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510(k) Data Aggregation

    K Number
    K042779
    Manufacturer
    Date Cleared
    2004-10-21

    (15 days)

    Product Code
    Regulation Number
    892.1630
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K003256

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

    The Radiotherapy Solution Based on CR25.0 is indicated for producing simulation and quality control images for use in radiation therapy planning and quality control.

    Device Description

    The Radiotherapy Solution Based on CR allows the application of Portal Imaging in a very wide dose range (1 MU - 400 MU's and higher) by using two different Portal Imaging Cassette types, which are optimised for image quality at their intended dose range. The Radiotherapy Solution Based on CR supports both low- and high-dose applications (sometimes called localisation and verification portal imaging). Not only does the system enable the acquisition of the images under the typical Radiotherapy conditions, the specific requirements for these images are also met which allows their use by the typical "next-in-line" radiotherapy applications. Typical "next-in-line" applications for simulation imaging are, for instance, image comparison and bloc compensator/MLC calculations. For portal imaging, a typical "next-in-line" application is image comparison with a reference image (this can be a simulation image or DRR: comparisons are made between hardcopy prints or on a digital workstation).

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called "Radiotherapy Solution Based on CR" (later referred to as "Radiotherapy Solution Based on CR25.0"). This submission focuses on demonstrating substantial equivalence to previously marketed predicate devices, rather than establishing specific performance criteria through a detailed clinical study with acceptance criteria.

    The submission is for an accessory to a CR system and emphasizes its technical characteristics and intended use being similar to existing cleared devices. Therefore, the information typically found in a clinical study demonstrating performance against acceptance criteria in terms of accuracy, sensitivity, specificity, or other quantitative metrics is largely absent.

    Here's an analysis based on the provided text, highlighting what is available and what is not:

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

    This information is not explicitly provided in the submission. The submission states that the device "has been tested for proper performance to specifications through various in-house reliability and imaging performance demonstration tests." However, the specific acceptance criteria for these "specifications" and the quantitative results are not detailed.

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

    The text mentions "Clinical performance has been tested in the typical environment of a clinical radiotherapy department, and sample clinical images have been provided in this 510(k)." The sample size for this "clinical performance" test is not specified, nor is the exact data provenance (country of origin, retrospective/prospective). The emphasis is on demonstrating "sample clinical images" as confirmatory evidence of equivalence.

    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):

    This information is not provided. Given the nature of a 510(k) submission focused on substantial equivalence rather than a de novo clinical performance study, the establishment of ground truth by multiple experts is not detailed. The "clinical performance" testing seems to be more about confirming the device functions as expected in a real-world setting rather than a rigorous diagnostic accuracy study.

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

    This information is not provided.

    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:

    An MRMC comparative effectiveness study was not conducted or reported. The device is an image acquisition and processing system, not an AI-assisted diagnostic tool for human readers. Its primary function is to enable "Portal Imaging" and produce images for "simulation and quality control" in radiotherapy.

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

    A standalone performance evaluation of the "algorithm" in the sense of a diagnostic accuracy study is not explicitly detailed. The device is an integrated system (cassettes, image acquisition, and processing) for producing images. The "performance to specifications" would likely involve objective image quality metrics (e.g., spatial resolution, contrast, noise, dose linearity) which are inherent to the algorithm and hardware working together. However, specific acceptance criteria and detailed results for these are not provided in the summary.

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

    Given the device's function in radiotherapy imaging (localization and verification, simulation, quality control), the "ground truth" for its performance would likely relate to the accuracy of anatomical representation, consistency of image quality, and ability to meet the requirements for "next-in-line" radiotherapy applications. However, the specific methodology for establishing this "ground truth" (e.g., comparison to known anatomical landmarks, phantoms, established dosimetry) is not detailed in the provided summary. There is no mention of expert consensus, pathology, or outcomes data in the context of establishing ground truth for the clinical performance.

    8. The sample size for the training set:

    The concept of a "training set" in the context of machine learning is not applicable to this device. This device is an imaging system, not a machine learning model.

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

    As the concept of a "training set" is not applicable, this information is not relevant.

