K Number
K242019
Device Name
GXR-Series Diagnostic X-Ray System
Manufacturer
Date Cleared
2025-01-07

(181 days)

Product Code
Regulation Number
892.1680
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays.
Device Description
The GXR Series Diagnostic X-ray System consists of a combination of an x-ray generator, and associated equipment such as tube stand, patient table, and, digital imaging system.
More Information

No
The document mentions "image processing" and "anatomical view-based digital image processing" which are common in medical imaging devices and do not necessarily indicate AI/ML. There is no mention of AI, ML, deep learning, neural networks, or any related terms. The description of performance studies and key metrics also lacks any indication of AI/ML-specific evaluation methods.

No
The device is described as a "Diagnostic X-ray System" intended for "obtaining human anatomical images for medical diagnostic by using X-rays," which indicates its purpose is for diagnosis, not treatment.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states that the device is "intended for use in obtaining human anatomical images for medical diagnostic by using X-rays." This directly indicates its role in diagnosis.

No

The device description explicitly states it consists of a combination of an x-ray generator and associated hardware like a tube stand, patient table, and digital imaging system, in addition to software for image processing.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is "obtaining human anatomical images for medical diagnostic by using X-rays." This describes an imaging system used to visualize internal structures of the body, not a device that analyzes samples (like blood, urine, or tissue) outside of the body to diagnose a condition.
  • Device Description: The description details components of an X-ray imaging system (generator, tube stand, table, digital imaging system). These are all external components used for capturing images of the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, reagents, or performing tests on specimens. The focus is entirely on image acquisition and processing.

IVD devices are specifically designed to perform tests on specimens derived from the human body to provide information for diagnosis, monitoring, or screening. This device's function is to create images of the body itself.

N/A

Intended Use / Indications for Use

The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays.

Product codes

KPR, MQB

Device Description

The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays.

The GXR-Series Diagnostic X-ray System consists of a combination of an x-ray generator, and associated equipment such as tube stand, patient table, and, digital imaging system.

The "GXR-S/CS/US" system provides excellent performance and stable operation while state-of-the-art image quality. The "GXR-S/CS/US" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility, and long-term stability. It includes an Automatic Calibration function and a control console that offers graphic waveform and data of x-ray exposure. The "GXR-C" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability with capacitor assisted general line power supply. The "GXR-U" series provides same output rating and performances of line-powered generators, requiring only 900VA line power for battery charging. The operator control console is designed in two types: one with a large graphic LCD panel display and a soft membrane switch, and another with a Touch function through a large graphic LCD panel display and intuitive GUI configuration. Remote Diagnosis Software can generate reports and transfer them via internet to the manufacturer, enabling fast and accurate diagnosis. The APR (Anatomical Programming) and optional AEC (Automatic Exposure Control) features provide optimized exposure factors.

The "GXR-SD/CSD/USD" system also provides excellent performance and stable operation with state-of-the-art image quality. It incorporates digital flat panel detector technology for improved workflow, exam speed, and comfort. The digital flat panel detector offers excellent spatial resolution, MTF, DQE, and stability. Selection of an anatomical study on the imaging software automatically sets up the x-ray generator's preprogrammed exposure technique and post-image processing. High resolution grid supplies excellent image quality. A high performance imaging workstation and "RADMAX" software provide a convenient interface and easy operation. Anatomical view-based digital image processing automatically optimizes and enhances image quality. Automatic image storage and print with DICOM 3.0 networking capability increases throughput and decreases examination time. Remote diagnosis function enables fast and accurate problem diagnosis and saves service cost and system downtime.

The software (X-CON for Analog Diagnostic X-ray Systems and RADMAX for Digital Diagnostic X-ray Systems) performs system control and radiological image processing. Both software versions are identical to the predicate device and are considered "Moderate" Level of Concern. The device does not contact the patient, nor does it control any life sustaining devices. A physician, providing ample opportunity for competent human intervention, interprets all images and information being displayed and printed.

The operating principles involve setting irradiation conditions (40 to 125 (150) kVp, 10 to 400 (500) mA). X-rays generated enter an X-ray Film or Flat Panel detector to produce a radiographic image. For Digital Diagnostic X-ray Systems, an image is generated after image processing.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

Human anatomical images

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Medical professional Facility.
To prevent excess radiation exposure to patient and operator from either primary or secondary radiation, this "GXR-Series Diagnostic X-ray System" must be operated and serviced by trained personnel who are familiar with the safety precautions required.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The GXR-Series Diagnostic X-Ray System has been assessed and tested and has passed predetermined testing criteria. The Validation Test Plan was designed to evaluate input functions, output functions, and actions performed by the subject device and followed the process documented in the System Validation Test Plan. Nonclinical testing results are provided in the 510(k). Validation testing indicated that as required by the risk analysis, designated individuals performed all verification and validation activities and that the results demonstrated that the predetermined acceptance criteria were met.

