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510(k) Data Aggregation

    K Number
    K222198
    Manufacturer
    Date Cleared
    2022-11-09

    (110 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Exo Imaging Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Exo Iris is indicated for use by qualified and trained healthcare professionals in environments where healthcare is provided to enable diagnostic ultrasound imaging and measurement of anatomical structures and fluids of adult and pediatric patients for the following clinical applications: Peripheral Vessel (including carotid, deep vein thrombosis and arterial studies), Procedural Guidance, Small Organ (including thyroid, scrotum and breast), Cardiac, Abdominal, Urology, Fetal/Obstetric, Gynecological, Musculoskeletal (conventional), Musculoskeletal (superficial) and Ophthalmic. Modes of operation include: B-Mode + Color Doppler, B-Mode + M-Mode.

    Device Description

    The subject device, Exo Iris is a hand-held, general purpose diagnostic imaging system used to enable visualization of anatomical structures and fluid of adult and pediatric patients. The system is intended to be used by trained healthcare professionals.

    The system generates 2D images using a single ultrasound transducer with broad imaqing capabilities. The imaqes are displayed on a commercial off-the-shelf mobile device (iPhone) by means of a proprietary mobile application (Exo Iris app) provided by Exo Imaging. Images can be displayed in the following modes: B-Mode, B-Mode + Color Doppler, B-Mode+ M-Mode.

    The mobile application's user interface includes touchscreen menus, buttons, controls, indicators, and navigation icons that allow the operator to control the system and to view ultrasound images.

    AI/ML Overview

    The provided text does not contain detailed information about the acceptance criteria and study proving the device meets those criteria in a format that allows for a direct population of all the requested fields. The document primarily focuses on FDA 510(k) clearance, asserting substantial equivalence to a predicate device.

    Here's an attempt to extract and infer information based on the text:

    1. Table of acceptance criteria and the reported device performance

    The document broadly states that "All specifications for Exo Iris have been verified and validated... and the results demonstrated that the predetermined acceptance criteria were met." However, it does not provide a specific table of acceptance criteria with corresponding performance results. Instead, it lists the standards against which testing was conducted.

    Acceptance Criteria Category (Inferred from standards)Reported Device Performance (General Statement)
    Electrical Safety (per ANSI/AAMI ES60601-1)Compliant with applicable electrical safety standards
    Electromagnetic Compatibility (EMC) (per IEC 60601-1-2, FCC Part 15)Compliant with applicable EMC standards
    Ultrasound Safety and Performance (per IEC 60601-2-37, NEMA UD-2)Meets safety and performance requirements for ultrasonic medical diagnostic and monitoring equipment; Meets standard for acoustic output measurement
    Biocompatibility (per ISO 10993)Compliant with ISO 10993
    Software Life Cycle Processes (per IEC 62304)Compliant with Medical Device Software - Software Life Cycle Processes
    Design Control and Risk Mitigation (per 21 CFR Part 820.30, ISO 14971)All design verification and validation activities performed; predetermined acceptance criteria met; all risk mitigations satisfactorily verified and validated.

    2. Sample size used for the test set and the data provenance

    The document explicitly states: "No human clinical data is provided to support substantial equivalence."
    Therefore, there is no information on a specific "test set" in terms of patient data. The performance evaluations were primarily through bench testing against established standards.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable, as no human clinical data (and thus no ground truth derived from it) was used for substantial equivalence.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as no human clinical data (and thus no adjudication of ground truth) was used for substantial equivalence.

    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 MRMC study was done, as the submission explicitly states "No human clinical data is provided to support substantial equivalence." The device is a diagnostic ultrasound system, not an AI-assisted diagnostic tool in the context of this submission that would require demonstrating an improvement in human reader performance.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    This refers to the device itself as a diagnostic ultrasound system. Its performance evaluation was done through bench testing to ensure it meets technical standards, not as an algorithm performing standalone diagnostics on patient cases.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" for the device's performance is derived from its ability to meet the technical specifications and requirements defined by the various industry standards mentioned (e.g., electrical safety, acoustic output, software quality). There is no "ground truth" related to disease detection or diagnosis established through expert consensus, pathology, or outcomes data in this submission.

    8. The sample size for the training set

    Not applicable. The document describes a diagnostic ultrasound system, not an AI/ML device that requires a training set of data.

    9. How the ground truth for the training set was established

    Not applicable, as no training set was used.

