K Number
K231660
Date Cleared
2023-12-20

(196 days)

Product Code
Regulation Number
872.1800
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Digital image scanner of dental is intended to be used for scanning and processing digital images exposed on IP Imaging Plate in dental applications.

Device Description

Digital image scanner of dental is a dental device that scans IP Imaging plates that have been exposed in place of dental X-ray film and allows the resulting images to be displayed on the screen and stored for later recovery. It will be used by licensed clinicians and authorized technicians for this purpose. The device is an intraoral Plate Scanner, which is designed to read out intraoral Plates of the size S0, S1, S2 and S3. The intraoral plates are put into the mouth of the patient, exposed to X-rays and then are read out with the device. The read-out-process is carried out with 630-645 nm laser. The laser beam is moved across the surface of the plate by an oscillating mirror. The laser beam stimulates the top coating of the plates, which consists of X-rays sensitive material. Depending on the exposed dose, the coating emits different levels of light. These light particles are then requisitioned by an optical sensor (Photo Multiplier tube/ PMT) and transferred into an electrical output signal. This signal is digitalized and is the data for the digital X-ray image. Before the plate is discharged, the remaining data is erased by a LED-PCB. The user chooses which size of plate he must use and prepares the device by inserting the appropriate plate insert into the device. He then exposes the plate and then puts the plate directly into the insert by pushing it out of the light protection envelope. The user closes the light protection over and starts the read-out process. After the read out process the picture is transmitted to the screen, the picture can be viewed, and the IP is erased and ready to use for the next acquisition.

AI/ML Overview

The provided document is a 510(k) summary for a dental image scanner. It describes the device, compares it to a predicate device, and outlines the non-clinical testing performed to demonstrate substantial equivalence. However, it does not contain a detailed study proving the device meets specific acceptance criteria in the way medical imaging AI/CAD performance studies typically do, nor does it refer to a multi-reader multi-case (MRMC) study. The testing described focuses on device performance characteristics rather than diagnostic accuracy with human readers.

Therefore, many of the requested criteria cannot be directly extracted from this document, as they pertain to clinical or human performance studies, which are explicitly stated as "not required for this submission."

Here's the information that can be extracted or inferred, with explanations for what cannot be found:

1. Table of Acceptance Criteria and Reported Device Performance

The document doesn't present a formal table of general acceptance criteria with performance results in the context of diagnostic accuracy. Instead, it lists technical performance tests and states that the "Imaging standard requirements were met" and "Laser products have passed safety test."

Acceptance Criteria CategorySpecific Test/Parameter (if applicable)Reported Device Performance
Electrical SafetyIEC 60601-1Passed (does not raise questions about safety effectiveness)
Electromagnetic CompatibilityIEC 60601-1-2Passed (does not raise questions about safety effectiveness)
Imaging PerformanceImaging standard requirements (dental X-ray), IEC 61223-3-4Met X-ray equipment imaging standard requirements
Laser SafetyIEC 60825-1Passed safety test
Software Verification & ValidationFDA Guidance for Software in Medical DevicesAll functions supporting system specification are proper; verification and validation properly accomplished.
Image Plate TestImaging area, degree of attenuation, uniformity, image contrast, bit depth, spatial resolution/MTFVerified by testing
Image Accuracy & Fidelity TestAccuracy, uniformity, image contrast, spatial resolution/MTF, image fidelityVerified by testing
Theoretical ResolutionsNot explicitly an acceptance criterion, but mentioned17 LP/mm (compared to predicate's 10 or 33 LP/mm)
MTF (Modulation Transfer Function)Not explicitly an acceptance criterion, but mentionedMore than 45% at 3 lp/mm
DQE (Detective Quantum Efficiency)Not explicitly an acceptance criterion, but mentionedMore than 21.0% at 3 lp/mm

2. Sample size used for the test set and the data provenance

  • Sample Size for Test Set: Not specified. The document refers to "image plates test" and "image accuracy and fidelity test," which are laboratory/technical performance tests, not clinical performance tests with a specific patient dataset.
  • Data Provenance: Not applicable, as no patient data (images from humans) was used for performance testing (clinical testing was not required). The tests appear to be conducted on the device itself using phantom or test patterns.
  • Retrospective/Prospective: Not applicable.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

  • This information is not provided because diagnostic ground truth from expert readers was not established or used, as clinical testing was not required. The "ground truth" for the technical tests would be the known properties of the phantoms/test patterns used.

4. Adjudication method for the test set

  • Not applicable, as no expert reading or adjudication of diagnostic findings was involved.

