(198 days)
Yes
The intended use and device description explicitly state the use of "deep-learning-based algorithms" and "AI algorithms" for automatic contouring. The training and test set descriptions further detail the data used to train these algorithms.
No.
This device is a post-processing software that automatically contours anatomical structures for use in clinical workflows, such as radiation therapy treatment planning, but it does not directly treat or diagnose.
No
The "Intended Use / Indications for Use" states that the software is for "post-processing" and "is not intended to automatically detect or contour lesions." Additionally, the "Device Description" explicitly states, "AI-Rad Companion Organs RT is not intended to be used as a standalone diagnostic device and is not a clinical decision-making software."
Yes
The device is described as "post-processing software" and its function is to automatically contour structures from existing medical images. It explicitly states it is not a standalone diagnostic device and must be used in conjunction with other software like Treatment Planning Systems. There is no mention of any accompanying hardware component.
Based on the provided information, this device is not an In Vitro Diagnostic (IVD).
Here's why:
- Intended Use: The intended use clearly states that the software is for "post-processing software intended to automatically contour DICOM CT and MR predefined structures." It is used as input for clinical workflows like radiation therapy treatment planning. It is explicitly stated that it is "not intended to automatically detect or contour lesions" and is "not a standalone diagnostic device and is not a clinical decision-making software."
- Device Description: The description reinforces that the software provides "automatic segmentation of pre-defined structures such as Organs-at-risk (OAR) from CT or MR medical series, prior to dosimetry planning in radiation therapy." It emphasizes that the output "must be reviewed and, where necessary, edited with appropriate software before accepting generated contours as input to treatment planning steps."
- Nature of IVDs: In Vitro Diagnostics are medical devices intended to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. This software does not perform any tests on biological samples. It processes medical images.
The software is a medical image processing tool used to assist in the planning of radiation therapy, which is a treatment, not a diagnostic process in the sense of an IVD.
No
The letter does not explicitly state that the FDA has reviewed and approved or cleared a Predetermined Change Control Plan (PCCP) for this specific device.
Intended Use / Indications for Use
AI-Rad Companion Organs RT is a post-processing software intended to automatically contour DICOM CT and MR predefined structures using deep-leaming-based algorithms.
Contours that are generated by AI-Rad Companion Organs RT may be used as input for clinical workflows including external beam radiation therapy treatment planning. AI-Rad Companion Organs RT must be used in conjunction with appropriate software such as Treatment Planning Systems and Interactive Contouring applications, to review, edit, and accept contours generated by AI-Rad Companion Organs RT.
The output of AI-Rad Companion Organs RT are intended to be used by trained medical professionals.
The software is not intended to automatically detect or contour lesions.
Product codes
QKB
Device Description
AI-Rad Companion Organs RT provides automatic segmentation of pre-defined structures such as Organs-at-risk (OAR) from CT or MR medical series, prior to dosimetry planning in radiation therapy. AI-Rad Companion Organs RT is not intended to be used as a standalone diagnostic device and is not a clinical decision-making software.
CT or MR series of images serve as input for AI-Rad Companion Organs RT and are acquired as part of a typical scanner acquisition. Once processed by the AI algorithms, generated contours in DICOM-RTSTRUCT format are reviewed in a confirmation window, allowing clinical user to confirm or reject the contours before sending to the target system. Optionally, the user may select to directly transfer the contours to a configurable DICOM node (e.g., the TPS, which is the standard location for the planning of radiation therapy).
The output of AI-Rad Companion Organs RT must be reviewed and, where necessary, edited with appropriate software before accepting generated contours as input to treatment planning steps. The output of AI-Rad Companion Organs RT is intended to be used by qualified medical professionals. The qualified medical professional can perform a complementary manual editing of the contours or add any new contours in the TPS (or any other interactive contouring application supporting DICOM-RT objects) as part of the routine clinical workflow.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Yes
Input Imaging Modality
DICOM CT and MR
Anatomical Site
CT: Head & Neck, Thorax, Abdomen & Pelvis, Head & Neck lymph nodes (166 OAR)
MR: Pelvis (9 OAR)
Indicated Patient Age Range
Adult use only
22 years and older
Intended User / Care Setting
trained medical professionals / clinicians
Description of the training set, sample size, data source, and annotation protocol
MR Training Data:
- T1 VIBE/Dixon W: 219 datasets (USA: 59, EU: 160). Age: 22 years and older. Manufacturer: Siemens Healthineers. Annotated Organs: Body, Femoral Head Right, Femoral Head Left. Field Strength: 1.5T: 59, 3.0T: 160.
- T2 W TSE: 225 datasets (USA: 225). Age: 22 years and older. Manufacturer: Siemens Healthineers. Annotated Organs: Anal Canal, Rectum, Penile Bulb, Seminal Vesicle, Bladder. Field Strength: 1.5T: 83, 3.0T: 142.
- Prostate (T2W): 960 datasets (USA & EU). Age: 62 (average). Manufacturer: Siemens Healthineers. Annotated Organs: Prostate. Field Strength: 1.5T & 3.0T.
CT Training Data:
- Cochlea: 215 training sets, 24 validation sets.
- Thyroid: 293 training sets, 56 validation sets.
- Constrictor Muscles: 335 training sets, 89 validation sets.
- Chest Wall: 48 training sets, 12 validation sets.
