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510(k) Data Aggregation
(23 days)
DuraDiagnost
The DuraDiagnost is intended for use in generating radiographic images of human anatomy by qualified/trained doctor or technician. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. This device is not intended for mammographic applications.
The DuraDiagnost is a flexible digital radiography (DR) system that is designed to provide fast and smooth radiography examinations of sitting, standing or lying patients.
The DuraDiagnost consist of the following components: Tube column with X-ray assembly, wall stand with detector carrier, patient table with detector carrier and floating table top, high voltage generator, and acquisition and reviewing workstation for post-processing, storage and viewing of images. Images may be transferred via a DICOM network for printing, storage and detailed review.
The provided text describes a 510(k) premarket notification for the Philips DuraDiagnost, an X-ray system. The submission focuses on demonstrating substantial equivalence to a predicate device (DuraDiagnost K141381), rather than proving the performance of a novel AI algorithm. Therefore, many of the requested details, such as acceptance criteria for AI performance metrics, sample sizes for test sets, expert adjudication methods for AI ground truth, MRMC studies, standalone AI performance, and AI training set details, are not applicable to this submission.
The document primarily evaluates the DuraDiagnost against safety and effectiveness standards applicable to X-ray systems and its equivalence to a previous version of the device.
Here's the information that can be extracted, and an explanation of why other requested information is not present:
1. A table of acceptance criteria and the reported device performance
The document does not provide specific quantitative acceptance criteria for image quality or clinical performance metrics in a readily extractable table format for human or AI performance. Instead, it states that the device meets acceptance criteria by:
- Complying with international and FDA-recognized consensus standards.
- Demonstrating substantial equivalence to its predicate device in terms of design, technology, indications for use, safety, and effectiveness.
The "performance" is reported as compliance with the following standards and internal tests:
Acceptance Criteria (Demonstrated via) | Reported Device Performance |
---|---|
Compliance with Consensus Standards | - AAMI / ANSI ES60601-1: 2005/(R)2012 and . C1:2009/(R)2012 and, A2:2010/(R)2012 (consolidated text) Medical electrical equipment -Part 1: General requirements for basic safety and essential performance. (Edition 3.1). |
- IEC 60601-1-2 (Edition 4.0 2014): Electromagnetic Disturbances | |
- IEC 60601-1-3 (Edition 2.1 2013): Radiation Protection in Diagnostic X-Ray Equipment | |
- IEC 60601-2-28 (Edition 2.0 2010-03): X-ray tube assemblies for medical diagnosis | |
- IEC 60601-2-54 (Edition 1.1 2015): X-Ray Equipment for Radiography and Radioscopy | |
- IEC 60601-1-6 (Edition 3.1 2013): Usability | |
- IEC 62304 (Edition 1.1 2015): Medical device software (Software life cycle processes) | |
- IEC 62366-1 (Edition 1.0 2015): Application of usability engineering to medical devices | |
- ISO 14971 (Edition 2.0, corrected version, 2007): Application of risk management to medical devices | |
- CFR 1020.30: Diagnostic x-ray systems and their major components | |
- CFR 1020.31: Radiographic equipment | |
- FDA Guidance: "Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices - September 1, 2016" | |
- FDA Guidance: "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices - May 11, 2005." | |
- FDA Guidance: "Guidance for Industry and FDA Staff - Content of Premarket Submissions for Management of Cybersecurity in Medical Devices", issued October 2, 2014 | |
- FDA Guidance: "Pediatric Information for X-ray Imaging Device Premarket Notifications," issued November 28, 2017 | |
Verification/Validation Tests (Non-clinical) | - Tests performed with regards to intended use, technical claims, requirement specifications, and risk management results. |
Substantial Equivalence to Predicate Device (K141381) | - The DuraDiagnost, including its wireless portable detector (SkyPlate E) and fixed RAD detector (Pixium 4343RCE), and the UNIQUE 2 Post Processing software, are found to be substantially equivalent to components and functionalities of legally marketed predicate devices and reference devices. Minor differences in technical characteristics (e.g., image area, image matrix, pixel size, operating system) are stated not to affect safety or effectiveness. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document as it is a 510(k) submission based on comparison to a predicate device and compliance with general safety and performance standards for X-ray systems, not specific clinical performance studies with AI. The non-clinical verification/validation tests performed would typically use test phantoms or specific equipment testing, not a "test set" of patient data in the way an AI algorithm would.
