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510(k) Data Aggregation

    K Number
    K231761
    Date Cleared
    2023-10-27

    (133 days)

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

    PodSKAN HF Diagnostic X-Ray System is intended for use by the qualified and trained clinicians or radiographers for generating X-rays of feet. It can be used for adults and paediatrics.

    PodSKAN is not intended for Mammography and Fluoroscopy Applications.

    Device Description

    PodSKAN is an advanced high frequency type X-Ray system designed for superior image quality with powerful 2.8KW generator and very low leakage radiation. The system houses two microprocessors, one for control/supervisory functions and another one man-machine/User interface. It can be easily plugged into 16A wall socket with 120 VAC or 240 VAC, 50/60 Hz. The technology incorporates feedback circuits to ensure highest accuracy & reproduceability of X-Ray output. It consists of

    • . Tube head assembly (including collimator and goniometer)
    • Base foot platform and side handle for patient support .
    • External console and Hand switch .

    PodSKAN HF diagnostic X-ray system can be used with Film, Computed Radiography (CR) and Digital Radiography system image receptors along with associated image capture software. Skanray recommends using 510(k) cleared flat panel detectors with AED functionality wired or wireless of size 10"x12" or 14"x17"and image acquisition systems to maintain compliance and quality

    AI/ML Overview

    The provided document is a 510(k) summary for the PodSKAN HF Diagnostic X-ray System. It focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific acceptance criteria through a dedicated study.

    Therefore, the acceptance criteria and study details as requested (sample size, data provenance, ground truth establishment, MRMC study, standalone performance) are not explicitly present in the provided text. The document refers to compliance with various IEC standards and FDA performance standards (21 CFR 1020.30-1020.31) but does not present a specific study with defined acceptance criteria and reported device performance in a tabular format as requested for a diagnostic AI/medical device.

    However, I can extract the relevant information regarding performance and compliance from the document and highlight what is missing based on your request.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not provide a table with "acceptance criteria" and "reported device performance" in the context of a diagnostic accuracy study. Instead, it discusses compliance with regulatory standards and compares technical specifications to predicate devices.

    Acceptance Criteria (Implied by Compliance)Reported Device Performance (from "Comparison to Predicate and Reference devices" and "Performance data")
    IEC 60601-1: General requirements for basic safety and essential performanceThe subject device has been evaluated and found to be compliant to safety and essential performance as per IEC 60601-1.
    IEC 60601-2-28: Basic safety and essential performance of X-ray tube assembliesNot explicitly stated as "met" but implied by overall compliance.
    IEC 60601-2-54: Basic safety and essential performance of X-ray equipment for radiography and radioscopyThe subject device has been evaluated and found to be compliant as per IEC 60601-2-54 regarding accuracy of loading factors, reproducibility of radiation output.
    IEC 60601-1-3: Radiation protection in diagnostic X-ray equipmentThe subject device has been evaluated and found to be compliant as per IEC 60601-1-3 regarding half value layer, leakage radiation in loading and normal state, and stray radiation.
    IEC 60601-1-6 & IEC 62366-1: Usability EngineeringThe device complies with these standards (listed).
    IEC 62304: Medical device software – Software life-cycle processesThe device complies with this standard (listed).
    ISO 10993-1: Biological evaluation of medical devicesThe device complies with this standard (listed).
    IEC 60601-1-2: Electromagnetic disturbancesThe subject device has been evaluated and found to be compliant as per IEC 60601-1-2 regarding conducted emission, radiated emission, harmonics, voltage fluctuations, electrostatic discharge (ESD), electrical fast transients (EFT), radiated RF electromagnetic field, continuous conducted RF, surges, power frequency magnetic field, voltage dips and short interruption.
    FDA Performance standards 21 CFR 1020.30-1020.31: Diagnostic X-Ray system and Radiographic equipmentThe device also complies with FDA performance standards 21CFR 1020.30-1020.31.
    kV Accuracy: (Self-imposed for better performance)+/- 5% (Predicate devices: +/- 8%) - Better performance than predicate.
    Collimator lamp timer: (Functionality)30 seconds (Predicate devices: 13 seconds) - Substantially Equivalent. Function is available; timing does not impact indicated application.
    Image Quality: (Implied for diagnostic systems)"The validation testing, which includes sample clinical images, demonstrates compliance to the diagnostic quality imaging performance when used with 510k cleared detector and imaging software for the intended application."