Key Results:

  • Verification and Validation testing concluded no impact on safety and effectiveness for Image Processing Module 4.
  • All modified flat panel detectors have been verified according to "SSXI non-clinical performance data". There is no new potential or increased safety risks concerning this difference.
  • Models for patient tables have been tested against International Safety and EMC Standards. Any differences do not change or add new potential safety risks. Determination is "No negative impact on safety or effectiveness".
  • Models for wall bucky stand have been tested against International Safety and EMC Standards. Any differences do not change or add new potential safety risks. Determination is "No negative impact on safety or effectiveness".
  • Models for Image Processing Module have been conducted Verification activity. Any differences do not change or add new potential safety risks. Determination is "No negative impact on safety or effectiveness".
  • Based on the performance as documented in the V&V Testing, the subject device was found to have a safe and effectiveness profile that is similar to the predicate device.
  • The subject device conforms to all applicable aspects of 21CFR 1020.30.
  • Nonclinical tests demonstrate that the device is as safe, as effective, and performs comparably to the predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K202572

Reference Device(s)

K221345, K210316, K223930, K210314, K182537

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

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January 7, 2025

DRGEM Corporation % Jongseon Park Regulatory Affairs | Engineer 7F, E-B/D Gwangmyeong Techno-Park, 60Haan-ro, GwangMyeong-si, Gyeonggi 14322 SOUTH KOREA

Re: K242019

Trade/Device Name: GXR-series diagnostic x-ray system Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary X-Ray System Regulatory Class: Class II Product Code: KPR, MQB Dated: July 10, 2024 Received: December 3, 2024

Dear Jongseon Park:

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.

1

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 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.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

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-regulatory

2

assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Lu Jiang

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

Enclosure

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Indications for Use

510(k) Number (if known) K242019

Device Name GXR-Series Diagnostic X-Ray System

Indications for Use (Describe)

The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays.

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

K242019

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

I. SUBMITTER [21 CFR 807.92(a) (1)]

DRGEM Corporation 7F E-B/D Gwangmyeong Techno-Park 60, Haan-ro, Gwangmyeong-si, Gyeonggi-do, 14322 Korea Email: pjs98@drgem.co.kr TEL: +82-70-4285-3734, FAX: +82-2-869-8567 Contact Person: Mr. Jongseon PARK, Engineer | Regulatory Affairs Date Prepared: June 15, 2024

II. PROPOSED DEVICE INFORMATION [21 CFR 807.92(a) (2)]

Product Name:GXR-Series Diagnostic X-Ray System
Common Name:Stationary X-Ray System
Classification Name:Stationary x-ray system
Product Code:KPR
Regulation Number:892.1680
Associated Product Code:MQB
Regulatory Class:II

Available Device Models : (Models: GXR32S, GXR-40S, GX
82S, GXR-C32S, GXR-C40S, GXR-C52S, GXR-U32S, GXR

XR-52S, GXR-68S, GXR-R-U40S, GXR-32SD, GXR-40SD, GXR-52SD, GXR-68SD, GXR-82SD, GXR-C32SD, GXR-C40SD, GXR-C52SD, GXR-U32SD, GXR-U40SD, FDR Clinica FGXR-32S, FDR Clinica FGXR-40S, FDR Clinica FGXR-52S, FDR Clinica FGXR-68S, FDR Clinica FGXR-82S, FDR Clinica FGXR-C32S, FDR Clinica FGXR-C40S, FDR Clinica FGXR-C52S, FDR Clinica FGXR-U32S, FDR Clinica FGXR-U40S)

III. PREDICATE DEVICES INFORMATION [21 CFR 807.92(a) (3)]

Product Name:GXR-series Diagnostic X-Ray System, (Models GXR-S, GXR-SD series)
Common Name:Stationary X-Ray System
Classification Name:Stationary x-ray system
510(k) Number:K202572
Product Code:KPR
Regulation Number:892.1680
Regulatory Class:II

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IV. DEVICE DESCRIPTION [21 CFR 807.92(a) (4)]

· Device Features:

· GXR-S/CS/US 'Analog Diagnostic X-ray System'

" GXR-S/CS/US" system provides excellent performance and stable operation while state-of-the-art image quality. The "GXR-S/CS/US" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility, and longterm stability.

Automatic Calibration function of the generator will minimize calibration time and set correct calibration value. Also the control console of "GXR", "GXR-U" series offers graphic waveform and data of x-ray exposure. So, it is not needed to perform the manual calibration procedure with measurement equipment. Naturally, the generator supports Automatic, Semi-auto and Manual Calibration functions. Adaptable calibration function keeps up long-term stability and accuracy by trimming calibration data whenever xray exposed.

