K Number
K192506
Device Name
Vantage Galan 3T, MRT-3020, V6.0
Date Cleared
2020-03-02

(172 days)

Product Code
Regulation Number
892.1000
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Vantage Galan 3T systems are indicated for use as a diagnostic imaging modality that produces crosssectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body. Additionally, this system is capable of non-contrast enhanced imaging, such as MRA. MRI (magnetic resonance imaging) images correspond to the spatial distribution of protons (hydrogen nuclei) that exhibit nuclear magnetic resonance (NMR). The NMR properties of body tissues and fluids are: - Proton density (PD) (also called hydrogen density) - Spin-lattice relaxation time (T1) - Spin-spin relaxation time (T2) - Flow dynamics - Chemical Shift Depending on the region of interest, contrast agents may be used. When interpreted by a trained physician, these images yield information that can be useful in diagnosis.
Device Description
The Vantage Galan (Model MRT-3020) is a 3 Tesla Magnetic Resonance Imaging (MRI) System, previously cleared under K181593. This system is based upon the technology and materials of previously marketed Canon Medical Systems and is intended to acquire and display crosssectional transaxial, coronal, sagittal, and oblique images of anatomic structures of the head or body.
More Information

No
The document does not mention AI, ML, or related terms, and the performance studies focus on traditional image quality metrics and SAR calculations.

No.
The device is indicated for use as a diagnostic imaging modality to produce images useful in diagnosis, not for therapeutic purposes.

Yes
The "Intended Use / Indications for Use" section explicitly states that the device is "indicated for use as a diagnostic imaging modality" and that, when interpreted by a trained physician, the images "yield information that can be useful in diagnosis."

No

The device description explicitly states it is a "3 Tesla Magnetic Resonance Imaging (MRI) System," which is a hardware device. While it likely includes software for operation and image processing, it is not solely software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information for diagnosis, monitoring, or screening.
  • Device Function: The Vantage Galan 3T system is a Magnetic Resonance Imaging (MRI) system. It produces images of the internal structures of the body by using magnetic fields and radio waves. It does not analyze specimens taken from the body.
  • Intended Use: The intended use clearly states that it "produces crosssectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body." This is an in vivo (within the living body) imaging technique, not an in vitro diagnostic test.
  • Input: The input is the patient's body within the MRI scanner, not a biological specimen.

Therefore, based on the provided information, the Vantage Galan 3T system is an in vivo diagnostic imaging device, not an IVD.

N/A

Intended Use / Indications for Use

Vantage Galan 3T systems are indicated for use as a diagnostic imaging modality that produces cross-sectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body. Additionally, this system is capable of non-contrast enhanced imaging, such as MRA.

MRI (magnetic resonance imaging) images correspond to the spatial distribution of protons (hydrogen nuclei) that exhibit nuclear magnetic resonance (NMR). The NMR properties of body tissues and fluids are:

  • Proton density (PD) (also called hydrogen density)
  • . Spin-lattice relaxation time (T1)
  • Spin-spin relaxation time (T2)
  • Flow dynamics
  • Chemical Shift

Depending on the region of interest, contrast agents may be used. When interpreted by a trained physician, these images yield information that can be useful in diagnosis.

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

LNH

Device Description

The Vantage Galan (Model MRT-3020) is a 3 Tesla Magnetic Resonance Imaging (MRI) System, previously cleared under K181593. This system is based upon the technology and materials of previously marketed Canon Medical Systems and is intended to acquire and display crosssectional transaxial, coronal, sagittal, and oblique images of anatomic structures of the head or body.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Magnetic Resonance Imaging (MRI)

Anatomical Site

head or body

Indicated Patient Age Range

Not Found

Intended User / Care Setting

trained physician / Not Found

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

Not Found

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

MR image quality metrics were performed, utilizing phantoms and volunteer images, to assess Compressed SPEEDER with regards to SNR, unfolding error artifacts and performance in all the phase encode directions. It was concluded that Compressed SPEEDER met all acceptance criteria.

