K Number
K200469
Device Name
PAPAYA 3D Premium & PAPAYA 3D Premium Plus
Manufacturer
Date Cleared
2020-09-16

(203 days)

Product Code
Regulation Number
892.1750
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The X-ray unit system is a diagnostic imaging system which consists of multiple image acquisition modes; panoramic, cephalometric, and CBCT (Cone Beam Computed Tomography). X-ray unit system is used for dental radiographic examination and diagnosis of teeth, jaw, oral structures and skull. The device is to be operated and used by dentists and other legally qualified professionals.
Device Description
The proposed device PAPAYA 3D Premium Plus the computed tomography x-ray system which consists of image acquisition modes; panorana, cephalometric, and computed tomography. The difference between PAPAYA 3D Premium Plus is only optional of the cephalometric detector. It designed for dental radiography of the oral and cranionarial as teeth, jaws and oral structures. The device with cephalometric detector is named PAPAYA 3D Premium Plus and the device without cephalometric detector is named PAPAYA 3D Premium. The proposed device are composed of flat panel x-ray detectors which are based on CMOS, and TFT detector types and divided in to CT, panoramic and cephalometric radiography, and x-ay tube. CMOS, and TFT detectors are used to capture scamed image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D the anatomic stuctures by acquiring 3609rotational image sequences of oral and craniofacial area.
More Information

No
The summary describes a standard dental X-ray system with different imaging modes and detectors. There is no mention of AI, ML, or any related technologies in the device description, intended use, or performance studies. The "Mentions AI, DNN, or ML" field is explicitly marked as "Not Found".

No
The device is used for diagnostic imaging (examination and diagnosis) and not for treating or preventing diseases.

Yes

The "Intended Use / Indications for Use" section explicitly states that the X-ray unit system is a "diagnostic imaging system" and is used for "diagnosis of teeth, jaw, oral structures and skull."

No

The device description explicitly states it is a "computed tomography x-ray system" composed of hardware components like "flat panel x-ray detectors" and an "x-ray tube," which are physical components, not software.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices intended to be used in vitro for the examination of specimens, including blood and tissue samples, derived from the human body, solely or principally for the purpose of providing information concerning a physiological or pathological state, or concerning a congenital abnormality, or to determine the safety and compatibility with potential recipients, or to monitor therapeutic measures.
  • Device Function: The described device is an X-ray imaging system. It acquires images of the internal structures of the body (teeth, jaw, skull, etc.) using X-rays. This is an in vivo diagnostic method, meaning it is performed on a living organism.
  • Lack of Specimen Analysis: The device does not analyze biological specimens (blood, tissue, etc.) outside of the body.

Therefore, based on the provided information, the device clearly falls under the category of an in vivo diagnostic imaging system, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The X-ray unit system is a diagnostic imaging system which consists of multiple image acquisition modes; panoramic, cephalometric, and CBCT (Cone Beam Computed Tomography). X-ray unit system is used for dental radiographic examination and diagnosis of teeth, jaw, oral structures and skull. The device is to be operated and used by dentists and other legally qualified professionals.

Product codes

OAS, MUH

Device Description

The proposed device PAPAYA 3D Premium Plus the computed tomography x-ray system which consists of image acquisition modes; panorana, cephalometric, and computed tomography. The difference between PAPAYA 3D Premium Plus is only optional of the cephalometric detector. It designed for dental radiography of the oral and cranionarial as teeth, jaws and oral structures. The device with cephalometric detector is named PAPAYA 3D Premium Plus and the device without cephalometric detector is named PAPAYA 3D Premium.

The proposed device are composed of flat panel x-ray detectors which are based on CMOS, and TFT detector types and divided in to CT, panoramic and cephalometric radiography, and x-ay tube. CMOS, and TFT detectors are used to capture scamed image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D the anatomic stuctures by acquiring 3609rotational image sequences of oral and craniofacial area.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

teeth, jaw, oral structures and skull.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dentists and other legally qualified professionals.

