(129 days)
The Xstrahl Photoelectric Therapy System is a low energy X-Ray system intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
Typical applications include treatment for Basal Cell Carcinoma, Squamous Cell Carcinoma, Metatypic Carcinoma, Cutaneous Appendage Carcinoma, Karposi's Sarcoma, Merkel Cell Carcinoma, Lentigo Maligna, Lentigo Maligna Melanoma, Cutaneous Lymphomas (B and T cell) and Keloids.
The X80 / RADiant / Photoelectric Therapy System (hereafter referred to as the RADiant System) is a compact and ergonomic superficial X-Ray therapy system operating in the 10kV to 80kV range intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
The RADiant System is a standalone X-Ray radiation therapy system consisting of the X-Ray Therapy Unit, a TP2 Central Control Unit (CCU), a Control POD (Control POD), and a PC on which user interface software is loaded. The system has a time-based control system used with treatment filters and applicators. A range of bespoke treatment applicators and beam filters are available for use with the RADiant System.
The system is freestanding, self-contained, unobtrusive, compact and ergonomic in design, which helps to ensure a reassuring and stress-free patient experience. The system is floor mounted in order to accommodate almost any clinical space, and features ergonomically designed controls ensuring smooth adjustment and safe, simple patient set-up. The system requires connection to the clinical facilities electrical supply and room interlocks.
The Xstrahl Photoelectric Therapy System (RADiant Aura) is a low energy X-Ray system intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
Here’s an analysis of the provided information regarding its acceptance criteria and the study:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to a predicate device rather than detailing specific acceptance criteria for performance metrics in a clinical study. The "acceptance criteria" here are generally understood as meeting design requirements, mitigating risks, and conforming to relevant standards, which are evaluated through non-clinical testing.
| Acceptance Criteria Category | Specific Criteria (Inferred from documentation) | Reported Device Performance |
|---|---|---|
| Functionality & Design | Device functionality works as per intended use. | Successfully demonstrated through 26 independent verification tests and 18 independent validation tests. These included tests for: applicator/filter retention during motion, residual motion, power loss response, system stability, radiation leakage, and component/system build. |
| Software Performance | Software runs successfully and without changes from predicate. | Software run-through functionality test completed successfully. The software versions (Concerto 2.3, Fisica 1.06, TP2 1.24) used in the predicate device work without changes with RADiant Aura. |
| Positioning Accuracy | Ability to position the treatment head for different patient positions (laying/seated) is not affected by design changes. | Testing confirmed that the ability to position the treatment head was not affected by design changes. |
| Dose Reproducibility | Dose reproducibility meets standards. | Determined successfully in accordance with BS EN 60601-2-8:2015+A1:2016 clause 201.10.1.2.112 ('Agreement between indicated values and effective values'). |
| Output Measurements | Output measurements meet recognized codes of practice. | Independent output measurements completed successfully at National Physics Laboratory UK (NPL) as per Xstrahl Customer Acceptance Test procedure and verified compliance with AAPM (2001) and IPEMB (1996) protocols. |
| Safety and Effectiveness | No new issues of safety or effectiveness are raised compared to the predicate device. | The detailed comparison with the predicate device and the successful completion of all verification and validation tests support this. The device conforms to applicable sections of standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-8, IEC 60601-1-6, IEC 62366, IEC 62304, ISO 14971). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated as a "test set" in the context of clinical data. The testing described largely involves non-clinical (engineering and technical) verification and validation. This means the "sample size" would refer to the number of devices or components tested. The document mentions "Twenty Six independent verification tests and 18 independent validation tests were executed on the RADiant Aura systems." This implies that at least one, but likely a limited number (e.g., prototype or production units), of RADiant Aura systems were subjected to these tests.
