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510(k) Data Aggregation

    K Number
    K214062
    Manufacturer
    Date Cleared
    2022-02-04

    (39 days)

    Product Code
    Regulation Number
    892.1200
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Radialis PET Camera is intended for medical purposes to image and measure the distribution of injected positron emitting radiopharmaceuticals in human beings for the purpose of determining various metabolic and physiologic functions within the human body.

    Device Description

    The Radialis PET Camera is a high spatial resolution, small field-of-view PET imaging camera specifically developed for close-range, organ-targeted (i.e., limited field) imaging. The Radialis PET Camera is a partial-ring planar PET camera, equipped with lutetium-containing gamma-ray detectors, which collect gamma rays emitted by injected positron-emitting radiopharmaceuticals, and generates images corresponding to the relative concentrations of these radiopharmaceuticals in the body. The Radialis PET Camera is designed to collect gamma rays emitted by the injected radiopharmaceutical in a patient's body part with high efficiency.

    AI/ML Overview

    The Radialis PET Camera is intended for medical purposes to image and measure the distribution of injected positron emitting radiopharmaceuticals in human beings for the purpose of determining various metabolic and physiologic functions within the human body.

    Here's an analysis of the acceptance criteria and the study information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided text does not explicitly state quantitative acceptance criteria in a table format for performance metrics. Instead, it lists various performance aspects that were tested and states that the device "complies with its predetermined specifications and with applicable standards." The "Reported Device Performance" is generally descriptive rather than numerical.

    Performance AspectAcceptance Criteria (Implicit/General)Reported Device Performance
    RadiationCompliance with applicable standardsTested and found compliant
    ResolutionMeets predetermined specificationsTested and found compliant; images demonstrate high-resolution
    Spatial LinearityMeets predetermined specificationsTested and found compliant
    System SensitivityMeets predetermined specificationsTested and found compliant
    Flood Field UniformityMeets predetermined specificationsTested and found compliant
    CoincidenceMeets predetermined specificationsTested and found compliant
    ScatterMeets predetermined specificationsTested and found compliant
    Imaging WorkflowMeets predetermined specificationsTested and found compliant
    NotificationsMeets predetermined specificationsTested and found compliant
    CleaningMeets predetermined specificationsTested and found compliant
    LifecycleMeets predetermined specificationsTested and found compliant
    BiocompatibilityCompliance with applicable standardsPatient contact material tested and found compliant
    Electrical Safety / Electromagnetic CompatibilityCompliance with AAMI / ANSI ES60601-1:2005/(R)2012 and IEC 60601-1-2:2014Undergone testing and found compliant
    Software TestingCompliance with IEC 62304 and FDA GuidanceDesigned and developed according to robust SDLC, rigorously verified and validated

    2. Sample Size for the Test Set and Data Provenance

    The non-clinical testing included an imaging study with:

    • Sample Size for Test Set: Three (3) patients.
    • Data Provenance: Not specified, but the submission is from a Canadian company (Radialis Inc. Suite 2300B, 290 Munro Street Thunder Bay, Ontario P7A 7T1 Canada), so the data could be from Canada. The study type is presumably prospective in nature for these three patients to acquire images for demonstration.

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

    This information is not provided in the document. The text states "Three (3) patients were imaged with the Radialis PET Camera and the images were provided. The images demonstrate the high-resolution image capability of the Radialis PET Camera." There is no mention of experts reviewing these images to establish a ground truth.

    4. Adjudication Method for the Test Set

    This information is not provided in the document. Given the limited description of clinical imaging (only 3 patients for demonstration), it's unlikely a formal adjudication process was described for these images.

    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 done. The submission focuses on the technical performance and substantial equivalence of the device itself, not on human reader performance with or without AI assistance. The device in question is a PET Camera, not an AI diagnostic tool that assists human readers.

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

    The Radialis PET Camera is a hardware device (an Emission Computed Tomography System), not an algorithm that performs standalone analysis. Therefore, a standalone algorithm performance study as typically defined for AI/ML devices was not done. The "performance testing" described refers to the functional performance of the hardware and its associated software for image acquisition and processing.

    7. The Type of Ground Truth Used

    For the very limited "clinical images" set (3 patients), the type of ground truth used is not explicitly stated. However, the purpose was to "demonstrate the high-resolution image capability." This suggests the images were likely reviewed based on visual assessment of image quality, potentially against expected physiological distribution of radiopharmaceuticals, rather than a definitive "ground truth" for a diagnostic task (e.g., pathology, outcomes).

    For the broader performance testing (Resolution, Sensitivity, etc.), the "ground truth" would be established by physical phantom measurements and documented engineering specifications conforming to NEMA NU 4:2008 and other relevant standards.

    8. The Sample Size for the Training Set

    This device appears to be a traditional medical imaging device (PET Camera) and not an AI/ML device that requires a "training set" in the context of machine learning. The section on "Software Testing" refers to robust software development processes, verification, and validation, but this pertains to the software functionality of the imaging system, not an AI model trained on a dataset. Therefore, there is no mention of a training set sample size.

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

    As there is no mention of a training set, this question is not applicable.

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