(58 days)
No
The summary describes a mobile digital X-ray system with various hardware configurations and software for image acquisition and processing. There is no mention of AI, ML, or related terms, nor any description of training or test data sets typically associated with AI/ML development. The focus is on the mechanical, electrical, and basic software control aspects of the device.
No.
The device is described as taking "diagnostic radiographic exposures," which indicates it is used for diagnosis, not therapy.
Yes
Explanation: The "Intended Use / Indications for Use" section explicitly states that the device is "for taking diagnostic radiographic exposures."
No
The device is a mobile digital diagnostic xray system that includes significant hardware components such as an X-ray generator, X-ray tube, motorized movements, battery packs, and digital X-ray panels, in addition to software.
Based on the provided text, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening.
- Device Function: The description clearly states that this device is a "mobile digital diagnostic xray system" used for "taking diagnostic radiographic exposures of the skull, spinal column, extremities, and other body parts." This involves generating X-rays and capturing images of the inside of the body, not analyzing samples taken from the body.
- Intended Use: The intended use describes imaging procedures performed directly on the patient ("with the patient sitting, standing, or lying").
- No Mention of Specimen Analysis: The entire description focuses on the X-ray generation, image acquisition, and image processing of radiographic images, with no mention of analyzing biological specimens.
Therefore, this device falls under the category of medical imaging devices, not In Vitro Diagnostic devices.
N/A
Intended Use / Indications for Use
Intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography.
Product codes (comma separated list FDA assigned to the subject device)
IZL, MOB, MQB
Device Description
These are redesigned versions of our predicate mobile digital diagnostic xray systems. They feature motorized movement and full battery operation. Various Canon digital Xray panels are supplied with the system. The Mobile X-Ray Unit PhoeniX has a Basic configuration or Advanced configuration. Advanced configurations include: Second screen on head assembly, Smooth movements of head assembly, Telescopic arm in four steps instead three steps for basic configuration.
The Mobile X-Ray unit is provided with touch screen to operate as a control console. The Digital Imaging System is composed by image receptors and application for image acquisition (control console & image processing controller). The Image acquisition software "CANON CXDI Control Software NE" runs on Mobile X-ray unit and it is displayed on touch screen. It is the user interface and compatible digital detectors are listed above. All have FDA Clearance. The Advanced configuration has a second Touch Screen Monitor located on head-assembly.
The PhoeniX Mobile X-Ray Unit is provided with separate battery packs for X-Ray generation and motorized movements of the unit can operate connected to mains or in stand-alone mode, that is, operating without mains being present or unplugged from mains. The unit is connected to mains to charge the batteries; New rating: the input voltage range goes from 100 V~ to 240 V~, 1 phase, 1.1 kVA. New X-ray generator (model SHFM) is mounted on Battery Mobile X-Ray unit PhoeniX. This new X-Ray generator for PhoeniX Mobile X-Ray Unit has a radiogenic unit mounted on headassembly and comprising an X-ray tube with rotating anode and its circuit for high voltage. The electronic and associated software to control the X-ray generation are placed on mobile cart. The Battery Mobile X-Ray Unit PhoeniX is provided with different output powers: 20 kW, 32 kW, 40 kW and 50 kW. There are available two X-ray tube inserts with rotating anode manufactured by CANON ELECTRON TUBES & DEVICES: XRR-3331 insert, E7886 insert. New: Manual Beam Limiting Device from Ralco, model: R108 F. External interface (controls) and covers are provided by Sedecal. There are two versions of collimator assembly, Basic and Advanced.
The Battery Mobile X-Ray Unit Phoenix is driven by holding the handlebar with the hands. It is provided to internal sensor (gauges) that control the direction and speed of each wheel depending the force applied by the operator. New: the handlebar is capacitive handlebar and when operator put his hands-on handlebar the movements are enabled. The height of handlebar is adaptable to improve the user commodity. Four buttons are provided on the hand grips placed on Head-Assembly. They control the motion of each driving wheel and allow fine positioning adjustment of the patient (movements with low speed because this control is not intended for long displacement).
The Battery Mobile X-Ray unit supports:
- Ethernet communication (with hospital and backup cable for digital detectors)
- Wireless Wi-Fi communications (with digital detectors and remote hand switch). The wireless communication is supported by Access Point and one single internal antenna.
New: the front panel of Phoenix has a VGA port to display control console on external monitor. New: USB ports. Infrared data communication for register the Wireless Detector to the Mobile unit by infrared communication. (This operation is done during installation process by service personnel.)
Options: Barcode scanner for register patient information. Dosimetry for Dose Area Product (DAP).
