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510(k) Data Aggregation
(85 days)
This Digital Mobile Diagnostic X-Ray System is intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography.
These are modified versions of the predicate mobile digital diagnostic x-ray systems. They feature motorized movement and full battery operation. Various Canon digital X-ray panels are supplied with the system. The Mobile X-Ray Unit MOVIX DReamy has a Basic configuration or Advanced configuration. The Mobile X-Ray unit MOVIX DReamy is provided with touch screen to operate as a control console. The Digital Imaging System is composed by image receptors and application for image acquisition (control console & image processing controller). The Image acquisition software "CANON CXDI Control Software NE" runs on MOVIX DReamy and it is displayed on touch screen. The MOVIX DReamy Mobile X-Ray Unit is provided with separate battery packs for X-Ray generation and motorized movements of the unit can operate connected to mains or in stand-alone mode. New X-ray generator (model SHFM) is mounted on Battery Mobile X-Ray unit MOVIX DReamy. This X-Ray generator for MOVIX DReamy Mobile X-Ray Unit has a radiogenic unit mounted on head-assembly and comprising an X-ray tube with rotating anode and its circuit for high voltage. The electronic and associated software to control the X-ray generation are placed on mobile cart. The Battery Mobile X-Ray Unit MOVIX DReamy is provided with different output powers: 20 kW, 32 kW, 40 kW and 50 kW. There are available two X-ray tube inserts with rotating anode manufactured by CANON ELECTRON TUBES & DEVICES: XRR-3331 insert and E7886 insert. The Manual Beam Limiting Device is from Ralco, model: R108 F. External interface (controls) and covers are provided by Sedecal. There are two versions of collimator assembly, Basic and Advanced.
Based on the provided text, the MOVIX DReamy device is a mobile X-ray system. The document does not describe acceptance criteria for an AI/ML device or a study proving that the device meets such criteria. Instead, it is a 510(k) premarket notification for a mobile X-ray system, establishing substantial equivalence to a predicate device.
Therefore, I cannot provide the requested information regarding acceptance criteria and a study proving an AI/ML device meets them based on the given document. The document describes the device, its intended use, comparison to a predicate device, and compliance with various international standards, but it explicitly states that no clinical testing was required to establish substantial equivalence.
The relevant sections for this request (AI/ML acceptance criteria and performance study) are not present in this document because it pertains to a different type of medical device clearance.
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(51 days)
Intended for digital image capture use in general radiographic examinations, wherever conventional screen-film systems may be used, excluding fluoroscopy, angiography and mammography. The kit allows imaging of the skull, chest, shoulders, spine, abdomen, pelvis, and extremities.
PRIMO S is an image acquisition and processing software application, in radiography mode for Flat Panel detectors. The software is specifically designed for integration with production equipment of the SEDECAL group. The PRIMO S application will be used on different types of Sedecal equipment / systems:
- mobile units
- fixed installations.
The PRIMO S VP application provides the following functions:
- User login: the device is usable only by authenticated users
- Management of the operator interface GUIs and setup of the application itself
- The operator interface GUI must reserve a space on the monitor for the Sedecal equipment/system GUI (choice of examination (APR), X-ray generator commands, collimator, stand, etc.)
- Management of patient data through manual entry and reception from the DICOM WORKLIST service
- Management of image processing algorithms for each type of examination
- Management of the automatic advancement procedures of the operations during the study.
- Image acquisition and processing
- Saving in Hard Disk of the acquired images
- Automatic and manual image stitching procedure
- Off-line image editing and optimization using process and graphic functions
- Documentation of images and study data using DICOM services of STORE, PRINT, CDROM, MPPS, RDSR, STORAGE COMMITMENT
- Application configuration setup
- Export and automatic saving of images on external support (USB key)
The application communicates with the Sedecal equipment through software modules (DLL) for:
- The choice of the examination, made by the operator through a GUI defined by Sedecal (APR)
- Send the exposure parameters foreseen by the selected exam (kV, mA, mAs, ms, collimator aperture, stand position, ...)
- Receive the system status parameters and the exposure result
While the provided text describes the PRIMO S device and its 510(k) submission, it explicitly states:
"6. Clinical testing. Not required for a determination of substantial equivalence."
This indicates that a clinical study with detailed acceptance criteria and performance metrics, as requested in your prompt, was not performed or required for the FDA clearance of this specific device. The clearance was based on substantial equivalence to a predicate device, supported by non-clinical testing and adherence to various standards.
Therefore, I cannot provide the specific information you requested regarding validation studies, sample sizes, expert involvement, adjudication methods, MRMC studies, standalone performance, or ground truth establishment for a clinical test set, as such a study was not conducted or reported in this document.
The document primarily focuses on:
- Device Description: What PRIMO S is and what it does.
- Indications for Use: The medical conditions and body parts it's intended for.
- Technological Characteristics Comparison: How it compares to its predicate device (Sedecal SA K130883) in terms of X-ray generator, digital detectors, panel sizes, operating system, etc.