    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: "The validation testing, which includes sample clinical images, demonstrates compliance to the diagnostic quality imaging performance when used with 510k cleared detector and imaging software for the intended application."
    • No specific sample size for a test set (e.g., number of images/patients) is provided.
    • No data provenance (country of origin, retrospective/prospective) is mentioned.
    • This device is an X-ray system (hardware), not an AI diagnostic algorithm. The "validation testing" with "sample clinical images" appears to be for general image quality assessment of the hardware, not for diagnostic accuracy of an AI.

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

    • Not applicable/Not mentioned. Since this is a submission for an X-ray hardware system, not an AI diagnostic algorithm, the concept of "ground truth" for diagnostic labels established by experts is not discussed in the provided text. The performance data focuses on compliance with physical and electrical standards for X-ray generation and image quality.

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

    • Not applicable/Not mentioned. This information is typically relevant for studies evaluating the diagnostic accuracy of a software algorithm, particularly when establishing a consensus ground truth. It is not discussed for this X-ray hardware system.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • No MRMC comparative effectiveness study was performed or mentioned. The device is an X-ray system, not an AI software intended to assist human readers.

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

    • Not applicable. This refers to the standalone performance of an AI algorithm. The PodSKAN HF Diagnostic X-ray System is hardware.

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

    • Not explicitly defined/Not applicable in the typical sense for a diagnostic algorithm. For an X-ray hardware system, "ground truth" would relate to the physical and radiation output accuracy relative to established standards (e.g., kV accuracy, mAs reproducibility, HVL), as well as the ability to produce images of "diagnostic quality," which is assessed qualitatively or against established phantom images/standards rather than disease-specific pathology or outcomes data in this context.

    8. The sample size for the training set

    • Not applicable. The device is hardware, not a machine learning model that undergoes a training phase.

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

    • Not applicable. As above, this is hardware, not an AI/ML system requiring a training set with established ground truth.
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    K Number
    K212940
    Date Cleared
    2022-03-04

    (170 days)

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

    SKANMOBILE and SKANMOBILE-DR are intended for use in generating radio graphic images of human anatomy in all general-purpose x-ray diagnostic procedures for all patient population including paediatrics and adults. It may be used in radiology departments, emergency rooms, intensive care units, operating rooms, orthopaedics clinics, military camps, paediatric clinics, medical camps and small hospitals.

    SKANMOBILE and SKANMOBILE-DR are indicated for taking radiographic exposures of the skull, spinal column, chest, abdomen, extremities and other body parts with the patient sitting, standing or lying in the prone or supine position. The device has been designed for indoor usage and used/operated only by the trained & qualified physicians or x-ray technologist.

    SKANMOBILE and SKANMOBILE-DR are not intended for mammographic applications.

    Device Description

    The SKANMOBILE and SKANMOBILE-DR are X-ray systems which generates high frequency X-rays for diagnostic radiography in all patient population including pediatrics and adults.

    SKANMOBILE houses two microprocessors: one for control/supervisory functions and another for man-machine/user interface. The technology incorporates feedback circuits to ensure accuracy & reproducibility of X-Ray output.

    SKANMOBILE consists of following sub-assemblies:

    1. Tube head
    2. SKANMOBILE trolley

    SKANMOBILE-DR is a variant based on SKANMOBILE platform. SKANMOBILE-DR is a digital radiographic system designed for optimized image quality featuring wireless flat panel detector and operator console for digital imaging integrated with high frequency generator. SKANMOBILE-DR is similar to SKANMOBILE where tube head generator, collimator, and counter balancing mechanism remains same. The new or modified assemblies/sub-assemblies that are used in SKANMOBILE-DR are as follows:

    1. Touchscreen operator console.
    2. Modified brake mechanism for wheels
    3. Modified cassette tray to house the cassette / flat panel detectors.

    Both SKANMOBILE and SKANMOBILE-DR consists of software/firmware which enables the operation of the devices.

    AI/ML Overview

    The provided text does not contain information about specific acceptance criteria or an internal study demonstrating that the device meets those criteria. Instead, it focuses on the device's substantial equivalence to predicate devices, compliance with regulatory standards, and summarizes non-clinical performance data.

    Therefore, I cannot populate the table of acceptance criteria or provide details about a study proving the device meets acceptance criteria as described in your request. The document explicitly states that "clinical studies are not required" for this submission, further indicating the absence of a study focused on proving specific performance metrics against pre-defined acceptance criteria in a clinical setting.

    However, I can extract information related to the device's performance, testing, and ground truth establishment in a general sense based on the provided text, especially concerning the evaluation of the flat panel detectors which are a key component.

