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510(k) Data Aggregation

    K Number
    K222080
    Date Cleared
    2022-10-06

    (83 days)

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

    K200218

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

    The Garion is intended to be used and operated by: adequately trained, qualified and authorized health care professionals who have full understanding of the safety information and emergency procedures as well as the capabilities and functions of the device. The device is used for radiological guidance and visualization during diagnostic, interventional and surgical procedures on all patients, except neonates (birth to one month), within the limits of the device is to be used in health care facilities both inside and outside the operating room, sterile as well as non-sterile environment in a variety of procedures.

    Device Description

    GARION is mobile fluoroscopy system is designed to provdie fluoroscopic and spot-film images of thepatient during diagnostic, surgical procedures. This device is a digital X-ray radiographic equipment that consists of high voltage generator, X-ray control unit, X-ray tube unit, Collimator, image processing unit. The image processing unit consists of medical image detector, power supply, medical image collecting unit and relevant software.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called "Garion", an image-intensified fluoroscopic x-ray system. The document focuses on demonstrating substantial equivalence to a legally marketed predicate device, "Zenition 70".

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document focuses on demonstrating substantial equivalence to a predicate device rather than defining specific performance acceptance criteria for the Garion device against a set of quantitative metrics. The "performance" is implicitly assessed through a comparison of technical characteristics to the predicate.

    Acceptance Criteria (Implicit from Substantial Equivalence Claim)Reported Device Performance (Comparison to Predicate: Zenition 70 K183040)
    Indications for UseSame as predicate
    X-ray Tube Anode TypeRotating Anode (Same as predicate)
    X-ray Tube Anode Target Angle10° (Same as predicate)
    X-ray Tube Focal Size0.3/0.6 (Same as predicate)
    Fluoroscopic Mode kV range40-125 kV (Similar, slightly higher peak kVp than predicate's 40-120 kV)
    Fluoroscopic Mode mA range0.1-100 mA (Similar, slightly higher mA than predicate's 0.5-60 mA)
    Pulse FluoroYES (Same as predicate)
    ABS functionYES (Same as predicate)
    FPD ScintillatorCesium Iodide (Same as predicate)
    FPD Detector typeAmorphous silicon detector (Same as predicate)
    FPD Active detector size228.6 mm x 228.6 mm (Similar, slightly larger image than predicate's 207x207 mm)
    FPD Total pixel matrix1024x1024 (Similar to predicate's 1344x1344)
    FPD Pixel pitch205 μm (Similar to predicate's 154 μm)
    FPD A/D Conversion16 bit (Same as predicate)
    FPD MTF (1.0 lp/mm)0.64 (Similar, slightly better than predicate's 0.59)
    FPD DQE (0 lp/mm)0.77 (Same as predicate)
    SID980mm (Similar to predicate's 993mm)
    C-arm Rail Rotation Range±180° (Similar to predicate's ±200°)
    Linear FR-arm Movement Range200mm (Same as predicate)
    Linear T-arm Movement Range400mm (Similar to predicate's 490 mm)
    Swing-arm Rotation Range±15° (Similar, slightly better than predicate's ±10°)
    Collimator ControlMotor control / rotation (Same as predicate)

    The acceptance criterion, in this context, is that the Garion device's technological characteristics are substantially equivalent to the predicate device, implying similar safety and effectiveness. The reported performance is the direct comparison of these characteristics.

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

    The document explicitly states: "9. Summary of clinical testing: Not required for a finding of substantial equivalene." This indicates that no clinical test set was used to evaluate the device's performance against specific acceptance criteria. The evaluation relies on comparing the technical specifications of the new device to the predicate device and adherence to relevant IEC standards.

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

    Since no clinical test set was used, there were no experts establishing ground truth for a test set.

    4. Adjudication Method for the Test Set:

    Not applicable, as no clinical test set was used.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

    No, an MRMC comparative effectiveness study was not done. The document states that clinical testing was not required for substantial equivalence.

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

    The "Garion" is an X-ray system, not an AI algorithm. Therefore, the concept of "standalone (algorithm only)" performance is not applicable in the same way as it would be for a pure software device. The evaluation is of the hardware and integrated software for image acquisition and display.

    7. The Type of Ground Truth Used:

    The "ground truth" for the substantial equivalence claim is effectively the established safety and effectiveness of the legally marketed predicate device (Zenition 70), supported by the device's compliance with applicable performance standards (IEC and FDA Radiation Safety Performance Standard). The comparison of technical specifications aims to show that the Garion device is sufficiently similar to the predicate to assume similar safety and effectiveness.

    8. The Sample Size for the Training Set:

    The concept of a "training set" is typically associated with machine learning or AI algorithms. Since this submission is for an X-ray system and does not mention any AI components requiring supervised learning, there is no training set in the conventional sense.

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

    Not applicable, as there is no mention of a training set or AI algorithms requiring ground truth establishment.

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    K Number
    K212813
    Device Name
    Zenition 70
    Date Cleared
    2021-10-01

    (28 days)

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

    K200218

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

    The proposed Zenition 70 is intended to be used and operated by: adequately trained, qualified and authorized health care professionals who have full understanding of the safety information and emergency procedures as well as the capabilities and functions of the device.

