(77 days)
iTR2000 is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
iTR2000™ is a stand-alone software product which may be marketed as a software-only product, as well as for use in conjunction with standard PC hardware, off-the-shelf software or third-party teleradiology/PACS software. iTR2000™ provides short-term remote access to medical images by radiologists, referring physicians and other licensed professionals, utilizing a personal computer or workstation with internet access. Images are securely stored on a internet website for on-demand remote retrieval via the iTR2000™ software, or via a standard web browser without the use of propriety software. The iTR2000™ system employs the latest internet security techniques and meets all current federal medical communications standards including recent proposals from HCFA and HHS. iTR2000™ is primarily intended to allow the transmission, retrieval and review of images produced by imaging equipment otherwise not part of a digital Picture Archive and Communication System (PACS) network or legacy equipment not compatible with ACR/NEMA DICOM 3.0. Conventional film-based images can be optically digitized and stored in a standard image format, such as JPEG. iTR2000™ can also be configured to web-enable third-party DICOM-capable teleradiology/PACS systems in low-volume environments for remote or on-call activities. iTR2000™ is designed for use primarily with small-matrix imaging modalities, such as images produced by Computed Tomography (CT), Ultrasound (US), Magnetic Resonance Imaging (MRI), Nuclear Medicine (NM), digital flourography and digital angiography. The use of images produced by large-matrix imaging systems, such as digitized radiographic films and computed radiography or mammography. requires the use of digitization and viewing equipment which exceed the stated minimum requirements for the standard iTR2000™ system. iTR2000™ does not control the actual image-taking system (i.e. x-ray, MRI, ultrasound or scintography machines).
This document describes the iTR2000™ teleradiology software, its intended use, and its substantial equivalence to predicate devices, rather than a study proving the device meets specific performance acceptance criteria. The document is a 510(k) Summary, which is a premarket submission made to FDA to demonstrate that the device to be marketed is as safe and effective, that is, substantially equivalent, to a legally marketed device.
Therefore, many of the requested details about acceptance criteria, study design, and performance metrics are not explicitly provided in this type of document.
Here's an analysis based on the provided text, addressing the points where information is available or noting its absence:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Stated or Implied) | Reported Device Performance |
|---|---|
| Safety: | |
| No patient contacting components | Device has no patient contacting components. |
| Does not impact quality of original acquired image data | Device does not impact the quality of the original acquired image data. |
| Utilizes standard data communications controls for error detection and correction | Standard data communications controls for error detection and correction are utilized. |
| Employs latest internet security techniques | Employs the latest internet security techniques and meets all current federal medical communications standards. |
| Substantial equivalence to predicate devices regarding safety | Concluded to be as safe as legally marketed predicate devices. |
| Effectiveness: | |
| Ability to transfer digital image files between personal computers | Primarily an image communications software program used to transfer digital image files between personal computers. |
| Functional for off-site review of medical images | Intended to be used for the transportation, storage and retrieval of digital medical images for the purpose of off-site review. |
| Compatibility with small-matrix imaging modalities (CT, US, MRI, NM, digital fluorography, angiography) | Designed for use primarily with small-matrix imaging modalities. |
| Image compression equivalent to predicate devices | Recommended JPEG image compression libraries and default compression settings are believed to be substantially equivalent to those in previously cleared products. |
| Substantial equivalence to predicate devices regarding efficacy | Concluded to be as effective as legally marketed predicate devices. |
| Functional testing of image transfer | Functional testing included the transfer of diagnostic imaging studies for over 1200 complete studies. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: "Functional testing including the transfer of diagnostic imaging studies for over 1200 complete studies." The document does not specify if these "studies" were used as a "test set" in a formal performance evaluation against predefined criteria or if this refers to internal development testing. It's likely the latter given the context of a 510(k) summary focused on substantial equivalence.
