K Number
K203610
Device Name
Automatic Anatomy Recognition (AAR)
Date Cleared
2021-04-20

(131 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Automatic Anatomy Recognition (AAR) is a software-only medical device intended for use by technicians and trained physicians to derive contours of anatomical structures from computed tomography studies for input to a radiation treatment planning system. It is only intended to work for anatomical structures in the head & neck and thoracic body regions. It is not for use on patients below 18 years of age and it relies on third party treatment planning systems to display and edit the contours.
Device Description
Automatic Anatomy Recognition product for radiation therapy planning (AAR) is a software-only medical device and is deployed on a cloud-based platform. AAR is intended to be used on adults undergoing treatment that requires the identification of anatomical structures in the body considered to be "organs at risk" (OAR). AAR is intended to be used in the head and thoracic body regions. AAR automatically processes computed tomography (CT) studies and produces contours with no human intervention. AAR does not provide the capability to modify contours. If adjustments are required, they must be performed on another system.
More Information

Not Found

Yes
The document explicitly states that the software implements "artificial intelligence (AI) including non-adaptive machine learning algorithms".

No.
This device is a software tool used in radiation treatment planning to identify anatomical structures. It does not directly treat or diagnose a disease.

No

The device is intended to derive contours of anatomical structures for input to a radiation treatment planning system. It processes CT studies to identify "organs at risk" (OAR) for radiation therapy. This function is for planning treatment, not for diagnosing a disease or condition.

Yes

The device description explicitly states "Automatic Anatomy Recognition product for radiation therapy planning (AAR) is a software-only medical device". The description of its function and deployment on a cloud-based platform further supports this. While it processes CT studies and outputs contours for use in other systems, it does not include any hardware components.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to provide information for diagnosis, monitoring, or screening.
  • Device Function: The described device, Automatic Anatomy Recognition (AAR), is a software-only medical device that processes computed tomography (CT) studies (medical images) to derive contours of anatomical structures. It does not analyze biological samples from the body.
  • Intended Use: The intended use is for radiation treatment planning, specifically to identify "organs at risk" (OAR) from CT images. This is a process that occurs after a diagnosis has been made and is part of the treatment planning workflow, not the diagnostic process itself.

The device falls under the category of radiological image processing software, which is distinct from in vitro diagnostics.

No
The letter does not state that the FDA has reviewed and approved or cleared a Predetermined Change Control Plan (PCCP) for this specific device.

Intended Use / Indications for Use

Automatic Anatomy Recognition (AAR) is a software-only medical device intended for use by technicians and trained physicians to derive contours of anatomical structures from computed tomography studies for input to a radiation treatment planning system. It is only intended to work for anatomical structures in the head & neck and thoracic body regions. It is not for use on patients below 18 years of age and it relies on third party treatment planning systems to display and edit the contours.

Product codes

QKB

Device Description

Automatic Anatomy Recognition product for radiation therapy planning (AAR) is a software-only medical device and is deployed on a cloud-based platform. AAR is intended to be used on adults undergoing treatment that requires the identification of anatomical structures in the body considered to be "organs at risk" (OAR). AAR is intended to be used in the head and thoracic body regions.

AAR operates independently from the treatment plan that is subsequently created based on AARgenerated contours. Therefore, AAR is agnostic to the method of radiation treatment delivery such as photons, protons, or other, to the modality of radiation treatment such as three-dimensional conformal radiation therapy (3D-CRT), intensity modulated radiation therapy (IMRT), or other, and to the intent of radiation treatment such as definitive (curative), neoadjuvant, adjuvant, or palliative.

AAR is also agnostic to the disease process being treated in the head and neck or thoracic body regions, For example, the identification of OARs is required during the treatment of head and neck cancers such as squamous cell carcinoma, brain cancer, and lymphoma. The identification of OARs is also required during the treatment of thoracic cancers such as lung cancer, breast cancer, esophageal cancer, lymphoma, and thymoma, just to name a few.

AAR automatically processes computed tomography (CT) studies and produces contours with no human intervention. AAR does not provide the capability to modify contours. If adjustments are required, they must be performed on another system.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Yes

Input Imaging Modality

Computed Tomography

Anatomical Site

Head & neck, thoracic body regions

Indicated Patient Age Range

Not for use on patients below 18 years of age (i.e. 18 years of age and older)

Intended User / Care Setting

Technicians and trained physicians

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)

Segmentation Performance Test: Evaluated automated segmentation accuracy non-inferiority using DICE similarity coefficients. Software Verification and Validation testing.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K191928

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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).

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Image /page/0/Picture/10 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a seal on the left and the FDA acronym with the full name of the agency on the right. The seal features an eagle with its wings spread, surrounded by text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA". The right side of the logo displays the acronym "FDA" in blue, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in a larger, bolder font, also in blue.