- LN Supraclavicular, Axilla Levels, Internal Mammaries: 228 training sets, 28 validation sets.
- Duodenum, Bowels, Sigmoid: 332 training sets, 84 validation sets.
- Stomach: 371 training sets, 92 validation sets.
- Pancreas: 369 training sets, 92 validation sets.
- Pulmonary Artery, Vena Cava, Trachea, Spinal Canal, Proximal Bronchus: 113 training sets, 34 validation sets.
- Ventricles & Atriums: 706 training sets, 273 validation sets.
- Descending Coronary Artery: 252 training sets, 45 validation sets.
- Penile Bulb: 854 training sets, 213 validation sets.
- Uterus: 381 training sets, 94 validation sets.
Annotation Protocol (for both training and validation testing data): The annotation protocols for the OAR were defined following the NRG/RTOG guidelines. The ground truth annotations were drawn manually by a team of experienced annotators mentored by radiologists or radiation oncologists using an internal annotation tool. Additionally, a quality assessment including review and correction of each annotation was done by a board-certified radiation oncologist using validated medical image annotation tools.
Description of the test set, sample size, data source, and annotation protocol
MR Validation Testing Data:
- Sample Size: N=66
- Data Origin: Multiple clinical sites across North America & Europe.
- T1 Dixon W (N=30): USA: 15, EU: 15. Age: 22 years and older. Manufacturer: Siemens Healthineers. Annotated Organs: Body, Femoral Head Right, Femoral Head Left. Slice Thickness: = 70: 4, Unknown: 110. Manufacturer: Siemens: 73. Body Region: Head & Neck: 24, Thorax & Abdomen: 20, Pelvis: 29. Slice Thickness: 3: 1.
- Cohort B (N=40): 4 clinical sites (Canada: 40). Sex: Male: 19, Female: 21. Age: 70: 12. Manufacturer: GE: 18, Philips: 22. Body Region: Head & Neck: 40. Slice Thickness: 3: 3.
- Cohort C (N=301): 25 clinical sites (NA: 165, EU: 44, Asia: 33, SA: 19, Australia: 28, Unknown: 12). Sex: Male: 53, Female: 50, Unknown: 198. Age: 70: 12. Manufacturer: Siemens: 53, GE: 59, Philips: 119, Varian: 44, Others: 26. Body Region: Head & Neck: 50, Thorax: 81, Abdomen: 115, Pelvis: 55. Slice Thickness: 3: 15.
- Annotation Protocol: Ground truth annotations were established following RTOG and clinical guidelines using manual annotation.
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Study Type: Retrospective performance studies.
MR Contouring Algorithm Performance:
- Sample Size: N=66
- Key Metrics: Dice coefficient and Absolute Symmetric Surface Distance (ASSD). Failure rate.
- Acceptance Criteria: The average segmentation accuracy (Dice value) of all subject device organs should be equivalent or better than the overall segmentation accuracy of the predicate device. The overall fail rate for each organ/anatomical structure is smaller than 15%.
- Performance Results (Subject device):
- Dice [%] Avg: 85.75, Std: 6.48, 95 % CI Bootstrap: [82.85, 87.58]
- ASSD [mm] Avg: 1.25, Std: 1.28, 95 % CI Bootstrap: [0.95, 2.02]
- Fail [%]: 2.75
- Comparison to Reference Device (MRCAT Pelvis K182888):
- AI-Rad Companion Organs RT VA50 – all organs: Dice % Average 86 (95% CI 83-88)
- AI-Rad Companion Organs RT VA50 – common organs: Dice % Average 82 (95% CI 78-84)
- MRCAT Pelvis (K182888) – all organs: Dice % Average 77 (95% CI 75-79)
- Detailed Organ Performance (N=36 where applicable):
- Bladder: Dice 91.32 (Std 6.85), ASSD 0.91 (Std 1.82)
- Rectum: Dice 84.87 (Std 6.21), ASSD 1.32 (Std 1.64)
- Anal Canal: Dice 75.78 (Std 7.43), ASSD 1.19 (Std 0.65)
- Penile Bulb: Dice 82.29 (Std 6.89), ASSD 0.55 (Std 0.46)
- Seminal Vesicle: Dice 66.08 (Std 18.65), ASSD 2.06 (Std 3.63)
- Prostate: Dice 84.76 (Std 5.32), ASSD 0.94 (Std 0.62)
- Femur Right (N=30): Dice 94.29 (Std 2.21), ASSD 1.1 (Std 0.45)
- Femur Left (N=30): Dice 94.38 (Std 2.88), ASSD 1.06 (Std 0.52)
- Body (N=30): Dice 98.01 (Std 1.88), ASSD 2.12 (Std 1.74)
CT Contouring Algorithm Performance:
- Sample Size: N=414
- Key Metrics: Dice coefficient and Absolute Symmetric Surface Distance (ASSD).
- Acceptance Criteria:
- For organs in Predicate Device: All organs segmented in predicate are also in subject device. Average Dice score difference between subject and predicate device smaller than 3%.
- For New Organs for Subject Device: Baseline value defined by subtracting reference value using 5% error margin for Dice and 0.1 mm for ASSD. Subject device in selected reference metric has higher value than defined baseline value.
