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510(k) Data Aggregation

    K Number
    K162585
    Date Cleared
    2016-11-04

    (49 days)

    Product Code
    Regulation Number
    872.1800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Suni Medical Imaging, Inc

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

    The SunilQ Digital Radiography system is used to collect dental x-ray photons and convert them into electronic impulses that may be stored, viewed and manipulated for diagnostic use by dentists.

    Device Description

    The SuniIQ Digital Radiography System reduces x-ray exposure by producing real time digital intra-oral images. The System accomplishes this by replacing X-ray film with a reusable electronic sensor that captures the X-ray photons and converts them to an electronic signal which, in turn, is captured in a computer for viewing, manipulating, storing, and output.

    AI/ML Overview

    The acceptance criteria and study information for the SuniIQ Digital Radiography System are outlined below:

    1. Acceptance Criteria and Reported Device Performance

    The document does not explicitly state numerical acceptance criteria for specific performance metrics. However, it indicates a general acceptance criterion that the device must be "as safe, as effective, and performs as well as or better than the predicate device."

    Tested FunctionAcceptance Criteria (Implied)Reported Device Performance
    Relative errorMust meet functional requirements; comparable to predicate.Pass
    X-Ray SaturationMust meet functional requirements; comparable to predicate.Pass
    Image sizeMust meet functional requirements; comparable to predicate.Pass
    Image orientationMust meet functional requirements; comparable to predicate.Pass
    Set up time, USB current, and clock patternMust meet functional requirements; comparable to predicate.Pass
    Dose loss and focus to detector distance (FDD)Must meet functional requirements; comparable to predicate.Pass
    Saturation ComparisonMust meet functional requirements; comparable to predicate.Pass
    Printed Circuit Board (PCB)Must meet functional requirements; comparable to predicate.Pass
    Software Development Kit (SDK)Must meet functional requirements; comparable to predicate.Pass
    Time to ready for exposure stateMust meet functional requirements; comparable to predicate.Pass
    Test Pattern ImagesMust meet functional requirements; comparable to predicate.Pass
    Dental Phantom ImagesMust meet functional requirements; comparable to predicate.Pass
    Other Operating systemsMust meet functional requirements; comparable to predicate.Pass
    Software Verification & ValidationOperate as specified, meeting IEC 62304 standards and FDA guidances.All features verified to operate as specified. All test passing criteria met.
    BiocompatibilityMeet ISO 10993-1:2009 and FDA draft guidance.Met requirements.
    DisinfectionRecommended cleaning method confirmed.Confirmed.
    Electromagnetic Compatibility and Electrical SafetyMeet IEC 60601-1:2005 and ANSI/AAMI ES60601-1:2005 for safety, IEC 60601-1-2:2007 for EMC.Met requirements.

    The study concludes that "Testing confirms that the SuniIQ System is as safe, as effective, and performs as well as or better than the predicate device," and that "The identified technological differences between the subject and predicate devices were assessed through bench performance testing data and software V&V testing to demonstrate that they are substantially equivalent."

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

    The document does not specify a distinct "test set" in terms of patient data. The testing described focuses on bench testing and software verification and validation (V&V).

    • Bench Testing: The "tested functions" listed cover various technical aspects of the device, likely using controlled laboratory conditions and specific testing protocols (e.g., test pattern images, dental phantom images). The sample sizes for these tests are not explicitly stated, but are implied to be sufficient for verifying the functional requirements.
    • Data Provenance: The document does not refer to clinical data or country of origin for a test set. The validation is primarily technical.

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

    No information is provided regarding experts establishing ground truth for a clinical "test set," as the device's performance was evaluated through bench testing and software V&V, not a clinical study involving diagnostic interpretations by experts.

    4. Adjudication Method for the Test Set

    Not applicable, as no clinical test set requiring expert adjudication is described in the document.