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. The document explicitly states under section 7, "Clinical Testing: Clinical testing was not required for this submission." This type of study would fall under clinical testing.
  • Effect Size: Not applicable as no such study was performed.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

  • The device is a hardware scanner, not an AI/CAD algorithm. The "Image Reading and Checking Testing" falls under standalone performance, as it assesses the device's ability to accurately scan and process images. However, this is about the quality of the image output from the scanner, not the diagnostic performance of an AI algorithm on those images.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

  • For the technical performance tests ("Image Reading and Checking Testing"), the ground truth would be established by the known characteristics of the test patterns, phantoms, and calibrated equipment used for measurement. It is not expert consensus, pathology, or outcomes data, as these relate to clinical diagnostic accuracy, which was not assessed.

8. The sample size for the training set

  • Not applicable. This device is a scanner, not an AI or machine learning algorithm that requires a training set. The "software verification and validation testing" refers to typical software engineering V&V processes, not machine learning model training.

9. How the ground truth for the training set was established

  • Not applicable, as there is no training set for this device (it's not an AI/ML algorithm).

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December 20, 2023

Jiangsu Dynamic Medical Technology Co., Ltd. % Doris Dong General Manager Shanghai CV Technology Co., Ltd. Room 602, No. 19 Dongbao Road, Songjiang Area SHANGHAI, SHANGHAI 201613 CHINA

Re: K231660

Trade/Device Name: Digital image scanner of dental Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral Source X-Ray System Regulatory Class: Class II Product Code: MUH Dated: November 20, 2023 Received: November 24, 2023

Dear Doris Dong:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

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Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Lu Jiang

Lu Jiang, Ph.D. Assistant Director Diagnostic X-Ray Systems Team DHT8B: Division of Radiologic Imaging Devices and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Indications for Use

510(k) Number (if known) K231660

Device Name Digital image scanner of dental

Indications for Use (Describe)

Digital image scanner of dental is intended to be used for scanning and processing digital images exposed on IP Imaging Plate in dental applications.

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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510(k) Summary [As required by 21 CFR 807.92]

1. Submission Information

510(k) Number:K231660
Date:December 08, 2023
Type of 510(k) Submission:Traditional 510(k)
Basis for 510(k) Submission:New device
Owner:JIANGSU DYNAMIC MEDICAL TECHNOLOGY CO., LTD.No.108 Xingpu Road, Lujia Town, Kunshan, Suzhou, Jiangsu, China215331Tel: 86-512-82627666Email: technic2@dynamicgroup.cn
Contact:Doris Dong[Consultant, from Shanghai CV Technology Co., Ltd.]Add: Room 602, No. 19 Dongbao Road, Songjiang Area, Shanghai, 201613ChinaE-mail: doris.d@ceve.org.cnTel: 86 21-31261348 / Fax: 86 21-57712250

2. Device Description

Proprietary Name:Digital image scanner of dental
Model:DDT-100, DDT-100C, DDT-200, DDT-200C
Common Name:Extraoral source x-ray system
Classification Name:Extraoral source x-ray system
Regulation Number:21 CFR 872.1800
Product Code:MUH
Device Class:2
Review Panel:Radiology
Device Description:Digital image scanner of dental is a dental device that scans IP

maging plates that have been exposed in place of dental X-ray film and allows the resulting images to be displayed on the screen and stored for later recovery. It will be used by licensed clinicians and authorized technicians for this purpose. The device is an intraoral Plate Scanner, which is designed to read out intraoral Plates of the size S0, S1, S2 and S3. The intraoral plates are put into the mouth of the patient, exposed to X-rays and then are read out with the device. The read-out-process is carried out with 630-645 nm laser. The laser beam is moved across the surface of the plate by an oscillating mirror. The laser beam stimulates the top coating of the plates, which consists of X-rays sensitive material. Depending on the exposed dose, the coating emits different levels of light. These light particles are then requisitioned by an optical sensor (Photo Multiplier tube/ PMT) and transferred into an electrical output signal. This signal is digitalized and is the data for the digital X-ray image. Before the plate is discharged, the remaining data is erased by a LED-PCB. The user chooses which size of plate he must use and prepares the device by inserting the appropriate plate

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insert into the device. He then exposes the plate and then puts the plate
directly into the insert by pushing it out of the light protection envelope.
The user closes the light protection over and starts the read-out process.
After the read out process the picture is transmitted to the screen, the
picture can be viewed, and the IP is erased and ready to use for the next
acquisition.
Indications for use:Digital image scanner of dental is intended to be used for scanning and
processing digital images exposed on IP Imaging Plate in dental
applications.

