(88 days)
Exhibit is a software package, which may be marketed as a software only solution, as well as in coniunction with standard PC hardware. Exhibit is a PC-based, DICOM-compliant PACS device that is able to receive and display DICOM images. Images sent to Exhibit are converted into formats suitable for viewing in a web browser, and stored in a local cache (hard disk). The algorithms used by Exhibit to create JPEG and wavelet images follow known and accepted protocols.
lmages sent to Exhibit can be viewed using a Java applet that runs within a web browser such as Netscape or Internet Explorer. The Exhibit applet can be used for the purposes of viewing images over a hospital intranet, or over the internet from a remote location. Images stored on Exhibit are transient, as Exhibit is not intended to be an archiving device.
Exhibit uses standard "off-the-shelf" PC hardware and communicates using the standard TCP/IP stack. The network hardware used to support the TCP/IP stack is superfluous to Exhibit.
Exhibit is a software package, which may be marketed as a software only solution, as well as in conjunction with standard PC hardware. Exhibit is a PC-based, DICOM-compliant PACS device that is able to receive and display DICOM images. Images sent to Exhibit are converted into formats suitable for viewing in a web browser, and stored in a local cache (hard disk). The algorithms used by Exhibit to create JPEG and wavelet images follow known and accepted protocols.
lmages sent to Exhibit can be viewed using a Java applet that runs within a web browser such as Netscape or Internet Explorer. The Exhibit applet can be used for the purposes of viewing images over a hospital intranet, or over the internet from a remote location. Images stored on Exhibit are transient, as Exhibit is not intended to be an archiving device.
Exhibit uses standard "off-the-shelf" PC hardware and communicates using the standard TCP/IP stack. The network hardware used to support the TCP/IP stack is superfluous to Exhibit.
The provided document, K982769, for Mitra Imaging, Inc.'s Exhibit software, is a 510(k) summary submitted to the FDA. It does not contain a detailed study demonstrating the device meets specific performance acceptance criteria. Instead, it focuses on establishing substantial equivalence to a predicate device (Algotec Systems Ltd.'s MediSurf).
Therefore, many of the requested details about acceptance criteria, study design, and ground truth establishment are not present in this document.
Here's a breakdown of what can be extracted and what is explicitly not available:
1. Table of Acceptance Criteria and Reported Device Performance
This information is not provided in the document. The submission focuses on establishing substantial equivalence based on technological characteristics and intended use, rather than specific performance metrics with acceptance criteria.
The substantial equivalence chart (Section 1.9) compares features:
| Specification | Exhibit (This submission) | MediSurf (K971347) |
|---|---|---|
| Graphical User Interface | Yes | Yes |
| Uses Java programming language | Yes | Yes |
| Applets viewed inside web browser | Yes | Yes |
| Applets stored on remote server | Yes | Yes |
| Communications | TCP/IP | TCP/IP |
| Image Review | Window Level/Flip/Rotate/Zoom | Window Level/Flip/Rotate/Zoom/Pan |
| Server Platform | PC - Windows NT | UNIX |
| Client Platform | Any Java-compatible web browser | Any Java-compatible web browser |
| JPEG for thumbnail view | Yes | No |
| Wavelet compression for transmission of images | Yes | Yes |
2. Sample size used for the test set and the data provenance
This information is not provided. As no specific performance study is detailed, there's no mention of a test set size or data provenance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided, as no specific performance study is detailed.
4. Adjudication method for the test set
This information is not provided, as no specific performance study is detailed.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This information is not provided. The Exhibit software is described as a PACS Teleradiology System for viewing images. It is not presented as an AI-assisted diagnostic tool that would typically undergo an MRMC study to show improvement for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
A standalone performance study, in the sense of demonstrating a diagnostic algorithm's accuracy, was not described or performed for this submission. The "effectiveness" mentioned (Section 1.8) refers to the software's ability to perform its stated functions (receive, convert, display DICOM images), with "extensive testing... performed by programmers, by non-programmers, quality control staff, and by potential customers," rather than a formal clinical or diagnostic performance study.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
This information is not applicable/provided, as no specific performance study requiring ground truth for clinical or diagnostic accuracy is detailed. The "ground truth" implicitly assumed is that the software correctly receives, converts, and displays images as intended by its design.
