(163 days)
No
The document explicitly states "Mentions AI, DNN, or ML: Not Found" and does not describe any AI/ML components in the device description or performance studies. While it mentions a 2D/3D algorithm for image processing, this alone does not indicate AI/ML.
Yes
The device is described as a "Proton Therapy System" used for "precision radiotherapy of lesions, turnors, and conditions anywhere in the body where radiation treatment is indicated," directly implying a therapeutic purpose.
No
The device description clearly states it "generates ionizing radiation (protons) in order to deliver radiation therapy," which is a treatment function, not a diagnostic one. While it mentions image acquisition, this is for guidance during treatment, not for diagnosing conditions.
No
The device description explicitly lists hardware components like a Cyclotron, Beam Transport System, Treatment Room with a rotating Gantry, and Treatment Control Room, indicating it is a physical system that generates radiation, not solely software.
Based on the provided information, the ProBeam 360° Proton Therapy System is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for "precision radiotherapy of lesions, turnors, and conditions anywhere in the body where radiation treatment is indicated." This describes a therapeutic device that delivers radiation to treat conditions within the body.
- Device Description: The device generates "ionizing radiation (protons)" to deliver "radiation therapy." This is a direct treatment method applied to the patient.
- IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body (like blood, urine, tissue) to detect diseases, conditions, or infections. The ProBeam 360° System does not perform such tests.
The device is clearly a therapeutic radiation delivery system, not a diagnostic tool that analyzes biological samples.
N/A
Intended Use / Indications for Use
The ProBeam 360° Proton Therapy System provides protons for precision radiotherapy of lesions, turnors, and conditions anywhere in the body where radiation treatment is indicated.
Product codes
LHN
Device Description
The ProBeam 360° Proton Therapy System is a device that generates ionizing radiation (protons) in order to deliver radiation therapy in accordance with a predetermined treatment plan. The ProBeam 360° System version 1.0 is available in single-room, compact configuration and includes the following primary components:
- Cyclotron
- Beam Transport System
- Treatment Room with a rotating Gantry
- Treatment Control Room
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
2D image acquisition, CBCT (3D) image acquisition
Anatomical Site
anywhere in the body
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Not Found
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)
Hardware and software design verification and design validation testing was performed according to the FDA Quality System Regulation (21 CFR §820), ISO 13485 quality Management System standard, ISO 14971 Risk Management Standard, and IEC 62304 Software Life Cycle Process standard.
Test results showed conformance to applicable requirements specifications and assured hazard safeguards functioned properly. Software design verification and design validation testing were conducted, and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
Electrical safety and electromagnetic compatibility (EMC) testing were performed for the ProBeam 360° System. The system conforms to FDA recognized consensus standards for electrical safety and electromagnetic compatibility.
No animal studies or clinical tests have been included in this pre-market submission.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 892.5050 Medical charged-particle radiation therapy system.
(a)
Identification. A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.(b)
Classification. Class II. When intended for use as a quality control system, the film dosimetry system (film scanning system) included as an accessory to the device described in paragraph (a) of this section, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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December 1, 2022
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".
Varian Medical Systems, Inc. % Mr. Peter Coronado Sr. Director, Regulatory Affairs 3100 Hansen Way PALO ALTO CA 94304
Re: K221791
Trade/Device Name: ProBeam 360° Proton Therapy System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: Class II Product Code: LHN Dated: October 28, 2022 Received: October 31, 2022
Dear Mr. Peter Coronado:
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 devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
1
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,
| Lora D.
Weidner -S | Digitally signed by Lor
D. Weidner -S
Date: 2022.12.01
19:38:07 -05'00' |
----------------------- | ---------------------------------------------------------------------------------- |
---|
Lora D. Weidner, Ph.D. Assistant Director Radiation Therapy Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices 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) K221791
Device Name ProBeam 360° Proton Therapy System
Indications for Use (Describe)
The ProBeam 360° Proton Therapy System provides protons for precision radiotherapy of lesions, turnors, and conditions anywhere in the body where radiation treatment is indicated.
Type of Use (Select one or both, as applicable) | |
---|---|
☑ Prescription Use (Part 21 CFR 801 Subpart D) | |
☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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Premarket Notification - 510(k) Summary
ProBeam 360° Proton Therapy System version 1.0
l. Submitter's Name
Varian Medical Systems 3100 Hansen Way Palo Alto, CA 94304
Contact Name: Mr. Peter J. Coronado, Senior Director Regulatory Affairs Phone: 650-424-6320 | Fax: 650-646-9200 E-mail: submissions.support@varian.com Date Prepared: 18 June 2022
II. Device Information
Proprietary Name: ProBeam 360° Proton Therapy System version 1.0 Common/ Usual Name: Proton Therapy System Classification Name: System, Radiation Therapy, Charged-Particle, Medical Regulation Number: §892.5050 Product Code: LHN
III. Predicate Device
ProBeam Proton Therapy System v2.0 (K133191)
IV. Device Description
The ProBeam 360° Proton Therapy System is a device that generates ionizing radiation (protons) in order to deliver radiation therapy in accordance with a predetermined treatment plan.