- Non-Clinical Testing: A list of standards (IEC 62304, EN/IEC 62366-1, ISO 14971, NEMA DICOM, ISO 15223-1) that were employed in development, and mention of software validation based on FDA guidance and cybersecurity considerations.
Since there's no clinical trial data, I cannot populate the table or answer the specific questions about the study design that would prove the device meets acceptance criteria based on clinical performance.
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(26 days)
The DIGITAL RADIOGRAPHY CXDI-CS01 provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The DIGITAL RADIOGRAPHY CXDI-CS01 is a series of solid-state x-ray detectors. The detector intercepts x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the digital values are sent to the PC via wired or wireless connection, converted to images with the CXDI Control Software (CCS), then displayed on monitors. The digital value can be communicated to the operator console via wired or wireless connection.
The subject of this Special 510(k) submission is a change to the DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless to make a series of detectors including the DIGITAL RADIOGRAPHY CXDI-702C Wireless (K192632), CXDI-402C Wireless (K192632), CXDI-710C Wireless (K170332), CXDI-810C Wireless (K170332), and CXDI-410C Wireless (K171270), under the proposed device the DIGITAL RADIOGRAPHY CXDI-CS01. This change will change the Multi Box to be a Standard Component from an optional component for the detectors. The Multi Box has the functions of connecting to the X-ray generator to synchronize the X-ray exposure and photographing, supplying power to the FPD (front panel detector), communicating between the FPD and the image capture computer, connecting the status indicator to the Multi Box to turn the FPD on and off and switch to a ready state, connecting to the WLAN access point to communicate to the FPD wirelessly, and connecting to the docking station to charge the FPD and communicate between the FPD and image capture computer. These functions of the Multi Box have not changed since its clearance under the predicate device (K192632). The X-ray I/F (Interface) Unit has been removed as an optional component for the DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless as the Multi Box performs the function of the X-ray I/F Unit (connecting to the X-ray generator to synchronize the x-ray exposure and photographing). In addition, the detectors will all use the version software cleared under the DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless (K192632). Together, these changes make up the DIGITAL RADIOGRAPHY CXDI-CS01.
The provided text describes a Special 510(k) submission (K203849) for a device called "DIGITAL RADIOGRAPHY CXDI-CS01". This submission is for modifications to previously cleared devices rather than a new standalone device. Therefore, the document focuses on demonstrating that the changes do not negatively impact the device's compliance with established standards and do not raise new questions of safety or effectiveness compared to the predicate device.
The acceptance criteria are therefore related to maintaining compliance with existing performance standards and regulations rather than establishing new performance metrics. The study described is a verification/validation activity to confirm that the modifications do not affect compliance.
Here's the information extracted from the document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not detail specific quantitative acceptance criteria or performance metrics for the device's diagnostic capabilities (e.g., sensitivity, specificity for detecting a disease). Instead, it focuses on demonstrating continued compliance with established standards after modifications. The "performance" section primarily shows that key technical characteristics related to image acquisition are identical to the predicate and reference devices.
Acceptance Criterion (Implicit) | Reported Device Performance |
---|---|
Continued compliance with FDA requirements for Solid State X-ray Imaging Devices (Guidance for 510(k) Submissions) | Documentation was provided demonstrating that the changes to DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless do not impact the device's compliance. |
Continued conformance with U.S. Performance Standard for radiographic equipment | Evaluation confirmed that the changes did not impact DIGITAL RADIOGRAPHY CXDI-CS01 conformance. |
Continued conformance with relevant voluntary safety standards (IEC 60601-1, 60601-1-2, 60601-1-3, 60601-1-6, 62366, 60601-2-54, 62220-1, and 62304) | Evaluation confirmed that the changes did not impact DIGITAL RADIOGRAPHY CXDI-CS01 conformance with these standards for Electrical safety and Electromagnetic Compatibility testing. |
No new questions regarding safety or effectiveness compared to the predicate device | Verification/validation activities successfully demonstrated that the device continues to meet the standards for the areas impacted by the device modifications to the predicate device and raises no new questions regarding either safety or effectiveness when compared to the predicate device. |
Technological Characteristics (e.g., Scintillator, Pixel Pitch, Spatial Resolution) remain equivalent to predicate | Scintillator: CsI(Tl) [Cesium Iodide doped with Thallium] (Identical to predicate and reference devices) |
Pixel Pitch: 125μm (Identical to predicate and reference devices) | |
Spatial Resolution: 35% [MTF@2lp/mm] (Identical to predicate and reference devices) | |
Indication for Use: Identical to predicate device | |
Application: General Radiography (Identical to predicate device) | |
Case Material: Magnesium alloy / Carbon Fiber (Identical across various models of proposed and predicate/reference devices) | |
Software functionality (CXDI Control Software V2.19) | CXDI Control Software V2.19 (Identical to predicate device, updated from V2.16 for some reference devices) |
2. Sample size used for the test set and the data provenance
The document does not specify a "test set" in terms of imaging data or patient cases. The study described is a design verification and validation process focused on the engineering and regulatory impact of changes (making the Multi Box a standard component, removing the X-ray I/F Interface as an option, and updating software). This typically involves testing the modified device against specified technical requirements and standards, not a clinical study with a patient image dataset.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. As described above, this was not a clinical study involving image interpretation with expert ground truth.
