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510(k) Data Aggregation

    K Number
    K220392
    Manufacturer
    Date Cleared
    2022-05-19

    (97 days)

    Product Code
    Regulation Number
    892.1750
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K103182

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

    PAPAYA 3D & PAPAYA 3D Plus are digital panoramic, cephalometric and tomographic extra-oral X- ray systems, indicated for use in:

    (i) producing panoramic X-ray images of the maxillofacial area, for diagnostic examination of dentition (teeth), jaws and oral structures; and

    (ii) producing radiographs of jaws, parts of the skull and carpus for the purpose of cephalometric examination, when equipped with the cephalometric arm (Only for PAPAYA 3D Plus);

    (ii) producing tomographic images of the oral and maxillofacial structure, for diagnostic examination of dentition(teeth), jaws ,oral structures and some cranial bones if equipped with CBCT option.

    The systems accomplish tomographic exam by acquiring a 360-degree rotational X- ray sequence of images and reconstructing a three-dimensional matrix of the examined volumensional views of this volume and displaying both two dimensional images and three-dimensional renderings.

    Device Description

    PAPAYA 3D & PAPAYA 3D Plus are diagnostic imaging system which consists of multiple image acquisition modes; panorama, cephalometric, and computed tomography. Also, PAPAYA 3D & PAPAYA 3D Plus are designed for dental radiography of the oral and craniofacial anatomy such as teeth, jaws and oral structures. The difference between PAPAYA 3D & PAPAYA 3D Plus is only optional of the cephalometric detector. Without cephalometric detector, we name model PAPAYA, and with cephalometric detector, we name model PAPAYA Plus. Due to this difference, the cephalometric image acquisition function applies only to PAPAYA 3D Plus, not to PAPAYA 3D.

    PAPAYA 3D Plus is equipped with extra-oral flat panel x-ray detectors which is based on CMOS digital X-ray detector and has CT, panoramic and cephalometric radiography with an extra-oral x-ray tube. CMOS Flat panel detectors are used to capture scanned image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D diagnostic images of the anatomic structures by acquiring 360ºrotational image sequences of oral and craniofacial area.

    The differences from predicate device (K150354) are change of power voltage, addition of image processing software (Theia, Triana).

    AI/ML Overview

    The provided text does not contain detailed acceptance criteria and a study specifically proving the device meets those criteria for the PAPAYA 3D & PAPAYA 3D Plus, particularly with respect to its image processing software (Triana/Theia) beyond software validation. The submission primarily focuses on demonstrating substantial equivalence to a predicate device (K150354) through a comparison of physical characteristics, intended use, and general performance specifications, along with adherence to various safety and regulatory standards.

    Here's a breakdown of the available information from the provided text, addressing your questions to the extent possible:

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

    The document presents performance specifications, but these are general technical specifications for the imaging hardware, not specific acceptance criteria for diagnostic performance outcomes. The comparison is between the proposed device and the predicate device.

    CriteriaProposed Device (PAPAYA 3D & PAPAYA 3D Plus)Predicate Device (PAPAYA 3D Plus - K150354)
    3D TechnologyCone beam Computed tomographyCone beam Computed tomography
    CT FOV (DXH)14x14, 14x8, 8x8, 7x7, 4x4 cm14x14, 14x8, 8x8, 7x7, 4x4 cm
    Input Voltage100-240 V~, 50/60Hz100-120 V~, 50/60Hz
    Tube Voltage60-90 kV60-90 kV
    Tube Current4-12 mA4-12 mA
    Focal Spot Size0.5 mm0.5 mm
    Total Filtration2.8 mm Al (Canon tube)2.5 mm Al (CEI tube)
    2.8 mm Al (Canon tube)
    Exposure TimePanorama: max 17 sec
    Cephalo: max 15.5 sec (Plus only)
    CT: max 15 secPanorama: max 17 sec
    Cephalo: max 15.5 sec
    CT: max 15 sec
    Image ReceptorPanoramic: CMOS FPD
    Cephalo: CMOS FPD
    CT: CMOS FPDPanoramic: CMOS FPD
    Cephalo: CMOS FPD
    CT: CMOS FPD
    Image processing S/WTriana (K103182) / Theia- (The predicate device itself likely had an image viewer, but it's not explicitly named as "Theia" or "Triana" in the predicate column of this table.)
    Image Quality (from non-clinical tests)MTF: >80% at 21lp/mm (panoramic/cephalometric sensors)
    DQE: ~80% at 01lp/mm (panoramic/cephalometric sensors)
    Dynamic Range: >72dB (panoramic/cephalometric sensors)
    MTF: >60% at 11lp/mm (all detectors)
    DQE: ~70% at 01lp/mm (all detectors)
    Dynamic Range: >72dB (all detectors)(Implicitly similar or was the benchmark for the proposed device's "similar" image quality)

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

    The document mentions "Non-Clinical Test results" referencing "each detector of PAPAYA 3D Plus" and "additional detector test results," but does not specify a sample size for any clinical test set or data provenance (country, retrospective/prospective). The evaluation appears to be based on technical specifications and laboratory testing of the detectors, rather than a clinical study with patient data.