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

    No MRMC comparative effectiveness study is mentioned. The document primarily focuses on demonstrating substantial equivalence through technical performance comparisons with a predicate device, rather than assessing human reader improvement with AI assistance. The device is a "digital radiography system," which captures images; it is not presented as an AI-powered diagnostic aide.

    6. Standalone (Algorithm Only) Performance Study

    The document describes the performance of the "SuniIQ Digital Radiography System" itself, which is a hardware and software system for capturing and displaying dental x-ray images. The "software components" within the SuniIQ handle sensor control, data transfer, and include an "optional filter algorithm" for image correction. The performance reported in the "Bench Testing" and "Software V&V" sections can be considered the standalone performance of this system, demonstrating its ability to acquire and process images. There is no mention of a separate "AI algorithm" being evaluated independently.

    7. Type of Ground Truth Used

    The ground truth for the evaluations conducted was primarily based on:

    • Functional Requirements/Specifications: The device's performance was compared against defined functional requirements for items like relative error, X-ray saturation, image size, etc.
    • Predicate Device Performance: Direct comparison to the performance of the predicate SuniRay II System (K070219) was used as a benchmark for many functional tests.
    • Industry Standards: Compliance with standards like IEC 62304 for software, ISO 10993-1 for biocompatibility, IEC 60601-1 for safety, and IEC 60601-1-2 for EMC served as ground truth for regulatory and quality aspects.
    • Test Pattern Images and Dental Phantom Images: These are controlled inputs with known characteristics, used to assess image quality and system response under controlled conditions.

    There is no mention of pathology, expert consensus on clinical findings, or outcomes data being used as ground truth.

    8. Sample Size for the Training Set

    The document does not mention a "training set." The device is a digital radiography system, not a machine learning or AI algorithm in the context of typical AI device approvals that involve training datasets. The "software components" are described as drivers, control software, and an optional filter algorithm, implying traditional software development and verification rather than machine learning training.

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

    Not applicable, as no training set is mentioned or implied for this device.

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    K Number
    K083917
    Date Cleared
    2009-06-02

    (154 days)

    Product Code
    Regulation Number
    892.1750
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SUNI MEDICAL IMAGING, INC.

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

    The Suni3D is a computed tomography x-ray system, which is a diagnostic x-ray system intended to produce panoramic, cephalometric, and cross-sectional images for dental examination and diagnosis of diseases of the teeth, jaw and oral structures by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles.

    Device Description

    Not Found

    AI/ML Overview

    I am sorry, but the provided text does not contain information about the acceptance criteria and the study that proves the device meets the acceptance criteria. The document is an FDA 510(k) clearance letter for the Suni3D computed tomography x-ray system, confirming its substantial equivalence to a predicate device. It specifies the intended use and regulatory information but does not detail performance metrics, study designs, or ground truth establishment.

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    K Number
    K070219
    Date Cleared
    2007-02-07

    (15 days)

    Product Code
    Regulation Number
    872.1800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SUNI MEDICAL IMAGING, INC.

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

    The SuniRay II Digital Radiography System is used to collect dental x-ray photons and convert them into electronic impulses that may be stored, viewed, and manipulated for diagnostic use by dentists.

    Device Description

    The Suni SuniRay II Digital Radiography System ("System") will produce real time digital intra-oral images with a reduction in X-ray dosages as compared to film. The System accomplishes this by replacing X-ray film with an electronic sensor that captures the X-ray photons and converts the photons to an electronic signal which in turn is captured in a computer for viewing, manipulating, storing, and outputting (printing or Email).

    The System consists of two sensor versions (designated as #1 & #2 sizes; equivalent to dental film sizes), an attached USB electronics box that controls the sensor and interfaces to the computer USB port. The System also includes software drivers that control the USB electronics box, and a Graphical User Interface (GUI) that allows the user access to the data and control functions of the System.

    The GUI used with the device was designed by Apteryx, Inc. who holds 510(k) K983111 for their product. Apteryx is responsible for both product validation and GMP compliance. The SuniRay II System software utilizes the Windows XP environment.

