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510(k) Data Aggregation

    K Number
    K243473
    Date Cleared
    2025-07-29

    (263 days)

    Product Code
    Regulation Number
    892.1720
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PRORAD ATLAS ULTRAPORTABLE Digital X-ray system is intended to deliver high-quality, diagnostic radiographic images of the body extremities. It utilizes a portable X-ray unit, flat-panel detector and image acquisition software to produce clear digital images, enabling fast and accurate diagnosis. The portable X-ray unit is intended to be used only when stand/tripod mounted.

    The PRORAD ATLAS ULTRAPORTABLE X-ray digital system is predominantly employed in various settings, including health-care centres, temporary and emergency health centres (established, especially in pandemic circumstances), outreach and field interventions (such as mobile clinics/vans, screening campaigns, and home care), and tele-radiology solutions in remote areas.

    The primary users anticipated for the system include radiographers, radiological technologists, and medical professionals who are trained in safety, radiation protection, and image management.

    The PRORAD ATLAS ULTRAPORTABLE PLUS Digital X-ray system is intended to deliver high-quality, diagnostic radiographic images of the body extremities. It utilizes a portable X-ray Unit, flat-panel detector and real-time image processing using software to produce clear digital images, enabling fast and accurate diagnosis. The portable X-ray unit is intended to be used only when stand/tripod mounted.

    The PRORAD ATLAS ULTRAPORTABLE PLUS X-ray digital system is predominantly employed in various settings, including health-care centres, temporary and emergency health centres (established, especially in pandemic circumstances), outreach and field interventions (such as mobile clinics/vans, screening campaigns, and home care), and tele-radiology solutions in remote areas.

    The primary users anticipated for the system include radiographers, radiological technologists, and medical professionals who are trained in safety, radiation protection, and image management.

    Device Description

    The PRORAD ATLAS X-Ray system includes the ULTRAPORTABLE and ULTRAPORTABLE PLUS, which are portable diagnostic X-ray systems with fixed 70kV and 2mA tube current. These systems are intended to produce anatomical X-rays of the body extremities in both pediatric and adult patients. The PRORAD ATLAS X-Ray system was designed, developed, and manufactured by Prognosys Medical Systems Private Limited. The model numbers are listed below.

    Model NumberModel NameModel Description
    A86-ATL-0001PRORAD ATLAS ULTRAPORTABLEThese are ultraportable X-ray systems designed to generate diagnostic, high-quality X-ray images
    A87-ATL-0001The PRORAD ATLAS ULTRAPORTABLE PLUS

    The PRORAD ATLAS X-ray system is a sophisticated, battery-powered X-ray generator offered in two versions: PRORAD ATLAS ULTRAPORTABLE and ULTRAPORTABLE PLUS. The main distinction between these models lies in their exposure time ranges and target anatomical areas. The ULTRAPORTABLE model provides exposure times ranging from 0.01 to 1.30 seconds, while the ULTRAPORTABLE PLUS model offers an extended exposure range of 0.01 to 2.5 seconds. Both models share identical internal components, software, algorithms, and operational features and are intended for imaging body extremities. The system includes a high-voltage tank with an X-ray tube mounted on an adjustable tripod stand, allowing users to adjust the height to the specific imaging area. Exposure parameters are configured through the X-ray generator's graphical user interface (GUI). After setting the parameters and positioning the patient on the detector, the X-ray is activated via an exposure switch. The detector captures the radiation, converts it into a digital signal, and transmits the data wirelessly to a computer equipped with compatible software. The images are processed and displayed on the computer for diagnostic review. The PRORAD ATLAS system is compatible with several 510(k)-cleared detectors and their associated software, listed below in Table 1. Prognosys includes one detector and its pre-configured software in the package, depending on availability. Fully battery-operated, the system does not support direct power connection but can seamlessly integrate with multiple detectors and compatible software as part of the package.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and supporting documentation for the PRORAD ATLAS ULTRAPORTABLE X-Ray Systems do not include acceptance criteria or a detailed study that proves the device meets specific performance criteria beyond general safety and effectiveness.