    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. The document describes technical testing of components (detectors), and software validation (IEC 62304), not a clinical study involving experts establishing ground truth for diagnostic accuracy.

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

    Not applicable. As no clinical study with a 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

    No MRMC comparative effectiveness study is mentioned. The device described (PAPAYA 3D & PAPAYA 3D Plus) is an imaging system (hardware) and associated image processing software (Triana/Theia). The software functions listed are for image viewing and manipulation (e.g., 3D visualization, 2D analysis, MPR, measurement, rotation), not AI assistance for diagnosis. Therefore, this question is not applicable to the information provided.

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

    The software (Triana/Theia) is an image processing and viewing tool, not a standalone diagnostic algorithm. Its validation was done against IEC 62304:2006/AC: 2008 for software lifecycle processes, not for standalone diagnostic performance.

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

    For the detector performance tests (MTF, DQE, Dynamic Range), the "ground truth" would be established by physical measurement standards and calibration, not clinical ground truth like pathology or expert consensus. For the software validation, the "ground truth" or reference for validation would be the functional and performance requirements defined during software development, ensuring it operates as intended according to IEC 62304.

    8. The sample size for the training set

    Not applicable. The document describes an imaging hardware system and image viewing software. There is no mention of an "AI" component or machine learning algorithm that would require a training set.

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

    Not applicable. As no training set for an AI algorithm is mentioned.


    Summary of what the document does describe for proving acceptance:

    The document focuses on demonstrating substantial equivalence to an existing predicate device (PAPAYA 3D Plus, K150354) by showing that the proposed devices (PAPAYA 3D & PAPAYA 3D Plus) have the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness.

    The primary methods of "proving acceptance" appear to be:

    • Comparison to Predicate Device: A detailed comparison table ([6]) highlights the similarities in indications for use, 3D technology, CT FOV, tube parameters, exposure times, and image receptors.
    • Safety and EMC Testing: The device underwent testing to established international standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-63) to verify electrical, mechanical, environmental safety, and electromagnetic compatibility ([8]).
    • Performance Data for Detectors: Non-clinical tests were performed on the detectors, measuring MTF, DQE, and dynamic range, demonstrating "similar" diagnostic image quality to the predicate device ([8]).
    • Software Validation: The image processing software (Theia) was validated according to IEC 62304:2006/AC: 2008, and its similarities to the already cleared Triana software (K103182) are highlighted. The software is classified as having a "Minor Level of Concern" ([8]).
    • Compliance with Regulations: The device meets EPRC standards (21 CFR 1020.30.31.33) and NEMA PS 3.1-3.18 (DICOM Set). Relevant FDA guidance documents for submissions were also considered ([8]).
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    K Number
    K220423
    Manufacturer
    Date Cleared
    2022-05-19

    (94 days)

    Product Code
    Regulation Number
    872.1800
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K103182

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

    PAPAYA & PAPAYA Plus are digital extraoral source X-ray system intended to produce panoramic and cephalometric(option) images of the oral and craniofacial anatomy for a precise treatment planning in adult and pediatric care. The system is used for dental & skull radiographic examination and diagnosis of teeth, jaw, oral structure, and skull by exposing an X-ray image receptor to ionizing radiation, with a digital imaging capability for taking both panoramic and cephalometric images. And This system can be equipped cust(Tomographic) option, which is capable of taking crosssectional radiographic images provide dimensional information for dental implant planning and information about location of impacted teeth.

    Device Description

    The proposed devices PAPAYA & PAPAYA Plus are diagnostic imaging system which consists of multiple image acquisition modes; panorama and cephalometric. The difference beteween PAPAYA & PAPA YA Plus is only optional of the cephalometric detector. (Without cephalometric detector, we model named PAPAYA, and with cephalometric detector, we model named PAPAYA Plus.)

    The proposed devices have the CUST imaging option which is used to reconstruct tomographic images from a set of pre-acquired projection radiographic images of the object.

    The differences from predicate device(K141700) are change of power voltage, addition of image processing software(Theia, Triana).