- Data Provenance: This information refers to the origin of the data. Since the testing is non-clinical, the data provenance is primarily from internal testing conducted by Xstrahl Ltd. and independent testing by the National Physics Laboratory UK (NPL). The context is purely technical performance evaluation, not clinical outcomes from human patients. The data is prospective in the sense that it was generated specifically for this submission to verify the new design. There is no mention of country of origin of clinical data, as no clinical data is presented.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This section is not applicable as the document describes non-clinical performance and safety testing, not a clinical study requiring expert-established ground truth for a test set (e.g., image interpretation or disease diagnosis). The "ground truth" here is adherence to engineering specifications, safety standards, and physical laws, verified by technical measurements and evaluations.
4. Adjudication Method for the Test Set
This is not applicable as the document describes non-clinical performance and safety testing. Adjudication methods are typically used in clinical studies when multiple human readers evaluate data, and their assessments need to be reconciled to establish a ground truth.
5. 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, an MRMC comparative effectiveness study was not done. This device is an X-Ray radiation therapy system, not an AI diagnostic or assistance tool. The submission focuses on the safety and performance of the hardware and software for delivering radiation therapy, not on interpreting medical images or assisting human readers in diagnosis.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This question is not directly applicable in the context of this device. The "algorithm" in this case refers to the embedded software and control systems of the radiation therapy device. The non-clinical testing described (e.g., software run-through functionality test, dose reproducibility) effectively evaluates the "standalone" performance of these systems in meeting their intended technical specifications, without direct human intervention in the treatment delivery process once programmed. However, the device itself is a treatment device, not a diagnostic algorithm.
7. The Type of Ground Truth Used
For the non-clinical testing, the "ground truth" used was based on:
- Engineering specifications and design requirements: The device was tested against its defined operational parameters and expected performance.
- International and national standards: Compliance with standards like BS EN 60601-2-8, IEC 60601-1, etc., served as the ground truth for safety, electrical performance, usability, and software lifecycle.
- Recognized codes of practice: For output measurements, protocols from AAPM (2001) and IPEMB (1996) were used as the benchmark for accurate dose delivery.
8. The Sample Size for the Training Set
There is no mention of a training set in the document. This is because the device is not an AI/ML-based diagnostic or predictive algorithm that typically requires large datasets for training. The software components mentioned (Concerto, Fisica, TP2) appear to be control software and firmware for the device's operation, not machine learning models.
9. How the Ground Truth for the Training Set Was Established
This is not applicable as there is no training set for an AI/ML model mentioned in the context of this device.
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July 13, 2023
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Xstrahl Ltd. % Vineet Gupta Technical Director Unit 2 Maybrook Industrial Estate Maybrook Road Brownhills. West Midlands WS8 7DG UNITED KINGDOM
Re: K230611
Trade/Device Name: X80 / RADiant / PhotoElectric Therapy System (RADiant Aura) Regulation Number: 21 CFR 892.5900 Regulation Name: X-Ray radiation therapy system Regulatory Class: Class II Product Code: JAD Dated: March 3, 2023 Received: March 6, 2023
Dear Vineet Gupta:
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
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Image /page/1/Picture/5 description: The image shows a digital signature. The signature is for Lora D. Weidner. The date of the signature is 2023.07.13, and the time is 11:10:11 -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) K230611
Device Name
X80 / RADiant / Photoelectric Therapy System (RADiant Aura)
Indications for Use (Describe)
The Xstrahl Photoelectric Therapy System is a low energy X-Ray system intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
Typical applications include treatment for Basal Cell Carcinoma, Squamous Cell Carcinoma, Metatypic Carcinoma, Cutaneous Appendage Carcinoma, Karposi's Sarcoma, Merkel Cell Carcinoma, Lentigo Maligna, Lentigo Maligna Melanoma, Cutaneous Lymphomas (B and T cell) and Keloids.
| 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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| Xstrahl Ltd Unit 2 Maybrook Industrial Estate Maybrook Road, Brownhills, West Midlands, WS8 7DG United Kingdom T +44 (0)1543 688920 E support@xstrahl.com
Xstrahl.com
510(K) SUMMARY K230611
A. SUBMITTERS NAME
Xstrahl Ltd.
