(154 days)
Not Found
Yes
The device description mentions the "Auto ElastQ software feature is intended to assist users in making stiffness measurements using 2D-SWE in the liver by recommending specific frames and ROI positions to the user." This recommendation process, especially when compared to manual measurements in a performance study, strongly suggests the use of an algorithm that learns from data to make these recommendations, which is characteristic of machine learning.
No
The intended use explicitly states "diagnostic ultrasound imaging and fluid flow analysis," and the clinical environments are for "diagnosis of patients." While it can assist in image guidance during treatment, its primary function is diagnostic, not therapeutic.
Yes.
The "Intended Use / Indications for Use" section explicitly states "The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body" and similarly for Affiniti, consistently using the term "diagnostic ultrasound systems."
No
The device description explicitly states that the Auto ElastQ software feature is introduced onto existing EPIQ and Affiniti Series Diagnostic Ultrasound Systems, which are hardware-based ultrasound machines. While the submission is for a software feature, the overall medical device is a hardware system with integrated software.
Based on the provided information, the EPIQ and Affiniti Ultrasound Diagnostic Systems, even with the addition of the Auto ElastQ software feature, are not In Vitro Diagnostic (IVD) devices.
Here's why:
- IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, tissue) to obtain information for diagnostic or monitoring purposes.
- Device Function: The EPIQ and Affiniti systems are described as diagnostic ultrasound imaging and fluid flow analysis systems. They use ultrasound waves to create images of internal structures and analyze fluid movement within the body. This is an in vivo (within the living body) diagnostic method, not an in vitro (outside the living body) method.
- Intended Use: The intended use clearly states "diagnostic ultrasound imaging and fluid flow analysis of the human body," and lists various anatomical sites within the body.
- Device Description: The description focuses on the ultrasound system itself and a software feature that assists with measurements based on the ultrasound images. There is no mention of analyzing specimens taken from the body.
Therefore, these devices fall under the category of medical imaging devices used for diagnosis, which are distinct from IVD devices.
No
The clearance letter does not explicitly state that the FDA has reviewed and approved or cleared a Predetermined Change Control Plan (PCCP) for this specific device. The 'Control Plan Authorized (PCCP) and relevant text' section is marked as "Not Found".
Intended Use / Indications for Use
EPIQ: The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use: Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Cardiac), intra-luminal, intra-luminal, intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transveginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Affiniti: The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use: Abdominal, Cardiac Adult, Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculosketal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Product codes
IYN, IYO, ITX, OBJ, QIH
Device Description
The purpose of this Traditional 510(k) Pre-Market Notification is to introduce the Auto ElastQ software feature onto the EPIQ and Affiniti Series Diagnostic Ultrasound Systems. The proposed EPIQ Series Diagnostic Ultrasound System and Affiniti Series Diagnostic Ultrasound Systems with new Auto ElastQ software feature, which is a workflow-enhancement software feature, is equivalent to predicate device, K240850.
The Auto ElastQ software feature is intended to assist users in making stiffness measurements using 2D-SWE in the liver by recommending specific frames and ROI positions to the user.
No hardware changes to the EPIQ or Affiniti Systems are reguired when using the Auto ElastQ software feature, and existing, commercialized Philips transducers are used for the Auto ElastQ software feature. The feature is supported by EPIQ and Affiniti models running software version 12.0.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Ultrasound
Anatomical Site
Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult), Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Indicated Patient Age Range
Not Found
Intended User / Care Setting
appropriately trained healthcare professionals for clinics, hospitals, and clinical point-of-care.
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
Non-clinical verification testing was conducted to address the change and performance test data were provided to support the introduction of the subject software algorithm for the Auto ElastQ software feature. All software verification tests met the acceptance criteria.
A retrospective data analysis study was conducted to evaluate the performance of the Auto ElastQ software compared to manual measurements performed by expert readers, with the manual measurements used as ground truth for the study. The results demonstrated high agreement of Auto ElastQ algorithm-generated measurements with manual elastography measurements, meeting the acceptance criteria for the study.
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
A retrospective data analysis study was conducted to evaluate the performance of the Auto ElastQ software compared to manual measurements performed by expert readers.
The results demonstrated high agreement of Auto ElastQ algorithm-generated measurements, based on statistical analysis, with manual elastography measurements.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 892.1550 Ultrasonic pulsed doppler imaging system.
