(268 days)
SIDDHARTH-II is intended to perform image guided stereotactic radiotherapy for the lessons, tumors & conditions anywhere in the body where radiation treatment is indicated for adults and Pediatric patients.
Integrated Radiation Field Analyser (RFA) of Siddharth-II is intended to collect beam data in water under the aspect of machine QA for the following purposes:
-
acceptance testing , periodic QA procedures, and/or commissioning of a radiation therapy system.
-
beam data analysis according to international therapy dosimetry protocols
-
acquisition, formatting and transfer of basic data to treatment planning systems
The indication for use of Immobilization & Patient Positioning devices (IMPACT) is to immobilize the patient during treatment by providing appropriate support and comfort which in turn leads to precise treatment delivery.
SIDDHARTH-II, the subject device remains same as the most recently cleared predicate device SIDDHARTH-II (K210894). In addition, with the features and specifications of existing 510k cleared equipment, the Radiation Field analyzer (RFA) has been permanently integrated with gantry of Siddharth-II to perform beam data analysis as per international therapy dosimetry protocols.
The integrated RFA is retracted and accommodated within the gantry of the radiation therapy equipment after performing data dosimetry operations. This provides an integrated solution for validating the performance of a radiation therapy equipment using an RFA which is in-built with the radiation therapy equipment that is primarily employed for providing radiation treatments to patients.
The following functionalities can be achieved by using this RFA integrated with Siddharth-II.
- . Acceptance testing, Commissioning and Periodic Quality Assurance Measurements for radiation beams emitted by radiation therapy equipment SIDDHARTH-II
- . Beam data analysis according to international therapy dosimetry protocols
- . Collection of beam data for Treatment Planning System
The RFA setup consists of RFA electromechanical arm for 3-dimensional movement of radiation detector. Ion Chamber (Radiation Detector), Built-in Electrometer, RFA water tank and Water Reservoir. The design control procedures applied to the development of the SIDDHARTH-II and its modifications include requirements reviews, risk analysis, and verification and validation testing. The results of verification and validation activities demonstrate that the acceptance criteria have been met.
All other features and technological characteristics of the SIDDHARTH-II remains as cleared by K210894.
The provided text is a 510(k) summary for the Panacea Medical Technologies Pvt Ltd. SIDDHARTH-II device, specifically addressing the integration of a Radiation Field Analyzer (RFA). It focuses on demonstrating substantial equivalence to a previously cleared predicate device (SIDDHARTH-II, K210894) rather than presenting a detailed study proving the device meets specific acceptance criteria in the context of, for example, a diagnostic performance study.
The document states that "The results of verification and validation activities demonstrate that the acceptance criteria have been met," but it does not explicitly list those criteria in a table format, nor does it provide a detailed study report that would typically include information on sample size, expert adjudication, or MRMC studies for diagnostic performance.
Based on the provided text, here's what can be extracted and what information is not available regarding explicit acceptance criteria and a study proving performance in a diagnostic or clinical efficacy sense:
The acceptance criteria and performance are discussed in the context of engineering and regulatory compliance verification and validation for the addition of the RFA feature, rather than a clinical performance study with human subjects or readers.
Acceptance Criteria and Reported Device Performance (as inferred from the document)
Since there isn't a table of diagnostic performance acceptance criteria, I will infer the performance criteria from the "Performance Data" section (VII) which focuses on non-clinical testing and regulatory compliance.
| Acceptance Criteria Category (Inferred) | Reported Device Performance (Summary) |
|---|---|
| General Safety and Effectiveness | "The non-clinical data support the safety of the device as compared to the predicate and the software verification and validation demonstrate that the subject device with additional RFA feature performs as intended. Panacea therefore considers the SIDDHARTH-II to be as safe and effective and to perform at least as well as the predicate devices." (Page 10) |
| Software Performance | "Software verification testing was conducted as required by FDA's Guidance... [and] concludes that the software of the subject device was considered as a 'Major' level of concern and also it is in compliance with IEC 62304 Software Life cycle processes." (Page 10) |
| Electrical Safety & EMC | "Electrical safety & electromagnetic (EMC) testing were conducted on the SIDDHARTH-II which verified complies with the IEC/ES 60601-1 standards for safety & IEC 60601-1-2 EMC standard." (Page 10) |
| RFA Feature Performance (Non-Clinical) | "Non-clinical performance testing for RFA feature of subject device was performed according to IEC 60731:2016 and to specific properties of Ion chamber (Radiation detector), Electrometer, and water phantom systems which included radiotherapy dose measurements i.e. with step by step measurements and also measurement accuracy with respect to radiation detector, positioning, reproducibility and mechanical alignment." (Page 10) |
| Regulatory Standards Conformance | "SIDDHARTH-II conforms with the FDA recognized standards and other international standards listed below [e.g., ANSI/AAMI ES60601-1, IEC 60601-1-3, IEC 60731, ISO 14971, etc.]." (Page 10) |
Study Details (Based on the Provided Text)
Given that this is a 510(k) for an integrated hardware/software component within a radiation therapy system, the "study" described is a non-clinical verification and validation (V&V) of the RFA component's functionality and safety, and regulatory compliance, rather than a clinical trial or performance study of a diagnostic AI.
