(237 days)
For In Vitro Diagnostic Use
HALO AP Dx is a software only device intended as an aid to the pathologist to review, interpret and manage digital images of scanned surgical pathology slides prepared from formalin-fixed paraffin embedded (FFPE) tissue for the purposes of pathology primary diagnosis. HALO AP Dx is not intended for use with frozen section, cytology, or non-FFPE hematopathology specimens.
It is the responsibility of a qualified pathologist to employ appropriate procedures and safeguards to assure the quality of the images obtained and, where necessary, use conventional light microscopy review when making a diagnostic decision. HALO AP Dx is intended for use with the Hamamatsu NanoZoomer S360MD Slide scanner and the JVC Kenwood JD-C240BN01A display.
HALO AP Dx, version 2.1 is a browser-based software-only device intended to aid pathology professionals in viewing, manipulating, management and interpretation of digital pathology whole slide images (WSI) of glass slides obtained from the Hamamatsu Photonics K.K. NanoZoomer S360MD scanner and viewed on the JVC Kenwood JD-C240BN01A display.
HALO AP Dx is typically operated as follows:
- Image acquisition is performed using the predicate device, NanoZoomer S360MD Slide scanner according to its Instructions for Use. The operator performs quality control of the digital slides per the instructions of the NanoZoomer and lab specifications to determine if re-scans are necessary.
- Once image acquisition is complete, the unaltered image is saved by the scanner's software to an image storage location. HALO AP Dx ingests the image, and a copy of image metadata is stored in the subject device's database to improve viewing response times.
- Scanned images are reviewed by scanning personnel such as histotechnicians to confirm image quality and initiate any re-scans before making it available to the pathologist.
- The reading pathologist selects a patient case from a selected worklist within HALO AP Dx whereby the subject device fetches the associated images from external image storage.
- The reading pathologist uses the subject device to view the images and can perform the following actions, as needed:
a. Zoom and pan the image.
b. Measure distances and areas in the image.
c. Annotate images.
d. View multiple images side by side in a synchronized fashion.
The above steps are repeated as necessary.
After viewing all images belonging to a particular case (patient), the pathologist will make a diagnosis which is documented in another system, such as a Laboratory Information System (LIS).
The interoperable components of HALO AP Dx are provided in table 1 below:
Table 1. Interoperable Components for Use with HALO AP Dx
| Components | Manufacturer | Model |
|---|---|---|
| Scanner | Hamamatsu | NanoZoomer S360MD Slide scanner |
| Display | JVC | JD-C240BN01A |
This FDA 510(k) clearance letter pertains to HALO AP Dx, a software-only device for digital pathology image review. The documentation indicates that the device has been deemed substantially equivalent to a predicate device, the Hamamatsu NanoZoomer S360MD Slide scanner system (K213883).
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document defines the performance data points primarily through "Performance Data" and "Summary of Studies" sections, focusing on comparisons to the predicate device and usability. There are no explicit quantitative "acceptance criteria" presented as specific thresholds, but rather statements of adequacy and similarity to the predicate.
| Acceptance Criterion (Implicit) | Reported Device Performance |
|---|---|
| Image Reproduction Quality (Color Accuracy) | Criteria: Identical image reproduction compared to the predicate device (NZViewMD viewer), specifically regarding pixel-wise color accuracy. |
| Performance: Pixel-level comparisons demonstrated that the 95th percentile CIEDE2000 values across all Regions of Interest (ROIs) from varied tissue types and diagnoses were less than 3 ΔE00. This was determined to be "identical image reproduction." | |
| Turnaround Time (Image Loading - Case Selection) | Criteria: "When selecting a case, it should not take longer than 4 seconds until the image is fully loaded." |
| Performance: Determined to be "adequate for the intended use of the subject device." (No specific value reported, but implies |
§ 864.3700 Whole slide imaging system.
(a)
Identification. The whole slide imaging system is an automated digital slide creation, viewing, and management system intended as an aid to the pathologist to review and interpret digital images of surgical pathology slides. The system generates digital images that would otherwise be appropriate for manual visualization by conventional light microscopy.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Premarket notification submissions must include the following information:
(i) The indications for use must specify the tissue specimen that is intended to be used with the whole slide imaging system and the components of the system.
(ii) A detailed description of the device and bench testing results at the component level, including for the following, as appropriate:
(A) Slide feeder;
(B) Light source;
(C) Imaging optics;
(D) Mechanical scanner movement;
(E) Digital imaging sensor;
(F) Image processing software;
(G) Image composition techniques;
(H) Image file formats;
(I) Image review manipulation software;
(J) Computer environment; and
(K) Display system.
(iii) Detailed bench testing and results at the system level, including for the following, as appropriate:
(A) Color reproducibility;
(B) Spatial resolution;
(C) Focusing test;
(D) Whole slide tissue coverage;
(E) Stitching error; and
(F) Turnaround time.
(iv) Detailed information demonstrating the performance characteristics of the device, including, as appropriate:
(A) Precision to evaluate intra-system and inter-system precision using a comprehensive set of clinical specimens with defined, clinically relevant histologic features from various organ systems and diseases. Multiple whole slide imaging systems, multiple sites, and multiple readers must be included.
(B) Reproducibility data to evaluate inter-site variability using a comprehensive set of clinical specimens with defined, clinically relevant histologic features from various organ systems and diseases. Multiple whole slide imaging systems, multiple sites, and multiple readers must be included.
(C) Data from a clinical study to demonstrate that viewing, reviewing, and diagnosing digital images of surgical pathology slides prepared from tissue slides using the whole slide imaging system is non-inferior to using an optical microscope. The study should evaluate the difference in major discordance rates between manual digital (MD) and manual optical (MO) modalities when compared to the reference (
e.g., main sign-out diagnosis).(D) A detailed human factor engineering process must be used to evaluate the whole slide imaging system user interface(s).
(2) Labeling compliant with 21 CFR 809.10(b) must include the following:
(i) The intended use statement must include the information described in paragraph (b)(1)(i) of this section, as applicable, and a statement that reads, “It is the responsibility of a qualified pathologist to employ appropriate procedures and safeguards to assure the validity of the interpretation of images obtained using this device.”
(ii) A description of the technical studies and the summary of results, including those that relate to paragraphs (b)(1)(ii) and (iii) of this section, as appropriate.
(iii) A description of the performance studies and the summary of results, including those that relate to paragraph (b)(1)(iv) of this section, as appropriate.
(iv) A limiting statement that specifies that pathologists should exercise professional judgment in each clinical situation and examine the glass slides by conventional microscopy if there is doubt about the ability to accurately render an interpretation using this device alone.