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510(k) Data Aggregation
(36 days)
I-View Gold and Imagen Gold Dental Sensors
I-View Gold sensors are digital dental intraoral sensors intended to collect dental x-ray photons and convert them into electronic impulses that may be stored, viewed, and manipulated for diagnostic use by dentists.
The subject I-View Gold and Imagen Gold sensors are intraoral digital x-ray systems comprised of two components: (1) an intraoral detector which connects to a PC via a USB port: and (2) an Image Management Software package.
The subject comes in two sizes: Size 1 is 600mm² and Size 2 is 884mm² and two brand names.
Direct digital systems acquire images with a sensor that is connected to a computer to produce an image almost instantaneously following exposure.
This document describes the marketing clearance for the I-View Gold and Imagen Gold Dental Sensors (K200625). The submission focuses on demonstrating substantial equivalence to a legally marketed predicate device (EzSensor Classic, K153060), rather than providing detailed acceptance criteria and a standalone study proving the device meets those specific acceptance criteria for performance metrics like diagnostic accuracy.
The FDA's 510(k) clearance process primarily evaluates whether a new device is "substantially equivalent" to a legally marketed predicate device in terms of intended use, technological characteristics, and safety and effectiveness. It does not typically require the applicant to establish novel performance acceptance criteria or conduct a de novo clinical study to prove those criteria are met, especially for devices with well-understood technology and established clinical pathways like dental X-ray sensors.
Therefore, the requested information regarding "acceptance criteria" and "the study that proves the device meets the acceptance criteria" in the context of diagnostic performance (e.g., sensitivity, specificity, accuracy for a specific clinical task) is not found in this 510(k) summary. The document focuses on demonstrating that the new device functions similarly and is as safe and effective as the predicate based on bench testing (SSIX Report, electrical safety, EMC, software documentation) and comparison of technical specifications.
Here's a breakdown of what can be extracted about "acceptance" and "testing" from the provided document, framed within the substantial equivalence argument, and what information is not available:
Information Available/Inferred from the Document:
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A table of acceptance criteria and the reported device performance:
- Acceptance Criteria (Implied for Substantial Equivalence): The implicit "acceptance criterion" is that the technological characteristics and performance are comparable to the predicate device (EzSensor Classic, K153060) to ensure equivalent safety and effectiveness.
- Reported Device Performance (Comparative Metrics): The table Compares technological characteristics. The "performance" here refers to measured physical and technical parameters, not diagnostic accuracy. The reported values for the subject device are expected to be sufficiently similar to the predicate to establish equivalence.
Characteristic Acceptance Criteria (Implicit: Comparable to Predicate) Reported Device Performance (Subject Device) Predicate Device Performance Common Name Intraoral Digital X-Ray Sensor Intraoral Digital X-Ray Sensor Intraoral Digital X-Ray Sensor Indications for Use Same as predicate Same as predicate Same as subject Intended Use Same as predicate Same as predicate Same as subject Principles of operation Same as predicate ('X-ray radiation => scintillator => fiber optic => CMOS => electronics => PC') Same as predicate Same as subject Sensor Thickness (mm) 4.8 mm 4.8 4.8 USB Module Integrated USB 2.0 module Integrated USB 2.0 module Integrated USB 2.0 module Pixel Pitch (Full/Binning mode) 14.8 / 29.6 14.8 / 29.6 14.8 / 29.6 DQE (6lp/mm, Full/Binning mode) 0.38 / 0.34 0.38 / 0.34 0.38 / 0.34 MTF (3lp/mm, Full/Binning mode) 0.642 / 0.630 0.642 / 0.630 0.642 / 0.630 Typical dose range (Incisor & Canine) 300 ~ 500 300 ~ 500 300 ~ 500 Typical dose range (Molar) 400 ~ 600 400 ~ 600 400 ~ 600 Standards of Conformity Compliance with relevant IEC/ISO standards Listed standards achieved Listed standards achieved Biocompatibility Not warranted (no patient contact) Not warranted (no patient contact), single-use protective barrier used Not warranted (no patient contact), single-use protective barrier used Electrical Safety & EMC Compliance with IEC 60601-1, IEC 60601-1-2 Conforms to standards Conforms to standards -
Sample sizes used for the test set and the data provenance:
- Test Set Sample Size: Not applicable/Not specified for a clinical performance test. The "test set" here refers to the physical units subjected to bench testing (e.g., for electrical safety, EMC, SSIX report). The sample size for these engineering tests is not provided in this summary.
- Data Provenance: The tests are "Non-Clinical Performance Data." There is no mention of patient data (images) or their provenance (country of origin, retrospective/prospective) because a clinical study was not presented for this 510(k) submission.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. No clinical test set with ground truth established by experts is described, as this is a substantial equivalence submission relying on bench testing and comparison to a predicate, not a de novo clinical performance study for diagnostic accuracy.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. No clinical test set requiring adjudication is described.
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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 device is a digital X-ray sensor, not an AI-powered diagnostic aid. Therefore, no MRMC study or assessment of AI assistance to human readers was performed or presented.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a hardware sensor with image acquisition and management software, not an algorithm for autonomous diagnostic performance.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable for clinical ground truth. The "ground truth" for the non-clinical tests would be defined by engineering specifications and reference standards (e.g., a calibrated measurement for DQE, MTF).
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The sample size for the training set:
- Not applicable. This is a hardware device with associated image processing firmware/software, not a machine learning model that requires a training set in the AI sense.
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How the ground truth for the training set was established:
- Not applicable. See point 8.
Summary of what's provided related to "proving" performance:
The document states "Bench tests were performed and the SSIX Report is shown in this submission. Additional certificates for the device are also within this submission." These tests (e.g., DQE, MTF, electrical safety, EMC) provide objective measurements of the device's physical and technical performance parameters, which are then compared to the predicate device to argue for substantial equivalence. The "proof" here is that these technical specifications are essentially identical to those of the cleared predicate device, and the device conforms to relevant safety and performance standards (IEC, ISO).
In a 510(k), especially for a device like this, the "acceptance criteria" for clearance are primarily:
- Same intended use as the predicate.
- Same technological characteristics as the predicate OR different technological characteristics that do not raise new questions of safety and effectiveness.
- Performance data (bench testing) demonstrating that the device is as safe and effective as the predicate.
This submission explicitly concludes: "The subject and the predicate device have the same intended use and the same technological features. I View Gold and Imagen Gold Sensors and share the same principles of operation, sensor technology, use the same USB connection to PC and use similar imaging firmware. The conclusion is that the subject device is as safe and effective as the predicate." The "study" proving this is the collection of non-clinical bench tests and the detailed comparative analysis of technical specifications presented in the submission.
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