(118 days)
No
The provided text describes standard medical imaging processing and analysis tools, such as MPR, volume rendering, segmentation, and fusion. It does not mention any AI or ML techniques being used. The "Mentions AI, DNN, or ML" section in the input seems to be from a different document or a misinterpretation, as it is not present in the provided text.
No
The device is medical imaging software intended to aid medical professionals in reading, interpreting, and treatment planning by processing and analyzing medical images. It does not directly provide therapy or therapeutic benefit to a patient.
Yes
The "Intended Use / Indications for Use" section states that the software is "intended to provide trained medical professionals with tools to aid them in reading, interpreting, and treatment planning," and accepts medical images for these purposes. While it explicitly states "This product is not intended for use with or for the primary diagnostic interpretation of Mammography images," it generally aids in the interpretation of various other medical images, which is a diagnostic function.
Yes
The device is described as "medical application software running on Windows server/client configuration installed on commercial general-purpose Windows-compatible computers." It explicitly states it is software and does not mention any proprietary hardware components required for its function beyond standard computing infrastructure.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use clearly states that the software is for "reading, interpreting, and treatment planning" using medical images acquired from various imaging devices. This is focused on the analysis and visualization of images generated by the patient's body through imaging modalities, not on analyzing samples taken from the patient's body (like blood, urine, tissue, etc.).
- Device Description: The device description reinforces this by explaining how it connects to imaging devices and PACS systems to retrieve and process image data.
- Lack of IVD Characteristics: There is no mention of analyzing biological samples, reagents, or any of the typical components associated with in vitro diagnostics.
IVD devices are specifically designed to perform tests on specimens taken from the human body to provide information for diagnosis, monitoring, or screening. This software operates on medical images, which are a different type of data.
N/A
Intended Use / Indications for Use
Synapse 3D Base Tools is medical imaging software that is intended to provide trained medical professionals with tools to aid them in reading, interpreting, and treatment planning. Synapse 3D Base Tools accepts DICOM compliant medical images acquired from a variety of imaging devices including, CT, MR, CR, NM, PT, and XA, etc.
This product is not intended for use with or for the primary diagnostic interpretation of Mammography images. Synapse 3D Base Tools provides several levels of tools to the user:
Basic imaging tools for general images, including 2D viewing, volume rendering and 3D volume viewing, orthogonal / oblique / curved Multi-Planar Reconstructions (MPR), Average (RaySum) and Minimum (MinIP) Intensity Projection. 4D volume viewing, image subtraction, surface rendering, sector and rectangular shape MPR image viewing, MPR for dental images, creating and displaying multiple MPR images along an object, time-density distribution, basic image processing, CINE, measurements, annotations, reporting, storing, distribution, and general image management and administration tools, etc.
-Tools for regional segmentation of anatomical structures within the image data, path definition through vascular and other tubular structures, and boundary detection.
-Image viewing tools for modality specific images, including CT PET fusion and ADC image viewing for MR studies. -Imaging tools for CT images including virtual endoscopic viewing.
-Imaging tools for MR images including delayed enhancement image viewing, diffusion-weighted MRI data analysis.
Product codes (comma separated list FDA assigned to the subject device)
LLZ
Device Description
Synapse 3D Base Tools (V6.1) (this submission) is updated software of previously-cleared Synapse 3D Base Tools (V3.0) (cleared by CDRH via K120361 on 04/06/2012).
The 3D image analysis software Synapse 3D Base Tools (V6.1) is medical application software running on Windows server/client configuration installed on commercial general-purpose Windows-compatible computers. It offers software tools which can be used by trained professionals to interpret medical images obtained from various medical devices, to create reports, or to develop treatment plans.
Synapse 3D Base Tools is connected through DICOM standard to medical devices such as CT, MR, CR, US, NM, PT, XA, etc. and to a PACS system storing data generated by these medical devices, and it retrieves image data via network communications based on the DICOM standard. The retrieved image data are stored on the local disk managed by Synapse 3D Base Tools (V6.1), and the associated image-related information of the image data is registered in its database and is used for display, image processing, analysis, etc. Images newly created by Synapse 3D Base Tools (V6.1) not only can be displayed on a display, but also can be printed on a hardcopy using a DICOM printer or a Windows printer.
