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510(k) Data Aggregation
(313 days)
Nightwear Aligners are indicated for the alignment of permanent teeth during orthodontic treatment of malocclusion.
The Smylio Nightwear Aligners are thermoformed plastic aligners designed to be worn in sequence to facilitate the movement to the final desired position. The sequential aligners introduce incremental movements that move teeth by way of gentle continuous force. The aligners are to be worn at least 9 to 12 hours a day and are to be removed for eating and for cleaning.
Smylio Nightwear Aligners are designed from digital scans of a patient's dentition submitted by a dental health professional (e.g., dentist or orthodontist). Using the scan, sequential dental models are designed and approved by the treating physician prior to manufacturing.
Once the treatment plan is reviewed and approved by a dental health professional, each 3D model from the treatment plan is manufactured. The aligner trays are then manufactured by thermoforming a dental thermoplastic sheet over each model. The aligners are shipped to the treating clinician's office where they are then distributed to the patient in sequential stages. The patients' dental health professional then monitors their treatment of the first aligner to the delivery of the final aligner.
Nightwear Aligners are a sequence of transparent aligners created from a digital orthodontic treatment plan. The Nightwear Aligners are fabricated of a transparent thermoformed polyurethane plastic. Each aligner delivers a unique combination of minor forces to create the planned tooth movement. The digital orthodontic treatment plan is created by a dental health professional. The Nightwear Aligners incorporate the use of attachments to create spaces and force points in order to cause minor tooth movement. These force points are located in specific areas and positioned in such a way that they provide a continuous force which slowly dissipates over time on the tooth to be moved for as long as the aligner is worn.
The provided text describes the Smylio Nightwear Aligners and its substantial equivalence to a predicate device (iSMILE Aligners K200908). However, it does not contain acceptance criteria or a study designed to explicitly prove the device meets specific performance acceptance criteria in terms of diagnostic accuracy or a quantitative measure of treatment effectiveness with a defined threshold.
Instead, the document focuses on demonstrating substantial equivalence for regulatory clearance based on:
- Similarities in Indications for Use: Both devices are indicated for the alignment of permanent teeth during orthodontic treatment of malocclusion.
- Similarities in Technological Characteristics: The device description, materials, manufacturing method, and mode of action are compared and found to be "Same" as the predicate device.
- Non-clinical performance testing: Durability testing, material property testing (ASTM D638, ASTM D790), and biocompatibility testing (ISO 10993 standards) were performed to ensure the material and manufacturing process are suitable.
- Clinical performance testing: An internal clinical study was conducted to demonstrate that tooth alignment may occur with the specified wear time for mild malocclusions. This is a descriptive finding rather than a performance metric against a predefined acceptance criterion.
Therefore, many of the requested items (acceptance criteria table, ground truth establishment, MRMC study, effect size) are not explicitly present or detailed in the provided text because the regulatory submission's goal was substantial equivalence, not necessarily a performance claim against specific quantitative targets.
However, I can extract the information that is present and note where the information is absent according to your request.
Description of Acceptance Criteria and Proving Study (Based on Provided Text)
The provided text focuses on establishing substantial equivalence to a predicate device (iSMILE Aligners, K200908) for regulatory purposes, rather than proving the device meets specific quantitative performance acceptance criteria in terms of treatment efficacy or diagnostic accuracy against a predefined threshold. The "acceptance criteria" can be inferred as successful demonstration of similar indications for use, technological characteristics, and safety and basic functional performance, which collectively support substantial equivalence.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Inferred from Substantial Equivalence Claim) | Reported Device Performance (as per text) |
---|---|
Indications for Use: Alignment of permanent teeth during orthodontic treatment of malocclusion. | Smylio Nightwear Aligners: Indicated for the alignment of permanent teeth during orthodontic treatment of malocclusion. Predicate (iSMILE Aligners): Indicated for the alignment of teeth during orthodontic treatment of malocclusion. (Result: Same) |
Technological Characteristics: Similar materials, design, manufacturing, and mode of action as predicate. | Smylio Nightwear Aligners: Thermoplastic Polymer, thermoformed, patient-specific, removable, delivers combination of minor forces for tooth movement. Predicate (iSMILE Aligners): Shares these characteristics. (Result: Same for all compared specifications including Regulation Number, Classification Name, Product Code, Classification, OTC or Rx, Material, Material Properties, Biocompatibility, Device Description, Anatomy Location, Size, Manufacturing Method, Patient Removable, Mode of Action.) |
Material Properties (Non-clinical): Sufficient tensile strength, elasticity, ductility, chemical resistance, and clarity. | Material property testing performed to investigate elongation, tensile and flexural properties in accordance with ASTM D638 and ASTM D790. Demonstrated sufficient properties. |
Manufacturing Process (Non-clinical): Robustness from 3D printing through thermoforming. | Internal manufacturing validation performed; robustness of process demonstrated. |
Durability (Non-clinical): Suitable for prescribed period of use in real-world simulation. | Durability testing conducted; ensured suitability. |
Biocompatibility (Non-clinical): Meets established standards for patient-contacting material. | Biocompatibility testing for aligner material performed in accordance with ISO 10993-1, ISO 10993-5:2009, ISO 10993-10:2010, and ISO 10993-11:2017. |
Clinical Performance: Tooth alignment may occur under specified conditions (for mild malocclusions). | Study demonstrated that tooth alignment may occur for patients with at least 9 to 12 hours of wear time per day for one week prior to moving to the next aligner for patients with mild malocclusions. |
2. Sample size used for the test set and the data provenance
- Sample Size (Clinical): 20 patients
- Data Provenance: The study was conducted internally under an FDA cleared IDE application (G200298). The country of origin is not specified but it is an internal clinical performance test. The study is prospective in nature as it is a "clinical performance testing" that "was conducted".
