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510(k) Data Aggregation
(125 days)
The PENTAX Medical Video Processor EPK-i8020c is intended to be used with the PENTAX Medical camera heads, endoscopes, light sources, monitors ancillary equipment for gastrontestinal and pulmonary endoscopic diagnosis, treatment and video observation.
The PENTAX Medical EPK-i8020c includes a digital post-processing imaging enhancement technology (PENTAX i-ScanTM), and optical imaging enhancement technology (OE). These imaging enhancement technologies are intended to be used as an optional adjunct following traditional white light endoscopy and is not intended to replace histopathological sampling. i-Scan and OE are compatible with PENTAX Medical video gastrointestinal endoscopes and bronchoscopes.
The PENTAX Medical Video Processor EPK-i8020c is intended to be used with PENTAX Medical endoscopes, monitors and other peripheral devices for endoscopic diagnosis, treatment, and video observation. The video processor consists of a video system, integrated light source, monitor, and ancillary equipment.
The EPK-i8020c includes a digital post-processing imaging enhancement technology (PENTAX Medical i-scan™) and an optical imaging enhancement technology (OE). These post-imaging functions are not intended to replace histopathological sampling.
The brand name "INSPIRA™" is provided for the EPK-i8020c video processor and the name is found in the instructions for use (IFU) and/or in the commercial materials such as brochures.
The provided text describes the 510(k) submission for the PENTAX Medical Video Processor EPK-i8020c. This submission focuses on demonstrating substantial equivalence to a predicate device, rather than proving the device meets specific acceptance criteria through a clinical study with a defined ground truth.
Therefore, many of the requested details about acceptance criteria, specific performance metrics, sample sizes for test and training sets, expert qualifications, and ground truth establishment are not explicitly provided in the document, as the submission relies on non-clinical performance data and a comparison to an already cleared predicate device.
However, I can extract information related to the device's performance testing and the nature of the study conducted:
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Functional and Safety Standards Compliance | The PENTAX Medical EPK-i8020c Video Imaging System has been successfully tested for its functions, performance, and safety as per FDA recognized consensus standards. This includes: |
- Reprocessing Validation (for non-reprocessed devices) | Not required, as the subject device is not reprocessed and provided non-sterile. Reprocessing procedures for reference devices (video bronchoscopes) remain unchanged. |
- Sterilization and Shelf Life (for non-sterile devices) | Not required, as the subject device is not reprocessed and is not provided sterile. |
- Biocompatibility (for devices without direct/indirect patient contact) | Not required, as the subject device does not contain any direct or indirect patient contact components. Materials of reference devices (video bronchoscopes) remain unchanged. |
- Software and Cybersecurity Compliance | Software verification and validation, including cybersecurity assessments, were conducted according to IEC 62304: 2006 + A1: 2015 and FDA Guidance for Industry and Staff documents on software and cybersecurity in medical devices. |
- Electrical Safety (ES) and Electromagnetic Compatibility (EMC) | Confirmed by IEC 60601-1-2:2014; IEC 60601-1:2005+CORR 1:2006+CORR 2:2007+A1:2012; and IEC 60601-2-18:2009. |
- System Performance Equivalence to Predicate | The system performance of the subject device demonstrated equivalence to the predicate device. |
- Optical Performance Equivalence to Predicate and Reference | Optical properties of imaging and illumination performances were measured. All results show that the optical characteristics of the subject device are equivalent to those of the predicate device and the reference device. |
- Ability to visualize vascularity and mucosal surface | An animal image capture study indicated that the subject device is able to visualize vascularity and mucosal surface for targeted anatomical areas as well as the predicate device and the reference device. This was performed as part of optical and color performance testing. "This study raised no issues of safety and effectiveness of the device as these differences have no effect on the performance, function or general intended use of the device." (From section 7) |
- Substantial Equivalence to Predicate | The subject device is deemed "as safe and effective as the predicate device" with "no differences in indications for use and intended use" and "technological differences... are not substantive." |
2. Sample size used for the test set and the data provenance:
- Test set sample size: Not specified. The document refers to "performance testing" and an "animal image capture study" but does not quantify the number of cases or animals involved.
