(27 days)
VIVIX-S VW series is used for the general-purpose diagnostic procedures, and as intended to replace radiographic film/ screen systems. The VIVIX-S VW series is not intended for mammography applications.
VIVIX-S VW, a series for of flat panel detectors models named; FXRD-2530VW, FXRD-2530VW PLUS, FXRD-3643VW, FXRD-3643VW PLUS, FXRD-4343VW, FXRD-4343VW PLUS, with imaging areas of 25cm x 30cm, 36cm x 43cm, 43cm, respectively. The device intercepts x-ray photons and the scintillator emits visible spectrum photons that illuminate an array of photo (a-SI)-detectors that create electrical signals. After the electrical signals are generated, it is converted to digital value, and the Software which acquires and processes the data values from the detector. The resulting digital images will be displayed on monitors. These devices should be integrated with an operating PC and an X-Ray generator. It can be utilized to digitalize x-ray images and transfer for radiography diagnostic.
The retrieved text discusses the VIVIX-S VW digital flat panel X-ray detector, which is being reviewed for 510(k) clearance. The focus of the document is to demonstrate "substantial equivalence" of the device to previously cleared predicate devices, rather than establishing acceptance criteria for a new AI/CADe device with associated clinical studies that specifically prove these criteria are met.
Therefore, the provided text does not contain the detailed information required to fill out all the requested fields regarding acceptance criteria in the context of an AI/CADe device, as it is a 510(k) summary for a general X-ray detector. Specifically, it lacks information on:
- Specific acceptance criteria for clinical performance (e.g., sensitivity, specificity, AUC values with thresholds).
- The methodology for establishing ground truth for a test set (e.g., how experts determined disease presence/absence in a test set, number of experts, qualifications).
- Adjudication methods.
- MRMC comparative effectiveness study details (effect size of human readers with/without AI assistance).
- Standalone algorithm performance (since this is an X-ray detector, not an AI algorithm).
- Sample size and ground truth for a training set (which would be relevant for an AI model).
However, based on the information available, here's what can be extracted and inferred to the best extent possible for a general X-ray detector:
1. A table of acceptance criteria and the reported device performance
For an X-ray detector, acceptance criteria are primarily related to physical and imaging performance characteristics, not diagnostic accuracy in the way an AI algorithm would be evaluated. The text focuses on demonstrating equivalence to predicate devices using these metrics.
| Acceptance Criteria (Predicate Performance) | Reported Device Performance (Subject Device) |
|---|---|
| MTF (at 1lp/mm) | |
| FXRD-1717VA: 72 | FXRD-4343VAW: 76 |
| FXRD-1717VB: 60 | FXRD-4343VAW PLUS: 60 |
| FXRD-1417NAW: 75 | FXRD-3643VAW: 74 |
| FXRD-1417NBW: 61.5 | FXRD-3643VAW PLUS: 59 |
| FXRD-1012NA(W): 75 | FXRD-2530VAW: 76 |
| FXRD-1012NB(W): 58.5 | FXRD-2530VAW PLUS: 60 |
| DQE (at 1lp/mm) | |
| FXRD-1717VA: 45 | FXRD-4343VAW: 45 |
| FXRD-1717VB: 28.5 | FXRD-4343VAW PLUS: 53 |
| FXRD-1417NAW: 46.5 | FXRD-3643VAW: 41.5 |
| FXRD-1417NBW: 27.5 | FXRD-3643VAW PLUS: 51 |
| FXRD-1012NA(W): 49 | FXRD-2530VAW: 46 |
| FXRD-1012NB(W): 27 | FXRD-2530VAW PLUS: 52 |
| Spatial Resolution | |
| 3.5 lp/mm (for 1717V and 1417N predicates) | 3.5 lp/mm (for 4343VAW, 3643VAW) |
| 4.0 lp/mm (for 1012N predicate) | 4.0 lp/mm (for 2530VAW) |
| Diagnostic Capability (Clinical) | "Equivalent diagnostic capability" |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not explicitly stated. The document mentions "a comparison test was conducted" for non-clinical data and "A single-blinded concurrence study" for clinical data, but without specific numbers of images or cases.