Quantitative Radiology Solutions, LLC % Mary Vater 510(k) Consultant Medical Device Academy 345 Lincoln Hill Rd. SHREWSBURY, VT 05738

Re: K203610

Trade/Device Name: Automatic Anatomy Recognition (AAR) Regulation Number: 21 CFR 892.2050 Regulation Name: Picture Archiving And Communications System Regulatory Class: Class II Product Code: QKB Dated: March 22, 2021 Received: March 23, 2021

Dear Mary Vater:

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

April 20, 2021

1

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-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) K203610

Device Name Automatic Anatomy Recognition System

Indications for Use (Describe)

Automatic Anatomy Recognition (AAR) is a software-only medical device intended for use by technicians and trained physicians to derive contours of anatomical structures from computed tomography studies for input to a radiation treatment planning system. It is only intended to work for anatomical structures in the head & neck and thoracic body regions. It is not for use on patients below 18 years of age and it relies on third party treatment planning systems to display and edit the contours.

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

This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of 21 CFR §807.92:

  1. SUBMITTER Quantitative Radiology Solutions, LLC 3675 Market Street, Suite 200 Philadelphia, PA 19104 | USA Tel: +1.973.590.8574

Contact Person: Steve Owens Date Prepared: December 9, 2020

II. DEVICE
Name of Device:Automatic Anatomy Recognition
Classification Name:Picture Archiving And Communications System
Regulation:21 CFR §892.2050
Regulatory Class:Class II
Product Classification Code:QKB

Ⅲ. PREDICATE DEVICE

Predicate Manufacturer:Xiamen Manteia Technology LTD.
Predicate Trade Name:AccuContour™
Predicate 510(k):K191928

No reference devices were used in this submission.

IV. DEVICE DESCRIPTION

...

Automatic Anatomy Recognition product for radiation therapy planning (AAR) is a software-only medical device and is deployed on a cloud-based platform. AAR is intended to be used on adults undergoing treatment that requires the identification of anatomical structures in the body considered to be "organs at risk" (OAR). AAR is intended to be used in the head and thoracic body regions.

AAR operates independently from the treatment plan that is subsequently created based on AARgenerated contours. Therefore, AAR is agnostic to the method of radiation treatment delivery such as photons, protons, or other, to the modality of radiation treatment such as three-dimensional conformal radiation therapy (3D-CRT), intensity modulated radiation therapy (IMRT), or other, and to the intent of radiation treatment such as definitive (curative), neoadjuvant, adjuvant, or palliative.

AAR is also agnostic to the disease process being treated in the head and neck or thoracic body regions, For example, the identification of OARs is required during the treatment of head and neck cancers such as squamous cell carcinoma, brain cancer, and lymphoma. The identification of OARs is also required during the treatment of thoracic cancers such as lung cancer, breast cancer, esophageal cancer, lymphoma, and thymoma, just to name a few.

AAR automatically processes computed tomography (CT) studies and produces contours with no human intervention. AAR does not provide the capability to modify contours. If adjustments are required, they must be performed on another system.

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V. INDICATIONS FOR USE

Automatic Anatomy Recognition (AAR) is a software-only medical device intended for use by technicians and trained physicians to derive contours of anatomical structures from computed tomography studies for input to a radiation treatment planning system. It is only intended to work for anatomical structures in the head & neck and thoracic body regions. It is not for use on patients below 18 years of age and it relies on third party treatment planning systems to display and edit the contours.

COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE VI. PREDICATE DEVCE

The following characteristics were compared between the subject device and the predicate device in order to demonstrate substantial equivalence:

