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510(k) Data Aggregation

    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PRORAD ATLAS ULTRAPORTABLE Digital X-ray system is intended to deliver high-quality, diagnostic radiographic images of the body extremities. It utilizes a portable X-ray unit, flat-panel detector and image acquisition software to produce clear digital images, enabling fast and accurate diagnosis. The portable X-ray unit is intended to be used only when stand/tripod mounted.

    The PRORAD ATLAS ULTRAPORTABLE X-ray digital system is predominantly employed in various settings, including health-care centres, temporary and emergency health centres (established, especially in pandemic circumstances), outreach and field interventions (such as mobile clinics/vans, screening campaigns, and home care), and tele-radiology solutions in remote areas.

    The primary users anticipated for the system include radiographers, radiological technologists, and medical professionals who are trained in safety, radiation protection, and image management.

    The PRORAD ATLAS ULTRAPORTABLE PLUS Digital X-ray system is intended to deliver high-quality, diagnostic radiographic images of the body extremities. It utilizes a portable X-ray Unit, flat-panel detector and real-time image processing using software to produce clear digital images, enabling fast and accurate diagnosis. The portable X-ray unit is intended to be used only when stand/tripod mounted.

    The PRORAD ATLAS ULTRAPORTABLE PLUS X-ray digital system is predominantly employed in various settings, including health-care centres, temporary and emergency health centres (established, especially in pandemic circumstances), outreach and field interventions (such as mobile clinics/vans, screening campaigns, and home care), and tele-radiology solutions in remote areas.

    The primary users anticipated for the system include radiographers, radiological technologists, and medical professionals who are trained in safety, radiation protection, and image management.

    Device Description

    The PRORAD ATLAS X-Ray system includes the ULTRAPORTABLE and ULTRAPORTABLE PLUS, which are portable diagnostic X-ray systems with fixed 70kV and 2mA tube current. These systems are intended to produce anatomical X-rays of the body extremities in both pediatric and adult patients. The PRORAD ATLAS X-Ray system was designed, developed, and manufactured by Prognosys Medical Systems Private Limited. The model numbers are listed below.

    Model NumberModel NameModel Description
    A86-ATL-0001PRORAD ATLAS ULTRAPORTABLEThese are ultraportable X-ray systems designed to generate diagnostic, high-quality X-ray images
    A87-ATL-0001The PRORAD ATLAS ULTRAPORTABLE PLUS

    The PRORAD ATLAS X-ray system is a sophisticated, battery-powered X-ray generator offered in two versions: PRORAD ATLAS ULTRAPORTABLE and ULTRAPORTABLE PLUS. The main distinction between these models lies in their exposure time ranges and target anatomical areas. The ULTRAPORTABLE model provides exposure times ranging from 0.01 to 1.30 seconds, while the ULTRAPORTABLE PLUS model offers an extended exposure range of 0.01 to 2.5 seconds. Both models share identical internal components, software, algorithms, and operational features and are intended for imaging body extremities. The system includes a high-voltage tank with an X-ray tube mounted on an adjustable tripod stand, allowing users to adjust the height to the specific imaging area. Exposure parameters are configured through the X-ray generator's graphical user interface (GUI). After setting the parameters and positioning the patient on the detector, the X-ray is activated via an exposure switch. The detector captures the radiation, converts it into a digital signal, and transmits the data wirelessly to a computer equipped with compatible software. The images are processed and displayed on the computer for diagnostic review. The PRORAD ATLAS system is compatible with several 510(k)-cleared detectors and their associated software, listed below in Table 1. Prognosys includes one detector and its pre-configured software in the package, depending on availability. Fully battery-operated, the system does not support direct power connection but can seamlessly integrate with multiple detectors and compatible software as part of the package.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and supporting documentation for the PRORAD ATLAS ULTRAPORTABLE X-Ray Systems do not include acceptance criteria or a detailed study that proves the device meets specific performance criteria beyond general safety and effectiveness.