    The document primarily focuses on demonstrating substantial equivalence to a predicate device (Remex KA6, K212144) rather than presenting a performance study with defined acceptance criteria. The "Summary of non-clinical testing" lists a series of international standards (IEC, ISO) and FDA guidance documents that were followed for design control, risk management, verification, and validation. The "Summary of clinical testing" mentions that clinical images were collected and reviewed by a qualified radiologist, confirming they are "clinically acceptable." However, specific quantitative acceptance criteria for image quality, diagnostic accuracy, or other performance metrics, along with the study design and results against those criteria, are not detailed in this document.

    Therefore, I cannot provide a table of acceptance criteria and reported device performance, nor can I provide information about sample size, expert details, adjudication methods, MRMC studies, standalone performance, or training set specifics, as this information is not present in the provided text.

    Based on the available text, here's what can be extracted:

    • Overall Conclusion: The device is deemed "safe and effective when the device is used as labelled and is substantially equivalent to the predicate device."

    Here's a breakdown of why the requested information cannot be fully provided based on the input:

    1. A table of acceptance criteria and the reported device performance: This information is not explicitly stated in the document. The document confirms that "Validation of PRORAD ATLAS X-Ray System has demonstrated that the system enables optimal and quality imaging of anatomical structures" and that clinical images are "clinically acceptable," but no specific quantitative criteria or performance metrics are given.

    2. Sample size used for the test set and the data provenance: The document states that "Clinical images of body extremities were collected from patients of varying ages, weights, and BMIs." However, the exact sample size and the provenance (e.g., country of origin, retrospective/prospective nature) of this clinical image test set are not specified.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: The document mentions that images were "reviewed by a qualified radiologist." It does not specify the number of radiologists or their specific qualifications (e.g., years of experience, board certification).

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: No adjudication method for the clinical image review is described.

    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: An MRMC study is not mentioned. The device described is an X-ray system, not an AI software to assist human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: This is not applicable as the device is an X-ray system, not an algorithm, and it's intended to be used by trained medical professionals.

    7. The type of ground truth used: The ground truth for the clinical images appears to be "clinical acceptability" as determined by a "qualified radiologist." This aligns with "expert consensus" in a general sense, but no more objective ground truth (e.g., pathology, outcomes data) is mentioned for the image quality assessment.

    8. The sample size for the training set: The document does not mention a training set, as it describes an X-ray hardware system, not an AI-driven software that requires a training set.

    9. How the ground truth for the training set was established: Not applicable, as no training set is mentioned.

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    K Number
    K240771
    Date Cleared
    2024-11-12

    (236 days)

    Product Code
    Regulation Number
    892.1680
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Wireless(V14 CLARITY, V14 HC, V17 CLARITY, V17 HC, F14 CLARITY, F14 HC)/Wired(V14 CLARITY, V14 HC, V17 CLARITY, V17 HC, F14 CLARITY, F14 HC, W17 Clarity, W17 HC) PRORAD X-Ray Flat Panel Detector with DROC is intended to capture for display radiographic images of human anatomy. It is intended for use in general projection radiographic applications wherever conventional film/screen or CR systems may be used. The PRORAD X-Ray Flat Panel Detector with DROC is not intended for mammography, tomography, and angiography applications. The use of this product is not recommended for pregnant women and the risk of radioactivity must be evaluated by a physician.

    Device Description

    PRORAD X-Ray Flat Panel Detector with DROC is the similar product to the predicate, Yushan X-Ray Flat Panel Detector with DROC, K201528, K210988, K220510. There are 8 models in this submission, V14 Clarity, V14 HC, V17 Clarity, V17 HC, W17 HC, F14 Clarity, F14 HC, W17 Clarity are a portable(wireless)/nonportable(wired) digital detector. The PRORAD X-Ray Flat Panel Detector with DROC is designed to be used in any environment that would typically use a radiographic cassette for examinations. Detectors can be placed in a wall bucky for upright exams, a table bucky for recumbent exams, or removed from the bucky for non-grid or free cassette exams. These medical devices have memory exposure mode, and extended image readout feature. Additionally, rounded-edge design for easy handling, image compression algorithm for faster image transfer, LED design for easy detector identification, extra protection against ingress of water.