    The device is used for radiological guidance and visualization during diagnostic, interventional and surgical procedures on all patients, except neonates (birth to one month), within the limits of the device. The device is to be used in health care facilities both inside and outside the operating room, sterile as well as non-sterile environment in a variety of procedures.

    Applications:

    • Orthopedic
    • Neuro
    • Abdominal
    • Vascular
    • Thoracic
    • Cardiac
    Device Description

    The proposed Zenition 70 is a mobile, diagnostic X-ray imaging and viewing system. It is designed for medical use in healthcare facilities where X-ray imaging is needed. The system comprises two main components: The C-arm stand and a mobile view station.

    AI/ML Overview

    The provided text is a 510(k) summary for the Philips Zenition 70, a fluoroscopic X-ray system. The submission focuses on demonstrating substantial equivalence to a predicate device (previous Zenition 70 model K183040) and a reference device (Digiscan FDX K200218) by adding a new flat panel detector (FD17) and some software/UI updates.

    The document states that no clinical studies were required as substantial equivalence was demonstrated through non-clinical performance testing and similarity in indications for use and technological characteristics. Therefore, the device's acceptance criteria are primarily met through compliance with recognized standards and verification of technical performance, rather than a clinical study involving human readers or a set of clinical cases with ground truth.

    Here's an analysis of the provided information based on your request:

    1. A table of acceptance criteria and the reported device performance

    The document doesn't present a table of specific clinical acceptance criteria and corresponding performance metrics from a study involving clinical cases. Instead, the acceptance criteria are largely defined by adherence to a comprehensive list of international and FDA-recognized consensus standards and FDA guidance documents. The "reported device performance" is the statement that the device complies with these standards.

    Acceptance Criteria CategorySpecific Criteria (as derived from the text)Reported Device Performance
    Basic Safety & Essential PerformanceCompliance with ES60601-1:2005/(R)2012 and A1:2012Complies
    Electromagnetic DisturbancesCompliance with IEC 60601-1-2 (Edition 4.0 2014-02)Complies
    Radiation Protection (Diagnostic X-Ray)Compliance with IEC 60601-1-3 (Edition 2.1 2013-04)Complies
    UsabilityCompliance with IEC 60601-1-6 (Edition 3.1 2013-10) and IEC 62366-1 (Edition 1.0 2015-02)Complies
    Safety & Performance (Interventional X-Ray)Compliance with IEC 60601-2-43 (Edition 2.1 2017-05)Complies
    Safety & Performance (Radiography and Radioscopy)Compliance with IEC 60601-2-54 (Edition 1.2 2018-06)Complies
    X-Ray Tube AssembliesCompliance with IEC 60601-2-28 (Edition 2.0 2010-03)Complies
    Software Life Cycle ProcessesCompliance with IEC 62304 (Edition 1.1 2015-06)Complies
    Risk ManagementCompliance with ISO 14971 (Edition 2.0 2007-03)Complies
    Medical Device SymbolsCompliance with ISO 15223-1 (Edition 3.0 2016-11)Complies
    Solid State X-ray Imaging DevicesAdherence to "FDA Guidance for the Submission of 510(k)'s for Solid State X-ray Imaging Devices"Assessed and Verified
    Pediatric InformationAdherence to "Pediatric Information for X-ray Imaging Device Premarket Notifications"(Not explicitly stated as "complies" but is a guidance document followed)
    Software in Medical Devices (Content of Submissions)Adherence to "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices"(Not explicitly stated as "complies" but is a guidance document followed)
    Cybersecurity ManagementAdherence to "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices"(Not explicitly stated as "complies" but is a guidance document followed)
    Image Quality PerformanceImage quality performance of FD17 (PX3030S) compared to FD15 (PX2630Sv) and FD12 (PX2121CV/S) detectors.Found to be equal.
    Safety and EffectivenessNo new questions regarding safety or effectiveness raised by differences.Demonstrated for substantial equivalence.
    Intended Use & Technical ClaimsNon-clinical V&V tests performed with regards to intended use, technical claims, requirement specifications, and risk management results.All tests used to support substantial equivalence and demonstrate the device meets acceptance criteria and is adequate for intended use.

    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 Zenition 70 did not require clinical study since substantial equivalence to the currently marketed and predicate device Zenition 70 was demonstrated with the following attributes: Indications for use; Technological characteristics; Non-clinical performance testing; and Safety and effectiveness."
    Therefore, there was no test set of clinical cases that a sample size would apply to. The testing involved non-clinical performance evaluations against standards.

    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, as no clinical test set requiring expert ground truth was performed.

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

    Not applicable, as no clinical test set requiring adjudication was performed.

    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

    Not applicable. This is a submission for an X-ray imaging system, not an AI-powered diagnostic device, and no MRMC study was conducted.

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

    Not applicable, as this is an imaging system, not a standalone algorithm. Its performance is evaluated through technical standards.

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

    The "ground truth" for this submission comes from the established and recognized international and FDA standards for medical electrical equipment and X-ray imaging devices. The performance of the new FD17 detector was compared to the predicate detectors, where "image quality performance...is compared and found to be equal." This comparison is technical/physical, not clinical.

    8. The sample size for the training set

    Not applicable, as this is an X-ray system. The "training" for such a device involves engineering, design, and manufacturing processes compliant with quality systems, not machine learning training on a dataset.

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

    Not applicable, as there is no "training set" in the context of machine learning for this device.

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