K Number
K220822
Device Name
3D-SHAPER
Date Cleared
2022-12-09

(263 days)

Product Code
Regulation Number
892.1170
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

3D-SHAPER uses data from conventional Dual Energy X-Ray Absorptiometry (DXA) scans to measure the distribution of bone mineral mass at specific cross sections of the hip and allows the physician to estimate structural properties of the hip, such as CSA, CSMI, Z, Buckling Ratio, cortical sBMD, trabecular vBMD and integral vBMD.

3D-SHAPER is indicated to be used by qualified medical professionals to assist healthcare professionals in the bone health evaluation & changes, and cannot fully substitute their clinical judgement.

Device Description

3D-SHAPER is a software reconstructing in 3D, the shape and bone mineral density from 2D DXA images. The software incorporates a DXA-based 3D reconstruction and measures the distribution of bone mineral mass at specific cross sections of the hip. It provides physicians with estimates of the structural properties of the hip, such as densities or geometrical parameters. The software is not suitable for use with paediatric patients or for subjects with hip prosthesis such as total hip replacement prosthesis, hip resurfacing prosthesis or an osteosynthesis system, since the software has not been tested against these conditions. 3D-SHAPER is indicated to be used by qualified medical professionals to assist healthcare professionals in the bone health evaluation & changes, and cannot fully substitute their clinical judgement.

The 3D-SHAPER® measurements include:

Cortical surface Bone Mineral Density (Cortical sBMD, mg/cm2)

Trabecular volumetric Bone Mineral Density (Trabecular vBMD, mg/cm³)

Integral volumetric Bone Mineral Density (Integral vBMD, mg/cm³), the integral compartment being the union of the cortical and trabecular compartments.

Hip structural measurements: Cross-Sectional Area (CSA, in cm²), Cross-Sectional Moment of Inertia (CSMI, in cm4), section modulus (Z, in cm3) and buckling Ratio (BR).

Cortical sBMD, trabecular VBMD and integral vBMD are calculated at the total femur. CSA, CSMI, Z and BR are calculated in cross-sections at the neck, intertrochanteric region and lower shaft.

AI/ML Overview

Here's a breakdown of the acceptance criteria and study information for the 3D-SHAPER device, based on the provided document:

1. Table of Acceptance Criteria and Reported Device Performance:

The document primarily focuses on demonstrating substantial equivalence to a predicate device through correlation studies rather than establishing absolute performance metrics against predefined acceptance criteria for each measurement. However, it does outline the type of performance expected in the "Performance Bench Testing" section.

Feature/MetricAcceptance Criteria (Implied by correlation values)Reported Device Performance (Correlation to QCT)
Integral vBMDVery strong correlation (r ≥ 0.9)r = 0.96
Cortical sBMDVery strong correlation (r ≥ 0.9)r = 0.95
Trabecular vBMDVery strong correlation (r ≥ 0.9)r = 0.93
CSAVery strong correlation (r ≥ 0.95)r ≥ 0.95
CSMIVery strong correlation (r ≥ 0.92)r ≥ 0.92
ZVery strong correlation (r ≥ 0.91)r ≥ 0.91
Buckling Ratio (BR)Strong correlation (r ≥ 0.7)r ≥ 0.71
Computing timeNot explicitly stated as a targetLower than 2 minutes and 30 seconds
Software convergenceNot explicitly stated as a targetSuperior to 95%

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

The document mentions two main studies:

  • Correlation Study with Predicate Device:
    • Sample Size: 740 men and women (94% women).
    • Data Provenance: Not explicitly stated (e.g., country of origin). The study is retrospective in the sense that existing DXA scans were analyzed by both the 3D-SHAPER and the predicate device.
  • Performance Bench Testing (Correlation to QCT):
    • Sample Size: Not explicitly stated for this particular correlation study with QCT. It refers to "subject-specific models of the femoral shape and measurements compared to Quantitative Computed Tomography (QCT)." This implies data from human subjects but the exact number isn't provided.
    • Data Provenance: Not explicitly stated. Likely retrospective, as it compares measurements to an established imaging modality (QCT).