4. Adjudication method for the test set
Not applicable.
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 study was performed or described. The device is a digital radiography detector and associated software, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an algorithm for autonomous interpretation. It's an imaging capture device.
7. The type of ground truth used
Not applicable in the context of clinical diagnostic accuracy. The "ground truth" for this submission is adherence to existing regulatory requirements and technical standards.
8. The sample size for the training set
Not applicable. This is not a machine learning or AI-based device requiring a training set.
9. How the ground truth for the training set was established
Not applicable.
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(55 days)
Intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography.
This is a new generation of Ceiling Suspension Radiographic System. This system is characterized by its simple and functional design. Thanks to its vertical and horizontal displacements, the suspension can cover almost all the room positions in which it is installed allowing all radiographic procedures. The system is modular and supports different configurations, such as radiographic system without radiographic table or without Wall Stand. The X-ray image receptors used in this system are digital detectors. X-ray film and Computed Radiography (CR) image receptors can be used but they rarely are these days. The device software used is the CANON CXDI which is supplied unmodified by CANON (Clearance numbers above). It has a moderate level of concern. The Radiographic System ChallengeX AP is provided with Auto-positioning, Auto-centering and Auto-tracking functions and it is composed of: Ceiling Suspension (OTC), Radiographic Table, Wall Stand, High Voltage X-ray Generator and acquisition image software. Auto-tracking allows the X-ray Tube to follow the Receptor when it changes position or the other way around while the SID remains constant. The "Auto" features were present and validated in the predicate system.
The document provided is a 510(k) premarket notification for a medical device called "Radiographic System Challenge X." This notification aims to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving that the device meets specific acceptance criteria in a clinical study with an AI component.
Therefore, the requested information regarding acceptance criteria, study details, sample sizes, expert involvement, adjudication methods, MRMC studies, standalone performance, and ground truth establishment for AI-based analysis is not present in the provided text.
The document discusses non-clinical testing for compliance with international standards and FDA guidance for traditional medical device aspects such as safety, electrical compatibility, radiation protection, and software validation. It explicitly states that clinical testing was not required to establish substantial equivalence because the digital x-ray receptor panels already had previous FDA clearance.
Key takeaway from the document regarding studies:
- No AI component or AI-specific acceptance criteria are documented.
- The device is a traditional X-ray system, not an AI-powered diagnostic tool.
- Clinical testing was not performed for this submission. The substantial equivalence was established through non-clinical bench testing and compliance with existing standards and previously cleared components (like the detectors and software).
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(28 days)
Intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography
The Soltus 500 Mobile Digital X-Ray System, Model 10501, ("Mobile X-Ray System") is the same as the predicate mobile PhoeniX with 2 additional features, (i) Distributed Antenna System (DAS), and (ii) Enhanced Work Flow (EWF). The Mobile X-Ray System has motorized movement and full battery operation. It contains a touch screen that operates as a control console. The Mobile X-Ray System supports various Canon flat panel detectors (Digital Radiography CXDI) supplied with the unit.
The provided text is a 510(k) Summary for the Soltus 500 mobile X-ray system. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study to prove meeting specific acceptance criteria for performance metrics typically associated with AI/CADe devices.
Therefore, many of the requested elements for acceptance criteria and study details (like sample size for test/training sets, expert qualifications, adjudication methods, effect size of human readers with AI, ground truth details) are not applicable or findable in this type of submission.
Here's a breakdown based on the information available in the provided text:
1. A table of acceptance criteria and the reported device performance
The document doesn't present specific performance metrics or acceptance criteria in the typical sense of an AI/CADe device. Instead, the "acceptance criteria" are implied by demonstrating substantial equivalence to a predicate device and compliance with relevant safety and performance standards.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Safety and Effectiveness (equivalent to predicate) | "The results of bench testing indicates that the new device is as safe and effective as the predicate device." |
"Proper system operation is fully verified upon installation." | |
"We verified that the modified combination of components worked properly and produced diagnostic quality images as good as our predicate generator/panel combination." | |
"The Soltus 500 Battery Mobile X-Ray Units have been tested to be in compliance with the following International Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-54, IEC 60601-2-28, IEC 60601-1-6, IEC 62304." | |
Technological Characteristics (substantially the same) | See the "Substantial Equivalence Chart" (Page 4-5) which details that most characteristics (Indications for Use, Configuration, X-ray Generator(s), Collimator, Digital X-ray Panel Supplied, Software, Panel Interface, Meets US Performance Standard, Power Source) are "SAME" as the predicate K192011. The differences (Computer, Wireless Antennas) are described as improvements (EWF, DAS) that do not impact safety or effectiveness. |
Firmware and Cybersecurity Validation | "Firmware was validated according to the FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005." |
"Because the system uses Wi-Fi and Ethernet, we observed the recommendations contained in the FDA Guidance Document: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014." | |
Diagnostic Quality Images | "produced diagnostic quality images as good as our predicate generator/panel combination." |
Compliance with relevant standards | IEC 60601-1:2005+A1:2012 (Edition 3.1) |
IEC 60601-1-2:2014 (Edition 4.0) | |
IEC 60601-1-3:2008+A1:2013 (Edition 2.1) | |
IEC 60601-2-54:2009+A1:2015 (Edition 1.1) | |
IEC 60601-2-28:2010 (Edition 2.0) | |
IEC 60601-1-6:2010 + A1:2013 (Edition 3.1) | |
IEC 62304:2006 + A1:2016 (Edition 1.1) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable/Not provided. This device is a mobile X-ray system, not an AI/CADe device that performs diagnostic analysis on images. The evaluation primarily involved bench testing of the hardware and software components, and comparison to the predicate device. Clinical testing was explicitly stated as "not required."