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of Experts: Not specified.
- Qualifications of Experts: The clinical performance was determined "as determined by the treating dentist." No further specific qualifications (e.g., years of experience, specialization) are provided for these dentists.
4. Adjudication method for the test set
- Adjudication Method: Not specified. The outcome was "as determined by the treating dentist," implying a single determination, not a consensus or adjudicated process among multiple experts.
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
- MRMC Study: No, an MRMC comparative effectiveness study was not performed. This device is an orthodontic aligner, not an AI-powered diagnostic tool, so such a study would not be applicable. The text does not mention AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. This device is a physical orthodontic aligner, not an algorithm or AI system.
7. The type of ground truth used
- Type of Ground Truth: The "ground truth" for the clinical performance was the observation that "tooth alignment may occur for patients with mild malocclusions as determined by the treating dentist." This appears to be a clinical assessment/outcome, not pathology, imaging, or universally accepted objective ground truth.
8. The sample size for the training set
- Training Set Sample Size: Not applicable. This refers to a physical medical device, not a machine learning algorithm that requires a training set. The "design" (digital models) is approved by the treating physician, but this is not a training set in the context of AI.
9. How the ground truth for the training set was established
- Ground Truth for Training Set: Not applicable (as above, no training set for an algorithm). The device design process involves digital scans and sequential dental models designed and approved by the treating physician, which would be the "input" for manufacturing, not a training set with established ground truth for an algorithm.
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(104 days)
The DR 600 system is a General Radiography X-ray imaging system used in hospitals, clinics and medical practices by radiographers, radiologists and physicists to make, process and view static X-ray radiographic images of the skeleton (including skull, spinal column and extremities), chest, abdomen and other body parts on adult, pediatric or neonatal patients.
In addition, the system provides the Agfa tomosynthesis option, which is intended to acquire tomographic slices of human anatomy and to be used with Agfa DR X-ray systems. Digital tomosynthesis is used to synthesize tomographic slices from a single tomographic sweep.
Applications can be performed with the patient in the sitting, standing or lying position.
This system is not intended for mammography applications.
The DR 600 with Tomosynthesis is a tomographic and solid state x-ray system (product codes IZF and MQB) intended to capture tomographic slices and static images of the human body. The DR 600 with Tomosynthesis is a ceiling mounted tomographic and general radiographic system that consists of a tube and operator console with a motorized patient table and/or wall stand. The DR 600 with Tomosynthesis uses Agfa's NX workstation with MUSICA2 ™ image processing and flat-panel detectors of the scintillator-photodetector type (Cesium Iodide - CsI or Gadolinium Oxysulfide - GOS). It is capable of replacing other direct radiography, tomography, image intensifying tubes and TV cameras, including computed radiography systems with conventional or phosphorous film cassettes.
The provided text describes the Agfa DR 600 with Tomosynthesis device and its K193262 510(k) submission. However, it does not contain specific acceptance criteria or a detailed clinical study demonstrating the device's meeting of these criteria. The document focuses on showing substantial equivalence to predicate devices primarily through technological characteristics and bench testing, not through comparative clinical effectiveness studies with explicit acceptance criteria for diagnostic performance.
Therefore, many of the requested details about acceptance criteria, clinical study design, sample sizes, ground truth establishment, expert qualifications, and MRMC studies are not present in the provided text. The document explicitly states: "No clinical trials were performed in the device. No animal or clinical studies were performed in the development of the new device."