Tube Arm specifications:
- Counterbalanced tube arm.
- Tube arm reach 1220 mm horizontally for both configurations (Advanced option with 4 steps and Basic option with 3 steps).
- Column rotation: ± 317 °.
- Maximum SID to floor is 2020 mm for both configurations.
- Minimum SID to floor is 530 mm for both configurations.
Mobile Unit:
- Weight: the worst configuration 520 kg.
- Size (L x W x H): Mobile on parking position: 1220 x 540 x 1290 mm. Mobile fully extended (Telescopic column & Telescopic arm): 2290 x 1790 x 2230 mm.
- Frontal anti-collision system.
- Motorized unit up to 5,5 km/h.
- Motor drive with two independent drive motors, one for each wheel (forward and reverse).
Touch screen console:
- Main control console: 19 inch.
- Additionally, second touch screen of 8.4 inch for Advanced configuration.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
X-ray
Anatomical Site
skull, spinal column, chest, abdomen, extremities, and other body parts
Indicated Patient Age Range
adult and pediatric subjects
Intended User / Care Setting
qualified/trained doctor or technician
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)
Summary of non-clinical testing: Systems covering all generator/panel combinations were assembled and tested and found to be operating properly. Firmware was validated according to the FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005. Because the system uses Wi-Fi and Ethernet, we observed the recommendations contained in the FDA Guidance Document: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014. The digital panel software employed was already reviewed by FDA in K190368. The PhoeniX Battery Mobile X-Ray Units have been tested to be in compliance with the following International Standards: IEC 60601-1:2005+A1:2012 (Edition 3.1), IEC 60601-1-2:2014 (Edition 4.0), IEC 60601-1-3:2008+A1:2013 (Edition 2.1), IEC 60601-2-54:2009+A1:2015 (Edition 1.1), IEC 60601-2-28:2010 (Edition 2.0), IEC 60601-1-6:2010 + A1:2013 (Edition 3.1), IEC 62304:2006 + A1:2016 (Edition 1.1).
Summary of clinical testing: Clinical testing was not required to establish substantial equivalence because all digital x-ray receptor panels have had previous FDA clearance.
Key results: After analyzing bench and clinical tests, it is the conclusion of Sedecal SA. that the new PhoeniX Digital Diagnostic Mobile 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.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
K131106, K133693, K170332, K171270, K190368
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 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.
0
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, 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.
SEDECAL, SA. % Mr. Daniel Kamm Principal Engineer Kamm & Associates 8870 Ravello Ct NAPLES, FL 34114
Re: K192011
Trade/Device Name: PhoeniX Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: Class II Product Code: IZL, MOB Dated: July 26, 2019 Received: July 29, 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
September 25, 2019
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
2
Indications for Use
510(k) Number (if known) K192011
Device Name PhoeniX
Indications for Use (Describe)
Intended for use by a qualified/trained doctor or technician on both adult and pediatic subjects for taking diagnostic radiographic exposures of the skull, spinal column, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for 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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3
510(k) Summary: 510(k) Number K192011
Image /page/3/Picture/1 description: The image is a logo for SEDECAL. The logo is a teal rounded rectangle with a white border. Inside the rectangle, there is a white icon of a person sitting at a desk on the left and the word "SEDECAL" in white on the right.
SEDECAL SA C/ Pelaya, 9 - 13, Pol. Ind. Río de Janeiro 28110 Algete, Madrid España (Spain) Tel .- +34 91 6280544 Fax.- +34 91 6280574 Date Prepared: July 10, 2019 Contact: Mª Luisa Gómez de Agüero, Quality and Regulatory Manager
-
- Identification of the Device: Trade/Device Name: PhoeniX Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Codes: IZL, MQB. Common/Usual Name: Digital Mobile Diagnostic X-Ray System
-
- Equivalent legally marketed device: K161345 Trade/Device Name: RadPRO® Mobile 40kW; RadPRO® Mobile 40kW FLEXPLUS, Model SM-40HF-B-D-VIR Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Codes: IZL, MQB. Common/Usual Name: Digital Mobile Diagnostic X-Ray System
-
- Reference devices: We employ these cleared devices (K131106, K133693, K170332 and K171270 with software update cleared in K190368) without modification: Trade/Device Name: Canon Digital X-ray Panels CANON CXDI-401C Wireless CANON CXDI-701C Wireless CANON CXDI-801C Wireless CANON CXDI-710C Wireless CANON CXDI-810C Wireless CANON CXDI-410C Wireless Regulation Number: 21 CFR 892. 1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: MQB
-
- Indications for Use: Intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting,
4
standing, or lying in the prone or supine position. Not for mammography.
