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510(k) Data Aggregation
(26 days)
Digital Radiography CXDI-Pro, Digital Radiography D1
The DIGITAL RADIOGRAPHY CXDI-Pro / D1 provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The DIGITAL RADIOGRAPHY CXDI-Pro, also called the DIGITAL RADIOGRAPHY D1, (hereinafter referred to as CXDI-Pro) is a solid-state x-ray imager. The CXDI-Pro is a series of detectors, and in the predicate submission (K221876) consists of the CXDI-703C Wireless and CXDI-403C Wireless detectors, also called the AR-D3543W and AR-D4343W detectors respectively. The detectors intercept x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the signals are converted to digital values. The digital values are sent to the PC via a wired or wireless connection, converted to images with the CXDI Control Software, and then displayed on the PC/monitors. The PC/monitors used with the CXDI-Pro are not a part of this submission. The proposed changes to the predicate device, CXDI-Pro, includes the addition of the new detector, CXDI-803C Wireless (also called the AR-D2735W) to the CXDI-Pro series; a firmware update from 01.01.03.00 to 01.02.00.01; and a CXDI Control Software version update from 3.10.2.2 to 3.10.2.6. The new detector, CXDI-803C Wireless, which differs in pixel count, imaging area, external dimensions, and weight, has the same image performance as the predicate detectors. None of the CXDI-Pro detectors have any dynamic functions (such as fluoroscopy).
Here's a breakdown of the acceptance criteria and study information based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state numerical "acceptance criteria" in the format of a table with thresholds and corresponding performance values. Instead, it focuses on demonstrating substantial equivalence to a predicate device by comparing technological characteristics and ensuring continued conformance with safety and performance standards.
The closest to "reported device performance" are the shared technical specifications and the statement that the new detector has the "same image performance as the predicate detectors."
Characteristic / Standard | Acceptance/Conformance Statement (Implied Criteria) | Reported Device Performance |
---|---|---|
Intended Use | Identical to predicate device: Digital image capture for conventional film/screen radiographic examinations, displaying radiographic images of human anatomy, replacing film/screen systems in all general diagnostic procedures (excluding mammography). | The proposed device's Indications for Use are identical to the predicate device. |
Functional Design | Substantially equivalent to predicate device. | The flat panel detector units are functionally the same, using the same components. The fundamental scientific technology has not been modified. |
Device Components | Primarily identical, with specific modifications in detector model additions and firmware/software updates not impacting safety or effectiveness. | Proposed Device: CXDI-703C, CXDI-803C (NEW), CXDI-403C Wireless detectors. CXDI Control Software V3.10.2.6. Detector Firmware V01.02.00.01. |
Predicate Device: CXDI-703C, CXDI-403C Wireless detectors. CXDI Control Software V3.10.2.2. Detector Firmware V01.01.03.00. (The table lists the predicate as also having CXDI-803C, implying it was part of the earlier submission, but the text states the addition of 803C.) | ||
Image Performance | Same as predicate detectors. | The new detector, CXDI-803C Wireless, has the same image performance as the predicate detectors. |
Safety Standards | Conformance with U.S. Performance Standard for radiographic equipment and relevant voluntary safety standards for Electrical safety and Electromagnetic Compatibility testing (specifically IEC 60601-1, 60601-1-2, 60601-1-6, and 60601-2-54). Changes did not impact conformance and raised no new questions regarding safety or effectiveness. | Evaluation and verification/validation activities successfully demonstrated that the device continues to meet the standards for areas impacted by modifications. |
Cybersecurity | Conformance with "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" guidance. | Not explicitly detailed, but stated as followed for applicable guidance documents. |
Wireless Technology | Conformance with "Radio Frequency Wireless Technology in Medical Devices" guidance. | Not explicitly detailed, but stated as followed for applicable guidance documents. |
Mechanical/Electrical | Conformance with "Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices" guidance. | Not explicitly detailed, but stated as followed for applicable guidance documents. |
2. Sample size used for the test set and the data provenance
The document states: "Adequate detector bench testing should be sufficient to demonstrate that the subject detector. CXDI-Pro, works as intended."
It also mentions "verification/validation activities" which included "detector bench testing."