Synapse 3D Base Tools (V6.1) is a basic software module that works with other cleared clinical applications, including Synapse 3D Cardiac Tools (K200973), Synapse 3D Perfusion Analysis (K162287), Synapse 3D Lung and Abdomen Analysis (K130542), Synapse 3D Liver and Kidney Analysis (K142521), Synapse 3D Nodule Analysis (K120679), Synapse 3D Colon Analysis (K123566), Synapse 3D Tensor Analysis (K141514) and Synapse 3D Blood Flow Analysis (K191544). All these software modules consist of the Synapse 3D product family.
Synapse 3D Base Tools can be integrated with Fujifilm's Synapse PACS, and can be used as a part of a Synapse system. Synapse 3D Base Tools also can be integrated with Fujifilm's Synapse Cardiovascular for cardiology purposes.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Yes
Input Imaging Modality
DICOM compliant medical images acquired from a variety of imaging devices including, CT, MR, CR, US, NM, PT, and XA, etc.
Anatomical Site
Not Found
Indicated Patient Age Range
Not Found
Intended User / Care Setting
trained medical 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 (study type, sample size, AUC, MRMC, standalone performance, key results)
Nonclinical testing result:
The purpose of Software Development Process for Synapse 3D Bae Tools is to carry out the activities relating to the establishment of the software development plan (or plans) for definitely conducting software hazard analysis, risk management, requirement analysis, architectural design, the design specification, unit implementation and verification, software integration and integration testing, software system test, software release, software maintenance. The main activities in software development process are described as follows.
- Software development plan
- Software hazard analysis and risk management
- Software requirements analysis/specification
- Software architectural design
- Software detailed design specification
- Software unit module implementation and verification
- Software integration and system testing
Clinical tests:
The subject of this 510(k) notification, Synapse 3D Base Tools does not require clinical studies to support safety and effectiveness of the software.
Verification and Validation:
Testing for verification and validation involved system level functionality test, component testing, verification testing, integration testing, usability testing, installation/upgrade testing, labeling testing, as well as the testing for risk mitigations associated with the risk management process. In addition, benchmark performance testing was conducted using actual clinical images to help demonstrate that the semi-automatic or automatic segmentation, detection, and registration functions implemented in Synapse 3D Base Tools achieved the expected accuracy performance. Pass/Fail criteria were based on the requirements and intended use of the product. Test results showed that all tests passed successfully according to the design specifications. All of the different components of the Synapse 3D Base Tools software have been stress tested to ensure that the system as a whole provides all the capabilities necessary to operate according to its intended use and in a manner substantially equivalent to the predicate devices.
Cybersecurity:
The confidentiality, integrity and availability are maintained by Synapse 3D Base Tools in accordance with Section 6 of the Content of Premarket Submissions for Management of Cybersecurity in Medical Devices; Guidance for Industry and Food and Drug Administration Staff (October 2, 2014).
Synapse 3D Base Tools is connected through DICOM standard to medical devices and to a PACS system storing data generated by these medical devices, and it retrieves image data via network communication based on the DICOM standard. Therefore Synapse 3D Base Tools assures an adequate degree of protection for cybersecurity.
Performance standards:
- Digital Imaging and Communications in Medicine (DICOM) Set (PS 3.1 3.20) (2016).
- AAMI / ANSI / IEC 62304:2015, Medical Device Software Software Life Cycle Processes.
- ISO 14971 Second Edition 2007-03-01, Medical Devices Application of Risk Management to Medical Devices.
Conclusion:
Performance tests were conducted to test the functionality of the subject device, Synapse 3D Base Tools. Results of all conducted testing were acceptable in supporting the claim of substantial equivalence.
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.
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.
Not Found
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
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
0
February 9, 2021
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.