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

  • Correlation Study with Predicate Device: Ground truth for this study was the measurements produced by the predicate device (Hologic Hip Structural Analysis software, K061561). No human experts were involved in establishing this specific ground truth; it relied on a previously cleared, validated software.
  • Performance Bench Testing (Correlation to QCT): Ground truth was established by Quantitative Computed Tomography (QCT) measurements. QCT is a quantitative imaging technique that provides volumetric bone mineral density and structural information. No human experts are described as manually establishing this ground truth; it's a direct comparison to QCT output.

4. Adjudication Method:

  • Correlation Study with Predicate Device: There was no adjudication method described. The study compared the output of the 3D-SHAPER software directly against the output of the predicate device.
  • Performance Bench Testing (Correlation to QCT): There was no adjudication method described. The study compared the output of the 3D-SHAPER software directly against QCT measurements.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The study described focuses on the comparison of the 3D-SHAPER software's measurements against a predicate software and against QCT, not on how human readers' performance improves with or without AI assistance.

6. Standalone Performance:

Yes, a standalone performance study (algorithm only without human-in-the-loop) was done. The document consistently describes the 3D-SHAPER software's ability to measure structural properties from DXA scans and correlates these measurements with a predicate device and QCT. This is considered standalone performance.

7. Type of Ground Truth Used:

  • Correlation Study with Predicate Device: The ground truth was the output of a legally marketed predicate device (Hologic Hip Structural Analysis software).
  • Performance Bench Testing (Correlation to QCT): The ground truth was Quantitative Computed Tomography (QCT) measurements.

8. Sample Size for the Training Set:

The document does not provide any information regarding the sample size used for the training set. It focuses on the validation of the device.

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

The document does not provide any information on how the ground truth for the training set was established, as the training process itself is not detailed.

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Image /page/0/Picture/0 description: The image shows 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 FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 9, 2022

3D-Shaper Medical S.L % Ludovic Humbert CEO C/ Paris 179. 2-2 Barcelona, Barcelona 08036 SPAIN

Re: K220822

Trade/Device Name: 3D-SHAPER Regulation Number: 21 CFR 892.1170 Regulation Name: Bone densitometer Regulatory Class: Class II Product Code: KGI Dated: November 4, 2022 Received: November 4, 2022

Dear Ludovic Humbert:

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

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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 medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

2022.12.09
11:14:59
Lu Jiang
-05'00'

Lu Jiang, Ph.D. Assistant Director Diagnostic X-ray Systems Team DHT8B: Division of Radiological Imaging Devices and Electronic Products OHT8: Office of 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) K220822

Device Name 3D-SHAPER

Indications for Use (Describe)

3D-SHAPER uses data from conventional Dual Energy X-Ray Absorptiometry (DXA) scans to measure the distribution of bone mineral mass at specific cross sections of the hip and allows the physician to estimate structural properties of the hip, such as CSA, CSMI, Z, Buckling Ratio, cortical sBMD, trabecular vBMD and integral vBMD.

3D-SHAPER is indicated to be used by qualified medical professionals to assist healthcare professionals in the bone health evaluation & changes, and cannot fully substitute their clinical judgement.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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3D-SHAPERSection 5 - 510(k) SummaryDoc Ref.: 05
3D-SHAPER3D-SHAPERPage 1 of 8

1 General Information

This 510(k) Summary of safety and effectiveness information is being submitted in accordance with the requirements detailed in 21 CFR 807.92.

The assigned 510(k) number is: K220822

SUBMITTER NAME:3D-SHAPER MEDICAL S.L.
SUBMITTER ADDRESS:C/ Paris 179, 2º-2º
08036 Barcelona
BARCELONA
SPAIN
CONTACT:Ludovic Humbert
TELEPHONE:+34 93 328 3964
E-MAIL:ludovic.humbert@3d-shaper.com
DATE PREPARED:March, 7, 2022
DEVICE TRADE NAME:3D-SHAPER
COMMON NAME:3D Analysis software for Bone Densitometers
DEVICE CLASS:Class II
REGULATION NUMBER892.1170
REGULATION NAMEBone Densitometer
PRODUCT CODE:KGI
PREDICATE DEVICE(S):HIP STRUCTURAL ANALYSIS SOFTWARE OPTION FOR THE HOLOGICQDR X-RAY BONE DENSITOMETERS (K061561)

