(30 days)
Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography.
AcuityDR G4 combines components into a complete digital x-ray system upgrade kit, including software and digital radiography panels. The customer selects one of the following digital x-ray receptor panels: AcuityDR 1013 G4, AcuityDR 1717 G4. The solid state imaging receptors can be used in wireless or tethered configurations for use remain unchanged: Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography. So the only difference between this submission and the predicate submission is the available selection of (previously cleared) digital panels. Each system consists of the following items: Customer supplies: Diagnostic x-ray generator (HF) Class I Code IZO. + Tubehead: Class I Code ITV + Tube Mount: Class I Code IYB + Attached Collimator, Manual (IZX) Class II 510(k) Exempt We supply: Digital X-Ray Receptor Panel 892.1680 Class II Code MQB. Digital X-ray Software 892.2050 Class II Code LLZ. The software offered for sale with this system has received previous 510(k) clearance in K210919. We are supplying rebranded versions of the reference devices coupled with the Acculvue software cleared in our predicate K210919.
I am sorry, but the provided text does not contain the detailed information required to describe the acceptance criteria and the study that proves the device meets those criteria. Specifically, the document is a 510(k) summary for a medical device (AcuityDR G4) and focuses on demonstrating substantial equivalence to a predicate device.
The document discusses performance characteristics of the digital panels (DQE, MTF, resolution) and indicates that clinical image evaluation was performed on the proposed panels by a Board Certified Radiologist who found the images to be of excellent quality. However, it does not provide explicit acceptance criteria, a structured study design with specific metrics, or details about patient data, expert qualifications, or ground truth establishment in the way requested.
Here's a breakdown of why I cannot fulfill your request based on the provided text:
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Table of acceptance criteria and reported device performance: While performance characteristics like DQE and MTF values are reported, these are not presented as acceptance criteria in the context of a specific study to prove the device meets them. There's no clear threshold or target defined that the device needs to achieve to be considered "acceptable" in a formal study sense.
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Sample size used for the test set and data provenance: The document mentions "clinical image evaluation" was performed but does not specify the sample size of images or patients used. It also doesn't provide details on the data's origin (country, retrospective/prospective).
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Number of experts used to establish the ground truth and qualifications: It states "a Board Certified Radiologist" performed clinical image evaluation, implying one expert. However, their specific qualifications (e.g., years of experience, specific sub-specialty) are not provided beyond being "Board Certified." The method for establishing "ground truth" (if any beyond the radiologist's assessment) is not described.
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Adjudication method: Not mentioned.
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Multi-reader multi-case (MRMC) comparative effectiveness study: Not mentioned and typically not required for substantial equivalence claims for this type of device (an X-ray system). The evaluation described is a qualitative assessment of image quality by a radiologist. There is no mention of comparing human readers with and without AI assistance.
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Standalone (algorithm only) performance: Not applicable here as the device is an X-ray system, not an AI algorithm performing diagnostic tasks independently. The software provided is for controlling the X-ray generator and image acquisition, not for diagnostic interpretation.
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Type of ground truth used: The text indicates a "Board Certified Radiologist" evaluated image quality. This suggests expert consensus (though with only one expert mentioned) on image quality, but not pathology or outcomes data.
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Sample size for the training set: Not applicable and not mentioned, as this device itself is not a machine learning algorithm requiring a training set for diagnostic classification.
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How the ground truth for the training set was established: Not applicable.
The document mainly focuses on comparing the AcuityDR G4 system's technological characteristics (like detector DQE, MTF, and resolution) and indications for use to its predicate device (AcuityDRe, K210919) and other reference devices, concluding that the new device is substantially equivalent. The image quality evaluation by the radiologist appears to be a supportive qualitative assessment rather than a structured quantitative study with predefined acceptance criteria.
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July 12, 2023
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 includes a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Radmedix LLC % Daniel Kamm Principal Engineer Kamm & Associates 8870 Ravello Ct NAPLES, FL 34114
Re: K231709
Trade/Device Name: AcuityDR G4 (AcuityDR 1013 G4, AcuityDR 1417 G4, AcuityDR 1717 G4) Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: MQB, LLZ Dated: June 12, 2023 Received: June 12, 2023
Dear Daniel Kamm:
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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about 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 Radiological Imaging Devices and Electronic Products 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) K231709
Device Name AcuityDR G4 (AcuityDR 1013 G4, AcuityDR 1417 G4, AcuityDR 1717 G4)
Indications for Use (Describe)
Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography.
| 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 K231709
Image /page/3/Picture/1 description: The image shows a logo with the text "RadmediX". The "R" and "X" are in blue, while the "admedi" is in a smaller font size and in black. There is a larger, faded "RX" in the background, behind the main text. The logo is simple and modern, with a focus on the company name.
