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510(k) Data Aggregation

    K Number
    K162585
    Date Cleared
    2016-11-04

    (49 days)

    Product Code
    Regulation Number
    872.1800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    SuniIQ Digital Radiography System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SunilQ Digital Radiography system is used to collect dental x-ray photons and convert them into electronic impulses that may be stored, viewed and manipulated for diagnostic use by dentists.

    Device Description

    The SuniIQ Digital Radiography System reduces x-ray exposure by producing real time digital intra-oral images. The System accomplishes this by replacing X-ray film with a reusable electronic sensor that captures the X-ray photons and converts them to an electronic signal which, in turn, is captured in a computer for viewing, manipulating, storing, and output.

    AI/ML Overview

    The acceptance criteria and study information for the SuniIQ Digital Radiography System are outlined below:

    1. Acceptance Criteria and Reported Device Performance

    The document does not explicitly state numerical acceptance criteria for specific performance metrics. However, it indicates a general acceptance criterion that the device must be "as safe, as effective, and performs as well as or better than the predicate device."

    Tested FunctionAcceptance Criteria (Implied)Reported Device Performance
    Relative errorMust meet functional requirements; comparable to predicate.Pass
    X-Ray SaturationMust meet functional requirements; comparable to predicate.Pass
    Image sizeMust meet functional requirements; comparable to predicate.Pass
    Image orientationMust meet functional requirements; comparable to predicate.Pass
    Set up time, USB current, and clock patternMust meet functional requirements; comparable to predicate.Pass
    Dose loss and focus to detector distance (FDD)Must meet functional requirements; comparable to predicate.Pass
    Saturation ComparisonMust meet functional requirements; comparable to predicate.Pass
    Printed Circuit Board (PCB)Must meet functional requirements; comparable to predicate.Pass
    Software Development Kit (SDK)Must meet functional requirements; comparable to predicate.Pass
    Time to ready for exposure stateMust meet functional requirements; comparable to predicate.Pass
    Test Pattern ImagesMust meet functional requirements; comparable to predicate.Pass
    Dental Phantom ImagesMust meet functional requirements; comparable to predicate.Pass
    Other Operating systemsMust meet functional requirements; comparable to predicate.Pass
    Software Verification & ValidationOperate as specified, meeting IEC 62304 standards and FDA guidances.All features verified to operate as specified. All test passing criteria met.
    BiocompatibilityMeet ISO 10993-1:2009 and FDA draft guidance.Met requirements.
    DisinfectionRecommended cleaning method confirmed.Confirmed.
    Electromagnetic Compatibility and Electrical SafetyMeet IEC 60601-1:2005 and ANSI/AAMI ES60601-1:2005 for safety, IEC 60601-1-2:2007 for EMC.Met requirements.

    The study concludes that "Testing confirms that the SuniIQ System is as safe, as effective, and performs as well as or better than the predicate device," and that "The identified technological differences between the subject and predicate devices were assessed through bench performance testing data and software V&V testing to demonstrate that they are substantially equivalent."

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a distinct "test set" in terms of patient data. The testing described focuses on bench testing and software verification and validation (V&V).

    • Bench Testing: The "tested functions" listed cover various technical aspects of the device, likely using controlled laboratory conditions and specific testing protocols (e.g., test pattern images, dental phantom images). The sample sizes for these tests are not explicitly stated, but are implied to be sufficient for verifying the functional requirements.
    • Data Provenance: The document does not refer to clinical data or country of origin for a test set. The validation is primarily technical.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    No information is provided regarding experts establishing ground truth for a clinical "test set," as the device's performance was evaluated through bench testing and software V&V, not a clinical study involving diagnostic interpretations by experts.

    4. Adjudication Method for the Test Set

    Not applicable, as no clinical test set requiring expert adjudication is described in the document.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study is mentioned. The document primarily focuses on demonstrating substantial equivalence through technical performance comparisons with a predicate device, rather than assessing human reader improvement with AI assistance. The device is a "digital radiography system," which captures images; it is not presented as an AI-powered diagnostic aide.

    6. Standalone (Algorithm Only) Performance Study

    The document describes the performance of the "SuniIQ Digital Radiography System" itself, which is a hardware and software system for capturing and displaying dental x-ray images. The "software components" within the SuniIQ handle sensor control, data transfer, and include an "optional filter algorithm" for image correction. The performance reported in the "Bench Testing" and "Software V&V" sections can be considered the standalone performance of this system, demonstrating its ability to acquire and process images. There is no mention of a separate "AI algorithm" being evaluated independently.

    7. Type of Ground Truth Used

    The ground truth for the evaluations conducted was primarily based on:

    • Functional Requirements/Specifications: The device's performance was compared against defined functional requirements for items like relative error, X-ray saturation, image size, etc.
    • Predicate Device Performance: Direct comparison to the performance of the predicate SuniRay II System (K070219) was used as a benchmark for many functional tests.
    • Industry Standards: Compliance with standards like IEC 62304 for software, ISO 10993-1 for biocompatibility, IEC 60601-1 for safety, and IEC 60601-1-2 for EMC served as ground truth for regulatory and quality aspects.
    • Test Pattern Images and Dental Phantom Images: These are controlled inputs with known characteristics, used to assess image quality and system response under controlled conditions.

    There is no mention of pathology, expert consensus on clinical findings, or outcomes data being used as ground truth.

    8. Sample Size for the Training Set

    The document does not mention a "training set." The device is a digital radiography system, not a machine learning or AI algorithm in the context of typical AI device approvals that involve training datasets. The "software components" are described as drivers, control software, and an optional filter algorithm, implying traditional software development and verification rather than machine learning training.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as no training set is mentioned or implied for this device.

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