The "GXR-C" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability with capacitor assisted general line power supply.

Only 3KVA line power capacity is enough for x-ray generation up to 40KW, and "GXR-C" series provides minimum 100mAs output at maximum output rating without mA sliding down.

Also, maximum interval for full charging is 10 seconds after maximum output x-ray generation. Only 900VA line power capacity is enough for the battery charging, and "GXR-U" series provides same output rating and performances of line-powered generators.

The operator control console is designed in two types to be simple and user-friendly.

The first type features a large graphic LCD panel display and a soft membrane switch to allow easy selection or change of X-ray parameters.

The second type can be easily operated using the Touch function through a large graphic LCD panel display and intuitive GUI configuration.

Remote Diagnosis Software can make report about information of system, user, service and error by the USB connection between PC and control console, and transfer report to manufacturer via internet. So this function enables fast and accurate diagnosis on problems and saves service cost and system downtime. The APR (Anatomical Programming) and the optional AEC (Automatic Exposure Control) features give you controlled exposure factors, automatically optimized for the radiological study selected.

· GXR-SD/CSD/USD 'Digital Diagnostic X-ray System'

"GXR-SD/CSD/USD" system provides excellent performance and stable operation while state-of-the-art image quality.

The "GXR", "GXR-C", "GXR-U" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability.

Automatic Calibration function of the generator will minimize calibration time and set correct calibration value. Also the control console of "GXR", "GXR-U" series offers graphic waveform and data of x-ray exposure. So, it is not needed to perform the manual calibration procedure with measurement equipment. Naturally, the qenerator supports Automatic, Semi-auto and Manual Calibration functions.

Adaptable calibration function keeps up long-term stability and accuracy by trimming calibration data whenever xray exposed.

The "GXR-C" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability with capacitor assisted general line power supply.

Only 3kVA line power capacity is enough for x-ray generation up to 40kW, and "GXR-C" series provides minimum 100mAs output at maximum output rating without mA sliding down.

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Also, maximum interval for full charging is 10 seconds after maximum output x-ray generation.

Only 900VA line power capacity is enough for the battery charging, and "GXR-U" series provides same output rating and performances of line-powered generators.

Remote Diagnosis Software can make report about information of system, user, service and error by transfer report to manufacturer via internet. So this function enables fast and accurate diagnosis on problems and saves service cost and system downtime.

The APR (Anatomical Programming) and the optional AEC (Automatic Exposure Control) features give you controlled exposure factors, automatically optimized for the radiological study selected.

"GXR-SD/CSD/USD" provides state-of-the-art image quality; image processing and user interface; making the system easy to use.

"GXR-SD/CSD/USD" incorporates the digital flat panel detector technology.

Direct radiography via flat panel detector improves your workflow, exam speed and comfort with efficiency. Digital flat panel detector provides excellent spatial resolution, MTF, DQE and stability based on fine pixel pitch. Selection of an anatomical study on the imaging software automatically sets up the x-ray generator's preprogrammed exposure technique setting and post image processing for selected study. Also, high resolution grid supplies excellent image quality.

A high performance imaging workstation and "RADMAX" software serves you a convenient interface and easy operation. Anatomical view-based digital image processing automatically optimizes and enhances the quality of the captured images. Automatic image storage and print with DICOM 3.0 networking capability increases exam throughput and decreases examination time. Remote diagnosis function enables fast and accurate diagnosis on problems and saves service cost and system downtime.

· Device Identification:

The GXR Series Diagnostic X-ray System consists of a combination of an x-ray generator, and associated equipment such as tube stand, patient table, and, digital imaging system.

· Device Characteristics:

Software

The subject device 'GXR-Series Diagnostic X-ray System' use software (including firmware).

[GXR-S, CS, US 'Analog Diagnostic X-ray System'] Its S/W (X-CON) can perform system control such as the collimation size, filter selection, Control of Generator.

[GXR-SD, CSD, USD 'Digital Diagnostic X-ray System'] Its S/W (RADMAX) can perform processing the radiological image acquired from Solid State X-ray Imaging Device.

Both software being used is identical to the predicate device "GXR-series Diagnostic X-ray System", and its LOC (Level of Concern) is 'Moderate'.

Accordingly, this software (X-CON) is based on predicate device 'GXR-S series Diagnostic system.

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Software Level Determination

(Moderate Level of Concern)

The device does not contact the patient, nor does it control any life sustaining devices. A physician. providing ample opportunity for competent human intervention, interprets all images and information being displayed and printed.

