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510(k) Data Aggregation

    K Number
    K203551
    Date Cleared
    2020-12-18

    (14 days)

    Product Code
    Regulation Number
    892.1650
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Alphenix, INFX-8000V/B, /S, V9.1

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

    This device is a digital radiography/fluoroscopy system used in a diagnostic and interventional angiography configuration. The system is indicate for use in diagnostic and angiographic procedures for blood vessels in the heart, brain, abdomen and lower extremities.

    Device Description

    The Alphenix, INFX-8000V/B, /S V9.1, is an X-ray system that is capable of radiographic and fluoroscopic studies and is used in an interventional setting. The system consists of a C-arm/Omega-arm which is equipped with an X-ray tube, beam limiter and X-ray receptor, X-ray controller, computers with system and processing software, and a patient radiographic table.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a de novo study with specific clinical acceptance criteria. Therefore, the document does not contain the detailed information requested for a study proving device acceptance criteria in the typical sense of a clinical trial for a new product.

    However, based on the information provided, here's what can be extracted and inferred regarding the device's assessment:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission is for modifications to a previously cleared device, focusing on maintaining or improving performance compared to the predicate. The "acceptance criteria" are primarily related to safety, effectiveness, and substantial equivalence to the predicate.

    Acceptance Criteria (Inferred from 510(k))Reported Device Performance (as stated in the document)
    Safety: Conformity to applicable safety standards and mitigation of risks.The device is designed and manufactured under the Quality System Regulations (21 CFR § 820, ISO 13485). Conforms to IEC60601-1, IEC 60601-2-43, IEC60601-2-28, and other specified standards. Risk analysis and verification/validation testing conducted through bench testing demonstrated established specifications for the device have been met. All known risks were mitigated.
    Effectiveness: Performance equal to or better than the predicate system, especially regarding image quality, usability, and dose optimization."This submission contains test data that demonstrates that the system modifications result in performance that is equal to or better than the predicate system." Specifically mentions:V9.1 Software: improved usabilityAlphaCT IQ improvement2D IQ ImprovementDose optimization for DSA and spot fluoroscopyUsability/Operability improvement
    Substantial Equivalence: No new indications for use or intended use, similar performance to predicate.The device "performs in a manner similar to and is intended for the same use as the predicate device." "The modifications incorporated do not change the indications for use or the intended use of the device." "It is concluded that the subject device is substantially equivalent in safety and effectiveness to the predicate device."
    Compliance with Federal Regulations: Adherence to all relevant FDA regulations.Conforms to applicable Performance Standards for Ionizing Radiation Emitting Products [21 CFR Subchapter J, Federal Diagnostic X-ray Equipment Standard]. Followed FDA guidance for software documentation for a Moderate Level of Concern.

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

    The document explicitly states: "Clinical images were deemed not necessary for the aforementioned improvements via design control and risk management activities."

    Therefore, a "test set" in the sense of clinical patient data with specific sample sizes for this submission is not applicable. The testing primarily involved bench testing and phantom testing. The provenance of such phantom test data is not specified (e.g., country of origin), but it would typically be internal to the manufacturer. The data is retrospective in the sense that it's generated for the submission based on the modified device's performance.

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

    Since clinical images were not used and the testing focused on technical performance via bench and phantom tests, there were no external experts establishing ground truth in the context of clinical diagnoses or interpretations for a "test set" of patient data. The "ground truth" for these engineering and phantom tests would be established by the device's technical specifications and engineering requirements, verified by the manufacturer's qualified personnel.

    4. Adjudication Method for the Test Set

    Not applicable, as a clinical test set requiring adjudication was not used.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC comparative effectiveness study was not done. The document states: "Clinical images were deemed not necessary for the aforementioned improvements."

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

    The device is an interventional fluoroscopic X-ray system, not primarily an AI algorithm. While software improvements are noted, the "standalone" performance here refers to the system as a whole, including its imaging capabilities. The testing mentioned ("bench testing" and "phantom testing") represents the standalone performance of the modified system.

    7. The Type of Ground Truth Used

    For the technical and phantom testing performed, the "ground truth" was based on:

    • Engineering specifications and design requirements: For safety, performance parameters, and compliance with standards.
    • Physical properties of phantoms: For evaluating image metrics (e.g., AlphaCT IQ improvement, 2D IQ Improvement).
    • Predicate device's established performance: As the basis for comparison to demonstrate "equal to or better" performance.

    8. The Sample Size for the Training Set

    Not applicable. The device is not an AI algorithm that undergoes "training" on a dataset in the machine learning sense to develop its primary function. The software changes are described as functional improvements, usability enhancements, and operating system updates, not as a deep learning model trained on a specific dataset.

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

    Not applicable, as there was no explicit "training set" in the context of machine learning.

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