K Number
K232325
Device Name
RAYSCAN a-Expert
Manufacturer
Date Cleared
2024-04-18

(259 days)

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

The RAYSCAN a- P, SC, OCL, OCS panoramic X-ray imaging system with Cephalostat is an extra-oral source X-ray system, intended for dental radiographic examination of the teeth, jaw, and oral structures, to include panoramic examinations and implantology and for TMJ studies and cephalometry. Images are obtained using the standard narrow beam technique.

Device Description

RAYSCAN α-Expert (RAYSCAN α-P, SC, OCL, OCS) provides panoramic for scanning teeth, jaw and oral structures. By rotating the C-arm, which houses a high-voltage generator, an all-in-one Xray tube and a detector on each end, panoramic images of oral and maxillofacial structures are obtained byrecombining data scanned from different angles. Functionalities include panoramic image scanning for obtaining images of whole teeth, and a Cephalometric scanning option for obtaining Cephalic images.

AI/ML Overview

The provided text describes a 510(k) premarket notification for the "RAYSAN α-Expert" dental X-ray system. The submission affirms its substantial equivalence to a predicate device, K142058. While it outlines several tests conducted to support this claim, it does not provide explicit acceptance criteria in a table format nor does it detail a specific study with quantitative performance metrics for a direct comparison against such criteria.

Here's a breakdown of the information that can be extracted, and where there are gaps regarding the requested specifics:

1. A table of acceptance criteria and the reported device performance

The document does not provide a table of acceptance criteria with corresponding device performance metrics. Instead, it states that "All test results were satisfactory" for performance (imaging performance) testing conducted according to IEC 61223-3-4. It also mentions that "a licensed practitioner reviewed the sample clinical images and deemed them to be of acceptable quality for the intended use." This indicates a subjective assessment of image quality rather than quantitative performance against defined acceptance criteria.

2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Test Set Sample Size: The document mentions that "images were gathered from all detectors of RAYSCAN α-Expert using protocols with random patient age, gender, and size" and that "Clinical imaging samples were collected from new detectors on the proposed device at the two offices where the predicate device was installed for the clinical test images." However, it does not specify the exact number of images or patients in the clinical test set.
  • Data Provenance: The images were collected "at the two offices where the predicate device was installed for the clinical test images." The manufacturer is Ray Co., Ltd. located in South Korea. It's implied these are prospective clinical images gathered for the purpose of the submission.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

  • Number of Experts: "The clinical performance of RAYSCAN α-Expert were clinically tested and approved by two licensed practitioners/clinicians."
  • Qualifications of Experts: They are described as "licensed practitioners/clinicians." No specific details such as years of experience, specialization (e.g., radiologist, dentist), or board certification are provided.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

The document states, "A licensed practitioner reviewed the sample clinical images and deemed them to be of acceptable quality for the intended use." It implies individual review, but does not specify any formal adjudication method (e.g., whether the two practitioners independently reviewed images and consensus was reached, or if there was a third adjudicator in case of disagreement).

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

  • MRMC Study: No MRMC comparative effectiveness study is mentioned. This device is an X-ray imaging system, not an AI-assisted diagnostic tool for humans, so this type of study would not be applicable. The comparison is between the new device's image quality and the image quality of the predicate device.
  • Effect Size: Not applicable.

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

This refers to an X-ray imaging device, not an algorithm. Therefore, "standalone (algorithm only)" performance is not applicable. The device's primary function is image acquisition.

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

The ground truth for the clinical image quality assessment appears to be expert opinion/consensus (from two licensed practitioners) regarding whether the images were "of acceptable quality for the intended use." There's no mention of pathology or outcomes data for establishing ground truth.

8. The sample size for the training set

The document mentions software validation, but this X-ray system is not described as an AI/ML device that requires a distinct "training set" in the context of machine learning model development. This question is not directly applicable to the type of device described.

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

As the device is not described as involving an AI/ML model with a training set, this question is not directly applicable. The software mentioned is for saving patient and image data, inquiries, and image generation, and was validated according to FDA guidance for software in medical devices, not specific AI/ML training.

Summary of what is present and what is missing:

  • Acceptance Criteria/Performance Table: Not provided in the requested format. General statement of "satisfactory" test results and "acceptable quality."
  • Test Set Sample Size & Provenance: Sample size not quantified. Provenance is South Korea, likely prospective.
  • Number & Qualification of Experts: Two licensed practitioners/clinicians. No further qualification details.
  • Adjudication Method: Not specified.
  • MRMC Study: Not applicable.
  • Standalone Performance: Not applicable.
  • Type of Ground Truth: Expert opinion on image quality.
  • Training Set Sample Size: Not applicable (not an AI/ML device in this context).
  • Training Set Ground Truth: Not applicable.