The ProBeam 360° System version 1.0 is available in single-room, compact configuration and includes the following primary components:
- Cyclotron
- Beam Transport System ●
- Treatment Room with a rotating Gantry
- Treatment Control Room
V. Indications for Use
ProBeam 360° Proton Therapy System provides protons for precision radiotherapy of lesions, tumors, and conditions anywhere in the body where radiation treatment is indicated.
VI. Comparison of Technological Characteristics with the Predicate Device
At a high-level, the subject device differs from the predicate device as a result of the following characteristics:
- Smaller Gantry
- . Compact single Gantry room configuration
- Compact Beam Transport System ●
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- Reduced-Energy Cyclotron ●
- . Patient Positioning Robot
- CBCT acquisition
- Updated Software Release to support changes listed above ●
Table 1. Comparison of Subject Device to Predicate Device
Device | Predicate Device: | Subject Device: | Comparison |
---|---|---|---|
Characteristic | ProBeam Proton Therapy System | ||
(K133191) | ProBeam 360° Proton Therapy | ||
System | |||
Intended Use/ | |||
Indications for Use | ProBeam Proton Therapy System | ||
provides protons for precision | |||
radiotherapy of lesions, tumors, and | |||
conditions anywhere in the body | |||
where radiation treatment is | |||
indicated. | ProBeam 360° Proton Therapy System | ||
provides protons for precision | |||
radiotherapy of lesions, tumors, and | |||
conditions anywhere in the body where | |||
radiation treatment is indicated. | Same | ||
Radiation Source | |||
Accelerator | Isochronous Cyclotron | Isochronous Cyclotron | Same |
Type of Coils | Superconducting Coils | Superconducting Coils | Same |
Cooling Method | Helium Cryogen Cooling | Helium Cryogen Cooling | Same |
Treatment Particle | Proton | Proton | Same |
Cyclotron Energy | 250 MeV | 226 MeV | Energy reduced cyclotron to |
allow compact Gantry design. | |||
Substantially equivalent to | |||
ProBeam K133191 | |||
Nominal Energy | 70 MeV – 240 MeV | 69 MeV – 218 MeV | Reduced maximum beam energy |
to allow compact Gantry design. | |||
Substantially equivalent to | |||
ProBeam K133191 | |||
Beam Delivery | |||
Beam Transport | |||
System | Standard beam optical system with | ||
quadrupoles and dipole magnets | Standard beam optical system with | ||
quadrupoles and dipole magnets | Same | ||
Switching System | Yes | None | Single Room system does not |
require room switching capability | |||
as compared to multi-room | |||
system ProBeam K133191. | |||
Beam Transport | |||
Magnets | Yes | Yes | Same |
Beam Angle | |||
Adjustment | Adjustable: Rotating Isocentric Gantry | ||
rooms | |||
Fixed: Fixed Beam Room | Adjustable: Rotating Isocentric Gantry | ||
room | Same as Adjustable in ProBeam | ||
K133191 | |||
Beam Delivery | Beam Spot Scanning | Beam Spot Scanning | Same |
Beam Spot Shape | Spot size expressed as 1σ (sigma) | ||
value of the gaussian profile of the | |||
beam in air at isocenter: | |||
$σ$ = 4.0 mm ± 15% at 240 MeV | |||
$σ$ = 4.0 mm ± 15% at 140 MeV | |||
$σ$ = 5.4 mm ± 15% at 70 MeV | Spot size expressed as 1σ (sigma) value | ||
of the gaussian profile of the beam in air | |||
at isocenter: | |||
$σ$ = 3.8 mm ± 15% at 218 MeV | |||
$σ$ = 4.4 mm ± 15% at 140 MeV | |||
$σ$ = 5.9 mm ± 15% at 69 MeV | Substantially the same beam | ||
characteristics as ProBeam | |||
K133191. | |||
Beam Field Size | Max: 30cm (x) x 40cm (y) | Max: 25cm (x) x 25cm (y) | Reduced field size as compared |
to ProBeam K133191. | |||
Dose Rate | 2 Gy/l/min | 2 Gy/l/min | Same |
Physical Characteristics | |||
Treatment Room | |||
Configuration | Multi-Room | Single Gantry Room Compact | |
configuration | Allows installation in building | ||
with small footprint. Single | |||
Gantry room is substantially | |||
equivalent to Rotating Isocentric | |||
Device | |||
Characteristic | Predicate Device: | ||
ProBeam Proton Therapy System | |||
(K133191) | Subject Device: | ||
ProBeam 360° Proton Therapy | |||
System | Comparison | ||
Patient Positioning | Forte 6-AxisRobotic Treatment Table | ||
(K122413) | Leoni Orion 6-AxisRobotic Treatment | ||
Table (K160518) | Substantially equivalent | ||
Maximum Load | 273 Kg (550lbs) | 226 kg (500 lbs) | New patient positioning system |
as cleared in K160518 supports | |||
up to 226 kg. | |||
Patient Position | |||
Verification System | 2D image acquisition, wall-mounted | ||
