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510(k) Data Aggregation

    K Number
    K173433
    Date Cleared
    2018-02-05

    (95 days)

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

    K163210, K153318, K170113, K171461

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

    ProxiDiagnost N90 is a multi-functional general R/F system. It is suitable for all routine radiography and fluoroscopy exams, including specialist areas like angiography or pediatric work, excluding mammography.

    Device Description

    The ProxiDiagnost N90 is a multi-functional nearby controlled fluoroscopy system in combination with a high-end digital radiography system consisting of a floor-mounted tiltadjustable patient support table and a scan unit consisting of a tube and a flat panel dynamic detector, Pixium FE4343F, for the fluoroscopy examinations. The tabletop can be moved by a motor in the lateral and longitudinal direction and can be tilted -85° to +90° degrees. The scan unit tilts with the table and can be moved in the longitudinal and lateral direction, relative to the table and to the patient. The fully integrated system is provided with a x-ray tube(s) with collimator and high resolution displays. The ProxiDiagnost N90 is configured with a Philips x-ray generator and a flat panel dynamic detector, Pixium FE4343F, components of the Philips radiography/fluoroscopy Image Chain. As additional options, the ProxiDiagnost N90 can be used as a digital radiography system consisting of a mounted tube in a ceiling suspension together with the portable or fixed detector in the vertical stand.

    AI/ML Overview

    Based on the provided text, the ProxiDiagnost N90 is evaluated for substantial equivalence to its predicate device, EasyDiagnost Eleva (K031535). The document outlines non-clinical data and makes a case against the need for a clinical study.

    Here's an analysis of the requested information:

    1. Table of acceptance criteria and the reported device performance:

    The document broadly states that "The test results demonstrate that the proposed ProxiDiagnost N90 meets the acceptance criteria and is adequate for its intended use." However, specific numerical acceptance criteria or performance metrics for the ProxiDiagnost N90 are not detailed in a table. The comparison provided focuses on demonstrating technological similarities to the predicate device rather than presenting specific performance thresholds for the new device.

    The "Discussion" column in the "Summary of technological characteristics" table implicitly suggests that if a characteristic is "Similar" or "Equivalent" to the predicate, it meets acceptance criteria for substantial equivalence.