    The PRORAD X-Ray Flat Panel Detector with DROC sensor can automatically collects x-ray images from an x-ray source. It collects x-rays and digitizes the images for their transfer and display to a computer. The x-ray generator (an integral part of a complete x-ray system), is not part of the submission. The sensor includes a flat panel for x-ray acquisition and digitization and a computer (including proprietary processing software) for processing, annotating and storing x-ray images. The personal computer is not part of this submission.

    PRORAD series is working by using DROC. This is a software running on a Windows PC as an user interface for radiologist to perform a general radiography exam. The function include:

    1. Detector status update
    2. Xray exposure workflow
    3. Image viewer and measurement.
    4. Post image process and DICOM file I/O
    5. Image database: DROC support the necessary DICOM Services to allow a smooth integration into the clinical network
    AI/ML Overview

    This submission for the PRORAD X-Ray Flat Panel Detector with DROC (K240771) indicates that no new performance data was generated to demonstrate substantial equivalence. Instead, the device is deemed substantially equivalent to its predicate devices (Yushan X-Ray Flat Panel Detector with DROC, K201528, K210988, K220510) due to minimal changes in product name, appearance, and labeling, implying that the performance of the device is identical to the predicates. Therefore, the acceptance criteria and study details would be those established for the predicate devices.

    However, based solely on the provided document, which states "no clinical study has been performed" and that "the performance data is the same and need no extra validation," it explicitly does not include a study directly proving the device meets new acceptance criteria. It relies on the substantial equivalence argument, meaning the predicate devices' performance data is referenced implicitly.

    Since the document explicitly states "No clinical study has been performed" and "Therefore the performance data is the same and need no extra validation", there isn't a direct study described in this document that proves the device meets (new) acceptance criteria. Instead, the device is deemed substantially equivalent to the predicate devices and thus relies on the predicate devices' performance data. The document does not provide details of any specific acceptance criteria or performance study results for the PRORAD device itself.

    However, based on the non-clinical performance data section, it states that "the image quality evaluation confirmed that the image quality of the PRORAD X-Ray Flat Panel Detector with DROC is substantially equivalent to that of the predicate device." While this isn't a detailed study, it implies a comparison.

    Here's an attempt to answer the questions based on the limited information regarding this specific device's performance, highlighting the reliance on predicate device information:

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

    Based on the provided document, no specific acceptance criteria for the PRORAD X-Ray Flat Panel Detector with DROC itself are listed, nor is new device performance data reported. The document states that the device's technical characteristics, design, functional, and performance characteristics are similar to the predicate devices. The assumption is that the new device meets the same performance characteristics as the predicate. The comparison table of technical characteristics (from page 8-14 of the original document) contains performance-related metrics that are presented as identical or nearly identical between the subject device and the predicates.

    Acceptance Criteria (Implied from Predicate/Comparison)Reported Device Performance (PRORAD)
    Technical Characteristics
    Pixel Pitch140 μm
    DQE (GOS, at 1 lp/mm, RQA5)0.27
    DQE (CsI, at 1 lp/mm, RQA5)0.50 (V14/V17 Clarity & F14 Clarity)
    MTF (GOS, at 1 lp/mm, RQA5)0.52
    MTF (CsI, at 1 lp/mm, RQA5)0.69 (V14/V17 Clarity & W17 Clarity)
    Max. Resolution (GOS)3.57 lp/mm
    Max. Resolution (CsI)3.57 lp/mm
    A/D Conversion16 bit
    Safety and Standards Compliance
    Compliance with AAMI/ANSI ES60601-1, IEC 60601-1, IEC 60601-1-2, IEC 62304, IEC 60601-1-6, ANSI AAMI IEC 62366-1 and ANSI/AAMI HE75.Confirmed (through non-clinical tests)
    Compliance with FDA's Guidance for the Submission of 510(k)s for Solid State X-ray Imaging DevicesFollowed
    Compliance with Guidance for the Content of Premarket Submissions for Device Software Functions (Software Level of Concern: Basic)Followed
    Compliance with Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket SubmissionsFollowed (risks addressed, controls implemented)
    Load-bearing characteristicsTested and Passed
    Protection against ingress of waterTested and Passed
    EMC emission testing (IEC60601-1-2)Satisfactory
    Biocompatibility (ISO 10993 series)Demonstrated (materials safe and effective)
    Image QualitySubstantially equivalent to predicate device