    The document primarily focuses on demonstrating substantial equivalence to a predicate device (Remex KA6, K212144) rather than presenting a performance study with defined acceptance criteria. The "Summary of non-clinical testing" lists a series of international standards (IEC, ISO) and FDA guidance documents that were followed for design control, risk management, verification, and validation. The "Summary of clinical testing" mentions that clinical images were collected and reviewed by a qualified radiologist, confirming they are "clinically acceptable." However, specific quantitative acceptance criteria for image quality, diagnostic accuracy, or other performance metrics, along with the study design and results against those criteria, are not detailed in this document.

    Therefore, I cannot provide a table of acceptance criteria and reported device performance, nor can I provide information about sample size, expert details, adjudication methods, MRMC studies, standalone performance, or training set specifics, as this information is not present in the provided text.

    Based on the available text, here's what can be extracted:

    • Overall Conclusion: The device is deemed "safe and effective when the device is used as labelled and is substantially equivalent to the predicate device."

    Here's a breakdown of why the requested information cannot be fully provided based on the input:

    1. A table of acceptance criteria and the reported device performance: This information is not explicitly stated in the document. The document confirms that "Validation of PRORAD ATLAS X-Ray System has demonstrated that the system enables optimal and quality imaging of anatomical structures" and that clinical images are "clinically acceptable," but no specific quantitative criteria or performance metrics are given.

    2. Sample size used for the test set and the data provenance: The document states that "Clinical images of body extremities were collected from patients of varying ages, weights, and BMIs." However, the exact sample size and the provenance (e.g., country of origin, retrospective/prospective nature) of this clinical image test set are not specified.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: The document mentions that images were "reviewed by a qualified radiologist." It does not specify the number of radiologists or their specific qualifications (e.g., years of experience, board certification).

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: No adjudication method for the clinical image review is described.

    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: An MRMC study is not mentioned. The device described is an X-ray system, not an AI software to assist human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: This is not applicable as the device is an X-ray system, not an algorithm, and it's intended to be used by trained medical professionals.

    7. The type of ground truth used: The ground truth for the clinical images appears to be "clinical acceptability" as determined by a "qualified radiologist." This aligns with "expert consensus" in a general sense, but no more objective ground truth (e.g., pathology, outcomes data) is mentioned for the image quality assessment.

    8. The sample size for the training set: The document does not mention a training set, as it describes an X-ray hardware system, not an AI-driven software that requires a training set.

    9. How the ground truth for the training set was established: Not applicable, as no training set is mentioned.

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    K Number
    K221876
    Manufacturer
    Date Cleared
    2022-07-15

    (17 days)

    Product Code
    Regulation Number
    892.1680
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K213780

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

    The DIGITAL RADIOGRAPHY CXDI-Pro / D1 provides digital image capture for conventional film/screen radiographic examinations. This device is intended to capture, for display, radiographic images of human anatomy, and to replace radiographic film/screen systems in all general purpose diagnostic procedures. This device is not intended for mammography applications.

    Device Description

    The DIGITAL RADIOGRAPHY CXDI-Pro, also called the DIGITAL RADIOGRAPHY D1, (hereinafter referred to as CXDI-Pro) is a solid-state x-ray imager. The CXDI-Pro is a series of detectors, and in the predicate device (K220098) consists of the CXDI-703C Wireless and CXDI-403C Wireless detectors, also called the AR-D3543W and AR-D4343W detectors respectively. The detectors intercept x-ray photons, and the scintillator emits visible spectrum photons that illuminate an array of photodetectors that create electrical signals. After the electrical signals are generated, the signals are converted to digital values The digital values are sent to the PC via a wired or wireless connection, converted to images with the CXDI Control Software, and then displayed on the PC/monitors The PC/monitors used with the CXDI-Pro are not a part of this submission.

    The subject of this Special 510(k) submission is a change to the predicate device, including compatibility with the Multi Box and Status Indicator, DIGITAL RADIOGRAPHY CXDI-Elite components that were cleared under K213780. The Status Indicator can be used when the proposed device is used in combination with the Multi Box. In addition, the CXDI Control Software has been updated from V3.10.0.8 to V3.10.2.2 to fix some bugs. Together, these changes make up the CXDI-Pro.