-
- Description of the Device: These are redesigned versions of our predicate mobile digital diagnostic xray systems. They feature motorized movement and full battery operation. Various Canon digital Xray panels are supplied with the system. (See list above.) The Mobile X-Ray Unit PhoeniX has a Basic configuration or Advanced configuration. Advanced configurations include:
- Second screen on head assembly.
- Smooth movements of head assembly.
- Telescopic arm in four steps instead three steps for basic configuration.
The Mobile X-Ray unit is provided with touch screen to operate as a control console. The Digital Imaging System is composed by image receptors and application for image acquisition (control console & image processing controller). The Image acquisition software "CANON CXDI Control Software NE" runs on Mobile X-ray unit and it is displayed on touch screen. It is the user interface and compatible digital detectors are listed above. All have FDA Clearance. The Advanced configuration has a second Touch Screen Monitor located on head-assembly.
The PhoeniX Mobile X-Ray Unit is provided with separate battery packs for X-Ray generation and motorized movements of the unit can operate connected to mains or in stand-alone mode, that is, operating without mains being present or unplugged from mains. The unit is connected to mains to charge the batteries; New rating: the input voltage range goes from 100 V~ to 240 V~, 1 phase, 1.1 kVA. New X-ray generator (model SHFM) is mounted on Battery Mobile X-Ray unit PhoeniX. This new X-Ray generator for PhoeniX Mobile X-Ray Unit has a radiogenic unit mounted on headassembly and comprising an X-ray tube with rotating anode and its circuit for high voltage. The electronic and associated software to control the X-ray generation are placed on mobile cart. The Battery Mobile X-Ray Unit PhoeniX is provided with different output powers: 20 kW, 32 kW, 40 kW and 50 kW. There are available two X-ray tube inserts with rotating anode manufactured by CANON ELECTRON TUBES & DEVICES:
-
New: XRR-3331 insert.
-
New: E7886 insert.
New: Manual Beam Limiting Device from Ralco, model: R108 F. External interface (controls) and covers are provided by Sedecal. There are two versions of collimator assembly, Basic and Advanced.
Image /page/4/Picture/10 description: The image is a comparison of two different models of a medical device, labeled as "Basic" and "Advanced". The "Basic" model features a white box-like structure with a black control panel that has knobs and buttons. The "Advanced" model has a similar white box-like structure, but it is attached to a more complex arm and has a screen with various settings displayed.
5
| Basic | Advanced |
|---|---|
| Knobs to adjust the collimator blades. | |
| Collimator light push button. | |
| Rail system to install external additional | |
| filtration. | |
| Measuring tape to measure the SID. | |
| Double laser (optional) | |
| Motorized filter (optional) | Knobs to adjust the collimator blades. |
| Collimator light push button. | |
| Rail system to install external additional filtration. | |
| Measuring tape to measure the SID. | |
| Double laser (optional) | |
| Motorized filter (optional) | |
| Rear knobs to adjust the collimator blades (optional). | |
| Additional options selectable with TFT: | |
| Variable additional filtration. | |
| Collimator blades aperture. |
The Battery Mobile X-Ray Unit Phoenix is driven by holding the handlebar with the hands. It is provided to internal sensor (gauges) that control the direction and speed of each wheel depending the force applied by the operator.
New: the handlebar is capacitive handlebar and when operator put his hands-on handlebar the movements are enabled. The height of handlebar is adaptable to improve the user commodity.
Four buttons are provided on the hand grips placed on Head-Assembly. They control the motion of each driving wheel and allow fine positioning adjustment of the patient (movements with low speed because this control is not intended for long displacement).
The Battery Mobile X-Ray unit supports:
- Ethernet communication (with hospital and backup cable for digital detectors) ●
- . Wireless Wi-Fi communications (with digital detectors and remote hand switch). The wireless communication is supported by Access Point and one single internal antenna.
New: the front panel of Phoenix has a VGA port to display control console on external monitor. New: USB ports.
Infrared data communication for register the Wireless Detector to the Mobile unit by infrared communication. (This operation is done during installation process by service personnel.) Options:
Barcode scanner for register patient information.
Dosimetry for Dose Area Product (DAP).
Tube Arm specifications:
-Counterbalanced tube arm.
- Tube arm reach 1220 mm horizontally for both configurations (Advanced option with 4 steps and Basic option with 3 steps).
-Column rotation: ± 317 °.
-
Maximum SID to floor is 2020 mm for both configurations.
-
Minimum SID to floor is 530 mm for both configurations.
Mobile Unit:
- Weight: the worst configuration 520 kg.