- Data Provenance: Not specified.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Number of Experts: Not specified.
- Qualifications of Experts: Not specified. The study is described as a "single-blinded concurrence study," implying comparison between readers, but details on how ground truth was established are missing.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Adjudication Method: Not specified. The term "concurrence study" implies agreement, but the method for resolving discrepancies or establishing a definitive ground truth is not detailed.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- MRMC Study: The document describes a "single-blinded concurrence study" to confirm "equivalent diagnostic capability to the predicate devices." This is not an MRMC study comparing human readers with and without AI assistance, but rather a study comparing the diagnostic capability of images produced by the subject device versus predicate devices.
- Effect Size of Human Reader Improvement: Not applicable, as this was not an AI-assisted diagnostic study.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Study: Not applicable. This device is a digital X-ray detector, not an AI algorithm. Its performance is inherent in the image quality it produces, which is then interpreted by a human. The "standalone" concept typically applies to AI algorithms.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Type of Ground Truth: Not explicitly stated. For a "concurrence study" comparing diagnostic capability of images, the ground truth would likely be established by expert radiologists, possibly through consensus or by reference to other clinical information, but the method is not described.
8. The sample size for the training set
- Sample Size for Training Set: Not applicable. This device is a hardware X-ray detector, not a machine learning algorithm that requires a training set.
9. How the ground truth for the training set was established
- Ground Truth for Training Set: Not applicable, as there is no training set for a hardware device.
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March 18, 2020
Image /page/0/Picture/1 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 logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.
Vieworks Co., Ltd. % Mrs. Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA, Inc. 1150 Roosevelt, STE 200 IRVINE CA 92620
Re: K200418
Trade/Device Name: VIVIX-S VW Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: MQB Dated: January 27, 2020 Received: February 20, 2020
Dear Mrs. Chung:
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) K200418
Device Name VIVIX-S VW
Indications for Use (Describe)
VIVIX-S VW series is used for the general-purpose diagnostic procedures, and as intended to replace radiographic film/ screen systems. The VIVIX-S VW series is not intended for mammography applications.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| ------------------------------------------------- | -- |
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary
(K200418)
This 510(k) summary information is prepared in accordance with 21 CFR807.92
1. Date Prepared [21 CFR 807.92(a) (1)]
3/9/2020
2. Submitter's Information [21 CFR 807.92(a) (1)]
Name of Sponsor: Vieworks Co., Ltd. Address: (Gwanyang-dong) 41-3, Burim-ro 170beon-gil,Dongan-gu, Anyang-si, Gyeonggi-do, 431-060 Republic of Korea Contact Name: Kim, Jordin / Regulatory Affairs Associate Registration Number: 3006013411 Name of Manufacturer: Same as Sponsor
3. Trade Name, Common Name, Classification [21 CFR 807.92(a) (2)]
| Trade Name: | VIVIX-S VW |
|---|---|
| Model Name: | FXRD-4343VAW, FXRD-4343VAW PLUS, FXRD-3643VAW, FXRD-3643VAW PLUS, FXRD-2530VAW, FXRD-2530VAW PLUS |