FDA Establishment Registration No. 3004561814
B. ADDRESS
Unit 2, Maybrook Industrial Estate Maybrook Road Brownhills, West Midlands WS8 7DG United Kingdom
C. CONTACT
| Name: | Vineet Gupta, Ph.D. |
|---|---|
| Designation: | Technical Director |
| Phone: | (412) 320 5048 |
| Email: | vineetgupta@xstrahl.com |
D. DATE PREPARED:
3-March-2023
E. DEVICE NAME:
| Device Trade Name: | X80 / RADiant / PhotoElectric Therapy System |
|---|---|
| Classification Name: | X-Ray Radiation Therapy System |
| Model / Market Name: | RADiant Aura |
F. DEVICE CLASS:
| Device Class: | II |
|---|---|
| Panel: | Radiology |
| Product Code: | JAD |
| Regulation Number: | 21CFR 892.5900 |
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G. PREDICATE DEVICES:
X80 / RADiant / PhotoElectric Therapy System (K172080)
H. STATEMENT ON INDICATIONS FOR USE:
The intended use and indications for use of the system have not changed due to the modification to the product. The modification has not changed the fundamental operating principle of the product.
Intended Use
The Xstrahl Photoelectric Therapy System is a low energy X-Ray system intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
Indications for Use
The Xstrahl Photoelectric Therapy System is a low energy X-Ray system intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
Typical applications include treatment for Basal Cell Carcinoma, Squamous Cell Carcinoma, Metatypic Carcinoma, Cutaneous Appendage Carcinoma, Karposi's Sarcoma, Merkel Cell Carcinoma, Lentigo Maligna, Lentigo Maligna Melanoma, Cutaneous Lymphomas (B and T cell) and Keloids.
DEVICE DESCRIPTION: I.
The X80 / RADiant / Photoelectric Therapy System (hereafter referred to as the RADiant System) is a compact and ergonomic superficial X-Ray therapy system operating in the 10kV to 80kV range intended for superficial radiotherapy and surface electronic brachytherapy treatment of primary malignant epithelial neoplasms of the skin and keloids.
The RADiant System is a standalone X-Ray radiation therapy system consisting of the X-Ray Therapy Unit, a TP2 Central Control Unit (CCU), a Control POD (Control POD), and a PC on which user interface software is loaded. The system has a time-based control system used with treatment filters and applicators. A range of bespoke treatment applicators and beam filters are available for use with the RADiant System.
The system is freestanding, self-contained, unobtrusive, compact and ergonomic in design, which helps to ensure a reassuring and stress-free patient experience. The system is floor mounted in order to accommodate almost any clinical space, and features ergonomically designed controls ensuring smooth adjustment and safe, simple patient set-up. The system requires connection to the clinical facilities electrical supply and room interlocks.
The system is intended for use within a hospital or other clinical environment where the patient is treated under 'outpatient' conditions by trained medical professionals only e.g. Radiographers, Clinicians and Oncologists. It is not intended for use by a patient or general public. The clinical environment typically consists of a safety-interlocked lead lined shielded Treatment Room housing the X-Ray Therapy Unit, the TP2 Central Control Unit and an Emergency Stop Button, with a Control Room housing the Control POD
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and the PC. Door interlocks and warning lights are located at the access point to the treatment room. The operator is located outside the treatment room during the treatment process.
J. PREDICATE DEVICE INFORMATION:
The RADiant Aura system is substantially equivalent to its primary predicate device RADiant (K172080; Decision Date: 29-September-2017).
The fundamental scientific technology of the RADiant Aura System with respect to its predicate device (RADiant system) has not changed. The intended use and indications for use of the device have not changed. Based upon the performance testing results for RADiant Aura (as detailed in the submission), the system raises no new issues of safety or effectiveness.