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    K Number
    K211527
    Device Name
    Exo Iris
    Manufacturer
    Date Cleared
    2021-08-20

    (95 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Exo Imaging Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Exo Iris is indicated for use by qualified and trained healthcare professionals in environments where healthcare is provided to enable diagnostic ultrasound imaging and measurement of anatomical structures and fluids of adult and pediatric patients for the following clinical applications: Peripheral Vessel (including carotid, deep vein thrombosis and arterial studies), Small Organ (including thyroid, scrotum and breast), Cardiac, Abdominal, Urology, Fetal/Obstetric, Gynecological, Musculoskeletal (conventional), Musculoskeletal (superficial). Modes of operation include: B-mode, B-mode + Color Doppler.

    Device Description

    Exo Iris is a hand-held, general purpose diagnostic imaging system used to enable visualization of anatomical structures and fluid of adult and pediatric patients. The system is intended to be used by trained healthcare professionals.

    The system generates 2D images using a single ultrasound transducer with broad imaging capabilities. The images are displayed on a commercial off-the-shelf mobile device (iPhone) by means of a proprietary mobile application (Exo Iris app) provided by Exo Imaging. Images can be displayed in the following modes: B-Mode, B-Mode + Color Doppler.

    The mobile application's user interface includes touchscreen menus, buttons, controls, indicators, and navigation icons that allow the operator to control the system and to view ultrasound images.

    AI/ML Overview

    This document is an FDA 510(k) clearance letter for the Exo Iris Ultrasound System. It primarily focuses on demonstrating substantial equivalence to a predicate device rather than providing a detailed study report on acceptance criteria for an AI/ML-driven device.

    Based on the provided text, the Exo Iris is a general diagnostic ultrasound system, not explicitly described as having integrated AI/ML functionality that would necessitate specific performance studies for AI/ML algorithms. The letter states "Clinical data were not required for this type of device." and "Software testing, consisted of verification and validation testing including test cases related to off the shelf software, as well as cybersecurity features." This suggests the software component is more for device control and data display rather than for diagnostic AI/ML algorithms.

    Therefore, many of the requested details regarding AI/ML study components (such as expert ground truth, adjudication, MRMC studies, standalone performance, training set details) are not present in this document because the device, as described for this 510(k), does not appear to involve a diagnostic AI/ML algorithm requiring such evaluations.

    However, I will extract and present the information available regarding acceptance criteria and performance data for the device itself, acknowledging that it's from a device safety/performance perspective rather than an AI/ML algorithm's diagnostic performance.


    Acceptance Criteria and Device Performance (as per general device clearance):

    Acceptance Criteria CategoryReported Device Performance
    Electrical SafetyYes, compliant with applicable electrical safety standards (IEC 60601-1, IEC 60601-1-2)
    Mechanical SafetyMeets mechanical safety standards for a Class II medical device
    BiocompatibilityYes, compliant with ISO 10993
    Acoustic OutputCompliant with NEMA UD-2 and applicable FDA Guidance
    Software FunctionalityVerification and validation testing, including test cases related to off-the-shelf software and cybersecurity features, demonstrated meeting predetermined acceptance criteria.
    Risk ManagementPotential risks identified per ISO 14971, analyzed, mitigations implemented and tested. All risk mitigations satisfactorily verified and validated.
    Design ControlAll specifications verified and validated per company's Design Control Process (in compliance with 21 CFR Part 820.30); results demonstrated predetermined acceptance criteria were met.
    Substantial EquivalenceDemonstrated substantial equivalence to the predicate device (Butterfly iQ Ultrasound System, K202406) based on indications for use and technological characteristics.

    Information NOT Available in the Document (due to the nature of the device and submission):

    As the document indicates, clinical data were not required for this type of device, and the focus is on device safety and operational performance compared to a predicate, not AI/ML diagnostic performance. Therefore, the following are not applicable or not provided:

    1. Sample size used for the test set and the data provenance: Not applicable for a standalone AI/ML performance study as this device is a general diagnostic ultrasound system. Device testing involved bench testing and software verification, not a clinical test set of images for an AI.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable as there was no AI/ML specific diagnostic test set requiring expert ground truth.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
    4. 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: Not applicable.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not applicable.
    7. The sample size for the training set: Not applicable.
    8. How the ground truth for the training set was established: Not applicable.

    Summary of what is present:

    The document describes the regulatory clearance for a diagnostic ultrasound system (Exo Iris). The performance data presented are primarily technical and safety verifications required for medical devices (electrical safety, mechanical safety, biocompatibility, acoustic output, software functionality, and risk management) to demonstrate substantial equivalence to a predicate device, rather than the performance of a diagnostic AI/ML algorithm.

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