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510(k) Data Aggregation
(53 days)
The NDOHD system is intended for viewing, acquiring, recording, archiving and retrieving video and still images of endoscopic and fluoroscopic procedures. The professionals or practitioners using this system would be medical doctors or clinicians such as speech pathologists. The device is a prescription device. The NDOHD system is not intended to be used in an environment that requires sterilization.
The NDOнd High Definition Imaging System (NDOнD) previously acquired FDA clearance in 2013 as a Class II picture archiving and communication system that provides capabilities related to the acquisition, transfer, display, storage, and digital processing of images and videos (K131873). Altaravision replaced off the shelf hardware components due to the hardware becoming obsolete. Altaravision also updated the NDOHD software to enable use of the new hardware, improve the software user interface and conform to Apple's latest coding best practices.
The provided text is a 510(k) Summary for the Altaravision, Inc. NDŌHD High Definition Imaging System (NDOHD). This submission is for a modification to an already cleared device (K131873), primarily due to hardware obsolescence and software updates. It is a Picture Archiving Communications System (PACS) device.
Key takeaway: This is a 510(k) submission for an updated version of a previously cleared PACS device. The core of the submission is to demonstrate substantial equivalence to the predicate device, not to prove clinical efficacy through a new clinical trial against defined acceptance criteria for a novel AI algorithm.
Therefore, many of the typical questions regarding acceptance criteria for AI/ML devices and their associated studies (e.g., sample size for test sets, number of experts, adjudication methods, MRMC studies, standalone performance, ground truth for training) are not directly applicable or explicitly detailed in this type of submission, as the device is not an AI/ML diagnostic or assistive tool in the way that those questions imply. The testing described is primarily for software verification, system validation, and electrical safety, ensuring the new hardware and software function as intended and are as safe and effective as the predicate device.
However, I will extract relevant information where possible and explicitly state when a requested piece of information is not present or applicable.
Acceptance Criteria and Study to Prove Device Meets Criteria
Given that this is a 510(k) for an updated PACS system, the "acceptance criteria" are primarily related to demonstrating substantial equivalence to the predicate device (NDŌHD High Definition Imaging System, K131873) in terms of intended use, indications for use, technological characteristics, and safety and effectiveness. The "study" is the collection of verification and validation testing performed.
1. Table of acceptance criteria and the reported device performance:
Since this is a substantial equivalence submission for a PACS device update, the "acceptance criteria" are not presented as numerical performance targets (e.g., sensitivity, specificity) for a diagnostic task. Instead, they are implied through direct comparison to the predicate device across various characteristics and verification/validation testing. The performance is essentially reported as "equivalent" or "identical" to the predicate, with differences not affecting intended use, safety, or effectiveness.
| Acceptance Criterion (Implied by Substantial Equivalence Claim) | Reported Device Performance (Comparison to Predicate K131873) |
|---|---|
| Intended Use | Identical |
| Indications for Use | Identical |
| Target Population | Identical |
| Computer Hardware | Equivalent (MacBook Pro 13-inch and 15-inch vs. 15-inch; differences in specific models due to obsolescence, but functionally equivalent) |
| Display | Equivalent (Built-in computer display – 13-inch and 15-inch vs. 15-inch) |
| Storage Medium | Equivalent (Non-removable Solid State Drive (SSD) vs. Non-removable hard drive) |
| Operating System | Equivalent (macOS 10.14+ vs. macOS 10.8+; difference in version does not affect intended use or safety/effectiveness) |
| Camera Coupler | Identical (C-Mount) |
| Camera-Computer Cable | Different (USB-3.0 USB C to USB Micro-B vs. Firewire; difference does not affect intended use or safety/effectiveness) |
| Video Output Format | Different (.mp4 H.264 Video vs. .mov H.264 Video; difference does not affect intended use or safety/effectiveness) |
| Still Image Output Format | Identical (.tiff Image) |
| Camera Sensor Type | Different (CMOS vs. CCD Progressive; difference does not affect intended use or safety/effectiveness) |
| Camera Frame Rate | Different (203 fps vs. 31 fps; difference does not affect intended use or safety/effectiveness - note: higher frame rate is generally considered an improvement for video capture in this context, but framed as not impacting safety/effectiveness rather than a performance target met) |
| Pixel Size | Equivalent (4.8 μm x 4.8 μm vs. 4.65 μm x 4.65 μm) |
| Camera Bit Depth | Equivalent (10 bits vs. 8-14 bits) |
| Camera Resolution (H x V) | Different (1280 px x 1024 px vs. 1032 px x 776 px; difference does not affect intended use or safety/effectiveness - note: higher resolution is generally an improvement, but framed as not impacting safety/effectiveness) |
| Power Consumption | Equivalent (3 W (Typical) vs. < 4 W) |
| Lossy Image Compression | Identical (Yes, H.264 compression) |
| Power Source | Identical (Computer built-in battery operated) |
| Software Functionality | Equivalent (Controls recording, playback, storage, retrieval, live view of video, audio, images; updated UI, conform to Apple coding best practices) |
| Programming Language | Different (Swift vs. Objective C; difference does not affect intended use or safety/effectiveness) |
| Safety and Effectiveness | Demonstrated through software verification, system validation, and electrical safety testing according to FDA Guidance and Industry Standards (listed in Section 7). |
2. Sample sized used for the test set and the data provenance:
- Sample Size for Test Set: This information is not provided in the summary. For a PACS system, validation testing would involve testing functionalities (acquisition, storage, display, retrieval, etc.) with various typical image/video files, but specific "test set" sizes for clinical evaluation (like for an algorithm) are not explicitly mentioned.