Additionally, representative images, reviewed by American Board Certified Radiologists, were obtained using the subject device. Reviewers provided detailed assessments of image degradation, diagnostic performance, lesion conspicuity, and clinical utility. It was confirmed that Compressed SPEEDER images were of diagnostic quality.

T2 Map Using Pre-Contrast Pulses was evaluated utilizing phantom and volunteer images. It was concluded that T2 maps can be generated using the data acquired using pre-contrast pulses.

New SAR calculation method was evaluated by imaging and modeling a phantom of known dimension and electromagnetic properties in combination with volunteer imaging. It was concluded that the new SAR calculation method is substantially equivalent to the predicate device as demonstrated by the results of the above testing.

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

Risk analysis and verification/validation testing conducted through bench testing are included in this submission which demonstrate that the system requirements have been met. Additionally, image quality testing was completed which demonstrated that the subject device meets predetermined acceptance criteria.

MR image quality metrics were performed, utilizing phantoms and volunteer images, to assess Compressed SPEEDER with regards to SNR, unfolding error artifacts and performance in all the phase encode directions. It was concluded that Compressed SPEEDER met all acceptance criteria.

Additionally, representative images, reviewed by American Board Certified Radiologists, were obtained using the subject device. Reviewers provided detailed assessments of image degradation, diagnostic performance, lesion conspicuity, and clinical utility. It was confirmed that Compressed SPEEDER images were of diagnostic quality.

T2 Map Using Pre-Contrast Pulses was evaluated utilizing phantom and volunteer images. It was concluded that T2 maps can be generated using the data acquired using pre-contrast pulses.

New SAR calculation method was evaluated by imaging and modeling a phantom of known dimension and electromagnetic properties in combination with volunteer imaging. It was concluded that the new SAR calculation method is substantially equivalent to the predicate device as demonstrated by the results of the above testing.

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.

K181593

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.

K162183, K183657, K182282

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

§ 892.1000 Magnetic resonance diagnostic device.

(a)
Identification. A magnetic resonance diagnostic device is intended for general diagnostic use to present images which reflect the spatial distribution and/or magnetic resonance spectra which reflect frequency and distribution of nuclei exhibiting nuclear magnetic resonance. Other physical parameters derived from the images and/or spectra may also be produced. The device includes hydrogen-1 (proton) imaging, sodium-23 imaging, hydrogen-1 spectroscopy, phosphorus-31 spectroscopy, and chemical shift imaging (preserving simultaneous frequency and spatial information).(b)
Classification. Class II (special controls). A magnetic resonance imaging disposable kit intended for use with a magnetic resonance diagnostic device only 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 shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym and full name on the right. The FDA part of the logo is in blue, with the acronym in a square and the full name written out to the right of it. The full name reads "U.S. Food & Drug Administration".

Canon Medical Systems Corporation % Ms. Janine F. Reyes Manager, Regulatory Affairs Canon Medical Systems USA, Inc. 2441 Michelle Drive TUSTIN CA 92780

Re: K192506

Trade/Device Name: Vantage Galan 3T, MRT-3020, V6.0 Regulation Number: 21 CFR 892.1000 Regulation Name: Magnetic resonance diagnostic device Regulatory Class: Class II Product Code: LNH Dated: January 21, 2020 Received: January 22, 2020

Dear Ms. Reyes:

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

March 2, 2020

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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known)

K192506

Device Name Vantage Galan 3T, MRT-3020, V6.0

Indications for Use (Describe)

Vantage Galan 3T systems are indicated for use as a diagnostic imaging modality that produces cross-sectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body. Additionally, this system is capable of non-contrast enhanced imaging, such as MRA.