| Common Name: | Digital Flat Panel X-ray Detector |
| Classification Name: | Regulation Name: Stationary X-Ray System |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR 892.1680 |
| Product Code: | MQB |
| Device Class: | 2 |
4. Identification of Predicate Device(s) [21 CFR 807.92(a) (3)]
| 510(k) Number: | K181003 |
|---|---|
| Applicant: | Vieworks Co., Ltd. |
| Trade Name: | VIVIX-S 1717V |
| Model Name: | FXRD-1717VAFXRD-1717VB |
| Common Name: | Digital Flat Panel X-ray Detector |
| Classification Name: | Regulation Name: Stationary X-Ray System |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR 892.1680 |
| Product Code: | MQB |
| Device Class: | 2 |
| Decision Date: | 03/15/2018 |
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Type: Traditional 510(k) Number: K163703 Vieworks Co., Ltd. Applicant: Trade Name: VIVIX-S 1417N Model Name: FXRD-1417NAW FXRD-1417NBW Digital Flat Panel X-ray Detector Common Name: Classification Name: Regulation Name: Stationary X-Ray System Classification Panel: Radiology Classification Regulation: 21 CFR 892.1680 Product Code: MQB Device Class: 2 01/05/2017 Decision Date: Type: Traditional 510(k) Number: K152885 Applicant: Vieworks Co., Ltd. Trade Name: VIVIX-S 1012N Model Name: FXRD-1012NA FXRD-1012NB FXRD-1012NAW FXRD-1012NBW Digital Flat Panel X-ray Detector Common Name: Regulation Name: Stationary X-Ray System Classification Name: Classification Panel: Radiology Classification Regulation: 21 CFR 892.1680 Product Code: MQB Device Class: 2 Decision Date: 01/28/2016 Type: Traditional
5. Description of the Device [21 CFR 807.92(a) (4)]
- General Description o
VIVIX-S VW, a series for of flat panel detectors models named; FXRD-2530VW, FXRD-2530VW PLUS, FXRD-3643VW, FXRD-3643VW PLUS, FXRD-4343VW, FXRD-4343VW PLUS, with imaging areas of 25cm x 30cm, 36cm x 43cm, 43cm, respectively. The device intercepts x-ray photons and the scintillator emits visible spectrum photons that illuminate an array of photo (a-SI)-detectors that create electrical signals. After the electrical signals are generated, it is converted to digital value, and the Software which acquires and processes the data values from the detector. The resulting digital images will be displayed on monitors. These devices should be integrated with an operating PC and an X-Ray generator. It can be utilized to digitalize x-ray images and transfer for radiography diagnostic.
{5}------------------------------------------------
6. Indications for Use [21 CFR 807.92(a)(5)]
VIVIX-S VW series is used for the general-purpose diagnostic procedures, and as well as intended to replace radiographic film/ screen systems. The VIVIX-S VW series is not intended for mammography applications.
7. Technological Characteristics [21 CFR 807.92(a) (6)]
Comparisons with the predicate, devices show the technological characteristics of the proposed VIVIX-S 1751S device to be substantially equivalent to the predicate devices. The proposed devices are functionally identical to the predicate devices.
8. Substantial Equivalence [21 CFR 807.92(b)(1) and 807.92]
When compared to the predicate devices (K181003, K163703, K152885), the VIVIX-S VW presented in this submission has the same:
- Intended Use
- Technological characteristics
- Operating principle
- · Design features
- Communication Method
- Scintillator Materials
- Resolution
There is similar performance as follow.
- Performance (MTF)
- · Performance (DQE)
There are no significant difference between the VIVIX-S 1751S and the predicate device that would adversely affect the use of the product. It is substantially equivalent to these devices in design, function, materials, operational principles and intended use.