-
Sample size used for the test set and the data provenance:
- The document mentions "non-clinical performance testing for RFA feature" involving "radiotherapy dose measurements i.e. with step by step measurements and also measurement accuracy with respect to radiation detector, positioning, reproducibility and mechanical alignment."
- Sample Size: Not specified in terms of number of cases, but rather as test procedures on the device components (e.g., "step by step measurements"). This likely refers to quantitative measurements conducted during engineering tests, not a patient or image dataset.
- Data Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). The testing would have been conducted in a lab or manufacturing environment.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable / Not specified. This type of information is relevant for studies involving human interpretation or clinical data (e.g., radiologists for ground truth). The testing described is hardware and software functional and safety testing, evaluated against engineering specifications and international standards (like IEC 60731:2016 for dose measurements).
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication is typically for clinical data consensus or discrepancies among human readers. For non-clinical device testing, the methods involve direct measurement and comparison to predefined engineering specifications and regulatory standards.
-
If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No. This type of study is not mentioned or implied because the device is a radiation therapy system with an integrated QA tool (RFA), not a diagnostic AI system intended to assist human readers in image interpretation.
-
If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Yes, in essence, for the RFA component's function. The "non-clinical performance testing for RFA feature" describes evaluating the RFA's ability to perform "radiotherapy dose measurements," "measurement accuracy with respect to radiation detector, positioning, reproducibility and mechanical alignment." This would be the RFA's function operating standalone (i.e., collecting data and measuring) outside of human-in-the-loop interpretation.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Engineering specifications and international standards. For the RFA's performance, the ground truth is against the expected physical properties of radiation beams and the accuracy requirements defined by standards like IEC 60731:2016. For software, ground truth is conformity to functional requirements and safety standards (e.g., IEC 62304).
-
The sample size for the training set:
- Not applicable / Not specified. This device is not an AI/ML system that requires a "training set" in the sense of a dataset for machine learning. The "training" for the device development would be the engineering design and programming process.
-
How the ground truth for the training set was established:
- Not applicable / Not specified. (As above, no ML training set.)
Summary of what the document describes as "proof":
The document primarily relies on non-clinical verification and validation testing of the RFA module and its integration, along with demonstrating conformance to various international consensus standards (e.g., IEC 60601-1, IEC 60731, IEC 62304, ISO 14971) to establish safety, effectiveness, and substantial equivalence to the previously cleared predicate device. It explicitly states that "clinical testing was not necessary to support substantial equivalence data" (Page 11).
Therefore, the "proof" is based on adherence to predefined engineering specifications, the results of hardware and software functional tests, electrical safety, EMC tests, and compliance with the relevant medical device standards.
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Image /page/0/Picture/0 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" followed by the words "U.S. Food & Drug Administration".
Panacea Medical Technologies Pvt Ltd. % Valli G. Plot No. 35, 4th Phase, Malur KIADB Industrial Area Malur, Kolar District 563130 INDIA
Re: K222762
Trade/Device Name: SIDDHARTH-II; IMPACT Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: Class II Product Code: IYE Dated: May 4, 2023 Received: May 9, 2023
Dear Valli G .:
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
June 8, 2023
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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. | Digitally signed by Lora |
|---|---|
| Weidner -S | D. Weidner -S |
| Date: 2023.06.08 16:14:57 | |
| -04'00' |
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
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Indications for Use
510(k) Number (if known) K222762
Device Name
SIDDHARTH-II and IMPACT
Indications for Use (Describe)
SIDDHARTH-II is intended to perform image guided stereotactic radiotherapy for the lessons, tumors & conditions anywhere in the body where radiation treatment is indicated for adults and Pediatric patients.
