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510(k) Data Aggregation

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

    The intended use of the Affiniti 30, Affiniti 70 Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body with the following Indications for Use: Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculoskeletal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Transesophageal (Cardiac), Transrectal, Transvaginal.

    The clinical environments where the Affiniti Diagnostic Ultrasound Systems can be used include Clinics, and clinical point-of-care for diagnosis of patients.

    When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live Echo Guidance. The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information, and only for the purposes for which it was designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgment and best clinical procedure.

    Philips CX50 Diagnostic Ultrasound Systems is intended for diagnostic ultrasound imaging in B (or 2- D), M-mode (including Anatomical M-mode), Pulse Wave Doppler, Continuous Wave Doppler, Color Doppler, Tissue Doppler Imaging and Harmonics (Tissue and Contrast) modes.

    It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications: Ophthalmic Intraoperative Laparoscopic Fetal Abdominal Pediatric Small Organ Adult Cephalic Neonatal Cephalic Trans-vaginal Musculo-skeletal Gynecological Cardiac Pediatric Trans-Esoph. (Cardiac) Intracardiac echo Peripheral Vessel Other (Carotid)

    The intended use of the EPIQ, EPIQ 7 is diagnostic ultrasound imaging and fluid flow analysis of the human body with the following Indications for Use: Abdominal, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult), Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculoskeletal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal.

    The clinical environments where the EPIQ Diagnostic Ultrasound Systems can be used include Clinics, Hospitals, and clinical point-of-care for diagnosis of patients.

    When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live Echo Guidance. The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information, and only for the purposes for which it was designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgment and best clinical procedure.

    Philips Lumify Diagnostic Ultrasound System is intended for diagnostic ultrasound imaging in B (2D), Color Doppler, Combined (B+Color), and M modes. It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications: Fetal/Obstetric, Abdominal, Pediatric, Cephalic, Urology, Gynecological, Cardiac Fetal Echo, Small Organ, Musculoskeletal, Peripheral Vessel, Carotid, Cardiac. Lumify is a transportable ultrasound system intended for use in environments where healthcare is provided by healthcare professionals.

    QLAB Advanced Quantification Software is a software application package. It is designed to view and quantify image data acquired on Philips ultrasound systems.

    Philips Sparq Diagnostic Ultrasound System is intended for diagnostic ultrasound imaging in B (or 2- D), M-mode (including Anatomical M-mode), Pulse Wave Doppler, Continuous Wave Doppler, Color Doppler, Tissue Doppler Imaging and Harmonics (Tissue and Contrast) modes. It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications: Ophthalmic Fetal Abdominal Pediatric Small Organ Adult Cephalic Trans-vaginal Trans-rectal Musculo-skeletal Gynecological Cardiac Adult Trans-Esoph. (Cardiac) Peripheral Vessel.

    Device Description

    Philip Diagnostic Ultrasound Systems are durable, reusable capital equipment medical devices which are intended for high-resolution general imaging, interventional radiology, cardiology, vascular and OB/GYN applications and fluid flow analysis. They are intended to be used by trained professionals at various settings of patient care such as clinical admission, periodic evaluations, prior to hospitalization discharge, and/or academic research, via maneuverable caster wheels or mobile handheld components.

    Philips QLAB Advanced Quantification software (QLAB) is designed to view and quantify image data acquired on Philips ultrasound systems. QLAB is available either as a stand-alone product that can function on a standard PC, a dedicated workstation, and on-board Philips' Diagnostic Ultrasound Systems.

    Software modes/applications, scanning protocols, and pre-installed settings or functionality to create dedicated settings for imaging of specific anatomy are available with the subject Philips Diagnostic Ultrasound Systems and QLAB software and may vary among model configurations.

    The diagnostic ultrasound systems are manufactured with hardware components which consist of:

    • a primary console (e.g., workstation, tablet) with built-in software components, features, and 1) various clinical applications, and
      1. a range of compatible ultrasound transducers.