    The System sensors are in two formats. The #2 size is a larger sensor typical of the European format and the # 1 size is an intermediate size. The sensors consist of a CMOS type integrated circuit, and a high resolution scintillator screen that converts the photons from the X-rays into visible light, which is then acquired by the CMOS imaging integrated circuit. The sensors are encapsulated with a three-foot cable that is connected to the USB electronics box.

    The USB electronics box plugs into a computer USB port via a supplied USB cable. The USB electronics box contains the support and control circuitry for the sensor and allows for data communications with the computer. The USB electronics box contains all necessary circuits for sensor data acquisition as well as memory for firmware control of the CMOS X-ray sensor and USB. The USB electronics box communicates with the computer under control of a specific device driver that is active with the GUI.

    The System software functions on three levels: (1) The computer operating system (Microsoft Windows) controls the computer, user interface, and file structure; (2) Primary control of the sensor and bus functions is achieved by proprietary software and is either embedded firmware or in non user accessible drivers; and (3) A Graphical User Interface (GUI) allows the user to control the x-ray function, control of the sensor data acquisition, and image viewing, manipulation and output. Examples of the GUI include image capture, enhanced viewing features (zoom, pan, colorize, contrast/brightness, comparative analysis, etc) image organization, and storage.

    AI/ML Overview

    This report does not contain the information required to fulfill your request. The document is a 510(k) summary for the SuniRay II Digital Radiography System, primarily focused on demonstrating substantial equivalence to a predicate device.

    Specifically, it lacks the following crucial information:

    • Acceptance criteria and reported device performance
    • Details about any study conducted to prove the device meets acceptance criteria. This includes:
      • Sample size used for the test set
      • Data provenance
      • Number of experts and their qualifications for ground truth establishment
      • Adjudication method
      • Information about multi-reader multi-case (MRMC) comparative effectiveness studies
      • Information about standalone performance studies
      • Type of ground truth used
      • Sample size for the training set
      • How ground truth for the training set was established

    The document describes the device's function and components, its software, and its compliance with safety and electromagnetic compatibility standards (EN 60601). It also references Apteryx, Inc.'s 510(k) (K983111) for their GUI and states that Apteryx is responsible for product validation and GMP compliance. However, it does not provide details of any clinical or technical performance studies that would include acceptance criteria or specific performance metrics.

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    K Number
    K060149
    Date Cleared
    2006-02-03

    (14 days)

    Product Code
    Regulation Number
    872.1800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SUNI MEDICAL IMAGING, INC.

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

    For diagnostic radiographic use in dental, oral surgery, and orthodontic practices.

    Device Description

    Axial rotation x-ray source (PC-1000). The PC-1000 panoramic X-ray machine portion of the Sunipan Imaging System generates the required ionizing radiation (x-rays) This unit is identical to the PC-1000 model supplied directly by Panoramic Corporation for use with standard x-ray film. The Sunipan Imaging System combines this base x-ray unit with an available aftermarket digital imaging sensor, creating a filmless digital imaging system.

    Digital Image Sensor (Scan300fp/Retropan) is a high speed x-ray camera tailored for dental panographic applications. Originally designed and cleared for retro-conversion of existing standard panographic x-ray units. The sensor system utilizes direct conversion technology which offers a number of benefits over CCD technology. The images obtained may be reviewed and adjusted after exposure to focus on different layers or areas of clinical it rest.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the SuniPan Imaging System. This type of regulatory submission primarily focuses on demonstrating substantial equivalence to a predicate device rather than presenting extensive de novo clinical study data with detailed acceptance criteria and performance metrics typically seen for novel devices or AI/ML-based systems.

    Therefore, the document does not contain the detailed information requested regarding acceptance criteria, specific device performance against those criteria, ground truth establishment, sample sizes for training/test sets, expert qualifications, or MRMC studies.