- Performance Summary (Subject device CT contouring):
- Head & Neck: Avg Dice 76.5, Std 12.8, 95% CI [70.9, 80.8]
- Head & Neck lymph nodes: Avg Dice 69.2, Std 9.5, 95% CI [65.7, 72.5]
- Thorax: Avg Dice 82.1, Std 8.4, 95% CI [79.6, 83.9]
- Abdomen: Avg Dice 88.3, Std 8.3, 95% CI [80.9, 92.2]
- Pelvis: Avg Dice 84.0, Std 6.5, 95% CI [80.7, 86.7]
- Detailed Performance Evaluation of new organs in subject device (sample sizes vary by organ):
- Duodenum (N=76): Dice 77.3, ASSD 2.6
- Large Bowel (N=102): Dice 89.6, ASSD 2.1
- Sigmoid (N=74): Dice 79.9, ASSD 3.8
- Small Bowel (N=76): Dice 88.5, ASSD 1.3
- Uterus (N=25): Dice 87.8, ASSD 1.7
- Penile Bulb (N=30): Dice 74, ASSD 1.7
- Left Cochlea (N=25): Dice 74.8, ASSD 0.6
- Right Cochlea (N=25): Dice 79.9, ASSD 0.3
- Inferior Pharyngeal Constrictor Muscle (N=30): Dice 78.2, ASSD 0.8
- Middle Pharyngeal Constrictor Muscle (N=30): Dice 67.2, ASSD 0.9
- Superior Pharyngeal Constrictor Muscle (N=30): Dice 66.1, ASSD 0.8
- Thyroid (N=30): Dice 84.4, ASSD 0.7
- Pancreas (N=31): Dice 68.4, ASSD 3.5
- Stomach (N=31): Dice 90.7, ASSD 2
- Left Anterior Descending Coronary Artery (N=57): Dice 47.6, ASSD 4.1
- Left Atrium (N=57): Dice 86.1, ASSD 1.8
- Left Ventricle Endocardium (N=57): Dice 83.6, ASSD 2.3
- Left Ventricle (N=57): Dice 85.9, ASSD 2.7
- Right Atrium (N=57): Dice 79.5, ASSD 2.7
- Right Ventricle (N=57): Dice 83.4, ASSD 2.3
- Left Chest Wall (N=28): Dice 92.3, ASSD 1
- Right Chest Wall (N=28): Dice 92.6, ASSD 0.9
- Inferior Vena Cava (N=27): Dice 76.2, ASSD 2
- Proximal Bronchus (N=27): Dice 84.2, ASSD 1.1
- Pulmonary Artery (N=27): Dice 80, ASSD 2.3
- Spinal Canal (N=27): Dice 85.2, ASSD 1.3
- Superior Vena Cava (N=27): Dice 79, ASSD 1.5
- Trachea (N=27): Dice 88.7, ASSD 1
- Left Axilla Level I (N=24): Dice 81.5, ASSD 2.6
- Left Axilla Level II (N=24): Dice 79.2, ASSD 1.8
- Left Axilla Level III (N=24): Dice 75.4, ASSD 1.5
- Left Internal Mammary (N=24): Dice 58.6, ASSD 1.9
- Left Supraclavicular (N=24): Dice 79.5, ASSD 2
- Right Axilla Level I (N=24): Dice 80, ASSD 3
- Right Axilla Level II (N=24): Dice 77.6, ASSD 2
- Right Axilla Level III (N=24): Dice 75.9, ASSD 1.6
- Right Internal Mammary (N=24): Dice 62.6, ASSD 1.6
- Right Supraclavicular (N=24): Dice 79.7, ASSD 2
Key Results: The results of the subject device (AI-Rad Companion Organs RT SW VA50A) were equivalent or had better performance than the predicate device (AI-Rad Companion Organs RT SW VA40A). The performance of the enhanced CT organ contouring algorithm is comparable to the predicate device and comparable reference literature and cleared devices. The performance of the MR contouring algorithms is compared to the reference device, MRCAT Pelvis (K182888).
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Dice Coefficient (Dice [%]), Absolute Symmetric Surface Distance (ASSD [mm]), Fail rate (Fail [%]).
Predicate Device(s)
Reference Device(s)
K182888, K220783, K231765, K211881
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
0
April 3, 2024
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Siemens Medical Solutions U.S.A. % Kira Morales Regulatory Affairs Manager 40 Liberty Blvd. MALVERN, PA 19355
Re: K232899
Trade/Device Name: AI-Rad Companion Organs RT Regulation Number: 21 CFR 892.2050 Regulation Name: Medical Image Management And Processing System Regulatory Class: Class II Product Code: QKB Dated: March 1, 2024 Received: March 4, 2024
Dear Kira Morales:
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/cdrb/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).
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
1
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 medical devices and radiation-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,
Loran Weidner
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
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Indications for Use
510(k) Number (if known) K232899
Device Name AI-Rad Companion Organs RT
Indications for Use (Describe)
AI-Rad Companion Organs RT is a post-processing software intended to automatically contour DICOM CT and MR predefined structures using deep-leaming-based algorithms.
Contours that are generated by AI-Rad Companion Organs RT may be used as input for clinical workflows including external beam radiation therapy treatment planning. AI-Rad Companion Organs RT must be used in conjunction with appropriate software such as Treatment Planning Systems and Interactive Contouring applications, to review, edit, and accept contours generated by AI-Rad Companion Organs RT.