· Environment of Use:

This "GXR-series Diagnostic X-ray System" is for use by medical professional Facility. To prevent excess radiation exposure to patient and operator from either primary or secondary radiation, this "GXR-Series Diagnostic X-ray System" must be operated and serviced by trained personnel who are familiar with the safety precautions required.

· Brief Written Description of the Device:

The operating principles are as follows.

The irradiation conditions are 40 to 125 (150) kVp at the photographing site, and the tube current is 10 to 400 (500) mA. When X-rays generated under X-ray irradiation conditions enter the X-ray Film or Flat Panel detector, the film or flat panel detects X-rays incident through the incident surface during X-ray irradiation, and finally generates a radiographic image when X-ray irradiation is completed (in case of Digital Diagnostic X-ray System, After Image processing, Digital Image for Diaqnosis has been generated).

V. INDICATION FOR USE [21 CFR 807.92(a) (5)]

The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays.

VI. TECHNOLOGICAL CHARACTERISTICS [21 CFR 807.92(a) (6)]

The Subject device 'GXR-Series Diagnostic X-ray System' (Model: GXR-S, GXR-SD series) is based on the Predicate Device (GXR-series, K202572) including the system control, Indication for use and mechanical design.

The differences between the subject device and the predicate device have been thoroughly tested and verified for safety and effectiveness by an accredited Safety and EMC testing laboratory.

This 510(k) submission describes some modifications to the previously cleared predicate devices the 'GXR-SD Series' (K202572). The changes to the predicate 'GXR-SD series' (K202572) include:

8

System Imaging Software 'RADMAX'

· Graphical user interface (GUI): GUI of system software updated in order to improve the look and feel of user interface for better visibility & faster workflow.

· Image Processing Module added (Module 4): We conducted performance verification of Flat Panel detectors compared to existing image processing modules. Verification and Validation testing concluded no impact on safety and effectiveness.

Component Change

·10x12 inch Wireless Flat Panel detectors have been added

·Luna1012X manufactured by IRAY Technoloqy, FDA Cleared K221345

·14x17 inch Wireless Flat Panel detectors have been added

·Mars1417X manufactured by IRAY Technology, FDA Cleared K210316 ·A1417MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930 ·F1417MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930

·17x17 inch Wireless Flat Panel detectors have been added

·Mars1717X manufactured by IRAY Technology, FDA Cleared K210314 ·A1717MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930

·Patient Table option has been added

· PBT-6 (Deluxe) option manufactured by DRGEM

·Wall Bucky stand option has been added

·WBS (Manual Plus) option manufactured by DRGEM ·WBS-TA (Actuator) option manufactured by DRGEM ·WBS-TA (Deluxe) option manufactured by DRGEM

·Tube Stand option has been added

·TS-CSP (15inch LCD Panel) option manufactured by DRGEM

·Tube Housing Assembly models have been added

·RTM90HS Tube Housing Assembly option manufactured by IAE ·RTM101HS Tube Housing Assembly option manufactured by IAE ·RTC600HS Tube Housing Assembly option manufactured by IAE ·UH-6FC-31E Tube Housing Assembly option manufactured by Fujifilm

·GXR-Series Diagnostic X-ray System's 'Variant models' have been added

: Variant models (FDR Clinica FGXR-S, CS, US) of Subject Device have been added. These models are manufactured for OEM Contractor (Fujifilm Corporation).

Difference between predicate device (GXR-S, CS, US 'Analog Diagnostic X-ray

System') and OEM Model (FDR Clinica FGXR-S, CS, US) has only label, exterior color, model name.

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Substantial Equivalence Comparison

VII.SUBSTANTIAL EQUIVALENCE [21 CFR 807.92(b)]