(a)
Identification. An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.
0
December 12, 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 & Human Services logo. To the right of that is the FDA logo, which consists of a blue square with the letters "FDA" in white. To the right of the blue square, the words "U.S. FOOD & DRUG ADMINISTRATION" are written in blue.
Philips Ultrasound LLC Chanrasmey White Senior Regulatory Affairs Specialist 22100 Bothell Everett Hwy Bothell, Washington 98021
Re: K242020
EPIQ Series Diagnostic Ultrasound System; Affiniti Series Diagnostic Ultrasound Trade/Device Name: Svstem Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic Pulsed Doppler Imaging System Regulatory Class: Class II Product Code: IYN, IYO, ITX, OBJ, OIH Dated: November 12, 2024 Received: November 12, 2024
Dear Chanrasmey White:
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/cfpm/pm.cfm identifies combination product submissions. The general controls 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 (OS) 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
1
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-regulatoryinformation/postmarketing-safety-reporting-combination-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-advice-comprehensive-regulatory-assistance/unique-deviceidentification-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-reporting-mdr-how-report-medicaldevice-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/deviceadvice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuingeducation/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-devices/deviceadvice-comprehensive-regulatory-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,
YANNA S. KANG -S
Yanna Kang, Ph.D. Assistant Director Mammography and Ultrasound 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
2
Indications for Use
510(k) Number (if known) K242020
Device Name
EPIQ Series Diagnostic Ultrasound System; Affiniti Series Diagnostic Ultrasound System
Indications for Use (Describe) EPIO:
The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Cardiac), intra-luminal, intra-luminal, intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transveginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Affiniti:
The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculosketal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare
3
| professionals for the purposes for which they were designed. However, nothing stated in the user information reduces |
|---|
| your responsibility for sound clinical judgement and best clinical procedure. |
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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4
510(k) Summary
#K242020
This summary of safety and effectiveness information is submitted in accordance with 21 CFR § 807.92. Date Prepared: December 9, 2024
| I. | Submitter | |
|---|---|---|
| Manufacturer Name and Address | Philips Ultrasound LLC | |
| 22100 Bothell Everett Hwy | ||
| Bothell, WA 98021-8431 USA | ||
| Contact Information | Chanrasmey White | |
| Senior Regulatory Affairs Specialist | ||
| 22100 Bothell Everett Hwy | ||
| Bothell, WA 98021-8431 USA | ||
| smey.white@philips.com | ||
| 1-207-249-5503 | ||
| Secondary Contact | Amy Yang | |
| Regulatory Affairs Director | ||
| 22100 Bothell Everett Hwy | ||
| Bothell, WA 98021-8431 USA | ||
| amy.yang@philips.com | ||
| 1-304-266-8208 | ||
| II. | Device | |
| Proprietary Name | EPIQ Series Diagnostic Ultrasound System | |
| Affiniti Series Diagnostic Ultrasound System | ||
| Common Name | Diagnostic Ultrasound System and Transducers | |
| Product Code; | ||
| Regulation Description; | ||
| Regulation Number | IYN; Ultrasonic Pulsed Doppler Imaging System; 21 CFR 892.1550 (Primary) | |
| IYO; Ultrasonic Pulsed Echo Imaging System; 21 CFR 892.1560 | ||
| ITX; Diagnostic Ultrasonic Transducer; 21 CFR 892.1570 | ||
| OBJ; Diagnostic Intravascular Catheter; 21 CFR 870.1200 | ||
| QIH; Medical image management and processing system; 21 CFR 892.2050 | ||
| Device Class | Class II | |
| Review Panel | Radiology | |
| Predicate Device | K240850; EPIQ Series Diagnostic Ultrasound System and | |
| Affiniti Series Diagnostic Ultrasound System |
lll. Device Description
The purpose of this Traditional 510(k) Pre-Market Notification is to introduce the Auto ElastQ software feature onto the EPIQ and Affiniti Series Diagnostic Ultrasound Systems. The proposed EPIQ Series Diagnostic Ultrasound System and Affiniti Series Diagnostic Ultrasound Systems with new Auto ElastQ software feature, which is a workflow-enhancement software feature, is equivalent to predicate device, K240850.
The Auto ElastQ software feature is intended to assist users in making stiffness measurements using 2D-SWE in the liver by recommending specific frames and ROI positions to the user.