    A suite of compatible transducer types are offered such as transesophageal echocardiography (TEE) transducers, non-imaging (pencil) probes, curved array, linear array and sector/ohased array transducer models which have a prefix "C" are designed to provide larger fields of view and penetration for e.g., consolidation between bone spaces while linear array transducer models, which can be identified with a "L" prefix model name are designed to provide shallow visualization which are optimal for tissue layer interfaces. Sector/phased array transducer models which usually have a "S" prefix model names are designed to be applied for difficult anatomical sites (e.g., cardiac intercostal space (ICS)). Other Philips ultrasound transducers may also start with the prefix "X" which is referring to the xMatrix technology for two full-resolution planes of imaging. Volumetric three-dimensional (3D) imaging functionality is also available when specific transducer models are connected to the primary console. Philips ultrasound transducers may be bagged into compatible transducer/probe cover sheaths, designed by other manufacturers, for each procedure to prevent cross-contamination and reduce the risk of healthcareassociated infections.

    Some configurations may have additional previously-cleared accessories, components and software features which are manufactured by Philips Ultrasound, Inc. or other manufacturers.

    AI/ML Overview

    This document is a 510(k) Premarket Notification from Philips Ultrasound, Inc. to the FDA regarding several of their diagnostic ultrasound systems and software. The primary purpose of this submission is not to present performance data for a new device that meets acceptance criteria, but rather to assert substantial equivalence to previously cleared predicate devices for expanded labeling related to COVID-19.

    Therefore, the requested information regarding acceptance criteria and a study proving the device meets them, including sample sizes, ground truth establishment, expert qualifications, and comparative effectiveness studies, does not apply in the traditional sense for a new device submission with novel performance claims.

    Instead, the submission states:

    1. A table of acceptance criteria and the reported device performance:

    • There is no specific table of acceptance criteria or reported device performance for novel features in this submission.
    • The document focuses on establishing technological characteristic equivalence between the subject devices and their respective predicate devices.
    • Table 1, Table 2, Table 3, Table 4, Table 5, and Table 6 (spanning pages 13-25) provide a technological comparison for each subject device (Philips Lumify, EPIQ, Affiniti, CX50, Sparq, and QLAB software) against its predicate device. For all listed "Standard Features" (Indications for Use, Reusable?, Duration of Use, Scientific Technology, Operating principles, Type of Previously-cleared Transducers, Acoustic Outputs Within Range?, Previously cleared Imaging Modes?, Biocompatibility), the comparison consistently states "Identical." This indicates that no new performance metrics or acceptance criteria beyond those already established for the predicate devices are being introduced for new functionalities.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    • Not applicable. The submission does not describe a new performance study requiring a test set. It relies on the equivalence of the subject devices to their predicate devices, which would have undergone performance testing for their initial clearances.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):

    • Not applicable. No new ground truth establishment is described in this submission.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    • Not applicable. No new performance study or test set requiring adjudication is 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. No MRMC study is mentioned. The submission is for existing ultrasound systems and software with expanded labeling, not for AI-assisted diagnostic tools requiring such studies for comparative effectiveness.

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

    • Not applicable. While QLAB is software, the submission primarily focuses on maintaining substantial equivalence in its current functionality and expanding labeling. No new standalone algorithm performance is detailed.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

    • Not applicable. No new ground truth is described. The established safety and effectiveness of the predicate devices implicitly relied on various forms of ground truth relevant to diagnostic ultrasound at the time of their clearance.

    8. The sample size for the training set:

    • Not applicable. This submission does not involve a new machine learning algorithm or a training set.

    9. How the ground truth for the training set was established:

    • Not applicable. This submission does not involve a new machine learning algorithm or a training set.

    Summary of the Submission's Approach:

    The core of this 510(k) submission is to assert that the subject devices (various Philips Diagnostic Ultrasound Systems and QLAB software) are substantially equivalent to their respective predicate devices. The significant change being addressed is the "Expanded Labeling" to include information about lung and cardiac ultrasound imaging for COVID-19 patients, based on established methods or the latest society guidelines. The submission explicitly states:

    • "Relevant performance data does not apply to this submission." (Page 26)
    • "There are no changes in software, hardware, and intended uses of the subject devices comparing to the predicates." (Page 26)
    • "The results of the design controls activity support a determination that the subject devices do not raise new questions of safety or effectiveness and are substantially equivalent to the predicate devices." (Page 26)

    Therefore, the "study" proving the device meets "acceptance criteria" is essentially the argument of identical technological characteristics and unchanged intended uses compared to the already cleared predicate devices, with the new labeling information being based on general clinical practice and guidelines rather than new device-specific performance data.

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