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)
This is not applicable as the submission is not for an AI algorithm requiring clinical ground truth established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable.
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
This is not applicable. The device is an X-ray system, not an AI-powered diagnostic aide. The document explicitly states: "The DuraDiagnost does not require clinical study since substantial equivalence to the primary currently marketed and predicate device was demonstrated..." (Page 15).
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device includes image processing software (UNIQUE 2 and SkyFlow), listed as comparable or updated versions of software present in predicate/reference devices, but it is not presented as a standalone AI diagnostic algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
This is not applicable in the context of an AI study. The "ground truth" for this submission refers to the established safety standards and the performance characteristics of the predicate device, against which the new device (DuraDiagnost) is compared. Compliance with engineering standards and performance specifications (e.g., tube voltage, focal spot size, image matrix, pixel size) serves as the "ground truth" for the device's equivalent performance to what is already on the market.
8. The sample size for the training set
This is not applicable. The document does not describe the development or training of a new AI algorithm.
9. How the ground truth for the training set was established
This is not applicable.
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(16 days)
DURADIAGNOST
The DuraDiagnost is intended for use in generating radiographic images of human anatomy by qualified/trained doctor or technician. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. This device is not intended for mammographic applications.
The Philips DuraDiagnost Digital Diagnostic Radiographic System (DuraDiagnost) is a flexible digital radiography (DR) system that is designed to provide fast and smooth radiography examinations of sitting, standing or lying patients. The Philips DuraDiagnost consist of the following components: Tube column with X-ray assembly, wall stand with detector carrier, patient table with detector carrier and floating table top, high voltage generator, and acquisition and reviewing workstation for post-processing, storage and viewing of images. Images may be transferred via a DICOM network for printing, storage and detailed review.
Here's a breakdown of the acceptance criteria and the study information for the Philips DuraDiagnost, based on the provided 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices rather than setting specific performance acceptance criteria for the new device as would be found in a clinical trial protocol. Instead, the "acceptance criteria" here relate to the device meeting recognized standards and exhibiting technical characteristics similar to its predicates.
Feature / Standard | Acceptance Criteria (Implied) | Reported Device Performance (Philips DuraDiagnost) |
---|---|---|
Technical Design Characteristics | (Demonstrated similar construction and fundamental scientific technology to predicate devices for components like X-ray tube, generator, wall stand, patient table, detector, and workstation. See comparison features below.) | |
Tube Design | Identical to Philips BuckyVision (RO 1750 & SRO 33100) | RO 1750 & SRO 33100 |
Max Tube Voltage | Identical to predicate devices (150kV) | 150kV |
Focal Spot Size | Identical to predicate devices (0.6mm/1.2mm) | 0.6mm/1.2mm |
Tube Max Power | Identical to Philips BuckyVision (50KW/100KW) | 50KW/100KW |
Anode Type | Identical to predicate devices (Rotation) | Rotation |
Generator Max Power | Identical to Philips BuckyVision (50KW/65KW/80KW) | Identical to Philips BuckyVision (50KW/65KW/80KW) |
Generator kV Range | Identical to predicate devices (40-150) | 40-150 |
Generator mAs Product | Identical to Philips BuckyVision (0.5 mAs-600 mAs with AEC control) | 0.5 mAs-600 mAs (with AEC control) |
Collimator Operation | Manual collimation, same as GE Brivo XR385; also motorized automatic collimation option. | Manual collimation with motorized automatic collimation option |
Shape of Beam | Rectangular | Rectangular |
Detector Type | Digital Detector (Fixed & Wireless), identical to predicate devices (GE Brivo XR385, Philips BuckyVision, Swissray ddRVersa™ Motion) | Digital Detector (Fixed & Wireless) |
X-ray Scintillator Material | Fixed: GdOS, Wireless: Cesium Iodide; identical to predicate devices (GE Brivo XR385, Swissray ddRVersa™ Motion) | Fixed: GdOS, Wireless: Cesium Iodide |
Image Area | Wireless: 42.4cm x 34.8cm (identical to Swissray ddRVersa™ Motion); Fixed: 43cm x 43cm; slight differences with other predicates not expected to alter diagnostic image quality. | Wireless: 42.4cm x 34.8cm; Fixed: 43cm x 43cm |