3. Predicate Device Information

Predicate 510(k) Number:K212080
Marketing clearance date:27/09/2021
Product name:i-Scan Imaging Plate Scanner
Manufacturer:Guilin Woodpecker Medical Instrument Co., Ltd.
ParametersNew DevicePredicate DeviceComparison
510(k) numberK231660K212080--
SubmitterJIANGSU DYNAMICMEDICAL TECHNOLOGYCO.,LTD.Guilin Woodpecker MedicalInstrument Co., Ltd.--
Device nameDigital image scanner of dentali-Scan Imaging Plate Scanner--
ModelDDT-100,DDT-100C,DDT-200,DDT-200Ci-Scan--
Regulation number21 CFR 872.180021 CFR 872.1800Same
Device classIIIISame
Product codeMUHMUHSame
Classification nameExtraoral source x-ray systemExtraoral source x-ray systemSame
Indications for useDigital image scanner of dentalis intended to be used forscanning and processing digitalimages exposed on IP ImagingPlate in dental applications.i-Scan Imaging Plate Scanner isintended to be used for scanningand processing digital imagesexposed on IP Imaging Plate indental applications.Same
Prescription UseYesYesSame
Site of UseHospitals and clinicsHospitals and clinicsSame
Intended userOperated and used by trainedprofessionals with physician'sguidanceOperated and used by trainedprofessionals with physician'sguidanceSame
SterileNon-SterileNon-SterileSame
Product Dimension(HWD)DDT-100,DDT-100C:365262287mmDDT-200,DDT-200C:320170384mm138245.5290.2mmSimilarNote 1
Product WeightDDT-100,DDT-100C:9.3kgDDT-200.DDT-200C:9.3kg4.5kg
Mechanical designThe exposed and unwrapped plates are scanned using a laser with a certain wavelength of 630-645 nm. The scan pattern is line by lineThe exposed and unwrapped plates are scanned using a laser with a certain wavelength of 651-665 nm. The scan pattern is line by line.Similar Note 2
Electrical designLight with a wavelength of approximately 380 nm is from the plate in proportion to the number of captured x-ray photons. This light is collected and formed into an image that may be viewed on a video display and stored for later recovery in a computer memory.Light with a wavelength of approximately 380 nm is from the plate in proportion to the number of captured x-ray photons. This light is collected and formed into an image that may be viewed on a video display and stored for later recovery in a computer memory.Same
Viewing the imageThe touch screen only shows a preview which serves to provide an initial impression of the final x-ray image. For the purposes of diagnosis, the x-ray image must be viewed on a diagnostic monitor. The scanned images are displayed on an internal LCD or an external monitor using a computer and user software including image storage, retrieval and manipulation.The touch screen only shows a preview which serves to provide an initial impression of the final x-ray image. For the purposes of diagnosis, the x-ray image must be viewed on a diagnostic monitor. The scanned images are displayed on an internal LCD or an external monitor using a computer and user software including image storage, retrieval and manipulation.Same
Image scanningLaser/Photomultiplier TubeLaser/Photomultiplier TubeSame
Erasing the residual image following scanning for plate reuseThe residual image is erased in the scanner by an inline erasing function.The residual image is erased in the scanner by an inline erasing function.Same
Transport/feed mechanism of imaging plateThe Plate realizes transmission movement through a conveyor belt, and the movement of the laser and the IP image board provides two orthogonal scanning directions.The Plate realizes transmission movement through a conveyor belt, and the movement of the laser and the IP image board provides two orthogonal scanning directions.Same
Imaging plate sizeS0:22×35 mmS1:24×40 mmS2:31×41 mmS3:27×54 mmSize 0: 22×35 mmSize 1: 24×40 mmSize 2: 31×41 mmSize 3: 27×54 mmSame
Image data bit depth16 bits16 bitsSame
Contact body siteThe device does not directly contact with human body or organ.The device does not directly contact with human body or organ.Same
Patient ContaminationSingle patient use barrierSingle patient use barrierSame
preventionenvelope encloses the imaging plate while in the patient's mouth.envelope encloses the imaging plate while in the patient's mouth.
Electronic UserManualUser manual is provided in printed form to the user.User manual is provided in printed form to the user.Same
Image QualityTheoretical resolutions: 17 LP/mmTheoretical resolutions: 10 or 33 LP/mmSimilarNote 3
RFIDNoNoSame
MTFMore than 45% at 3 lp/mmMore than 45% at 3 lp/mmSame
DQEMore than 21.0% at 3 lp/mmMore than 21.0% at 3 lp/mmSame
Software/Firmware/MicroprocessorControl?Digital Image Scanner Of DentalAir-dental-woodpeckerSimilarNote 4
External power source100 to 240VAC, 50/60 Hz100 to 240VAC, 50/60 HzSame
Compliance standardsANSI AAMI ES60601-1IEC 60601-1-2IEC 61223-3-4IEC 60825-1ANSI AAMI ES60601-1IEC 60601-1-2IEC 62220-1IEC 61223-3-4IEC 60825-1IEC 61010-1SimilarNote 5
PictureImage: DDT-100, DDT-100C, DDT-200, DDT-200CImage: ScannerSimilarNote 1
LabelingMeet FDA's requirementMeet FDA's requirementSame

4. Comparison to predicate device

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Differences between New device and Predicate Device:

Note 1:

The weight, dimensions and appearance of the proposed device differ slightly from the predicate device,depending on the design and sales requirements of these differences are insignificant in terms of safety or effectiveness.