5
Image /page/5/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters against a white background. The font is sans-serif and the letters are evenly spaced. The word is horizontally oriented and fills most of the frame.
No hardware changes to the EPIQ or Affiniti Systems are reguired when using the Auto ElastQ software feature, and existing, commercialized Philips transducers are used for the Auto ElastQ software feature. The feature is supported by EPIQ and Affiniti models running software version 12.0.
IV. Indications for Use
EPIQ:
The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult). Cephalic (Neonatal). Fetal/Obstetric. Gynecological. Intraoperative (Vascular). Intraoperative (Cardiac), intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode, M Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healthcare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Affiniti:
The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal. Cardiac Adult. Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult), Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculoskeletal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode. PW Doppler. CW Doppler. Color Doppler. Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healthcare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Image /page/5/Picture/16 description: The image shows the Philips logo, which is a blue shield with the word "PHILIPS" at the top and a wavy line with stars inside the shield. Below the logo is the number 2 in a simple, sans-serif font. The logo is a well-known brand symbol, and the number 2 is likely an identifier or label.
6
PHILIPS
V. Comparison of Technological Characteristics with the Predicate
The purpose of the submission is to introduce the Auto ElastQ software feature onto the EPIQ and Affiniti Series Diagnostic Ultrasound Systems. The proposed EPIQ and Affiniti Series Diagnostic Ultrasound Systems are all Track 3 Devices and comply with the referenced standards as well as the FDA Ultrasound Guidance Document, Guidance for Industrly and FDA Staff – Marketing Clearance of Diagnostic Ultrasound Systems and Transducers, issued in February 2023. The subject devices are substantially equivalent to the predicate devices (K240850).
| | EPIQ Series Diagnostic
Ultrasound System
Affiniti Series Diagnostic
Ultrasound System
Proposed Devices | EPIQ Series Diagnostic
Ultrasound System
Affiniti Diagnostic Ultrasound
System
(K240850)
Predicate Device | Comparison |
|----------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Feature | | | |
| USA FDA
Classification | Class II | Class II | Identical |
| Primary Product
Code | IYN | IYN | Identical |
| Primary Regulation
Number | 21 CFR 892.1550 | 21 CFR 892.1550 | Identical |
| Marketing Name of
Application | Auto ElastQ | ElastQ | Subject of this
submission |
| Application
Description | The Auto ElastQ software feature
is intended to assist the user in
making liver stiffness
measurements using 2D-SWE
through recommended particular
frames and ROI positions to the
user.
The system software will select up
to three frames that are assessed
to be the most stable and present
these to the user. The circle ROI
will be launched in the locations
that are identified to be
homogenous and temporally
stable. | The ElastQ feature ("manual
workflow") is a tool for measuring
the stiffness of the target organ
(liver) which requires the user to
review a loop of elastography
images displayed on the system
and uses the trackball to cine to
the frame(s) that are visually
perceived to be the most stable.
The circle ROI is then launched in
the center of the shear wave
imaging box, and the user
manually positions the ROI within
the box in a location that appears
to be homogenous and
representative of the tissue in the
entire box. | Subject of this
submission
The difference between
the predicate and the
subject device is:
The proposed Auto
ElastQ feature
recommends particular
frames and ROI locations
that are assessed to be
most stable homogenous
to the user.
The predicate device
requires users to review
a loop of elastography
images and then use the
trackball to cine to the
frames that are visually
perceived to be the most
stable. Then the user
must manually positions
the ROI in a location that
appears to be most
stable and homogenous. |
| | EPIQ Series Diagnostic | EPIQ Series Diagnostic
Ultrasound System | |
| Feature | Ultrasound System
Affiniti Series Diagnostic
Ultrasound System | Affiniti Diagnostic Ultrasound
System
(K240850)
Predicate Device | Comparison |
| | Proposed Devices | | |
| User Interface
Presentation | The Auto ElastQ workflow
analyzes the frames present in
the cineloop buffer. The system
software will automatically cine to
three frames that are assessed to
be the most stable and present
these to the user. The
measurement ROI will
automatically launch and be
placed on locations identified to
be homogeneous and temporally
stable.
Even though the Auto ElastQ
feature will suggest a particular
ROI placement, the user must
inspect the results and ensure
that it meets intended clinical use.