Substantial Equivalence Comparison Table

ItemSubject DevicePredicate DeviceImpact of Differences
Device NameGXR-Series
Diagnostic X-ray SystemGXR-Series
Diagnostic X-ray SystemSame
510(k) numberK242019K202572-
Indication for useThe GXR-Series Diagnostic X-ray System is intended
for use in obtaining human anatomical images for
medical diagnostic by using X-rays.GXR-Series Diagnostic X-ray
System is a stationary X-ray
imaging system, for the
purpose of acquiring X-ray
images of the desired parts of
a patient's anatomy. This
device is not intended for
mammography or bone
density applications.Both devices are
fundamentally intended to
acquire anatomical images of
patients for medical
diagnostic purposes.
This means they essentially
share the same indication for
use. Some contents
mentioned in the predicate
device's Indication for use are
described in the
IFU(operation
Manual)_Contraindication
section of the subject device.
ManufacturerDRGEM CorporationDRGEM CorporationSame
Analog Diagnostic
X-ray SystemDigital Diagnostic
X-ray SystemAnalog
Diagnostic
X-ray SystemDigital
Diagnostic
X-ray System
DRGEMFujifilmDRGEMDRGEMDRGEMVariant models (FDR Clinica
FGXR-S, CS, US) of Subject
Device have been added.
Model
Name•GXR-32S•FDR Clinica
FGXR-32S•GXR-32SD•GXR-32S•GXR-32SDThese models are
manufactured for OEM
Contractor (Fujifilm
Corporation).
•GXR-40S•FDR Clinica
FGXR-40S•GXR-40SD•GXR-40S•GXR-40SDDifference between predicate
device (GXR-S, CS, US
'Analog Diagnostic X-ray
System') and OEM Model
(FDR Clinica FGXR-S, CS,
US) has only label, exterior
color.
All Specification is same as
predicate device (GXR-S, CS,
US).
•GXR-52S•FDR Clinica
FGXR-52S•GXR-52SD•GXR-52S•GXR-52SD
•GXR-68S•FDR Clinica
FGXR-68S•GXR-68SD•GXR-68S•GXR-68SD
•GXR-82S•FDR Clinica
FGXR-82S•GXR-82SD•GXR-82S•GXR-82SD
•GXR-C32S•FDR Clinica
FGXR-C32S•GXR-C32SD•GXR-C32S•GXR-C32SD
•GXR-C40S•FDR Clinica
FGXR-C40S•GXR-C40SD•GXR-C40S•GXR-C40SD
•GXR-C52S•FDR Clinica
FGXR-C52S•GXR-C52SD•GXR-C52S•GXR-C52SD
•GXR-U32S•FDR Clinica
FGXR-U32S•GXR-U32SD•GXR-U32S•GXR-U32SD
•GXR-U40S•FDR Clinica
FGXR-U40S•GXR-U40SD•GXR-U40S•GXR-U40SD

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Image /page/10/Picture/0 description: The image shows the logo for DRGEM. The letters "DR" are in black, and the letters "GEM" are in teal. Below the logo is the text "Your Best Healthcare" in a smaller font.

1. High Frequency X-ray Generator
Output Power Rating (kW)32kW, 40kW, 52kW, 68kW, 82kW32kW, 40kW, 52kW, 68kW, 82kW
Generator models (manufactured by DRGEM)•GXR-32•GXR-32
•GXR-40•GXR-40
•GXR-52•GXR-52
•GXR-68•GXR-68
•GXR-82•GXR-82
•GXR-C32•GXR-C32
•GXR-C40•GXR-C40
•GXR-C52•GXR-C52
•GXR-U32•GXR-U32
•GXR-U40•GXR-U40
Line voltage220~230VAC
380/400/480VAC220~230VAC
380/400/480VAC
2. Solid State X-ray Imaging Device (Digital Diagnostic X-ray System Only)
Flat panel Detector•PaxScan4343R v3 / VAREX•PaxScan4343R v3 / VAREXAdditional Solid State X-ray
Image detectors from the
predicate can be used with
the system. The system has
been tested and there is "No
negative impact on safety or
effectiveness".
And also, All modified flat
panel detector have been
verified according to "SSXI
non-clinical performance
data"
There is no new potential or
increased safety risks
concerning were raised
because of this difference.
•PaxScan4343RC / VAREX•PaxScan4343RC / VAREX
•PaxScan4336W v4 / VAREX•PaxScan4336W v4 / VAREX
•4343W (Basic) / VAREX•4343W / VAREX
•XRpad2 3025 HWC-M / VAREX•XRpad2 3025 HWC-M / VAREX
•XRpad2 4343 HWC-M / VAREX•XRpad2 4343 HWC-M / VAREX
•XRpad2 4336 HWC-M / VAREX•XRpad2 4336 HWC-M / VAREX
•Mano4343T / IRAY•Mano4343T / IRAY
•Mano4343X / IRAY•Mano4343X / IRAY
•Mano4336W / IRAY•Mano4336W / IRAY
•Mano4343W / IRAY•Mano4343W / IRAY
•Mars1417X / IRAY•VIVIX-S1417N / VIEWWORKS
•Mars1717X / IRAY•VIVIX-S1717N / VIEWWORKS
•Luna1012X / IRAY
•A1417MCW / H&abyz
A1717MCW / H&abyz
F1417MCW / H&abyz
3. Patient table
PBT-4 (Motorized)PBT-4 (Motorized)Yes, there is a difference. Models have been tested against International Safety and EMC Standards. Any differences between the subject device and predicate device do not change or add new potential safety risks. It is our determination that there is "No negative impact on safety or effectiveness" and there are no new potential or increased safety risks concerning this difference
PBT-6 (Motorized)PBT-6 (Motorized)
PBT-6 (Deluxe)PBT-1
Table TopLongitudinal$1,100(\pm550)mm \pm10mm$
$840(\pm420)mm \pm10mm$
$640(\pm320)mm \pm10mm$
Transverse (Later a)$350(\pm150)mm \pm10mm$
Configuration modelVerticalTravel$350(510\sim860)mm \pm5mm$
Speed13~19mm/sec±10%
(Full load to no load)
OperatingMotorized movement by foot/Hand grip Switch Linear Actuator
BuckyMechanical•740mm(±10)mm with standard tray
•500mm(±10)mm with rotating tray
Table Tracking•710mm(±10)mm with standard tray
(automatically move only)
PBT-1
PDT-1
4. Wall Bucky stand
WBS (Manual)WBS (Manual)Yes, there is a difference. Models have been tested against International Safety and EMC Standards. Any differences between the subject device and predicate device do not change or add new potential safety risks. It is our determination that there is "No negative impact on safety or effectiveness" and there are no new potential or increased safety risks concerning this difference
WBS-TM (Manual)WBS-TM (Manual)
WBS (Manual Plus)WBS (Motorized)
Cassette stroke1,220mm (300~1,520mm from floor to Bucky center) ± 10mm
1,390mm (300~1,690mm from floor to Bucky center) ± 10mm
1,640mm (300~1,940mm from floor to Bucky center) ± 10mm
Electrical Rating100-240VAC, 160VA, 50/60Hz
Configuration modelDimension/ Weight1,749(H) x 659(W) x 445(D) mm / 113kg(249lbs)
1,919(H) x 659(W) x 445(D) mm / 116kg(255lbs)
2,169(H) x 659(W) x 445(D) mm / 120kg(264lbs)
WBS (Motorized)WBS-TM (Motorized)
WBS-TM (Motorized)WBS-TA (Motorized)
WBS-TA (Motorized)
WBS-TA (Actuator)
Cassette stroke1,526mm (283~1,809mm from floor to Bucky center)±10mm