Fujifilm Corporation % Mr. Jeffrey Wan Senior Regulatory Affairs Specialist Fujifilm Medical Systems U.S.A., Inc. 81 Hartwell Avenue, Suite 300 LEXINGTON MA 02421
Re: K203103
Trade/Device Name: Synapse 3D, Synapse 3D Base Tools v6.1 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ Dated: December 14, 2020 Received: December 16, 2020
Dear Mr. Wan:
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
2
Indications for Use
510(k) Number (if known)
K203103
Device Name Synapse 3D, Synapse 3D Base Tools v6.1
Indications for Use (Describe)
Synapse 3D Base Tools is medical imaging software that is intended to provide trained medical professionals with tools to aid them in reading, interpreting, and treatment planning. Synapse 3D Base Tools accepts DICOM compliant medical images acquired from a variety of imaging devices including, CT, MR, CR, NM, PT, and XA, etc.
This product is not intended for use with or for the primary diagnostic interpretation of Mammography images. Synapse 3D Base Tools provides several levels of tools to the user:
Basic imaging tools for general images, including 2D viewing, volume rendering and 3D volume viewing, orthogonal / oblique / curved Multi-Planar Reconstructions (MPR), Average (RaySum) and Minimum (MinIP) Intensity Projection. 4D volume viewing, image subtraction, surface rendering, sector and rectangular shape MPR image viewing, MPR for dental images, creating and displaying multiple MPR images along an object, time-density distribution, basic image processing, CINE, measurements, annotations, reporting, storing, distribution, and general image management and administration tools, etc.
-Tools for regional segmentation of anatomical structures within the image data, path definition through vascular and other tubular structures, and boundary detection.
-Image viewing tools for modality specific images, including CT PET fusion and ADC image viewing for MR studies. -Imaging tools for CT images including virtual endoscopic viewing.
-Imaging tools for MR images including delayed enhancement image viewing, diffusion-weighted MRI data analysis.
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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3
Section 5
510(K) Summary
This Section contains:
510(k) Summary (per 21 CFR 807.92)
4
510(k) Summary
| Date Prepared: | Aug. 15, 2020 |
|---|---|
| Submitter's Information: | FUJIFILM Corporation |
| 26-30,NISHIAZABU 2-CHOME MINATO-KU | |
| TOKYO 106-8620 | |
| Telephone: (781) 323-5315 | |
| Contact: Tommy San | |
| Device Trade Name: | Synapse 3D, Synapse 3D Base Tools v6.1 |
| Device Common Names: | Picture Archiving and Communications System (PACS) |
| Device Clasification Name: | System, Image Processing, Radiological |
| Product Code: | LLZ |
| Regulation Number: | 21 CFR 892.2050 |
| Device Class: | Class II |
| Panel: | Radiology |
| Predicate Devices: | Synapse 3D Base Tools (K120361) |
| FUJIFILM Medical Systems U.S.A., Inc. |
5
1. Description of the Device
Synapse 3D Base Tools (V6.1) (this submission) is updated software of previously-cleared Synapse 3D Base Tools (V3.0) (cleared by CDRH via K120361 on 04/06/2012).
The 3D image analysis software Synapse 3D Base Tools (V6.1) is medical application software running on Windows server/client configuration installed on commercial general-purpose Windows-compatible computers. It offers software tools which can be used by trained professionals to interpret medical images obtained from various medical devices, to create reports, or to develop treatment plans.
Synapse 3D Base Tools is connected through DICOM standard to medical devices such as CT, MR, CR, US, NM, PT, XA, etc. and to a PACS system storing data generated by these medical devices, and it retrieves image data via network communications based on the DICOM standard. The retrieved image data are stored on the local disk managed by Synapse 3D Base Tools (V6.1), and the associated image-related information of the image data is registered in its database and is used for display, image processing, analysis, etc. Images newly created by Synapse 3D Base Tools (V6.1) not only can be displayed on a display, but also can be printed on a hardcopy using a DICOM printer or a Windows printer.
Synapse 3D Base Tools (V6.1) is a basic software module that works with other cleared clinical applications, including Synapse 3D Cardiac Tools (K200973), Synapse 3D Perfusion Analysis (K162287), Synapse 3D Lung and Abdomen Analysis (K130542), Synapse 3D Liver and Kidney Analysis (K142521), Synapse 3D Nodule Analysis (K120679), Synapse 3D Colon Analysis (K123566), Synapse 3D Tensor Analysis (K141514) and Synapse 3D Blood Flow Analysis (K191544). All these software modules consist of the Synapse 3D product family.