The output of AI-Rad Companion Organs RT are intended to be used by trained medical professionals.
The software is not intended to automatically detect or contour lesions.
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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Image /page/3/Picture/1 description: The image contains the logo for Siemens Healthineers. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the words is a graphic of orange dots.
510(k) SUMMARY FOR AI-Rad Companion Organs RT
Submitted by: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Date Prepared: April 2, 2024
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of Safe Medical Devices Act of 1990 and 21 CFR §807.92.
1. Submitter
| Importer/Distributor | Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard
Malvern, PA 19355
Mail Code: 65-3
Registration Number: 2240869 |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturing Site | Siemens Healthcare GmbH
Henkestrasse 127
Erlangen, Germany 91052
Registration Number: 3002808157 |
2. Contact Person
Kira Morales Senior Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19335 Phone: +1 (484) 901 - 9471 Email: kira.morales@siemens-healthineers.com
3. Device Name and Classification
Product Name: | AI-Rad Companion Organs RT |
---|---|
Common Name: | Medical Imaging Software |
Classification Name: | Medical Image Management and Processing System |
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Image /page/4/Picture/0 description: The image contains the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the word "Healthineers" is a graphic of orange dots.
Classification Panel: CFR Section: Device Class: Product Code:
4. Predicate Device
Product Name: Common Name: 510(k) Number: Clearance Date: Classification Name: Classification Panel: CFR Section: Device Class: Primary Product Code: Recall Information:
5. Reference Devices
Product Name: Common Name: 510(k) Number: Clearance Date: Classification Name: Classification Panel: CFR Section: Device Class: Primary Product Code:
Product Name:
Common Name: 510(k) Number: Clearance Date: Classification Name: Classification Panel: CFR Section: Device Class: Primary Product Code:
Product Name:
Common Name: 510(k) Number: Clearance Date: Classification Name: Radiology 21 CFR §892.2050 Class II OKB
AI-Rad Companion Organs RT Medical Imaging Software K221305 October 14, 2022 Medical Image Management and Processing System Radiology 21 CFR §892.2050 Class II OKB N/A
MRCAT Pelvis
Medical Imaging Software K182888 April 30, 2019 Medical charged-particle radiation therapy system Radiology 21 CFR §892.2050 Class II MUJ
RT Image Suite
Medical Imaging Software K220783 September 7, 2022 Medical charged-particle radiation therapy system Radiology 21 CFR §892.2050 Class II MUJ
Contour Protégé AI
Medical Imaging Software K231765 November 8, 2023 Medical image management and processing system
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Image /page/5/Picture/0 description: The image contains the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the words is a graphic of orange dots arranged in a circular pattern.
Classification Panel: Radiology 21 CFR §892.2050 CFR Section: Device Class: Class II Primary Product Code: OKB Product Name: AI Segmentation Common Name: Medical Image Segmentation Software 510(k) Number: K211881
Clearance Date: Classification Name: Classification Panel: CFR Section: Device Class: Primary Product Code:
September 2, 2021 Medical charged-particle radiation therapy system Radiology 21 CFR §892.2050 Class II MUJ
6. Indications for Use
AI-Rad Companion Organs RT is a post-processing software intended to automatically contour DICOM CT and MR pre-defined structures using deep-learning-based algorithms.
Contours that are generated by AI-Rad Companion Organs RT may be used as input for clinical workflows including external beam radiation therapy treatment planning. AI-Rad Companion Organs RT must be used in conjunction with appropriate software such as Treatment Planning Systems and Interactive Contouring applications, to review, edit, and accept contours generated by AI-Rad Companion Organs RT.
The outputs of AI-Rad Companion Organs RT are intended to be used by trained medical professionals.
The software is not intended to automatically detect or contour lesions.
7. Device Description
AI-Rad Companion Organs RT provides automatic segmentation of pre-defined structures such as Organs-at-risk (OAR) from CT or MR medical series, prior to dosimetry planning in radiation therapy. AI-Rad Companion Organs RT is not intended to be used as a standalone diagnostic device and is not a clinical decision-making software.
CT or MR series of images serve as input for AI-Rad Companion Organs RT and are acquired as part of a typical scanner acquisition. Once processed by the AI algorithms, generated contours in DICOM-RTSTRUCT format are reviewed in a confirmation window, allowing clinical user to confirm or reject the contours before sending to the target system. Optionally, the user may select to directly transfer the contours to a configurable DICOM node (e.g., the TPS, which is the standard location for the planning of radiation therapy).
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Image /page/6/Picture/0 description: The image contains the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the words is a cluster of orange dots arranged in a circular pattern.
The output of AI-Rad Companion Organs RT must be reviewed and, where necessary, edited with appropriate software before accepting generated contours as input to treatment planning steps. The output of AI-Rad Companion Organs RT is intended to be used by qualified medical professionals. The qualified medical professional can perform a complementary manual editing of the contours or add any new contours in the TPS (or any other interactive contouring application supporting DICOM-RT objects) as part of the routine clinical workflow.