- Data provenance: For the "animal image capture study," the data provenance is from an animal study. The country of origin is not specified but implicitly assumed to be from within PENTAX Medical's research and development. This was a non-clinical study.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Not specified. The animal study evaluated the device's ability to "visualize vascularity and mucosal surface," implying an objective assessment rather than a diagnostic interpretation requiring expert ground truth establishment for a specific medical condition. The study aimed to assess optical and color performance.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable/Not specified. Given the nature of the "animal image capture study" for optical and color performance, an adjudication method for diagnostic agreement with a ground truth is not described as the primary objective was visualization capability comparison.
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 done. The device (PENTAX Medical Video Processor EPK-i8020c) includes "digital post-processing imaging enhancement technology (PENTAX i-Scan™)" and "optical imaging enhancement technology (OE)." However, the submission does not describe a human-in-the-loop study to evaluate the effectiveness of these enhancements or how human readers' performance improves with or without these features. The statement is that these technologies are "intended to be used as an optional adjunct following traditional white light endoscopy and is not intended to replace histopathological sampling."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- A standalone performance assessment was done for various system components, including software and optical performance. The "animal image capture study" can be considered a standalone assessment of the device's imaging capabilities (optical and color performance) in a biological setting, comparing it to predicate/reference devices. This was an evaluation of device capability itself, not an algorithm's diagnostic output.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For the "animal image capture study," the "ground truth" was the objective presence of vascularity and mucosal surface in the animal model. The assessment was likely based on the visual quality and clarity of these features as captured by the device, compared to the predicate and reference devices. It was not a ground truth for a diagnostic condition established by pathology or expert consensus.
8. The sample size for the training set:
- Not applicable/Not specified. This submission does not describe a machine learning algorithm that would require a distinct training set. The device contains "digital post-processing imaging enhancement technology (PENTAX i-Scan™)," which might involve algorithms, but the development and training of these are not detailed as part of this 510(k) submission.
9. How the ground truth for the training set was established:
- Not applicable/Not specified, as no training set is discussed in this context.
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(447 days)
PENTAX Medical Single Use Video Bronchoscope EB-S01 is sterile single use flexible endoscopes intended for use with PENTAX Medical mobile processor, therapeutic accessories, and other ancillary equipment for endoscopy and endo-therapeutic procedures within the airways and tracheobronchial tree.
PENTAX Medical Mobile Processor ONE-M is intended to be used with PENTAX Medical endoscopes and other peripheral devices for endoscopic diagnosis, treatment and video observation.
PENTAX Medical Mobile Processor Plug-in ONE-Dock is intended to be attached to the PENTAX Medical Mobile Processor to provide additional ports for hardware interface.
PENTAX Medical ONE Pulmo Single Use Video Bronchoscope System is intended to provide the optical visualization of the airways and tracheobronchial tree for diagnostics and therapeutic applications. The PENTAX Medical ONE Pulmo Single Use Video Bronchoscope System consist of the following three component devices:
- . PENTAX Medical Single Use Video Bronchoscope EB11-S01 / EB15-S01
- . PENTAX Medical Mobile Processor ONE-M
- . PENTAX Medical Mobile Processor Plug-in ONE-Dock
The EB11-S01 / EB15-S01 endoscopes are connected to the ONE-M and video images captured with the bronchoscope are displayed on the touch screen of the ONE-M. The ONE-M is also connected to the Plug-in ONE-Dock, which has several interfaces, such as an external monitor to display captured images by the bronchoscope and a connection with an external network.
Based on the provided text, the document is a 510(k) Premarket Notification for the PENTAX Medical ONE Pulmo Single Use Video Bronchoscope System. This type of submission aims to demonstrate that a new device is "substantially equivalent" to a legally marketed predicate device, rather than proving clinical effectiveness through extensive clinical trials for new indications or technologies. Therefore, the information provided focuses on demonstrating equivalence through non-clinical performance data and technological comparisons, rather than a clinical study with detailed acceptance criteria and a human-in-the-loop performance study as might typically be found for AI/ML device submissions.
The document does not describe a study that proves the device meets specific acceptance criteria related to an AI/ML algorithm's diagnostic performance, as it is a bronchoscope system, not an AI/ML diagnostic aid. It lists various non-clinical performance tests to demonstrate substantial equivalence to a predicate device.
Therefore, many of the requested fields regarding acceptance criteria, study design for AI/ML, human expert involvement, and ground truth establishment are not applicable or not detailed in this submission because it is not an AI/ML device submission for diagnostic accuracy.