    Here's a breakdown of why the requested information isn't available in the provided text:

    • Premarket Notification (510(k)) Context: A 510(k) submission aims to prove that a new device is "substantially equivalent" to a legally marketed predicate device. This typically involves comparing design, materials, indications for use, and performance claims to the predicate. It usually doesn't require new clinical efficacy studies of the same rigor or depth as a PMA (Premarket Approval) submission, especially for established technologies like X-ray imaging.

    • Device Type: The SuniPan is a digital imaging device that combines an existing X-ray unit (PC-1000, identical to a film-based unit) with an aftermarket digital sensor (Scan300fp/Retropan). The digital sensor itself was previously cleared. The focus here is on the combination being equivalent to other digital panoramic systems.

    • Absence of Clinical Study Section: The document is primarily administrative and descriptive, listing device details, classification, equivalency claims, and the FDA's clearance letter. It lacks a dedicated "Clinical Study" or "Performance Data" section with detailed methodologies.

    Based on the provided text, I cannot complete the table or answer the specific questions about acceptance criteria and study details. The document indicates the device meets the regulatory requirements for "substantial equivalence" based on comparison to predicate devices, but it does not describe a study with explicit acceptance criteria for performance as would be expected for a novel diagnostic instrument.

    However, I can extract what is available regarding "equivalency" which serves as the basis for marketing clearance:


    1. Table of "Acceptance Criteria" (Implied by Substantial Equivalence) and Reported Device Performance

    Feature/Criterion (Implied by 510(k) Equivalency)Reported Device Performance (Summary from Document)
    Premarket Notification GoalSubstantial Equivalence: Suni Medical Imaging, Inc. believes the SuniPan Imaging System is substantially equivalent to legally marketed predicate devices (K051664 Scan300fp/Retropan and K043557 PC 1000). The FDA concurred with this determination, allowing the device to be marketed.
    Place of ManufactureEquivalent to predicate devices.
    Physical AppearanceEquivalent to predicate devices.
    Functional TestingEquivalent to predicate devices. (Details of this testing are not provided in the excerpt.) The PC-1000 panoramic X-ray machine portion is identical to a unit supplied by Panoramic Corporation for use with standard x-ray film. The digital image sensor (Scan300fp/Retropan) is a high-speed x-ray camera tailored for dental panographic applications, originally designed and cleared for retro-conversion. It uses direct conversion technology. Images can be reviewed and adjusted after exposure to focus on different layers or areas of clinical interest.
    Material CertificationEquivalent to predicate devices.
    Instructions for UseEquivalent to predicate devices.
    Indications for UseSubstantially equivalent to predicate devices: "For diagnostic radiographic use in dental, oral surgery, and orthodontic practices." (This indication was formally cleared by the FDA). The system generates required ionizing radiation (x-rays) and combines a base x-ray unit with an aftermarket digital imaging sensor to create a filmless digital imaging system.
    Patient Safety (Radiation Control)The device meets general controls provisions of the Act, including, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act): 21 CFR 1000-1050. (Implied compliance rather than specific performance metrics against acceptance criteria for radiation dose, etc.).

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

    • Not explicitly stated in the document. The 510(k) process typically relies on bench testing, comparison to predicate device specifications, and sometimes limited clinical data, but the specifics are not detailed here.

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

    • Not explicitly stated. Given it's a 510(k) for an established imaging technology, expert review for image quality or substantial equivalence might have been performed, but the document does not detail this.

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

    • Not explicitly stated.

    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. This is not an AI/ML device, nor is it a multi-reader multi-case study as described in the document. The device is a standard digital X-ray imaging system.

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

    • No. This is not an AI/ML diagnostic algorithm. It is a digital imaging acquisition system.

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

    • Not explicitly stated. For an imaging system, "ground truth" (if established for performance testing) would typically relate to the accuracy of imaging features against known physical standards or clinical outcomes. However, the document relies on its substantial equivalence to previously cleared devices.

    8. The sample size for the training set:

    • Not applicable as this is not a machine learning/AI device requiring a "training set."

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

    • Not applicable.
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