Based on the available information, here's what can be extracted and what is missing:
Acceptance Criteria and Device Performance (as inferred from the document's approach to substantial equivalence):
Since no specific acceptance criteria for diagnostic performance (e.g., sensitivity, specificity, AUC) are presented, the "acceptance criteria" for this 510(k) appear to be primarily focused on demonstrating substantial equivalence to predicate devices through technical specifications, image quality evaluations (bench testing), and compliance with various electrical safety, EMC, and software standards.
Acceptance Criteria (Inferred from Document) | Reported Device Performance |
---|---|
1. Technological Characteristics are Identical/Equivalent to Predicates: |
- Communications (DICOM)
- Flat Panel Detectors (type, material, sizes, pixel size, dynamic range)
- Operator Workstation (Agfa NX)
- Image Processing (MUSICA DTS, MUSICA2, MUSICA3/3+)
- Operating System (Windows 7, 8, 8.1, 10)
- Display System (Separately cleared medical display)
- Power Supply
- Generators
2. Indication for Use statement is consistent/identical to predicates.
3. Performance/Functionality as Intended:
- Confirmed functions and performs as intended.
- Supports a tomographic workflow and Smart Dr visualization (including adult and pediatric patients).
4. Image Quality Equivalent to Predicate:
- For both adult and pediatric patients.
5. Software Validation:
- Verification and validation plans confirmed.
- Risk assessment shows no unacceptable risks.
6. Electrical Safety and EMC Compliance:
- Adherence to specified IEC standards (60601-1, 60601-1-2, 60601-1-3, 60601-1-6, 60601-2-28, 60601-2-54).
- Compliance with FDA Subchapter J mandated performance standard 21 CFR 1020.30 and 1020.31.
7. Quality Management System Compliance:
- Adherence to ISO 13485:2015, ISO 14971:2012, ACR/NEMA PS3.1-3.20 (DICOM). | 1. Technological Characteristics:
- Communications: Same as both predicates (DICOM).
- Flat Panel Detectors: Same as both predicates (Flat Panel Detectors, GOS/CsI Scintillator, various sizes 17x17, 14x17, 10x10 in., 148 µm pixel size in primary predicate, 139 µm in other, 16 bit dynamic range in primary predicate, 14 bit in other). The new device shares characteristics with both, indicating equivalence.
- Operator Workstation: Same as both predicates (Agfa NX).
- Image Processing: MUSICA DTS, MUSICA2, MUSICA3/3+. The addition of tomographic image processing is identical to the DR 800 (K183275) primary predicate device.
- Operating System: Same as predicate K183275 (Windows 7, 8, 8.1, 10).
- Display System: Same as both predicates (Separately cleared medical display K051901).
- Power Supply: Same as predicate K152639 (50-60 Hz, 380/400/415/440/480V + 10%).
- Generators: Same as predicate K183275 (Choice of three models: 50, 65KW, 80 KW).
- Overall: "Principles of operation and technological characteristics of the new and predicate devices are the same."
2. Indication for Use: "The DR 600 system is a General Radiography X-ray imaging system... In addition, the system provides the Agfa tomosynthesis option... Digital tomosynthesis is used to synthesize tomographic slices from a single tomographic sweep." This is stated to be "virtually identical" to K152639 with the tomosynthesis addition from K183275.
3. Performance/Functionality:
- "Technical and acceptance testing was completed on the DR 600 in order to confirm the medical device functions and performs as intended. All deviations or variances are documented... All design input requirements have been tested and passed."
- "Functionality evaluations were conducted with three qualified radiographers. Usability and TBD. The results of these tests fell within the acceptance criteria for the DR 600; therefore, the DR 600 supports a tomographic workflow and Smart Dr visualization including adult and pediatric patients."
4. Image Quality: "Image quality bench tests were conducted in support of this 510(k) submission in which anthropomorphic adult and pediatric images taken with the DR 600 and the primary predicate device, DR 800 (K183275) were compared to ensure substantial equivalency. The test results indicated the image processing of the DR 600 passed the acceptance criteria and was equal to the image processing for the primary predicate, DR 800 (K183275) device for both adult and pediatric patients."
5. Software Validation: "Verification and validation testing confirmed the device meets performance, safety, usability and security requirements... For the NX22 (NX Nomad) software there are a total of 342 risks in the broadly acceptable region and 27 risks in the ALARP region with only one of these risks identified. Zero risks were identified in the Not Acceptable Region."
