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510(k) Data Aggregation

    K Number
    K250455
    Date Cleared
    2025-04-17

    (58 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    FLUOPTICS SAS (a Getinge Group Company}

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

    FLUOBEAM LX and FLUOBEAM LM are intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. Upon intravenous administration and use of an ICG consistent with its approved labeling, the FLUOBEAM LX and FLUOBEAM LM are indicated for use in capturing and viewing fluorescent images for the visualization of vessels, blood flow and tissue perfusion before, during and after organ transplant, plastic, micro- and reconstructive surgeries.

    The FLUOBEAM LX and FLUOBEAM LM can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue.

    Use of the FLUOBEAM LX and FLUOBEAM LM devices are intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    Upon interstitial administration and use of ICG consistent with its approved labeling, the FLUOBEAM LX and FLUOBEAM LM are used to perform intraoperative fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels and lymph nodes.

    Upon administration and use of pafolacianine consistent with its approved labeling, the FLUOBEAM LX and FLUOBEAM LM are used to perform intraoperative fluorescence imaging of tissues that have taken up the drug.

    Device Description

    FLUOBEAM LX and FLUOBEAM LM are imaging systems intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures.

    Class 1 infrared laser light is used to excite the fluorescent tissues of parathyroid glands or the ICG or the pafolacianine and illuminate the regions of a patient's body to be observed. A camera inside the optical head captures the fluorescent image that is used to visualize the parathyroid glands or assess the blood vessels and related tissue perfusion. FLUOBEAM LX and FLUOBEAM LM consist of the following components: a hardware part with a camera unit (optical head) linked by a specific cable to a control box and a software part with FLUOSOFT LX or FLUOSOFT LM imaging software. The optical head contains a video camera and light sources (laser and LEDs) and is used by hand. The control box receives the video signal of the fluorescent image from the optical head, it digitizes it and sends it to a computer that outputs it on a display screen and/or records it. Adjustments of the fluorescent image are possible either by the optical head or via the FLUOSOFT LX imaging software and the FLUOSOFT LM imaging software on the computer.

    The subject devices FLUOBEAM LX and FLUOBEAM LM have therefore exactly the same principle of operation of the predicate device. Only aesthetic aspects are different between FLUOBEAM LX and FLUOBEAM LM.

    This Traditional 510(k) premarket notification of the FLUOBEAM LX and FLUOBEAM LM is to expand the indication for use statement to include the usage in the lymphatic system with the use of an ICG consistent with its approved label.

    This Traditional 510(k) premarket notification of the FLUOBEAM LX and FLUOBEAM LM is to expand the indication for use statement to include the additional cleared infrared dye, pafolacianine, for use with infrared imaging.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the FLUOBEAM LX and LM Imaging Systems describe the device and its intended use, as well as the types of studies conducted to demonstrate substantial equivalence to predicate devices. However, the document does not contain a specific table of acceptance criteria nor detailed results of a study designed to explicitly "prove the device meets the acceptance criteria" in terms of clinical performance metrics. Instead, the focus is on demonstrating comparable performance to the predicate and reference devices through bench testing and, by extension, substantial equivalence for the expanded indications.

    Based on the information provided, here's a breakdown of the requested elements:


    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not explicitly provide a table of acceptance criteria with corresponding reported device performance values in the style typically found in a clinical study report with quantitative metrics like sensitivity, specificity, accuracy, or a specific statistical threshold for performance.

    Instead, the document states:

    • "The results of these performance evaluations demonstrated that the FLUOBEAM LX and FLUOBEAM LM met the acceptance criteria defined in the product specification, functioned as intended, and performed comparably to the predicate device."
    • "The FLUOBEAM LX and FLUOBEAM LM was able to visualize similar concentration samples of ICG compared to the reference device, both by analysis of the image contrast (SNR) and by observation of the images."
    • "The FLUOBEAM LX and FLUOBEAM LM was able to visualize lower concentration samples of pafolacianine compared to the reference device, both by analysis of the image contrast (SNR) and by observation of the images."

    This indicates that the "acceptance criteria" were qualitative (e.g., "capable of imaging ICG at different concentrations") and comparative (performing "similarly" or "better" than a reference device in terms of visualization capabilities and image contrast/SNR).

    Without explicit quantitative acceptance criteria in the document, a direct table cannot be constructed. The reported performance is primarily descriptive and comparative to other devices.


    2. Sample Size for the Test Set and Data Provenance

    The document describes bench testing for the performance evaluation.

    • Sample Size for Test Set: Not explicitly stated as a number of "cases" or "patients." The testing involved "different concentrations" of ICG and pafolacianine in in vitro settings. This implies multiple samples at varying concentrations were used for the bench tests.
    • Data Provenance: In vitro bench testing. No mention of human or animal data for the performance evaluation described. Therefore, there is no country of origin or retrospective/prospective designation relevant to clinical data.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    For the bench testing described, the "ground truth" would be the known concentrations of ICG and pafolacianine and the objective measurement of image contrast (SNR). This type of ground truth does not typically involve human expert interpretation in the same way clinical imaging studies do.

    Therefore, no experts were used to establish ground truth in the context of the in vitro performance tests.