Integrated Radiation Field Analyser (RFA) of Siddharth-II is intended to collect beam data in water under the aspect of machine QA for the following purposes:
-
acceptance testing , periodic QA procedures, and/or commissioning of a radiation therapy system.
-
beam data analysis according to international therapy dosimetry protocols
-
acquisition, formatting and transfer of basic data to treatment planning systems
The indication for use of Immobilization & Patient Positioning devices (IMPACT) is to immobilize the patient during treatment by providing appropriate support and comfort which in turn leads to precise treatment delivery.
| 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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Image /page/3/Picture/0 description: The image shows a logo for Panacea Engineering Medicine. The logo features a blue medical cross with a red heartbeat line running horizontally through the center. Below the cross, the word "PANACEA" is written in red, block letters. Underneath "PANACEA", the words "Engineering Medicine" are written in a smaller, italicized font.
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR §807.92.
| I. | Submitter's Information | |
|---|---|---|
| Company Name: | Panacea Medical Technologies Pvt Ltd | |
| Company Address: | Plot No.35, 4th Phase, Malur KIADB Industrial Area, | |
| Malur-563130, Kolar District, INDIA | ||
| Contact Name: | Ms. Valli | |
| Contact Number : | +91 9343779160 | |
| Date prepared: | 10-Sep-22 | |
| III. | Device Information | |
| Name of the Device: | SIDDHARTH-II;IMPACT | |
| Proprietary Name: | Panacea Medical technologies Pvt. Ltd | |
| Common Name: | Linear accelerator for radiation therapy system | |
| Classification Name: | Medical charged-particle radiation therapy system | |
| Regulatory Class: | Class II | |
| Product Code: | IYE |
IV. Predicate Device
| Panacea Device: SIDDHARTH-II | |
|---|---|
| Legally Marketed Proposed | Primary Predicate Device |
| Predicate Device Name | SIDDHARTH-II;IMPACT |
| Trade/Proprietary Name | Panacea Medical Technologies Pvt. Ltd |
| 510(k) Number | K210894 |
| Date Cleared | 28-Sep-21 |
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Image /page/4/Picture/0 description: The image shows the logo for Panacea Engineering Medicine. The logo features a blue medical cross symbol with a red waveform inside, representing medical technology. Below the symbol, the word "PANACEA" is written in red, block letters. Underneath "PANACEA", the words "Engineering Medicine" are written in a smaller, italicized font.
| Device Classification: | Class II |
|---|---|
| Product Code: | IYE |
| Panacea Device: | SIDDHARTH-II | |
|---|---|---|
| Legally Marketed reference Device | Reference device | |
| Name | Dose View 3D | |
| Trade/Proprietary Name | Standard Imaging | |
| 510(k) Number | K103193 | |
| Date Cleared | 27-Dec-2010 | |
| Device Classification: | Class II | |
| Product Code: | IYE |
v. Device Description
SIDDHARTH-II
SIDDHARTH-II, the subject device remains same as the most recently cleared predicate device SIDDHARTH-II (K210894). In addition, with the features and specifications of existing 510k cleared equipment, the Radiation Field analyzer (RFA) has been permanently integrated with gantry of Siddharth-II to perform beam data analysis as per international therapy dosimetry protocols.
The integrated RFA is retracted and accommodated within the gantry of the radiation therapy equipment after performing data dosimetry operations. This provides an integrated solution for validating the performance of a radiation therapy equipment using an RFA which is in-built with
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Image /page/5/Picture/0 description: The image shows a logo for Panacea Engineering Medicine. The logo features a blue plus sign with a red heartbeat symbol in the center. Below the plus sign, the word "PANACEA" is written in red, block letters. Underneath "PANACEA", the words "Engineering Medicine" are written in a smaller, blue font.
the radiation therapy equipment that is primarily employed for providing radiation treatments to patients.
The following functionalities can be achieved by using this RFA integrated with Siddharth-II.