K. COMPARISON TO THE PREDICATE DEVICE:
This section provides the summary of comparison of the RADiant Aura system to its predicate device.
| Sr. No. | ComparisonItem | Subject DeviceRADiant Aura (X80 / RADiant /Photoelectric Therapy System)(K230611) | Predicate DeviceX80 / RADiant / PhotoelectricTherapy System(K172080) |
|---|---|---|---|
| 1. | Intended Use | The Xstrahl Photoelectric TherapySystem is a low energy X-Ray systemintended for superficial radiotherapyand surface electronic brachytherapytreatment of primary malignantepithelial neoplasms of the skin andkeloids. | The Xstrahl Photoelectric TherapySystem is a low energy X-Ray systemintended for superficial radiotherapyand surface electronic brachytherapytreatment of primary malignantepithelial neoplasms of the skin andkeloids. |
| 2. | Indications forUse | The Xstrahl Photoelectric TherapySystem is a low energy X-Ray systemintended for superficial radiotherapyand surface electronic brachytherapytreatment of primary malignantepithelial neoplasms of the skin andkeloids. | The Xstrahl Photoelectric TherapySystem is a low energy X-Ray systemintended for superficial radiotherapyand surface electronic brachytherapytreatment of primary malignantepithelial neoplasms of the skin andkeloids. |
| Typical applications include treatmentfor Basal Cell Carcinoma, SquamousCell Carcinoma, Metatypic Carcinoma,Cutaneous Appendage Carcinoma,Karposi's Sarcoma, Merkel CellCarcinoma, Lentigo Maligna, LentigoMaligna Melanoma, CutaneousLymphomas (B and T cell) andKeloids. | Typical applications include treatmentfor Basal Cell Carcinoma, SquamousCell Carcinoma, Metatypic Carcinoma,Cutaneous Appendage Carcinoma,Karposi's Sarcoma, Merkel CellCarcinoma, Lentigo Maligna, LentigoMaligna Melanoma, CutaneousLymphomas (B and T cell) andKeloids. | ||
| 3. | FDA ProductCode | JAD | JAD |
| Sr. No. | ComparisonItem | Subject DeviceRADiant Aura (X80 / RADiant /Photoelectric Therapy System)(K230611) | Predicate DeviceX80 / RADiant / PhotoelectricTherapy System(K172080) |
| 4. | FDA Class | II | II |
| 5. | FDAClassificationName | X-Ray Radiation Therapy System | X-Ray Radiation Therapy System |
| 6. | FDA RegulationNumber | 21CFR 892.5900 | 21CFR 892.5900 |
| 7. | Physical Characteristics | ||
| 7a. | Basic Design | Base unit, with 4 lockable wheels,contains the x-ray generator and cooler.X-Ray tube head is mounted on asupport arm that is mounted on the baseunit. | Base unit, with 4 lockable wheels,contains the x-ray generator andcooler. X-Ray tube head is mountedon a support arm that is mounted onthe base unit. |
| 7b. | Base UnitDimension | 52 cm (D) x 57 cm (W) x 55 cm (H) | 52 cm (D) x 57 cm (W) x 55 cm (H) |
| 7c. | CCU Dimension | 28 cm (W) x 140 cm (H) x 170 cm (D) | 28 cm (W) x 140 cm (H) x 170 cm (D) |
| 7d. | POD Dimension | 20 cm (W) x 7.5 cm (H) x 150 cm (D) | 20 cm (W) x 7.5 cm (H) x 150 cm (D) |
| 8. | ARM Specifications | ||
| 8a. | Maximum WeightSupported | 8 kg | 4.5 kg |
| 8b. | Rotation about thebase unit | $\pm 95°$(Total rotation is the same withreference to 0 degrees) | $\pm 180°$(Total rotation is the same withreference to 0 degrees) |
| 8c. | Vertical Range | 125.7 cm to -23 cm | 59.5 cm to -23 cm |
| 8d. | Horizontal Range | 8.5 cm to 118 cm | 43 cm to 105 cm |
| 8e. | Number ofelectromagneticbrakes | 2 (1 between vertical arm and base unitand 1 between vertical and horizontalarm) | 2 (1 between vertical arm and base unitand 1 between vertical and horizontalarm) |
| 8f. | Number of gasstruts | 4 (all 4 of them in the vertical arm: twoof them to control the vertical armmotion and two of them to control thehorizontal arm motion) | 2 (one in vertical arm and 1 inhorizontal arm) |