Note 2:

The operating principle of scanning the image plates with a laser of approximately the same wavelength,both the proposal device and the predicate device scans the plates with a line-by-line pattern. The scans collect the same data and process this for visual imaging. They support the same indications for use; the differences in the mechanical design does not raise issues of safety and effectiveness.

Note 3:

The subject device displays theoretical resolutions of 17-Line Pairs per mm, whereas the predicate shows theoretical resolutions of 10- or 33-Line Pairs per mm. And the image resolution of the proposed device is between the image resolution of the predicate device. The differences do not affect the operating principle and the Image Quality distinctness is such that it does not affect the effectiveness of the device. Note 4:

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The software is not the same between the subject device and the predicate, but both the subject and predicate have followed the FDA Guidance for the Content of Premarket for Submissions for Software Contained in Medical Devices.

Note 5:

According to the latest requirements, IEC 6220-1 is not applicable to digital X-ray imaging equipment for dental radiography. IEC 61010-1 is the test for laboratory equipment, we have done the test for ANSI AAMI ES60601-1, the standard is more stringent than IEC 61010-1.Other tests are the same as the predicate equipment, so it does not cause safety problems.

5. Summary of Non-clinical Testing

The safety and effectiveness of the Digital image scanner of dental were established and the substantial equivalence determination was supported by a series of performance testing, including Electrical safety and electromagnetic compatibility (EMC), Software Verification Testing, image reading and checking testing.

Electrical safety and electromagnetic compatibility (EMC)

General Requirements For Basic Safety And Essential Performance:This product has passed the IEC 60601-1 test and does not raise questions about safety effectiveness.

General Requirements For Basic Safety And Essential Performance -- Collateral Standard: Electromagnetic Disturbances -- Requirements And Tests:This product has passed the IEC 60601-1-2 test and does not raise questions about safety effectiveness.

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate devices. The test results demonstrated that the proposed device complies with the following standards:

  1. ANSI AAMI ES60601-1: 2005/(R)2012 And A1:2012, C1:2009(R)2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, MOD);

  2. IEC 60601-1-2:2014, Medical Electrical Equipment -- Part 1-2: General Requirements For Basic Safety And Essential Performance -- Collateral Standard: Electromagnetic Disturbances -- Requirements And Tests;

Performance Testing

Acceptance tests - Imaging performance of dental X-ray:Imaging standard requirements were met for X-ray equipment.

Safety of laser products:Laser products have passed safety test.

  1. IEC 61223-3-4 First edition 2000-03, Evaluation and routine testing in medical imaging departments -Part 3-4: Acceptance tests - Imaging performance of dental X-ray;

  2. IEC 60825-1 Edition 2.0 2007-03, Safety of laser products - Part 1: Equipment classification, and requirements [Including: Technical Corrigendum 1 (2008), Interpretation Sheet 1 (2007), Interpretation Sheet 2 (2007)].

Software Verification and Validation Testing

Software testing and V&V:As a result of unit level test, integration review and system level test, we hereby certify that all the functions those support system specification are proper. We confirm that software verification and validation test is properly accomplished.

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Software verification and 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".

Image Reading and Checking Testing

Regarding image reading and checking testing, we performed image plates test and image accuracy and fidelity test respectively. Image plate test contains imaging area, degree of attenuation, uniformity, image contrast, bit depth and spatial resolution or MTF test, etc..Image accuracy and fidelity test contains accuracy test, uniformity, image contrast,spatial resolution or MTF test,and image fidelity test. The accuracy of image reading and checking results was verified by above testing.

6. Animal Study

Animal testing was not required for this submission.

7. Clinical Testing

Clinical testing was not required for this submission.

8. Substantial Equivalent (SE) Conclusion

Based upon comparison to the predicate devices, the proposed device is Substantial Equivalent (SE) to the predicate devices.

§ 872.1800 Extraoral source x-ray system.

(a)
Identification. An extraoral source x-ray system is an AC-powered device that produces x-rays and is intended for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures. The x-ray source (a tube) is located outside the mouth. This generic type of device may include patient and equipment supports and component parts.(b)
Classification. Class II.