K Number
K191504
Device Name
PowerDR
Date Cleared
2019-08-16

(71 days)

Product Code
Regulation Number
892.1650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The PowerDR™ Digital X-ray Imaging System is indicated for use as an X-ray imaging modality to acquire, process, display, quality assure and store digital medical X-ray images. The PowerDR™ Digital X-ray Imaging System is indicated for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not indicated for use in mammography.
Device Description
The PowerDR™ Console Application is a digital medical X-ray imaging system consisting of an X-Ray detector, computer hardware and the PowerDR™ software. The User supplies the X-Ray generator. The PowerDR™ Console Application is intended to enable a procedure of medical image acquisition, processing, display, quality assurance, and storage. The software interfaces to an X-Ray detector from variety of vendors to acquire raw pixel data. Its image-processing algorithms transform raw pixel data into diagnostic quality images and image sequences to aid the medical professional in diagnosis. For temporary storage, image data can be stored on the local computer. For long term storage, image data can be stored on a portable media device or a remote PACS (Picture Archive and Communication System) server. The PowerDR™ Digital X-ray Imaging System is intended for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not intended for use in mammography. The system can be sold with or without a computer, and with or without a compatible, previously cleared, digital receptor panel.
More Information

No
The document describes standard digital image processing algorithms and does not mention AI, ML, or related concepts.

No
This device is an X-ray imaging system used for diagnosis, not for therapy or treatment.

Yes
The device processes X-ray images and transforms raw pixel data into "diagnostic quality images and image sequences to aid the medical professional in diagnosis," indicating its role in the diagnostic process.

No

The device description explicitly states that the system consists of an X-Ray detector, computer hardware, and the PowerDR™ software. While the software is a component, it is 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.
  • Device Function: The PowerDR™ Digital X-ray Imaging System is an imaging modality that uses X-rays to create images of the inside of the body. It acquires, processes, displays, and stores these images.
  • No Sample Analysis: The description does not mention the analysis of any biological samples taken from the patient. The system works directly with the patient's body using X-rays.

Therefore, the PowerDR™ Digital X-ray Imaging System falls under the category of medical imaging devices, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The PowerDR™ Digital X-ray Imaging System is indicated for use as an X-ray imaging modality to acquire, process, display, quality assure and store digital medical X-ray images. The PowerDR™ Digital X-ray Imaging System is indicated for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not indicated for use in mammography. (Rx Only)

Product codes (comma separated list FDA assigned to the subject device)

JAA, MQB

Device Description

The PowerDR™ Console Application is a digital medical X-ray imaging system consisting of an X-Ray detector, computer hardware and the PowerDR™ software. The User supplies the X-Ray generator. The PowerDR™ Console Application is intended to enable a procedure of medical image acquisition, processing, display, quality assurance, and storage. The software interfaces to an X-Ray detector from variety of vendors to acquire raw pixel data. Its image-processing algorithms transform raw pixel data into diagnostic quality images and image sequences to aid the medical professional in diagnosis. For temporary storage, image data can be stored on the local computer. For long term storage, image data can be stored on a portable media device or a remote PACS (Picture Archive and Communication System) server. The PowerDR™ Digital X-ray Imaging System is intended for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not intended for use in mammography. The system can be sold with or without a computer, and with or without a compatible, previously cleared, digital receptor panel. The computer requirements are: Intel Core i5-8500, 6 Core, 9MB Cache, 3.0GHz, 4.1Ghz Turbo w/ HD Graphics 630, Win 10 Pro 64, 8x DVD+/-RW 9.5mm Optical Disk Drive, (2) 3.5 inch 1TB 7200rpm SATA Hard Disk Drives RAID 1, 8GB RAM, Intel Integrated Graphics, 22" display monitor 1920x1080 at 60 Hz. If the customer buys only the software, they are required to install and keep up to date one of the anti-virus programs cited in our User Manual. In addition the device conforms to the applicable provisions EPRC regulations, 21 CFR 1020.30, 1020.31, and 21 CFR 1020.32.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

Any anatomy

Indicated Patient Age Range

Adult, pediatric, and neonatal patients

Intended User / Care Setting

Radiology department and medical imaging center

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)

Bench testing including risk analysis and software validation was conducted. All proposed panels have previously received FDA 510(k) clearances. Performance was tested to ensure the device is as safe and effective as the predicate devices. Clinical testing was not deemed necessary.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K130318

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K133139, K133139, K150306, K141440, K141440, K163019, K163019, K153058, K153058, K150929, K162178, K153492, K172581, K161966, K161942

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the agency's name on the right. The symbol on the left is a stylized depiction of a human figure, while the text on the right reads "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue letters. The words "FOOD & DRUG" are larger than the other words.