| 9. | X-Ray Tube Head Specifications | ||
| 9a. | X-Ray TubeManufacturer | Varex Imaging | Varex Imaging |
| 9b. | Source Voltage | 10 kV to 80 kV | 10 kV to 80 kV |
| 9c. | Model Number | VF-80 | VF-80 |
| 9d. | Continuous MaxTube Power | 100 W | 100 W |
| 9d. | Rotation of theTube Head | $\pm 110°$ | $\pm 90°$ |
| 9e. | Tilt of the TubeHead | $\pm 45°$ | + 90° to - 15° |
| 9f. | Vertical Motion | 0-1 cm | None |
| 9e. | Number ofElectromechanicalBrakes | 2 (one to control the head rotation andthe other to control the head tilt) | None. This is based on a singlemechanical locking mechanism |
| Sr. No. | Comparison Item | Subject DeviceRADiant Aura (X80 / RADiant /Photoelectric Therapy System)(K230611) | Predicate DeviceX80 / RADiant / PhotoelectricTherapy System(K172080) |
| 9f. | Image of Tube Head and controls | Image: Tube head and controls of RADiant Aura (X80 / RADiant / Photoelectric Therapy System) (K230611)1. Tube head movement handle2. Tube head vertical movement handle3. Movement enable button for arm and head joints movement. Either button can be used.4. LED light ring switch | Image: Tube head and controls of X80 / RADiant / Photoelectric Therapy System (K172080)• Brake Button is the movement enable button for the arm joints movement• Thumb screw is the mechanical locking mechanism for head movement |
| 10. | Image showing arm and head movement labels | Image: Arm and head movement labels of RADiant Aura (X80 / RADiant / Photoelectric Therapy System) (K230611) | Image: Arm and head movement labels of X80 / RADiant / Photoelectric Therapy System (K172080) |
| 11. | Base Unit Components | ||
| 11a. | X-Ray Generator | SpellmanPower: 100 WKV Range: 0 to 80 kVmA Range: 0 to 2 mA | SpellmanPower: 100WKV Range: 0 to 80 kVmA Range: 0 to 2 mA |
| 11b. | Cooling System | Type: Air-cooled water-cooling systemPump: Laing D5-Pump 12V D5-VarioFan: 2 off 120 mm Noctua | Type: Air-cooled water-cooling systemPump: Laing D5-Pump 12V D5-VarioFan: 180mm Silverstone |
| 11c. | Number of PCBs in the Base Unit | 2 | 5 |
| 12. | Applicators | ||
| 12a. | Max Focal Spot Distance (FSD) supported | 10 cm | 10 cm |
| 12b. | Standard Applicator kit | Electronic Brachytherapy: 5 cm FSD (1 cm, 1.5 cm, 2 cm, 3 cm, 4 cm)Superficial Radiation Therapy: 6 cm FSD (1 cm, 1.5 cm, 2 cm, 3 cm, 4 cm) | Electronic Brachytherapy: 5 cm FSD (1 cm, 1.5 cm, 2 cm, 3 cm, 4 cm)Superficial Radiation Therapy: 6 cm FSD (1 cm, 1.5 cm, 2 cm, 3 cm, 4 cm) |
| Sr. No. | ComparisonItem | Subject DeviceRADiant Aura (X80 / RADiant /Photoelectric Therapy System)(K230611) | Predicate DeviceX80 / RADiant / PhotoelectricTherapy System(K172080) |
| 12c. | ApplicatorMaterial | Clear Cast Acrylic (PMMA) | Clear Cast Acrylic (PMMA) |
| 13. | Filters | ||
| 13a. | Filter Material | Aluminum | Aluminum |
| 13b. | Standard Filterthickness | 2.5 mm Al and 1.5 mm Al | 2.5 mm Al and 1.5 mm Al |
| 14. Software | |||
| 14a. | Concerto | Version: 2.3 | Version: 2.3 |
| 14b. | Fisica | Version: 1.06 | Version: 1.06 |
| 14c. | TP2 | Version: 1.24 | Version: 1.24 |
| 15. | System Image | Image: System Image | |
| 16. | Overall SystemArchitecture | Image: Overall System Architecture |
Table 1: Comparison of the Subject Device with Predicate Device
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RADiant Aura contains all the features and components for the system as present in the predicate device. RADiant Aura enhances the design of the arm and the head joint of the system. The similarities and differences are described in detail as part of this submission.