- Data Provenance: Not specified. It's almost certainly retrospective given the time period and nature of the product (software for image transfer). Country of origin is not mentioned.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Not Applicable / Not Provided: The document does not describe a study involving expert-established ground truth for a test set to measure diagnostic accuracy or similar performance. The device is a communication tool, not a diagnostic algorithm. The "ground truth" for its function would be successful and accurate transfer of image data, which was likely evaluated through technical means rather than expert adjudication of clinical findings.
4. Adjudication Method for the Test Set
- Not Applicable / Not Provided: As no expert-established ground truth or clinical performance study is described for a test set, there is no mention of an adjudication method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No: No MRMC study is described. The device is a teleradiology software for image transfer, not an AI-assisted diagnostic tool for human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Yes (for its function as a communication tool): The "functional testing" involving the transfer of over 1200 studies represents a standalone evaluation of the software's core function: to transfer images. The criteria for this testing would have related to successful transmission, integrity of the data, and speed, not clinical diagnostic performance.
7. The Type of Ground Truth Used
- Technical Verification: For the described functional testing, the "ground truth" would have been the integrity and successful transmission of the digital image files. This would be verified through technical checks (e.g., checksums, visual comparison to original files, successful display) rather than clinical ground truth like pathology or outcomes data.
8. The Sample Size for the Training Set
- Not Applicable / Not Provided: This device is software for image communication and transfer, not a machine learning or AI algorithm that requires a training set in the typical sense. Functional testing (described above) would be more analogous to system validation.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable / Not Provided: As explained in point 8, there's no "training set" in the context of an AI/ML algorithm.
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INTEL
ITR 2000
2400 Lorain Road San Marino, California 91108 - Oan Manhol Callonia - Phone (626) 457-1789
Fax (626) 457-1789
Email: info@inteleradiology.com Website: www.inteleradiology.com
N C
SEP 2 9 1999
Food and Drug Administration Center for Devices and Radiological Health Document Mail Center (HFZ-401) 9200 Corporate Boulevard Rockville, Maryland 20850
510(k) Summary
1. Identification
| Date Prepared: | July 11, 1999 |
|---|---|
| Submitter | inTeleRadiology, Inc.2400 Lorain RoadSan Marino, California 91108 |
| Contact | Michael Vincent Klein, M.D.Phone: (626) 457-1789Fax: (626) 457-1789 |
2. Device Name
| Proprietary Name: | iTR2000TM: internet TeleradiologyTM |
|---|---|
| Common Name: | Teleradiology Software |
| ClassificationName: | System, Digital Image Communications |
3. Registration Number:
Pending
4. Classification
| Class: | 2 |
|---|---|
| Panel: | Radiology |
| Product Code: | LMD |
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510(k) Summary - continued
5. Standards
| Performance: | None established |
|---|---|
| Voluntary: | American College of Radiology Standard for Teleradiology (Revision 35 -1998; for small matrix systems) |
| ISO/IEC 10918-1 Digital Compression and Coding of Continuous-Tone StillImages [also known as Joint Photographic Experts Group (JPEG):]Revision 13. July 1994] |
6. Predicate Devices
WINRAD Teleradiology System (Line Imaging Systems)
AMICAS Web/Intranet Image Server (AutoCyt Group, Inc.)
7. Device Description
iTR2000™ is a stand-alone software product which may be marketed as a software-only product, as well as for use in conjunction with standard PC hardware, off-the-shelf software or third-party teleradiology/PACS software.
iTR2000™ provides short-term remote access to medical images by radiologists, referring physicians and other licensed professionals, utilizing a personal computer or workstation with internet access. Images are securely stored on a internet website for on-demand remote retrieval via the iTR2000™ software, or via a standard web browser without the use of propriety software. The iTR2000™ system employs the latest internet security techniques and meets all current federal medical communications standards including recent proposals from HCFA and HHS.
iTR2000™ is primarily intended to allow the transmission, retrieval and review of images produced by imaging equipment otherwise not part of a digital Picture Archive and Communication System (PACS) network or legacy equipment not compatible with ACR/NEMA DICOM 3.0. Conventional film-based images can be optically digitized and stored in a standard image format, such as JPEG. iTR2000™ can also be configured to web-enable third-party DICOM-capable teleradiology/PACS systems in low-volume environments for remote or on-call activities.
