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510(k) Data Aggregation
(57 days)
RealCloud Imaging Inc. dba RealCloud Imaging
Brasseler GEM is a USB-driven digital intraoral x-ray sensor which is intended to acquire dental radiographic images. Brasseler GEM must be operated by healthcare professionals who have been trained and are competent using various methods of acquiring radiographic images of dental anatomy. Brasseler GEM can be used with dental positioning devices and holders to assist with aligning an x-ray source beam with the sensor and anatomy. Brasseler GEM can also be aligned by hand with assistance of patient.
Brasseler GEM is a USB-driven digital sensor designed for health care professionals already acquainted with the standard procedures for acquiring dental intraoral radiographs. Digital x-ray imaging is an aide for diagnosis and should always be confirmed by the doctor using appropriate additional diagnostic aides, professional judgement, and experience.
Brasseler GEM10 is for pediatric use and adult periapical use, GEM15 is for pediatric and adult bitewing and periapical use, and GEM20 is for adult use including bitewings. The Brasseler GEM design uses advanced ergonomic principles with four beveled corners, a moderate profile, and a rounded casing providing enhanced comfort for patients. Brasseler GEM is positioned in the patient's mouth in the same manner as intraoral film is positioned.
Brasseler GEM has a CMOS x-ray imager that creates a digital image from x-ray doses perceptible by the sensor. The digital image created is immediately visible on the screen of a personal computer connected to Brasseler GEM through the standard USB port. Image analysis software is not part of the submission. For Brasseler GEM to be used in a dental practice, an optional image analysis software will be necessary. Only with image analysis software can acquired images be optimized for specific diagnostic tasks, archived as image files, and printed out on a suitable printer. Software provides drivers and utilities for x-ray dose optimization, sensor activation and settings. Brasseler GEM capture x-ray images suitable for recognition of normal anatomical structures, dental pathologies, and abnormal conditions. Inadequate images may result in misdiagnosis thereby subjecting the patient to incorrect or unnecessary dental procedures that would present an unacceptable risk to the patient. Functions of the Brasseler GEM detector are controlled by software (firmware). The software of Brasseler GEM is of Moderate Level of Concern and is not based on the software of the predicate, Clio Prime.
Brasseler GEM shall be operated by healthcare professionals who are educated and competent to perform the acquisition of dental intraoral radiographs. Brasseler GEM can be used either in combination with positioners manufactured to facilitate the positioning and alignment with an x-ray beam, or it may also be positioned by hand with the assistance of the patient. Brasseler GEM can be used with patients of any age, providing the correct positioning of the sensor in the patient mouth can be realized. Using Brasseler GEM is a suitable diagnostic method and may offer reduced radiation exposure compared to analog procedures. Available software image enhancement tools may enhance sensitivity and consequently reduce errors introduced by subjective analysis. Brasseler GEM can perform and achieve the same type of two-dimensional images as conventional (traditional) film sizes 0, 1 and 2. Brasseler GEM cannot be used to, or as a substitution for extraoral or other types of dental x-ray. When using Brasseler GEM and software as a diagnostic aide, clinical experience and a combination of the diagnostic aides should be used to form a diagnosis and should not be solely relied upon for diagnosis.
The provided text describes Brasseler GEM, a digital intraoral x-ray sensor, and its equivalence to a predicate device, Clio Prime. The document primarily focuses on demonstrating substantial equivalence through comparison of technical specifications, rather than providing detailed acceptance criteria from a clinical study for diagnostic performance.
Therefore, the response below will focus on the information available in the provided text, and will explicitly state when information requested cannot be found.
Acceptance Criteria and Device Performance Study for Brasseler GEM
The provided document, a 510(k) summary, primarily relies on bench testing and comparison to a predicate device (SOTA Imaging's Clio Prime) to establish substantial equivalence. It does not detail specific diagnostic performance acceptance criteria in the manner one might find for an AI-based diagnostic device (e.g., sensitivity, specificity thresholds). Instead, the acceptance is based on demonstrating that the Brasseler GEM is as safe and effective as the legally marketed predicate device.
The "study that proves the device meets the acceptance criteria" largely refers to the comparative analysis presented through the Comparison Table and the stated equivalence of technical performance metrics like MTF and DQE.
1. A table of acceptance criteria and the reported device performance
Based on the provided document, the "acceptance criteria" are implied by the demonstration of substantial equivalence to the predicate device, Clio Prime. The performance is assessed by comparing technical specifications and affirming identical/equivalent performance in areas relevant to image quality.