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Image /page/11/Picture/0 description: The image contains the logo for DRGEM, a healthcare provider. The text "DRGEM" is displayed in bold, with "DR" in black and "GEM" in teal. Below the logo, the tagline "Your Best Healthcare" is written in a smaller, lighter font.

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Image /page/12/Picture/0 description: The image shows the logo for DRGEM, a healthcare company. The logo features the company name in bold, with "DR" in black and "GEM" in teal. Below the company name is the tagline "Your Best Healthcare" in a smaller, lighter font. The overall design is clean and professional, conveying a sense of trust and reliability.

1,526mm (450~1,976mm from floor to Bucky surface)±10mm
Tilting Range -20°~90
Tilting SpeedUp 8.2°/s
down 5.1°/s
WBS-TA (Deluxe)
1,566mm (283~1,849mm from floor to Bucky center)±10mm Cassette stroke
1,566mm (591~2,157mm from floor to Bucky surface)±10mm
Tilting Range -20°~90
Tilting SpeedUp 8.2°/s
down 5.1°/s
Vertical SpeedNormal 6.2 cm/s ± 15% (Up),
5.6cm/s ± 15% (Down)
Fast 12.1cm/s ± 15% (Up),
11.8cm/s ± 15% (Down)
5. Tube stand
Configuration modelTS-FM6 (Motorized)TS-FM6 (Motorized)
TS-FC6 (Motorized)TS-FC6 (Motorized)
TS-FC4 (Motorized)TS-FC4 (Motorized)
TS-FC2 (Motorized)TS-FC2 (Motorized)
TS-FM6 (Manual)TS-FM6 (Manual)
TS-FC6 (Manual)TS-FC6 (Manual)
TS-FC4 (Manual)TS-FC4 (Manual)
TS-FC2 (Manual)TS-FC2 (Manual)
TS-CSA (Manual, Motorized)TS-CSA (Manual, Motorized)
TS-CSP (Manual, Motorized) /
(7inch,15inch LCD panel)TS-CSP (Manual, Motorized) /
(7inch LCD panel)
TS-CSE (Manual)TS-CSE (Manual)
Tube Rotation Angle±135°, ±180°±135°, ±180°
6. X-ray tube housing Assembly
Configuration modelE7239XE7239X
DXT-8MDXT-8M
E7242XE7242X
DXT-11MDXT-11M
E7843XE7843X
DXT-10MDXT-10M
E7876XE7876X
E7884XE7884X
DXT-12MDXT-12M
E7252XE7252X
DXT-14UDXT-14U
RAD-14RAD-14
DXT-15UDXT-15U
-RAD-21-RAD-21
-RAD-60-RAD-60
-RAD-92-RAD-92
-E7255FX-E7255FX
-E7254FX-E7254FX
-E7869X-E7869X
-RTM90HS
-RTM101HS
-RTC600HS
-UH-6FC-31E
Max. kV125kV, 150kV125kV, 150kV
7. Collimator (Beam Limiting Device)Yes, there is a difference.
-R108-R108Collimator Configuration
-DXC-RML-DXC-RML, DXC-RMHModels have been partially
deleted based on predicate
Configuration
model-R302MLP/A-R302A, R302MLP/A,device.
R302MFMLP/AIt is our determination that
-MCRthere is "No negative
impact on safety or
Lamp TypeLED lamp
(Over 160LUX at 100cm SID)LED and Halogen lamp
(Over 160LUX at 100cm SID)effectiveness" and there
are no new potential
Electrical
Rating3VDC (1.5 V Battery x 4ea), 3mAor increased safety risks
concerning this difference
8. Image Processing and Storage (Digital Diagnostic X-ray System Only)
Configuration
modelRADMAXRADMAXsame
FDA Cleared--K182537-
Software
VersionRADMAX 1.02 VRADMAX 1.01 V- see below difference
Horizontal FlipYesYessame
Vertical FlipYesYessame
Rotate
CW/CCWYesYessame
Text
AnnotationYesYessame
Ruler:
Distance tooYesYessame
Angle
measurement
toolYesYessame
ZoomYesYessame
MagnifyYesYessame
Image panningYesYessame
Auto fitting to
window sizeYesYessame
Image crop/cutYesYessame
Image CopyYesYessame
Recover the
original imageYesYessame
CD Burning
DICOM PrintYesYessame
Image
StitchingYesYessame
Image
Processing
Module• MODULE 1
Edge Enhancement: 0 ~ 50
Contrast Factor : 1 ~ 200
Image Frequency : 0 ~ 20
Image Latitude : -10 ~ 10
Sharpness : 0 ~ 100