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

For the newly added CBCT image receptor (FXDD-0909GA), and Cephalometric mage receptor (FXDD-1012CA) it has been validated according to FDA "Gudance for the submission of 510(k)'s for Solid State X-ray Imaging Devices" as clinical considerations, and the climcal images were evaluated by the US board-certified oral surgeon. Throughout the evaluation by oral surgeon, the proposed device with newly added detectors are well enough to diagnosable and meet its indications for use.

Furthermore, the imaging performance of newly added CBCT image receptor (FXDD-0909GA) such as ganty positioning accuracy, In-plane uniformity, Spatial Resolution section thickness, Nose, Contrast to Noise Rato, Geometric Distortion, and Metal Artifacts and Cephalometric image receptor (FXDD-1012CA) such as Line pair resolution was tested with phantoms to validate its performance. The detail information about the clinical image evaluation can be found in the "Attachment X Evaluation of PAPAYA 3D Premium & PAPAYA 3D Premium Plus mages" and the imaging performance test report can be found in the "Attachment IX Solid State X-ray Imaging Device".

Key Metrics

Not Found

Predicate Device(s)

K150354

Reference Device(s)

K182805

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

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September 16, 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.

Genoray Co., Ltd. % Ms. Kaitlynn Min Business Development Manager Genoray America, Inc. 147 E. Bristol Lane ORANGE CA 92865

Re: K200469

Trade/Device Name: PAPAYA 3D Premium & PAPAYA 3D Premium Plus Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: Class II Product Code: OAS, MUH Dated: August 12, 2020 Received: August 13, 2020

Dear Ms. Min:

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) K200469

Device Name PAPAYA 3D Premium & PAPAYA 3D Premium Plus

Indications for Use (Describe)

The X-ray unit system is a diagnostic imaging system which consists of multiple image acquisition modes; panoramic, cephalometric, and CBCT (Cone Beam Computed Tomography). X-ray unit system is used for dental radiographic examination and diagnosis of teeth, jaw, oral structures and skull. The device is to be operated and other legally qualified professionals.

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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Exhibit 5 510(k) Summary

K200469

Date of Summary Preparation: February 21, 2020

1. Submitter and US Official Correspondent

Submitter: GENORAY Co., Ltd. Address: 512, 560, Dunchon-daero, Jungwon-gu, Seongnam-si, Gyeonggi-Do, Korea Telephone No .: +82-31-740-4100 Fax: +82-31-740-4195

Official Correspondent (U.S): Kaitlynn Min - Business Manager

Correspondent: GENORAY America Inc. Address: 147 E. Bristol Lane, Orange, CA 92865 USA Telephone No .: +1-855-436-6729 Fax: +1-714-786-8919 Email: kaitlynn@genorayamerica.com

2. Establishment Registration Number

: 3005843418

3. Device Information

  • Product/Trade Name: PAPAYA 3D Premium & PAPAYA 3D Premium Plus
  • 510(k) Number: K200469
  • Common Name: Computed Tomography X-ray System
  • Classification Name: Computed Tomography X-ray System
  • Classification panel: Radiology
  • Regulation number: 21 CFR 892.1750
  • Device Class: Class II
  • Primary Product code: OAS
  • Secondary product code: MUH

4. Predicate Device (Equivalent Legally Marketed Device)

PAPAYA 3D Plus (K150354, GENORAY Co., Ltd)

5. Description of the Device

The proposed device PAPAYA 3D Premium Plus the computed tomography x-ray system which consists of image acquisition modes; panorana, cephalometric, and computed tomography. The difference between PAPAYA 3D Premium Plus is only optional of the cephalometric detector. It designed for dental radiography of the oral and cranionarial as teeth, jaws and oral structures. The device with cephalometric detector is named PAPAYA 3D Premium Plus and the device without cephalometric detector is named PAPAYA 3D Premium.

The proposed device are composed of flat panel x-ray detectors which are based on CMOS, and TFT detector types and divided in to CT, panoramic and cephalometric radiography, and x-ay tube. CMOS, and TFT detectors are used to capture scamed image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D the anatomic stuctures by acquiring 3609rotational image sequences of oral and craniofacial area.