    4. Adjudication Method for the Test Set

    Given that the performance data presented is from in vitro bench testing involving objective measurements of image contrast (SNR) and visual observation of images by the testers/engineers, an adjudication method for a test set (e.g., 2+1, 3+1 by clinical experts) is not applicable or mentioned.


    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study is mentioned in the provided document. The performance evaluation focuses on the standalone device's capability and its comparison to predicate/reference devices through bench testing, not on human reader performance with or without AI assistance.


    6. Standalone Performance (Algorithm Only without Human-in-the-Loop Performance)

    The performance evaluation described is implicitly a standalone (algorithm only) assessment. The bench tests evaluated the system's ability to image ICG and pafolacianine at different concentrations and analyze image contrast (SNR) without human interpretation as part of the core performance metric. While "observation of the images" by humans is mentioned, the primary performance measure (SNR) and the ability to visualize specific concentrations are inherent properties of the imaging system itself.


    7. Type of Ground Truth Used

    For the performance evaluation described:

    • Type of Ground Truth: The ground truth used was known concentrations of ICG and pafolacianine for the in vitro imaging tests. The assessment involved comparing the device's ability to visualize these known concentrations and analyzing the Signal-to-Noise Ratio (SNR).

    8. Sample Size for the Training Set

    The document describes the FLUOBEAM LX and LM as imaging systems, which typically do not involve machine learning algorithms that require a "training set" in the traditional sense. The software updates mentioned likely relate to operational software, not an AI model trained on data.

    Therefore, a "training set" is not applicable or mentioned in the context of this device and its clearance.


    9. How the Ground Truth for the Training Set Was Established

    As noted above, a "training set" in the context of machine learning is not applicable for this device as described.

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    K Number
    K233564
    Date Cleared
    2023-12-15

    (39 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Fluoptics Sas (a Getinge Group Company)

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

    FLUOBEAM® LX and FLUOBEAM® LX Red are intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. Upon intravenous administration and use of an ICG consistent with its approved labeling, the FLUOBEAM® LX and FLUOBEAM® LX Red are indicated for use in capturing and viewing fluorescent images for the visualization of vessels, blood flow and tissue perfusion before, during and after organ transplant, plastic, micro- and reconstructive surgeries.

    The FLUOBEAM® LX and FLUOBEAM® LX Red can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue.

    Use of the FLUOBEAM® LX and FLUOBEAM® LX Red devices are intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    Device Description

    FLUOBEAM® LX and FLUOBEAM® LX Red are imaging systems intended to provide realtime near infrared (NIR) fluorescence imaging of tissue during surgical procedures. The FLUOBEAM® LX and FLUOBEAM® LX Red are indicated for use in capturing and viewing fluorescent images for the visualization of vessels, blood flow and tissue perfusion before, during and after organ transplant, plastic, micro- and reconstructive surgeries.

    FLUOBEAM® LX and FLUOBEAM® LX Red can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue. Use of the FLUOBEAM® LX and FLUOBEAM® LX Red devices are intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    FLUOBEAM® LX and FLUOBEAM® LX Red enable surgeons to observe fluorescent images of parathyroid glands, blood vessels and related tissue perfusion. Fluorescence can be observed as a result of natural fluorescence of parathyroid glands or as a result of a fluorescent product, indocyanine green (ICG), injected intravenously into patients before the surgery allowing the perfusion assessment.

    Class 1 infrared laser light is used to excite the fluorescent tissues of parathyroid glands or the ICG and illuminate the regions of a patient's body to be observed. A camera inside the optical head captures the fluorescent image that is used to visualize the parathyroid glands or assess the blood vessels and related tissue perfusion. FLUOBEAM® LX and FLUOBEAM® LX Red consist of the following components: a hardware part with a camera unit (optical head) linked by a specific cable to a control box and a software part with FLUOSOFT™ LX or FLUOSOFT™ LX Red imaging software. The optical head contains a video camera and light sources (laser and LEDs) and is used by hand. The control box receives the video signal of the fluorescent image from the optical head, it digitizes it and sends it to a computer that outputs it on a display screen and/or records it. Adjustments of the fluorescent image are possible either by the optical head or via the FLUOSOFT™ LX imaging software and the FLUOSOFT™ LX Red imaging software on the computer.

    This special 510(k) premarket notification is intended to re-frame the indications for use statement to be consistent with specific indications of legally marketed ICG products, eliminating the need for the co-packaging with ICG.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification from the FDA, specifically concerning a "Special 510(k)" for the FLUOBEAM® LX and FLUOBEAM® LX Red Imaging Systems.

    Crucially, this document states: "No performance data are needed to support the modified indications for use. As noted above, there are no technological changes associated with the proposed labeling changes. Additionally, no new surgical procedures or tissue types are being referenced in the modified indications for use."

    This means the submission is not presenting new performance studies or data to demonstrate the device meets acceptance criteria. Instead, it's leveraging the substantial equivalence to previously cleared devices (K190891 and K230898) and a reference device (K223020) because the changes are limited to refining the "Indications for Use" statement to align with existing ICG product labeling, thereby eliminating the need for co-packaging with ICG.

    Therefore, for the information requested in your prompt, based solely on the provided text, we cannot fill in most of the table or answer many of the questions as no new performance study data is presented.

