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510(k) Data Aggregation
(54 days)
The Z6 Diagnostic Ultrasound System is applicable for adults, pregnant women, pediatric patients and neonates. It is intended for use in fetal, abdominal, pediativ, small organ(breast, thyroid, testes), neonatal and adult cephalic, transrectal, trans-vaginal, musculo-skeletal(conventional, superficial), adult and pediatric cardiac, peripheral vessel , intraoperative(abdominal, thoracic, and vascular) and urology exams.
Z6 Diagnostic Ultrasound System is a general purpose, portable, software controlled, ultrasonic diagnostic system. Its function is to acquire and display ultrasound data in B-Mode, M-Mode, PW-Mode, CW-Mode, Color-Mode, Power/Dirpower Mode, 4D, Smart3D,TDI, Color M, Elastography, Biopsy Guidance, Contrast imaging (Contrast agent for Liver) or the combined mode (i.e. B/M-Mode, B/PW-mode, B/PW/Color). This system is a Track 3 device that employs an array of probes that include linear array and convex array.
This document is a 510(k) premarket notification for the Z6 Diagnostic Ultrasound System, which is a general-purpose ultrasonic diagnostic system. The document states that the device is substantially equivalent to legally marketed predicate devices and does not require clinical studies to support substantial equivalence. Therefore, the information typically associated with acceptance criteria and studies proving the device meets these criteria for a novel AI-driven medical device, such as detailed performance metrics, sample sizes for test sets, data provenance, expert ground truth establishment, adjudication methods, MRMC studies, or standalone algorithm performance, are not explicitly provided or applicable in the context of this specific 510(k) submission.
This 510(k) is primarily focused on demonstrating "substantial equivalence" to existing, legally marketed ultrasound devices (predicates). This means the device is shown to have the same intended use, similar technological characteristics, and be as safe and effective as a predicate device. The performance validation relies on non-clinical tests (acoustic output, biocompatibility, electrical/mechanical safety, etc.) and comparisons to previously cleared devices rather than new clinical efficacy studies.
Based on the provided text, here's what can be extracted regarding the device's validation and "acceptance criteria" in the context of a 510(k):
Acceptance Criteria (Implied by 510(k) Process for Substantial Equivalence):
The acceptance criteria for a 510(k) submission that relies on substantial equivalence are not explicit quantitative performance metrics like those for a novel AI algorithm. Instead, they are met by demonstrating that the new device:
- Has the same intended use as a predicate device.
- Has the same technological characteristics as a predicate device, or if it has different technological characteristics, that those differences do not raise new questions of safety or effectiveness AND the device is as safe and effective as the predicate device.
- Complies with applicable recognized safety standards.
The "Study" Proving the Device Meets Accepted Criteria (as described in the 510(k)):
The "study" here is the overall premarket notification submission process, which includes non-clinical testing and a detailed comparison to predicate devices, rather than a single clinical trial.
1. Table of Acceptance Criteria and Reported Device Performance:
Since this is a 510(k) for substantial equivalence and not a De Novo or PMA for a novel AI, there isn't a table of specific performance acceptance criteria like sensitivity, specificity, or AUC for an AI. Instead, the "performance" is demonstrated through adherence to safety standards and equivalence to predicate devices across various modes and applications.
