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510(k) Data Aggregation

    K Number
    K182517
    Device Name
    MULTIX Impact
    Date Cleared
    2019-01-11

    (120 days)

    Product Code
    Regulation Number
    892.1680
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The MULTIX Impact system is a radiographic system used in hospitals, clinics, and medical practices. MULTIX Impact enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The MULTIX Impact system is not meant for mammography.

    The MULTIX Impact uses digital detectors for generating diagnostic images by converting x-rays into image signals. The MULTIX Impact is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.

    Device Description

    The MULTIX Impact Radiography X-ray system is a modular system of X-ray components (floor-mounted X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless detectors) similar to the predicate the Multix Fusion Max. This 510(k) submission describes modifications to the predicate device the Multix Fusion Max cleared via K162971. The following modifications have been made to the cleared predicate device and the new system will be branded the MULTIX Impact:

    1. A new 43x35cm Wireless detector, 3543DR 1.
    2. A new X-ray tube and a new generator
    3. An optional 40 line grid with grid suppression algorithm
    4. Wireless Remote Control Console
    5. An optional All-in-one PC containing touch screen function
    6. An optional positioning assistance camera
    7. Upgrade software to VA10
    8. Upgrade operator system from Windows XP to Windows 10
    AI/ML Overview

    The Siemens MULTIX Impact X-ray system is a modification of the predicate device, the Multix Fusion Max (K162971). The submission focuses on demonstrating substantial equivalence rather than presenting an effectiveness study for a new clinical claim. Therefore, the information provided primarily concerns performance testing to confirm that the modifications do not negatively impact safety or effectiveness.

    Here's an analysis based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is a submission demonstrating substantial equivalence to a predicate device for an X-ray system, the acceptance criteria are generally focused on demonstrating that various component modifications do not degrade performance below the predicate's established levels, and that the device meets relevant safety and performance standards. Formal "acceptance criteria" for a specific clinical task are not explicitly stated for the device as a whole in the way they would be for a diagnostic AI algorithm. Instead, the comparison is to the predicate and established standards.