    Here's what can be extracted from the document:

    1. Table of acceptance criteria and the reported device performance:

    Acceptance Criteria (Not explicitly stated as such for new performance, but implied by substantial equivalence to predicates)Reported Device Performance (Implied by substantial equivalence to predicates)
    Ability to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures.Device provides real-time NIR fluorescence imaging.
    Visualization of vessels, blood flow and tissue perfusion with ICG.Device enables visualization of vessels, blood flow, and tissue perfusion with ICG.
    Assistance in imaging parathyroid glands and location due to auto-fluorescence.Device assists in imaging and locating parathyroid glands through auto-fluorescence.
    Consistent with the performance of predicate devices FLUOBEAM® LX (K190891) and FLUOBEAM LX Red (K230898).Device performance is substantially equivalent to predicate devices.

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

    • Sample size: Not applicable, as no new performance study data is presented. The submission relies on substantial equivalence.
    • Data provenance: Not applicable.

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

    • Not applicable, as no new performance study data is presented.

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

    • Not applicable, as no new performance study data is presented.

    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:

    • Not applicable. This device is an imaging system, not an AI/CADe/CADx device that assists human readers in interpretation or diagnosis. It aids in visualization during surgery. No MRMC study is mentioned.

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

    • Not applicable. This is not an algorithm-only device; it's an imaging system where a human observes the generated images.

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

    • Not explicitly stated for new data, as none was required. For the original clearance of the predicate devices, ground truth would likely have involved direct visual confirmation during surgery, correlation with anatomical knowledge, and potentially histopathological confirmation where applicable (e.g., for parathyroid tissue). The document reiterates that the device "is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues," implying that standard clinical and pathological evaluations remain the definitive ground truth for such aspects.

    8. The sample size for the training set:

    • Not applicable, as no new performance study data for a machine learning model is presented.

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

    • Not applicable, as no new performance study data for a machine learning model is presented.

    In summary: This 510(k) submission primarily focuses on a labeling change for an existing device, asserting that no new performance data is needed because "there are no technological changes associated with the proposed labeling changes. Additionally, no new surgical procedures or tissue types are being referenced in the modified indications for use." Therefore, the detailed performance study information requested is not present in this specific FDA clearance document.

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    K Number
    K230898
    Manufacturer
    Date Cleared
    2023-07-28

    (119 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Fluoptics Sas

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

    FLUOBEAM® LX Red is intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. The FLUOBEAM® LX Red is indicated for use in capturing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, perfused organs, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    The FLUOBEAM® LX Red can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue. Use of the FLUOBEAM® LX Red device is intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    Device Description

    FLUOBEAM® LX Red is an imaging system intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. The FLUOBEAM® LX Red is indicated for use in capturing and viewing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, perfused organs, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    FLUOBEAM® LX Red can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the autofluorescence of this tissue. Use of the FLUOBEAM® LX Red device is intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    FLUOBEAM® LX Red enables surgeons to observe fluorescent images of parathyroid glands, blood vessels and related tissue perfusion. Fluorescence can be observed thanks to natural fluorescence of parathyroid glands or thanks to a fluorescent product, indocyanine green (ICG), injected intravenously into patients before the surgery allowing the perfusion assessment.

    Class 1 infrared laser light is used to excite the fluorescent tissues of parathyroid glands or the ICG and illuminate the regions of a patient's body to be observed. A camera inside the optical head captures the fluorescent image that is used to visualize the parathyroid glands or assess the blood vessels and related tissue perfusion. FLUOBEAM® LX Red consists of the following components: a hardware part with a camera unit (optical head) linked by a specific cable to a control box and a software part with FLUOSOFT™ LX Red imaging software. The optical head contains a video camera and light sources (laser and LEDs) and is used by hand. The control box receives the video signal of the fluorescent image from the optical head, it digitizes it and sends it to a computer that outputs it on a display screen and/or records it. Adjustments of the fluorescent image are possible either by the optical head or via the FLUOSOFT™ LX Red imaging software on the computer.

    The modified device FLUOBEAM® LX Red has therefore exactly the same principle of operation of the predicate device. The modified device FLUOBEAM® LX Red is a device modification of the FLUOBEAM® LX device. Compared to the predicate device FLUOBEAM® LX, change of wavelength and detection range is being implemented for modified device FLUOBEAM® LX Red to improve performance in terms of sensitivity for the location of parathyroid glands due to the auto-fluorescence of this tissue while maintaining sensitivity to indocyanine green (ICG).

    AI/ML Overview

    The FLUOBEAM® LX Red is an imaging system designed to provide real-time near-infrared (NIR) fluorescence imaging of tissue during surgical procedures. It is indicated for visual assessment of blood flow using indocyanine green (ICG) as an adjunctive method, and for assisting in the location of parathyroid glands due to their autofluorescence.

