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510(k) Data Aggregation
(126 days)
Halcyon and Ethos radiotherapy system are indicated for the delivery of stereotactic radiosurgery and precision radiotherapy for lesions, tumors, and conditions anywhere in the body where radiation is indicated for adults and pediatric patients.
Halcyon and Ethos radiotherapy system with the HyperSight imaging feature produce kV CBCT anatomical images that can be used in the simulation and planning of radiation therapy.
Halcyon and Ethos Radiotherapy System are single energy medical linear accelerators (linacs) designed to deliver Image Guided Radiation Therapy and radiosurgery, using Intensity Modulated and Volumetric Modulated Arc Therapy techniques. They consist of the accelerator and patient support within a radiation shielded treatment room and a control console outside the treatment room.
An electron gun generates electrons which are accelerated by radio frequency (RF) power from a magnetron. The electrons strike a tungsten target producing photons (X-rays) for treatment and MV Imaging. The photons produced by the target are monitored and controlled by a pressurized ion chamber.
A beam collimation subsystem consisting of a primary and secondary collimator and two stacked multileaf collimators (MLCs) shapes the photon beam to define the treatment area.
X-Ray images of the patient are used by the treater to verify the correct treatment location. MV Imaging uses the treatment beam and a flat panel imager whereas kV imaging uses a high-capacity kV X-ray tube, a kV collimation system with full fan bowtie filter with movable y-blades to define the imaging beam size and to capture the image, a kV imager.
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(185 days)
The Elekta Medical Linear Accelerator (EMLA) is intended to be used for external beam radiation therapy (EBRT) treatments as determined by a licensed medical practitioner.
It is intended to assist a licensed medical practitioner in the delivery of EBRT to defined target volumes, while sparing surrounding normal tissue and critical organs from excess radiation.
Elekta Synergy and Elekta Harmony are the default entry-level configurations. It is intended to be used for single or multiple fractions using standard dose fractionation, hyperfractionation, and hypofractionation in all areas of the body where such treatment is indicated.
Elekta Infinity and Elekta Harmony Pro are the default mid-level configuration. It is intended to be used for single or multiple fractions using standard dose fractionation, hyperfractionation, hypofractionation and stereotactic delivery (stereotactic body radiation therapy – SBRT; stereotactic ablative radiotherapy – SABR) in all areas of the body where such treatment is indicated.
Versa HD and Elekta Evo are the default high-level configuration. It is intended to be used for single or multiple fractions using standard fractionation, hyperfractionation, hypofractionation and stereotactic delivery (stereotactic body radiation therapy – SBRT; stereotactic ablative radiotherapy – SABR; stereotactic radio surgery - SRS) in all areas of the body where such treatment is indicated and for the treatment of functional disorders, such as trigeminal neuralgia.
The EMLA is indicated for the delivery of curative and palliative intent EBRT to Adult and Pediatric patients with primary benign and malignant tumor and metastasis (or secondaries) anywhere in the body.
The Elekta Medical Linear Accelerator (EMLA) is an external beam, image guided Radiation Therapy device to assist a licensed practitioner in the delivery of ionizing radiation to a defined target volume. The system is located in a radiation-shielded treatment room and consists of several sub-systems, such as, the electron accelerator, beam shaping, imaging, computerized control systems and a treatment table to support the patient with accessories for patient positioning and set-up to deliver therapeutic treatments.
The EMLA is equipped with a MV portal imaging sub-system, i.e. iViewGT, and an optional kV imaging sub-system, i.e. XVI. The table is capable of linear and rotational movements.
The user interface controlling devices are located partly in the treatment room and partly in the control room.
The EMLA is made available in the following models: Elekta Synergy, Elekta Harmony, Elekta Infinity, Elekta Harmony Pro, Versa HD, Elekta Evo. The major differences are described in section VII.