Otherwise, the user can make
adjustments to what the feature
proposes, by either selecting a
different frame or a different ROI
position. | In the current released software
("manual workflow"), the user
reviews a loop of elastography
images displayed on the system
display and then uses the
trackball to cine to the frame(s)
that are visually perceived to be
the most stable. The circle ROI is
then launched in the center of the
shear wave imaging box, and the
user manually positions the ROI
within the box in a location that
appears to be homogeneous and
representative of the tissue in the
entire box. | Subject of this
submission
The proposed Auto
ElastQ will provide a
recommendation to the
user where the predicate
device requires the user
to navigate the system
manually. |
| Compatible
transducers | Auto ElastQ Feature:
C5-1 | ElastQ Feature:
C5-1 | Identical, no new
transducers or modes
are being introduced in
this submission. |
| Measurements
Performed | The Auto ElastQ feature
calculates stiffness
measurements based on selected
frames and ROI positions
recommended to the user or
based on user adjustments to
what the feature recommended. | The ElastQ feature calculates
stiffness measurements based on
the manually selected frames and
ROI positions. | No new measurements
are being introduced in
this submission. The
subject of this
submission is to provide
workflow enhancements. |
| Application
performance | A retrospective data analysis
study was conducted to evaluate
the performance of the Auto
ElastQ software compared to
manual measurements performed
by expert readers.
The results demonstrated high
agreement of Auto ElastQ
algorithm-generated
measurements, based on
statistical analysis, with manual
elastography measurements. | N/A - the equivalent functionality
is performed manually by the
users to select the most
appropriate frames and ROI
positions. | Subject of this
submission |
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Image /page/7/Picture/0 description: The image shows the word "PHILIPS" in blue letters. The letters are bold and sans-serif. The background is a light gray color.
VI. Safety Considerations
8
The subject device comply with the referenced standards as well as the FDA ultrasound guidance document. Guidance for Industry and FDA Staff – Marketing Clearance of Diagnostic Ultrasound Systems and Transducers, issued on February 2023.
VII. Non-Clinical Performance Data
The proposed modification of the EPIQ Series and Affiniti Series Diagnostic Ultrasound Systems was tested in accordance with Philips Internal Procedures. The design process incorporated IEC 62304 Medical Device Software - Software life cycle processes, 2006 + A 2015 and Risk Management procedures were applied in accordance with ISO 14971 Medical devices - Application of risk management to medical devices, to ensure the continued safe and effective performance. All software verification tests met the acceptance criteria.
Non-clinical verification testing was conducted to address the change and performance test data were provided to support the introduction of the subject software algorithm for the Auto ElastQ software feature. All software verification tests met the acceptance criteria.
A retrospective data analysis study was conducted to evaluate the performance of the Auto ElastQ software compared to manual measurements performed by expert readers, with the manual measurements used as ground truth for the study. The results demonstrated high agreement of Auto ElastQ algorithm-generated measurements with manual elastography measurements, meeting the acceptance criteria for the study.
VIII. Clinical Data
The proposed EPIQ and Affiniti Series Diagnostic Ultrasound System did not require clinical data for determination of substantial equivalence since substantial equivalence was demonstrated based on the following attributes:
- Design features ●
- Indications for use ●
- Fundamental scientific technology .
- Non-clinical performance testing ●
- Safety and effectiveness ●
IX. Conclusion
For testing, all pre-determined acceptance criteria were met. Results of these tests show that the proposed Auto ElastQ software feature meets the intended use. The proposed devices and predicate device:
- Are indicated for the diagnostic ultrasonic imaging and fluid flow analysis. ●
- Have identical intended users and use environments. ●
- . Have the same device classification, product codes.
- Have identical software. ●
- Are introducing no new hardware or transducers. ●
The differences between the proposed device and predicate device do not raise new questions of safety and/or effectiveness. The major differences include:
- The Auto ElastQ feature recommends particular frames that are assessed to be most stable and ROI locations that are assessed to be the most stable and homoqenous to the user, where the predicate devices require users to review a loop of elastography images then uses the trackball to cine to the frames that are visually perceived to be the most stable and manually positions the ROI in a location that appears to be most stable and homogenous.
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Therefore, the proposed Auto ElastQ feature for the EPIQ and Affiniti Series Diagnostic Ultrasound Systems is substantially equivalent to the predicate EPIQ and Affiniti Series Diagnostic Ultrasound Systems in terms of safety and effectiveness.