8. The sample size for the training set
This information is not provided. The software is not described as an AI/ML model that would require a distinct training set for its core functionality.
9. How the ground truth for the training set was established
This information is not applicable/provided, as the device is not an AI/ML model requiring a training set with established ground truth in the typical sense.
Summary of Device and its "Proof of Effectiveness" from the document:
The Exhibit software is a PC-based, DICOM-compliant PACS device that receives and displays DICOM images by converting them to web-browser compatible formats (JPEG and wavelet). Its intended use is for viewing images over an intranet or internet from a remote location. It is not intended for archiving.
The "study that proves the device meets the acceptance criteria" is primarily the claim of substantial equivalence to the predicate device, Algotec MediSurf (K971347). The manufacturer argues that Exhibit's intended use and technological characteristics are "virtually identical" to the predicate device, and any differences "have no significant influence on safety or effectiveness."
The document also mentions "extensive testing of the software package has been performed by programmers, by non-programmers, quality control staff, and by potential customers." This type of testing would assess the software's functional correctness, stability, and usability, but it's not described as a formal validation study with specific acceptance criteria beyond general functionality. The level of concern for the device is categorized as "minor," implying that its failure would not be expected to result in death or injury to a patient, which aligns with its function as an image viewing and distribution system rather than a diagnostic tool.
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K982769 P. 1 of 4
3 1998 NOV
510(k) SUMMARY
In accordance with the provisions of the Safe Medical Device Act of 1990, Mitra Imaging, Inc. is providing a summary of safety and effectiveness information regarding the Exhibit software.
-
1.1 Company Identification
Mitra Imaging, Inc. 115 Randall Drive Waterloo, Ontario, Canada N2V 1C5 Tel: (519) 746-2900 Fax: (519) 746-3745 -
1.2 Official Correspondent
Gary J. Allsebrook Regulatory Management Services 16303 Panoramic Way San Leandro, CA, USA, 94578-1116 -
1.3 Date of Submission
August 6, 1998 -
1.4 Device Name
Classification Name: Common/Usual Name: Proprietary Name:
PACS Teleradiology System Exhibit
- 1.5 Substantial Equivalence
The Exhibit software is substantially equivalent to the Algotec Systems Ltd. Product, MediSurf that is covered under K971347.
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K982769 p. 2 of 4
1.6 Device Description and Intended Use
Exhibit is a software package, which may be marketed as a software only solution, as well as in conjunction with standard PC hardware. Exhibit is a PC-based, DICOM-compliant PACS device that is able to receive and display DICOM images. Images sent to Exhibit are converted into formats suitable for viewing in a web browser, and stored in a local cache (hard disk). The algorithms used by Exhibit to create JPEG and wavelet images follow known and accepted protocols.
lmages sent to Exhibit can be viewed using a Java applet that runs within a web browser such as Netscape or Internet Explorer. The Exhibit applet can be used for the purposes of viewing images over a hospital intranet, or over the internet from a remote location. Images stored on Exhibit are transient, as Exhibit is not intended to be an archiving device.
Exhibit uses standard "off-the-shelf" PC hardware and communicates using the standard TCP/IP stack. The network hardware used to support the TCP/IP stack is superfluous to Exhibit.
1.7 Software Development
Mitra certifies that the Exhibit software is designed, developed, tested and validated according to written procedures. These procedures identify individuals within the organization responsible for developing and approving product specifications, coding and testing, validation testing and field maintenance. The software used in this product is used to convert DICOM images to formats that can be displayed within web browsers.
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K982769 p. 3 of 4
1.8 Safety and Effectiveness
General Safety and Effectiveness Concerns:
The device labeling contains instructions for use and indications for use.
