K Number
K200183
Device Name
CS 9600
Manufacturer
Date Cleared
2020-03-13

(49 days)

Product Code
Regulation Number
892.1750
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The CS 9600 is extraoral system intended to produce two-dimensional digital X-ray images of the dento-maxillofacial, ENT (Ear, Nose and Throat), cervical spine and wrist regions at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

The CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

Device Description

CS 9600 is an extraoral system intended to produce two-dimensional and three-dimensional digital X-ray images of the dento-maxilofacial, ENT (Ear, Nose and Throat), cervical spine and wrist regions at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

The CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

CS 9600 is a cone-beam computed tomography (CBCT) x-ray system. It means CS 9600 rotates around the patient, capturing data using a cone-shaped x-ray beam. These data are used to reconstruct a two or a three-dimensional (3D) image of the following regions of the patient's anatomy: dental (teeth); oral and maxillofacial region (mouth, jaw and neck); ears, nose and throat region (ENT); cervical spine or wrist region.

Additional features such as low dose mode, scout image and metal artifact reduction are also provided by the CS 9600.

The CS 9600 can also be upgraded with cephalometric modality. The cephalometric modality of the proposed device CS 9600 is the same than the one available in the reference device K151087. The cephalometric mode works with a narrow beam linear scanning process called a "slot technique". The patient head is scanned in lines with a flat, fan-shaped x-ray beam.

AI/ML Overview

The provided text describes the CS 9600 device, an extraoral system for producing 2D and 3D digital X-ray images, and its substantial equivalence to predicate devices. It specifically details the addition of an optional cephalometric modality.

Here's an analysis of the acceptance criteria and the study that proves the device meets those criteria, based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance:

The document doesn't present a formal table of acceptance criteria with specific quantitative thresholds. Instead, it describes performance through comparison to predicate devices and general statements about clinical effectiveness. The core "acceptance criteria" appear to be met by demonstrating substantial equivalence to these predicate devices.

Feature / ModalityPredicate Device (K181136) PerformanceReference Device (K151087) Performance (for Ceph)CS 9600 Reported PerformanceAcceptance Standard
Panoramic ModalityPresent, same specifications as CS 9600N/APresent, same specifications as predicate K181136Substantial Equivalence to K181136
3D ModalityPresent, same specifications as CS 9600N/APresent, same specifications as predicate K181136Substantial Equivalence to K181136
Cephalometric Modality (Optional)Not present in primary predicatePresent, with detailed specificationsPresent, identical to reference device K151087Substantial Equivalence to K151087
Image Quality (Cephalometric)N/ANot explicitly stated but implied acceptable"acceptable clinical effectiveness" and "clinically usable diagnostic quality"Qualified expert review
EMC & Electrical SafetyImplicitly met by predicateImplicitly met by referenceMeets IEC 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-63Compliance with specified IEC/AAMI standards
Software ValidationImplicitly met by predicateImplicitly met by referenceValidated according to FDA Guidance for Software and CybersecurityCompliance with specified FDA Guidances
DICOM ConformanceImplicitly met by predicateImplicitly met by referenceMeets NEMA PS 3.1-3.20Compliance with NEMA DICOM Set
Pediatric InformationImplicitly met by predicateImplicitly met by referenceProvides design features and instructions for pediatricsCompliance with FDA Guidance on Pediatric Information

2. Sample Size Used for the Test Set and Data Provenance:

The document does not explicitly state the sample size for the test set. It mentions "clinical images representative of the range of the different cephalometric radiological exams were taken." This implies a set of images was used, but the exact number is not provided. The data provenance (country of origin, retrospective/prospective) is also not stated.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:

The document states that "The cephalometric images were reviewed by a qualified expert." It indicates a single expert was used. The specific qualifications of this expert are not detailed beyond "qualified expert."

4. Adjudication Method for the Test Set:

No adjudication method is described. The review was conducted by a single "qualified expert."

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

No MRMC comparative effectiveness study was mentioned. The study focused on technical comparisons and single-expert clinical review, not on comparing human reader performance with and without AI assistance.

6. If a Standalone (algorithm only without human-in-the-loop performance) was done:

The device described is an X-ray imaging system, not an AI algorithm. Therefore, a standalone performance study of an algorithm independent of human interaction is not applicable in this context. The "performance testing" was for the imaging system itself.

7. The Type of Ground Truth Used:

For the cephalometric images, the ground truth was established through expert consensus (or rather, the opinion of a single "qualified expert") who "evaluated [the images] to be of acceptable clinical effectiveness for the proposed indications for use" and "deemed to be of a clinically usable diagnostic quality."

8. The Sample Size for the Training Set:

The document describes performance testing for an imaging device, not an AI algorithm. As such, there is no mention of a "training set" in the context of machine learning. The device's performance is established based on its physical characteristics, image quality, and regulatory compliance, rather than by training on a dataset.