RADiant Aura's (subject device (K230611) fundamental technological characteristics are the same as those of the predicate device (K172080). The x-ray tube (VF-80) and the generator (Spellman) used on both the systems are the same. The control system on the subject device (K230611) and the predicate device (K172080) is also the same. The firmware and the software used on both the devices (predicate (K172080) and subject (K230611)) are also the same. The overall system architecture of both the systems is also the same.
In addition, the target population and the indications for use are similar to that of the predicate device. Any minor differences in the features do not raise any concerns for safety, performance, or effectiveness of the
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device. The characteristics / features of RADiant Aura with respect to the predicate device is described in the comparison chart in the submission.
L. SUMMARY OF TESTING:
Design verification and validation testing was performed to ensure that the device functionality works as per its intended use, all risks are mitigated, is substantially equivalent, and the product conforms to the required standards.
Non-clinical testing, including verification of risk control measures, was completed and detailed results of these tests are included as part of this submission. Twenty Six independent verification tests and 18 independent validation tests were executed on the RADiant Aura systems. These tests included testing the system for its retention of the applicator and filter during various ranges of motion, residual motion of the system, system's response to power loss, system stability testing, radiation leakage testing, build of the individual components and the complete system. Software run-through functionality test was also completed successfully. The versions of the software used in predicate device (K17208) worked without any changes with the RADiant Aura system. Testing was also completed to ensure that the system's ability to position the treatment head to treat different locations while the patient was laying on the bed or was in seated position was not affected by the design changes with respect to the predicate device.
Testing was also completed successfully that determined the dose reproducibility in accordance with BS EN 60601-2-8:2015+A1:2016 clause 201.10.1.2.112 'Agreement between indicated values and effective values.'
In addition, independent output measurements were completed successfully at the National Physics Laboratory UK (NPL) as per Xstrahl Customer Acceptance Test procedure and to verify compliance with the following recognized codes of practice:
- AAPM. (2001). AAPM protocol for 40-300kV x-ray beam dosimetry in radiotherapy and o radiobiology.
- IPEMB. (1996). The IPEMB code of practice for the determination of absorbed dose for x-rays O below 300kV generating potential (0.035 mm Al-4 mm Cu HVL: 10-300kV generating potential).
Conclusion:
The verification and validation results demonstrate that the RADiant Aura system met its design requirements and specifications, is substantially equivalent to its predicate device, and conforms to the applicable sections of standards that includes:
- . IEC 60601-1: Medical Electrical Equipment – General Requirements for basic safety and essential performance
- IEC 60601-1-2: Medical electrical equipment Part 1-2: General requirements for basic safety and . essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
- . IEC 60601-2-8: Medical electrical equipment - Part 2-8: Particular requirements for the safety of therapeutic X-ray equipment operating in the range 10 kV to 1 MV
- IEC 60601-1-6: Medical electrical equipment Part 1-6: General requirements for basic safety and ● essential performance - Collateral standard: Usability
- IEC 62366: Medical devices Part 1: Application of usability engineering to medical devices ●
- IEC 62304: Medical device software Software life cycle processes ●
- ISO 14971: Medical devices Application of risk management to medical devices ●
§ 892.5900 X-ray radiation therapy system.
(a)
Identification. An x-ray radiation therapy system is a device intended to produce and control x-rays used for 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.