MRI (magnetic resonance imaging) images correspond to the spatial distribution of protons (hydrogen nuclei) that exhibit nuclear magnetic resonance (NMR). The NMR properties of body tissues and fluids are:

  • ·Proton density (PD) (also called hydrogen density) ·Spin-lattice relaxation time (T1) ·Spin-spin relaxation time (T2) ·Flow dynamics
    ·Chemical Shift

Depending on the region of interest, contrast agents may be used. When interpreted by a trained physician, these images yield information that can be useful in diagnosis.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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510(k) SUMMARY

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of Safe Medical Device Act 1990 and 21 CFR § 807.92

1. CLASSIFICATION and DEVICE NAME

Classification Name:Magnetic Resonance Diagnostic Device
Regulation Number:90-LNH (Per 21 CFR § 892.1000)
Trade Proprietary Name:Vantage Galan 3T, MRT-3020, V6.0
Model Number:MRT-3020

2. SUBMITTER'S NAME

Canon Medical Systems Corporation 1385 Shimoishigami Otawara-Shi, Tochigi-ken, Japan 324-8550

3. OFFICIAL CORRESPONDENT

Naofumi Watanabe Senior Manager, Regulatory Affairs and Vigilance Canon Medical Systems Corporation

4. CONTACT PERSON, U.S. AGENT and ADDRESS

Contact Person

Janine F. Reyes Manager, Regulatory Affairs Canon Medical Systems USA, Inc. 2441 Michelle Drive, Tustin, CA 92780 Phone: (714) 669-7853 Fax: (714) 730-1310 E-mail: jfreyes@us.medical.canon

Official Correspondent/U.S. Agent

Paul Biggins Senior Director, Regulatory Affairs Canon Medical Systems USA, Inc. 2441 Michelle Drive, Tustin, CA 92780 Phone: (714) 730-7808 Fax: (714) 730-1310 E-mail: pbiggins@us.medical.canon

4

    1. MANUFACTURING SITE Canon Medical Systems Corporation 1385 Shimoishigami Otawara-shi, Tochigi 324-8550, Japan
    1. ESTABLISHMENT REGISTRATION 9614698
    1. DATE PREPARED September 10th, 2019
    1. DEVICE NAME Vantage Galan 3T, MRT-3020, V6.0
    1. TRADE NAME Vantage Galan 3T, MRT-3020, V6.0

10. CLASSIFICATION NAME

Magnetic Resonance Diagnostic Device (MRDD)

11. CLASSIFICATION PANEL

Radiology

    1. DEVICE CLASSIFICATION
      Class II (per 21 CFR 892.1000, Magnetic Resonance Diagnostic Device)

13. PRODUCT CODE

90-LNH

14. PREDICATE DEVICE

Predicate Device (system): Vantage Galan 3T, MRT-3020/A7, V5.0 (K181593) Reference Device (system): Vantage Galan 3T, MRT-3020 (K162183), Vantage Galan 3T, MRT-3020/A9 (K183657), Vantage Orian 1.5T, MRT-1550 (K182282)

SystemSubject DevicePredicate DeviceReference DeviceReference DeviceReference Device
Vantage Galan
3T, MRT-3020,
V6.0Vantage Galan 3T,
MRT-3020/A7,
V5.0Vantage Galan 3T,
MRT-3020,
V4.0Vantage Galan 3T,
MRT-3020/A9,
V5.0Vantage Orian
1.5T, MRT-1550,
V4.5
Marketed
ByCanon Medical
Systems USA, Inc.Canon Medical
Systems USA, Inc.Canon Medical
Systems USA, Inc.Canon Medical
Systems USA, Inc.Canon Medical
Systems USA, Inc.
510(k)
NumberThis SubmissionK181593K162183K183657K182282
Clearance
DateAugust 13, 2018November 25, 2016March 15, 2019October 19, 2018

5

15. REASON FOR SUBMISSION

Modification of a cleared device

16. SUBMISSION TYPE

Traditional 510(k) Premarket Notification

17. DEVICE DESCRIPTION

The Vantage Galan (Model MRT-3020) is a 3 Tesla Magnetic Resonance Imaging (MRI) System, previously cleared under K181593. This system is based upon the technology and materials of previously marketed Canon Medical Systems and is intended to acquire and display crosssectional transaxial, coronal, sagittal, and oblique images of anatomic structures of the head or body.