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

    The document states, "No clinical study has been performed." For non-clinical tests (e.g., electrical safety, EMC, mechanical, biocompatibility), sample sizes are not specified. The "image quality evaluation" also does not mention a sample size or data provenance. The assessment relies on the inherent similarity of the new device to the previously cleared predicate devices.

    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)

    Not applicable, as no new clinical study was performed for this 510(k) submission. The document relies on "image quality evaluation" that confirmed substantial equivalence, but details on experts or ground truth establishment for this comparison are not provided.

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

    Not applicable, as no new clinical study involving adjudication was performed for this 510(k) submission.

    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 a digital X-ray flat panel detector, not an AI-assisted diagnostic tool.

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

    Not applicable. This device is an imaging hardware component, not an algorithm for standalone diagnostic performance.

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

    Not applicable, as no new clinical study requiring ground truth was performed for this 510(k) submission. The "image quality evaluation" for substantial equivalence would likely rely on quantitative technical metrics rather than clinical ground truth for diagnostic accuracy.

    8. The sample size for the training set

    Not applicable, as no machine learning algorithm development (which would require a training set) is described for this device in the document.

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

    Not applicable, as no machine learning algorithm development is described.

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

    ProRad Series Stationary Radiographic System is intended for use by a qualified, trained doctor or technician on both adult and paediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography.

    Device Description

    The ProRad series Stationary Radiographic System is a diagnostic x-ray system intended for general purpose radiographic imaging of the human body. There are two types of configurations (2FC and 3NC) for ProRad; the difference is in the mounting of the X-ray tube. For X-ray tube mounting the configuration is either the floor mounted (2FC) or ceiling suspension (3NC) assembly.

    The devices are a new combination of a previously cleared solid state digital x-ray acquisition panel and software with the diagnostic x-ray components (including Xray tube, high frequency X-ray generator, a tilting vertical bucky, X-ray table and collimator) required to make a complete system. The purchaser may select any of the digital panels and software based on the user's requirements. The other components are also available in different configurations to meet specific customer needs. The X-ray panel and imaging software have been previously cleared by the FDA, and most of the other components are used in previously cleared 510(k) devices.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information for the ProRad 2FC and ProRad 3NC Digital Stationary Radiographic Systems, based on the provided text:

    Acceptance Criteria and Device Performance Table:

    The document primarily focuses on demonstrating substantial equivalence to predicate devices rather than setting and reporting specific performance metrics with acceptance criteria in a comparative table for novel device features. The "Comparable Properties" table (pages 6-8) is used to show alignment with predicate devices.