• MODULE 2
Histogram Optimization : -100 ~ 100
Skin line Weight : -100 ~ 100
Latitude Compression : -100 ~ 100
Contrast Enhancement : -100 ~ 100
Edge Enhancement : -100 ~ 100
Noise Suppression : -100 ~ 100
Gamma : -20 ~ 20

• MODULE 3
Global Brightness : -100 ~ 100
Global Contrast : -100 ~ 100
Latitude Compression : -100 ~ 100
S-Structure Enhancement : -100 ~ 100
Noise Suppression : -100 ~ 100
Gamma : -20 ~ 20

• MODULE 4
Global Contrast : -30 ~ 30
Global Brightness : -20 ~ 20
Local Contrast : 0 ~ 20
Small Enhancement : 0 ~ 20
Latitude Reduction : -20 ~ 20
Noise Suppression : 0 ~ 20
Gamma : -20 ~ 20 | • MODULE 1
Edge Enhancement: 0 ~ 50
Contrast Factor : 1 ~ 200
Image Frequency : 0 ~ 20
Image Latitude : -10 ~ 10
Sharpness : 0 ~ 100

• MODULE 2
Histogram Optimization : -100 ~ 100
Skin line Weight : -100 ~ 100
Latitude Compression : -100 ~ 100
Contrast Enhancement : -100 ~ 100
Edge Enhancement : -100 ~ 100
Noise Suppression : -100 ~ 100
Gamma : -20 ~ 20

• MODULE 3
Global Brightness : -100 ~ 100
Global Contrast : -100 ~ 100
Latitude Compression : -100 ~ 100
S-Structure Enhancement : -100 ~ 100
Noise Suppression : -100 ~ 100
Gamma : -20 ~ 20 | Yes, there is a difference.
Models have been
conducted Verification
activity. Any differences
between the subject device
and predicate device do
not change or add new
potential safety risks. It is
our determination that
there is "No negative
impact on safety or
effectiveness" and there
are no new potential
or increased safety risks
concerning this difference |

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Image /page/15/Picture/0 description: The image is a logo for DRGEM, a healthcare company. The logo features the text "DRGEM" in a bold, sans-serif font, with "DR" in black and "GEM" in teal. Below the company name is the tagline "Your Best Healthcare" in a smaller, lighter font.

VIII. SUMMARY OF NON-CLINICAL Data [21 CFR 807.92(b) (1)]

Nonclinical Testing:

The GXR-Series Diagnostic X-Ray System, has been assessed and tested and has passed predetermined testing criteria. The Validation Test Plan was designed to evaluate input functions, output functions, and actions performed by the subject device and followed the process documented in the System Validation Test Plan.