- Data Provenance: Not applicable in the context of this submission, as it's not evaluating clinical data for diagnoses made by the system. The system handles endoscopic and fluoroscopic procedure videos and images.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not applicable as the device is a PACS system for managing images, not an AI diagnostic tool requiring expert-established ground truth for performance evaluation of a clinical task.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- This information is not applicable for the reasons stated above.
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, an MRMC comparative effectiveness study was not performed. This device is a PACS system, not an AI assistant intended to improve human reader performance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- A "standalone" performance evaluation in the context of a diagnostic algorithm is not applicable. The device's performance relates to its ability to acquire, store, display, and retrieve images/videos correctly and safely, which was evaluated through verification and validation (V&V) testing, not through standalone diagnostic accuracy.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- "Ground truth" in the diagnostic sense (e.g., pathology for cancer detection) is not applicable to this PACS system. The V&V testing would establish that functionalities (e.g., image integrity, compression, display fidelity, storage/retrieval accuracy) meet their specifications, rather than clinical ground truth.
8. The sample size for the training set:
- This device is not an AI/ML algorithm that is "trained" on a dataset in the typical sense. Therefore, a "training set" sample size is not applicable. The software was updated and developed following coding best practices, and subjected to verification and validation.
9. How the ground truth for the training set was established:
- As the device is not an AI/ML algorithm with a "training set," this question is not applicable.
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(93 days)
The NDOHD system is intended for viewing, acquiring, archiving and retrieving video and still images of endoscopic and fluoroscopic procedures. The professionals or practitioners using this system would be medical doctors or clinicians such as speech pathologists. The device is a prescription device. The NDOHD system is not intended to be used in an environment that requires sterilization.
The NDOHD High Definition Imaging System (NDOHD) was initially commercialized in 2011 as a photographic accessory for endoscopes (FEM), Class I Exempt device. Altaravision has expanded the capabilities of the NDOHD system to include a computer and a camera, included a lossy image compression mechanism using standard irreversible compression technique, H.264, added a time code on the display of the image, created camera controls and added profiles for multiple camera settings and user preferences. Therefore, Altaravision has created a picture archiving and communication system that provides capabilities related to the acceptance, transfer, display, storage and digital processing of images and videos.
Here's an analysis of the provided 510(k) summary regarding the Altaravision NDOHD High Definition Imaging System, structured according to your requested points:
This device is a Picture Archiving and Communications System (PACS) and underwent a 510(k) submission, classifying it as a Class II medical device. The 510(k) submission primarily focuses on demonstrating substantial equivalence to a predicate device rather than conducting a separate clinical study to prove novel performance against specific acceptance criteria.
Therefore, there is no explicit table of acceptance criteria and reported device performance in the same manner one would expect for a diagnostic AI device or a device requiring new efficacy claims. The "acceptance criteria" for a 510(k) of this nature are implicitly met by demonstrating substantial equivalence through technical and functional comparisons, and adherence to relevant standards.
1. Table of Acceptance Criteria and Reported Device Performance
As noted, this 510(k) is for a PACS device demonstrating substantial equivalence, not a new AI diagnostic device with specific performance metrics like sensitivity or specificity. Thus, a traditional table of "acceptance criteria" and "reported device performance" in terms of clinical accuracy is not provided in the document.