    In summary:

    This 510(k) summary is typical for a device demonstrating substantial equivalence, where the focus is on comparing the new device's intended use and technological characteristics to already cleared predicate devices. It does not provide the detailed performance metrics, acceptance criteria, multi-reader studies, or comprehensive ground truth establishment methodologies that would be expected for a de novo device or an AI-based diagnostic tool requiring rigorous clinical validation. The "testing" mentioned is primarily for "proper performance to specifications" and "clinical performance" to confirm its functionality in a radiotherapy environment, without specific quantitative results against predefined acceptance criteria being disclosed in this summary.

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    K Number
    K032654
    Device Name
    PORT CASSETTE
    Date Cleared
    2003-10-09

    (42 days)

    Product Code
    Regulation Number
    892.1630
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K003256

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

    The PoRT Cassette is an accessory to the PcCR Digital Imaging Device and is indicated for portal imaging (Radiation Therapy Quality Control).

    Device Description

    The PoRT Cassette is an optional cassette to be used with the PcCR Digital Imaging Devices for portal imaging. The PcCR Digital Imaging Devices are filmless systems intended for digital radiography using a phosphor storage screen which were cleared under K003256. The PcCR Digital Imaging device enables the clinician to scan or import images for display, review, or storage in a database. The PcCR device consists of reusable phosphor storage screens for recording radiographic images, an image reader/digitizer, and software for displaying, enhancing, and storing radiographs using a user-provided personal computer. The PoRT Cassette is optional cassette to be used with the PcCR System and is also a reusable phosphor screen. It is offered in 14" x 17" size. Other than the addition of the PoRT Cassette and a software upgrade, the PcCR Digital Imaging Device is identical to that described in K003256.

    AI/ML Overview

    The provided 510(k) summary for the PoRT Cassette (K032654) contains very limited information regarding detailed acceptance criteria and the specifics of the study conducted. The summary focuses on establishing substantial equivalence to a predicate device and does not include an in-depth clinical or performance study breakdown typically found in a full submission.

    Based on the information provided, here's what can be extracted and what is missing:


    Acceptance Criteria and Reported Device Performance

    The document states: "Bench testing and clinical validation demonstrate that the PoRT Cassette performs according to specifications." However, it does not explicitly define what those specifications or acceptance criteria are, nor does it provide specific numerical results for device performance against those criteria. It only makes a general statement of compliance.

    Therefore, a table of acceptance criteria and reported device performance cannot be generated from the given text.


    Study Details

    The provided text mentions "Bench testing and clinical validation," but offers almost no specifics about these studies.

    1. Sample Size Used for the Test Set and Data Provenance:

      • Sample Size (Test Set): Not specified.
      • Data Provenance: Not specified (e.g., country of origin, retrospective/prospective).
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:

      • Not specified. The document does not mention the use of experts for ground truth establishment.
    3. Adjudication Method for the Test Set:

      • Not specified.
    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

      • No mention of an MRMC study being performed.
      • No data on the effect size of human readers improving with AI vs. without AI assistance. This device is an accessory to a digital imaging system, not explicitly an "AI" device as typically understood today, so such a study would likely not be relevant in this context.
    5. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop):

      • The document implies performance testing of the device itself ("bench testing"). However, it does not explicitly detail a "standalone" study in the context of an algorithm's performance without human interaction. The PoRT Cassette is a hardware component (reusable phosphor screen) and an associated software upgrade, not a standalone diagnostic algorithm.
    6. Type of Ground Truth Used:

      • Not specified. Given the nature of a portal imaging accessory for radiation therapy quality control, ground truth would likely involve comparison to known radiation fields, phantom measurements, or possibly expert assessment of image quality for therapy verification. However, this is speculative as the document is silent on this point.
    7. Sample Size for the Training Set:

      • Not specified. The document does not mention a "training set" in the context of machine learning, as this device is not presented as an AI/ML algorithm that would typically require such a set. Its "software upgrade" likely refers to functionality rather than an AI model.
    8. How the Ground Truth for the Training Set Was Established:

      • Not applicable/Not specified, as no training set (in the ML sense) is mentioned or implied.

    Summary of Missing Information:

    The provided 510(k) summary is extremely high-level and does not contain the detailed study results, acceptance criteria, or ground truth establishment methods that would typically be expected for a comprehensive clinical study report. It primarily serves to establish substantial equivalence based on intended use, technological characteristics, and operational characteristics, stating that "Bench testing and clinical validation demonstrate that the PoRT Cassette performs according to specifications" without providing those specifications or results.

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