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/Not provided. No clinical ground truth was established as clinical testing was not required.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable/Not provided. No adjudication method was used as no clinical test set requiring ground truth was established.
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. This was not an AI/CADe device, and therefore no MRMC study was performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is an X-ray imaging system, not a diagnostic algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable/Not provided. No clinical ground truth was used for evaluation. The "ground truth" for the device's functionality was based on engineering specifications, performance standards, and comparison to the predicate device's established performance, verified through bench testing.
8. The sample size for the training set
- Not applicable/Not provided. This is a hardware system, not an AI/ML algorithm that requires a training set.
9. How the ground truth for the training set was established
- Not applicable/Not provided. This is a hardware system; there is no training set or ground truth in this context.
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(45 days)
The DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.
The CXDI-702C Wireless and CXDI-402C Wireless are solid-state x-ray imagers with approximate imaging areas of 350 x 426 mm and 415 x 426 mm, respectively. The detector intercepts x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the signals are converted to digital values and the images will be displayed on monitors. The digital value can be communicated to the operator console via wired or wireless connection.
The subject of this Special 510(k) submission is a change to the Digital Radiography CXDI-710C Wireless and CXDI-410C Wireless to add the X-ray I/F unit option, update to the CXDI control software, change the IP Level, make changes to the case, and remove Standalone mode. The X-Ray I/F unit synchronizes the timing of the X-ray irradiation with the detector's capture and has been included in other Canon devices (CXDI-701C Wireless (K131106)). The X-Ray I/F Unit is an optional unit that allows the proposed device work together with several older units that use the X-ray I/F Unit instead of the multibox. The IP Level was changed from IPX7 to IP54. The Standalone mode was removed from the proposed devices. The imaging process to sharpen images, Edge Enhancement, was included in the Digital Radiography CXDI-710C Wireless and CXDI-410C Wireless, but adjustments of multiple imaging parameters were required to enhance structured edges. The optional feature, Advanced Edge Enhancement, for CXDI-702C Wireless and CXDI-402C Wireless automatically adjusts the six image processing parameters (Enhancement - Edge Enhancement, Enhancement - Edge Frequency, Enhancement - Contrast Boost, Dynamic Range Adjustment - Dark Region, Dynamic Range Enhancement - Bright Region, and Noise Reduction - Effect) by one button to enhance structures. The CXDI control software has been updated to a new version for functional improvements. The material of the casing of the detector has changed from fiberglass to magnesium alloy. Together, these changes to the Digital Radiography CXDI-710C Wireless and CXDI 410C Wireless make up the Digital Radiography CXDI-702C Wireless and CXDI-402C Wireless.
The provided text describes a 510(k) premarket notification for two digital radiography devices, the CXDI-702C Wireless and CXDI-402C Wireless. This submission is a "Special 510(k)," indicating that the changes made to the devices are minor and fall within established performance specifications, meaning a direct comparative effectiveness study with human readers (MRMC) might not have been the primary focus of the submission for overall device clearance, but rather a demonstration of continued equivalence through specific performance tests and comparative data with predicate devices.
The acceptance criteria and study proving the device meets these criteria can be inferred from the "Summary of Non-Clinical / Test Data" section and the "Comparisons with the predicate devices" table.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The submission focuses on demonstrating substantial equivalence to predicate devices (CXDI-710C Wireless and CXDI-410C Wireless) after specific modifications. Therefore, the "acceptance criteria" are primarily that the modified devices maintain performance comparable to the predicate devices and meet relevant safety and performance standards. The "reported device performance" is largely framed as successful verification and validation tests and comparability data.