The provided FDA 510(k) clearance letter and summary for the Elekta Medical Linear Accelerator (EMLA) describes performance testing for differences between the subject devices (new EMLA models) and the predicate devices (older EMLA models, K210500). The primary focus of the performance testing detailed in the summary is related to improvements in CBCT image quality and reconstruction.
Here’s a breakdown of the requested information based on the provided text:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly present a table of quantitative acceptance criteria alongside corresponding reported device performance values. Instead, it describes general improvements and conformance to standards. The acceptance is implicitly based on meeting or exceeding the predicate device's performance, especially for the high-definition (HD) reconstruction.
| Acceptance Criterion (Implicit) | Reported Device Performance (Summary of Test Results) |
|---|---|
| Conformance to applicable consensus standards (e.g., IEC 60601-2-68 for image quality, IEC 60601-2-1 Ed. 4 for Linac control) | Test results showed conformance of the subject devices to the applicable consensus standards, Elekta defined performance specifications, and associated risk management requirements. |
| FDK based reconstruction function: image quality for IGRT (uniformity, spatial resolution, low contrast visibility, geometric accuracy) | Improved image quality in uniformity, volume outline, and spatial resolution compared to the predicate device, with no adverse impact on registration accuracy. |
| FDK based reconstruction function: image registration accuracy | Accurate registration. The conclusion mentions "no adverse impact to the accuracy of registration" for the FDK based an improved FDK based reconstruction function. |
| HD Reconstruction function (pelvic anatomies): improved image quality for IGRT (uniformity, HU consistency, SNR, CNR, contrast consistency) compared to FDK based reconstruction | Image quality improved in terms of better uniformity and HU accuracy. Improved image quality results in better performance of the automatic registration function, often not requiring manual adjustment. Clinical survey showed a preference for HD Reconstruction over the predicate. |
| HD Reconstruction function (pelvic anatomies): image registration accuracy compared to FDK based reconstruction | Improved image quality often leads to better performance of the automatic registration function, not requiring any manual adjustment post registration. |
| HD Reconstruction function: Clinical image quality (qualitative comparison) | Users qualitatively compared image quality between the predicate device and the subject device, reporting improved image quality. Clinical survey showed a preference towards the HD Reconstruction of the subject device over the predicate. |
| Cybersecurity improvements for linac and imaging system control | The control system for the subject device has improvements to cybersecurity; enables compliance with IEC 60601-2-1 Ed. 4; supports an integrated beam gating interface in compliance with IEC 60601-2-1 Ed. 4 and based on NEMA RT 1-2014 standard. |
| Functional performance characteristics (e.g., photon and electron energy/dose rates) | Most characteristics are "Same" as predicate (e.g., dose rates). Harmony Pro supports more photon and electron energies than predicate Harmony. Subject Synergy uses Agility BLD (which covers MLCi2 performance) whereas predicate Synergy supports both. Elekta Evo supports HexaPOD evo RT System (highest performance). All subject devices conform to the same patient-contact materials and rely on predicate device test data where technological characteristics are the same. |
2. Sample size used for the test set and the data provenance
- FDK based reconstruction function (Image Quality Evaluation): "acquired image quality phantom data" - Specific sample size not provided, likely laboratory phantom data.
- FDK based reconstruction function (Image Registration Accuracy): "phantom data and CT reference data" - Specific sample size not provided, likely laboratory phantom data.
- HD Reconstruction vs. FDK (Image quality comparison - clinical data sets): A total of 124 different clinical data sets.
- HD Reconstruction vs. FDK (Image registration accuracy - clinical patient CBCT projection data sets): A total of 13 different clinical patient CBCT projection data sets.
- HD Reconstruction vs. FDK (Clinical image quality evaluation - clinical patient data): Specific number of patients/data sets not explicitly stated, but clinical patient data was used for qualitative comparison.
Data Provenance: The document does not explicitly state the country of origin for the clinical data or explicitly state whether it was retrospective or prospective. Given it's clinical data sets for evaluating reconstruction, it's highly likely to be retrospective data collected from clinical operations.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document states:
- For the FDK based reconstruction: "reconstruct a CBCT volume image which is suitable for visualizing anatomies to enable certain clinical judgment" - this implies expert judgment in assessment, but does not specify the number or qualifications.