6. Indications for use (intended use)

The X-ray unit system is a dagnostic maging system which consists of multiple mage acquisition modes; panorams, cephalometric, and CBCT (Cone Beam Computed Tomography). X-ray unit system is used for dental radiographic examination and diagnosis of teeth, aw, oral stuctures and skull. The device is to be operated and used by dentists and other legally qualified professionals.

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7. Substantial equivalence chart

CriteriaProposed DevicePredicate Device
NamePAPAYA 3D Premium &
PAPAYA 3D Premium PlusPAPAYA 3D Plus
ManufacturerGENORAY Co., Ltd.GENORAY Co., Ltd.
510(k) No.K200469K150354
FigureImage: PAPAYA 3D Plus
Indications
for useThe X-ray unit system is a diagnostic imaging system which consists of
multiple image acquisition modes; panoramic, cephalometric, and CBCT
(Cone Beam Computed Tomography). X-ray unit system is used for dental
radiographic examination and diagnosis of teeth, jaw, oral structures and
skull. The device is to be operated and used by dentists and other legally
qualified professionals.PAPAYA 3D Plus is a digital panoramic, cephalometric and tomographic
extra-oral X-ray system,
indicated for use in:
(i) Producing panoramic X-ray images of the maxillofacial area, for
diagnostic examination of dentition (teeth), jaws and oral structures; and
(ii) Producing radiographs of jaws, parts of the skull and carpus for the
purpose of cephalometric examination, when equipped with the
cephalometric arm;
(iii) Producing tomographic images of the oral and maxillofacial structure,
for diagnostic examination of dentition (teeth), jaws, oral structures and
some cranial bones if equipped with CBCT option.
The system accomplishes tomographic exam by acquiring a 360-degree
rotational X-ray sequence of images and reconstructing a three-dimensional
matrix of the examined volume, producing two-dimensional views of this
volume and displaying both two dimensional images and three-dimensional
renderings
Performance SpecificationPanoramicPanoramic
CephalometricPanoramic
Cephalometric
Computed tomographyComputed tomographyComputed tomography
Input Voltage100-240 V~, 50/60Hz100-240 V~, 50/60Hz100-120 V~, 50/60Hz
Tube Voltage60-90 kV60-90 kV60-90 kV
Tube Current4-12 mA4-12 mA4-12 mA
Focal Spot Size0.5 mm0.5 mm0.5 mm
Exposure TimePanorama: max 17 sec.
CBCT: max 24secPanorama: max 17 sec.
Cephalometric: max 15.5 sec.
CBCT: max. 24secPanorama: max 17sec.
Cephalometric: max 12sec.
CBCT: max. 15sec.
Image ReceptorPanoramic image receptor:
  • Extor-P (K150354)
    CBCT image receptor:
  • DualRay-S (K150354)
  • FXDD-0606CA (K182805)
  • FXDD-0909GA | Panoramic image receptor:
  • Extor-P (K150354)
    Cephalometric image receptors:
  • Extor-C (K150354)
  • FXDD-1012CA
    CBCT image receptors:
  • DualRay-S (K150354)
  • FXDD-0606CA (K182805)
  • FXDD-0909GA | Panoramic image receptor:
  • Extor-P
    Cephalometric image receptor:
  • Extor-C
    CBCT image receptor:
  • DualRay-S |
    | Image processing Software | Triana (K103182), Theia (optional) | Triana (K103182), Theia (optional) | Triana (K103182) |
    | Result | The proposed device, PAPAYA 3D Premium & PAPAYA 3D Premium Plus, was developed from the predicate device PAPAYA 3D Plus (K150354), and
    modifications are changing of input power, addition of detector, addition of image processing software, and minor external design changes. Accordingly, the
    characteristics of the proposed device is identical or similar to those of the predicate device regarding X-ray generation device characteristics including tube
    voltage, tube current, focal spot size.
    First of all, the input voltage (power rating) of Predicate device was 100-120V~, 50/60Hz, however due to changes of the power board, proposed device is
    available to 100-240V~, 50/60Hz.
    Second, the proposed device has same detector with predicate device which are DualRay-S (CT detector), Extor-C (cephalometric detector), Extor-P
    (panoramic detector), and additionally proposed device has FXDD-1012CA (cephalometric detector), FXDD-0606CA (CT detector), and FXDD-0909GA (CT
    detector). However cephalometric detectors (Extor-C, and FXDD-0909GA) are only available for PAPAYA 3D Plus and PAPAYA 3D premium Plus. Overall
    PAPAYA 3D Premium has one option for panoramic detector, and three types of CT detectors and PAPAYA 3D Premium Plus has one option for panoramic
    detector, two options for cephalometric detectors, and three types of CT detectors. Additionally, the FXDD-0606CA detector has been cleared under K182805,
    RCT800.
    Third, the predicate device can be used with image processing software, Triana, only. The proposed device can be used with same software, Triana, or newly
    developed image processing software, Theia. The difference between Triana and Theia is only UI, and the Theia was developed for marketing purpose only.
    Theia was validated throughout EN 62304:2006/AC: 2008.
    Fourth, the minor external design of the proposed device has changed comparing predicate device. The patient supporting area can be foldable, the emergency
    switch on the patient supporting area has been moved from downside to upside, the storage box has been added, and the plastic enclosure design has changed. | | |