| Parameter | Predicate Device | Subject Device | Equivalence |
|---|---|---|---|
| 510(k) Number | K181003 | - | - |
| Manufacturer | Vieworks Co., Ltd. | - | - |
| Device Name | VIVIX-S 1717V | VIVIX-S VW | - |
| Detector | FXRD-1717VA,FXRD-1717VB | FXRD-4343VAWFXRD-4343VAW PLUS | - |
| SCU | - | FXRS-04AFXRP-02A | PowerSupply |
| Software | VXvue | VXvue | Software |
| Common Name | Digital Flat Panel X-ray Detector | - | Equivalent |
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| Classification Name | Solid State X-Ray Imager (Flat Panel/Digital Imager) | Equivalent | |
|---|---|---|---|
| Classification Panel | Radiology | Equivalent | |
| ClassificationRegulation | 21 CFR 892.1680 | Equivalent | |
| Product Code | MQB | Equivalent | |
| Device Class | 2 | Equivalent | |
| Indications for Use | VIVIX-S 1717V series isindicated for digitalimaging solution designedas a general radiographicsystem for humananatomy. It is intended toreplace film or screenbased radiographicsystems in all generalpurposes of diagnosticprocedures. It is not to beused for mammography. | The VIVIX-S VW detectorsare used for the general-purpose diagnosticprocedures, and as well asintended to replaceradiographic film / screensystems.The VIVIX-S VW detectorsare not intended formammographyapplications. | Equivalent |
| MTF(Measured Values,at 1lp/mm) | FXRD-1717VA:72 | FXRD-4343VAW:76 | |
| (Measured Values,at 1lp/mm) | FXRD-1717VB:60 | FXRD-4343VAW PLUS:60 | |
| DQE(Measured Values,at 1lp/mm) | FXRD-1717VA:45 | FXRD-4343VAW:45 | |
| FXRD-1717VB:28.5 | FXRD-4343VAW PLUS:53 | ||
| Spatial Resolution | 3.5 lp/mm | FXRD-4343VAW:3.5 lp/mm | |
| FXRD-4343VAW PLUS:3.5 lp/mm |
| Parameter | Predicate Device | Subject Device | Equivalence |
|---|---|---|---|
| 510(k) Number | K163703 | - | - |
| Manufacturer | Vieworks Co., Ltd. | - | - |
| Device Name | FXRD-1417N | VIVIX-S 3643VW | - |
| Detector | FXRD-1417NAW,FXRD-1417NBW | FXRD-3643VAWFXRD-3643VAW PLUS | - |
| SCU | FXRS-03AFXRS-04AFXRP-02A | FXRS-04AFXRP-02A | PowerSupply |
| Software | VXvue | VXvue | Software |
| Common Name | Digital Flat Panel X-ray Detector | Equivalent | |
| Classification Name | Solid State X-Ray Imager (Flat Panel/Digital Imager) | Equivalent | |
| Classification Panel | Radiology | Equivalent |
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| ClassificationRegulation | 21 CFR 892.1680 | Equivalent | |
|---|---|---|---|
| Product Code | MQB | Equivalent | |
| Device Class | 2 | Equivalent | |
| Indications for Use | FXRD-1417NAW andFXRD-1417NBW areindicated for digitalimaging solution designedas a general radiographicsystem for humananatomy. It is intended toreplace film or screenbased radiographicsystems in all generalpurposes of diagnosticprocedures. It is not to beused for mammography. | The VIVIX-S VW detectorsare used for the general-purpose diagnosticprocedures, and as well asintended to replaceradiographic film / screensystems.The VIVIX-S VW detectorsare not intended formammographyapplications. | Equivalent |
| MTF(Measured Values,at 1lp/mm) | FXRD-1417NAW:75 | FXRD-3643VAW:74 | |
| FXRD-1417NBW:61.5 | FXRD-3643VAW PLUS:59 | ||
| DQE(Measured Values,at 1lp/mm) | FXRD-1417NAW:46.5 | FXRD-3643VAW:41.5 | |
| FXRD-1417NBW:27.5 | FXRD-3643VAW PLUS:51 | ||
| Spatial Resolution | 3.5lp/mm | FXRD-3643VAW:3.5lp/mm | |
| FXRD-3643VAW PLUS:3.5lp/mm |
| Parameter | Predicate Device | Subject Device | Equivalence |
|---|---|---|---|
| 510(k) Number | K152855 | - | - |
| Manufacturer | Vieworks Co., Ltd. | - | - |
| Device Name | VIVIX-S 1012N | VIVIX-S 2530VW | - |
| Detector | FXRD-1012NA,FXRD-1012NB,FXRD-1012NAW,FXRD-1012NBW | FXRD-2530VAWFXRD-2530VAW PLUS | - |
| SCU | FXRS-02AFXRS-03AFXRS-04AFXRP-02A | FXRS-04AFXRP-02A | PowerSupply |
| Software | VXvue | VXvue | Software |
| Common Name | Digital Flat Panel X-ray Detector | - | Equivalent |
| Classification Name | Solid State X-Ray Imager (Flat Panel/Digital Imager) | - | Equivalent |