- For the HD Reconstruction: "suitable for visualizing the pelvic anatomies to enable certain clinical judgment".
- "A clinical image quality evaluation was performed between HD Reconstruction function and FDK based reconstruction function, using clinical patient data, where user qualitatively compared image quality between the predicate device and the subject device and reported improved image quality." - This indicates qualitative evaluation by "user", but the number and specific qualifications (e.g., radiologist with X years of experience) are not defined. The document also mentions "Formal validation of the clinical workflows has been performed by competent and professionally qualified personnel" but does not specify them in relation to ground truth establishment for the test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
The document does not describe a formal adjudication method (like 2+1 or 3+1 consensus) for establishing ground truth or evaluating the clinical image quality. It generally refers to qualitative comparison by "user" or "competent and professionally qualified personnel".
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
The document mentions "A clinical image quality evaluation was performed between HD Reconstruction function and FDK based reconstruction function, using clinical patient data, where user qualitatively compared image quality between the predicate device and the subject device and reported improved image quality." It also notes "A clinical survey shows a preference towards the HD Reconstruction of the subject device over the predicate."
This suggests a form of reader study or survey was conducted, where users (human readers) compare images from the legacy FDK method (without the new AI-ML component) to the HD Reconstruction (which "includes an AI-ML based component to estimate the scatter"). However, it's not explicitly labeled as a "multi reader multi case (MRMC) comparative effectiveness study" in the formal sense, and no quantitative effect size of improvement for human readers is provided. The improvement is described qualitatively (e.g., "improved image quality," "better uniformity and HU accuracy," "preference").
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, standalone algorithm performance evaluation was done for the FDK and HD reconstruction functions. This is evident from:
- "Image quality evaluation was performed for the FDK based reconstruction function, using acquired image quality phantom data, to evaluate uniformity, spatial resolution, low contrast visibility, and geometric accuracy in accordance with IEC 60601-2-68;"
- "Image quality comparison was performed between HD Reconstruction function and FDK based reconstruction function, using data acquired on phantom data, to evaluate uniformity, spatial resolution, low contrast visibility, and geometric accuracy in accordance with IEC 60601-2-68."
- "Image quality comparison was performed between HD Reconstruction function and FDK based reconstruction function, using a total of 124 different clinical data sets, to evaluate uniformity, Hounsfield Unit consistency, signal-to-noise ratio, contrast-to-noise ratio, and contrast consistency."
These evaluations measure the intrinsic performance of the reconstruction algorithms without explicit human interaction beyond setting up the evaluation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The types of ground truth used include:
- Phantom Data: For evaluating image quality metrics (uniformity, spatial resolution, low contrast visibility, geometric accuracy) and image registration accuracy (against CT reference data). Phantoms often have known properties or are designed to allow for quantitative measurement of image accuracy.
- CT Reference Data: Used for comparing image registration accuracy. CT imaging is considered a high-fidelity reference.
- Clinical Patient Data: Used for comparing various image quality metrics (Hounsfield Unit consistency, signal-to-noise ratio, contrast-to-noise ratio, contrast consistency) and for qualitative "user" comparison of image quality. The "ground truth" for clinical image quality comparison would effectively be the subjective assessment of the users or experts performing the comparison against each other, and against the clinical utility standards.
- Simulated Monte Carlo data: Used to train the neural network component of the HD reconstruction that estimates scatter. This implies a simulated ground truth for scatter estimation.
8. The sample size for the training set
The document states: "It includes an AI-ML based component to estimate the scatter to enable its automatic removal from the projection images acquired by the imager ahead of the volume reconstruction. Simulated Monte Carlo data is used to train the network."
The specific sample size for the training set (i.e., the amount of simulated Monte Carlo data) for the AI-ML component is not provided.