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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 and Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

April 18, 2024

Ray Co., Ltd. % Sooji Huh RA Specialist 1F-3F, 4F(Part), 5F, 265, Daeji-Ro, Suji-gu Yongin-si, Gyeonggi-do 16882 SOUTH KOREA

Re: K232325

Trade/Device Name: RAYSCAN α-Expert Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral Source X-Ray System Regulatory Class: Class II Product Code: MUH Dated: August 3, 2023 Received: August 3, 2023

Dear Sooji Huh:

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 (QS) 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 Radiological 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)

K232325

Device Name RAYSCAN a-Expert

Indications for Use (Describe)

The RAYSCAN a- P, SC, OCL, OCS panoramic X-ray imaging system with Cephalostat is an extra-oral source X-ray system, intended for dental radiographic examination of the teeth, jaw, and oral structures, to include panoramic examinations and implantology and for TMJ studies and cephalometry. Images are obtained using the standard narrow beam technique.

Type of Use (Select one or both, as applicable):
(\overline{X}) Prescription Use (Part 21 CFR 801 Subpart D)(\square) Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

K232325

1. 510(k) Summary

The summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR Part 807.92.

2. Date: August 03, 2023

3. Administrative Information

ApplicantRay Co., Ltd.
Address1F~3F, 4F(Part), 5F, 265, Daeji-ro, Suji-gu, Yongin-si,16882, Korea
ManufacturerNameRay Co., Ltd.
Address1F~3F, 4F(Part), 5F, 265, Daeji-ro, Suji-gu, Yongin-si,16882, Korea
Tel+82-31-605-1000
Fax+82-2-6280-5534
Contact PersonNameSooji Huh
Emailsooji.huh@raymedical.co.kr

4. Device Information

Trade/Proprietary NameRAYSCAN α-Expert
Common NameDental panoramic and cephalometric X-ray system
ClassificationNameDeviceExtraoral source dental X-ray system
RegulationNumber21 CFR 872.1800
Class2
Product CodeMUH
Review PanelRadiology

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5. Predicate device

ParameterPredicate Device
Device NameRAYSCAN α-Expert
ManufacturerRAY Co., Ltd
510(K) NumberK142058Special 510k
Classification nameExtraoral source dental X-raysystem
Regulation number872.1800
Primary product codeMUH

6. Device Description

RAYSCAN α-Expert (RAYSCAN α-P, SC, OCL, OCS) provides panoramic for scanning teeth, jaw and oral structures. By rotating the C-arm, which houses a high-voltage generator, an all-in-one Xray tube and a detector on each end, panoramic images of oral and maxillofacial structures are obtained byrecombining data scanned from different angles. Functionalities include panoramic image scanning for obtaining images of whole teeth, and a Cephalometric scanning option for obtaining Cephalic images.

7. Indication for use

The RAYSCAN a- P, SC, OCL, OCS panoramic X-ray imaging system with Cephalostat is an extraoral source X-ray system, intended for dental radiographic examination of the teeth, jaw, and oral structures, to include panoramic examinations and implantology and for TMJ studies and cephalometry. Images are obtained using the standard narrow beam technique.

8. Patient population

The device is intended to acquire diagnostic x-ray images of adult and pediatric individuals/patients without restriction on ethnic group, gender, weight, health status, or condition. We recommend that patients who undergo X-ray diagnostic radiation exposure be over 5 years old.

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9. Comparison with predicate device

The following table provides the summary of the technological characteristics of RAYSCAN α-Expert compared to the predicate device