- . Acceptance testing, Commissioning and Periodic Quality Assurance Measurements for radiation beams emitted by radiation therapy equipment SIDDHARTH-II
- . Beam data analysis according to international therapy dosimetry protocols
- . Collection of beam data for Treatment Planning System
The RFA setup consists of RFA electromechanical arm for 3-dimensional movement of radiation detector. Ion Chamber (Radiation Detector), Built-in Electrometer, RFA water tank and Water Reservoir. The design control procedures applied to the development of the SIDDHARTH-II and its modifications include requirements reviews, risk analysis, and verification and validation testing. The results of verification and validation activities demonstrate that the acceptance criteria have been met.
All other features and technological characteristics of the SIDDHARTH-II remains as cleared by K210894.
Comparison of Technological Characteristics with the predicate Device
Compared with the predicate device SIDDHARTH-II (K210894), the basic operation and technological characteristics are the same. Operational differences are described in the Instructions for use of SIDDHARTH-II.
Significant differences between the modified device to the existing 510k cleared device appears below.
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Image /page/6/Picture/0 description: The image shows the logo for Panacea Engineering Medicine. The logo features a blue medical cross symbol with a red line running horizontally through the center, resembling an electrocardiogram (ECG) waveform. Below the symbol, the word "PANACEA" is written in red, block letters, and beneath that, the words "Engineering Medicine" are written in a smaller, blue font.
| SPECIFICATION | CLEARED DEVICE(SIDDHARTH-II_K210894) | MODIFIED DEVICE(SIDDHARTH-II) |
|---|---|---|
| Intended Use | SIDDHARTH-II is intended toperform image guidedstereotactic radiotherapy for thelesions, tumors & conditionsanywhere in the body whereradiation treatment is indicatedfor adults and Pediatric patients. | Unchanged |
| Indication for use | SIDDHARTH-II is intended toperform image guidedstereotactic radiotherapy for thelesions, tumors & conditionsanywhere in the body whereradiation treatment is indicatedfor adults and Pediatric patients. | SIDDHARTH-II is intended toperform image guided stereotacticradiotherapy for the lesions, tumors& conditions anywhere in the bodyindicated for adults and Pediatricpatients. |
| The indication for use ofImmobilization & PatientPositioning devices (IMPACT)is to immobilize the patientduring treatment by providingappropriate support and comfortwhich in turn leads to precisetreatment delivery. | Integrated Radiation Field Analyzer(RFA) of Siddharth-II is intended tocollect beam data in water under theaspect of machine QA for thefollowing purposes:- acceptance testing, periodic QAprocedures, and/or commissioningof a radiation therapy system.- beam data analysis according tointernational therapy dosimetry | |
| SPECIFICATION | CLEARED DEVICE(SIDDHARTH-II_K210894) | MODIFIED DEVICE(SIDDHARTH-II) |
| protocols- acquisition, formatting and transferof basic data to treatment planningsystems | ||
| The indication for use ofImmobilization & PatientPositioning devices (IMPACT) is toimmobilize the patient duringtreatment by providing appropriatesupport and comfort which in turnleads to precise treatment delivery. | ||
| User Interface Device | Control Console PC | Unchanged |
| Use Environment | Hospital (Shielded bunker) | Unchanged |
| Target to Axis Distance(TAD) (in cm) | 100 | Unchanged |
| Gantry range of Rotation(°) | ±185 | Unchanged |
| Beam Stopping Devices | Yes | Unchanged |
| Type of Gantry | Ring | Unchanged |
| Beam Energy | 6 MV | Unchanged |
| SPECIFICATION | CLEARED DEVICE(SIDDHARTH-II_K210894) | MODIFIED DEVICE(SIDDHARTH-II) |
| Patient Support System | • Lateral• Longitudinal• Vertical• Theta• Pitch• Roll | Unchanged |
| Treatment Modality | • IGRT With Kv Imaging• 3D CRT Treatment• IMRT Treatment• VMAT Treatment• SBRT Treatment | Unchanged |
| In-built Automated QATool - Radiation FieldAnalyzer (RFA) | No | Yes |
| RFA arm Motions(To perform 3-dimensional radiationdose measurements) | No | • Offset Motion (X)• Linear Motion (Y)• Vertical Motion (Z) |
| Software | SIDDHARTH-II provides anintuitive and simplifiedworkflow for the user to enter,plan, edit and execute patienttreatment swiftly throughtreatment module. | In addition with treatment module,RFA Dosimetry Module has beenintegrated in SIDDHARTH-IISoftware to control RFA motions &to perform RFA QA Applications |
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Image /page/7/Picture/0 description: The image shows the logo for Panacea Engineering Medicine. The logo features a blue medical cross symbol with a red heartbeat line running horizontally through the center. Below the symbol, the word "PANACEA" is written in red, block letters, and below that, the words "Engineering Medicine" are written in a smaller, blue font.