    Here’s a breakdown of the acceptance criteria and the study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    SafetyLaser SafetyMeets IEC 60825-1 (Class 1 laser product)
    Performance - ImagingHomogeneity of excitation illumination patternDemonstrated equivalence through bench testing
    Performance - ImagingLive image quality (spatial resolution)Demonstrated equivalence through bench testing
    Performance - ImagingLive image quality (acquisition frame rate)Demonstrated equivalence through bench testing
    Performance - ImagingFluorescence sensitivityDemonstrated equivalence through bench testing
    Clinical Performance (ICG Fluorescence)ICG fluorescence imaging of blood flow in comparison to predicate devicePerformance supported by clinical tests on 5 patients
    Clinical Performance (Autofluorescence)Sensitivity for location of parathyroid glands due to autofluorescenceImproved performance compared to predicate device (implied by change in wavelength/detection range)
    Clinical Performance (ICG Sensitivity)Maintaining sensitivity to indocyanine green (ICG)Maintained sensitivity compared to predicate device (implied by change in wavelength/detection range)
    Overall PerformanceFunction as intended and perform comparably to predicate deviceTests demonstrated that FLUOBEAM® LX Red met acceptance criteria, functioned as intended, and performed comparably to the predicate device FLUOBEAM® LX.

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

    • Test Set Sample Size: 5 patients for the clinical tests on ICG fluorescence imaging.
    • Data Provenance: Not explicitly stated, but given it's for a European company (FLUOPTICS SAS, France), the data is likely from a European country. The text does not specify if it was retrospective or prospective, but clinical tests are generally prospective.

    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 in the document. The general indication statement mentions that the device is intended to "assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care," suggesting that expert assessment and histology are the ground truth, but doesn't specify the number or qualifications of experts involved in the study itself.

    4. Adjudication method for the test set:

    • This information is not provided in the document.

    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, a multi-reader multi-case (MRMC) comparative effectiveness study involving human readers and AI assistance was not mentioned. This device is an imaging system, not an AI-driven algorithm with a human-in-the-loop component.

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

    • This device is an imaging system, not solely an algorithm. Its performance is intrinsically linked to the physical hardware (camera, light source) and software for image acquisition and display. Therefore, a "standalone algorithm only" performance study, as typically understood for AI, is not applicable in this context. The document describes bench tests for image quality and sensitivity, and clinical tests for its imaging capabilities.

    7. The type of ground truth used:

    • For ICG fluorescence imaging for blood flow assessment: The ground truth is implied by comparison to the predicate device in clinical settings, and by the "visual assessment of blood flow." Ultimately, the standard of care for confirming tissue perfusion and viability would involve clinical observation, surgical assessment, and potentially other diagnostic tools.
    • For parathyroid gland location: The ground truth is implied to be "visually identified gland/tissues" by experienced visual assessment and "biopsy with conventional histopathological confirmation per standard of care."

    8. The sample size for the training set:

    • This information is not provided as the document does not mention any machine learning or AI models with distinct training sets. The device's performance is established through engineering design, bench testing, and limited clinical validation.

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

    • This information is not applicable as the document does not mention a training set in the context of machine learning or AI.
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    K Number
    K190891
    Device Name
    Fluobeam LX
    Manufacturer
    Date Cleared
    2019-07-31

    (117 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Fluoptics

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

    Fluobeam® LX is intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. The Fluobeam® LX is indicated for use in capturing and viewing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, perfused organs, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    The Fluobeam® LX can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue.

    Use of the Fluobeam® LX device is intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    Device Description

    Fluobeam® LX is an imaging system intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. This device is indicated for use in capturing and viewing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, perfused organs, and related tissuetransfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    Fluobeam® LX can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the autofluorescence of this tissue. Use of the Fluobeam® LX device is intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in locating visually identified gland/tissues.

    Fluobeam® LX enables surgeons to observe fluorescent images of parathyroid glands, blood vessels and related tissue perfusion. Fluorescence can be observed thanks to natural fluorescence of parathyroid glands or thanks to a fluorescent product, indocyanine green (ICG), injected intravenously into patients before the surgery allowing the perfusion assessment.

    Class 1 infrared laser light is used to excite the fluorescent tissues of parathyroid glands or the ICG and illuminate the regions of a patient's body to be observed. A camera inside the optical head captures the fluorescent image that is used to visualize the parathyroid glands or assess the blood vessels and related tissue perfusion. Fluobeam® LX consists of the following components: a hardware part with a camera unit (optical head) linked by a specific cable to a control box and a software part with Fluosoft™ LX imaging software. The optical head contains a video camera and light sources (laser and LEDs) and is used by hand. The control box receives the video signal of the fluorescent image from the optical head, it digitizes it and sends it to a computer that outputs it on a display screen and/or records it. Adjustments of the fluorescent image are possible either by the optical head or via the Fluosoft™ LX imaging software on the computer.

    The subject device Fluobeam® LX has therefore exactly the same principle of operation of the predicate device. Fluobeam® LX is only a second generation than the predicate Fluobeam® device.

    AI/ML Overview

    The provided text describes the Fluobeam LX device and its substantial equivalence to a predicate device, but it does not contain specific acceptance criteria or an explicit study proving performance against those criteria in the format requested.

    Instead, it refers to:

    • Bench testing to support a determination of substantial equivalence, covering homogeneity of excitation illumination, live image quality (spatial resolution and acquisition frame rate), and fluorescence sensitivity.
    • Clinical data acquired by independent surgeons in Europe to confirm bench test results.
    • Performance and safety testing according to international standards (IEC 60601-1, IEC 60601-1-2, IEC 60825-1).