Acceptance Criteria (Implied by Predicate Equivalence) | Reported Device Performance (Brasseler GEM) | Predicate Device Performance (Clio Prime) |
---|---|---|
Intended Use | Acquire dental radiographic images by healthcare professionals for intraoral diagnostic purposes. | Acquire dental intraoral radiography images by healthcare professionals for intraoral diagnostic purposes. |
Indications for Use | Same as Intended Use. Can be used with positioning devices or handheld. | Same as Intended Use. Can be used with positioning devices or handheld. |
Sensor Exterior Sizes | 3 sizes: 36.36 x 24.53 mm, 38.83 x 29.63 mm, 41.80 x 30.48 mm | 2 sizes: 36.31 x 30.42 mm, 41.76 x 30.42 mm |
Sensor Imaging Sizes | 3 sizes: 30.26 x 20.32 mm, 33.15 x 26.25 mm, 36.08 x 26.25 mm | 2 sizes: 30.26 x 20.32 mm, 36.08 x 26.25 mm |
Overall Imaging Areas | 3 sizes: 615 mm2, 870 mm2, 947.1 mm2 | 2 sizes: 615.0 mm2, 947.1 mm2 |
Pixel Size | 19.5 µm | 19.5 µm |
Imager Resolution | 3 resolutions: 1539 x 1026, 1692 x 1324, 1842 x 1324 pixels | 2 resolutions: 1539 x 1042, 1842 x 1342 pixels |
X-Ray Resolution | 20+ visible lp/mm | 20+ visible lp/mm |
Dynamic Range | 16,384:1 | 16,384:1 |
Technology | CMOS | CMOS |
Scintillator Technology | Cesium Iodide | Cesium Iodide |
Operating System Compatibility | Microsoft Windows 7 and 10 | Microsoft Windows 7 and 10 |
Interface to PC | USB 2.0, Type A | USB 2.0, Type A |
Cable Length | 1.9 m and 2.9 m | 1.9 m and 2.9 m |
Power Consumption | 0.8 Watts Max | 0.8 Watts Max |
Electrical Rating | DC 5V, 350 mA max | DC 5V, 350 mA max |
Sterilization Suitability | Not suitable for sterilization; requires hygienic barrier. | Not suitable for sterilization; requires hygienic barrier. |
Housing | IPx8 Equivalent ISO 10993-1 Biocompatible | IPx8 Equivalent ISO 10993-1 Biocompatible |
MTF (Modulation Transfer Function) | Identical to Clio Prime | (Baseline for comparison) |
DQE (Detective Quantum Efficiency) | Substantially equivalent to Clio Prime | (Baseline for comparison) |
Biocompatibility | Based on predicate device, identical materials and manufacturing. | (Baseline for comparison) |
Software Level of Concern | Moderate (not based on predicate software) | (Predicate software not described in detail) |
Note: The document emphasizes that "Brasseler GEM is not only similar in performance as Clio Prime but is also safe and effective based on performance testing." The performance testing mentioned is primarily bench testing and direct comparison of specifications.
2. Sample sizes used for the test set and the data provenance
The document refers to "extensive bench testing" and "clinical images" for performance testing.
- Test Set Sample Size: The specific sample sizes for bench testing are not explicitly quantified in terms of number of devices or number of test cases run beyond "extensive bench testing." For "clinical images," no specific number of images is provided, nor the number of patients/cases represented.
- Data Provenance: Not specified (e.g., country of origin, retrospective or prospective). The document only states "RealCloud Imaging has provided clinical images."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable / Not specified. The study described focuses on technical equivalence and image acquisition capabilities, not on diagnostic accuracy requiring ground truth established by experts for clinical images. The text states: "Digital x-ray imaging is an aide for diagnosis and should always be confirmed by the doctor using appropriate additional diagnostic aides, professional judgement, and experience." This implies the device provides images for human interpretation, rather than an AI producing a diagnosis that needs expert ground truth for validation.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable / Not specified. As the study is focused on technical equivalence rather than diagnostic accuracy determined by human readers, an adjudication method for a test set is not detailed.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No. An MRMC comparative effectiveness study was not performed as this is a device for image acquisition, not an AI assisting human readers with diagnosis. There is no AI component described that would augment human diagnostic performance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, in a sense. The "performance testing" described (bench tests, MTF, DQE comparison) reflects the standalone performance of the Brasseler GEM sensor and its ability to acquire images, independent of human interpretation or an AI algorithm. However, this is not an "algorithm only" performance meant for diagnostic output. The text states: "Image analysis software is not part of the submission... only with image analysis software can acquired images be optimized for specific diagnostic tasks, archived as image files, and printed out on a suitable printer." This implies the device itself is an image capture hardware without integrated diagnostic algorithms.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable / Not specified. The "performance testing" detailed focuses on technical specifications (MTF, DQE validation against a predicate device) and basic functionality via "clinical images" to show the system works as intended. There is no mention of "ground truth" for diagnostic accuracy established by expert consensus, pathology, or outcomes data, as the device's role is imaging, not diagnosis.