However, I can extract the relevant information that is present and explain why other requested information is not available:
1. A table of acceptance criteria and the reported device performance:
The document describes general performance equivalency rather than specific quantitative acceptance criteria for image analysis or diagnostic performance of an AI system. The key "acceptance criteria" here relate to demonstrating equivalence to a predicate device and meeting recognized standards for safety and performance (e.g., electrical safety, biocompatibility).
Category | Acceptance Statement (Implied Criteria) | Reported Device Performance |
---|---|---|
Intended Use/Indications | Must have the same or similar intended use and indications for use as the predicate device. | "The predicate and subject device have the same Intended use and Indications for Use..." (Page 4). "There are no differences in indications for use and intended use between the subject and predicate device and are therefore, substantially equivalent." (Page 9) |
Technological Characteristics | Must have similar fundamental technology, operating principles, design features, and constituent materials. | "The components of the subject device have the same fundamental technology and operating principles as the predicate device, as well as the same intended use." (Page 7). Minor differences (i-Scan™ technology) evaluated. |
Reprocessing Validation | Not required if device is single-use and sterile. | "EB-S01 scopes are provided sterile for single use and are discarded after use. Therefore, reprocessing validation is not required." (Page 8) |
Sterilization & Shelf Life | Validation of EO sterilization in accordance with specified ISO standards; stated shelf life. | Validated per ISO 11135:2014, AAMI/ANSI/ISO 10993-7:2008, ISO 11737-1:2018, and ISO 11737-2:2019. Shelf-life is 1 year. (Page 8) |
Biocompatibility | Confirmation of biocompatibility (cytotoxicity, sensitization, intracutaneous reactivity) per ISO 10993 standards; risk level "Acceptable." | Confirmed per ISO 10993-1, 5, and 10. Risk levels of local toxicity determined as "Acceptable." (Page 8) |
Software & Cybersecurity | Verification and validation per IEC 62304 and FDA guidance documents. | Conducted according to IEC 62304:2006 + A1:2015 and relevant FDA guidance documents ("Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices," "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices," and "Post-market Management of Cybersecurity in Medical Devices"). (Page 8) |
Electrical Safety & EMC | Confirmation of acceptable levels per specified IEC standards. | Confirmed per IEC 60601-1-2:2014; IEC 60601-1:2005+CORR 1:2006+CORR 2:2007+A1:2012; and IEC 60601-2-18:2009. (Page 9) |
System Performance | Demonstrated equivalence to the predicate device. | "The system performance of the subject device demonstrated the equivalence to the predicate device." (Page 9) |
Optical Performance | Measured and shown to be equivalent to the predicate device. | "All results show that the optical characteristics of the subject device is equivalent to those of the predicate device." (Page 9) |
Animal Image Capture | Must be able to visualize vascularity and mucosal surface as well or better than the predicate device. | "The results indicate that the subject device is able to visualize vascularity and mucosal surface for each anatomical area as well or better than the predicate device." (Page 9) |
2. Sample size used for the test set and the data provenance:
- Test Set: Not applicable in the context of an AI/ML "test set" for diagnostic performance. Performance testing involved various engineering and animal studies. For the "Animal Image Capture Study," an animal model was used, but the specific number of animals is not provided. The data provenance is implied to be from internal testing by PENTAX Medical.
- Data Provenance: Implied to be from internal testing and validation studies conducted by PENTAX Medical (e.g., "PENTAX Medical coordinated with HA2 Medizintechnik GmbH (German company) to validate the use of EO sterilization"). The animal study location and specifics are not provided.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not applicable and not provided. The ground truth for this device's performance does not involve human expert adjudication of images for diagnostic purposes in the way it would for an AI/ML algorithm. The performance evaluation focused on physical, electrical, and optical properties as well as safety and biocompatibility.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable, as this is not an AI/ML diagnostic device requiring expert adjudication of results.
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 device is a bronchoscope system, not an AI-assisted diagnostic tool for image interpretation. No MRMC study was conducted or required for this type of submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable, as this is a medical device for direct visualization and not an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
Not applicable in the AI/ML sense. The "ground truth" for this submission are the established performance specifications for medical devices, relevant ISO standards, and the performance of the predicate device, against which the subject device's non-clinical performance was compared (e.g., electrical safety standards, biocompatibility testing results, optical measurements, and visualization capabilities in an animal model).
8. The sample size for the training set:
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established:
Not applicable.
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