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510(k) Data Aggregation

    K Number
    K200999
    Date Cleared
    2021-01-06

    (265 days)

    Product Code
    Regulation Number
    884.2980
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Thermidas Americas, Inc.

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

    The Thermidas IR System is for adjunctive use in addition to other clinical diagnostic procedures for diagnostic imaging for thermally significant indications of all skin regions of the human body. The system is for reviewing and reporting of temperature patterns and changes. The significance of the value of these thermal patterns is determined by professional investigation. The system is not intended for absolute temperature measurements. The Thermidas IR system is intended for use by trained technical personnel.

    Device Description

    The Thermidas IR System consists of an off-the-shelf thermal imaging camera, a mount for the camera and a Windows workstation running the Thermidas Imager software. The Thermidas IR System is a non-invasive medical device which uses infrared radiation naturally emitted by the patient, which senses variations in temperature. The captured data is processed by software producing a quantitative image on the computer screen. The medical professional can use the image to review, analyze, investigate, and quantify the temperature of the objects that are imaged.

    AI/ML Overview

    The Thermidas IR System (ThIR-A615) is a Class I, reserved telethermographic system. Since it is a Class I device, clinical studies were not required and were not performed. Therefore, information regarding acceptance criteria based on clinical performance, sample sizes for test and training sets, expert qualifications, ground truth establishment, adjudication methods, or multi-reader multi-case studies is not available in the provided text.

    The substantial equivalence determination was based on non-clinical performance testing against several international and national standards.

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

    Since clinical performance testing was not required or performed, the "reported device performance" in terms of clinical metrics (e.g., sensitivity, specificity) is not available. The acceptance criteria were met by demonstrating compliance with the following non-clinical testing standards:

    Acceptance Criteria (Standard Compliance)Reported Device Performance (Compliance Statement)
    EN ISO 13485:2016Compliance with this standard for Medical devices - Quality management systems
    EN IS 14971:2012Compliance with this standard for Medical devices - Application of risk management to medical devices
    IEC 62304:2015 (Ed 1.1)Compliance with this standard for Medical device software - Software life cycle processes
    EN 62366-1:2015Compliance with this standard for Medical devices - Application of usability engineering to medical devices
    EN 60601-1:2006+A1:2013Compliance with this standard for Medical electrical equipment - General requirements for basic safety and essential performance
    EN 606001-1-2:2015Compliance with this standard for Medical electrical equipment - Electromagnetic disturbances - Requirements and tests
    IEC 60601-1-2:2014Compliance with this standard for Medical electrical equipment - Electromagnetic disturbances - Requirements and tests
    ANSI/AAMI ES60601-1:2005/(R)2012Compliance with this standard for Medical electrical equipment - General requirements for basic safety and essential performance
    Directive 93/42/EEC on Medical DevicesCompliance with Annex II for infrared imaging devices for medical diagnostic purposes

    Discussion on Device Features Compared to Predicate (Found in the "Predicate Device Comparison" Table):

    While not formal performance metrics, the device's technical specifications and features were compared to the predicate to establish substantial equivalence. These comparisons highlight attributes that contribute to the device's functional performance:

    • Resolution: Both the predicate and proposed device support high resolution (e.g., 640x480). The proposed device explicitly states it uses a "640 x 480 pixel microbolometer that detects temperature differences as small as 50 mK, for accuracy at longer distances."
    • Image Frequency: Both devices offer high image frequency (e.g., 50-60 Hz) for real-time viewing. The proposed device specifies "Stream full-frame 16-bit images at 50 Hz, or in windowed mode as high as 200 Hz, for high-speed processes."
    • Focus: Both offer automatic focus.
    • Connectivity: Both use Gigabit Ethernet.
    • Calibration: Both are factory calibrated.
    • Lens: Both use a 25-degree standard lens.
    • Software Features: Both provide software for capturing, displaying, and analyzing thermal patterns (e.g., patient records, image capture, visualization, ROI analysis, reporting).

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

    • Not Applicable. Clinical studies were not required or performed for this Class I device. The testing involved compliance with non-clinical engineering and quality standards.

    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. Clinical studies were not required or performed. There was no clinical ground truth established for a test set.

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

    • Not Applicable. No clinical test set requiring adjudication was used.

    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. No MRMC study was conducted. The device is a telethermographic system for adjunctive diagnostic imaging, and the provided documentation does not indicate it uses AI for image interpretation or for assisting human readers in a comparative effectiveness study.

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

    • Not Applicable. Clinical studies were not performed. The device is a system for reviewing and reporting temperature patterns, with the interpretation by trained technical personnel. The software itself "makes no determination regarding what the thermal patterns or relative temperature values mean" and "The decision making is not based on the software itself."

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

    • Not Applicable. No clinical ground truth was established as clinical studies were not performed. For the non-clinical testing, compliance with standards served as the "ground truth" for safety and performance according to those standards.

    8. The sample size for the training set

    • Not Applicable. As clinical studies were not performed, there was no clinical training set.

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

    • Not Applicable. As clinical studies were not performed, there was no clinical training set or associated ground truth establishment.
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