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8. Safety, EMC and Performance data comparison to Predicate

Since electrical and mechanice of the proposed device las changed, such as input voltage, additional detector options, additional inage processing software option, external design, companing to predicate device the safety and EMC test was performed throughout IEC 60601-1, IEC 60601-1-3, IEC 60601-1-6, IEC 60601-2-63, and IEC 60601-1-2 to minimize electrical, mechanical and radiation hazards

For the additional software, Theia, saves the patient inage data and offers an inquiry function in addition, supports the mage processing finction intended to obtain images by using the PAPAYA 3D Premium Plus and detector options for dagnosis. And has been validated according to NEMA PS 3.1-3.20. DICOM, FDA Guidance "Guidance for the Content of Premarket Submissions for Software Contained in Medical devices". FDA Guidance "Guidance for the content of premarket submissions for management of cyber security" to ensure substantial equivalence. The software, Theia, was consider level of concern, since a failure or latent flaw in the software would not directly result in serious injury or death to the patient or operator.

For the newly added CBCT image receptor (FXDD-0909GA), and Cephalometric mage receptor (FXDD-1012CA) it has been validated according to FDA "Gudance for the submission of 510(k)'s for Solid State X-ray Imaging Devices" as clinical considerations, and the climcal images were evaluated by the US board-certified oral surgeon. Throughout the evaluation by oral surgeon, the proposed device with newly added detectors are well enough to diagnosable and meet its indications for use.

Furthernore, the imaging performance of newly added CBCT image receptor (FXDD-0909GA) such as ganty positioning accuracy, In-plane uniformity, Spatial Resolution section thickness, Nose, Contrast to Noise Rato, Geometric Distortion, and Metal Artifacts and Cephalometric image receptor (FXDD-1012CA) such as Line pair resolution was tested with phantoms to validate its performance. The detail information about the clinical image evaluation can be found in the "Attachment X Evaluation of PAPAYA 3D Premium & PAPAYA 3D Premium Plus mages" and the imaging performance test report can be found in the "Attachment IX Solid State X-ray Imaging Device".

Overall the modifications from the predicate device were completed in accordance GENORAY management system design controls. A risk analysis, validation testing and Declaration of Controls were submitted to support the substantial equivalence of the modified proposed device. The results of them indicate that the modified proposed device is as safe and effective as the predicate devices.

9. Conclusion

Proposed device has the same indication for use as the predicate device have been no changes that impact ether the findamental technology or the indications for use. The proposed device with modifications outlined in this Premarket Notification is substantally equivalent to the currently commercially available predicate device.