Acceptance Criteria (Implied by 510(k) Process) | Reported Device "Performance" / Compliance |
---|---|
Intended Use Equivalence: Same intended use as predicate devices. | The Z6 system has the same intended uses as the predicate device Z6 (K122010). It is applicable for adults, pregnant women, pediatric patients, and neonates across various anatomical regions (fetal, abdominal, pediatric, small organ, neonatal/adult cephalic, trans-rectal, trans-vaginal, musculo-skeletal, cardiac, peripheral vessel, and urology exams). |
Technological Equivalence / No New Safety/Effectiveness Questions: Same or comparable technological characteristics as predicates, and any differences don't raise new safety/effectiveness concerns. | Z6 has the same technological characteristics as predicate devices. New added features (ECG, 4D, Smart3D, Contrast imaging, Elastography, Free Xros X, TDI, Color M, iNeedle, Medsight, iWorks, iLive) are deemed "substantially equivalent" to features found in other predicate Mindray devices (DC-30, M7, DC-70). |
Acoustic Output Safety: Acoustic power levels are below FDA limits. | The acoustic power levels of Z6 are below the limits of FDA, same as predicate device Z6(K122010). |
Electrical and Physical Safety: Compliance with recognized safety standards. | Z6 is designed in compliance with FDA recognized electrical and physical safety standards (e.g., AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-2-37, ISO 14971). |
Biocompatibility: Patient contact materials meet ISO standards. | Patient contact materials of new transducers and needle-guided brackets (NGB-001, NGB-002) are tested under ISO 10993-1. |
Cleaning and Disinfection Effectiveness: (Implied by general safety requirements) | Evaluated for cleaning and disinfection effectiveness. |
Usability: (Implied by general safety requirements) | Complies with IEC 60601-1-6 (usability standard). |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not applicable in the context of this 510(k). The regulatory pathway for this device (a general-purpose ultrasound system with additional features found in other cleared devices) does not typically require a "test set" of patient data for performance evaluation in the same manner a novel AI algorithm would. Instead, substantial equivalence is primarily demonstrated through non-clinical testing and comparison to existing, cleared devices.
- Data Provenance: Not applicable, as patient data test sets are not described. The validation is based on engineering testing and comparison to predicate device specifications.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts:
- Not applicable. There is no mention of a formal "ground truth" establishment by experts using a test set of patient data for the Z6 Diagnostic Ultrasound System in this 510(k). The submission focuses on device specifications, safety standards, and equivalence to predicate devices.
4. Adjudication Method for the Test Set:
- Not applicable. No test set requiring adjudication is described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done, and Effect Size of Human Readers Improvement with AI vs. Without AI Assistance:
- No. This 510(k) does not describe an MRMC study. The device is a diagnostic ultrasound system, not an AI-assisted interpretation tool in the manner that would typically necessitate such a study (e.g., for an AI CAD system). The "AI" features mentioned (Smart3D, iNeedle, etc.) are likely integrated functionalities that enhance image acquisition or guidance, not interpretative AI requiring MRMC.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done:
- Not applicable for the overall device. The device is an ultrasound system with integrated features. While some features (like "Smart3D" or "iNeedle") might involve internal algorithms, their performance is demonstrated as part of the overall device's functionality and comparison to similar features in predicate devices, not as standalone AI outputs that require independent assessment against a ground truth.
7. The Type of Ground Truth Used:
- Not explicitly defined as a "ground truth" for clinical performance. For a traditional ultrasound system seeking 510(k) clearance via substantial equivalence, the "ground truth" for regulatory purposes often refers to established engineering standards, existing predicate device performance, and the inherent safety/efficacy of ultrasound technology itself, rather than a clinical dataset with adjudicated diagnoses.
8. The Sample Size for the Training Set:
- Not applicable. This submission is for a diagnostic ultrasound system, not a machine learning model developed with a training set of patient data and medical images.
9. How the Ground Truth for the Training Set was Established:
- Not applicable. As there is no mention of a training set for an AI model, there is no ground truth establishment for it.
In summary: This 510(k) submission for the Z6 Diagnostic Ultrasound System relies on demonstrating substantial equivalence to existing, legally marketed ultrasound devices. It does so by showing that the device has the same intended use, comparable technological characteristics (with new features demonstrated as equivalent to those found in other cleared predicate devices), and complies with relevant safety and performance standards through non-clinical testing. It does not involve the type of clinical performance studies, test sets, or AI model validation methods typically associated with novel AI-driven devices seeking a different regulatory pathway or greater emphasis on clinical efficacy.
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