543RPWCMDR 2STW-MIL (Uses Dell Latitude 14 with theHF120/60HPPWV Generator with ToshibaFDX3543RPW	CMDR.CW.120.60.S for Dell Precision orCMDR.CW.120.60.R for Dell Latitude Laptop orequivalent Uses HF120/60HPPWV Generator withCareView 1500Cw and O&R Imaging SoftwareCMDR.CW.100.S for Dell Precision orCMDR.CW.100.Rfor Dell Latitude Laptop orequivalent Uses HF100H+ Generator with CareView1500Cw and O&R Imaging Software.CMDR.CW.1202.S for Dell Precision Laptop orequivalent orCMDR.CW.1202.R for Dell Latitude Laptop orequivalent Uses HF1202 Generator with CareView1500Cw and O&R Imaging SoftwareCMDR 2CW-MIL (Uses Dell Latitude 7424 orequivalent with the HF120/60HPPWV Generator

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1. The technological characteristics, including design, materials, composition, and energy source, are substantially the same, so there are no issues impacting safety and effectiveness. Safety and Effectiveness, comparison to predicate device. The results of bench testing indicate that the new devices are as safe and effective as the predicate devices. Proper system operation is fully verified upon installation. We verified that the modified combination of components worked properly and produced diagnostic quality images as good as our predicate generator/panel combination. NO HARDWARE OR SOFTWARE MODIFICATIONS TO ALREADY CLEARED DEVICES WERE REQUIRED TO CREATE THESE NEW MODELS. The main difference from the predicate device is the addition of the CareView 1500 CW flat-panel detector, that replaces the Toshiba and Perkin-Elmer digital imagers used with the predicate system.
1. Summary of non-clinical testing: Prototype systems covering all generator/panel combinations were assembled and tested. First the dicomPACS® software was installed on the Dell Inspiron laptop computer. The proper installation was verified by running the software. A Wi-Fi connection was confirmed between the PerkinElmer panel and the Dell laptop. The panel was confirmed to be charged and turned on. Then the MinXray HF portable generator was turned on. The MinXray portable X-ray generator was set to generate an exposure. The generator was aimed at the PerkinElmer panel, and a radiographic phantom was placed on the panel. Several test exposures showed that the system was operating properly. No modifications were necessary to any of the hardware or software other than changing the digital panel. The comples with DHHS radiation safety standards currently in effect, and has undergone testing for compliance with UL 60601-1 (2005) [Electrical medical device safety), IEC 60601-1-2 (2007) (Electromagnetic Compatibility). Additionally, the HF1202H PowerPlus generator meets IEC 60601-2-54: Medical electrical equipment - Part 2-54: Particular requirements for the basic safety and essential performance of X-ray equipment for radiography and radioscopy. The other generators were designed and cleared prior to the issuance of this standard. We verified software compatibility with the new CareView Cw digital panel. The risks and hazardous impacts of the device modification were analyzed by FMEA methodology. The specific risk control and protective measures to mitigate the risks from the modification were reviewed and implemented as part of product design. The overall assessment concluded that all identified risks and hazardous conditions were successfully mitigated and accepted.

We employed the i.b.a. Test Device DIGI-13, a device for quality tests at CR and DR systems (e.g. for acceptance tests according to DIN V 6868-58 and constancy tests according to DIN 6868-13) to obtain images from both the predicate and the new digital panel. All panel/generator combinations were tested. The images were evaluated and found to be of diagnostic quality.

In recognition of the FDA Guidance on Cybersecurity, we added Cybersecurity precautions to our labeling and obtained Cybersecurity information from our DICOM software supplier Oehm Und Rehbein.

1. Summary of clinical testing: Clinical testing was not required to establish substantial equivalence.
1. Conclusion: After analyzing bench and clinical tests, it is the conclusion of MinXray Inc. that the modified Digital Diagnostic X-Ray Systems are as safe and effective as the predicate device, have few technological differences, and has the same indications for use, thus rendering it substantially equivalent to the predicate device.

Regulation Number and Section

§ 892.1720 Mobile x-ray system.

(a)
Identification. A mobile x-ray system is a transportable device system intended to be used to generate and control x-ray for diagnostic procedures. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.