Instead, the "acceptance criteria" are implied by conformance to international and FDA standards, and the "reported performance" is essentially the device's functional capabilities compared to a predicate device.
| Category | Acceptance Criteria (Implied by 510(k) Process) | Reported Device Performance (as demonstrated by substantial equivalence to K991738 and adherence to standards) |
|---|---|---|
| Intended Use | Must be the same or very similar to the predicate device. | The NDOHD system's intended use (viewing, acquiring, archiving and retrieving video and still images of endoscopic and fluoroscopic procedures) is determined to be the Same as predicate. |
| Indications for Use | Must be the same or very similar to the predicate device. | The NDOHD system's indications for use are determined to be the Same as predicate. |
| Target Population | Must be the same or very similar to the predicate device. | Target population (Medical doctors or clinicians such as speech pathologists) is determined to be the Same as predicate. |
| Display | Must be functionally comparable or superior, suitable for the intended use. | Uses a built-in computer display, which is considered Similar to predicate (NEC MultiSync E900+). |
| Storage Medium | Must be suitable for archiving and retrieving images. | Uses a non-removable hard drive, considered Similar to predicate (removable 2Gb hard drive). Functionally comparable. |
| Video Output Format | Must be suitable for image processing and archiving. | Uses .mov H.264 Video and .tiff still images. Considered Similar to predicate (MJPEG and AVI), with the NDOHD using an OS agnostic format compared to the predicate's Windows-specific formats. |
| Camera CCD | If integrated, must provide adequate image quality for the intended use. | 1032x762 CCD, 1/3" sensor, 31 FPS, 800Mb/s. The predicate device listed "Optional" for Camera. The NDOHD's integrated camera is compared to an optional component of the predicate. |
| Lossy Image Compression | Must utilize a known and accepted compression technique. | Uses H.264 compression. Considered Similar to predicate ("Yes," exact type unknown for predicate). |
| Energy | Must comply with safety standards for medical electrical equipment. | Computer built-in battery operated. Considered Similar to predicate (UPS battery operated). Both use battery during operation, and NDOHD includes safety controls to prevent use while plugged into AC power. |
| Software Functionality | Must adequately control recording, playback, storage, and retrieval of medical images. | NDOHD Software controls recording, playback, storage, retrieval, and live view of HD video, audio, and images. Considered Similar to predicate (DVRS Software controlling recording, playback, storage, retrieval of digital video and audio). NDOHD offers live view and is Macintosh-compatible, while the predicate is Microsoft-compatible. |
| Software Validation | Must comply with FDA guidance for medical device software. | Validation completed according to "General Principles of Software Validation; Final Guidance for Industry and FDA Staff, January 11, 2002" and "Guidance for the Submission of Premarket Notifications for Medical Image Management Devices, July 27, 2000". |
| Electrical Safety | Must comply with relevant IEC standards for medical electrical equipment. | Testing completed according to IEC 60601-1, IEC 60601-1-1, and IEC 60601-2-18. |
2. Sample Size Used for the Test Set and the Data Provenance
This document does not describe a clinical study with a "test set" of patient data in the typical sense (e.g., a set of medical images for diagnostic performance evaluation). The testing described relates to software validation and electrical safety, which are engineering and quality assurance activities, not clinical performance studies using patient data.
- Sample Size for Test Set: Not applicable/not specified for clinical performance. The testing involved functional and safety assessments of the device itself.
- Data Provenance: Not applicable, as no external patient data test set was used for performance claims.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
Not applicable. No ground truth establishment by experts for a test set of patient data is mentioned because this is a PACS device whose 510(k) focused on substantial equivalence through functional and safety testing, not diagnostic performance.
4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set
Not applicable. No patient data test set requiring expert adjudication was described.
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
Not applicable. This device is a PACS for viewing, acquiring, archiving, and retrieving images. It is not an AI-assisted diagnostic tool, and therefore, an MRMC study comparing human reader performance with and without AI assistance was not conducted or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. The NDOHD system is a human-in-the-loop system (a PACS) for medical professionals. It does not contain a standalone AI algorithm for diagnostic interpretation in the way one might evaluate AI performance for, say, lesion detection.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not applicable. For the software validation and electrical safety tests, the "ground truth" would be the specifications, requirements, and industry standards themselves, rather than clinical ground truth from patient data.
8. The Sample Size for the Training Set
Not applicable. This document is for a medical device (PACS) that does not describe an AI algorithm explicitly trained on a dataset for clinical performance.
9. How the Ground Truth for the Training Set was Established
Not applicable, as no AI training set is described.
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