    AI/ML Overview

    Based on the provided text, the device in question, DIGITAL RADIOGRAPHY CXDI-Pro / D1, is a digital radiography system, and the submission (K221876) is a Special 510(k). This means the submission focuses on modifications to an already cleared predicate device (K220098) rather than a completely new device. Therefore, the clinical testing section is deemed "not necessary" due to "minor differences from the predicate device."

    This significantly limits the type of performance study and acceptance criteria information available. Special 510(k) submissions typically rely heavily on non-clinical bench testing and verification/validation activities to demonstrate that changes do not adversely affect safety or effectiveness, rather than large-scale clinical trials measuring diagnostic accuracy.

    Here's an analysis based on the constraint that "clinical testing is not necessary" for this specific submission:

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

    Since clinical testing was not performed for this submission, there are no acceptance criteria related to diagnostic accuracy or human-in-the-loop performance. The acceptance criteria and performance reported are focused on demonstrating that the modifications (addition of Multi Box and Status Indicator, software update, and firmware update) do not negatively impact the fundamental scientific technology and existing safety/performance standards of the predicate device.

    Acceptance Criteria CategorySpecific Acceptance Criteria (from text)Reported Device Performance / Evaluation (from text)
    Safety & Electrical PerformanceConformance with U.S. Performance Standard for radiographic equipment.Evaluation confirmed changes did not impact conformance.
    Conformance with relevant voluntary safety standards for Electrical safety (IEC 60601-1).Evaluation confirmed changes did not impact conformance.
    Electromagnetic Compatibility (EMC)Conformance with relevant voluntary safety standards for Electromagnetic Compatibility (IEC 60601-1-2).Evaluation confirmed changes did not impact conformance.
    Usability / Software LifecycleConformance with IEC 60601-1-6 (Usability). (Implied by software update context)Verification/validation activities demonstrated the device continues to meet standards.
    X-ray Imaging EquipmentConformance with IEC 60601-2-54 (X-ray equipment for radiography and radioscopy).Evaluation confirmed changes did not impact conformance.
    Software FunctionalityCXDI Control Software V3.10.2.2 fixes previous bugs (from V3.10.0.8).Verification/validation activities demonstrated the CXDI-Pro works as intended with the updated software.
    Bio-compatibilityConformance with ISO 10993-1 for biological evaluation.Follows applicable elements of ISO 10993-1.
    Overall EquivalenceNo new questions regarding safety or effectiveness compared to the predicate device.Verification/validation activities support a determination of substantial equivalence.

    2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    The document explicitly states: "Clinical testing is not necessary for the current submission, based on the minor differences from the predicate device. Adequate verification and validation activities should be sufficient to demonstrate that the CXDI-Pro works as intended."

    Therefore, there is no human patient "test set" or related sample size or data provenance information. The "test set" here refers to the bench tests and engineering validations performed on the device and its components to ensure compliance with the mentioned technical standards and functionality.

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

    Not applicable, as human clinical evaluation or ground truth adjudication by experts (e.g., radiologists) for diagnostic performance was not part of this "Special 510(k)" submission. The "ground truth" for the non-clinical tests would be established through engineering specifications, calibration standards, and regulatory requirements.

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

    Not applicable, as there was no test set requiring human expert adjudication for diagnostic performance.

    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. This device is a digital radiography system; the submission focuses on hardware and software updates to the imaging system itself, not an AI feature that assists human readers.

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

    No standalone performance evaluation of a diagnostic algorithm was done. This is a review of a general-purpose digital X-ray system, not an AI diagnostic algorithm. The software update mentioned is for the CXDI Control Software, which governs the imaging process and display, not for an AI interpretation algorithm.

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

    The "ground truth" for this submission's evaluation is based on engineering specifications, regulatory standards (e.g., IEC 60601 series, U.S. Performance Standard for radiographic equipment), and the performance characteristics of the predicate device. It's not clinical ground truth (like pathology or patient outcomes) because clinical testing was not required.

    8. The sample size for the training set:

    Not applicable. This submission is for modifications to a general radiography system, not for an AI algorithm. There is no "training set" in the context of machine learning.

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

    Not applicable, as there is no training set for an AI algorithm.

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