-Size (L x W x H):
Mobile on parking position: 1220 x 540 x 1290 mm. o
Mobile fully extended (Telescopic column & Telescopic arm): 2290 x 1790 x 2230 mm. o
-Frontal anti-collision system.
-
Motorized unit up to 5,5 km/h.
-
Motor drive with two independent drive motors, one for each wheel (forward and reverse).
6
-Touch screen console:
- Main control console: 19 inch. 0
- Additionally, second touch screen of 8.4 inch for Advanced configuration 0
8) Substantial Equivalence Chart
| Characteristic | Predicate: K161345, Trade/Device Name:
RadPRO® Mobile 40kW; RadPRO® Mobile
40kW FLEXPLUS, Model SM-40HF-B-D-VIR | Phoenix |
|-------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for
Use: | Intended for use by a qualified/trained doctor
or technician on both adult and pediatric
subjects for taking diagnostic radiographic
exposures of the skull, spinal
column, chest, abdomen, extremities, and
other body parts. Applications can be
performed with the patient sitting, standing,
or lying in the prone or supine position. Not
for mammography | SAME |
| Configuration | Mobile System with digital x-ray panel and
image acquisition computer | SAME |
| X-ray
Generator(s) | kW Rating: 40 kW only.
kV range: From 40 kV to 150 kV in 1 kV steps
mA range: From 10 mA to 500 mA | kW rating: 20 kW, 32 kW, 40 kW and 50 kW.
kV range: from 40 kV to 150 kV in 1 kV steps.
mA range: from 10 mA to 630 mA / 640 mA /
650 mA. |
| Collimator | Ralco R221 DHHS | Ralco R108F (Two versions, see details above.) |
| Photos | Image: RadPRO® Mobile | Image: Phoenix Basic |
| Characteristic | Predicate: K161345, Trade/Device Name:
RadPRO® Mobile 40kW; RadPRO® Mobile
40kW FLEXPLUS, Model SM-40HF-B-D-VIR | Phoenix |
| Photos | Image: RadPRO® Mobile Flex Plus | Image: Phoenix Advanced |
| Digital X-ray
Panel Supplied | Canon CXDI 401C Wireless (CSI) K133693
Pixel size: 125 μm 3320 × 3408 pixels
Canon CXDI 701C Wireless (CSI) K131106
Pixel size: 125 μm 2800 × 3408 pixels
Canon CXDI 801C Wireless (CSI) K131106
Pixel size: 125 μm 2800 × 2192 pixels | CANON CXDI-401C Wireless (SAME)
CANON CXDI-701C Wireless (SAME)
CANON CXDI-801C Wireless (SAME)
Plus:
CANON CXDI-710C Wireless
CANON CXDI-810C Wireless
CANON CXDI-410C Wireless |
| Software | Canon control software CXDI-NE | SAME, updated in K190368 |
| Panel Interface | Ethernet or Wi-Fi wireless | SAME |
| Meets US
Performance
Standard | YES 21 CFR 1020.30 | SAME |
| Power Source | Input transformer with 7 input voltage taps
(100 / 110 / 120 /, 127 / 220 / 230 / 240 V~).
AC 20 amp and Batteries | Universal power supply, from 100 V~ to 240
V~. 1 phase, 1.1 kVA |
7
-
- 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.
-
- Summary of non-clinical testing: Systems covering all generator/panel combinations were assembled and tested and found to be operating properly. Firmware was validated according to the FDA Guidance: Guidance for the Content of Premarket
8
Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005. Because the system uses Wi-Fi and Ethernet, we observed the recommendations contained in the FDA Guidance Document: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014. The digital panel software employed was already reviewed by FDA in K190368. The PhoeniX Battery Mobile X-Ray Units have been tested to be in compliance with the following International Standards:
- a) IEC 60601-1:2005+A1:2012 (Edition 3.1)
- b) IEC 60601-1-2:2014 (Edition 4.0)
- c) IEC 60601-1-3:2008+A1:2013 (Edition 2.1)
- d) IEC 60601-2-54:2009+A1:2015 (Edition 1.1)
- e) IEC 60601-2-28:2010 (Edition 2.0)
- IEC 60601-1-6:2010 + A1:2013 (Edition 3.1) f)
- g) IEC 62304:2006 + A1:2016 (Edition 1.1)
-
- Summary of clinical testing: Clinical testing was not required to establish substantial equivalence because all digital x-ray receptor panels have had previous FDA clearance.
-
- Conclusion: After analyzing bench and clinical tests, it is the conclusion of Sedecal SA. that the new PhoeniX Digital Diagnostic Mobile 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.