RadmediX, LLC 2510 Lance Rd. Dayton, OH 45409 Tel: 844 723 6334 Registration Number: 3009134655
1. Administrative Information
Reason for Submission: 510(k) Notification for AcuityDR G4 Submitter Submission contact person: Gabriel Issa, Director of Equipment Contact e-mail: gabe@radmedix.com Date prepared: June 9, 2023
ldentification:
Classification Name: Classification Panel: Classification Regulation: Device Class: Product Code:
AcuityDR G4 (AcuityDR 1013 G4, AcuityDR 1417 G4, AcuityDR 1717 G4) Stationary X-Ray System Radiology 21 CFR §892.1680 Class II MQB, LLZ
Substantially equivalent device:
| Trade Name: | AcuityDRe |
|---|---|
| Manufacturer: | RadmediX |
| 510(k) #: | K210919 |
| Classification Name: | Stationary x-ray system |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR §892.1680 |
| Device Class: | Class II |
| Product Code: | MQB, LLZ |
Reference devices:
| K210314 | |
|---|---|
| Trade/Device Name: | Mars1717X Wireless Digital Flat Panel Detector |
| Regulation Number: | 21 CFR 892.1680 |
| Regulation Name: | Stationary x-ray system |
| Regulatory Class: | Class II |
| Product Code: | MQB |
K210316
| Trade/Device Name: | Mars 1417X Wireless Digital Flat Panel Detecto |
|---|---|
| Regulation Number: | 21 CFR 892.1680 |
| Regulation Name: | Stationary x-ray system |
| Regulatory Class: | Class II |
| Product Code: | MQB |
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| K220668 | |
|---|---|
| Trade/Device Name: | Wireless Digital Flat Panel Detector |
| Regulation Number: | 21 CFR 892.1680 |
| Regulation Name: | Stationary X-Ray System |
| Regulatory Class: | Class II |
| Product Code: | MQB |
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- Device description: AcuityDR G4 combines components into a complete digital x-ray system upgrade kit, including software and digital radiography panels. The customer selects one of the following digital x-ray receptor panels: AcuityDR 1013 G4, AcuityDR 1717 G4. The solid state imaging receptors can be used in wireless or tethered configurations for use remain unchanged: Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography. So the only difference between this submission and the predicate submission is the available selection of (previously cleared) digital panels. Each system consists of the following items: Customer supplies: Diagnostic x-ray generator (HF) Class I Code IZO. + Tubehead: Class I Code ITV + Tube Mount: Class I Code IYB + Attached Collimator, Manual (IZX) Class II 510(k) Exempt We supply: Digital X-Ray Receptor Panel 892.1680 Class II Code MQB. Digital X-ray Software 892.2050 Class II Code LLZ. The software offered for sale with this system has received previous 510(k) clearance in K210919. We are supplying rebranded versions of the reference devices coupled with the Acculvue software cleared in our predicate K210919.
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- Indications for Use: Intended for use by a qualified/trained physician or technician on both adult and pediatric subjects for taking diagnostic x-rays. Not for mammography.
| ComparableProperties | AcuityDRe, K210919 | AcuityDR G4 | ComparisonResults |
|---|---|---|---|
| Indications foruse | Intended for use by aqualified/trained physician ortechnician on both adult and pediatricsubjects for taking diagnostic x-rays.Not for mammography. | Intended for use by aqualified/trained physician ortechnician on both adult and pediatricsubjects for taking diagnostic x-rays.Not for mammography. | SAME |
| X-ray Generator | Supplied by User: CPI or Sedecal | Supplied by User: CPI or Sedecal | SAME |
| Software Controlof TechniqueFactor | Possible for certain CPI or SedecalGenerators (Validated previously). Seebelow. | Possible for certain CPI or SedecalGenerators (Validated previously). Seebelow. | SAME |
| Digital X-RayDetectors | AcuityDRe 1417wAcuityDRe 1717wAcuityDRe 1717t | AcuityDR 1013 G4AcuityDR 1417 G4AcuityDR 1717 G4 | SAME |
| PanelPerformance | AcuityDRe 1417w: DQE@ 1.0 lp/mm: 35%; MTF @ 2.0 lp/mm: 31% | AcuityDR 1013 G4: DQE@ 1.0 lp/mm: 51%; MTF @ 2.0 lp/mm: 38% | Similar but betterresults |
| AcuityDRe 1717w/1717t: DQE@ 1.0 lp/mm: 42%; MTF@ 2.0 lp/mm: 38% | AcuityDR 1417 G4: DQE@ 1.0 lp/mm: 55.9%; MTF @ 2.0 lp/mm: 40.4%AcuityDR 1717 G4: DQE@ 1.0 lp/mm: 55.9%; MTF @ 2.0 lp/mm: 40.4% |
4. Technological characteristics: Comparison Table
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| ComparableProperties | AcuityDRe, K210919 | AcuityDR G4 | ComparisonResults |
|---|---|---|---|
| Panel Sizes | AcuityDRe 1417w 148 µmAcuityDRe 1717w 140 µmAcuityDRe 1717t 140 µm | AcuityDR 1013 G4 100 µmAcuityDR 1417 G4 100 μmAcuityDR 1717 G4 100 µm | Similar but higherresolution |
| Operator console | Windows PC using Windows 10-loT | Windows PC using Windows 10-loT | SAME. |
| AcquisitionSoftware | AccuVue | AccuVue | SAME. |
| Power Source | AC Line or rechargeable batteries(wireless models) | AC Line or rechargeable batteries (allmodels) | SAME. |
| Standards | Same as below | Same as below | SAME. |
- Non clinical testing: Testing was performed according to the following standards:
| FDARecognitionNumber | StandardDevelopingOrganization | StandardDesignationNumber And Date | Title Of Standard |
