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510(k) Data Aggregation

    K Number
    K150306
    Date Cleared
    2015-10-10

    (243 days)

    Product Code
    Regulation Number
    892.1650
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K131314, K141440, K142718

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

    The D-RS AT Digital Dynamic Remote System Is indicated for use in generating fluoroscopic images of human anatomy for diagnostic procedures. It Is intended to replace fluoroscopic images obtained through image intensionaly. Not intended for mammography applications.

    Device Description

    The D2RS AT Digital Dynamic Remote System is a direct digital dynamic remote-controlled fluoroscopy and radiography system equipped with the latest generation of Trixell Flat Panel Detector (FPD). The single FPD can perform both fluoroscopy and radiography and is detachable and portable for direct projections to create a unique and highly versatile 3-in-1 imaging solution. The receptor panel directly converts the X-ray images captured by the sensor into a high-resolution digital images. The instrument is suited for use inside a patient environment. This unit converts the X-rays into digital signals. The unit can acquire still and moving images. The system includes a remotely controlled tilting/elevating table. Panel information: Based on a flat-panel digital detector with the largest field-of-view in the market, the Pixium RF 4343 FL is designed for easy integration in classical R&F tables. It allows manufacturers to offer radiologists an all-digital real-time system, generating high-quality images for both routine dynamic applications and high-end static ones. Digital technology facilitates the work of X-ray technicians and speeds up the process, allowing medical centers to optimize patient throughput. Universal: a single detector for both Radiography and Fluoroscopy. An optional static panel may be added to the system: Trixell Pixium 3543EZ. The 3543EZ panel has already been cleared in various 510(k)s including K131314 and K141440. That panel is not mounted and can be moved around by the technician. The system must always have either the Pixium RF 4343, Pixium RF 4343FL for the system to be able to perform fluoroscopy. These fluoroscopic panels were not to our knowledge previously cleared by FDA, so complete performance information as requested by the FDA guidance document on solid state x-ray panels has been provided.

    AI/ML Overview

    This document describes the D²RS_AT Digital Dynamic Remote System, an image-intensified fluoroscopic x-ray system seeking 510(k) clearance. The provided text outlines the device's characteristics, its comparison to a predicate device, and the testing conducted to demonstrate its safety and effectiveness.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document implicitly defines acceptance criteria through comparison to a predicate device (Stephanix D²RF K102529) and adherence to various standards and guidance documents. Explicit quantitative acceptance criteria are not provided as a list with pass/fail thresholds. Instead, performance metrics are presented for both the new device's panels and the predicate device's panel, and the conclusion states that the new device performs "comparably to and is substantially equivalent to the predicate device."

    Performance CharacteristicPredicate Device Panel (CXDI-50RF) Reported PerformanceNew Device Panels (Pixium RF 4343 / 4343 FL) Reported PerformanceAcceptance Criterion/Comparison
    Image Quality- MTF (Modulation Transfer Function)- MTF (Modulation Transfer Function)The technological characteristics are equivalent to the predicate. The MTF and DQE comparisons in the table above show the new digital panels perform better in some measurements and slightly worse in other measurements, but such numbers should be compared with caution because of measurement uncertainty error. This implies that the performance should be "comparable" or "substantially equivalent" to the predicate, accounting for measurement variability. The conclusion states "images produced by the new panels have equivalent image quality."
    - DQE (Detective Quantum Efficiency)DQE: 72% (0 cy/mm), 60% (1 cy/mm), 42% (2cy/mm), 24% (3cy/mm)DQE: 65% (0 cy/mm), 52% (1 cy/mm), 42% (2cy/mm), 28% (3cy/mm)
    Spatial Resolution3.2 lp/mm3.4 lp/mmThe new panels' spatial resolution is superior. This implicitly means it meets or exceeds an acceptable level.
    Pixel Pitch160 µm148 µmThe new panels' pixel pitch is superior (smaller). This implicitly means it meets or exceeds an acceptable level.
    Frame Rate (Fps Max)30 fps30 fpsEquivalent to the predicate. This implies meeting the predicate's performance.
    Binning Max2x23x3This is a different capability, not directly comparable in terms of "better" or "worse" performance against a single metric for acceptance, but rather a functional characteristic that is part of the overall "equivalent" functional identity.
    Software ValidationNot explicitly detailed for predicatePerformedCompliance with safety and effectiveness standards.
    Electrical SafetyNot explicitly detailed for predicatePerformed, complies with IEC 60601-1, IEC 60601-1-3, IEC 60601-2-54, 21CFR Subchapter JCompliance with relevant safety standards.
    EMC (Electromagnetic Compatibility)Not explicitly detailed for predicatePerformed, complies with IEC 60601-1-2Compliance with relevant EMC standards.
    DICOM 3 StandardYESYESCompliance with interoperability standards.
    Indications for UseSimilar, primarily diagnostic procedures.The D²RS_AT Digital Dynamic Remote System is indicated for use in generating fluoroscopic images of human anatomy for diagnostic procedures. Not intended for mammography.The new device's indications are consistent with a cleared fluoroscopic system and are comparable to the predicate's, demonstrating it's suitable for its intended purpose.
    Guidance Document ComplianceNot explicitly detailed for predicateCompliance with "Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices."Adherence to FDA-specific guidance for similar devices.
    US Performance StandardNot explicitly detailed for predicateComplies with 1020.30, 1020.31, 1020.32Compliance with US performance standards for radiographic equipment.