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

August 16, 2019

Re: K191504

Trade/Device Name: PowerDR™ Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: Class II Product Code: JAA, MQB Dated: June 3, 2019 Received: June 6, 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

1

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) K191504

Device Name PowerDR™

Indications for Use (Describe)

The PowerDR Digital X-ray Imaging System is indicated for use as an X-ray imaging modality to acquire, process, display, quality assure and store digital medical X-ray images.

The PowerDR Digital X-ray Imaging System is indicated for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not indicated for use in mammography.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary 510(k) Number K191504

Image /page/3/Picture/1 description: The image shows the logo for RADinfo SYSTEMS. The logo consists of the text "RADinfo SYSTEMS" in bold black letters, with the word "RADinfo" being larger than the word "SYSTEMS". Below the text is the tagline "Delivering Solutions that Meet Your Vision" in a smaller, lighter font. To the right of the text is a blue circular graphic with a stylized letter "R" inside.

Radiology Information Systems, Inc. 43676 Trade Center Place, Ste 100 Dulles, VA 20166 Ph: 703-713-3313 Fx: 703-713-3343 www.radinfosystems.com Contact/Prepared by: Chen-Tai Ma Ph.D. Contact Title CEO and President Date Prepared: August 9, 2019

    1. Identification of the Device: Trade/Device Name: PowerDR™ Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: JAA, MQB
    1. Equivalent legally marketed device: K130318, Varian Medical Systems, X-Ray Products-InfiMed Trade/Device Name: Nexus DRF Digital X-ray Imaging System Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: JAA, MQB
    1. Indications for Use (intended use) The PowerDR™ Digital X-ray Imaging System is indicated for use as an Xray imaging modality to acquire, process, display, quality assure and store digital medical X-ray images. The PowerDR™ Digital X-ray Imaging System is indicated for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not indicated for use in mammography. (Rx Only)
    1. Description of the Device: The PowerDR™ Console Application is a digital medical X-ray imaging system consisting of an X-Ray detector, computer hardware and the PowerDR™ software. The User supplies the X-Ray generator. The PowerDR™ Console Application is intended to enable a procedure of medical image acquisition, processing, display, quality assurance, and storage. The software interfaces to an X-Ray detector from variety of vendors to acquire raw pixel data. Its image-processing algorithms transform raw pixel data into diagnostic quality images and image sequences to aid the medical professional in diagnosis. For temporary storage, image data can be stored on the local computer. For long term storage, image data can be stored on a portable media device or a remote PACS (Picture Archive and Communication System) server. The PowerDR™ Digital X-ray Imaging System is intended for use in general radiographic and fluoroscopic examinations of any anatomy for adult, pediatric, and neonatal patients. It is not intended for use in mammography. The system can be sold with or without a computer, and with or without a compatible, previously cleared, digital receptor panel. The computer requirements are: Intel Core i5-8500, 6 Core, 9MB Cache, 3.0GHz, 4.1Ghz Turbo w/ HD Graphics 630, Win 10 Pro 64, 8x DVD+/-RW 9.5mm Optical Disk Drive, (2) 3.5 inch 1TB 7200rpm SATA Hard Disk Drives RAID 1, 8GB RAM, Intel Integrated Graphics, 22" display monitor 1920x1080 at 60 Hz. If the customer buys only the software, they are required to install and keep up to date one of the anti-virus programs cited in our User Manual. In addition the device conforms to the applicable provisions EPRC regulations, 21 CFR 1020.30, 1020.31, and 21 CFR 1020.32.

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    1. Safety and Effectiveness, comparison to predicate device. The results of image inspection, bench, and test laboratory results indicates that the new device is as safe and effective as the predicate devices. All of the proposed panels have previously received FDA 510(k) clearances.