Synapse 3D Base Tools can be integrated with Fujifilm's Synapse PACS, and can be used as a part of a Synapse system. Synapse 3D Base Tools also can be integrated with Fujifilm's Synapse Cardiovascular for cardiology purposes.
6
2. Indications for Use
Synapse 3D Base Tools is medical imaging software that is intended to provide trained medical professionals with tools to aid them in reading, interpreting, reporting, and treatment planning. Synapse 3D Base Tools accepts DICOM compliant medical images acquired from a variety of imaging devices including, CT, MR, CR, US, NM, PT, and XA, etc.
This product is not intended for use with or for the primary diagnostic interpretation of Mammography images.
Synapse 3D Base Tools provides several levels of tools to the user:
Basic imaging tools for general images, including 2D viewing, volume rendering and 3D volume viewing, orthogonal / oblique / curved Multi-Planar Reconstructions (MPR), Maximum (MIP), Average (RaySum) and Minimum (MinIP) Intensity Projection, 4D volume viewing, image fusion, image subtraction, surface rendering, sector and rectangular shape MPR image viewing, MPR for dental images, creating and displaying multiple MPR images along an object, time-density distribution, basic image processing, CINE, measurements, annotations, reporting, printing, storing, distribution, and general image management and administration tools, etc.
-
Tools for regional segmentation of anatomical structures within the image data, path definition through vascular and other tubular structures, and boundary detection.
-
Image viewing tools for modality specific images, including CT PET fusion and ADC image viewing for MR studies.
-
Imaging tools for CT images including virtual endoscopic viewing.
-
Imaging tools for MR images including delayed enhancement image viewing, diffusion-weighted MRI data analysis.
3. Substantial Equivalence Comparison
Synapse 3D Base Tools has the same intended use, similar labeling, and clinical application tools as those of the cleared predicate device Synapse 3D Base Tools (K120361). The device features and technical characteristics comparison with predicates is shown as Table 1 Device Features and Technical Characteristics Comparison Matrix.
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| Device Parameters | Synapse 3D Base Tools
(V6.1)
(This submission) | Synapse 3D Base
Tools(V3.0)
(K120361)
(Primary predicate
device) |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------|
| Basic features and basic imaging tools | | |
| 2D Viewing | Yes | Yes |
| Image Storing (DICOM
SCP) | Yes | Yes |
| Image Communication
(DICOM SCU) | Yes | Yes |
| DICOM Interface
(SCP/SCU) | Yes | Yes |
| Printing (DICOM SCU) | Yes | Yes |
| Measurements (2D and
3D) | Yes | Yes |
| Annotations -
Standardized and Free
Text | Yes | Yes |
| Reporting | Yes | Yes |
| Cine | Yes | Yes |
| Volume Rendering and
3D Viewing | Yes | Yes |
| MPR
• orthogonal / oblique /
curved Multi-Planar
Reconstructions (MPR),
• Sector and rectangular
shape MPR image
viewing
• MPR for dental images
• Multiple MPR images
along an object (Slicer) | Yes | Yes |
| Maximum, Average,
Minimum Intensity | Yes | Yes |
| Device Parameters | Synapse 3D Base Tools (V6.1) (This submission) | Synapse 3D Base Tools(V3.0) (K120361) (Primary predicate device) |
| Projection | | |
| 4D viewing | Yes | Yes |
| Image fusion | Yes | Yes |
| Surface rendering | Yes | Yes |
| Image subtraction (3D) | Yes | Yes |
| Time-density distribution | Yes | Yes |
| General image data management and administration tools | Yes | Yes |
| In-depth analysis tools | | |
| Segmentation | Yes (Some segmentation applications are implemented using a deep learning method called as “Fully Convolutional Network”) | Yes |
| Path definition | Yes | Yes |
| Boundary detection | Yes | Yes |
| Modality specific imaging tools | | |
| CT PET fusion | Yes | Yes |
| ADC image viewing (MRI) | Yes | Yes |
| Virtual Endoscopic Simulator | Yes | N/A |
| Diffusion-weighted MRI Data Analysis | Yes | N/A |
| Delayed Enhancement Image Viewing | Yes | N/A |
| Product characteristics | | |
| Device Parameters | Synapse 3D Base Tools
(V6.1)
(This submission) | Synapse 3D Base
Tools(V3.0)
(K120361)
(Primary predicate
device) |
| Product Availability | Software Product | Software Product |
| Hardware Platform | Windows PC | Windows PC |
Table 1 Device Features and Technical Characteristics Comparison Matrix
8
9
The main differences as in-depth analysis tools are shown as follows.