    The document states: "The results of these performance evaluations demonstrated that the Fluobeam® LX met the acceptance criteria defined in the product specification, functioned as intended, and performed comparably to the predicate device." However, the specific acceptance criteria and the detailed results of the studies are not provided in this document.

    Therefore, I cannot populate the table or answer all of your questions directly from the provided text.

    Here is what I can infer or state based on the given information:

    1. A table of acceptance criteria and the reported device performance

    Acceptance Criteria (Inferred from testing categories)Reported Device Performance (General Statement)
    Homogeneity of excitation illuminationMet acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    Live image quality (spatial resolution)Met acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    Live image quality (acquisition frame rate)Met acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    Fluorescence sensitivityMet acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    Electrical safety (IEC 60601-1)Met acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    EMC (IEC 60601-1-2)Met acceptance criteria, functioned as intended, and performed comparably to the predicate device.
    Laser safety (IEC 60825-1)Met acceptance criteria, functioned as intended, and performed comparably to the predicate device.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample size for test set: Not specified.
    • Data provenance: Clinical data was acquired by independent surgeons in Europe. It's not explicitly stated if it was retrospective or prospective, but the phrasing "acquired by independent surgeons" suggests a form of prospective or concurrent data collection during clinical use.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Number of experts: "Independent surgeons" were involved, but the specific number is not provided.
    • Qualifications of experts: They are described as "independent surgeons." No further details on their specific qualifications or experience are given.

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

    • Not specified. The text only mentions that surgeons "accepted to share the images with Fluoptics to compare the two devices."

    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, a multi-reader multi-case (MRMC) comparative effectiveness study focusing on human reader improvement with AI assistance was not described. The device is for real-time fluorescence imaging and is stated to assist, not replace, experienced visual assessment. The comparison was primarily between the new device (Fluobeam LX) and its predicate device (Fluobeam 800 Clinic).

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

    • The device is an imaging system intended to "assist, not replace, experienced visual assessment." It creates images for human interpretation, so a standalone "algorithm only" performance study in the sense of an automated diagnostic AI would not be applicable or described in this context.

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

    • For the parathyroid gland location, the device is an "adjunctive method to assist in the location of parathyroid glands" and its use "is intended to assist, not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care." This implies that the standard of care, including histopathological confirmation (pathology), would serve as the ultimate ground truth for actual parathyroid tissue, but the device assists in locating visually identified glands.

    8. The sample size for the training set

    • Not specified. This document only mentions "clinical data were also acquired by independent surgeons" (implying a test or validation set) and does not refer to a separate training set for an AI/algorithm in the way modern machine learning devices often do. The Fluobeam LX is an imaging system, and its performance evaluation focused on its imaging capabilities and equivalence to a predicate device, rather than training a predictive model.

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

    • Not applicable/Not specified, as a training set for an AI model is not described in this document.
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    K Number
    DEN170092
    Manufacturer
    Date Cleared
    2018-11-02

    (315 days)

    Product Code
    Regulation Number
    878.4550
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Fluoptics

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

    The Fluoptics Fluobeam® Imaging system is intended to provide real-time near infrared (NIR) fluorescence imaging of tissue during surgical procedures. The Fluoptics Fluobeam® Imaging system is indicated for use in capturing and viewing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, perfused organs, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    The Fluoptics Fluobeam® Imaging system can also be used to assist in the imaging of parathyroid glands and can be used as an adjunctive method to assist in the location of parathyroid glands due to the auto-fluorescence of this tissue.

    Use of the Fluobeam® device is intended to assist. not replace, experienced visual assessment, and biopsy with conventional histopathological confirmation per standard of care. The system is not to be used to confirm the absence of parathyroid tissue or glands and is only to be used to assist in location of visually identified gland/tissues.

    Device Description

    The Fluobeam 800 Clinic Imaging Device Used With Fluocase 800 Control System is an autofluorescence imaging system that is capable of visualizing autofluorescent signals from the parathyroid glands. The device is a non-contacting imaging system that excites fluorescent molecules with non-ionizing near-infrared light at 750 nm and collects emissions from 800 nm to (6) (4) mm. The collected emissions are subsequently displayed as an image on a panel PC screen.

    The Fluobeam device is composed of the following components:

      1. The optical head (FluoBeam 800 Clinic® Device)
      • a. Contains 750 nm laser (for fluorescence excitation), NIR LEDs (b) (4) and white LEDs (normal illumination λ
    AI/ML Overview

    The Fluoptics Fluobeam 800 Clinic® Imaging Device with Fluocase 800™ Control System is an autofluorescence detection device for general surgery and dermatological use. It is intended to provide real-time near-infrared (NIR) fluorescence imaging of tissue during surgical procedures for the visual assessment of blood flow and as an adjunctive method to assist in the localization of parathyroid glands due to their autofluorescence. It is explicitly stated that the device is to assist, not replace, experienced visual assessment and biopsy with conventional histopathological confirmation, and is not to be used to provide a diagnosis or confirm the absence of parathyroid tissue.

    Here's an analysis of its acceptance criteria and the supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided text does not explicitly define a set of quantitative "acceptance criteria" for the device's performance in terms of sensitivity, specificity, or other metrics (e.g., a specific minimum sensitivity for parathyroid detection). Instead, the acceptance is based on demonstrating the device's clinical applicability as an adjunctive tool and the mitigation of identified risks. The special controls listed define requirements for performance testing, but not quantitative thresholds.