5. Substantial Equivalence Chart

CharacteristicPredicate DeviceProposed Device
IdentificationK130318, Varian Medical Systems, X- Ray
Products-InfiMed , Trade/Device Name:
Nexus DRF Digital X-ray Imaging SystemRADinfo SYSTEMS, Digital X-ray Imaging
Products, Trade/Device Name:
PowerDR™ Console Application
Intended Use:The InfiMed i5 Digital X-ray Imaging
System is a high resolution digital imaging
system intended to replace conventional
film techniques, or existing digital systems,
in multipurpose or dedicated applications
specified below. The i5 Digital X-ray
Imaging System enables an operator to
acquire, display, process, export images to
portable media, send images over a
network for long term storage and
distribute hardcopy images with a laser
printer.The PowerDR™ Digital X-ray Imaging
System is indicated for use to acquire,
process, display, quality assure and store
digital medical X-ray images. The
PowerDR™ Digital X-ray Imaging System is
indicated for use in general radiographic
and fluoroscopic examinations of any
anatomy for adult, pediatric, and neonatal
patients. It is not indicated for use in
mammography.
(similar)
DescriptionDigital image software applicationSame
Where usedRadiology department and medical
imaging center use in general
radiographic examinations and
applications. For the RF/DSA application,
the InfiMed i5 Digital X-ray Imaging
System is intended for use where general
fluoroscopy, interventional fluoroscopy or
angiography imaging procedures are
performed.Radiology department and medical imaging
center use in general radiographic
examinations and applications. For the
RF/DSA application, the PowerDR™ Digital
X-ray Imaging System is intended for use
where general fluoroscopy, interventional
fluoroscopy or angiography imaging
procedures are performed. SAME
image
processingImage processing algorithms enable the
operator to bring out diagnostic details
difficult to see using conventional imaging
techniques.The image processing software, used
with a cleared DR device, provides
diagnostic quality images to aid
physicians with diagnosis.
image StorageImages can be stored locally for temporary
storage.Same
Image data
sourceA variety of image receptors from
commercially available flat panel
detectors.Same
ConfigurationDigital Panel, a connected personal
computer, and installed application
software.Same
Primary Digital
PanelVarex/PaxScan 4343CB flat panel
detectorMultiple panels supported: Pixium;
Careray; Varex/XRPad2. Only FDA cleared
panels are supported. See detailed list
below.
CharacteristicPredicate DeviceProposed Device
System
SoftwareInstalled on a Microsoft Windows PC
(Windows 10 64 bit)Same
Image
data
formatThe input and output image pixel data is
the raster data. The photometric
representation of the image pixel data is
provided.Same
Image
presentationEnhanced Visualization Processing
(EVP)Same
Application
softwareEnhanced GUI for easy navigationSame
Tracking
Xray doseDose recording from generatorSame
Fluoro
image
processingAdvanced contrast and edge
enhancementSame
MutiRad imageSupport last image hold and review
previous framesSame
Dose and
processing
Auto optimizedBased on selected Fluoro frames rate
and magnificationSame
Quality
AssuranceSupport various quality assurance
toolsSame
DICOM 3.0
ConformanceYesYes
IHE
Integration
profileYesYes
Power source
(for required
computer)120 VACSame
Computer
PlatformWindows 10® 64 bit operating
systemSame, see computer requirements in
description above.
ManufacturerModel NumberStatic/Dynamic
Note: All Dynamic
panels can take Static
Images.510(k) Number
Thales PixiumRAD 4343StaticK133139
Thales PixiumRAD 4143StaticK133139
Thales PixiumRF 4343DynamicK150306
Thales Pixium3543 EZStaticK141440
Thales Pixium2430 EZStaticK141440
CarerayCareView 750CStaticK163019
CarerayCareView 750CwStaticK163019
CarerayCareView 1500 LStaticK153058
CarerayCareView 1500CStaticK153058
CarerayCareView 1500CwStaticK150929
CarerayCareView 1500PStaticK162178
CarerayCareView 1800LStaticK153492
CarerayCareView 1800CwStaticK172581
VarexXRpad2 4336DynamicK161966
VarexXRpad2 3025DynamicK161942

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    1. Summary of Bench Testing Conducted: This is a software product installed on a PC using Windows 10® 64 bit operating system which interfaces with FDA cleared digital x-ray receptor panels. All compatible digital panels have already received FDA clearances. See list below Risk Analysis and software validation was conducted in accordance with FDA guidance documents. All panels had been tested in accordance with the FDA guidance on Solid State Imaging Devices via their previous clearances. We employed these FDA guidance documents in the development of this software product: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Guidance for Industry and FDA Staff MAY 2005; AND Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff OCTOBER 2014. We also employed FDA recommendations in our labeling regarding imaging the pediatric population: Pediatric Information for X-ray Imaging Device Premarket Notifications Guidance for Industry and Food and Druq Administration Staff, November 2017. The user manual states: "Use special care when imaging patients outside the typical adult size range. Children are more radiosensitive than adults."

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Each available digital receptor panel has undergone a rigorous verification and validation procedure prior to addition to our line-up.

List of Tested Panels

    1. Summary of Clinical Testing: Clinical testing was not necessary to establish substantial equivalence. All digital panels employed have received previous FDA clearance.
    1. Conclusion: After analyzing bench testing and risk analysis and compliance to the DICOM standard, it is the conclusion of Radiology Information Systems, Inc. that the PowerDR™ Digital X-ray Imaging System is 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.