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Image: 3D-SHAPER logoSection 5 - 510(k) SummaryDoc Ref.: 05
3D-SHAPER3D-SHAPERPage 2 of 8

Description of the device and its intended use ਜ

3D-SHAPER is a software reconstructing in 3D, the shape and bone mineral density from 2D DXA images. The software incorporates a DXA-based 3D reconstruction and measures the distribution of bone mineral mass at specific cross sections of the hip. It provides physicians with estimates of the structural properties of the hip, such as densities or geometrical parameters. The software is not suitable for use with paediatric patients or for subjects with hip prosthesis such as total hip replacement prosthesis, hip resurfacing prosthesis or an osteosynthesis system, since the software has not been tested against these conditions. 3D-SHAPER is indicated to be used by qualified medical professionals to assist healthcare professionals in the bone health evaluation & changes, and cannot fully substitute their clinical judgement.

The 3D-SHAPER® measurements include:

Cortical surface Bone Mineral Density (Cortical sBMD, mg/cm2)

Trabecular volumetric Bone Mineral Density (Trabecular vBMD, mg/cm³)

Integral volumetric Bone Mineral Density (Integral vBMD, mg/cm³), the integral compartment being the union of the cortical and trabecular compartments.

Hip structural measurements: Cross-Sectional Area (CSA, in cm²), Cross-Sectional Moment of Inertia (CSMI, in cm4), section modulus (Z, in cm3) and buckling Ratio (BR).

Cortical sBMD, trabecular VBMD and integral vBMD are calculated at the total femur. CSA, CSMI, Z and BR are calculated in cross-sections at the neck, intertrochanteric region and lower shaft.

INTENDED USE:

As established in the Indications for Use Statement :

3D-SHAPER uses data from conventional Dual Energy X-Ray Absorptiometry (DXA) scans to measure the distribution of bone mineral mass at specific cross sections or regions of the hip and allows the physician to estimate structural properties of the hip, such as CSA, CSMI, Z, Buckling Ratio, cortical sBMD, trabecular vBMD and integral vBMD.

3D-SHAPER is indicated to be used by qualified medical professionals to assist healthcare professionals in the bone health evaluation & changes, and cannot fully substitute their clinical judgement.

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3D-SHAPERSection 5 – 510(k) SummaryDoc Ref.: 05
3D-SHAPERPage 3 of 8

2 Summary of Comparison with Predicate Device

Characteristics and features of the 3D-SHAPER software application have been compared to the features of the chosen, previously cleared, predicate device. The following predicate device was selected due to the similarities in application features, intended use and indications for use.

510(k)NumberProductManufacturer
K061561HIP STRUCTURAL ANALYSIS SOFTWAREOPTION FOR THE HOLOGIC QDR X-RAYBONE DENSITOMETERSHOLOGIC, INC.

Table 1. Information about Predicate Device

Comparison of the proposed device with the predicate device is summarized in the following table:

ElementsofComparisonNew DevicePredicate DeviceDiscussion
3D-SHAPER(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)Software Option for the HologicQDR X-Ray Bone Densitometers(Hologic, Inc)
Regulatory Data
Regulatory ClassClass IIClass IIIdentical
ClassificationnameBone DensitometerBone DensitometerIdentical
RegulationNumber21 CFR 892.117021 CFR 892.1170Identical
Product CodeKGIKGIIdentical
FDA Clearance-510(k) cleared: K061561-
Use