Acceptance Criteria (Inferred from submission purpose and tests) | Reported Device Performance (Summary) |
---|---|
Maintain fundamental scientific technology | The fundamental scientific technology of the DIGITAL RADIOGRAPHY CXDI-702C Wireless and CXDI-402C Wireless has not been modified. |
Mitigate risks and hazardous impacts of device modifications (e.g., FMEA) | Risks and hazardous impacts of the device modification were analyzed by FMEA methodology. Specific risk control and protective measures were reviewed and implemented. Overall assessment concluded all identified risks and hazardous conditions were successfully mitigated and accepted. |
Maintain "safe and effective" performance comparable to predicate devices | Tests performed demonstrated that the devices are safe and effective, perform comparably to the predicate devices, and are substantially equivalent to the predicate devices. |
Meet internal functional specifications (including software) | Verification/validation testing to internal functional specifications (including software) was conducted and results were provided. |
Produce non-clinical image quality comparable to predicate devices | Non-clinical image comparisons involving flat panel display images taken by the new device and the predicate devices were performed. |
Usability of new features (e.g., Advanced Edge Enhancement) | Interviews were conducted with experienced clinicians on the usability of the advanced edge enhancement. |
Compliance with FDA requirements for software (Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices for a moderate LOC) | Documentation was provided demonstrating compliance, including results of verification/validation plus traceability of verification/validation tests to software requirements and software risk hazards. |
Compliance with other relevant FDA guidance (e.g., Radio Frequency Wireless Technology in Medical Devices, Cybersecurity) | Other FDA guidance documents used in development include Radio Frequency Wireless Technology in Medical Devices and Content of Premarket Submissions for Management of Cybersecurity in Medical Devices. Documentation provided confirmed changes do not impact compliance with FDA requirements for Solid State X-ray Imaging Devices. |
Compliance with U.S. Performance Standard for radiographic equipment and voluntary safety standards (IEC 60601 series) | Testing confirmed that the CXDI-702C Wireless and CXDI-402C Wireless comply with the U.S. Performance Standard for radiographic equipment and with relevant voluntary safety standards for Electrical safety and Electromagnetic Compatibility testing, specifically IEC standards 60601-1, 60601-1-2, 60601-1-6, and 60601-2-54. |
Biocompatibility (ISO 10993 series) | Biocompatibility evaluation confirmed that the changes did not impact safety and that the devices comply with ISO 10993-1, 10993-5, and 10993-10. |
No new questions regarding safety or effectiveness | Verification/validation activities successfully demonstrated that the device continues to meet standards for areas impacted by modifications and raises no new questions regarding either safety or effectiveness when compared to the predicate device. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not explicitly state a numerical sample size for the "non-clinical image comparisons" or "interviews with experienced clinicians." It refers to "tests performed on the models" and "non-clinical image comparisons." For a 510(k) Special submission, the focus is often on demonstrating that the modifications do not adversely affect performance, rather than a large-scale clinical trial.
- Data Provenance: Not explicitly stated. Given that it's a submission for products by Canon, Inc. (Japan), the non-clinical tests would typically be performed internally or by contracted labs. The "interviews with experienced clinicians" likely involved healthcare professionals in a relevant market, but the specific country is not detailed. The data is retrospective in the sense that it evaluates the modified device against known performance of the predicate device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Number of Experts: Not explicitly stated for image evaluation.
- Qualifications of Experts: The document mentions "experienced clinicians" for interviews regarding the usability of the Advanced Edge Enhancement feature. Their specific qualifications (e.g., "radiologist with 10 years of experience") are not detailed. For the image comparisons, it implies internal testing and comparison to established predicate performance rather than requiring independent expert reads to establish ground truth in the same way a diagnostic AI would.
4. Adjudication Method for the Test Set
- Adjudication Method: Not specified. For non-clinical image comparisons demonstrating comparability, a formal adjudication process like 2+1 or 3+1 by multiple readers is not typically detailed in this type of 510(k) submission. It's more about objective image quality metrics and visual comparison against predicate performance.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- MRMC Study: No, the document does not indicate that a formal MRMC comparative effectiveness study was conducted. This type of study is more common for novel diagnostic AI devices where the primary claim is an improvement in human reader performance with AI assistance. For a Special 510(k) of a digital X-ray detector with minor modifications, the focus is on maintaining equivalence rather than demonstrating improvement over human readers.
- Effect Size: Not applicable, as an MRMC study was not described.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable in the context of a digital X-ray detector. The device itself (the detector) processes images and provides them for display, but it doesn't have a diagnostic "algorithm" that operates independently to provide outputs like disease detection that would require a standalone performance evaluation in the same way a diagnostic AI software would. The "Advanced Edge Enhancement" is an image processing feature, not a diagnostic algorithm. The document explicitly states the "Standalone mode was removed from the proposed devices" for how the detector operates, meaning it always communicates with an operator console (human-in-the-loop for image review).
7. The Type of Ground Truth Used
- Ground Truth: For the non-clinical image comparisons, the "ground truth" would be established by comparing the images from the modified device against the known and accepted image quality and characteristics of the legally marketed predicate devices. This isn't "expert consensus" or "pathology" in the diagnostic sense, but rather a technical comparison of image properties (e.g., resolution, contrast, noise, and the visual appearance of anatomical structures) to ensure the modifications did not degrade quality. The "usability" of the Advanced Edge Enhancement was evaluated through clinician interviews, where their feedback implicitly serves as a form of ground truth for user experience.