-
- The new segmentation features implemented using an algorithm "graph cuts" same as the algorithm used in our previously cleared Synapse 3D Basic Tools (K120361).
-
- The old segmentation features that had existed in our previously cleared Synapse 3D Basic Tools (K120361) are implemented using a new algorithm called as "Fully Convolutional Network" - a new deep learning-based algorithm.
-
- The new segmentation features are implemented using a new algorithm called as "Fully Convolutional Network" - a new deep learning-based algorithm.
The main differences presented as new features of modality specific imaging tools are shown as follows.
-
- Virtual Endoscopic Simulator (CT).
-
- Diffusion-weighted MRI Data Analysis (MRI).
-
- Delayed Enhancement Image Viewing (MRI).
4. Safety Information
Synapse 3D Base Tools introduces no new safety or efficacy issues other than those already indentified with the predicate devices. The Risk Management and the results of the Hazard Analysis combined with the appropriate preventive measures taken indicate that the device is of moderate concern as per the May 11, 2005 issue of the "Guidance for the Content of Premarket Submission for Software Contained in Medical Devices." The Synapse 3D Base Tools labeling contains instructions for use and necessary cautions, warnings and notes to provide the safe and effective use of the device.
5. Testing and Performance Information
Nonclinical testing result:
The purpose of Software Development Process for Synapse 3D Bae Tools is to carry out the activities relating to the establishment of the software development plan (or plans) for definitely conducting software hazard analysis, risk management, requirement analysis, architectural design, the design specification, unit implementation and verification, software integration and integration testing, software system test, software release, software maintenance. The main activities in software development process are described as follows.
10
- Software development plan ●
- Software hazard analysis and risk management
- Software requirements analysis/specification ●
- Software architectural design ●
- Software detailed design specification
- Software unit module implementation and verification ●
- Software integration and system testing ●
Clinical tests:
The subject of this 510(k) notification, Synapse 3D Base Tools does not require clinical studies to support safety and effectiveness of the software.
Verification and Validation:
Testing for verification and validation involved system level functionality test, component testing, verification testing, integration testing, usability testing, installation/upgrade testing, labeling testing, as well as the testing for risk mitigations associated with the risk management process. In addition, benchmark performance testing was conducted using actual clinical images to help demonstrate that the semi-automatic or automatic segmentation, detection, and registration functions implemented in Synapse 3D Base Tools achieved the expected accuracy performance. Pass/Fail criteria were based on the requirements and intended use of the product. Test results showed that all tests passed successfully according to the design specifications. All of the different components of the Synapse 3D Base Tools software have been stress tested to ensure that the system as a whole provides all the capabilities necessary to operate according to its intended use and in a manner substantially equivalent to the predicate devices.
Cybersecurity:
The confidentiality, integrity and availability are maintained by Synapse 3D Base Tools in accordance with Section 6 of the Content of Premarket Submissions for Management of Cybersecurity in Medical Devices; Guidance for Industry and Food and Drug Administration Staff (October 2, 2014).
Synapse 3D Base Tools is connected through DICOM standard to medical devices and to a PACS system storing data generated by these medical devices, and it retrieves image data via network communication based on the DICOM standard. Therefore Synapse 3D Base Tools assures an adequate degree of protection for cybersecurity.
Performance standards:
- Digital Imaging and Communications in Medicine (DICOM) Set (PS 3.1 3.20) (2016). .
- AAMI / ANSI / IEC 62304:2015, Medical Device Software Software Life Cycle Processes.
- • ISO 14971 Second Edition 2007-03-01, Medical Devices Application of Risk Management to Medical Devices.
11
6. Conclusion
Performance tests were conducted to test the functionality of the subject device, Synapse 3D Base Tools. Results of all conducted testing were acceptable in supporting the claim of substantial equivalence.