Image Matrix Size | Wireless: 2866 x 2350 (identical to Swissray ddRVersa™ Motion); Fixed: 2874 x 2869; slight differences with other predicates not expected to alter diagnostic image resolution. | Wireless: 2866 x 2350; Fixed: 2874 x 2869 |
A/D Conversion | Identical to Philips BuckyVision and Swissray ddRVersa™ Motion (16 bits). | 16 bits |
SID | Table: 50-110cm; Wallstand: 100-180cm (slight differences with GE Brivo XR385 not expected to significantly alter application usage). | Table: 50-110cm; Wallstand: 100-180cm |
DICOM | DICOM 3.0 compatible (same as all predicate devices). | DICOM 3.0 compatible |
Software Platform | Eleva workspot (same as Philips BuckyVision). | Eleva workspot |
Compliance with Standards & Guidance | Compliance with all listed international and FDA-recognized consensus standards and FDA Guidance documents. | Complies with AAMI / ANSI ES60601-1, IEC 60601-1-2, 60601-1-3, 60601-2-28, 60601-2-54, IEC 62304, ISO 14971, IEC 62366, CFR 1020.30, CFR 1020.31, and FDA guidance documents related to solid state X-ray imaging, software, wireless technology, and pediatric information. |
Diagnostic Image Quality | Similar diagnostic image quality when compared with the predicate devices. | Demonstrated similar diagnostic image quality to predicate devices. |
Safety and Effectiveness | Equivalent to predicate devices in terms of safety and effectiveness for its intended use. Overall device is adequate for its intended use. | Demonstrated substantial equivalence in safety and effectiveness compared to predicate devices through design features, fundamental scientific technology, indications for use, and non-clinical performance (verification/validation) tests. |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not applicable. This 510(k) relies on non-clinical performance testing and comparison to predicate devices, not a clinical test set of patient images.
- Data Provenance: The data provenance is primarily from bench testing, engineering verification, and validation activities against recognized standards and guidance documents. This is not patient-level data. The manufacturer is Philips Healthcare (Suzhou) Co., Ltd in China.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
- Number of Experts: Not applicable. Since there was no clinical test set of patient images, no experts were used to establish ground truth in this context. The "ground truth" for this submission is related to engineering specifications and compliance with regulatory standards.
- Qualifications of Experts: N/A
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. No test set of patient images requiring adjudication was used.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
- MRMC Study: No, an MRMC comparative effectiveness study was not done. The submission explicitly states: "Clinical study was not warranted to support this 510(k) submission, since substantial equivalence to the currently marketed and predicate devices was demonstrated with the following attributes: Design features; Indication for use; Fundamental scientific technology; and Safety and effectiveness."
- Effect Size: Not applicable, as no MRMC study was performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- This device is a hardware digital radiographic system with integral software for image acquisition, processing, storage, and viewing. It is not an AI algorithm in the context of standalone performance. Therefore, a "standalone algorithm only" performance study is not applicable. The performance evaluation focuses on the entire system's compliance with standards and equivalence to predicate systems.
7. The Type of Ground Truth Used
- The "ground truth" for this submission is based on:
- Engineering Specifications and Design Features: Comparing the technical characteristics of the DuraDiagnost to those of the predicate devices.
- International and FDA-recognized Consensus Standards: Compliance with electrical safety, EMC, radiation protection, software lifecycle, risk management, and usability standards (e.g., IEC 60601 series, IEC 62304, ISO 14971).
- FDA Guidance Documents: Adherence to specific guidance for solid-state X-ray imaging, software, wireless technology, and pediatric information.
- Predicate Device Performance: The established safety and effectiveness of the legally marketed predicate devices (GE Brivo XR385, Philips BuckyVision, Swissray ddRVersa™ Motion) serves as a benchmark for substantial equivalence.
8. The Sample Size for the Training Set
- Training Set Sample Size: Not applicable. This submission is for a conventional digital radiographic system and does not involve an AI algorithm with a training set of images. The "training" for such a system would involve engineering design and software development, not machine learning from a dataset.
9. How the Ground Truth for the Training Set Was Established
- Ground Truth for Training Set: Not applicable, as there is no AI algorithm training set involved.
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