iTR2000™ is designed for use primarily with small-matrix imaging modalities, such as images produced by Computed Tomography (CT), Ultrasound (US), Magnetic Resonance Imaging (MRI), Nuclear Medicine (NM), digital flourography and digital angiography. The use of images produced by large-matrix imaging systems, such as digitized radiographic films and computed radiography or mammography. requires the use of digitization and viewing equipment which exceed the stated minimum requirements for the standard iTR2000™ system. iTR2000™ does not control the actual image-taking system (i.e. x-ray, MRI, ultrasound or scintography machines).
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iTR2000™ is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
9. Safety and Effectiveness
The iTR2000™ software is primarily an image communications software program used to transfer digital image files between personal computers and is utilized only by competent medical professionals. The system has no patient contacting components. The device does not impact the quality of the original acquired image data. It does not require specialized or nonstandard devices of any type. Competent health professionals would reasonably be expected to exercise judgment and professional expertise in the use and interpretation of the transferred image files.
Similar to the predicate devices. iTR2000™ can be used with image compression to remove redundant or unimportant information in the original image data. The recommended JPEG image compression libraries and default compression settings are believed to be substantially equivalent to the libraries used in the previously cleared products.
9. Testing
The safety of this program has been determined through the various stages of software development which included the development of product specifications, coding, testing, debugging, in-house validation and field maintenance. Functional testing including the transfer of diagnostic imaging studies for over 1200 complete studies. Standard data communications controls for error detection and correction are utilized.
10. Conclusions
iTR2000™ software is a medical device, and it has the same indications for use, the same technological characteristics and the same target population as the legally marketed predicate devices.
Any differences between the iTR2000™ software and the predicate devices have no significant influence on safety or efficacy. The iTR2000™ system employs the latest internet security techniques and meets all current federal medical communications standards including recent proposals from HCFA and HHS. No new issues of safety and effectiveness are raised.
InTeleRadiology, Inc., believes sufficient information is included to reach a determination of substantial equivalence. We conclude that the iTR2000™ software is as safe and effective as the legally marketed devices and is substantially equivalent to the previously marketed devices (as listed above in Part 6),
Michael Vincent Klein.
July 11, 1999
July 11, 1996
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three lines forming its body and wings. The eagle is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 2 9 1999
Michael Vincent Klein, M.D. CEO Inteleradiology, Inc. 2400 Lorain Road San Marino, CA 91108
Dear Dr. Klein:
Re:
K992352 ITR2000 Internet Teleradiology Dated: July 11, 1999 Received: July 14, 1999 Product Code: 90 LMD Requlatory Class: I (one) 21 CFR 892.2020
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 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 (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. Ilsing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either 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 (QS) 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 with 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/cdrh/dsma/dsmamain.html".
Sincerely yours,
CAPT Daniel G. Schultz, M.D. Acting Director, Division of Reproductive, Abdominal, Ear, Nose and Throat, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Page 2 of 2
| 510(k) Number (if known): ____ | K992352 |
|---|---|
| -------------------------------- | --------- |
iTR2000 Device Name:
Indications For Use:
iTR2000 is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
David G. Syphm
(Division Sign-Off)
Division of Reproductive, Abdominal, ENT, and Radiological Devices 510(k) Number
Prescription Use
(Per 21 CFR 801.109)
OR
Over-The-Counter Use_
(Optional Format 1-2-96)
§ 892.2020 Medical image communications device.
(a)
Identification. A medical image communications device provides electronic transfer of medical image data between medical devices. It may include a physical communications medium, modems, and interfaces. It may provide simple image review software functionality for medical image processing and manipulation, such as grayscale window and level, zoom and pan, user delineated geometric measurements, compression, or user added image annotations. The device does not perform advanced image processing or complex quantitative functions. This does not include electronic transfer of medical image software functions.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 892.9.