18. SUMMARY OF CHANGE(S)

This submission is to report the following software functionalities have been added:

Summary of Hardware Changes:

  • New Cover Design
  • Optional Dockable/Detachable Table

Summary of Software Changes:

  • New SAR: New calculation method is applied.
  • Compressed SPEEDER (Compressed Sensing)*: ●
    • This application allows accelerated fast scan of the brain, cervical spine, thoracic . spine, lumbar spine, shoulder, knee, foot, ankle, elbow and wrist. Compressed SPEEDER combines parallel imaging by using multi-sensitivity map and compressed sensing.
    • . Compressed SPEEDER feature allows acceleration factors for shorter scan times or higher resolution in FSE2D imaging based upon the principle of Compressed Sensing in combination with parallel imaging.
  • T2 Map Using Pre-Contrast Pulses: ECG gating or peripheral pulse gating is used in scanning with FFE2D sequences, and different Pre-contrast pulses are used to obtain multiple TEeff images.
  • CP Mode (quadrature transmit mode): has been added. ●

Labeling Changes:

  • Adaptive Scan Mode: The function name of "Limited Scan Mode" has been changed to "Adaptive Scan Mode".
    *Note: Compressed SPEEDER should not be used for contrast-agent-enhanced imaging.

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Made For life

19. SAFETY PARAMETERS

| Item | Subject Device:
Vantage Galan 3T,
MRT-3020, V6.0 | Predicate Device:
Vantage Galan 3.0T, MRT-
3020/A7, V5.0 | Notes |
|---------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|-------|
| Static field strength | 3T | 3T | Same |
| Operational Modes | Normal and 1st Operating Mode | Normal and 1st Operating Mode | Same |
| i. Safety parameter display | SAR, dB/dt | SAR, dB/dt | Same |
| ii. Operating mode access
requirements | Allows screen access to 1st level
operating mode | Allows screen access to 1st level
operating mode | Same |
| Maximum SAR | 4W/kg for whole body (1st operating
mode specified in IEC 60601-2-33:
2010+A1:2013+A2:2015) | 4W/kg for whole body (1st
operating mode specified in IEC
60601-2-33: 2010+A1:2013) | Same |
| Maximum dB/dt | 1st operating mode specified in
IEC 60601-2-33:
2010+A1:2013+A2:2015 | 1st operating mode specified in
IEC 60601-2-33: 2010+A1:2013 | Same |
| Potential emergency
condition and means
provided for shutdown | Shutdown by Emergency Ramp
Down Unit for collision hazard for
ferromagnetic objects | Shutdown by Emergency Ramp
Down Unit for collision hazard
for ferromagnetic objects | Same |

20. IMAGING PERFORMANCE PARAMETERS

No change from the previous predicate submission, K181593.

21. INDICATIONS FOR USE

Vantage Galan 3T systems are indicated for use as a diagnostic imaging modality that produces crosssectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body. Additionally, this system is capable of non-contrast enhanced imaging, such as MRA.

MRI (magnetic resonance imaging) images correspond to the spatial distribution of protons (hydrogen nuclei) that exhibit nuclear magnetic resonance (NMR). The NMR properties of body tissues and fluids are:

  • Proton density (PD) (also called hydrogen density)
  • . Spin-lattice relaxation time (T1)
  • Spin-spin relaxation time (T2)
  • Flow dynamics
  • Chemical Shift

Depending on the region of interest, contrast agents may be used. When interpreted by a trained physician, these images yield information that can be useful in diagnosis.