8. Substantially Equivalent (SE) and Technological Characteristics
The indented use of the predicate device and the subject device are equivalent. The two main difference compared to the predicate, AI-Rad Companion Organs RT (K221305):
- MR Contouring Algorithms ●
- o T1 Model for 3 target organs
- o T2 Model for 6 target organs
- . Update CT contouring algorithm for 38 new organs
AI-Rad Companion Organs RT VA50 and AI-Rad Companion Organs RT VA40 both use a deep learning algorithm to support their AI claims. Additionally, they both process CT data in DICOM format, making them vendor agnostic and create outputs which can be used by any TPS system. The MR contouring has only been validated for Siemens Healthineers' scanner data. The deep learning CT algorithm within AI-Rad Companion Organs RT VA50 has been enhanced from the algorithm in AI-Rad Companion Organs RT VA40 (K221305). All models contained within AI-Rad Companion Organs RT VA50 and AI-Rad Companion Organs RT VA40 (K221305) are locked and cannot be modified by the user.
The subject device, AI-Rad Companion Organs RT, is substantially equivalent with regards to the software features, functionalities, and core algorithms. The performance of the new MR contouring algorithm within AI-Rad Companion Organs RT VA50 is comparable to the algorithm in MRCAT Pelvis (K182888). The performance of the new CT contouring algorithms have been validated against FDA/CE cleared devices or from literature.
The risk analysis and non-clinical data support that both devices perform equivalently and do not raise different questions of the safety and effectiveness.
Subject Device | Predicate Device | Reference Device | |
---|---|---|---|
Device | |||
Manufacturer | Siemens | Siemens | Philips Medical |
Systems MR Finland | |||
Device Name | AI-Rad Companion | ||
Organs RT | AI-Rad Companion | ||
Organs RT | MRCAT Pelvis | ||
510(k) Number | TBD | K221305 | K182888 |
processing software | processing software | Ingenia 1.5T and 3.0T | |
intended to | intended to | MR systems. Intended | |
automatically contour | automatically contour | Use: MRCAT imaging | |
DICOM CT and MR | DICOM CT imaging | is intended to provide | |
pre-defined structures | data using deep- | the operator with | |
using deep-learning- | learning-based | information of tissue | |
based algorithms. | algorithms. | properties for radiation | |
Contours that are | Contours that are | attenuation estimation | |
generated by AI-Rad | generated by AI-Rad | purposes in photon | |
Companion Organs RT | Companion Organs RT | external beam | |
may be used as input | may be used as input | radiotherapy treatment | |
for clinical workflows | for clinical workflows | planning. Indications | |
including external | including external | for use: MRCAT | |
beam radiation therapy | beam radiation therapy | Pelvis is indicated for | |
treatment planning. | treatment planning. AI- | radiotherapy treatment | |
AI-Rad Companion | Rad Companion | planning of soft tissue | |
Organs RT must be | Organs RT must be | cancers in the pelvic | |
used in conjunction | used in conjunction | region. | |
with appropriate | with appropriate | ||
software such as | software such as | ||
Treatment Planning | Treatment Planning | ||
Systems and | Systems and | ||
Interactive Contouring | Interactive Contouring | ||
applications, to review, | applications, to review, | ||
edit, and accept | edit, and accept | ||
contours generated by | contours generated by | ||
AI-Rad Companion | AI-Rad Companion | ||
Organs RT. | Organs RT. | ||
The outputs of AI-Rad | The output of AI-Rad | ||
Companion Organs RT | Companion Organs RT | ||
are intended to be used | in the format of | ||
by trained medical | RTSTRUCT objects | ||
professionals. | are intended to be used | ||
The software is not | by trained medical | ||
intended to | professionals. | ||
automatically detect or | The software is not | ||
contour lesions | intended to | ||
automatically detect or | |||
contour lesions. Only | |||
DICOM images of | |||
Algorithm | |||
Segmentation of Organ at Risk in the Anatomic Regions | Deep Learning | Deep Learning | Machine-learning |
Compatible Modality | CT & MR Images | CT Images | MR |
Compatible Scanner Models | CT: Head & Neck, | ||
Thorax, Abdomen & Pelvis | |||
Head & Neck lymph nodes | |||
(166 OAR) | |||
MR: Pelvis (9 OAR) | CT: Head & Neck, | ||
Thorax, Abdomen & Pelvis | |||
Head & Neck lymph nodes | |||
(128 OAR) | Male and female pelvis, with soft-tissue cancer in the anatomical pelvic region below L1 vertebra, including (post-operative) prostate, rectum, anus, bladder and cervix | ||
Compatible Treatment Planning System | No Limitation on scanner model for CT. | ||
Siemens Healthineers' data only for MR. | |||
DICOM compliance required. | No Limitation on scanner model, | ||
DICOM compliance required. | Ingenia 1.5T and 3.0T MR-RT, Ingenia Ambition 1.5T MR-RT and Ingenia Elition 3.0T MR-RT | ||
Contraindications | No Limitation on TPS model, DICOM compliance required. | No Limitation on TPS model, DICOM compliance required. | No Limitation on TPS model, DICOM compliance required. |
Target Population | Adult use only | Adult use only | Adult use only |
AI-Rad Companion Organs RT is designed for use only in adult populations. | |||
AI-Rad Companion Organs RT is designed for any patient for whom relevant modality scans are available. | AI-Rad Companion Organs RT is designed for use only in adult populations. | ||
AI-Rad Companion Organs RT is designed for any patient for whom relevant modality scans are available. More specifically, the software is validated on previously acquired CT DICOM volumes for radiation therapy treatment planning, including, head and | No information publicly available | ||