The hardware components specified (but not supplied) are all "off the shelf" computer components.
Validation and Effectiveness:
Extensive testing of the software package has been performed by programmers, by non-programmers, quality control staff, and by potential customers.
Substantial Equivalence:
The Exhibit software is a software package used to receive DICOM images, convert them to a web-browser compatible format, and to transfer those converted images to a viewing applet.
Exhibit is substantially equivalent to the Algotec MediSurf product, in that it receives DICOM images, converts them to wavelet format and displays them within a web browser. The intended use and technological characteristics of the system are virtually identical to MediSurf (K971347). Any differences between the Exhibit software and the equivalent device have no significant influence on safety or effectiveness.
It is our conclusion that there is no software component in the Exhibit product or hardware component which would be used in conjunction with the Exhibit product that we know of whose failure or latent design flaw would be expected to result in death or injury to a patient. Thus the "Level of Concern" of the Mitra Exhibit product is "minor".
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1.9 Substantial Equivalence Chart
| Specification | Exhibit (This submission) | MediSurf (K971347) |
|---|---|---|
| Graphical UserInterface | Yes | Yes |
| Uses Javaprogramminglanguage | Yes | Yes |
| Applets viewed insideweb browser | Yes | Yes |
| Applets stored onremote server | Yes | Yes |
| Communications | TCP/IP | TCP/IP |
| Image Review | Window Level/Flip/Rotate/Zoom | Window Level/Flip/Rotate/Zoom/Pan |
| Server Platform | PC - Windows NT | UNIX |
| Client Platform | Any Java-compatible webbrowser | Any Java-compatible web browser |
| JPEG for thumbnailview | Yes | No |
| Wavelet compressionfor transmission ofimages | Yes | Yes |
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Re:
Image /page/4/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES (USA)" arranged around the top half of the circle. Inside the circle is a stylized emblem featuring three abstract human figures, represented by flowing lines, positioned closely together.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
NOV 3 1998
MITRA Imaging, Inc. c/o Gary J. Allesbrook Regulatory Management Services 16303 Panoramic Way San Leandro, CA 94578
K982769 Teleradiology System Dated: August 6, 1998 Received: August 7, 1998 Regulatory class: II 21 CFR 892.2050/Procode: 90 LLZ
Dear Mr. Allesbrook:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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 (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (OS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitm diagnostic devices), please contact the Office of Compliance at (301) 594-4613. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address "http://www.fda.gov/cdrividsmardsmamain.html".
Sincerely yours,
Lillian Yin, Ph.D.
Lillian Yin. Ph.D Director, Division of Reproductiv Abdominal, Ear, Nose and Throa and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Page 1 of 1
510(k) Number (if known): K982769
Device Name: Mitra Imaging Inc., Exhibit
Indications For Use:
Exhibit is a software package, which may be marketed as a software only solution, as well as in coniunction with standard PC hardware. Exhibit is a PC-based, DICOM-compliant PACS device that is able to receive and display DICOM images. Images sent to Exhibit are converted into formats suitable for viewing in a web browser, and stored in a local cache (hard disk). The algorithms used by Exhibit to create JPEG and wavelet images follow known and accepted protocols.
lmages sent to Exhibit can be viewed using a Java applet that runs within a web browser such as Netscape or Internet Explorer. The Exhibit applet can be used for the purposes of viewing images over a hospital intranet, or over the internet from a remote location. Images stored on Exhibit are transient, as Exhibit is not intended to be an archiving device.
Exhibit uses standard "off-the-shelf" PC hardware and communicates using the standard TCP/IP stack. The network hardware used to support the TCP/IP stack is superfluous to Exhibit.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 901.109)
OR
Over-the-Counter Use
Eminl C. Syzman
Division Sign Off
(Optional Format 1-2-96)
(Division Sign-Off)
Division of Reproductive, Abdominal, ENT,
and Radiological Devices
510(k) Number K982769
§ 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).