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Indications for Use
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SIDDHARTH-II is intended to perform image guided stereotactic radiotherapy for the lesions, tumors & conditions anywhere in the body where radiation treatment is indicated for adults and Pediatric patients.
Integrated Radiation Field Analyzer (RFA) of Siddharth-II is intended to collect beam data in water under the aspect of machine QA for the following purposes:
- acceptance testing, periodic OA procedures, and/or commissioning of a radiation therapy system.
- beam data analysis according to international therapy dosimetry protocols
- acquisition, formatting, and transfer of basic data to treatment planning systems
The indication for use of Immobilization & Patient Positioning devices (IMPACT) is to immobilize the patient during treatment by providing appropriate support and comfort which in turn leads to precise treatment delivery.
VI. Substantial equivalence summarv
Panacea claims the modified device in this 510k submission to be substantially equivalent to the predicate devices previously cleared by the FDA in the 510(k) specified above.
Panacea claims this equivalence because the proposed devices have equivalent designs, intended uses, target population, patient positioning and used materials. The integration and performance of the new Radiation Field Analyzer for QA purposes was supported by the reference device. Although small technological differences exist, these products have similar product characteristics for use in radiotherapy and further detailed information is included in Substantial Equivalence Discussion of this submission.
Performance Data VII.
Hardware and software verification and validation testing was conducted according to the FDA Quality System Regulation (21 CFR $820), ISO 13485 quality Management System standard, ISO 14971 Risk Management Standard and the other FDA recognized consensus standards listed below. Test results showed conformance to applicable requirements specifications.
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Image /page/10/Picture/0 description: The image shows a logo for Panacea Engineering Medicine. The logo features a blue medical cross with a red heartbeat line in the center. Below the cross, the word "PANACEA" is written in red, with the words "Engineering Medicine" in blue underneath.
The non-clinical data support the safety of the device as compared to the predicate and the software verification and validation demonstrate that the subject device with additional RFA feature performs as intended. Panacea therefore considers the SIDDHARTH-II to be as safe and effective and to perform at least as well as the predicate devices. The imaging, radiation therapy capabilities of the subject device remain same with the existing 510k cleared device.
Software verification testing was conducted as required by FDA's Guidance for Industry and FDA Staff, "Guidance for the content of Premarket Submissions for Software contained in Medical Devices" as it concludes that the software of the subject device was considered as a "Major" level of concern and also it is in compliance with IEC 62304 Software Life cycle processes.
Electrical safety & electromagnetic (EMC) testing were conducted on the SIDDHARTH-II which verified complies with the IEC/ES 60601-1 standards for safety & IEC 60601-1-2 EMC standard.
Non-clinical performance testing for RFA feature of subject device was performed according to IEC 60731:2016 and to specific properties of Ion chamber (Radiation detector), Electrometer, and water phantom systems which included radiotherapy dose measurements i.e. with step by step measurements and also measurement accuracy with respect to radiation detector, positioning, reproducibility and mechanical alignment.
Standards Conformance
SIDDHARTH-II conforms with the FDA recognized standards and other international standards listed below.
ANSI/AAMI ES60601-1, IEC 60601-1-3, IEC 60601-2-1, IEC 60601-2-68, IEC 60601-1-6, IEC 60601-1-2, IEC 62274, IEC 61217, IEC 62304, ISO 10993-1, ISO 10993-5, ISO 10993-10, IEC 60825-1, IEC 60976, IEC 60731, ISO 15223-1, and ISO 14971
VIII. Clinical Testing
Similar devices have been on the market for many years with proven safety and efficacy for the use of the device. Based on this history and the use of the device, clinical testing was not
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necessary to support substantial equivalence data. The non-clinical testing performed supports safety and efficacy of the devices in comparison to the predicate and provides data to show substantial equivalence to the predicated device.
IX. Conclusion
The results of verification, validation & safety standards testing demonstrates that the modified SIDDHARTH-II complies to the specified safety & performance criteria & it is substantially equivalent to the predicate device which do not raise any new issues on safety & effectiveness.
N/A