9. How the ground truth for the training set was established
The ground truth for the training set of the AI-ML component was established through Simulated Monte Carlo data. Monte Carlo simulations are a computational method that can model the physical interactions of radiation with matter, providing a "ground truth" for scatter estimation in this context.
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(30 days)
ExacTrac Dynamic is intended to position patients at an accurately defined point within the treatment beam of a medical accelerator for stereotactic radiosurgery or radiotherapy procedures, to monitor the patient position and to provide a beam hold signal in case of a deviation in order to treat lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.
ExacTrac Dynamic (ETD) is a patient positioning and monitoring device used in a radiotherapy environment as an add-on system to standard linear accelerators (linacs). It uses radiotherapy treatment plans and the associated computed tomography (CT) data to determine the patient's planned position and compares it via oblique X-ray images to the actual patient position. The calculated correction shift will then be transferred to the treatment machine to align the patient correctly at the machine's treatment position. During treatment, the patient is monitored with a thermal-surface camera and X-ray imaging to ensure that there is no misalignment due to patient movement. Positioning and monitoring are also possible in combination with implanted markers. By defining the marker positions, ExacTrac Dynamic can position the patient by using X-rays and thereafter monitor the position during treatment.
Additionally, ExacTrac Dynamic features a breath-hold (BH) functionality to serve as a tool to assist respiratory motion management. This functionality includes special features and workflows to correctly position the patient at a BH level and thereafter monitor this position using surface tracking. Regardless of the treatment indication, a correlation between the patient's surface and internal anatomy must be evaluated with Image-Guided Radiation Therapy. The manually acquired X-ray images support a visual inspection of organs at risk (OARs). The aim of this technique is to treat the patient only during breath hold phases where the treatment target is at a certain position to reduce respiratory-induced tumor motion and to ensure a certain planned distance to OARs such as the heart. In addition to the X-ray based positioning technique, the system can also monitor the patient after external devices such as Cone-Beam CT (CBCT has been used to position the patient).
The ExacTrac Dynamic Surface (ETDS) is a camera-only platform without the X-ray system and is available as a configuration which enables surface-based patient monitoring. This system includes an identical thermal-surface camera, workstation, and interconnection hardware to the linac as the ETD system. The workflows supported by ETDS are surface based only and must be combined with an external IGRT device (e.g., CBCT).
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(109 days)
ChartCheck is intended to assist with the quality assessment of radiotherapy treatment plans and on treatment review.
The ChartCheck device is software that enables trained radiation oncology personnel to perform quality assessments of treatment plans and treatment chart reviews utilizing plan, treatment, imaging, as well as documentation data obtained from an Oncology Information System database(s).
ChartCheck contains 3 main components:
a. An agent service that is configured by the user to monitor an Oncology Information System (OIS) database. The agent watches for new treatment plans, treatment records, documentation, and images. The agent uploads data to a checking service.
b. A checking service that compares the treatment records to the treatment plan and calculates check states as new records are uploaded from the agent. The checking service processes on-treatment imaging data and interfaces with outside software platforms for dose calculation activities.
c. A web application accessed via a web browser that contains several components.
i. Chart checking mode, which allows a medical physicist to review treatment records and check state results, record chart check comments, and mark the chart check as approved.
ii. An image viewer that allows a medical physicist to review on-treatment imaging, on-treatment dose calculation results, and perform deformable registration editing.
iii. Settings mode, which allows an administrator to set check state colors, configure settings, define check state templates, set up check alerts, documentation generation, and billing settings.
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(95 days)
IDENTIFY is indicated for adult patients undergoing radiotherapy treatment simulation and/or delivery. IDENTIFY is indicated for positioning of patients, and for monitoring patient motion including respiratory patterns. It allows for data output to radiotherapy devices to synchronize image acquisition or treatment delivery with the acquired motion information.