9. How the Ground Truth for the Training Set Was Established:

As mentioned above, the concept of a "training set" for an AI algorithm is not applicable to the information provided for this medical imaging device.

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March 13, 2020

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Trophy % Ms. Marie-Pierre Labat-Camy Global Regulatory Affairs Senior Manager 4 Rue F. Pelloutier - Croissy-Beaubourg 77435 Marne La Vallée, Cedex 2 FRANCE

Re: K200183

Trade/Device Name: CS 9600 Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: Class II Product Code: OAS Dated: January 22, 2020 Received: January 24, 2020

Dear Ms. Marie-Pierre Labat-Camy:

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 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-reporting

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combination-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 medical devices and radiation-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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ATTACHMENT 7

INDICATIONS FOR USE STATEMENT

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Indications for Use

510(k) Number (if known)

K200183

Device Name

CS 9600

Indications for Use (Describe)

The CS 9600 is extraoral system intended to produce two-dimensional digital X-ray images of the dento-maxillofacial, ENT (Ear, Nose and Throat), cervical spine and wrist regions at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

The CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

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

K200183

1. Date 510(k) Summary prepared

March 11, 2020

2. Submitter information

Applicant

Trophy 4 Rue F. Pelloutier - Croissy-Beaubourg 77435 Marne La Vallée, Cedex 2 France Phone: +33 1 64 80 85 26 Contact person: Ms. Marie-Pierre LABAT-CAMY

United Stated Sales Representative (U.S. Designated Agent):

Carestream Dental LLC 3625 Cumberland Boulevard, Suite 700, Atlanta. GA USA 30339 Phone: +1 (470) 481-4619 Contact: Mr. Sonny T. Nguyen

3. Device name and classification

Trade name: CS 9600 Regulation number: 21 CFR 892.1750 Requlation name (classification name): Computed tomography x-ray system Common name: Cone-beam computed tomography system Device Class: II Product Code: OAS

4. Predicate device and reference device

We consider the CS 9600 to be similar in design, composition and function to the following primary predicate device and reference device introduced into commercial distribution affer May 28, 1976:

PrimaryNamePredicateDevice510(k)Company Name
CS 9600K181136Trophy

Requlation number: 21 CFR 892.1750 Regulation name (classification name): Computed tomography x-ray system Common name: Cone-beam computed tomography system Device Class: II Product Code: OAS

Reference Device Name510(k)Company Name
CS 8100SCK151087Trophy

Regulation number: 21 CFR 872.1800 Regulation name (classification name): Extraoral source x-ray system Common name: X-ray imaging device Device Class: II Product Code: MUH

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5. Device Description

CS 9600 is an extraoral system intended to produce two-dimensional and three-dimensional digital X-ray images of the dento-maxilofacial, ENT (Ear, Nose and Throat), cervical spine and wrist regions at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

The CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

CS 9600 is a cone-beam computed tomography (CBCT) x-ray system. It means CS 9600 rotates around the patient, capturing data using a cone-shaped x-ray beam. These data are used to reconstruct a two or a three-dimensional (3D) image of the following regions of the patient's anatomy: dental (teeth); oral and maxillofacial region (mouth, jaw and neck); ears, nose and throat region (ENT); cervical spine or wrist region.

Additional features such as low dose mode, scout image and metal artifact reduction are also provided by the CS 9600.

The CS 9600 can also be upgraded with cephalometric modality. The cephalometric modality of the proposed device CS 9600 is the same than the one available in the reference device K151087. The cephalometric mode works with a narrow beam linear scanning process called a "slot technique". The patient head is scanned in lines with a flat, fan-shaped x-ray beam.

6. Indication for use

CS 9600 is an extraoral system intended to produce two-dimensional and three-dimensional digital X-ray images of the dento-maxilofacial, ENT (Ear, Nose and Throat), cervical spine and wrist regions at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

The CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

7. Substantial Equivalence

The subject device CS 9600, the primary predicate device K181136 and the reference device K151087 have the same intended use: extraoral x-ray systems that are intended to produce digital X-ray images at the direction of healthcare professionals as diagnostic support for pediatric and adult patients.

Both the CS 9600 and primary predicate device are intended as Cone-Beam Computed Tomography. The primary predicate device K181136 has the most similar indication for use and technological characteristics with the proposed device CS 9600.

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The table below provides the summary of the technological characteristics of CS 9600 compared to the primary predicate device.