8. The Sample Size for the Training Set
- Training Set Sample Size: The document does not describe a "training set" because the device is a digital X-ray detector, not an AI algorithm that learns from data. The "Advanced Edge Enhancement" is likely a rule-based or engineered image processing algorithm, not a machine learning model that requires a training set.
9. How the Ground Truth for the Training Set was Established
- Ground Truth for Training Set: Not applicable, as there is no mention of a training set for an AI algorithm.
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(58 days)
Intended for use by a qualified/trained doctor or technician on both adult and pediatic subjects for taking diagnostic radiographic exposures of the skull, spinal column, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography
These are redesigned versions of our predicate mobile digital diagnostic xray systems. They feature motorized movement and full battery operation. Various Canon digital Xray panels are supplied with the system. (See list above.) The Mobile X-Ray Unit PhoeniX has a Basic configuration or Advanced configuration. Advanced configurations include:
- Second screen on head assembly.
- Smooth movements of head assembly.
- Telescopic arm in four steps instead three steps for basic configuration.
The Mobile X-Ray unit is provided with touch screen to operate as a control console. The Digital Imaging System is composed by image receptors and application for image acquisition (control console & image processing controller). The Image acquisition software "CANON CXDI Control Software NE" runs on Mobile X-ray unit and it is displayed on touch screen. It is the user interface and compatible digital detectors are listed above. All have FDA Clearance. The Advanced configuration has a second Touch Screen Monitor located on head-assembly.
The PhoeniX Mobile X-Ray Unit is provided with separate battery packs for X-Ray generation and motorized movements of the unit can operate connected to mains or in stand-alone mode, that is, operating without mains being present or unplugged from mains. The unit is connected to mains to charge the batteries; New rating: the input voltage range goes from 100 V~ to 240 V~, 1 phase, 1.1 kVA. New X-ray generator (model SHFM) is mounted on Battery Mobile X-Ray unit PhoeniX. This new X-Ray generator for PhoeniX Mobile X-Ray Unit has a radiogenic unit mounted on headassembly and comprising an X-ray tube with rotating anode and its circuit for high voltage. The electronic and associated software to control the X-ray generation are placed on mobile cart. The Battery Mobile X-Ray Unit PhoeniX is provided with different output powers: 20 kW, 32 kW, 40 kW and 50 kW. There are available two X-ray tube inserts with rotating anode manufactured by CANON ELECTRON TUBES & DEVICES:
- New: XRR-3331 insert.
- New: E7886 insert.
New: Manual Beam Limiting Device from Ralco, model: R108 F. External interface (controls) and covers are provided by Sedecal. There are two versions of collimator assembly, Basic and Advanced.
The provided text describes a 510(k) premarket notification for a mobile X-ray system named PhoeniX. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting a standalone study for novel acceptance criteria.
Therefore, many of the requested items (acceptance criteria, specific study details with sample sizes, expert involvement, and ground truth information) are not directly addressed in the provided FDA submission as they would be for a de novo marketing authorization or a more extensive clinical study. The submission relies heavily on non-clinical testing and the prior clearance of its components and predicate devices.
However, I can extract information related to the device's technical specifications and the basis for its substantial equivalence, which implicitly acts as its "acceptance criteria" for regulatory clearance.
Here's an analysis based on the provided text, addressing the points where information is available:
1. Table of Acceptance Criteria (Implicit) and Reported Device Performance
The device is considered acceptable if its performance and specifications are substantially equivalent to the predicate device and meet relevant international standards. The "reported device performance" in this context refers to its technical specifications and compliance with safety standards, rather than clinical performance metrics like sensitivity or specificity.
