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510(k) Data Aggregation
(206 days)
KALARE
- Intended to be used as a universal diaging system for radiographic and fluoroscopic examinations, including general R&F and pediatric examinations.
- Intended for use by a qualified/trained doctor or technologist on both and pediatric subjects taking diagnostic and fluoroscopic exposures of the whole body, skull, spinal column, extremities and other body parts. Applications can be performed with the patient sitting, standing, or lying in prone or supine position.
The main function of the KALARE (DREX-KL80) is to perform fluoroscopy/radiography of the examinations of the gastrointestinal tract examination, support for endoscopy, nonvascular contrast study, general abdominal radiography and general skeletal radiography. Using fluorescent scintillation effects of X-rays that have passed through the patient's body, image information is obtained for medical diagnosis and treatment.
This 510(k) submission (K133553) describes a modification to an existing device, the KALARE (DREX-KL80), which involves the addition of a previously cleared Flat Panel Detector (FPD). As such, the study performed is a justification of substantial equivalence rather than a detailed performance study against specific acceptance criteria for a novel device.
Here's an analysis of the provided information, addressing your points where possible:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Safety | The device is designed and manufactured under Quality System Regulations (21 CFR § 820 and ISO 13485). |
Conforms with applicable parts of IEC60601-1, IEC 60601-2-7, IEC60601-2-28, and IEC 60601-2-32 standards. | |
Meets all requirements of the Federal Diagnostic Equipment Standard (21 CFR §1020). | |
Effectiveness | Bench testing: Confirmed that the installation of the detector met the stated specifications of the component manufacturer. |
Comparative Testing: Image quality, artifacts, and motion/dynamic capabilities were compared between the predicate device and the modified device. | |
Conclusion: The testing demonstrated that substantial equivalence to the predicate device could be proven without the use of clinical images. | |
Indications for Use Unchanged | The modifications incorporated into the KALARE do not change the indications for use or the intended use of the device. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not applicable in the traditional sense of a clinical test set. The study primarily involved bench testing and comparative non-clinical performance evaluations.
- Data Provenance: The testing was conducted in accordance with applicable standards published by the International Electromechanical Commission (IEC). The device's manufacturing site is in Japan (Toshiba Medical Systems Corporation). The specific location or "provenance" of the bench testing is not explicitly stated beyond "Testing of the modified system was conducted...". The study type is a verification and validation study focused on demonstrating substantial equivalence through non-clinical means.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This information is not provided because the study did not involve a clinical test set with a need for expert-established ground truth. The evaluation was primarily technical and comparative against the predicate device's established performance and component specifications.
4. Adjudication Method for the Test Set
- Not applicable, as no external expert adjudication of clinical cases was performed.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, a MRMC comparative effectiveness study was not done. The submission explicitly states: "The conclusion of this testing demonstrated that substantial equivalence to the predicate device could be proven without the use of clinical images."
6. Standalone (Algorithm Only) Performance Study
- No, a standalone (algorithm only) performance study was not done for a new or modified algorithm. The device is an X-ray system that incorporates a (modified) detector, not an AI algorithm.
7. Type of Ground Truth Used
- The "ground truth" for this submission would be defined by the technical specifications of the previously cleared FPD component, the established performance characteristics of the predicate device, and the applicable industry standards (IEC, 21 CFR §1020). The testing aimed to show that the new configuration met these technical and performance benchmarks.
8. Sample Size for the Training Set
- Not applicable. This is a submission for a modification to a medical device (an X-ray system), not for a machine learning or AI algorithm that would require a training set.
9. How the Ground Truth for the Training Set Was Established
- Not applicable, as there was no training set for an AI algorithm.
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(67 days)
KALARE DIAGNOSTIC X-RAY TABLE SYSTEM
Intended to be used as a universal diagnostic imaging system for radiographic and fluoroscopic examinations, including general R&F and pediatric examinations. Intended for use by a qualified/trained doctor or technologist on both adult and pediatric subjects taking diagnostic radiographic and fluoroscopic exposures of the whole body, skull, spinal column, chest, abdomen, extremities and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position.
The main function of the KALARE (DREX-KL80) is to perform fluoroscopy/radiography of the examinations of the gastrointestinal tract examination, support for endoscopy, nonvascular contrast study, general abdominal radiography and general skeletal radiography. Using fluorescent scintillation effects of X-rays that have passed through the patient's body. image information is obtained for medical diagnosis and treatment.
The provided text is a 510(k) summary for the Toshiba KALARE (DREX-KL80) X-Ray Diagnostic Table System. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study with specific acceptance criteria and performance metrics for a new, independent device evaluation.
Therefore, the requested information for acceptance criteria, device performance, sample sizes, ground truth establishment, expert involvement, and MRMC studies is not available within this document.
Here's an explanation based on the provided text:
Acceptance Criteria and Study Information Unavailable
The document is a "SUMMARY OF SAFETY AND EFFECTIVENESS" for a 510(k) premarket notification. The core of a 510(k) submission is to demonstrate that a new device is "substantially equivalent" to a legally marketed predicate device, not to perform novel clinical or performance studies with predefined acceptance criteria.
Key points from the document indicating this:
- Section 11. SUBSTANTIAL EQUIVALENCE: States, "The KALARE (DREX-KL80) is of comparable type and is substantially equivalent to the GE Precision 500D R&F X-ray (K081091)." This is the primary "proof" for a 510(k) device.
- Section 13. CONCLUSION: Re-affirms, "The KALARE (DREX-KL80) complies with the same or equivalent standards and has the same intended use as the predicate device."
- FDA Response Letter: States, "We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent... to legally marketed predicate devices."
Because this is a substantial equivalence submission for an X-ray diagnostic table system (a hardware device), the FDA clearance is based on the device meeting established electrical, radiation safety, and performance standards as outlined in 21 CFR Subchapter J, Federal Diagnostic X-ray Equipment Standard and IEC60601-1 standards and its collateral standards, and demonstrating that its specifications are comparable to the predicate device.
Therefore, the following information is not present in the provided text:
- Table of acceptance criteria and reported device performance: Not applicable for a substantial equivalence claim based on predicate device comparison for a hardware system. Performance is assumed to be equivalent to the predicate, and compliance is to safety standards.
- Sample size used for the test set and the data provenance: No clinical test set data is provided. Compliance is based on technical specifications and standards.
- Number of experts used to establish the ground truth for the test set and their qualifications: Not applicable.
- Adjudication method for the test set: Not applicable.
- If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and the effect size: Not applicable. This type of study is more common for diagnostic algorithms or imaging techniques where reader performance is a direct output. This is a hardware system.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable, as this is a hardware system, not an algorithm.
- The type of ground truth used: Not applicable.
- The sample size for the training set: Not applicable, as there's no machine learning algorithm being trained.
- How the ground truth for the training set was established: Not applicable.
In summary, the provided document demonstrates that the KALARE (DREX-KL80) device meets the regulatory requirements for market clearance by proving its substantial equivalence to an existing predicate device and by conforming to applicable safety and performance standards for X-ray equipment. It does not contain a study with specific clinical acceptance criteria and performance metrics for a novel evaluation.
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