    Study Proving Acceptance Criteria:

    The study conducted to prove the device meets the acceptance criteria is detailed under "Bench/Performance Testing/Data" and "Clinical Evaluation."

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

    • Test Set Sample Size: Not explicitly stated. The "Clinical Evaluation" mentions a "board certified radiologist reviewed both static and moving images." This implies a qualitative assessment of some images, but the number of images or cases reviewed is not specified.
    • Data Provenance: The document does not specify country of origin for the data or whether it was retrospective or prospective. Given that the device is manufactured in France (Rue Jean Moulin - ZI du Bayon La Ricamarie - FRANCE), it's plausible testing was conducted there or in another location appropriate for device evaluation. The context of a 510(k) submission typically involves data collected specifically for the regulatory submission, making it akin to a prospective study for that purpose, even if the cases themselves might be simulated or representative.

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

    • Number of Experts: "a board certified radiologist reviewed..." indicates one radiologist.
    • Qualifications of Experts: "board certified radiologist." Specific experience (e.g., "10 years of experience") is not provided.

    4. Adjudication Method for the Test Set:

    • Adjudication Method: Not applicable or "none" for multiple readers. Since only one radiologist is mentioned as reviewing the images, there was no multi-reader consensus or adjudication process described. The single radiologist's assessment served as the "truth" for the clinical evaluation.

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

    • No, an MRMC comparative effectiveness study was not explicitly described. The "Clinical Evaluation" section mentions a single board-certified radiologist reviewing images but does not present a comparison of human reader performance with and without AI assistance, nor does it quantify an effect size of improvement. The study focuses on the device's image quality for diagnostic purposes rather than the reader's comparative performance with different aids.

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

    • Yes, a standalone study (or rather, non-human-in-the-loop performance evaluation) was done as part of the bench testing. The "Bench/Performance Testing/Data" section discusses objective metrics like MTF, DQE, spatial resolution, and pixel pitch. These are measurements of the device's inherent image quality characteristics, independent of a human observer's interpretation.

    7. The Type of Ground Truth Used:

    • For Bench/Performance Testing: The ground truth is objective physical measurements of the system's performance characteristics (e.g., specific X-ray phantom designs for MTF/DQE, calibrated measurement tools for spatial resolution, etc.).
    • For Clinical Evaluation: The "ground truth" was established by the subjective assessment of "good diagnostic quality" by a single board certified radiologist. This is an expert opinion-based ground truth.

    8. The Sample Size for the Training Set:

    • Not Applicable / Not Provided. This device is an X-ray imaging system, not an AI / machine learning algorithm that typically requires a training set of data. The document describes a physical medical imaging device and its components (flat panel detectors). Therefore, no "training set" in the context of machine learning is applicable or mentioned.

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

    • Not Applicable / Not Provided. As there is no mention of an AI/ML component requiring a training set, the establishment of ground truth for such a set is not relevant to this submission.
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