6. Electrical Safety and EMC Compliance: Document states compliance with all listed IEC standards and FDA performance standards.
7. Quality Management System Compliance: Document states adherence to all listed ISO and other standards. |
Study Details (Based on the provided text):
-
Sample sizes used for the test set and the data provenance:
- Test Set: No specific numerical sample size is mentioned for image quality evaluations beyond "anthropomorphic adult and pediatric images." The document mentions "functionality evaluations were conducted with three qualified radiographers," but this refers to human user testing of workflow and usability, not diagnostic image performance.
- Data Provenance: Not explicitly stated, but likely retrospective as it refers to comparisons of images taken with the new device and a predicate device. The comparison of anthropomorphic phantom images suggests a controlled laboratory setting.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document states "Laboratory data and image quality evaluations conducted with internal and independent specialists confirm that performance is equivalent to the predicates." It also mentions "clinical image quality evaluations for adults and pediatric patients" and "functionality evaluations were conducted with three qualified radiographers."
- Number of Experts: At least "three qualified radiographers" for functionality, and "internal and independent specialists" for image quality, but exact numbers or specific qualifications (e.g., years of experience, board certification) are not detailed.
- Qualifications: "Qualified radiographers" and "internal and independent specialists."
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No adjudication method is described for the image quality evaluations or other performance tests. The comparison to predicates implies direct visual or quantitative comparison by specialists.
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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 was done. The document explicitly states: "No clinical trials were performed in the device. No animal or clinical studies were performed in the development of the new device."
- Therefore, no effect size of human readers improving with AI assistance is provided as this type of study was not conducted. The device in question is an imaging system, not an AI-based diagnostic assistance tool.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The "performance data including clinical image quality evaluations for adults and pediatric patients" involved the system's output. The "image processing of the DR 600 passed the acceptance criteria and was equal to the image processing for the primary predicate, DR 800 (K183275) device for both adult and pediatric patients." This implies an evaluation of the algorithm's output (image quality) without necessarily focusing on a human-in-the-loop diagnostic task. So, in essence, standalone image quality performance was evaluated against a predicate.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for image quality evaluation appears to be comparison to a cleared predicate device's image quality, as judged by "internal and independent specialists," using anthropomorphic phantoms. There is no mention of pathological confirmation or patient outcomes for establishing ground truth, as it was not a clinical trial.
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The sample size for the training set:
- This device is an X-ray system with image processing, not a machine learning/AI algorithm that requires a "training set" in the traditional sense of AI development. The software capabilities (MUSICA DTS, MUSICA2, MUSICA3/3+) are described as being identical to previously cleared versions in predicate devices. Therefore, a "training set" for a new AI model is not applicable here.
-
How the ground truth for the training set was established:
- Not applicable, as no new AI model training set is described. The image processing algorithms are identical to those previously cleared.
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(25 days)
The DR 100s system is a mobile X-ray imaging system used in hospitals, clinics and medical practices by radiographers and radiologists to make, process and view static X-ray radiographic images of the skeleton (including skull, spinal column and extremities), chest, abdomen and other body parts on adult, pediatric or neonatal patients.
Applications can be performed with the patient in the sitting, standing or lying position.
This device is not intended for mammography applications.
Agfa's DR 100s is a mobile x-ray system, a direct radiography system (product code ILL) intended to capture images of the human body. The device is an integrated mobile digital radiography x-ray system. The complete DR 100s systems consists of the mobile x-ray unit with integrated x-ray generator and NX software and one or more DR detectors. The new device uses Agfa's NX workstation with MUSICA image processing and flat-panel detectors for digital image capture. It is compatible with Agfa's computed radiography systems as well.
This submission is to add another mobile unit to Agfa's direct radiography portfolio.
The optional image processing allows users to conveniently select image processing settings for different patient sizes and examinations. The image processing algorithms in the new device are identical to those previously cleared in the DX-D 100 (K103597) and other devices in Agfa's radiography portfolio today, which includes DR 600 (K152639), DR 400 (K141192) and DR 800 (K183275).
Significant dose reduction can be achieved using the DR 100s with patented Agfa's MUSICA imaging processing and CsI flat-panel detectors. Testing with board certified radiologists determined that Cesium Bromide (CR) and Cesium Iodine (DR) detectors when used with MUSICA imaging processing can provide dose reduction between 50-60% for adult patients and up to 60% for pediatric and neonatal patients when compared to traditional Barium Fluoro Bromide CR systems (K141602).
Principles of operation and technological characteristics of the new and predicate device are the same. The new device is virtually identical to Agfa's DX-D 100(K103597) with the exception that it has a telescopic column and ergonomic design. It uses the same flat panel detectors to capture and digitize the image. Differences in devices do not alter the intended diagnostic effect.