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| Classification Panel | Radiology | Equivalent | |
|---|---|---|---|
| Classification | |||
| Regulation | 21 CFR 892.1680 | Equivalent | |
| Product Code | MQB | Equivalent | |
| Device Class | 2 | Equivalent | |
| Indications for Use | FXRD-1012NA, FXRD-1012NB, FXRD-1012NAWand FXRD-1012NBW areindicated for digital imagingsolution designed as ageneral radiographicsystem for human anatomy.It is intended to replace filmor screen basedradiographic systems in allgeneral purposes ofdiagnostic procedures. It isnot to be used formammography. | The VIVIX-S VW detectorsare used for the general-purpose diagnosticprocedures, and as well asintended to replaceradiographic film / screensystems. The VIVIX-S VWdetectors are not intendedfor mammographyapplications. | Equivalent |
| MTF(Measured Values,at 1lp/mm) | FXRD-1012NA(W):75 | FXRD-2530VAW:76 | |
| FXRD-1012NB(W):58.5 | FXRD-2530VAW PLUS:60 | ||
| DQE(Measured Values,at 1lp/mm) | FXRD-1012NA(W):49 | FXRD-2530VAW:46 | |
| FXRD-1012NB(W):27 | FXRD-2530VAW PLUS:52 | ||
| Spatial Resolution | 4.0 lp/mm | FXRD-2530VAW:4.0 lp/mm | |
| FXRD-2530VAW PLUS:4.0 lp/mm |
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9. Summary of Non-Clinical Data
A comparison test was conducted between the subject devices (VIVIX-S VW) and the predicate device (K181003, K163703, K152885) on the items such as DQE, MTF and spatial resolution.
These detectors comply with the following international and FDA-recognized consensus standards:
- · 21CFR1020.30, Diagnostic X-ray Systems and their major components
- · 21CFR1020.31, Radiographic equipment
-
- IEC 60601-1 Medical Electrical Equipment -- Part 1: General Requirements for Basic Safety and Essential Performance.
- CAN/CSA-C22.2 No. 60601-1 (2008) (Medical Equipment –Part 1
: General Requirements for Basic Safety and Essential Performance) (includes National Differences for Canada)
- ANSI/AAMI ES60601-1 (2005+ C1:09+A2:10) (Medical Electrical Equipment Part 1
- · IEC 60601-1-2 Medical Electrical Equipment Part 1-2
- : General Requirements for Basic Safety and Essential Performance Collateral Standard: Electromagnetic Compatibility - Requirements And Tests
10. Summary of Clinical Data
A single-blinded concurrence study according to CDRH's Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices was conducted, and the study confirmed that the new x-ray detectors VIVIX-S VW provide images of equivalent diagnostic capability to the predicate devices, the VIVIX-S 1717V, VIVIX-S 1417N, VIVIX-S 1012N and its results demonstrate substantial equivalence.
11. Conclusion [21 CFR 807.92(b) (3)]
The VIVIX-S VW Digital X-ray detectors are substantially equivalent to the currently marketed and predicate devices (K181003) in terms of design features, fundamental scientific technology, indications for use, and safety and effectiveness.
Additionally, Substantial equivalence was demonstrated through the non-clinical performance, which complied with the requirements specified in the international and FDA-recognized consensus standards, IEC60601-1, IEC 60601-1-2, 3 and the clinical test, which complied with the requirements specified in the CDRH's Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices.
The results of these tests demonstrate that VIVIX-S VW Digital X-ray detectors meets the acceptance criteria and is adequate for this intended use. The comparison of technological characteristics, non-clinical performance data, safety testing, and clinical image concurrence data demonstrates that the device is as safe, as effective, and performs as well the predicate devices.
§ 892.1680 Stationary x-ray system.
(a)
Identification. A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. 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). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary 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.