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510(k) Data Aggregation

    K Number
    K212056
    Date Cleared
    2021-08-04

    (34 days)

    Product Code
    Regulation Number
    892.1000
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Vantage Galan 3T systems are indicated for use as a diagnostic imaging modality that produces cross-sectional transaxial, coronal, sagittal, and oblique images that display anatomic structures of the head or body. Additionally, this system is capable of non-contrast enhanced imaging, such as MRA.

    MRI (magnetic resonance imaging) images correspond to the spatial distribution of protons (hydrogen nuclei) that exhibit nuclear magnetic resonance (NMR). The NMR properties of body tissues and fluids are:

    ·Proton density (PD) (also called hydrogen density)

    • ·Spin-lattice relaxation time (T1)
    • ·Spin-spin relaxation time (T2)
    • ·Flow dynamics
    • ·Chemical Shift

    Depending on the region of interest, contrast agents may be used. When interpreted by a trained physician, these images vield information that can be useful in diagnosis.

    Device Description

    The Vantage Galan (Model MRT-3020) is a 3 Tesla Magnetic Resonance Imaging (MRI) System, previously cleared under K203553. This system is based upon the technology and materials of previously marketed Canon Medical Systems and is intended to acquire and display crosssectional transaxial, coronal, sagittal, and oblique images of anatomic structures of the head or body.

    AI/ML Overview

    This FDA 510(k) summary describes modifications to an existing device, the Vantage Galan 3T MRI system with AiCE Reconstruction Processing Unit, rather than a completely new device. Therefore, the "study" described focuses on validating that the changes do not negatively impact the device's performance or safety compared to the previously cleared predicate device.

    Here's an analysis based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state acceptance criteria in a quantitative table format for performance metrics. Instead, it demonstrates through testing that the device modifications meet existing safety and image quality standards and are equivalent to the predicate device. The performance reports are qualitative confirmations that the changes do not degrade performance.

    Parameter TestedAcceptance Criteria (Implied)Reported Device Performance
    Image Quality: Image Homogeneity (Rx/Tx Correction Plus)Improved homogeneity compared to images without intensity correction."Rx/Tx Correction Plus increases the homogeneity of the image compared to the image without intensity correction."
    Image Quality: Distortion (Expanded SPEEDER)Reduced distortion due to magnetic field inhomogeneity with increased acceleration factor."It was confirmed that the distortion due to magnetic field inhomogeneity was reduced by increasing the Exsper acceleration factor."
    Image Quality: Low Contrast (Expanded SPEEDER)Maintain acceptable low contrast performance.Not explicitly quantified, but implied to be acceptable as part of overall performance validation and substantial equivalence.
    Image Quality: SNR (Expanded SPEEDER)Maintain acceptable Signal-to-Noise Ratio (SNR) performance.Not explicitly quantified, but implied to be acceptable as part of overall performance validation and substantial equivalence.
    Software Functionality (EPI, FSE 2D, FFE 2D/3D, Double Coverage Interleave)All new/modified software features function as intended and meet system requirements."Risk Management activities for new software functionalities and pulse sequences are included in this submission. The test methods used are the same as those submitted in the previously cleared submission... A declaration of conformity with design controls is included in this submission."
    Patient Belt Material ChangeNo adverse impact on patient safety or device function.Implicitly covered by risk analysis and overall safety assessment.
    Safety Parameters (Static field strength, Operational Modes, SAR, dB/dt, Emergency shutdown)Match predicate device specifications.All listed as "Same" as the predicate device.

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

    • Sample Size: The document mentions "phantom images" for image quality metrics and "volunteer clinical imaging" but does not specify numerical sample sizes for either.
    • Data Provenance: The document does not specify the country of origin of the data. It mentions "bench testing" and "volunteer clinical imaging" as testing methods, implying a prospective collection for the purpose of this submission, but no further details are given.

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

    The document does not provide details on experts used to establish ground truth for the test set. For a device like an MRI system with software modifications, ground truth validation usually involves quantitative image quality metrics using phantoms, and potentially qualitative assessment by radiologists in clinical imaging, but this is not explicitly detailed here.

    4. Adjudication Method for the Test Set

    The document does not describe any adjudication method (e.g., 2+1, 3+1) for the test set.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not explicitly mentioned or described in this document. The submission is for modifications to a cleared device and focuses on establishing substantial equivalence and safety, not on demonstrating improved diagnostic accuracy with human-AI assistance.

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

    The focus of the testing mentioned (image homogeneity, distortion, SNR, low contrast, software functionality) primarily aligns with standalone algorithm performance as applied to image reconstruction and quality. The "AiCE Reconstruction Processing Unit" is an AI-powered reconstruction technology, and the tests would assess its direct impact on image characteristics. However, there isn't a specific section titled "standalone performance study" with detailed metrics outside of the general image quality evaluations.

    7. The Type of Ground Truth Used

    • For image quality metrics (homogeneity, distortion, SNR, low contrast), the ground truth is often established via physical phantoms with known properties and computational models.
    • For software functionality, the ground truth is adherence to design specifications and system requirements.
    • For clinical imaging validation, the "ground truth" often refers to a consensus reading by expert radiologists, but details here are absent.

    8. The Sample Size for the Training Set

    The document does not refer to a "training set" in the context of this submission. The AiCE Reconstruction Processing Unit (which likely uses AI) was part of the predicate device (K203553). This submission is for modifications to the system around that already cleared AI component (e.g., new pulse sequences, increased acceleration factors). Therefore, details about the training data for AiCE itself would have been part of the K203553 submission, not this one.

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

    As explained above, this submission focuses on modifications to a previously cleared device. Information regarding the training set and its ground truth for the AiCE Reconstruction Processing Unit would have been established during the development and clearance of the predicate device (K203553). This document does not provide those details.

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