- Sample Size for Test Set: Not explicitly stated in terms of number of images or cases. The testing appears to be primarily at the component level (detector, firmware, software) through bench testing and conformance to standards, rather than a clinical study with a specific number of patient cases.
- Data Provenance: Not specified, but given the nature of "bench testing" and "conformance with U.S. Performance Standard," it would likely involve laboratory test data and manufactured test images, rather than patient data from specific countries. This is a "Special 510(k) Submission" for modifications, so extensive new clinical data is often not required if substantial equivalence can be demonstrated through non-clinical means.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This was a non-clinical submission focused on technical equivalency, safety, and performance standards. There was no clinical ground truth established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This was a non-clinical submission; no adjudication method for a clinical test set was required or mentioned.
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. The device described is a digital radiography detector system, not an AI-powered diagnostic tool. Therefore, an MRMC comparative effectiveness study regarding human reader improvement with AI assistance is not relevant or reported.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. The device is a hardware component (detector) and associated software/firmware for image acquisition and display, not an algorithm providing a standalone diagnostic output.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not applicable. For this specific submission, the "ground truth" was established against technical specifications, engineering performance metrics (e.g., MTF, DQE), and conformance to internationally recognized safety and performance standards (e.g., IEC 60601 series). There was no clinical ground truth (expert consensus, pathology, outcomes data) as this was a non-clinical submission for device modifications.
8. The sample size for the training set
Not applicable. This device is a diagnostic imaging system component, not a machine learning algorithm that requires a "training set."
9. How the ground truth for the training set was established
Not applicable. There was no training set for a machine learning algorithm.
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(17 days)
Digital Radiography CXDI-Pro, Digital Radiography D1
The DIGITAL RADIOGRAPHY CXDI-Pro / D1 provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The DIGITAL RADIOGRAPHY CXDI-Pro, also called the DIGITAL RADIOGRAPHY D1, (hereinafter referred to as CXDI-Pro) is a solid-state x-ray imager. The CXDI-Pro is a series of detectors, and in the predicate device (K220098) consists of the CXDI-703C Wireless and CXDI-403C Wireless detectors, also called the AR-D3543W and AR-D4343W detectors respectively. The detectors intercept x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the signals are converted to digital values The digital values are sent to the PC via a wired or wireless connection, converted to images with the CXDI Control Software, and then displayed on the PC/monitors The PC/monitors used with the CXDI-Pro are not a part of this submission.
The subject of this Special 510(k) submission is a change to the predicate device, including compatibility with the Multi Box and Status Indicator, DIGITAL RADIOGRAPHY CXDI-Elite components that were cleared under K213780. The Status Indicator can be used when the proposed device is used in combination with the Multi Box. In addition, the CXDI Control Software has been updated from V3.10.0.8 to V3.10.2.2 to fix some bugs. Together, these changes make up the CXDI-Pro.
Based on the provided text, the device in question, DIGITAL RADIOGRAPHY CXDI-Pro / D1, is a digital radiography system, and the submission (K221876) is a Special 510(k). This means the submission focuses on modifications to an already cleared predicate device (K220098) rather than a completely new device. Therefore, the clinical testing section is deemed "not necessary" due to "minor differences from the predicate device."
This significantly limits the type of performance study and acceptance criteria information available. Special 510(k) submissions typically rely heavily on non-clinical bench testing and verification/validation activities to demonstrate that changes do not adversely affect safety or effectiveness, rather than large-scale clinical trials measuring diagnostic accuracy.
Here's an analysis based on the constraint that "clinical testing is not necessary" for this specific submission:
1. A table of acceptance criteria and the reported device performance:
Since clinical testing was not performed for this submission, there are no acceptance criteria related to diagnostic accuracy or human-in-the-loop performance. The acceptance criteria and performance reported are focused on demonstrating that the modifications (addition of Multi Box and Status Indicator, software update, and firmware update) do not negatively impact the fundamental scientific technology and existing safety/performance standards of the predicate device.