    Acceptance Criteria CategorySpecific Criteria (Implicit from Equivalence)Reported Device Performance (as stated in the document)
    Intended UseEquivalent to predicate devices (K150816, K153119) for diagnostic radiographic exposures of various body parts in adults and pediatrics, excluding mammography."Equivalent" to predicate devices.
    Configuration of Digital PanelsBattery or AC operated wireless IEEE 802.11n or Wired Ethernet."Same" as predicate devices.
    Digital Panel Models and their Clearance NumbersUtilize previously cleared FDA digital flat panel detectors (specific K numbers listed in Note 1)."Similar functionality" to predicate devices (Note 1 states the subject device uses different flat panel detectors that are previously FDA cleared, and testing demonstrates no increased safety concern or effect on effectiveness).
    Image Acquisition Panel SpecificationsComparable pixel resolution and size range (e.g., 3,320 x 3,408 Pixels 125 µm, 3,072 x 3,072 Pixels 139 µm, etc.)."Similar functionality" to predicate devices (Note 1).
    DICOM ComplianceDICOM 3 compliant."Same" as predicate devices.
    WiFi Wireless (if applicable)Functionality similar to predicate wireless detectors."Similar functionality" to predicate devices (specific Canon, Varex, PerkinElmer, and DRTECH wireless detectors listed).
    Image Acquisition SoftwareUtilize previously cleared FDA image processing software (specific K numbers listed in Note 2)."Similar functionality" to predicate devices (Note 2 states Prognosys uses previously cleared FDA software and does not modify it).
    Power SourceAC Line, various voltages available."Same" as predicate devices.
    X-ray GeneratorRange of power ratings (e.g., 32 kW to 80 kW, 125 kV/150 kV)."Same or similar functionality" to predicate devices (Note 3 states the subject device uses similar X-ray generators with different power ratings and that these generators have been used in previously cleared 510(k) devices).
    X-ray TubesRange of kV, focal spot sizes, and heat units (e.g., Toshiba E7239FX, Varex RAD14, etc.)."Similar functionality" to predicate devices (Note 4 states both configurations provide similar imaging resolution and these tubes have been used in previously cleared 510(k) devices).
    CollimatorAdequate inherent filtration."Similar functionality" to predicate devices (Note 5 states the inherent filtration is different but does not affect safety and effectiveness).
    Performance Standard ComplianceCompliance with FDA 21 CFR 1020.30-31 (Performance Standards for Diagnostic X-Ray Systems and Their Major Components)."Same" as predicate devices.
    Electrical SafetyCompliance with IEC 60601-1."Same" as predicate devices.
    Electromagnetic Compatibility (EMC)Compliance with IEC 60601-1-2.Device complies with this standard.
    Radiation ProtectionCompliance with IEC 60601-1-3.Device complies with this standard.
    Specific Safety/Performance for X-ray EquipmentCompliance with IEC 60601-2-54.Device complies with this standard.
    UsabilityCompliance with IEC 60601-1-6.Device complies with this standard.
    Risk ManagementCompliance with ISO 14971.Device complies with this standard.
    CybersecurityAdherence to "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, 2014" guidance for device labeling.Cybersecurity concerns were addressed based on the US FDA Guidance document.

    1. Sample sized used for the test set and the data provenance:

    • Sample Size: Not explicitly stated as a separate "test set" for a dedicated algorithm performance study. Instead, compliance is demonstrated through testing of the integrated system and reliance on previous FDA clearances for individual components.
    • Data Provenance: Not applicable in the context of an algorithm performance test set. The clinical images reviewed by a radiologist were "acquired by the device," but the origin (e.g., country, prospective/retrospective status) is not specified.

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

    • Number of Experts: One radiologist.
    • Qualifications of Experts: Only "a radiologist" is mentioned. Specific qualifications (e.g., years of experience, board certification) are not detailed.

    3. Adjudication method for the test set:

    • Adjudication method: Not applicable. The radiologist's review was a single assessment, not a consensus or adjudication process among multiple readers.

    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:

    • MRMC Study: No. The document explicitly states: "Since the digital x-ray panels and software have previously received FDA clearance, a clinical study was not required as per the FDA guidance document." The clinical image review was supplementary.
    • Effect size of human reader improvement with AI: Not applicable, as no MRMC study or AI assistance evaluation was conducted. The device is an imaging system, not an AI diagnostic tool.

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

    • Standalone Performance Study: No. This device is a diagnostic X-ray system, which intrinsically requires a human (a qualified doctor or technician) in the loop for operation and interpretation. The performance of individual cleared components (digital panels, software) was relied upon.

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

    • Type of Ground Truth: For the supplementary review, the "ground truth" was the radiologist's assessment that the images were "acceptable and allowed the radiologist to make an accurate diagnosis." This is a form of expert opinion on image quality and diagnostic utility, rather than an objective "truth" like pathology or outcomes.

    7. The sample size for the training set:

    • Sample Size for Training Set: Not applicable. This document does not describe a machine learning algorithm that requires a training set. The device is a conventional X-ray system composed of cleared components.

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

    • Ground Truth for Training Set: Not applicable, as there is no machine learning algorithm described.
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