    However, based on the Clinical Conclusions and the Benefit-Risk Determination, the implicit acceptance criteria are that the device can:

    • Consistently demonstrate autofluorescence of parathyroid glands with an intensity typically greater than surrounding tissues.
    • Improve parathyroid gland localization during surgery.
    • Result in reduced adverse clinical outcomes such as postoperative hypocalcemia, inadvertent resection, and autotransplantation when used as an adjunct.
    • Demonstrate safety, with identified risks mitigated through performance testing, software verification, and labeling.
    • Not lead to significant increases in operative time.

    Here's how the reported device performance addresses these implicit criteria:

    Acceptance Criterion (Implicit)Reported Device Performance (from Clinical Conclusions)Supporting Study
    Consistent autofluorescence of parathyroid glands with higher intensity than surrounding tissues.Parathyroid glands consistently autofluoresce with average intensity typically greater than nearby and surrounding tissues. (Mean intensity for parathyroid glands was 40.6 (±26.5) vs. thyroid 31.8 (±22.3) and background 16.6 (±15.4) in Study 1; Mean intensity for parathyroid glands was 47.6 (±26.9) vs. thyroid 22.2 and background 9.1 in Study 2). 98% of ultimately identified parathyroid glands autofluoresced in Study 4.Study 1, Study 2, Study 4
    Improve parathyroid gland localization during surgery.Autofluorescence appears to allow detection of parathyroid glands earlier in the surgical procedure. The number of parathyroid glands visualized with the device was significantly higher than with direct direct light in Study 2 (mean 3.7 vs 2.5). In Study 3, parathyroid identification rates were higher in the NIR+ group compared to NIR- group (76.3% vs. 65.7% of theoretically present parathyroids). In Study 4, 46% of located glands were not identified on initial visual inspection, and in 77% of patients, at least one gland was detected by autofluorescence before direct inspection.Study 2, Study 3, Study 4
    Reduction in adverse clinical outcomes (postoperative hypocalcemia, inadvertent resection, autotransplantation) when used as an adjunct.Study 3 provides reasonable affirmation that earlier detection can result in reduced postoperative transient hypocalcemia (NIR+ 5.3% vs NIR- 20.9%, Control 1 16.1%, Control 2 19.5%), inadvertent resection (NIR+ 1.1% vs NIR- 7.2%, Control 1 8%, Control 2 6.9%), and autotransplantation (NIR+ 2.1% vs NIR- 15.0%, Control 1 16.7%, Control 2 16.1%).Study 3
    Demonstrates safety (mitigation of electrical, mechanical, thermal, light/laser, infection, adverse tissue reaction, false identification risks).Passes various safety standards including IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60825-1, EN 62471. Software verification and validation performed (moderate level of concern). No direct/indirect patient contacting components for biocompatibility. Shelf life and sterility addressed for sterile sheath. Labeling includes risk mitigation warnings for false identification. No device-related AEs, SAEs, or UADEs reported in clinical studies.Non-clinical/Bench Studies, Software, Labeling, Risks to Health
    No significant increase in operative time.Study 3 reported no significant difference in operative time for the same surgeon with and without the device (NIR+ compared to NIR-).Study 3
    Acceptable occurrence of false positives/negatives when used as an adjunct, with appropriate labeling. (The device is not diagnostic and not for confirmation or concluding absence of parathyroid tissue, so absolute accuracy metrics are not the primary goal).False negatives are not frequent (98% reported sensitivity in Study 4 regarding identified parathyroid glands). False positives represent a more frequent occurrence (13 glands in 28 patients were false positives in Study 1; colloid nodules in Study 5). This moderate uncertainty of false diagnoses risk is mitigated by adjunctive use and labeling indicating the device is not for confirmation or diagnosis.Study 1, Study 4, Study 5, Labeling, Benefit-Risk

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

    Study 1 (Falco et al 2016):

    • Sample Size: 28 patients.
    • Data Provenance: Prospective, single institution (unspecified country, but given authors are from US/Argentina in other papers, likely US or Europe), between June 2015 and August 2015.

    Study 2 (Falco et al 2017):

    • Sample Size: 74 patients.
    • Data Provenance: Prospective, single institution (unspecified country, likely same as Study 1), between October 2015 and February 2016.

    Study 3 (Benmiloud et al):

    • Sample Size: 513 total patients (NIR+ group: 93, NIR- group: 153, Control 1: 180, Control 2: 87).
    • Data Provenance: "Before and After Controlled Study", single institution (unspecified country, authors typically based in France). Data from January 2015-January 2016 (Period 1) and February 2016-September 2016 (Period 2).

    Study 4 (Kahramangil et al):

    • Sample Size: 210 prospectively-enrolled patients.
    • Data Provenance: Retrospective review of prospectively-enrolled patients from three centers (one being the same hospital as Study 3). Unspecified years for data acquisition, unspecified country (authors typically based in US/Argentina/Turkey/France).

    Study 5 (De Leeuw et al):

    • Sample Size: 35 patients (28 specimens included for analysis).
    • Data Provenance: Prospective, single-center investigation (unspecified country, authors from France). Data between December 2014 and March 2015.