or nozzle mounted | 2D image acquisition and CBCT, nozzle | ||
mounted | Adapted from reference device to | ||
allows for 3D image CBCT. Nozzle | |||
mounted same as predicate | |||
ProBeam K133191. | |||
Image Acquisition | Functionality included in P2VA / | ||
Imaging Supervisor. Limited to 2D | |||
image acquisition. | Functionality included in PVA / Imaging | ||
Supervisor. 2D and CBCT (3D) image | |||
acquisition. | Allows for 3D image CBCT. See | ||
table 2 for comparison to | |||
reference device. | |||
Version | Version 2.0 | ProBeam 360° version 1.0 | Supports changes for compact |
Gantry, patient positioning table, | |||
and operating system updates. | |||
Network | |||
Connectivity | None | Remote Monitoring and Limited Remote | |
control | Remote network connectivity | ||
enables the Varian service | |||
technicians to perform remote | |||
service activities. | |||
2D/3D Match | Integration of 2D/3D algorithm into | ||
P2VA | Integration of 2D/3D algorithm into | ||
P2VA | Same | ||
CBCT Imaging | None | 3D CBCT reconstruction algorithm | Allows for 3D image CBCT. See |
table 2 for comparison to | |||
reference device. | |||
3D/3D Match | Not included | 3D/3D registration algorithm for | |
patient setup | Allows for 3D image CBCT. See | ||
table 2 for comparison to | |||
reference device |
5
varian
A Siemens Healthineers Company
A Siemens Healthineers Company
Table 1. Comparison of Subject Device to Predicate Device
Table 2. Comparison of Subject Device to Reference Device
| Device Characteristic | Reference Device:
TrueBeam System
(K123291) | Subject Device:
ProBeam 360 Proton Therapy
System | Comparison |
|-----------------------|------------------------------------------------------|---------------------------------------------------------|------------|
| Imaging | | | |
| Patient Position | 3D CBCT | 3D CBCT | Same |
| Verification System | | | |
| Image Acquisition | Functionality included in PVA/
Imaging Supervisor | Functionality included in PVA/ Imaging
Supervisor | Same |
| CBCT Imaging | 3D CBCT reconstruction
algorithm | 3D CBCT reconstruction algorithm | Same |
| 3D/3D Match | 3D/3D registration algorithm for
patient setup | 3D/3D registration algorithm for
patient setup | Same |
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VII. Summary of Performance Testing (Non-Clinical Testing)
Design verification and design validation testing demonstrates that the ProBeam 360° System v1.0 performs as intended and meets its essential performance defined as: the functionality enabling its intended use to deliver the radiation dose as prescribed for treatment.
The software for the subject device is considered to have a "major" level of concern, since a failure or latent flaw in the software could directly result in serious injury or death to the patient or operator.
Hardware and software design verification and design validation testing was performed according to the FDA Quality System Regulation (21 CFR §820), ISO 13485 quality Management System standard, ISO 14971 Risk Management Standard, and IEC 62304 Software Life Cycle Process standard.
Test results showed conformance to applicable requirements specifications and assured hazard safeguards functioned properly. Software design verification and design validation testing were conducted, and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
Electrical safety and electromagnetic compatibility (EMC) testing were performed for the ProBeam 360° System. The system conforms to FDA recognized consensus standards for electrical safety and electromagnetic compatibility.
No animal studies or clinical tests have been included in this pre-market submission.
VIII. Determination of Substantial Equivalence to the Predicate Device
A subset of technological characteristics and features of the subject device differs from the predicate device. These differences are all considered to be enhancements of the predicate, which facilitate the compact, single-room design of the subject device, ProBeam 360° System.
The Intended Use and indications for use are substantially the same as the predicate device. Further, there are no changes in the principle of operation of the devices. The Verification and Validation demonstrates that the device is as safe and effective as the predicate. Varian therefore believes the data demonstrates that the ProBeam 360° System v1.0 is substantially equivalent to the predicate device, ProBeam Proton Therapy System v.2.0 (K133191).