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Image: 3D-SHAPERSection 5 – 510(k) SummaryDoc Ref.: 05
3D-SHAPER3D-SHAPERPage 4 of 8
ElementsofNew DevicePredicate DeviceDiscussion
Comparison3D-SHAPER(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)Software Option for the HologicQDR X-Ray Bone Densitometers(Hologic, Inc)
Indication for Use/ Intended Use3D-SHAPER uses data fromconventional Dual Energy X-RayAbsorptiometry (DXA) scans tomeasure the distribution ofbone mineral mass at specificcross sections or regions of thehip and allows the physician toestimate structural properties ofthe hip, such as CSA, CSMI, Z,Buckling Ratio, cortical sBMD,trabecular vBMD and integralvBMD.3D-SHAPER is indicated to beused by qualified medicalprofessionals to assisthealthcare professionals in thebone health evaluation &changes, and cannot fullysubstitute their clinicaljudgement.The Hip Structure Analysis(HSA®) for QDR X-ray BoneDensitometers uses data fromconventional Dual Energy X-rayAbsorptiometry (DXA) scans tomeasure the distribution ofbone mineral mass at specificcross sections of the hip andallows the physician to estimatestructural properties of the hip,such as CSA, CSMI, Z andBuckling Ratio.Similar toPredicatedevice
Technical characteristics
GeneraldescriptionIs a software solution toestimate bone mineraldistribution and structuralproperties of the hip.Is a software solution toestimate bone mineraldistribution and structuralproperties of the hip.identical
Mode of actionSoftware SolutionSoftware SolutionIdentical
Operating SystemWindowsWindowsIdentical

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Image: 3D-SHAPER logoSection 5 – 510(k) SummaryDoc Ref.: 05
3D-SHAPERPage 5 of 8
ElementsofComparisonNew DevicePredicate DeviceDiscussion
3D-SHAPER(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)Software Option for the HologicQDR X-Ray Bone Densitometers(Hologic, Inc)
PrinciplesofoperationAnalysis of DXA imagesAnalysis of DXA imagesIdentical
User InterfaceMouse, KeyboardMouse, KeyboardIdentical
Target PopulationPatients needing a bone healthassessment.Patients needing a bone healthassessment.Identical
Anatomical sitesHipHipIdentical
Conditions of useIt is intended for exclusive useby professional users.It is intended for exclusive useby professional users.Identical
The software is intended toassist healthcare professionalsin the bone health evaluationand cannot fully substitute theirclinical judgement.The software is intended toassist healthcare professionalsin the bone health evaluationand cannot fully substitute theirclinical judgement.
Images supportedDualEnergyX-rayAbsorptiometry (DXA) scansfrom Bone DensitometersDualEnergyX-rayAbsorptiometry (DXA) scansfrom Bone DensitometersIdentical
Image Features
Image assessmentBy visualization and analysis ofthe imagesBy visualization and analysis ofthe imagesIdentical
Image display andmanipulation- 2D review- Pan/zoom; magnify; maximizeand minimize; scroll through- 2D review- Adjust window level, contrastand brightness.Similartopredicatedevice

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Image: 3D-SHAPER logoSection 5 – 510(k) SummaryDoc Ref.: 05
3D-SHAPER3D-SHAPERPage 6 of 8
ElementsofNew DevicePredicate DeviceDiscussion
Comparison3D-SHAPER(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)Software Option for the HologicQDR X-Ray Bone Densitometers(Hologic, Inc)
slice stack; adjust window level,contrast and brightness.
Resultvisualization- Numerical- NumericalSimilar topredicatedevice
- Graph- Graph
- 2D view- 2D view
- 3D view
Export capabilities- Snapshots as PNG- Numerical data as a databasefileSimilar topredicatedevice
- Numerical data as CSV file- Study data as an internal fileformat
- Study data as an internal fileformat- DXA scan as a proprietary fileformat
- 3D-Shaper analysis as aproprietary file format- Report
- Report
Performing Bone Analysis
Measure the distribution ofbone mineral mass from a 3Dimage of the hip and allow thephysician to estimate structuralproperties of the hip, such asCSA, CSMI, Z, Buckling Ratio,volumetric bone mineraldensities and surface bonemineral density.Measure the distribution ofbone mineral mass from a 2Dimage of the hip and allows thephysician to estimate structuralproperties of the hip, such asCSA, CSMI, Z and Buckling Ratio.Similar topredicatedevice

Table 2. Comparison of technological characteristics and features - proposed and Predicate device

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Image: 3D-SHAPER logo3D-SHAPERSection 5 – 510(k) SummaryDoc Ref.: 05
3D-SHAPERPage 7 of 8

3D-SHAPER software has the same indications for use and similar technological characteristics as the predicate device. Additionally, 3D-SHAPER and its predicate device are a software option to the Bone Densitometer equipment and as such, has the same Regulation Number & Product Code as the predicate device. Both devices proposed the same functionality in terms of Image display and manipulation, results visualization and export capabilities.