8. The sample size for the training set
Not applicable / Not specified. This device is an x-ray sensor (hardware), not an AI algorithm that requires a training set. The firmware of the device is mentioned as "software... of Moderate Level of Concern," but this refers to its operational control, not an AI model for image interpretation or diagnosis.
9. How the ground truth for the training set was established
Not applicable / Not specified. As this device is a hardware sensor and not an AI algorithm requiring a training set, the concept of establishing ground truth for a training set does not apply here.
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(39 days)
REALCLOUD IMAGING INC.
Dentrix Ascend Imaging is a web-based Dental Picture Archiving and Communications Systems (PACS), i.e. dental imaging software, that enables dental care facilities to acquire, process, edit, and enhance dental images.
Dentrix Ascend Imaging provides a web-based interface for image acquisition and management of images which are used in the field of Dentistry and when operated by dental professionals who are responsible for providing dental care.
Images can be acquired from dental image acquisition devices and/or consumer imaging devices such as color digital cameras. Previously acquired images or volumes can be selected for upload directly from the user's computer.
Supported images include intraoral dental x-rays/volumes and intraoral and extraoral color images produced by intraoral video or consumer digital cameras.
Dentrix Ascend Imaging is used for diagnostic purposes in the field of dentistry. Dentrix Ascend Imaging is not intended for diagnostic use on a mobile display.
Images can be edited/enhanced (e.g. zoomed, contrast adjusted, rotated, rotated, filtered, etc...) as well as exported to standard image file formats.
Dentrix Ascend Imaging is web-based dental image software that provides Internet access to an image library for each patient in a practice. It also provides tools for dental practices to manipulate patient images and both acquire and upload new images in industry standard formats. Images canbe annotated and tagged and are available for use. Dentrix Ascend Imaging can be accessed by the user via an internet connection and does not require traditional s oftware installation on the user's computer.
Dentrix Ascend Imaging operates from within the Google brand ChromeWeb Browser version 39.x and higher on supported Windows and Mac Operating Systems and from within the Apple brand Safari Web Browser 8.x on Apple IOS iPad devices. Dentrix Ascend Imaging requires a minimum 17" monitor for viewing images upon a Windows or MAC PC, and operates upon an iPad device with minimum 1024 X768 resolution. The iPad device can be used for non-diagnostic purposes only.
The provided document is a 510(k) premarket notification for a medical device called Dentrix Ascend Imaging, a web-based Picture Archiving and Communications System (PACS) for dental imaging. This type of submission relies on demonstrating substantial equivalence to a legally marketed predicate device rather than providing extensive clinical study data to prove novel safety and effectiveness.
Therefore, the document does not contain the detailed information typically found in a study demonstrating acceptance criteria for a new device's performance, especially not in a clinical context.
Here's a breakdown of the requested information based on the provided text, highlighting what is present and what is absent:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly define "acceptance criteria" in a quantitative, measurable sense for the device's diagnostic performance (e.g., sensitivity, specificity, accuracy against a gold standard). Instead, it establishes substantial equivalence by comparing its features and functions to the predicate device.
The table below summarizes the comparison between the proposed device (Dentrix Ascend Imaging) and the predicate device (Curve Image) as presented in the document, which serves as the basis for demonstrating equivalence and, implicitly, meeting "acceptance" in the context of a 510(k).
