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510(k) Data Aggregation
(149 days)
SIMPLANT 2011
SimPlant 2011 is intended for use as a software interface and image segmentation system for the transfer of imaging information from a medical scanner such as a CT scanner or a Magnetic Resonance scanner. It is also intended as pre-planning software for dental implant placement and surgical treatment.
SimPlant 2011 is intended for use as a software interface and image segmentation system for the transfer of imaging information from a medical scanner such as a CT scanner or a Magnetic Resonance scanner. It is also intended as pro-planning software for dental implant placement and surgical treatment.
The provided text does not contain detailed acceptance criteria and a study proving the device meets those criteria in the typical format of a medical device performance study. Instead, it details a 510(k) premarket notification for SimPlant 2011, focusing on demonstrating substantial equivalence to a predicate device (SimPlant Dr James, K053592).
This type of submission primarily relies on showing that the new device has the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness. As such, the "acceptance criteria" discussed are largely related to software validation and regulatory compliance, rather than specific clinical performance metrics.
However, based on the information provided, here's an attempt to answer your questions, interpreting "acceptance criteria" in the context of this 510(k) submission:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Interpreted from 510(k)) | Reported Device Performance |
---|---|
General Compliance/Functionality: |
- Software functionality as described in its design.
- Robustness to usual, unexpected, and invalid inputs.
- Adherence to medical device software development lifecycle standards (e.g., ISO 13485:2003, IEC 62304:2006, EN ISO 14971:2007). | - The SimPlant 2011 software was thoroughly tested and originates from the same medical software platform as the cleared predicate (K033849).
- Testing performed included Unit, Integration, IR, Smoke, Formal (General, Reference, Usage), Acceptance, Alpha, and Beta testing.
- Both static (inspections, walkthroughs) and dynamic analysis were used to find and prevent problems and demonstrate run-time behavior.
- "All controls and procedures are functioning properly" as per documented test plan derived from final specifications. Results are on file at Materialise Dental. |
| Substantial Equivalence: - Same intended use as the predicate device.
- Similar technological characteristics to the predicate device.
- Any differences in technological characteristics do not raise new questions of safety or effectiveness. | - Intended Use: Identified as "substantially equivalent" for use as a software interface and image segmentation system, and as pre-planning software for dental implant placement and surgical treatment. (Matches predicate's general intended use).
- Technological Comparison: SimPlant 2011 has more features (e.g., ISO Surface, X-Ray Rendering, Segmentation Wizard, advanced virtual teeth, dual scan registration, optical scanner support, occlusion tool, virtual occludator) than the predicate, SimPlant System.
- Conclusion: The submitter states, "considered to be substantially equivalent in design, material and function... It is believed to perform as well as the predicate device." FDA concurrence on substantial equivalence was granted. |
| Safety & Effectiveness: - Device does not contact the patient.
- Device does not deliver medication or therapeutic treatment.
- Application of risk management to devices. | - The product "does not contact the patient and does not deliver medication or therapeutic treatment."
- Risk management was applied in accordance with EN ISO standard 14971:2007. |
2. Sample Size Used for the Test Set and the Data Provenance
The document does not specify a "test set" in the context of clinical data or patient images for performance evaluation. The "tests" mentioned are primarily related to software engineering and validation (Unit testing, Integration testing, etc.) to ensure the software itself functions as designed. There is no mention of a specific dataset of patient images used to evaluate the clinical performance or accuracy of the segmentation or planning features in a statistically quantifiable manner.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
Not applicable. As noted above, there's no mention of a clinical "test set" requiring expert-established ground truth for performance evaluation. The validation described is focused on software quality and functionality.
4. Adjudication Method for the Test Set
Not applicable for the same reasons as 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 is not mentioned or described in this 510(k) submission. The document focuses on demonstrating substantial equivalence of the software's functionality and safety, not on its impact on human reader performance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
The document describes "thorough testing" of the software, including various types of software testing (Unit, Integration, Formal, Acceptance, etc.). This would inherently involve evaluating the algorithm's standalone performance in terms of its intended software functions (e.g., segmentation, rendering, planning tools). However, it does not describe a clinical standalone performance study in the sense of an algorithm making a diagnostic or treatment decision without human involvement and comparing its output to a clinical ground truth. The device is explicitly "pre-planning software," implying human-in-the-loop usage.
7. The Type of Ground Truth Used
For the software validation described, the "ground truth" would be the expected behavior or output of the software as defined by its specifications and requirements. For example, during unit testing, the ground truth for a specific module's output would be what the developer intended it to produce given a set of inputs. For integration testing, it would be the correct interaction between modules. There is no mention of clinical ground truth (e.g., pathology, outcomes data, or expert consensus on patient data) being used for performance evaluation.
8. The Sample Size for the Training Set
There is no mention of a training set in the context of machine learning or AI models. This submission is from 2011, and while some "advanced" features are listed (e.g., "Segmentation Wizard"), the documentation does not describe an AI/ML-driven system that would typically require a training set of labeled data in the modern sense. The "training" here refers to software development and validation processes, not machine learning model training.
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no mention of a training set as understood in AI/ML context.
Summary of Approach in the Document:
The provided document details a 510(k) Special Premarket Notification for SimPlant 2011. The primary focus of a 510(k) is to demonstrate substantial equivalence to a predicate device. This typically involves:
- Comparing Intended Use: Showing the new device has the same purpose.
- Comparing Technological Characteristics: Identifying similarities and differences with the predicate.
- Demonstrating Safety and Effectiveness of Differences: Proving that any novel features or modifications do not introduce new risks or reduce effectiveness. This generally relies on non-clinical performance data (e.g., engineering tests, software validation, bench testing) and adherence to recognized standards, rather than large-scale clinical trials or detailed performance studies with patient data and expert ground truth.
Therefore, the "acceptance criteria" and "studies" mentioned are largely about internal software development validation, quality system compliance, and regulatory comparison, not comprehensive clinical performance evaluation against a defined clinical ground truth.
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