    Here's an analysis of what is available in the document:

    1. Table of Acceptance Criteria and Reported Device Performance:

    As mentioned, explicit acceptance criteria are not presented in the provided text. The document focuses on demonstrating substantial equivalence to predicate devices and adherence to various electrical, safety, and image quality standards (DQE, MTF).

    Acceptance Criteria (Not explicitly stated as such, but derived from performance evaluations)Reported Device Performance (Subject Device)
    Detective Quantum Efficiency (DQE) of Digital PanelPaxscan 4336Wv4: 0.242 @ 1cycle/mm, 0.125 @ 2cycles/mm, 0.04 @ 3cycles/mm CareView1500P: ~65% @ (0 lp/mm), ~20% @ (3 lp/mm)
    Modulation Transfer Function (MTF) of Digital PanelPaxscan 4336Wv4: 0.521 @ 1cycle/mm, 0.206 @ 2cycles/mm, 0.08 @ 3cycles/mm CareView1500P: ~70% @ (1 lp/mm), ~40% (@2 lp/mm), ~22% (@3 lp/mm)
    Image Quality (Readability by Radiologist/Radiographer)"Images were of good quality which were easily read by the radiologist"
    Electrical SafetyComplies with IEC-60601, IEC-60601-1-2, IEC-60601-1-3, IEC-60601-2-54, IEC-60601-2-28, IEC 60601-1-6
    Electromagnetic Compatibility (EMC)Complies with IEC-60601-1-2
    Software Life Cycle ProcessesComplies with IEC 62304:2006
    Risk ManagementComplies with ISO 14971:2012
    Exposure Index of Digital X-ray systemsComplies with IEC 62494-1
    Determination of Detective Quantum EfficiencyComplies with IEC 62220-1-1
    Digital Imaging and Communications in Medicine (DICOM)Complies with NEMA PS 3.1 - 3.20 (2016) and supports DICOM
    Radiation Dose DocumentationComplies with IEC 61910-1
    Characteristics of Focal SpotsComplies with IEC 60336
    Determination of quality equivalent filtration and permanent filtrationComplies with IEC 60522:1999
    Biological evaluation of medical devicesComplies with ISO 10993-1:2009
    Information supplied by the manufacturer of medical devicesComplies with EN 1041:2008+A1:2013
    Medical devices - Symbols to be used with medical device labelsComplies with ISO 15223-1
    Performance Testing of Shipping Containers and SystemsComplies with ASTM D4169-16
    Performance Standard for Radiation Safety for Diagnostic X-Ray SystemsComplies with 21 CFR 1020.30 and 1020.31

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

    • Test Set Sample Size: Not specified in terms of number of images/patients.
    • Data Provenance: Not specified. It mentions testing was done "both in-house and by outsourcing to appropriate third-party vendors." The document does not indicate the country of origin of the data or whether it was retrospective or prospective.

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

    • The document states that "The quality of the images obtained from the subject devices were analysed by a radiographer and a radiologist and it was found the images were of good quality which were easily read by the radiologist".
    • Number of experts: At least one radiographer and at least one radiologist ("a radiographer and a radiologist").
    • Qualifications: "radiographer" and "radiologist." No specific years of experience are mentioned.

    4. Adjudication method for the test set:

    • Not specified. The text simply says "analysed by a radiographer and a radiologist." It does not describe a formal adjudication process (e.g., 2+1, 3+1).

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • No MRMC comparative effectiveness study was done. The device described is a mobile X-ray system, not an AI-assisted diagnostic tool for image interpretation.

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

    • Not applicable as this is an X-ray imaging system, not an algorithm for image interpretation. The "software/firmware" described primarily controls the operation of the device and integrates with image acquisition software.

    7. The type of ground truth used:

    • For image quality, the ground truth was "expert consensus" implicitly, as it was determined by the analysis of a radiographer and a radiologist who found the images to be of "good quality" and "easily read."
    • For technical specifications (DQE, MTF, electrical safety, etc.), the "ground truth" or reference was compliance with various international standards (IEC, ISO, NEMA, ASTM, 21 CFR).

    8. The sample size for the training set:

    • Not applicable. The document discusses a physical X-ray device and its control software. There is no mention of a "training set" for an AI or machine learning algorithm. The software development "has been executed as per the requirements of ISO 62304" and undergone "software validation & verification," not machine learning training.

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

    • Not applicable, as there is no training set for an AI/ML algorithm mentioned.
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