Nonclinical testing results are provided in the 510(k). Validation testing indicated that as required by the risk analysis, designated individuals performed all verification and validation activities and that the results demonstrated that the predetermined acceptance criteria were met.

| Std # | Safety/EMC Standards Description | FDA Rec.
Standard # |
|-----------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|
| IEC 60601-1-3 | Medical electrical equipment
Part 1-3: General Requirements for Radiation Protection in Diagnostic X-Ray Equipment | 12-336 |
| IEC 60601-1-6 | IEC 60601-1-6 Edition 3.1 2013-10
Medical electrical equipment - Part 1-6: General requirements for basic safety and
essential performance - Collateral standard: Usability | 5-132 |
| IEC 60601-2-28 | IEC 60601-2-28
Medical electrical equipment Part 2: Particular requirements for the safety of X-ray source
assemblies and X-ray tube assemblies for medical diagnosis | 12-309 |
| IEC 60601-2-54 | IEC 60601-2-54
Medical electrical equipment
Part 2: Particular requirements for the basic safety and essential performance
of X-ray equipment for radiography and radioscopy | 12-348 |
| IEC 60601-1-2
(EMC) | IEC 60601-1-2 Edition 4.0 2014-02. Medical electrical equipment - Part 1-2: General
requirements for basic safety and essential performance - Collateral Standard:
Electromagnetic disturbances Requirements and tests. | 19-36 |
| IEC 62304:2006 | IEC 62304 Edition 1.1 2015-06 CONSOLIDATED VERSION
Medical device software - Software life cycle processes | 13-79 |
| IEC 60601-1 | Medical electrical equipment, Part 1: General requirements for basic safety and essential
performance | 19-46 |
| ISO 14971:2019 | ISO 14971:2019 Third Edition, Medical devices - Applications of risk management to
medical devices. | 5-125 |
| ISO 15223-1 | ISO 15223-1 Fourth Edition 2021-07, Medical devices - Symbols to be used with medical
device labels, labelling, and information to be supplied - Part 1: General requirements. | 5-134 |
| IEC 62366-1 | 62366-1 Edition 1.1 2020-06 CONSOLIDATED VERSION Medical devices - Part 1:
Application of usability engineering to medical devices | 5-129 |
| TR 60601-4-2 | TR 60601-4-2 Edition 1.0 2016-05 Medical electrical equipment - Part 4-2: Guidance and
interpretation - Electromagnetic immunity: performance of medical electrical equipment and
medical electrical systems | 19-19 |
| NEMA PS 3.1-
3.20 (2022) | Digital Imaging and Communications in Medicine (DICOM) Set | 12-349 |
| ISO IEC10918-1 | ISO IEC10918-1 First edition 1994-02-15 Information technology - Digital compression and
coding of continuous-tone still images: Requirements and guidelines [Including: Technical
Corrigendum 1 (2005)] | 12-261 |
| IEC 62494-1 | IEC 62494-1 Edition 1.0 (2008-08) Medical electrical equipment- Exposure index of digital
X-ray imaging systems - part 1: Definitions and requirements for general radiography | 12-215 |
| FDA Guidance | Pediatric Information for X-ray Imaging Device Premarket Notifications dated November 28, 2017 | |
| FDA Guidance | Format for Traditional and Abbreviated 510(k)s, Guidance for Industry and Food and Drug Administration
Staff, Document issued on September 13, 2019. | |
| FDA Guidance | Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices dated September 1, 2016 | |
| FDA Guidance | Guidance for Industry and FDA Staff Guidance for the Content of Premarket Submissions for Software
contained in Medical Devices, Document issued on: May 11, 2005 Medical Devices, Document issued on:
May 11, 2005 | |
| FDA Guidance | Content of Premarket Submissions for Device Software Functions Guidance for Industry and Food and
Drug Administration Staff Document issued on June 14, 2023. | |
| FDA Guidance | Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions
Guidance for Industry and Food and Drug Administration Staff Document issued on September 27, 2023. | |

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Summary:

Based on the performance as documented in the V&V Testinq, the subject device was found to have a safe and effectiveness profile that is similar to the predicate device. The following International Standards were used to develop and verify electrical safety, and EMC. GXR-Series Diagnostic X-Ray System has met all the requirements listed in the Standards except for inapplicable requirements (which are listed in the various test reports).

The subject device conform to all applicable aspects of 21CFR 1020.30.

IX. CONCLUSIONS [21 CFR 807.92(b) (3)]

The 510(k) Pre-Market Notification for GXR-series Diagnostic X-ray System, contains adequate information, data, and nonclinical test results to enable FDA - CDRH to determine substantial equivalence to the predicate device. The subject device and the predicate device are substantially equivalent in the areas of technical characteristics, general function, application, and intended use does not raise any new potential safety risks and is equivalent in performance to existing legally marketed devices.

Nonclinical tests demonstrate that the device is as safe, as effective, and performs comparably to the predicate devices.