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

    • Study 1: Histologic confirmation for adenomas and normal gland biopsies for patients with primary hyperparathyroidism. Other surgical procedures did not have histology confirmation. The specific number and qualifications of pathologists are not mentioned.
    • Study 2: Parathyroid adenomas were resected for histology. Normal glands were not resected for histology. The specific number and qualifications of pathologists are not mentioned.
    • Study 3: "Parathyroids were only recorded as observed if the surgeon had 'no doubts' that the tissue was parathyroid." No tissue biopsies were performed for confirmation in the groups. The surgeons were "Surgeon 1 (five years of experience)" and "Surgeon 2 (twenty-five years of experience)."
    • Study 4: Parathyroids were confirmed with either frozen section histology, or if they met three visual criteria (yellow brown color, discrete shape, distinct vasculature). The specific number and qualifications of pathologists or surgeons are not mentioned beyond the general description.
    • Study 5: A "blinded pathologist" identified tissue using conventional histology. The qualifications or specific number of pathologists are not given.

    4. Adjudication method for the test set

    • Study 1: No explicit adjudication method mentioned. Histologic confirmation used where possible.
    • Study 2: No explicit adjudication method mentioned. Histologic confirmation used for adenomas.
    • Study 3: The surgeon's "no doubts" visual assessment was the primary "ground truth" for identified parathyroids, coupled with clinical outcomes. No independent adjudication mentioned.
    • Study 4: Confirmation by either frozen section histology or by meeting three visual criteria. No separate adjudication process beyond these methods.
    • Study 5: Histology results from a blinded pathologist were compared to the "scientist's" determination using Fluoptics. The "scientist" was a blinded investigator (not a clinician, unfamiliar with anatomy). This method itself acts as a form of adjudication against a histological ground truth.

    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 explicit traditional Multi-Reader Multi-Case (MRMC) comparative effectiveness study evaluating human readers' improvement with vs without AI assistance was described in the provided text. The studies focused on surgeon performance with and without the device, but not in a strict MRMC design with defined reader cohorts analyzing cases.

    • Study 2 did compare visualizations using the device (NIRL) versus direct inspection (WL), showing a mean difference (NIRL-WL) of 1.2 (0.8) parathyroid glands per patient, with 86.5% of patients having four glands visualized with the device vs. 12.2% with white light. This suggests an improvement in glandular visualization.
    • Study 3 compared clinical outcomes between groups where a surgeon did or did not use the device. Autotransplantation rates were significantly reduced in the NIR+ group compared to all other groups (e.g., NIR+: 2.1% vs. NIR-: 15.0%), and inadvertent parathyroid resection also occurred less frequently. This implies an improvement in surgical performance (a human "reader" or surgeon using the device). The "effect size" can be inferred from the differences in clinical outcomes and identification rates (e.g., reduction in hypocalcemia from 20.9% to 5.3% for transient hypocalcemia in one comparison).

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

    No standalone performance of the algorithm (device processing without human interpretation) was explicitly assessed or reported. The device is consistently described as an adjunctive tool to assist human surgeons. Clinical studies always involve a surgeon using the device in real-time.

    7. The type of ground truth used

    The ground truth varied across studies:

    • Study 1 & 2: Histology for resected parathyroid adenomas and normal gland biopsies (where performed). For many other tissues, visual assessment by the surgeon.
    • Study 3: Surgeon's visual assessment ("no doubts") that tissue was parathyroid, complemented by clinical outcomes (hypocalcemia, autotransplantation, inadvertent resection). No histology.
    • Study 4: Frozen section histology OR meeting three visual criteria (yellow-brown color, ovoid shape, distinct vasculature) by the surgeon.
    • Study 5: Conventional histology (H&E Saffron staining) by a blinded pathologist.

    8. The sample size for the training set

    The provided documents describe clinical studies used for evaluating the device's performance and supporting its regulatory acceptance, not for training a specific AI algorithm. The device, the Fluobeam 800 Clinic, is an imaging system that captures autofluorescent signals and displays them. While it has software with "several modes (standard, advanced, perfusion, low signals, and time lapse) for visualizing fluorescence and autofluorescence images" and allows for adjustment of imaging parameters, it is not described as an AI/ML algorithm that requires a "training set" in the conventional sense (i.e., for learning to identify features or make decisions). It functions more as an imaging modality. Therefore, a "training set" for an AI algorithm is not applicable or provided in the context of this device description.

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

    As noted above, the device is an imaging system, not an AI/ML algorithm requiring a training set. Therefore, this question is not applicable.

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    K Number
    K132475
    Manufacturer
    Date Cleared
    2014-05-07

    (273 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    FLUOPTICS

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

    As an imaging system used in capturing and viewing fluorescent images for the visual assessment of blood flow in adults as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive and organ transplant surgeries.