ParameterProposed DevicePredicate Device
ManufacturerRAY Co., Ltd.RAY Co., Ltd.
Device nameRAYSCAN α-ExpertRAYSCAN α-Expert
510(K) Number(Traditional 510K)K142058(Special 510K)
Common NameDental panoramic and cephalometric X-ray systemDental panoramic and cephalometric X-ray system
Indications for useThe RAYSCAN α- P, SC, OCL, OCS panoramic X-ray imaging system with Cephalostat is an extra-oral source X-ray system, intended for dental radiographic examination of the teeth, jaw, and oral structures, to include panoramic examinations and implantology and for TMJ studies and cephalometry. Images are obtained using the standard narrow beam technique.The RAYSCAN α- Expert Dental X-Ray System is an extraoral source dental panoramic and optional cephalometric X-ray system intended to produce X-rays for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures.
Mode of OperationSame as predicate device #1Continuous operation with intermittent, stated permissible loading
Performance SpecificationSame as predicate device #11) Panoramic2) Cephalometric(optional)- One shot type- Scan type
Functional OptionSame as predicate device #1BaseRAYSCAN α-P :PANOOption(CEPH)RAYSCAN α-SC :PANO + SCAN CEPHRAYSCAN α-OCS :PANO + One shot(One shot, Standard Type)RAYSCAN α-OCL :PANO + One shot(One shot, Large Type)
Detector Type
PANOSame as predicate device #1
Pluto0600X
Ceph (Scan)Same as predicate device #1
Ceph (One shot)FXRD-1717VAFXDD-1012CA
Exposure switch TypeSame as predicate device #1"Deadman" Button type
MainSame as predicate device #1Ceph Apparatus
ComponentsSame as predicate device #1Vertical Carriage
Same as predicate device #1Rotator
Same as predicate device #1X-RAY Generator
Same as predicate device #1X-ray tube
Same as predicate device #1High Frequency Generator
Same as predicate device #1Column
Same as predicate device #1Touch monitor (panel)
Detector- PANOC10500DPluto0600XDetector- PANOC10500D
- CephXID-C24DC(Scan)FXRD-1717VA (One shot, Large Size)FXDD-1012CA (One shot, StandardSize)- CephXID-C24DC(Scan)PaxScan 4336X(One shot, Large Size)PaxScan 2530C(One shot, StandardSize)
Same as predicate device #1Chinrest
Same as predicate device #1Head rest
Same as predicate device #1Automatic Collimator
Same as predicate device #1Exposure switch
Same as predicate device #1Emergency stop switch
Same as predicate device #1Console PC set
AutomaticCollimatorSame as predicate device #1Panoramic examsCephalometric exams
Display TypeSame as predicate device #1TFT LCD type(Normally black)*1280x800 pixel
ClassSame as predicate device #1Class I with type B applied partsaccording to IEC 60601-1
Focal sizeSame as predicate device #10.5
X-ray Voltage(Patient)60~100kVp60~90kVp
X-ray Current(Patient)1~17mA4~17mA
Total Filtration2.8mmAl equivalent2.6 mm Al equivalent
DetectorPixel sizePANOSame as predicate device #1C10500D: 100μm
Pluto0600X : 100μmN/A
Ceph (Scan)Same as predicate device #1XID-C24DC: 100μm
Ceph(One shot)FXRD-1717VA : 140μmPaxScan 4336X: 139μm
FXDD-1012CA : 124μmPaxScan 2530C: 139μm
MagnificaPANO1.31C10500D: 1.3
tionCeph (Scan)Same as predicate device #1XID-C24DC: 1.11
Ceph(One shot)FXRD-1717VA : 1.13PaxScan 4336X: 1.13
FXDD-1012CA : 1.12PaxScan 2530C: 1.12
Scan timeSame as predicate device #1Pano : below 14sec
Ceph[Scan type] : below 19.8secCeph[Scan type] : below 19sec
Ceph[One shot type(S)]: below 0.8secCeph[One shot type]: below 2sec
Ceph[One shot type(L)]: below 0.5sec
Format compatibleSame as predicate device #1DICOM 3.0 Format compatible
Image Viewing SoftwareSame as predicate device #1RayScan(Cleared under K142058)
Image acquisitionSame as predicate device #1Giga-Ethernet Network
Total HeightSame as predicate device #1Max 2,296mm
Weight1) Panoramic(PANO)=150kg(330.7lb) ±10%1) Panoramic(PANO)=148kg(326lb) ±10%
2) Panoramic(PANO) + Cephalostic(Scan type)= 177.5kg (391.3lb) ± 10%2) Panoramic(PANO) + Cephalostic(Scan type)= 164kg (362lb) ± 10%
3) Panoramic(PANO) + Cephalostic(One shot type, installed in α-OCS)=176kg (388lb) ± 10%3) Panoramic(PANO) + Cephalostic(One shot type, installed in α-OCS)=166kg (366lb) ± 10%
4) Panoramic(PANO) + Cephalostic(One shot type, installed in α-OCL)=176kg (388lb) ± 10%4) Panoramic(PANO) + Cephalostic(One shot type, installed in α-OCL)=166kg (465.2lb) ± 10%
Type ofinstallationSame as predicate device #1Wall or floor mount
Patient positionSame as predicate device #1Standing / Wheelchair
ApplicableStandardsIEC 60601-1IEC 60601-1-3IEC 60601-2-63IEC 60601-1-2IEC 60601-1IEC 60601-1-3IEC 60601-2-28IEC 60601-2-63IEC 60601-1-2

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The product is principally just the same as in the previous 510(k) #K142058.

The complete of differences of the subject device to the predicate #142058 device is as follows - The maximum X-ray voltage of the tube has been changed from 90kV to 100kV

  • The minimum X-ray current of the tube has been changed from 4mA to 1mA - The Ceph(Scan) scan time has been changed from 20sec to 19.8sec

  • Added new Pano Detector(Pluto0600X)

  • Change of the Detector (using One-shot).