Proposed devicePrimary Predicate Device
COMPANYNAMEMODEL NAMETrophyCS 9600TrophyCS 9600
510(K) NumberK181136
Indication foruseCS 9600 is an extraoral system intended to producetwo-dimensional and three-dimensional digital X-rayimages of the dento-maxillofacial, ENT (Ear, Nose andThroat), cervical spine and wrist regions at the directionof healthcare professionals as diagnostic support forpediatric and adult patients.The CS 9600 can be upgraded to producecephalometric digital X-ray images. This includesimaging the hand and wrist to obtain carpus image forgrowth and maturity assessment.CS 9600 is an extraoral system intendedto produce two-dimensional and three-dimensional digital X-ray images of thedento-maxillofacial, ENT (Ear, Nose andThroat), cervical spine and wrist regionsat the direction of healthcareprofessionals as diagnostic support forpediatric and adult patients.
Performancespecification· Panoramic modality· 3D modality· Cephalometric modality (optional)· Panoramic modality· 3D modality
Rated linevoltage100-240 Vac - 50/60 HzSame
X-ray tubevoltage60-90 kV60-120 kV (in option)Same
X-ray tubecurrent2-15 mASame
X-ray tubeDF-071G or OX/120-0307Same
Tube focalspot0.3 or 0.7 mmSame
Patient sizes4 patients sizes:child, small adult, medium adult, large adultSame

The proposed CS 9600 and the primary predicate device CS 9600 (K181136) have the same panoramic two-dimensional modality and three-dimensional 3D modality.

COMPANY NAMEMODEL NAMEProposed deviceTrophyCS 9600Primary Predicate deviceTrophyCS 9600
510(K) NumberK181136
Two-dimensional modality: PANORAMIC
SensortechnologyCMOSSame
Image field6.4 x 140 mm (for adult patient size)6.4 x 120 mm (for child patient size)120 x 140 mm (for sinus one-shot exam)Same
Gray scale16384 - 14 bitsSame
Magnification1.28Same
RadiologicalExams• Full panoramic• Segmented panoramic• Bitewing• Maxillary sinus• Lateral TMJ x2 and Lateral TMJx4• Sinus AP / PA / Lateral• Orthogonal panoramicSame
Exposure time0.5 to 13 secondsSame
COMPANY NAMEMODEL NAMEProposed deviceTrophyCS 9600Primary Predicate deviceTrophyCS 9600
510(K) NumberK181136
Three-dimensional modality: 3D
SensortechnologyCMOSSame
Field of View(cm)diameter xheight• 4 x 4• 5 x 5 (child 4 x 4)• 5 x 8• 6 x 6• 8 x 5• 8 x 8• 10 x 5 (child 8 x 5)• 10 x 10* (child 8 x 8)• 12 x 5• 12 x 10*• 16 x 6• 16 x 10*• 16 x 12*• 16 x 17** with tip of the volumeSame
RadiologicalExams• Tooth/Teeth• Jaw (full, upper or lower)• Upper cervical spine• TMJ• Face• ENT• WristSame
Gray scale16384 - 14 bitsSame
Magnification1.4Same
Voxel size (µm)75, 150, 300 and 400Same
Exposure time3-20 secondsSame
OTHER INFORMATION
Low dose modeYesSame
Scout imageYesSame
3D Face PhotoYes in option (CS Face Scan)Same
Metal ArtefactReductionYes in option (CS MAR)Same
Concernedanatomical sites• Dento-maxillofacial area• ENT area• Cervical spine• Hand/wristSame
Sensor modelCGF81Same
Sensor activearea (mm)120 x 140Same
Pixel size (µm)100 x 100Same
Sensorresolution1200 x 1400 pixelsSame
Limitingresolution5 lp/mmSame
MTF, X-ray (%)at 1 lp/mm,Typical60Same
DQE, X-ray (%)at 0 lp/mm,Typical60Same
Proposed deviceReference Device
COMPANYNAMEMODEL NAMETrophyCS 9600TrophyCS 8100SC
510(K) NumberK151087
Indication foruseCS 9600 is an extraoral system intended toproduce two-dimensional and three-dimensionaldigital X-ray images of the dento-maxillofacial,ENT (Ear, Nose and Throat), cervical spine andwrist regions at the direction of healthcareprofessionals as diagnostic support for pediatricand adult patients.The CS 9600 can be upgraded to producecephalometric digital X-ray images. Thisincludes imaging the hand and wrist to obtaincarpus image for growth and maturityassessment.The CS 8100SC and the CS 8100SC Accessare indicated to produce complete andsegmented tomographic digital panoramic andcephalometric digital X-ray imagesto be used at the direction of healthcareprofessionals of the dento-maxillofacial region ofthe human anatomy as diagnostic support forpediatric and adult patients.This includes imaging the hand and wrist toobtain carpus image for growth and maturityassessment.In addition, the CS 8100SC is provided with thepanoramic radiological exam option whichallows the display of one determined segment ofthe dental structures usingthe capability of the system to explore each slideduring an exam.
Two-dimensional modality: CEPHALOMETRIC
SensortechnologyCMOSCMOS
RadiologicalExams• Lateral• Frontal AP or PA• Oblique• Submento-vertex• Carpus (optional)Same
Field of View(cm) LxH18x18, 18x24 and 26x24Same
Gray scale16384 - 14 bitsSame
Exposuretime2.96 to 10 seconds3 to 10 seconds
Sensor modelCGC95Same
Sensor activearea (mm)131.6 x 6.4Same
Pixel size(μm)100 x 100Same
Sensorresolution1316 x 64 pixelsSame
Limitingresolution5 lp/mmSame
MTF, X-ray(%) at 1lp/mm,Typical60Same
DQE, X-ray(%) at 0lp/mm,Typical60Same