    AI/ML Overview

    This FDA submission describes the PAPAYA & PAPAYA Plus digital extraoral source X-ray systems, which are intended to produce panoramic and cephalometric images for dental and craniofacial diagnosis and treatment planning. The submission asserts substantial equivalence to a previously cleared device, PAPAYA Plus (K141700).

    Here's an analysis of the provided information regarding acceptance criteria and supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not explicitly list acceptance criteria in the format of a separate table with target values. Instead, it presents a comparative table between the proposed device and the predicate device, highlighting performance specifications and software features. The "acceptance criteria" are implied to be that the proposed device performs at least equivalently to the predicate device, with any changes either being safety-verified or not impacting overall efficacy.

    CriteriaProposed device (PAPAYA & PAPAYA Plus)Predicate Device (PAPAYA Plus - K141700)Conclusion on Equivalence against Implicit Criteria
    Indications for UseSame as predicateDigital extraoral source X-ray system for panoramic and cephalometric images of oral/craniofacial anatomy, dental/skull radiographic examination, and CUST (Tomographic) option for cross-sectional images for implant planning and impacted teeth.Equivalent
    Performance SpecificationPanoramic (PAPAYA), Panoramic and Cephalometric (PAPAYA Plus)Panoramic (PAPAYA), Panoramic and Cephalometric (PAPAYA Plus)Equivalent
    Input Voltage100-240 V~, 50/60Hz120 V~, 60HzDifferent, but safety/EMC verified
    Tube Voltage60-90 kV60-90 kVEquivalent
    Tube Current4-12 mA4-12 mAEquivalent
    Focal Spot Size0.5 mm0.5 mmEquivalent
    Exposure TimePanorama: max 17 sec, Cephalo: max 12 secPanorama: max 17 sec, Cephalo: max 12 secEquivalent
    Exposure ModePanoramic, TMJ, SINUS, CUST, CephaloPanoramic, TMJ, SINUS, CUST, CephaloEquivalent
    Image ReceptorCMOS (Panoramic and Cephalometric)CMOS (Panoramic and Cephalometric)Equivalent
    Image Processing SoftwareTriana (K103182) or TheiaN/A (Predicate did not specify external image processing software in this comparison)Different, but Theia validated against IEC 62304 and deemed functionally equivalent to Triana
    Safety/EMC/Performance DataTested to IEC 60601-1, -1-2, -1-3, -1-6, -2-63,IEC 62366, IEC 62304, Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance, Guidance for Industry and FDA Staff Guidance for the Content of Premarket Submissions for Software contained in Medical Devices, Pediatric Information for X-ray Imaging Device Premarket Notifications, Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices, NEMA PS 3.1-3.20 (DICOM Set)Established in K141700Equivalent through compliance with relevant standards and guidelines

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

    The submission mentions "Clinical Evaluation Report and bench" testing for safety and effectiveness but does not provide specific details about the sample size used for any clinical test set or the provenance of any data (e.g., country of origin, retrospective/prospective). The primary focus of the performance data section is on adherence to regulatory standards and comparison to a predicate device's specifications.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    There is no mention of experts or ground truth establishment in the context of a diagnostic performance study for the proposed device in this submission. The submission centers on the physical device's specifications and software validation.

    4. Adjudication Method

    No adjudication method is mentioned, as there is no description of a study involving subjective assessment of diagnostic accuracy.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC study comparing human readers with and without AI assistance is mentioned. The device described is an X-ray imaging system and associated image processing software, not an AI-assisted diagnostic tool in the sense of providing automated interpretations. While the software offers "3D visualization, 2D analysis, various MPR functions," which can assist human readers, it's not discussed in the context of an MRMC study for effect size improvement.

    6. Standalone (Algorithm Only) Performance

    A standalone performance study for the image processing software (Triana or Theia) beyond the validation against IEC 62304 for software lifecycle processes is not explicitly described in terms of diagnostic accuracy or a specific clinical task without human interaction. The software is described as a tool to "obtain, store, inquire, and process the acquired image," suggesting it's an enhancement for human interpretation, not a standalone diagnostic algorithm.

    7. Type of Ground Truth Used

    No specific "ground truth" (e.g., expert consensus, pathology, outcomes data) is mentioned as part of a diagnostic accuracy study. The safety and performance assessments are based on compliance with electrical, mechanical, and imaging standards, as well as software validation.

    8. Sample Size for the Training Set

    The submission does not mention a training set, as it does not describe the development or validation of a machine learning-based diagnostic algorithm. The software mentioned (Triana/Theia) performs image processing and visualization, not AI-driven diagnosis requiring a training set.

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

    Since no training set is mentioned, this information is not provided.

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