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510(k) Data Aggregation
(53 days)
The NDOHD system is intended for viewing, acquiring, recording, archiving and retrieving video and still images of endoscopic and fluoroscopic procedures. The professionals or practitioners using this system would be medical doctors or clinicians such as speech pathologists. The device is a prescription device. The NDOHD system is not intended to be used in an environment that requires sterilization.
The NDOнd High Definition Imaging System (NDOнD) previously acquired FDA clearance in 2013 as a Class II picture archiving and communication system that provides capabilities related to the acquisition, transfer, display, storage, and digital processing of images and videos (K131873). Altaravision replaced off the shelf hardware components due to the hardware becoming obsolete. Altaravision also updated the NDOHD software to enable use of the new hardware, improve the software user interface and conform to Apple's latest coding best practices.
The provided text is a 510(k) Summary for the Altaravision, Inc. NDŌHD High Definition Imaging System (NDOHD). This submission is for a modification to an already cleared device (K131873), primarily due to hardware obsolescence and software updates. It is a Picture Archiving Communications System (PACS) device.
Key takeaway: This is a 510(k) submission for an updated version of a previously cleared PACS device. The core of the submission is to demonstrate substantial equivalence to the predicate device, not to prove clinical efficacy through a new clinical trial against defined acceptance criteria for a novel AI algorithm.
Therefore, many of the typical questions regarding acceptance criteria for AI/ML devices and their associated studies (e.g., sample size for test sets, number of experts, adjudication methods, MRMC studies, standalone performance, ground truth for training) are not directly applicable or explicitly detailed in this type of submission, as the device is not an AI/ML diagnostic or assistive tool in the way that those questions imply. The testing described is primarily for software verification, system validation, and electrical safety, ensuring the new hardware and software function as intended and are as safe and effective as the predicate device.
However, I will extract relevant information where possible and explicitly state when a requested piece of information is not present or applicable.
Acceptance Criteria and Study to Prove Device Meets Criteria
Given that this is a 510(k) for an updated PACS system, the "acceptance criteria" are primarily related to demonstrating substantial equivalence to the predicate device (NDŌHD High Definition Imaging System, K131873) in terms of intended use, indications for use, technological characteristics, and safety and effectiveness. The "study" is the collection of verification and validation testing performed.
1. Table of acceptance criteria and the reported device performance:
Since this is a substantial equivalence submission for a PACS device update, the "acceptance criteria" are not presented as numerical performance targets (e.g., sensitivity, specificity) for a diagnostic task. Instead, they are implied through direct comparison to the predicate device across various characteristics and verification/validation testing. The performance is essentially reported as "equivalent" or "identical" to the predicate, with differences not affecting intended use, safety, or effectiveness.
| Acceptance Criterion (Implied by Substantial Equivalence Claim) | Reported Device Performance (Comparison to Predicate K131873) |
|---|---|
| Intended Use | Identical |
| Indications for Use | Identical |
| Target Population | Identical |
| Computer Hardware | Equivalent (MacBook Pro 13-inch and 15-inch vs. 15-inch; differences in specific models due to obsolescence, but functionally equivalent) |
| Display | Equivalent (Built-in computer display – 13-inch and 15-inch vs. 15-inch) |
| Storage Medium | Equivalent (Non-removable Solid State Drive (SSD) vs. Non-removable hard drive) |
| Operating System | Equivalent (macOS 10.14+ vs. macOS 10.8+; difference in version does not affect intended use or safety/effectiveness) |
| Camera Coupler | Identical (C-Mount) |
| Camera-Computer Cable | Different (USB-3.0 USB C to USB Micro-B vs. Firewire; difference does not affect intended use or safety/effectiveness) |
| Video Output Format | Different (.mp4 H.264 Video vs. .mov H.264 Video; difference does not affect intended use or safety/effectiveness) |
| Still Image Output Format | Identical (.tiff Image) |
| Camera Sensor Type | Different (CMOS vs. CCD Progressive; difference does not affect intended use or safety/effectiveness) |
| Camera Frame Rate | Different (203 fps vs. 31 fps; difference does not affect intended use or safety/effectiveness - note: higher frame rate is generally considered an improvement for video capture in this context, but framed as not impacting safety/effectiveness rather than a performance target met) |
| Pixel Size | Equivalent (4.8 μm x 4.8 μm vs. 4.65 μm x 4.65 μm) |
| Camera Bit Depth | Equivalent (10 bits vs. 8-14 bits) |
| Camera Resolution (H x V) | Different (1280 px x 1024 px vs. 1032 px x 776 px; difference does not affect intended use or safety/effectiveness - note: higher resolution is generally an improvement, but framed as not impacting safety/effectiveness) |
| Power Consumption | Equivalent (3 W (Typical) vs. < 4 W) |
| Lossy Image Compression | Identical (Yes, H.264 compression) |
| Power Source | Identical (Computer built-in battery operated) |
| Software Functionality | Equivalent (Controls recording, playback, storage, retrieval, live view of video, audio, images; updated UI, conform to Apple coding best practices) |
| Programming Language | Different (Swift vs. Objective C; difference does not affect intended use or safety/effectiveness) |
| Safety and Effectiveness | Demonstrated through software verification, system validation, and electrical safety testing according to FDA Guidance and Industry Standards (listed in Section 7). |
2. Sample sized used for the test set and the data provenance:
- Sample Size for Test Set: This information is not provided in the summary. For a PACS system, validation testing would involve testing functionalities (acquisition, storage, display, retrieval, etc.) with various typical image/video files, but specific "test set" sizes for clinical evaluation (like for an algorithm) are not explicitly mentioned.
- Data Provenance: Not applicable in the context of this submission, as it's not evaluating clinical data for diagnoses made by the system. The system handles endoscopic and fluoroscopic procedure videos and images.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not applicable as the device is a PACS system for managing images, not an AI diagnostic tool requiring expert-established ground truth for performance evaluation of a clinical task.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- This information is not applicable for the reasons stated above.
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:
- No, an MRMC comparative effectiveness study was not performed. This device is a PACS system, not an AI assistant intended to improve human reader performance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- A "standalone" performance evaluation in the context of a diagnostic algorithm is not applicable. The device's performance relates to its ability to acquire, store, display, and retrieve images/videos correctly and safely, which was evaluated through verification and validation (V&V) testing, not through standalone diagnostic accuracy.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- "Ground truth" in the diagnostic sense (e.g., pathology for cancer detection) is not applicable to this PACS system. The V&V testing would establish that functionalities (e.g., image integrity, compression, display fidelity, storage/retrieval accuracy) meet their specifications, rather than clinical ground truth.
8. The sample size for the training set:
- This device is not an AI/ML algorithm that is "trained" on a dataset in the typical sense. Therefore, a "training set" sample size is not applicable. The software was updated and developed following coding best practices, and subjected to verification and validation.
9. How the ground truth for the training set was established:
- As the device is not an AI/ML algorithm with a "training set," this question is not applicable.
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