|---|---|---|---|
| 19-4 | IEC | 60601-1:2005/(R)2012And Al:2012 | Medical Electrical Equipment Part 1: General RequirementsFor Basic Safety And Essential Performance (IEC 606011:2005,MOD) |
| 19-8 | IEC | 60601-1-2:2014 | Medical Electrical Equipment Part 12: General RequirementsFor Basic Safety And Essential Performance Collateral Standard:Electromagnetic Disturbances Requirements And Tests |
| 12-342 | NEMA | PS 3.1 - 3.20(2021e) | NEMA Digital Imaging and Communications in Medicine(DICOM) Set |
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- The digital panel software employed was used unmodified from clearance obtained from FDA. The software has previously been validated as a control for CPI and Sedecal diagnostic x-ray generators. Compatible CPI generators: CMP 200 Series. Compatible Sedecal generators: SFHR and SHF Series. In recognition of possible cybersecurity threats to the software, we consulted this guidance: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff. As a result, we updated our own internal standard operating procedures and added cybersecurity precautions to the software users' manuals. In recognition of FDA pediatric concerns, we reviewed the FDA guidance: Pediatric Information for X-ray Imaging Device Premarket Notifications Guidance for Industry and Food and Drug Administration Staff and created labeling to comply with this guidance. In recognition of FDA's concerns about wireless performance we reviewed the FDA guidance: Radio Frequency Wireless Technology in Medical Devices Guidance for Industry and Food and Drug Administration Staff. Both the predicate and subject devices use the same wireless technology, standard Wi-Fi using FCC approved off the shelf components. Since three new digital receptor panels have had previous FDA clearance, imaging performance testing had previously been performed. Clinical image evaluation was performed on the proposed panels by a Board Certified Radiologist. The images were found to be of excellent quality.
Performance characteristics are as follows:
- The digital panel software employed was used unmodified from clearance obtained from FDA. The software has previously been validated as a control for CPI and Sedecal diagnostic x-ray generators. Compatible CPI generators: CMP 200 Series. Compatible Sedecal generators: SFHR and SHF Series. In recognition of possible cybersecurity threats to the software, we consulted this guidance: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff. As a result, we updated our own internal standard operating procedures and added cybersecurity precautions to the software users' manuals. In recognition of FDA pediatric concerns, we reviewed the FDA guidance: Pediatric Information for X-ray Imaging Device Premarket Notifications Guidance for Industry and Food and Drug Administration Staff and created labeling to comply with this guidance. In recognition of FDA's concerns about wireless performance we reviewed the FDA guidance: Radio Frequency Wireless Technology in Medical Devices Guidance for Industry and Food and Drug Administration Staff. Both the predicate and subject devices use the same wireless technology, standard Wi-Fi using FCC approved off the shelf components. Since three new digital receptor panels have had previous FDA clearance, imaging performance testing had previously been performed. Clinical image evaluation was performed on the proposed panels by a Board Certified Radiologist. The images were found to be of excellent quality.
AcuityDR 1013 G4: DQE@ 1.0 lp/mm:0.51; MTF @ 2.0 lp/mm: 0.38
AcuityDR 1417 G4: DQE@ 1.0 lp/mm:0.55; MTF @ 2.0 lp/mm: 0.40
AcuityDR 1717 G4 : DQE@ 1.0 lp/mm:0.55; MTF @ 2.0 lp/mm: 0.40
All proposed compatible generators carry NRTL listing labels, having been tested for safety. Validation of proper generator technique control had been previously performed. Each system is tested for proper integration prior to shipment to the customer. Since multiple configurations are available (generator and panel models), our service engineers fully test each new system upon installation at the customer site
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- 7 . Clinical testing. Not required for a determination of substantial equivalence.
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- Substantial Equivalence Discussion. When combined with a compatible generator/Tubestand combination the AcuityDR G4 performs the same functions as the predicate using the same technological methods to produce diagnostic x-ray images. In all material aspects, the AcuityDRe systems and the AcuityDR G4 systems are substantially equivalent to each other.
9. Substantial Equivalence Conclusion:
After analyzing bench test results, risk analysis, and clinical evaluation, it is the conclusion of RadmediX LLC that the AcuityDR G4 series of upgrade kits are as safe and effective as the predicate device, has few technological differences, and has the same indications for use, thus rendering it substantially equivalent to the predicate device.
§ 892.1680 Stationary x-ray system.
(a)
Identification. A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.