    Device Description

    The Fluobeam 800 Clinic® Imaging Device is an imaging system used in capturing and viewing fluorescent images for the visual assessment of blood flow as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used during plastic, micro-, reconstructive and organ transplant surgeries. The Fluobeam 800 Clinic® Imaging Device is intended for intraoperative visual assessment of blood vessels and related tissue perfusion, by enabling surgeons to observe fluorescent images of blood vessels and related tissue perfusion. Indocyanine green (ICG) is injected intravenously into patients. Class 1 infrared laser light is used to excite the fluorescence of ICG and illuminate the regions of a patient's body to be observed. A charge coupled device (CCD) camera captures the fluorescent image that is used to assess the blood vessels and related tissue perfusion. The Fluobeam 800 Clinic® Imaging Device consists of the following components: Fluobeam® camera unit and Fluocase 800 Control System. The Fluobeam® Camera Unit contains a CCD camera and laser sources and is used either by hand or attaching it to a mechanical arm. The Controller System receives the video signal of the fluorescent image from the Camera Unit, it digitizes it and sends it to a computer that outputs it on a display screen and/or records it. Adjustments of the fluorescent image are possible either by the Camera Unit or via a graphic interface on the computer.

    AI/ML Overview

    Here's an analysis of the provided text regarding the Fluoptics Fluobeam 800 Clinic® Imaging Device, focusing on acceptance criteria and supporting studies:

    It's important to note that the provided 510(k) summary primarily focuses on demonstrating substantial equivalence to a predicate device, rather than defining and proving specific quantitative acceptance criteria for its performance. The document states that the device functions as intended based on a review of published literature and the absence of adverse events in clinical use in Europe. It does not provide detailed performance metrics or a formal study with quantitative acceptance criteria as might be seen for novel high-risk devices or AI/ML-based algorithms requiring rigorous clinical validation.


    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided text, there are no explicitly stated quantitative acceptance criteria or specific reported device performance metrics in terms of clinical accuracy, sensitivity, or specificity. The acceptance relies on:

    Acceptance Criteria (Implied)Reported Device Performance
    Safety: Device operates safely according to standards.- Electrical per IEC 60601-1.
    • Electromagnetic Compatibility per IEC 60601-1-2.
    • Laser safety per IEC 60825-1 (Class I laser product).
    • "The Fluobeam 800 Clinic® Imaging Device has been sold and used clinically in Europe with no adverse events reported to date." |
      | Effectiveness (Functional Equivalence): Device functions as intended for visual assessment of blood flow and tissue perfusion. | - "All tests demonstrate that the device functions as intended."
    • "A review of the published literature concludes that the device worked as intended by safely assessing the blood flow and related tissue perfusion during surgeries."
    • "The intended use, indications for use, and the principles of operation of the Fluobeam 800 Clinic® Imaging Device and its predicate device are the same."
    • "The minor technological and design differences do not raise new or different questions of safety or effectiveness, as confirmed by verification and validation testing described in the 510(k) submission."
    • "All devices function as cameras allowing surgeons to view fluorescent images of blood flow and evaluation of tissue perfusion with the use of indocyanine green (ICG)." |

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size: Not explicitly stated. The document refers to "clinical use in Europe" and a "review of the published literature," implying a test set from real-world usage and previous studies, but a specific number of patients or cases for a dedicated validation study is not provided.
    • Data Provenance: Primarily retrospective, based on "clinical use in Europe" and "published literature." The country of origin for the "clinical use" is Europe, and the literature review would likely encompass various international studies.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

    • Number of Experts: Not specified. The "review of the published literature" would implicitly involve the expert opinions and findings presented in those publications, but there's no mention of a specific panel of experts convened to establish ground truth for this 510(k) submission's validation.
    • Qualifications of Experts: Not specified. It can be inferred that the experts involved in the published literature would be surgeons and medical professionals specializing in plastic, micro-, reconstructive, and organ transplant surgeries who use ICG fluorescence imaging.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not specified. Since there's no explicitly described dedicated test set with an independent ground truth establishment process led by a specific number of experts for this submission, no adjudication method is detailed. The "review of published literature" implies that prior studies' methodologies, including their ground truth establishment and potential adjudication, were considered.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    • MRMC Study: No, a multi-reader multi-case (MRMC) comparative effectiveness study is not mentioned in the provided text.
    • Effect Size: Not applicable, as no MRMC study was described.

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

    • Standalone Performance: Not applicable. The Fluobeam 800 Clinic® is an imaging system (hardware and software) designed for human visual assessment of blood flow. It is not an AI/ML algorithm that operates in a standalone capacity without human interpretation. It provides images that surgeons use to make decisions.

    7. The Type of Ground Truth Used

    • Type of Ground Truth: The ground truth for the effectiveness of visual assessment of blood flow and tissue perfusion, as supported by the "review of the published literature" and "clinical use in Europe," would be clinical outcomes and surgeons' intraoperative assessments of perfusion. This would likely be based on:
      • Surgical observations of tissue viability and blood flow during procedures.
      • Post-operative outcomes related to flap survival and graft integration.
      • Correlation between ICG fluorescence patterns and actual perfusion as determined by clinical judgment.

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. The Fluobeam 800 Clinic® is a traditional imaging device, not an AI/ML algorithm that requires a "training set" in the computational sense. Its design and functionality are based on established optical principles, laser physics, and ICG fluorescence properties, not machine learning model training.

    9. How the Ground Truth for the Training Set was Established

    • Ground Truth for Training Set: Not applicable, as it's not an AI/ML device requiring a training set. The "ground truth" for its development would be based on fundamental scientific understanding of fluorescence imaging, ICG pharmacokinetics, and surgical needs for perfusion assessment.
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