Acceptance Criteria Category | Specific Acceptance Criteria (from text) | Reported Device Performance / Evaluation (from text) |
---|---|---|
Safety & Electrical Performance | Conformance with U.S. Performance Standard for radiographic equipment. | Evaluation confirmed changes did not impact conformance. |
Conformance with relevant voluntary safety standards for Electrical safety (IEC 60601-1). | Evaluation confirmed changes did not impact conformance. | |
Electromagnetic Compatibility (EMC) | Conformance with relevant voluntary safety standards for Electromagnetic Compatibility (IEC 60601-1-2). | Evaluation confirmed changes did not impact conformance. |
Usability / Software Lifecycle | Conformance with IEC 60601-1-6 (Usability). (Implied by software update context) | Verification/validation activities demonstrated the device continues to meet standards. |
X-ray Imaging Equipment | Conformance with IEC 60601-2-54 (X-ray equipment for radiography and radioscopy). | Evaluation confirmed changes did not impact conformance. |
Software Functionality | CXDI Control Software V3.10.2.2 fixes previous bugs (from V3.10.0.8). | Verification/validation activities demonstrated the CXDI-Pro works as intended with the updated software. |
Bio-compatibility | Conformance with ISO 10993-1 for biological evaluation. | Follows applicable elements of ISO 10993-1. |
Overall Equivalence | No new questions regarding safety or effectiveness compared to the predicate device. | Verification/validation activities support a determination of substantial equivalence. |
2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
The document explicitly states: "Clinical testing is not necessary for the current submission, based on the minor differences from the predicate device. Adequate verification and validation activities should be sufficient to demonstrate that the CXDI-Pro works as intended."
Therefore, there is no human patient "test set" or related sample size or data provenance information. The "test set" here refers to the bench tests and engineering validations performed on the device and its components to ensure compliance with the mentioned technical standards and functionality.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable, as human clinical evaluation or ground truth adjudication by experts (e.g., radiologists) for diagnostic performance was not part of this "Special 510(k)" submission. The "ground truth" for the non-clinical tests would be established through engineering specifications, calibration standards, and regulatory requirements.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable, as there was no test set requiring human expert adjudication for diagnostic performance.
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 study was done. This device is a digital radiography system; the submission focuses on hardware and software updates to the imaging system itself, not an AI feature that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
No standalone performance evaluation of a diagnostic algorithm was done. This is a review of a general-purpose digital X-ray system, not an AI diagnostic algorithm. The software update mentioned is for the CXDI Control Software, which governs the imaging process and display, not for an AI interpretation algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for this submission's evaluation is based on engineering specifications, regulatory standards (e.g., IEC 60601 series, U.S. Performance Standard for radiographic equipment), and the performance characteristics of the predicate device. It's not clinical ground truth (like pathology or patient outcomes) because clinical testing was not required.
8. The sample size for the training set:
Not applicable. This submission is for modifications to a general radiography system, not for an AI algorithm. There is no "training set" in the context of machine learning.
9. How the ground truth for the training set was established:
Not applicable, as there is no training set for an AI algorithm.
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(23 days)
Digital Radiography CXDI-Pro, Digital Radiography D1
The DIGITAL RADIOGRAPHY CXDI-Pro / D1 provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The DIGITAL RADIOGRAPHY CXDI-Pro, also called the DIGITAL RADIOGRAPHY D1, (hereinafter referred to as CXDI-Pro) is a solid-state x-ray imager. The CXDI-Pro is a series of detectors, and in the predicate device consists of the CXDI-703C Wireless detector unit, also called the AR-D3543W detector. The detector intercepts x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the signals are converted to digital values, and the images will be displayed on monitors. The digital image can be communicated to the operator console via a wired or wireless connection.
The subject of this Special 510(k) submission is a change to the CXDI-Pro add a detector, the CXDI-403C Wireless (also called AR-D4343W) to the CXDI-Pro series of detectors. In addition, a Detector Stand (DS-01) and a new Battery Charger (BC-01) have been added as optional components to be used with the proposed CXDI-Pro detectors (CXDI-703C Wireless and CXDI-403C Wireless), the sleep to ready cycle time for the proposed CXDI-Pro detectors has been decreased, and the CXDI Contro Software has been updated from V3.10.0.3 to V3.10.0.8 to add the Intelligent NR function (cleared under K212269) and apply some bug fixes. Together, these changes make up the CXDI-Pro.