IDENTIFY uses surface guidance technology to monitor patient motion during radiotherapy treatment simulation and delivery. Its high precision SGRT cameras support:
- Positioning of the patient for treatment delivery
- Monitoring of the patient position during treatment delivery
- Respiratory motion management during simulation and treatment delivery
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(231 days)
AccuCheck is a quality assurance software to the quality assurance of general offline planning, online adaptive planning and various radiotherapy technology such as photon and proton. It is used for data transfer integrity check, secondary dose calculation with Monte Carlo algorithm, and treatment plan verification in radiotherapy. AccuCheck also provides independent dose verification based on Accelerator delivery log after radiotherapy plan execution.
AccuCheck is not a treatment planning system or a radiation delivery device. It is to be used only by trained radiation oncology personnel for quality assurance purposes.
AccuCheck, defined as a radiotherapy plan quality assurance system, aims to improve the clinical efficiency of offline and online quality control. AccuCheck supports Monte Carlo dose calculation engine, and is applicable to the quality assurance of general offline planning, online adaptive planning and various radiotherapy technology such as photon and proton.
AccuCheck is to be used for the quality assurance of offline plans and online adaptive radiotherapy plans, where the TPS Check module is used to check whether the parameters related to treatment plan are within the executable range of the machine; the Dose Check module is designed to use an independent dose calculation engine to re-calculate the original plan before the treatment, and is compared with the dose of the original plan; the Transfer Check module could verify whether errors are occurred during transferring from the TPS system to the accelerator; the Log Check module is used to obtain execution log of each execution of the accelerator, calculate dose through an independent dose calculation engine, and compare it with the dose of original plan; Treatment Summary supports physical dose accumulation of doses executed multiple times for a single plan, which reflect the stability of the accelerator operating, it could at the same time support the reconstruction of log to the fractional images so as to evaluate the daily exposure dose of the patient. AccuCheck provides abundant auxiliary analysis tools, including DVH Graph, Gamma Analysis, Target Coverage, Gamma Pass Rate of each ROI, Dose Statistics, and Clinical Goals Evaluation.
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(205 days)
The MOSkin radiation measurement system intended use is a dosimeter to measure radiation dose delivered by a radiation source to the location of an Radiation Dosimeter (RD) sensor on the patient in a clinical use environment. The system is intended for the verification of the output of radiation producing devices.
The output of the system is not used to directly adjust the radiation dose to the patient.
The Electrogenics Laboratories Ltd MOSkin Radiation Measurement System consists of the following components to provide secondary verification of dose from various radiotherapy and diagnostic imaging devices:
- MOSFET (Si-based metal-oxide-semiconductor field-effect transistor) Dosimeter (RD) to record radiation during radiation exposure.
- Reading device (HUB) for reading the radiation dose recorded by the dosimeter.
- MOSkin Software Application, a simple software tool that the user interacts with for radiation dose calculation, dose reporting, managing and storing data.
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(21 days)
The TrueBeam™, TrueBeam STx and Edge™ Systems are intended to provide stereotactic radiosurgery and precision radiotherapy for lesions, tumors, and conditions anywhere in the body where radiation therapy is indicated for adults and pediatric patients. The TrueBeam radiotherapy system can produce CBCT images that can be used in image guided radiation therapy, and the simulation and planning for adaptive radiation therapy.
The TrueBeam, TrueBeam STx and Edge Systems may be used in the delivery of radiation for treatment that includes: brain and spine tumors (such as glioma, meningioma, craniopharyngioma, pituitary tumors, spinal cord tumors, hemangioblastoma, orbital tumors, ocular tumors, optic nerve tumors, and skull based tumors), head and neck tumors (such as unknown primary of the head and neck, oral cavity, hypopharynx, larynx, oropharynx, nasopharynx, sinonasal, salivary gland, and thyroid cancer), thoracic tumors (such as lung cancer, esophageal cancer, thymic tumors, and mesothelioma), gynecologic tumors (such as ovarian, cervical, endometrial, vulvar, and vaginal), gastrointestinal tumors (such as gastric, pancreatic, hepatobiliary, colon, rectal, and anal carcinoma), genitourinary tumors (such as prostate, bladder, testicular, and kidney), breast tumors, sarcomas, lymphoid tumors (such as Hodgkin's and non-Hodgkin's lymphoma), skin cancers (such as squamous cell, basal cell, and melanoma), benign diseases (such as schwannoma, arteriovenous malformation, cavernous malformation, trigeminal neuralgia, chordoma, glomus tumors, hemangiomas, and medically refractory essential tremor (indicated for adults only)), metastasis (including all parts of the body such as brain, bone, liver, lung, kidney, and skin), pediatric tumors (such as glioma, ependymoma, pituitary tumors, hemangioblastoma, craniopharyngioma, meningioma, metastasis, medulloblastoma, nasopharyngeal tumors, arteriovenous malformation, cavernous malformation, and skull base tumors), and low-dose radiotherapy for adults with medically refractory osteoarthritis.