adult patients are considered to be valid input. |
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neck, thorax, abdomen, and pelvis. | |||
---|---|---|---|
Clinical | |||
condition the | |||
device is | |||
intended to | |||
diagnose, treat or | |||
manage | Limited to patients | ||
previously selected for | |||
Radiation Therapy. | Limited to patients | ||
previously selected for | |||
Radiation Therapy. | No information | ||
publicly available | |||
Software | |||
Architecture | AI-Rad Companion | ||
(Engine) architecture | |||
enabling the | |||
deployment of AI Rad | |||
Companion Organs RT | |||
using Edge and in the | |||
Cloud. The UI is | |||
provided using a web- | |||
based interface. | AI-Rad Companion | ||
(Engine) architecture | |||
enabling the | |||
deployment of AI Rad | |||
Companion Organs RT | |||
using Edge and in the | |||
Cloud. The UI is | |||
provided using a web- | |||
based interface. | No information | ||
publicly available | |||
Deployment | |||
Feature | Edge & Cloud | ||
Deployment | Edge & Cloud | ||
Deployment | No information | ||
publicly available | |||
Organ Templates | Creating, editing and | ||
deletion of organ | |||
templates. Customize | |||
predefined structure | |||
database with mapping | |||
to international | |||
nomenclature schemes. | Creating, editing and | ||
deletion of organ | |||
templates. Customize | |||
predefined structure | |||
database with mapping | |||
to international | |||
nomenclature schemes. | No information | ||
publicly available | |||
Automated | |||
workflow | AI-Rad Companion | ||
Organs RT | |||
automatically | |||
processes input image | |||
data and sends the | |||
results as DICOM-RT | |||
Structure Sets to a | |||
user-configurable | |||
target node. | AI-Rad Companion | ||
Organs RT | |||
automatically | |||
processes input image | |||
data and sends the | |||
results as DICOM-RT | |||
Structure Sets to a | |||
user-configurable | |||
target node. | Automatic contouring | ||
Contour | |||
visualization and | |||
editing feature | AI-Rad Companion | ||
Organs RT provides | |||
basic result preview of | |||
automatic | |||
segmentation results, | |||
and no editing feature | |||
of the automatic | |||
segmented contour. | AI-Rad Companion | ||
Organs RT provides | |||
basic result preview of | |||
automatic | |||
segmentation results, | |||
and no editing feature | |||
of the automatic | |||
segmented contour. | No information | ||
publicly available | |||
Segmentation | |||
Performance | MR: The target | ||
performance was | |||
validated using 66 | |||
cases to validate the | |||
overall performance of | |||
the MR contouring. | |||
CT: The target | |||
performance was | |||
validated using 414 | |||
cases distributed to | |||
three cohorts. | |||
Both: To objectively | |||
evaluate the target | |||
performance, the DICE | |||
coefficient, the | |||
absolute symmetric | |||
surface distance | |||
(ASSD) and the fail | |||
rate was evaluated. | |||
The segmentation | |||
performance of the | |||
subject was equivalent | |||
to the overall | |||
performance compared | |||
to the predicate, | |||
reference device and | |||
comparable literature | |||
& devices. | The target performance | ||
was validated using | |||
157 cases distributed to | |||
two cohorts. Cohort A | |||
is clinical routine | |||
treatment planning CT | |||
and it is split into two | |||
sub-cohort and Cohort | |||
B is PET-CT data. To | |||
objectively evaluate | |||
the target performance, | |||
the DICE coefficient, | |||
the absolute symmetric | |||
surface distance | |||
(ASSD) and the fail | |||
rate was evaluated. | |||
The segmentation | |||
performance of the | |||
subject and reference | |||
device were equivalent | |||
as well as the overall | |||
performance compared | |||
to the predicate device. | The mean and standard | ||
deviation Dice | |||
coefficients, along with | |||
the lower 95th | |||
percentile confidence | |||
bound were calculated. | |||
User Interface - | |||
Results Preview | |||
(Confirmation) | Basic visualization | ||
functionality of | |||
original data and | |||
generated contours | Basic visualization | ||
functionality of | |||
original data and | |||
generated contours | No information | ||
publicly available | |||
User Interface | |||
Configuration | Configuration UI | Configuration UI | No information |
publicly available | |||
Automated | |||
Workflow to TPS | Results send to | ||
Confirmation UI & | |||
Optional bypassing of | |||
Confirmation UI to | |||
TPS | Results send to | ||
Confirmation UI & | |||
Optional bypassing of | |||
Confirmation UI to | |||
TPS | No information | ||
publicly available | |||
Human Factors | Design to be used by | ||
trained clinicians. | Design to be used by | ||
trained clinicians. | Designed to be used by | ||
trained clinicians |
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Table 1: Indications for Use and Segmentation Feature Comparison
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SIEME Healthineers
The conclusions from all verification and validation data suggests that these enhancements are equivalent with respect to safety and effectiveness of the predicate device. These modifications do not change the intended use of the product. Siemens is of opinion that AI-Rad Companion Organs RT VA50 is substantially equivalent to the currently marketed device, AI-Rad Companion Organs RT (K221305).
9. Nonclinical Tests
Non-clinical tests were conducted to test the functionality of AI-Rad Companion Organs RT. Software validation and bench testing have been conducted to assess the performance claims as well as the claim of substantial equivalence to the predicate device.