  • Indications for Use The predicate and subject device have identical indications for use. .
  • . Materials - The predicate and subject device are both software-only medical devices.
  • Design The predicate and subject device both utilize deep learning contouring to . automatically contour the organ-at-risk for the head, neck, and thorax.
  • . Energy Source - The predicate and subject device both run within the users' existing computer system.
  • Other Design Features The predicate device has additional features such as patient . management, review of processed images, automatic image registration, manual contouring functionality, and segmentation in the abdomen and pelvic regions. This additional functionality is not required to achieve the intended use for the subject device.
  • . Performance Testing - The predicate and subject device conducted segmentation performance tests to evaluate the automated segmentation accuracy using DICE similarity coefficients. These tests were further supported by additional tests using a mean 95% Hausdorff Distance (HD) calculation.
Table 1: Proposed Predicate Device
Subject DeviceProposed Predicate DeviceRationale for SE
Device NameAutomatic Anatomy Recognition
(AAR)AccuContourTMN/A
ApplicantQuantitative Radiology SolutionsXiamen Manteia Technology LTD.N/A
510(k) NumberTBDK191928N/A
Decision DateTBD02/28/2020N/A
Regulation
Number892.2050892.2050Same
Regulation NamePicture archiving and
communication systemPicture archiving and communication
systemSame
DeviceRadiological Image Processing
Software for Radiation TherapyRadiological Image Processing
Software for Radiation TherapySame
Regulatory
DefinitionTo provide semi-automatic-or fully-
automated radiological image
process and analysis tools for
radiation therapy. Software
implementing artificial intelligence
(AI) including non-adaptive
machine learning algorithms trained
with clinical and/or artificial
radiological images. In these
devices, the algorithm training
images typically impact device.To provide semi-automatic or fully-
automated radiological image
process and analysis tools for
radiation therapy. Software
implementing artificial intelligence
(AI) including non-adaptive machine
learning algorithms trained with
clinical and/or artificial radiological
images. In these devices, the
algorithm training images typically
impact device performance. AI basedBoth the subject
device and the
predicate fall under
the regulatory
definition for
892.2050, product
code QKB.
Product Code
performance. AI based radiological
image processing software is
intended to be used in the workflow
of radiation therapy. Adaptive AI
algorithms are not within the scope
of this product code. Primary
radiation dose calculation or plan
optimization for treatment planning
are not within scope of the product
code.radiological image processing
software is intended to be used in the
workflow of radiation therapy.
Adaptive AI algorithms are not
within the scope of this product code.
Primary radiation dose calculation or
plan optimization for treatment
planning are not within scope of the
product code.
Product CodeQKBQKBSame
ClassificationClass IIClass IISame
510(k) Review
PanelRadiologyRadiologySame
Combination
Product?NoNoSame
Rx or OTC?RXRXSame
Intended Use /
Indications for UseAutomatic Anatomy Recognition
(AAR) is a software-only medical
device intended for use by
technicians and trained physicians
to derive contours of anatomical
structures from computed
tomography studies for input to a
radiation treatment planning system.
It is only intended to work for
anatomical structures in the head &
neck and thoracic body regions. It is
not for use on patients below 18
years of age and it relies on third
party treatment planning systems to
display and edit the contours.It is used by radiation oncology
department to register multimodality
images and segment (non-contrast)
CT images, to generate needed
information for treating planning,
treatment evaluation and treatment
adaptation.Same
Image process
functions1) Deep learning contouring: it
can automatically contour
anatomical structures, including
head and neck, thorax (for both
male and female).1) Deep learning contouring: it can
automatically contour the organ-
at-risk, including head and neck,
thorax, abdomen and pelvis (for
both male and female);
  1. Automatic Registration, and
  2. Manual Contour | Same. AAR contains
    only Deep Learning
    contouring |
    | General
    Functionalities | Receive, add/edit/delete,
    transmit, input/export, medical
    images and DICOM data | Receive, add/edit/delete,
    transmit, input/export, medical
    images and DICOM data;Patient management;Review of processed images;Open and Save of files. | Same. AAR only
    receives,
    adds/edits/deletes,
    transmits,
    inputs/exports
    medical images and
    DICOM data |
    | Operating Systems | Linux | Windows | QRS utilizes Linux as
    this OS is more
    secure as compared
    to Windows |
    | Segmentation Features | | | |
    | Algorithm | Deep Learning | Deep Learning | Same |
    | Compatible
    Modality | Non-Contrast CT | Non-Contrast CT | Same |
    | Compatible
    Scanner Models | No limitation on scanner model,
    DICOM 3.0 compliance required | No limitation on scanner model,
    DICOM 3.0 compliance required | Same |
    | Compatible
    Treatment
    Planning System | No limitation on TPS model,
    DICOM 3.0 compliance required. | No limitation on TPS model, DICOM
    3.0 compliance required. | Same |
    | Contraindications | AAR is not intended for use on
    patients below 18 years of age; | None | AAR is intended for
    use in adults |
    | Segmentation Features | | | |
    | Performance
    Testing | Segmentation Performance Test
    Evaluated automated
    segmentation accuracy non-
    inferiority using DICE
    similarity coefficients. Software Verification and
    Validation testing | Segmentation Performance Test
    Evaluated automated
    segmentation accuracy non-
    inferiority using DICE similarity
    coefficients. Registration Performance Test | Segmentation
    Performance Testing
    is equivalent.
    Registration
    performance test is
    N/A because the
    subject device does
    not do registration. |

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VII. PERFORMANCE DATA

The following performance data were provided in support of the substantial equivalence determination.

Sterilization & Shelf-life Testing

Not Applicable (Standalone Software)

Biocompatibility Testing

Not Applicable (Standalone Software)

Electrical safety and electromagnetic compatibility (EMC)

Not Applicable (Passive Device)

Software Verification and Validation Testing

Software Verification and Validation Testing included testing at the unit, integration, and system level per IEC 62304 standard.

Mechanical and acoustic Testing

Not Applicable (Standalone Software)

Animal Study

Animal performance testing was not required to demonstrate safety and effectiveness of the device.

Human Clinical Performance Testing

Clinical testing was not required to demonstrate the safety and effectiveness of the device.

VIII. CONCLUSIONS

Based on the comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.