Table: Comparison of Dentrix Ascend Imaging to Predicate Device
Feature/Characteristic | Predicate Device: Curve Image (K112974) | Proposed Device: Dentrix Ascend Imaging (K151438) | Equivalence Assessment / Reported Performance |
---|---|---|---|
Intended Use | Internet-based, image management software (PACS) for dental offices to keep hard and soft tissue charts in digital images. | Web-based Dental PACS, i.e., dental imaging software, that enables dental care facilities to acquire, process, edit, and enhance dental images. | "Virtually identical" |
Indications for Use | For diagnostic use, acquisition, editing, and storage of digital images. | For diagnostic purposes in the field of dentistry; acquisition, processing, editing, and enhancement of dental images. | "Virtually identical" |
Environment of Use | Dental Offices | Dental Offices | Identical |
Host Platform | Web-based Software Application | Web-based Software Application | Identical |
Technical Characteristics | - Web-based application and interface |
- Secure data transmission (HTTPS)
- Database Management and Storage
- Secure server and Infrastructure | - Web-based application and interface
- Secure data transmission (HTTPS)
- Database Management and Storage
- Secure server and Infrastructure | Identical |
| Key Functionality (Examples) | - Browsing images by date/source - Viewing an image
- Uploading image file
- Acquiring image from web camera/TWAIN/standard dental devices
- Copying/Saving/Annotating modified images
- Zooming, Inverting colors, Rotating, Flipping, Adjusting Brightness/Contrast
- Lossless Image Compression
- Zoom depth: absolute 1x, Fit, Relative
- Crop Image | - Browsing images by date/source
- Viewing an image
- Uploading image file
- Acquiring image from web camera/TWAIN/standard dental devices
- Exporting/Saving/Annotating modified images
- Zooming, Inverting, Rotating, Flipping, Adjusting Brightness/Contrast
- Lossless Image Compression
- Zoom depth: absolute 1x, Fit, Relative
- Spotlight Image
- Density Measurement | "Substantially all of the features and functionality." Dentrix Ascend Imaging has additional features like "Spotlight Image" and "Density Measurement" and some minor differences (e.g., "Exporting an Image" vs "Copying an Image"). |
| Non-Clinical Performance Testing | Not detailed for predicate, but assumed similar. | "Series of non-clinical performance tests were performed." These tests "demonstrated that Dentrix Ascend Imaging is safe and effective for its intended use and its indications of use." | Passed internal validation and verification testing for reliable post-processing and display of images. |
| Clinical Performance Testing | Not applicable / Not mentioned. | None performed or required. | Not required for substantial equivalence in this context. |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Absent. The document refers to "non-clinical performance testing" and "validation and verification testing" but does not detail the sample sizes, type of data (e.g., number of images, patient cases), or data provenance used for these internal tests. These tests are presumably internal development and verification tests rather than external clinical trials.
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)
- Absent. Since no clinical performance testing or diagnostic accuracy study is presented, the concept of "ground truth" established by experts for a test set is not applicable in this 510(k) submission. The non-clinical tests would have validated software functions against engineering specifications, not clinical outcomes.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Absent. As no clinical study involving expert interpretation is detailed, adjudication methods are not discussed.
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
- Absent. No MRMC or comparative effectiveness study involving human readers or AI assistance (as a diagnostic aid) was performed or mentioned. Dentrix Ascend Imaging is described as a PACS system, primarily for image acquisition, management, and post-processing, not an AI-powered diagnostic tool that assists human readers in lesion detection or diagnosis.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Absent. This device is a PACS for managing and displaying images under human professional operation, not a standalone diagnostic algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Absent. As detailed in points 2 and 3, no clinical ground truth (expert consensus, pathology, outcomes) was established or used for performance testing. The "ground truth" for the non-clinical tests would have been the functional specifications of the software.
8. The sample size for the training set
- Absent. This device is a PACS, not an AI/ML device that requires a training set of data.
9. How the ground truth for the training set was established
- Absent. This is not an AI/ML device and therefore does not have a training set or associated ground truth.
Conclusion on "Study":
The "study" referenced in the document is a "Summary of Non-Clinical Performance Testing," which involved "positive and negative testing against the device requirements and human factors" and "validation and verification testing." This is typical for demonstrating substantial equivalence for a PACS system, focusing on functional performance, cybersecurity, and adherence to recognized standards (ISO 14971:2007 for Risk Management, IEC 62304:2012 for Software Life Cycle Processes). It explicitly states that "No clinical performance testing has been included in this submission" and that such testing was "neither required nor performed" based on the hazard analysis and device classification. Therefore, the document does not contain the kind of detailed clinical study information often associated with proving acceptance criteria for diagnostic accuracy or safety in many other types of medical devices.
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