A correlation study has been performed to compare structural properties of the hip (such as CSA, CSMI, Z, Buckling Ratio) as well as volumetric bone mineral densities and surface bone mineral density obtained by 3D-SHAPER software and its predicate device. This study involved 740 men and women (94% women) aged 17 to 92 years old that were analysed using both 3D-SHAPER software and its predicate device. Very strong correlation coefficients (r≥0.9) were found between 3D-SHAPER and predicate device measurements for Integral vBMD, Trabecular vBMD, Cortical sBMD, CSA, CSMI and Z. Likewise, strong correlation coefficients (r≥0.7) were found between 3D-SHAPER and predicate device measurements for Buckling Ratio.

Based on this analysis, 3D-SHAPER Medical believes that the new device is considered substantially equivalent to the predicate device in terms of safety or effectiveness.

Design and Development of Device ന

Design and development included identification, evaluation and control of potential hazards as per standards ISO 14971 "Medical devices – Application of risk management to medical devices". The software development life-cycle included integration, verification testing and was successfully completed following standard IEC 62304 "Medical device software life-cycle processes" and IEC 82304 "Health software - Part 1: General requirements for product safety".

Additionally, 3D-SHAPER was designed, developed, tested, verified and validated according to documented procedures and specific protocols in line with the following FDA guidance documents:

  • Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices — May 11, 2005
  • Guidance for Off-The-Shelf Software Use in Medical Devices September 27, 2019 .
  • Guidance for Industry: Cybersecurity for Networked Medical Devices Containing Off-The-. Shelf (OTS) Software – January 14, 2005
  • . General Principles of Software Validation; Final Guidance for Industry and FDA Staff – January 11, 2002.
  • Guidance for Design Considerations and Pre-market Submission Recommendations for . Interoperable Medical Devices - September 6, 2017

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Image: 3D-SHAPERSection 5 – 510(k) SummaryDoc Ref.: 05
Image: 3D-SHAPER3D-SHAPERPage 8 of 8
  • . Guidance for Management of Cybersecurity in Medical Devices - October 18, 2018

Performance Bench Testing এ

The Performance Bench testing showed that 3D-SHAPER computing time was lower than two minutes and 30 seconds and software convergence superior to 95%. 3D-SHAPER provides accurate subjectspecific models of the femoral shape and measurements compared to Quantitative Computed Tomography (QCT). Very strong correlations (r) were found between 3D measurements obtained using 3D-SHAPER and QCT for integral vBMD (r=0.96), Cortical sBMD (r=0.95), Trabecular vBMD (r=0.93), CSA (r≥ 0.95), CSMI (r≥ 0.92) and Z (r≥ 0.91) while strong correlations were found for BR (r≥ 0.71). 3D-SHAPER provides precise 3D measurements that can be used to monitor bone changes over time. 3D-SHAPER supports DXA files obtained from GE and Hologic DXA Scanners.

Clinical Testing ഥ

Safety and performance of the proposed software is based on the software development life-cycle and bench testing. Design & Verification did not require clinical testing.

Summary Conclusions റ

Device description, intended use and indications for use for 3D-SHAPER have been identified and established. Results obtained from all performance testing, show fulfilment of the device design specifications, where applicable in accordance with the reference standards.

Specific characteristics, intended use and indications for use of the different system components have been compared with corresponding predicate devices. Results of the comparison indicate the presence of minor differences that we believe do not affect safety and performance.

We therefore believe that all issues regarding safety and performance of the proposed device have been successfully addressed and that the similarity of the device with the established predicates strongly supports the determination of substantial equivalence.

§ 892.1170 Bone densitometer.

(a)
Identification. A bone densitometer is a device intended for medical purposes to measure bone density and mineral content by x-ray or gamma ray transmission measurements through the bone and adjacent tissues. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.