    FeaturePredicate Device (EasyDiagnost Eleva (K031535))Proposed Device (ProxiDiagnost N90 (K173433))Acceptance Criteria (Implicit from Discussion)Reported Device Performance (Implicit)
    Working height (table top center to floorplate)83cm83.3cmSimilar to predicate; differences do not affect safety or effectiveness.Meets criteria
    Table tilt movement-20° to +90° (Optional: -30°, -45°, -85° to +90°)-90° to +90° movement speed with variable 1 to 6°/sSimilar to predicate; differences do not affect safety or effectiveness.Meets criteria
    Table top suspensionTwo sides suspensionsTwo sides suspensionsEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Table top materialPlastic laminate or carbon fiberSandwich of laminate, carbon and foamSimilar to predicate; differences do not affect safety or effectiveness.Meets criteria
    Table top movementLateral: -10 cm to + 9 cm, Longitudinal: ± 83 cmLateral: -10 cm to + 9 cm, Longitudinal: ± 83.5 cmEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Table top absorption0.7mm typical (@ 100kV, 2.7mm Al HVL)0.6mm Al typical @ 100kVSimilar to predicate; minor differences do not affect safety or effectiveness.Meets criteria
    Maximum patient weight180 kgstatic: 300 kg, tilt: 250 kg, all movements: 185 kgProposed device holds more weight; does not affect safety or effectiveness.Meets criteria
    Lateral scan distance22 cm22 cmEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Lateral scan speedManual MovementManual MovementEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Longitudinal scan distance75 cm mechanical range75 cm mechanical rangeEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Table column angulation-85° to +90°-85° to +90°Equivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Source image distance73 cm – 103 cm, 88 cm – 118 cm with Geomat in extended position81 cm – 130 cmSimilar to predicate; differences do not affect safety or effectiveness.Meets criteria
    CollimatorSquare / rectangular plus Irisrectangular collimationNo impact on safety or effectiveness. Same as reference device (CombiDiagnost R90).Meets criteria
    GridParkableParkableEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Picture archiving and communication systemYesYesEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Image chain (fluoroscopy)Philips Image Intensifier / CCD TV / Digital ImagingPhilips Dynamic Eleva Image ChainNo impact on safety or effectiveness. Same as reference device (Eleva Workspot with SkyFlow, CombiDiagnost R90).Meets criteria
    DetectorImage Intensifier 23 cm, 31 cm or 38 cmPixium FE 4343FNo impact on safety or effectiveness. Same as reference device (CombiDiagnost R90).Meets criteria
    Modulation Transfer Function (MTF) (according to IEC 62220-1-3 standard)Not available1 lp/mm 66%, 2 lp/mm 35%, 3 lp/mm 19%, 3.4 lp/mm 15%No impact on safety or effectiveness. Same as reference device (CombiDiagnost R90).Meets criteria (implicitly, as it aligns with a cleared component)
    Detective Quantum Efficiency (DQE) (according to IEC 62220-1-3 standard)Not availableDQE at 1 µGy: 0.05 lp/mm 65%, 1 lp/mm 51%, 2 lp/mm 41%, 3 lp/mm 27%, 3.4 lp/mm 18%No impact on safety or effectiveness. Same as reference device (CombiDiagnost R90).Meets criteria (implicitly, as it aligns with a cleared component)
    Wireless Static Detector for Radiographic ExamsWireless Portable Detector Pixium4600 (previous version of SkyPlate Detector)SkyPlate DetectorNo impact on safety or effectiveness. Same as reference device (SkyPlate Detectors for R/F Systems).Meets criteria
    Wireless Static Detector for Radiographic ExamsN/APixium RCENo impact on safety or effectiveness. Same as reference device (Pixium RCE).Meets criteria
    GeneratorPhilips Velara GCF/RF, 50kW, 65kW or 80kWPhilips Velara GCF/RF, 65 kW, optional 80 kWEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    TubePhilips SRO 2550 or SRM 2250 GSPhilips SRM 2250 ROT-GS 504 or SRO 2550 ROT380 or SRO 33100 ROT380 (optional in CSM)Equivalent to predicate; no impact to safety or effectiveness.Meets criteria
    System ControlNear byNearbyEquivalent to predicate; no impact to safety or effectiveness.Meets criteria
    Indications for UseMulti-functional/universal system, general R/F, Fluoroscopy, Radiography and Angiography, pediatric examinations and some more specialized interventional applications.Multi-functional general R/F system, all routine radiography and fluoroscopy exams, including specialist areas like angiography or pediatric work, excluding mammography.Equivalent to predicate; similar to reference device (CombiDiagnost R90).Meets criteria

    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 explicitly states: "The proposed ProxiDiagnost N90 did not require a clinical study since substantial equivalence to the currently marketed and predicate device was demonstrated with the following attributes: Design features, Indication for use, Fundamental scientific technology, Non-clinical performance testing including validation; and Safety and effectiveness."

    Therefore, there is no test set sample size from a clinical study for the ProxiDiagnost N90 itself. The evaluation relied on non-clinical verification and validation tests against recognized consensus standards and a comparison to the predicate and reference devices.

    No information on data provenance for a clinical test set is available, as no clinical study was conducted.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    Since no clinical study was performed and no test set with clinical data was used for evaluation, there were no experts used to establish ground truth for a test set in this submission.

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

    As no clinical test set was used for evaluation of the ProxiDiagnost N90, no adjudication method was applied for a test set.

    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:

    There is no mention of a multi-reader multi-case (MRMC) comparative effectiveness study being conducted for the ProxiDiagnost N90. The device is a general R/F system, not an AI-assisted diagnostic tool, so such a study would not be relevant in this context.

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

    The device is an imaging system, not an algorithm in the AI sense. Its "performance" would relate to image quality and system functionality, which was assessed through non-clinical performance testing (verification and validation tests according to standards like IEC 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-54, IEC 62220-1). These tests are typically "standalone" in that they evaluate the device's technical specifications and functionality independent of direct human interpretation studies.

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

    For the non-clinical performance and validation tests, the "ground truth" would be established by the specified engineering tolerances, recognized international standards (e.g., IEC standards for image quality, safety, and performance), and the performance characteristics of the predicate and reference devices. For instance, the MTF and DQE values for the detector are reported and implicitly "compared" to cleared components, meaning the "ground truth" for the acceptance of these values is their alignment with previously cleared and accepted digital imagers.

    8. The sample size for the training set:

    As no clinical study was performed and the device is an imaging system (not an AI model requiring a training set), there is no training set sample size.

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

    Since no training set was used, ground truth for a training set was not established.

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