    Attribute Tested/ModifiedAcceptance Criteria (Implied)Reported Device PerformanceComparison Results
    Indications for Use"Intended use is the same."Reworded for simplicity, but maintains same scope.Same
    Operating System"Does not affect safety or effectiveness."Upgraded from Windows XP to Windows 10.Meets criteria
    Suppression algorithm for low line grid"Does not affect image quality."Performance testing concluded.Meets criteria
    Post-processing software"Does not affect image quality."Different parameters (e.g., Contrast, Detail vs. Amplification, Edge Enhancement). Performance testing concluded.Meets criteria
    Floor mounted support"Does not affect safety or effectiveness."Mechanical (new feature).Meets criteria
    X-ray tube assemblySame or equivalent performance as predicate.80 kW, Two-focus.Same
    CollimatorSame or equivalent performance as predicate.Standard collimator (ACSS).Same
    Optional digital camera"Does not affect safety or effectiveness."Camera on collimator for patient positioning (new feature).Meets criteria
    Patient Table"Does not affect safety or effectiveness."Improvement of Bucky movement to motorized from manual.Meets criteria
    Bucky Wall StandSame or equivalent performance as predicate; "Does not affect safety or effectiveness."Similar to predicate, some models without charging tray.Meets criteria
    Touch InterfaceSame or equivalent functionality.Graphical user interface.Same
    X-ray generatorSame or equivalent performance.55kW, 65kW or 80kW.Same
    Operating modesSame or equivalent functionality.RAD Single Exposure.Same
    Imaging System"Does not affect safety or effectiveness."Addition of touch screen function as option.Meets criteria
    Display"Does not affect safety or effectiveness."Different size ratio (16:9 vs. 4:3).Meets criteria
    DICOM 3 FunctionsSame or equivalent functionality.Send, StC, Print, Query/Retrieve, Get Worklist, MPPS.Same
    Radiographic Grid"Does not affect image quality."Addition of 40-line grid (with suppression algorithm). Performance testing concluded.Meets criteria
    Accessory (Wireless Remote Control Console)"Does not affect safety or effectiveness."Improvement of wireless function.Meets criteria
    New 43x35cm Wireless detector (Trixell Pixium 3543 DR vs. 3543 EZh predicate)Detectors should exhibit comparable critical specifications (Dimensions, Resolution, Pixel size, Semiconductor Material, Scintillator, Acquisition depth, DQE, MTF). Differences should be "not significant."Dimensions: 345mm x 426mm (subject) vs. 348mm x 424mm (subject to predicate) and 349mm x 425mm (predicate). Resolution: 2156 x 2662 pixels (subject) vs. 2350 x 2866 pixels and 2356 x 2872 pixels (predicate). Pixel size: 160 µm (subject) vs. 148 µm (predicate). Other: Same for Semiconductor Material, Scintillator, Acquisition depth, DQE (51%), MTF (62-63%)."Difference not significant" for dimensions, resolution, pixel size. "Same" for other parameters.
    Compliance with StandardsConformance to various IEC, ISO, and NEMA standards, notably IEC 60601 series.Conforms to listed standards (IEC 60601-1:2012, IEC 60601-1-2:2014, IEC 60601-1-3:2008+A1:2013, IEC 62366-1:2015, ISO 14971:2007, IEC 60601-1-6:2013, IEC 62304:2015, IEC 60601-2-28:2010-03, IEC 60601-2-54:2015-04, NEMA PS 3.1 - 3.20 (2016), ISO 10993-1:2009).Achieved
    Software Concerns"All the software specifications have met the acceptance criteria" and "continued conformance with special controls for medical devices containing software."Software Documentation for Moderate Level of Concern per FDA Guidance (May 11, 2005) included. Non-clinical tests (integration and functional) conducted.Achieved
    Risk ManagementRisk control implemented to mitigate identified hazards.Hazard analysis completed, controls implemented, testing supports.Achieved

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

    The document describes modifications to an existing X-ray system and its components. The "test set" here refers to the actual physical device and its components undergoing verification and validation testing, rather than a dataset of medical images for a diagnostic algorithm.

    • Sample Size for Test Set: Not applicable in the context of a dataset of cases. The testing was performed on the MULTIX Impact system itself and its components.
    • Data Provenance: Not applicable in the clinical data sense. The testing is described as "Non-clinical tests... during product development" and "testing for verification and validation." This implies internal testing by the manufacturer.

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

    Not applicable. This is not a study requiring expert clinical read-outs for ground truth. The "ground truth" for this submission is adherence to technical specifications, performance standards (like DQE, MTF), and safety requirements, which are evaluated by engineering and quality control processes.

    4. Adjudication Method for the Test Set

    Not applicable. There is no mention of clinical image adjudication for ground truth establishment. Technical performance and safety are verified through engineering tests.

    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 MRMC study was performed or is mentioned. This submission is for an X-ray system, not an AI-powered diagnostic device, and it focuses on demonstrating substantial equivalence of modified hardware and software components, not on comparative effectiveness with human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. The device is an X-ray system, which is inherently used with human operators. There is no "algorithm only" performance claim. The software modifications are part of the overall X-ray system's functionality.

    7. The Type of Ground Truth Used

    The "ground truth" for this submission relates to:

    • Technical Specifications: Ensuring components meet their specified performance parameters (e.g., DQE, MTF for the detector, power output for the generator).
    • Compliance with Standards: Verification that the device adheres to recognized national and international standards (IEC, ISO, NEMA).
    • Safety and Effectiveness: Demonstration that modifications do not introduce new safety risks or degrade the overall effectiveness of the predicate device, as evaluated through risk analysis and functional testing.

    8. The Sample Size for the Training Set

    Not applicable. This is not an AI/machine learning device that requires a training set of data.

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

    Not applicable, as there is no training set for an AI algorithm.

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