AI-Rad Companion has been tested to meet the requirements of conformity to multiple industry standards. Non-clinical performance testing demonstrates that AI-Rad Companion Organs RT complies with the FDA guidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (May 11, 2005) as well as with the following voluntary FDA recognized Consensus Standards listed in Table 2.
| Recognition
Number | Product
Area | Title of Standard | Reference
Number and
Date | Standards
Development
Organization |
|-----------------------|--------------------------|-------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|------------------------------------------|
| 5-129 | General | Medical Devices –
Application of usability
engineering to medical
devices | 62366-1 Ed
1.1 2020-06
CV | IEC |
| 5-125 | General | Medical Devices –
application of risk
management to medical
devices | 14971:2019-
12 | ISO |
| 13-79 | Software/
Informatics | Medical device software –
software life cycle
processes [Including
Amendment 1 (2016)] | 62304 Ed 1.1
2015-06 CV | AAMI
ANSI
IEC |
| 12-349 | Radiology | Digital Imaging and
Communications in
Medicine (DICOM) Set | PS 3.1 – 3.20
2022d | NEMA |
| 5-134 | General | Medical devices – symbols
to be used with information
to be supplied by the
manufacturer - Part 1:
General Requirements | 15223-1
Fourth edition
2021-07 | ISO
IEC |
| 13-97 | Software/
Informatics | Health software – Part 1:
General requirements for
product safety | 82304-1
Edition 1.0
2016-10 | IEC |
Table 2: List of recognized standards
Verification and Validation
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Software documentation level, per FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" issued on June 14, 2023, is also included as part of this submission. The performance data demonstrates continued conformance with special controls for medical devices containing software. Non-clinical tests were conducted on the subject device during product development.
Software bench testing in the form of Unit, System and Integration tests were performed to evaluate the performance and functionality of the new features and software updates. All testable requirements in the Requirement Specifications and the Risk Analysis have been successfully verified and traced in accordance with the Siemens Healthineers DH product development process. Human factor usability validation is addressed in system testing and usability validation test records. Software verification and regression testing have been performed successfully to meet their previously determined acceptance criteria as stated in the test plans.
Siemens Healthineers adheres to the cybersecurity recommendations as defined the FDA Guidance "Content of Premarket Submissions for Management for Cybersecurity in Medical Devices," issued October 2, 2014 by implementing a process of preventing unauthorized access, modifications, misuse or denial of use, or the unauthorized use of information that is stored, accessed, or transferred from a medical device to an external recipient.
10. Performance Software Validation
To validate the AI-Rad Companion Organs RT software from clinical perspective, the autocontouring algorithms underwent a scientific evaluation. The results of clinical data-based software validation for the subject device AI-Rad Companion Organs RT (SW VA50A) demonstrated equivalent performance in comparison to the predicate device (SW VA40A, K221305). The performance of the enhanced CT organ contouring algorithm is comparable to the predicate device and comparable reference literature and cleared devices. The performance of the MR contouring algorithms is compared to the reference device, MRCAT Pelvis (K182888). A complete scientific evaluation report is provided in support of the device modifications.
MR Contouring Algorithm Performance
The performance of the AI-Rad Companion Organs RT has been validated in a retrospective performance study on MR data previously acquired (N= 66, data from multiple clinical sites across North America & Europe). Ground truth annotations were established following RTOG and clinical guidelines using manual annotation. The dice coefficient and the absolute symmetric surface distance (ASSD), were determined to quantify the similarity between the automatically contoured OAR and the manually delineated contours (ground truth). We also introduce the failure rate in this section. The results of subject device were equivalent or had better performance than the predicate device.
To have a fair comparison between reference and subject device, we compute the average Dice coefficient only for common organs available in both devices (Prostate, Bladder, Rectum, Penile Bulb and Seminal Vesicle).
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Validation Testing Subject | Acceptance Criteria |
---|---|
MR Contouring Organs | The average segmentation accuracy (Dice value) of all subject device organs should be equivalent or better than the overall segmentation accuracy of the predicate device The overall fail rate for each organ/anatomical structure is smaller than 15% |
Table 3: Acceptance Criteria of AIRC Organs RT VA50
| AI-Rad Companion Organs RT VA50A
(MR Contouring) | ||||||
---|---|---|---|---|---|---|
Dice [%] | ASSD [mm] | Fail [%] | ||||
Avg | Std | 95 % CI | ||||
Bootstrap | Avg | Std | 95 % CI | |||
Bootstrap | 2.75 | |||||
85.75 | 6.48 | [82.85, 87.58] | 1.25 | 1.28 | [0.95, 2.02] |
Table 4: Performance results of subject device
Dice % Average | 95% CI | |
---|---|---|
AI-Rad Companion Organs RT VA50 – all organs | 86 | (83-88) |
AI-Rad Companion Organs RT VA50 – common | ||
organs | 82 | (78-84) |
MRCAT Pelvis (K182888) – all organs | 77 | (75-79) |
Table 5: Performance results of subject device compared to the reference device
| Organ Name | No.