Acceptance Criteria (Implicitly based on Predicate & Standards) | Reported Device Performance (PhoeniX) |
---|---|
Indications for Use: | Intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography. (SAME as Predicate) |
Configuration: | Mobile System with digital x-ray panel and image acquisition computer. (SAME as Predicate) |
kW Rating: | 20 kW, 32 kW, 40 kW and 50 kW. (Predicate: 40 kW only) |
kV Range: | From 40 kV to 150 kV in 1 kV steps. (SAME as Predicate) |
mA Range: | From 10 mA to 630 mA / 640 mA / 650 mA. (Predicate: From 10 mA to 500 mA) |
Collimator: | Ralco R108F (Two versions: Basic and Advanced). (Predicate: Ralco R221 DHHS) |
Digital X-ray Panels Supplied: | CANON CXDI-401C Wireless, CANON CXDI-701C Wireless, CANON CXDI-801C Wireless. (SAME as Predicate). Plus: CANON CXDI-710C Wireless, CANON CXDI-810C Wireless, CANON CXDI-410C Wireless. (New panels, but all previously FDA cleared). |
Software: | Canon control software CXDI-NE. (SAME as Predicate, updated in K190368) |
Panel Interface: | Ethernet or Wi-Fi wireless. (SAME as Predicate) |
Meets US Performance Standard: | YES 21 CFR 1020.30. (SAME as Predicate) |
Power Source: | Universal power supply, from 100 V~ to 240 V~. 1 phase, 1.1 kVA. (Predicate: Input transformer with 7 input voltage taps; AC 20 amp and Batteries) |
Safety and Effectiveness: | "The results of bench testing indicate that the new devices are as safe and effective as the predicate devices. Proper system operation is fully verified upon installation. We verified that the modified combination of components worked properly and produced diagnostic quality images as good as our predicate generator/panel combination." |
Compliance with International Standards: | IEC 60601-1:2005+A1:2012 (Edition 3.1), IEC 60601-1-2:2014 (Edition 4.0), IEC 60601-1-3:2008+A1:2013 (Edition 2.1), IEC 60601-2-54:2009+A1:2015 (Edition 1.1), IEC 60601-2-28:2010 (Edition 2.0), IEC 60601-1-6:2010 + A1:2013 (Edition 3.1), IEC 62304:2006 + A1:2016 (Edition 1.1). (Compliance affirmed through non-clinical testing) |
Regarding the Study Proving Acceptance Criteria:
The "study" in this submission is primarily a non-clinical bench testing and comparative analysis to establish substantial equivalence to a legally marketed predicate device (K161345 RadPRO® Mobile 40kW; RadPRO® Mobile 40kW FLEXPLUS).
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not specified in terms of number of images or patients. The non-clinical testing involved "Systems covering all generator/panel combinations were assembled and tested." This suggests testing of device configurations rather than a "test set" of medical images or patient data in the typical sense of an AI/CAD device.
- Data Provenance: Not applicable in the context of clinical data for a "test set." The testing是在实验室环境中,使用设备进行物理和功能验证。
3. Number of Experts and Qualifications to Establish Ground Truth:
- Not applicable as this was a non-clinical submission for substantial equivalence based on technical specifications and functionality. Clinical trials requiring expert reads for ground truth were not performed.
4. Adjudication Method:
- Not applicable as there was no clinical reading study or consensus required for ground truth determination.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study was not done. The document states: "Summary of clinical testing: Clinical testing was not required to establish substantial equivalence because all digital x-ray receptor panels have had previous FDA clearance." This device is a mobile X-ray system, not an AI or CAD software that assists human readers.
6. Standalone (Algorithm Only Without Human-in-the-loop) Performance:
- Not applicable. This device is an X-ray imaging system, not an algorithm that performs a diagnostic task independently. Its performance is related to image quality, radiation output, mechanical safety, and electrical safety.
7. Type of Ground Truth Used:
- Technical Specifications and Compliance with Standards: The "ground truth" for this submission are the established performance characteristics of the predicate device and the specified requirements of relevant international safety and performance standards (e.g., IEC 60601 series, 21 CFR 1020.30). The "truth" is that the device meets these engineering and regulatory benchmarks.
- The document mentions that the modified combination of components "produced diagnostic quality images as good as our predicate generator/panel combination," implying an internal assessment of image quality, but no explicit detailed ground truth generation method is described for clinical image interpretation.
8. Sample Size for the Training Set:
- Not applicable. This is not an AI/ML device that requires a training set of data. The device's components (X-ray generator, panels, software) are either updates to existing technology or previously cleared devices.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable, as there is no training set for an AI/ML algorithm.
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(35 days)
ProRad Series Stationary Radiographic System is intended for use by a qualified, trained doctor or technician on both adult and paediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position. Not for mammography.
The ProRad series Stationary Radiographic System is a diagnostic x-ray system intended for general purpose radiographic imaging of the human body. There are two types of configurations (2FC and 3NC) for ProRad; the difference is in the mounting of the X-ray tube. For X-ray tube mounting the configuration is either the floor mounted (2FC) or ceiling suspension (3NC) assembly.
The devices are a new combination of a previously cleared solid state digital x-ray acquisition panel and software with the diagnostic x-ray components (including Xray tube, high frequency X-ray generator, a tilting vertical bucky, X-ray table and collimator) required to make a complete system. The purchaser may select any of the digital panels and software based on the user's requirements. The other components are also available in different configurations to meet specific customer needs. The X-ray panel and imaging software have been previously cleared by the FDA, and most of the other components are used in previously cleared 510(k) devices.
Here's an analysis of the acceptance criteria and study information for the ProRad 2FC and ProRad 3NC Digital Stationary Radiographic Systems, based on the provided text:
Acceptance Criteria and Device Performance Table:
The document primarily focuses on demonstrating substantial equivalence to predicate devices rather than setting and reporting specific performance metrics with acceptance criteria in a comparative table for novel device features. The "Comparable Properties" table (pages 6-8) is used to show alignment with predicate devices.