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The proposed CS 9600 and the primary predicate device CS 9600 (K181136) have the same panoramic two-dimensional modality and three-dimensional 3D modality.

The main difference between the proposed CS 9600 and the primary predicate device K181136 is the difference in 2D imaging capabilities available with the addition in the proposed CS 9600 of the optional two-dimensional cephalometric modality.

The proposed device CS 9600 can be upgraded to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

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When the CS 9600 is upgraded with cephalometric modality to produce cephalometric digital X-ray images, the cephalometric modality available is the same as the cephalometric modality available in previously cleared reference device K151087.

The following table provides the summary of the technological characteristics of the cephalometric modality of CS 9600 compared to the reference device K151087.

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When the CS 9600 is upgraded with cephalometric modality to produce cephalometric digital X-ray images, the proposed CS 9600 and the reference device K151087 have the same cephalometric modality. Both systems are able to produce cephalometric digital X-ray images. This includes imaging the hand and wrist to obtain carpus image for growth and maturity assessment.

While the indication for use of primary predicate device K181136 and reference device K151087 are different, both devices have the same intended use, namely extraoral x-ray system.

The proposed device CS 9600 combines the indication for use of both the primary predicate device K181136 with the part of indication for use related to the cephalometric modality of the reference device K151087.

8. Non-Clinical Performance Data

The Testing to verify the performance requirements of the subject device CS 9600 was conducted and including in this premarket notification.

Standards Conformance:

EMC and Electrical Safety testing were performed respectively by LCIE and UL laboratory and found to meet all the requirements in standards IEC 60601-1: 2005 with A1 2012 (AAMI/ANSI ES60601-1:2005/R(2012), IEC 60601-1-2: 2014, IEC 60601-1-3: 2008 with A1 2013. IEC 60601-2-63: 2017 and IEC 62304: 2006 with A1 2015.

CS 9600 meets the provisions of NEMA PS 3.1-3.20. Digital Imaging and Communications in Medicine (DICOM) Set. The software contained in CS 9600 has been validated according to FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices and FDA Guidance for the Content of Premarket Submissions for Management of Cybersecurity in Medical Devices.

The CS 9600 provides design features and instructions for pediation according to the FDA Guidance on Pediatric Information for X-ray Imaging Device Premarket Notifications.

Performance Testing:

Since there is no change on the two-dimensional panoramic and three-dimensional 3D modalities of the proposed device CS 9600 compared to the primary predicate device K181136, the performance testing was conducted on the new cephalometric modality added in the proposed device CS 9600. Following the FDA Guidance for the Submission of 510(k)'s for Solid State X-ray imaging Devices, for the new cephalometric imaging applications, clinical images representative of the range of the different cephalometric radiological exams were taken. The cephalometric images were reviewed by a qualified expert and were evaluated to be of acceptable clinical effectiveness for the proposed indications for use. The CS 9600 set of images were deemed to be of a clinically usable diagnostic quality.

Non clinical and bench testing was conducted as part of design control to ensure the substantial equivalence of CS 9600 with the primary predicate device K181136 and reference device K151087. CS 9600 has been tested to ensure that the system as a whole operated in a safe and effective manner that is substantially equivalent to the primary predicate device and for the cephalometric modality to the predicate device. The results of the performance testing support substantial equivalence.

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9. Conclusion

The comparison of characteristics supports substantial equivalence. CS 9600 is as safe and effective as the primary predicate device K181136 and as the reference device K151087 for the cephalometric modality.

CS 9600 is considered substantially equivalent to the primary predicate device K181136 because both have the most similar indication for use and technological characteristics. Both have the same panoramic two-dimensional modality and three-dimensional 3D modality. Cephalometric modality added in the proposed device CS 9600 is identical to the cephalometric modality included in previously cleared reference device K151087. The compared technical features for cephalometric imaging technology, Field of View, and other basic characteristics are matching very closely. There is no difference in the new cephalometric modality available in the proposed device CS 9600 and the cephalometric modality available on the reference device K151087. Therefore, the addition of the cephalometric modality to the CS 9600 does not raise questions of safety and effectiveness and does not have any effect on performance in practice.

§ 892.1750 Computed tomography x-ray system.

(a)
Identification. A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.