Here's a breakdown of the acceptance criteria and study information for the Canon Inc. Digital Radiography CXDI-Pro / D1, based on the provided FDA 510(k) summary:
This submission (K220098) is a Special 510(k) submission, which indicates that the changes made to the device (new detector, accessories, reduced cycle time, software update) did not fundamentally alter its intended use or fundamental scientific technology. Therefore, the primary focus of the performance evaluation is to ensure that these changes do not negatively impact the device's conformance with relevant standards and do not raise new questions of safety or effectiveness.
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a Special 510(k) for modifications to an already cleared device, the "acceptance criteria" are primarily related to maintaining conformance with existing performance and safety standards, rather than establishing new clinical performance targets. The reported device performance confirms that these standards are still met.
Acceptance Criteria (related to modified aspects) | Reported Device Performance |
---|---|
Maintain conformance with U.S. Performance Standard for radiographic equipment. | Evaluation of the addition of the new detector (CXDI-403C Wireless) and optional accessories (Detector Stand, Battery Charger) confirmed that the changes did not impact CXDI-Pro conformance with this standard. |
Maintain conformance with relevant voluntary safety standards for Electrical safety and Electromagnetic Compatibility (EMC), specifically IEC 60601-1, 60601-1-2, 60601-2-54, 60601-1-6, and IEC 60529. | Verification/validation activities successfully demonstrated that the device continues to meet these standards. |
Ensure the reduction in "Sleep to Ready Cycle Time" (from 7 sec to less than 5 sec) does not compromise safety or effectiveness. | Implied: The successful verification/validation activities encompass this change, indicating it does not raise new questions of safety or effectiveness. (Specific performance data for this change beyond the stated time is not detailed, but its successful integration into the system meeting overall standards implies acceptance.) |
Ensure the software update (V3.10.0.3 to V3.10.0.8, including Intelligent NR function K212269) and firmware update (01.00.00.03 to 01.00.02.00) do not compromise safety or effectiveness. | Implied: The software update to incorporate an already cleared feature (Intelligent NR, K212269) and bug fixes, along with the firmware update, were part of the verification/validation activities that demonstrated the device continues to meet standards and raises no new questions regarding safety or effectiveness. (Specific performance data for the software/firmware changes beyond their successful integration and bug fixes are not detailed in this summary.) |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a "test set sample size" in terms of patient images or clinical cases. The performance evaluation is described as "Verification/validation activities" which focused on technical performance and safety standards. This suggests that the testing involved:
- Engineering tests on the physical components (new detector, accessories).
- Software testing for the updated control software and firmware.
- Electromagnetic compatibility (EMC) testing.
- Electrical safety testing.
The data provenance is industrial and engineering testing, rather than clinical data from specific countries or retrospective/prospective studies.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of those Experts
Not applicable in the context of this Special 510(k). Ground truth for clinical diagnostic performance (e.g., presence/absence of disease) is not the focus of this submission. The "ground truth" here is adherence to engineering specifications and safety standards, which would be assessed by engineers and quality control personnel.
4. Adjudication Method for the Test Set
Not applicable. This is not a study requiring reader adjudication of clinical findings.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. This type of study is typically performed to demonstrate the clinical performance of a diagnostic aid, which is not the scope of this Special 510(k) submission focused on hardware/software modifications and maintaining safety/performance standards.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
The document primarily describes the performance of the overall digital radiography system, which includes the detector and control software. While the software update includes an "Intelligent NR function" (cleared under K212269), this submission's performance evaluation focuses on the integrated system's safety and continued conformance, not a standalone algorithm's diagnostic performance. Its effectiveness would have been established in the K212269 submission.
7. The Type of Ground Truth Used
The ground truth used for these verification and validation activities is based on:
- Engineering specifications (for the new detector, cycle time, accessories).
- International standards (IEC 60601-1, 60601-1-2, 60601-2-54, 60601-1-6, IEC 60529).
- U.S. Performance Standard for radiographic equipment.
- Software testing protocols to verify bug fixes and the integration of the Intelligent NR function without introducing new issues.
8. The Sample Size for the Training Set
Not applicable. This submission does not describe a machine learning model being developed or trained on a dataset. The software update includes an "Intelligent NR function" which would have involved a training set in its original K212269 submission, but that information is not provided here.
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no training set described in this submission.
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