The provided text describes the DR 100s mobile X-ray system and its substantial equivalence to a predicate device, the DX-D 100. However, it does not contain specific acceptance criteria or a detailed clinical study proving the device meets these criteria in the manner requested.
The document states that the DR 100s uses the same image processing algorithms and flat-panel detectors as previously cleared devices, and that "Clinical image validation was conducted during testing in support for the 510(k) clearances for the flat-panel detectors (K161368 and K172784) and MUSICA software (K183275) in a previous submission." It also mentions that "Image quality bench tests were conducted in support of this 510(k) submission in which anthropomorphic adult and pediatric images taken with the DR 100s and the predicate device, DX-D 100 (K103597) were compared to ensure substantial equivalency. The test results indicated the image processing of the DR 100s passed the acceptance criteria."
This means the primary method for demonstrating equivalence and meeting acceptance criteria was through bench testing and referencing prior clearances for components. There's no detailed mention of a specific, standalone clinical study with human patients for the DR 100s itself, nor a multi-reader multi-case (MRMC) study.
Therefore, many of the requested details about a clinical study's methodology (sample size, data provenance, expert numbers, adjudication, MRMC results, ground truth types) cannot be extracted from this document directly for the DR 100s.
Here's an attempt to answer the questions based only on the provided text, acknowledging where information is missing:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly list quantitative acceptance criteria in a table format for image quality or specific diagnostic performance metrics (e.g., sensitivity, specificity). Instead, it states:
- "The test results indicated the image processing of the DR 100s passed the acceptance criteria." (for image quality bench tests)
- "All design input requirements have been tested and passed." (for technical and acceptance testing)
- "The results of these tests fell within the acceptance criteria for the DR 100s X-ray system therefore, the DR 100s supports a General radiographic workflow including adult and pediatric patients." (for usability and functionality)
Without specific numerical criteria, a performance table cannot be constructed. The main "performance" metrics provided are technical specifications of the flat-panel detectors (DQE, MTF, pixel size, etc.) which are compared to predicate devices but don't represent acceptance criteria for a clinical study proving diagnostic performance.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: Not specified for the image quality bench tests. The document only mentions "anthropomorphic adult and pediatric images."
- Data Provenance: Not specified (e.g., country of origin, retrospective/prospective). The studies are described as "bench tests" using anthropomorphic phantoms, not real patient data directly for the DR 100s itself. The "clinical image validation" mentioned refers to prior 510(k) clearances for components (detectors and software), not this specific device submission.
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)
- Number of Experts: Not specified.
- Qualifications of Experts: It vaguely mentions "internal experts" for usability and functionality evaluations. For the "clinical image validation" of previously cleared components, it references validation conducted with "board certified radiologists" for dose reduction testing (K141602), but this is for a different aspect (dose reduction with MUSICA and CsI detectors) and potentially not the core image quality comparison for equivalence of the total system.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Adjudication Method: Not specified.
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
- MRMC Study: No MRMC study is explicitly mentioned for the DR 100s. The document states "No clinical trials were performed in the development of the device. No animal or clinical studies were performed in the development of the new device."
- Effect Size: Not applicable, as no MRMC study was performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- The device is a mobile X-ray system and image processor, not an AI algorithm for diagnosis. Its performance is inherent in the image acquisition and processing. The "image processing of the DR 100s passed the acceptance criteria" refers to the system's ability to produce images comparable to the predicate. Therefore, the "standalone" performance is the image quality produced directly by the system.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For the image quality bench tests, the "ground truth" was likely established through objective phantom measurements and comparison to the predicate device, rather than clinical ground truth (expert consensus, pathology, or outcomes data). The document refers to "anthropomorphic adult and pediatric images" meaning images of phantoms designed to mimic human anatomy.
8. The sample size for the training set
- Training Set for DR 100s: The DR 100s system itself is a hardware device with integrated software for image processing (MUSICA). It's not an AI model that undergoes a "training" phase in the conventional sense (e.g., deep learning). The MUSICA image processing algorithms are stated to be "identical to those previously cleared" in other Agfa devices (K103597, K152639, K141192, K183275). Therefore, any "training" (algorithm development/tuning) would have occurred for these prior versions/devices, and no specific training set for the DR 100s is mentioned.
9. How the ground truth for the training set was established
- Not applicable/Not specified as the DR 100s itself does not undergo a "training" phase like a new AI algorithm. The MUSICA algorithms were previously developed and cleared.
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