Study | Dice (%) | | | | ASSD (mm) | | | | |
|-----------------|--------------|----------|-------|-------|---------------|-----------|------|------|------|-------------|
| | | AVG | STD | MED | 95%CI | | AVG | STD | MED | 95%CI |
| Bladder | 36 | 91.32 | 6.85 | 93.48 | (87.69 92.87) | | 0.91 | 1.82 | 0.43 | (0.54 2.09) |
| Rectum | 36 | 84.87 | 6.21 | 86.61 | (82.56 86.67) | | 1.32 | 1.64 | 0.74 | (0.97 2.23) |
| Anal Canal | 36 | 75.78 | 7.43 | 77.43 | (73.17 78.04) | | 1.19 | 0.65 | 1.01 | (1.0 1.44) |
| Penile Bulb | 36 | 82.29 | 6.89 | 82.61 | (79.82 84.46) | | 0.55 | 0.46 | 0.41 | (1.27 4.77) |
| Seminal Vesicle | 36 | 66.08 | 18.65 | 72.97 | (57.19 71.3) | | 2.06 | 3.63 | 1.1 | (1.27 4.77) |
| Prostate | 36 | 84.76 | 5.32 | 85.68 | (82.59 86.44) | | 0.94 | 0.62 | 0.78 | (0.78 1.27) |
| Femur Right | 30 | 94.29 | 2.21 | 94.63 | (92.94 94.82) | | 1.1 | 0.45 | 1.03 | (0.99 1.37) |
| Femur Left | 30 | 94.38 | 2.88 | 95.01 | (92.68 95.09) | | 1.06 | 0.52 | 0.99 | (0.94 1.36) |
| Body | 30 | 98.01 | 1.88 | 98.89 | (97.0 98.49) | | 2.12 | 1.74 | 1.2 | (1.6 2.88) |
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Average
1.25 87.48 (82.85 87.58) 1.28 0.85 2.02) 85.75 6.48 (0.95
Table 6: Detailed Performance Results
T1 Dixon W | T2 W TSE | |
---|---|---|
# of Datasets | 30 | 36 |
Data Origin | USA: 15 | |
EU:15 | USA: 25 | |
EU: 11 | ||
Age | 22 years and older | 22 years and older |
Manufacturer | Siemens Healthineers | Siemens Healthineers |
Annotated Organs | Body | |
Femoral Head Right | ||
Femoral Head Left | Anal Canal, Prostate, Rectum, Penile | |
Bulb, Seminal Vesicle, Bladder | ||
Slice Thickness | = 70: 4 | |
Unknown: 110 | ||
*unknown due to data | ||
minimization on | ||
customer site | 70: 12 | 70: 12 |
Manufacturer | Siemens: 73 | GE: 18 |
Philips: 22 | Siemens: 53 | |
GE: 59 | ||
Philips: 119 | ||
Varian: 44 | ||
Others: 26 | ||
Body Region | Head & Neck: 24 | |
Thorax & Abdomen: 20 | ||
Pelvis: 29 | Head & Neck: 40 | Head & Neck: 50 |
Thorax: 81 | ||
Abdomen: 115 | ||
Pelvis: 55 | ||
Slice Thickness | 3: 1 | 3: 3 |
Table 7: Validation Testing Data Information
Organ Group | No. Training | No. Validation |
---|---|---|
Cochlea | 215 | 24 |
Thyroid | 293 | 56 |
Constrictor Muscles | 335 | 89 |
Chest Wall | 48 | 12 |
LN Supraclavicular, Axilla Levels, | ||
Internal Mammaries | 228 | 28 |
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Duodenum, Bowels, Sigmoid | 332 | 84 |
---|---|---|
Stomach | 371 | 92 |
Pancreas | 369 | 92 |
Pulmonary Artery, Vena Cava, Trachea, Spinal Canal, Proximal Bronchus | 113 | 34 |
Ventricles & Atriums | 706 | 273 |
Descending Coronary Artery | 252 | 45 |
Penile Bulb | 854 | 213 |
Uterus | 381 | 94 |
Table 8: Training Dataset Characteristics
Standard Annotation Process
In both the annotation process for the training and validation testing data, the annotation protocols for the OAR were defined following the NRG/RTOG guidelines. The ground truth annotations were drawn manually by a team of experienced annotators mentored by radiologists or radiation oncologists using an internal annotation tool. Additionally, a quality assessment including review and correction of each annotation was done by a board-certified radiation oncologist using validated medical image annotation tools.
Validation Testing & Training Data Independence
The training data used for the training of the algorithm is independent of the data used to test the algorithm.
11. Clinical Tests
No clinical tests were conducted to test the performance and functionality of the modifications introduced within AI-Rad Companion Organs RT. Verification and validation of the enhancements and improvements have been performed and these modifications have been validated for their intended use. The data from these activities were used to support the subject device and the substantial equivalence argument. No animal testing has been performed on the subject device.
12. Safety and Effectiveness
The device labeling contains instructions for use and any necessary cautions and warnings to ensure safe and effective use of the device.
Risk management is ensured via ISO 14971:2019 compliance to identify and provide mitigation of potential hazards in a risk analysis early in the design phase and continuously throughout the development of the product. These risks are controlled via measures realized during software development, testing and product labeling.
13. Conclusion
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Based on the discussion and validation testing and performance data above, the proposed device is determined to be as safe and effective as its predicate device, AI-Rad Companion Organs RT VA40 (K221305). In addition, the proposed device performs comparably to the reference device, MRCAT Pelvis (K182888).