VitalBeam® is intended to provide stereotactic radiosurgery and precision radiotherapy for lesions, tumors, and conditions anywhere in the body where radiation therapy is indicated for adults and pediatric patients.
VitalBeam may be used in the delivery of radiation for treatment that includes: brain and spine tumors (such as glioma, meningioma, craniopharyngioma, pituitary tumors, spinal cord tumors, hemangioblastoma, orbital tumors, ocular tumors, optic nerve tumors, and skull based tumors), head and neck tumors (such as unknown primary of the head and neck, oral cavity, hypopharynx, larynx, oropharynx, nasopharynx, sinonasal, salivary gland, and thyroid cancer), thoracic tumors (such as lung cancer, esophageal cancer, thymic tumors, and mesothelioma), gynecologic tumors (such as ovarian, cervical, endometrial, vulvar, and vaginal), gastrointestinal tumors (such as gastric, pancreatic, hepatobiliary, colon, rectal, and anal carcinoma), genitourinary tumors (such as prostate, bladder, testicular, and kidney), breast tumors, sarcomas, lymphoid tumors (such as Hodgkin's and non-Hodgkin's lymphoma), skin cancers (such as squamous cell, basal cell, and melanoma), benign diseases (such as schwannoma, arteriovenous malformation, cavernous malformation, trigeminal neuralgia, chordoma, glomus tumors, and hemangiomas), metastasis (including all parts of the body such as brain, bone, liver, lung, kidney, and skin), pediatric tumors (such as glioma, ependymoma, pituitary tumors, hemangioblastoma, craniopharyngioma, meningioma, metastasis, medulloblastoma, nasopharyngeal tumors, arteriovenous malformation, cavernous malformation, and skull base tumors), and low-dose radiotherapy for adults with medically refractory osteoarthritis.
The TrueBeam and VitalBeam Radiotherapy System is a medical linear accelerator that delivered therapeutic radiation to patient in accordance with the physician's prescription.
The system consists of two major components – a photon, electron and diagnostic kV X-ray radiation beam producing component that is installed in a radiation-shielded vault and a control console area located outside the treatment room.
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(54 days)
AquaCast Mask is a device used for the positioning and immobilization of patient's head undergoing or receiving a course of external beam radiation therapy for the treatment of cancer. Thermoplastic Mask is intended as a single-patient reusable device only and are not sterile.
AquaCast Mask is used for the positioning and immobilization of patient's head undergoing or receiving a course of external beam radiation therapy for the treatment of cancer. The low temperature thermoplastic mask is made of AquaCast polycaprolactone sheet for patient immobilization. Heat at a temperature of 150°F ~ 158°F is applied to the sheet to soften it and mold it to the shape of the patient anatomy. The perforated thermoplastic is pre-mounted to a non-patient contacting frame to interface with the user's existing support hardware and hold the patient's head in a fixed position for radiation therapy treatments
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(266 days)
Cranial 4Pi is intended for patient immobilization in radiotherapy and radiosurgery procedures.
Cranial 4Pi is indicated for any medical condition in which the use of radiotherapy or radiosurgery may be appropriate for cranial and head & neck treatments.