Acceptance Criteria Category | Specific Criteria (Implicit from Equivalence) | Reported Device Performance (as stated in the document) |
---|---|---|
Intended Use | Equivalent to predicate devices (K150816, K153119) for diagnostic radiographic exposures of various body parts in adults and pediatrics, excluding mammography. | "Equivalent" to predicate devices. |
Configuration of Digital Panels | Battery or AC operated wireless IEEE 802.11n or Wired Ethernet. | "Same" as predicate devices. |
Digital Panel Models and their Clearance Numbers | Utilize previously cleared FDA digital flat panel detectors (specific K numbers listed in Note 1). | "Similar functionality" to predicate devices (Note 1 states the subject device uses different flat panel detectors that are previously FDA cleared, and testing demonstrates no increased safety concern or effect on effectiveness). |
Image Acquisition Panel Specifications | Comparable pixel resolution and size range (e.g., 3,320 x 3,408 Pixels 125 µm, 3,072 x 3,072 Pixels 139 µm, etc.). | "Similar functionality" to predicate devices (Note 1). |
DICOM Compliance | DICOM 3 compliant. | "Same" as predicate devices. |
WiFi Wireless (if applicable) | Functionality similar to predicate wireless detectors. | "Similar functionality" to predicate devices (specific Canon, Varex, PerkinElmer, and DRTECH wireless detectors listed). |
Image Acquisition Software | Utilize previously cleared FDA image processing software (specific K numbers listed in Note 2). | "Similar functionality" to predicate devices (Note 2 states Prognosys uses previously cleared FDA software and does not modify it). |
Power Source | AC Line, various voltages available. | "Same" as predicate devices. |
X-ray Generator | Range of power ratings (e.g., 32 kW to 80 kW, 125 kV/150 kV). | "Same or similar functionality" to predicate devices (Note 3 states the subject device uses similar X-ray generators with different power ratings and that these generators have been used in previously cleared 510(k) devices). |
X-ray Tubes | Range of kV, focal spot sizes, and heat units (e.g., Toshiba E7239FX, Varex RAD14, etc.). | "Similar functionality" to predicate devices (Note 4 states both configurations provide similar imaging resolution and these tubes have been used in previously cleared 510(k) devices). |
Collimator | Adequate inherent filtration. | "Similar functionality" to predicate devices (Note 5 states the inherent filtration is different but does not affect safety and effectiveness). |
Performance Standard Compliance | Compliance with FDA 21 CFR 1020.30-31 (Performance Standards for Diagnostic X-Ray Systems and Their Major Components). | "Same" as predicate devices. |
Electrical Safety | Compliance with IEC 60601-1. | "Same" as predicate devices. |
Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1-2. | Device complies with this standard. |
Radiation Protection | Compliance with IEC 60601-1-3. | Device complies with this standard. |
Specific Safety/Performance for X-ray Equipment | Compliance with IEC 60601-2-54. | Device complies with this standard. |
Usability | Compliance with IEC 60601-1-6. | Device complies with this standard. |
Risk Management | Compliance with ISO 14971. | Device complies with this standard. |
Cybersecurity | Adherence to "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, 2014" guidance for device labeling. | Cybersecurity concerns were addressed based on the US FDA Guidance document. |
1. Sample sized used for the test set and the data provenance:
- Sample Size: Not explicitly stated as a separate "test set" for a dedicated algorithm performance study. Instead, compliance is demonstrated through testing of the integrated system and reliance on previous FDA clearances for individual components.
- Data Provenance: Not applicable in the context of an algorithm performance test set. The clinical images reviewed by a radiologist were "acquired by the device," but the origin (e.g., country, prospective/retrospective status) is not specified.
2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Number of Experts: One radiologist.
- Qualifications of Experts: Only "a radiologist" is mentioned. Specific qualifications (e.g., years of experience, board certification) are not detailed.
3. Adjudication method for the test set:
- Adjudication method: Not applicable. The radiologist's review was a single assessment, not a consensus or adjudication process among multiple readers.
4. 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:
- MRMC Study: No. The document explicitly states: "Since the digital x-ray panels and software have previously received FDA clearance, a clinical study was not required as per the FDA guidance document." The clinical image review was supplementary.
- Effect size of human reader improvement with AI: Not applicable, as no MRMC study or AI assistance evaluation was conducted. The device is an imaging system, not an AI diagnostic tool.
5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Standalone Performance Study: No. This device is a diagnostic X-ray system, which intrinsically requires a human (a qualified doctor or technician) in the loop for operation and interpretation. The performance of individual cleared components (digital panels, software) was relied upon.
6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Type of Ground Truth: For the supplementary review, the "ground truth" was the radiologist's assessment that the images were "acceptable and allowed the radiologist to make an accurate diagnosis." This is a form of expert opinion on image quality and diagnostic utility, rather than an objective "truth" like pathology or outcomes.
7. The sample size for the training set:
- Sample Size for Training Set: Not applicable. This document does not describe a machine learning algorithm that requires a training set. The device is a conventional X-ray system composed of cleared components.
8. How the ground truth for the training set was established:
- Ground Truth for Training Set: Not applicable, as there is no machine learning algorithm described.
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