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

(263 days)

Product Code
Regulation Number
892.1170
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
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.
More Information

Not Found

No
The description focuses on 3D reconstruction and measurement based on DXA data, without mentioning AI, ML, or related concepts. The performance studies are based on correlation and bench testing, not typical AI/ML validation metrics.

No.
The device is described as software that assists healthcare professionals in bone health evaluation by providing estimates of structural properties of the hip, not by directly treating a condition.

Yes

The device uses data from DXA scans to measure and estimate structural properties of the hip, such as bone mineral density and geometrical parameters. It is indicated to assist healthcare professionals in bone health evaluation, which is a diagnostic purpose.

Yes

The device description explicitly states that 3D-SHAPER is a software that reconstructs and measures data from existing DXA images. There is no mention of any accompanying hardware component being part of the device itself.

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

Here's why:

  • IVDs analyze samples taken from the human body. The definition of an IVD typically involves the examination of specimens such as blood, urine, tissue, or other bodily fluids.
  • This device analyzes images of the human body. 3D-SHAPER uses data from DXA scans, which are medical images, to assess bone structure and density within the body. It does not process or analyze biological samples taken from the patient.

Therefore, while 3D-SHAPER is a medical device used for diagnostic purposes (assisting in bone health evaluation), it falls under the category of imaging software or diagnostic imaging analysis software, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for 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.

Product codes

KGI

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.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Dual Energy X-Ray Absorptiometry (DXA) scans from Bone Densitometers

Anatomical Site

Hip

Indicated Patient Age Range

The software is not suitable for use with paediatric patients. (Implicitly adult patients).

Intended User / Care Setting

qualified medical professionals; professional users

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)

Bench Testing: 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 subject-specific 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.

Correlation Study: 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.

Clinical Testing: 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.

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

Not Found

Predicate Device(s)

K061561

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

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

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 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

2

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
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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 HOLOGIC
QDR X-RAY BONE DENSITOMETERS (K061561)

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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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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 SOFTWARE
OPTION FOR THE HOLOGIC QDR X-RAY
BONE DENSITOMETERSHOLOGIC, INC.

Table 1. Information about Predicate Device

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

| Elements
of

ComparisonNew DevicePredicate DeviceDiscussion
3D-SHAPER
(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)
Software Option for the Hologic
QDR X-Ray Bone Densitometers
(Hologic, Inc)
Regulatory Data
Regulatory ClassClass IIClass IIIdentical
Classification
nameBone DensitometerBone DensitometerIdentical
Regulation
Number21 CFR 892.117021 CFR 892.1170Identical
Product CodeKGIKGIIdentical
FDA Clearance-510(k) cleared: K061561-
Use

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| Elements

ofNew DevicePredicate DeviceDiscussion
Comparison3D-SHAPER
(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)
Software Option for the Hologic
QDR X-Ray Bone Densitometers
(Hologic, Inc)
Indication for Use
/ Intended Use3D-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.The Hip Structure Analysis
(HSA®) for QDR X-ray Bone
Densitometers 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 and
Buckling Ratio.Similar to
Predicate
device
Technical characteristics
General
descriptionIs a software solution to
estimate bone mineral
distribution and structural
properties of the hip.Is a software solution to
estimate bone mineral
distribution and structural
properties of the hip.identical
Mode of actionSoftware SolutionSoftware SolutionIdentical
Operating SystemWindowsWindowsIdentical

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| Elements
of

ComparisonNew DevicePredicate DeviceDiscussion
3D-SHAPER
(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)
Software Option for the Hologic
QDR X-Ray Bone Densitometers
(Hologic, Inc)
Principles
of
operationAnalysis of DXA imagesAnalysis of DXA imagesIdentical
User InterfaceMouse, KeyboardMouse, KeyboardIdentical
Target PopulationPatients needing a bone health
assessment.Patients needing a bone health
assessment.Identical
Anatomical sitesHipHipIdentical
Conditions of useIt is intended for exclusive use
by professional users.It is intended for exclusive use
by professional users.Identical
The software is intended to
assist healthcare professionals
in the bone health evaluation
and cannot fully substitute their
clinical judgement.The software is intended to
assist healthcare professionals
in the bone health evaluation
and cannot fully substitute their
clinical judgement.
Images supportedDual
Energy
X-ray
Absorptiometry (DXA) scans
from Bone DensitometersDual
Energy
X-ray
Absorptiometry (DXA) scans
from Bone DensitometersIdentical
Image Features
Image assessmentBy visualization and analysis of
the imagesBy visualization and analysis of
the imagesIdentical
Image display and
manipulation- 2D review
  • Pan/zoom; magnify; maximize
    and minimize; scroll through | - 2D review

  • Adjust window level, contrast
    and brightness. | Similar
    to
    predicate
    device |

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| Elements

ofNew DevicePredicate DeviceDiscussion
Comparison3D-SHAPER
(3D-SHAPER MEDICAL S.L)Hip Structural Analysis (HSA)
Software Option for the Hologic
QDR X-Ray Bone Densitometers
(Hologic, Inc)
slice stack; adjust window level,
contrast and brightness.
Result
visualization- Numerical- NumericalSimilar to
predicate
device
- Graph- Graph
- 2D view- 2D view
- 3D view
Export capabilities- Snapshots as PNG- Numerical data as a database
fileSimilar to
predicate
device
- Numerical data as CSV file- Study data as an internal file
format
- Study data as an internal file
format- DXA scan as a proprietary file
format
- 3D-Shaper analysis as a
proprietary file format- Report
- Report
Performing Bone Analysis
Measure the distribution of
bone mineral mass from a 3D
image of the hip and allow the
physician to estimate structural
properties of the hip, such as
CSA, CSMI, Z, Buckling Ratio,
volumetric bone mineral
densities and surface bone
mineral density.Measure the distribution of
bone mineral mass from a 2D
image of the hip and allows the
physician to estimate structural
properties of the hip, such as
CSA, CSMI, Z and Buckling Ratio.Similar to
predicate
device

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

9

| Image: 3D-SHAPER logo

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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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  • . 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.