Cranial 4Pi is an assembly of the following medical device/ accessory groups:
- CRANIAL 4PI OVERLAYS (CRANIAL 4PI CT OVERLAY, CRANIAL 4PI TREATMENT OVERLAY)
- CRANIAL 4PI HEADRESTS (CRANIAL 4PI HEADREST STANDARD, CRANIAL 4PI HEADREST LOW-NECK, CRANIAL 4PI HEADREST PLATFORM)
- CRANIAL 4PI HEADREST INLAYS (CRANIAL 4PI HEADREST INLAY STANDARD, CRANIAL 4PI HEADREST INLAY OPEN FACE, CRANIAL 4PI HEADREST INLAY H&N, CRANIAL 4PI HEAD SUPPORT STANDARD, CRANIAL 4PI HEAD SUPPORT WIDE)
- CRANIAL 4PI MASKS (CRANIAL 4PI BASIC MASK, CRANIAL 4PI OPEN FACE MASK, CRANIAL 4PI EXTENDED MASK, CRANIAL 4PI STEREOTACTIC MASK, CRANIAL 4PI STEREOTACTIC MASK 3.2MM)
- CRANIAL 4PI WEDGES AND SPACERS (CRANIAL 4PI WEDGE 5 DEG., CRANIAL 4PI WEDGE 10 DEG., CRANIAL 4PI SPACER 20MM, CRANIAL 4PI INDEXING PLATE)
The Cranial 4Pi Overlays are medical devices used for fixation of the patient in a CT- resp. linear accelerator - environment.
The Cranial 4Pi Headrests and the Cranial 4Pi Headrest Inlays are accessories to the Cranial 4Pi Overlays to allow an indication specific positioning of the patient's head and neck. The Cranial 4Pi Wedges and Spacers are accessories to the Cranial 4Pi Headrest Platform to adapt the inclination of the head support to the patients necks.
The Cranial 4Pi Masks are accessories to the Cranial 4Pi Overlays used for producing individual custom-made masks for patient immobilization to the Cranial 4Pi Overlay.
The provided text is a 510(k) Clearance Letter and 510(k) Summary for a medical device called "Cranial 4Pi Immobilization." This document focuses on demonstrating substantial equivalence to a predicate device, as required for FDA 510(k) clearance.
However, the provided text does not contain the detailed information typically found in a clinical study report or a pre-market approval (PMA) submission regarding acceptance criteria, study methodologies, or specific performance metrics with numerical results (like sensitivity, specificity, or AUC) that would be used to "prove the device meets acceptance criteria" for an AI/ML-driven device. The document primarily describes the device's components, indications for use, and a comparison to a predicate device to establish substantial equivalence.
The "Performance Data" section primarily addresses biocompatibility, mechanical verification, dosimetry, compatibility with another system, and mask stability. It does not describe a study to prove AI model performance against clinical acceptance criteria. The "Usability Evaluation" section describes a formative usability study, which is different from a performance study demonstrating clinical effectiveness or accuracy.
Therefore, many of the requested elements (especially those related to AI/ML model performance, ground truth establishment, expert adjudication, MRMC studies, or standalone algorithm performance) cannot be extracted from the provided text. The Cranial 4Pi Immobilization device appears to be a physical immobilization system, not an AI/ML diagnostic or prognostic tool.
Given the nature of the document (510(k) for an immobilization device), the concept of "acceptance criteria for an AI model" and "study that proves the device meets the acceptance criteria" in the traditional sense of an AI/ML clinical study does not apply here.
I will answer the questions based on the closest relevant information available in the provided text, and explicitly state where the information is not available or not applicable to the type of device described.
Preamble: Nature of the Device and Submission
The Cranial 4Pi Immobilization device is a physical medical device designed for patient immobilization during radiotherapy and radiosurgery. The 510(k) premarket notification for this device seeks to demonstrate substantial equivalence to an existing predicate device (K202050 - Cranial 4Pi Immobilization). This type of submission typically focuses on comparable intended use, technological characteristics, and safety/performance aspects relevant to the physical device's function (e.g., biocompatibility, mechanical stability, dosimetry interaction).