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Made For life

22. SUMMARY OF DESIGN CONTROL ACTIVITIES

Risk Management activities for new software functionalities and hardware changes are included in this submission. The test methods used are the same as those submitted in the previously cleared submission of the predicate device, Vantage Galan 3T, MRT-3020/A7, V5.0 (K181593). A declaration of conformity with design controls is included in this submission.

23. SAFETY

This device is designed and manufactured under the Quality System Regulations as outlined in 21 CFR § 820 and ISO 13485 Standards.

This device is based upon the same technologies, materials and software as the predicate device. Risk activities were conducted in concurrence with established medical device development standards and guidance. Additionally, testing was done in accordance with applicable recognized consensus standards published by the International Electrotechnical Commission (IEC) for medical devices and the National Electrical Manufacturers Association (NEMA):

LIST OF APPLICABLE STANDARDS

  • ANSI AAMI ES60601-1:2005/(R)2012 ● and A1:2012
  • . IEC60601-1-2 (2014)
  • . IEC60601-1-6 (2010), Amd.1 (2013)
  • IEC60601-2-33 (2010), Amd.1 (2013), Amd.2 (2015)
  • . IEC60825-1 (2007)
  • IEC62304 (2006), Amd.1 (2015) ●
  • IEC62366 (2007), Amd.1 (2014) ●
  • NEMA MS 1 (2008) ●
  • NEMA MS 2 (2008)
  • NEMA MS 3 (2008)
  • NEMA MS 4 (2010) ●
  • NEMA MS 5 (2010)

24. TESTING

Risk analysis and verification/validation testing conducted through bench testing are included in this submission which demonstrate that the system requirements have been met. Additionally, image quality testing was completed which demonstrated that the subject device meets predetermined acceptance criteria.

MR image quality metrics were performed, utilizing phantoms and volunteer images, to assess Compressed SPEEDER with regards to SNR, unfolding error artifacts and performance in all the phase encode directions. It was concluded that Compressed SPEEDER met all acceptance criteria.

Additionally, representative images, reviewed by American Board Certified Radiologists, were obtained using the subject device. Reviewers provided detailed assessments of image degradation, diagnostic performance, lesion conspicuity, and clinical utility. It was confirmed that Compressed SPEEDER images were of diagnostic quality.

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Image /page/8/Picture/0 description: The image shows the logo for Canon Medical Systems USA, Inc. The word "Canon" is in red, and the rest of the text is in black. The text is left-aligned and the font is sans-serif. The logo is simple and professional.

Made For life

T2 Map Using Pre-Contrast Pulses was evaluated utilizing phantom and volunteer images. It was concluded that T2 maps can be generated using the data acquired using pre-contrast pulses.

New SAR calculation method was evaluated by imaging and modeling a phantom of known dimension and electromagnetic properties in combination with volunteer imaging. It was concluded that the new SAR calculation method is substantially equivalent to the predicate device as demonstrated by the results of the above testing.

Software Documentation for a Moderate Level of Concern, per the FDA guidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document" issued on May 11, 2005, is also included as part of this submission.

25. SUBSTANTIAL EQUIVALENCE

Canon Medical Systems Corporation believes that the Vantage Galan 3T, MRT-3020, V6.0 Magnetic Resonance Imaging (MRI) System is substantially equivalent to the previously cleared predicate device, Vantage Galan 3T, MRT-3020/A7, V5.0, referenced in this submission. Canon Medical Systems Corporation believes that the changes incorporated into the Vantage Galan 3T, MRT-3020, V6.0 are substantially equivalent to the previously cleared predicate device.

26. CONCLUSION

The modifications incorporated into the Vantage Galan 3T, MRT-3020, V6.0 do not change the indications for use or the intended use of the device. Based upon bench testing, volunteer clinical imaging, successful completion of software validation and application of risk management and design controls, it is concluded that the subject device is safe and effective for its intended use.