However, X-ray voltage, X-ray current, one-shot ceph detector was identified in #K230753 The 510(k) for the existing detector used in our equipment is provided below.

ModalityDetector ModelCleared510(k) No.
PanoC10500DNo PMAK142058
PanoPluto0600XNo PMAK222666

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Scan CephXID-C24DCNo PMAK181452
One shot CephFXRD-1717VANo PMAK213226
One shot CephFXDD-1012CANo PMAK213226

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10. Safety and Effectiveness Information

RAYSCAN α-Expert system described in this 510(k) is similar to the predicate device in terms of indications for use, materials, safety characteristics, and X-ray source.

The following information further substantial equivalence between the subject device and predicate device.

The fundamental technological characteristics of the subject and predicate device are similar.

The imaging modes are similar; PANO, CEPH (Optional), Scan All viewing software programs have been cleared with previous 510k submissions; RAYSCAN(K142058).

The sponsor tested the subject device in a laboratory and provided a non-clinical performance report. The same test protocol was used to test the performance of the subject and the predicate device for comparison. The sponsor certifies that adequate design and development controls (according to 21 CFR 820.30) were in place for manufacturing the subject device.

The differences are as follows.

  • The maximum X-ray voltage of the tube has been changed from 90kV to 100kV
  • The minimum X-ray current of the tube has been changed from 4mA to 1mA
  • The Ceph(Scan) scan time has been changed from 20sec to 19.8sec
  • Added new Pano Detector(Pluto0600X)
  • Detector (using One-shot).

However, X-ray voltage, X-ray current, one-shot ceph detector was identified in #K230753

Electrical, mechanical and environmental safety testing according to standard of IEC 60601-1: 2005/AMD1:2012(3.1 Edition), IEC 60601-1-3: 2008/AMD1:2013(Second Edition), IEC 60601-1-6:2010(Third Edition) and IEC 60601-2-63: 2012/AMD1:2017(first Edition) were performed. EMC testing was conducted in accordance with the standard IEC 60601-1-2: 2014(Edition 4.0).

The software of RAYSCAN α-Expert saves patient and image data and offers an inquiry function. In addition, it supports the image generate function intended to obtain images using the RAYSCAN a-Expert equipment and various sensors for diagnosis. That has been validated according to the FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" and "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" to assure substantial equivalence. The software for this device was considered a "moderate" level of concern since a failure or latent flaw in the software would not directly result in serious injury or death to the patient or operator.

As a result, we identified the level of concern associated with a new device and provided documentation consistent with that level. Based on our risk analysis of software, the difference does not affect its safety and effectiveness.

Bench testing was conducted according to the FDA Guidance for the Submissions of 510(k)'s for Solid State X-ray Imaging Devices". Bench testing is used to assess whether the parameters required to describe functionalities related to imaging properties of the dental X-ray device and patient dosage satisfy the designated tolerance.

Performance (Imaging performance) testing was conducted according to standard of IEC 61223-3-4. All test results were satisfactory.

Non-clinical considerations were conducted in accordance with the FDA Guidance for the Submissions of 510(k)'s for Solid State X-ray Imaging Devices."

Because the subject device uses the same detector as the predicate device, there are no significant differences between the two devices as a result of non-clinical testing.

Clinical considerations were conducted according to the FDA Guidance "Format for Traditional and Abbreviated 510(k)s".

The main measure of clinical performance for RAYSCAN α-Expert is determined to be image quality. The clinical performance of RAYSCAN α-Expert were clinically tested and approved by two licensed

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practitioners/clinicians. These images were gathered from all detectors of RAYSCAN a-Expert using protocols with random patient age, gender, and size. A licensed practitioner reviewed the sample clinical images and deemed them to be of acceptable quality for the intended use. These results are substantially equivalent to the evaluation performed on predicate device.

Pediatric information related to the use of this device is provided to users in compliance with FDA guidance "Pediatric Information for X-ray Imaging Device Premarket Notifications".

The features of RAYSCAN a-Expert were clinically tested and approved by two licensed practitioners/clinicians. Clinical imaging samples were collected from new detectors on the proposed device at the two offices where the predicate device was installed for the clinical test images. These images were gathered from all detectors installed with RAYSCAN a-Expert using protocols with random patient age, gender, and size. A licensed practitioner reviewed the sample clinical images and deemed them to be of acceptable quality for the intended use.

11. Conclusions

In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this premarket notification. Ray Co., Ltd. concludes that the newly RAYSCAN a-Expert is safe, effective and substantially equivalent to the predicate device as described herein.

§ 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.