The provided documentation does not describe an AI/ML-driven component that would require acceptance criteria related to AI model performance (e.g., accuracy, sensitivity, specificity, AUC) or a study to prove such performance. Therefore, many of the questions asking about AI-specific validation (like ground truth, expert adjudication, MRMC studies, training/test sets for AI) are not applicable to this type of device and submission.
1. A table of acceptance criteria and the reported device performance
Based on the provided document, specific numerical "acceptance criteria" and "reported device performance" in the context of an AI/ML model are not available and not applicable. The document focuses on demonstrating substantial equivalence of a physical immobilization device.
However, the "Performance Data" section lists several tests and their outcomes, which serve as evidence that the device performs as intended for its physical function. These are not acceptance criteria for an AI model.
| Test Category | Acceptance Criteria (Explicitly stated or Inferred) | Reported Device Performance (as stated) |
|---|---|---|
| Biocompatibility | Risk mitigated by limited exposure and intact skin contact for Irritation/Sensitization; low unbound residues for coating. Cytotoxicity to be performed. | Cytotoxicity Testing: Amount of non-reacted ducts is considered low. Sensitization Testing (ISO 10993-10): - Saline Extraction: No sensitization reactions observed.- Cottonseed Oil Extraction: No sensitization reactions observed. Test article did not elicit sensitization reactions (guinea pigs). Positive controls validated sensitivity.Irritation Testing (ISO 10993-23): - No irritation observed (rabbits) compared to control based on erythema and edema scores for saline and cottonseed oil extracts. Test article met requirements for Intracutaneous (Intradermal) Reactivity Test. Positive controls validated sensitivity. |
| Mechanical Tests | Relevant for fulfillment of IEC 60601-1 requirements. | All mechanical tests relevant for fulfillment of IEC 60601-1 requirements were carried out successfully. |
| Dosimetry Tests | Verify that dose attenuation is acceptable. | Tests to verify that dose attenuation is acceptable with the hardware components were carried out successfully. |
| Compatibility Tests | Compatibility with ExacTrac Dynamic 2.0. | Compatibility with ExacTrac Dynamic 2.0 was tested successfully. |
| Mask Stability | Cranial 4Pi SRS mask 3.2 mm (vs. 2mm predicate) to have higher stability against head movement. | Technical validation test to prove that the Cranial 4Pi SRS mask 3.2 mm... having a 3.2 mm top mask sheet instead of 2mm has a higher stability against head movement was carried out successfully. |
| Usability Evaluation | Evaluate the usability of the subject devices. | Formative usability evaluation performed in three different clinics with seven participants to evaluate the usability of the subject devices. (Specific findings not detailed, but the study was performed). |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not applicable/not stated in the context of an AI/ML test set. The usability evaluation involved "seven participants" in "three different clinics." For biocompatibility, animal studies were performed (guinea pigs for sensitization, rabbits for irritation; specific number of animals not stated but implied to be sufficient for ISO standards).
- Data Provenance: Not applicable for an AI/ML test set. The usability evaluation involved "three different clinics" but the country of origin is not specified.
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. This device is a physical immobilization system, not an AI/ML diagnostic or prognostic tool that requires expert-established ground truth on medical images.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This information is relevant to validating AI/ML diagnostic performance against ground truth, which is not described for this device.
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. This is an AI/ML-specific study design. The device is a physical immobilization system, not an AI assistance tool for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is an AI/ML-specific validation. There is no AI algorithm component described for this physical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable. No ground truth for diagnostic or prognostic purposes is established for this physical device. The "performance data" relies on standards compliance (e.g., ISO, IEC), physical measurements, and usability feedback.
8. The sample size for the training set
- Not applicable. There is no AI model described that would require a training set.
9. How the ground truth for the training set was established
- Not applicable. There is no AI model described.
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