TRILOGY RADIOTHERAPY DELIVERY SYSTEM AND TRILOGY TX DELIVERY SYSTEM

K070094 · Varian Medical Systems, Inc. · IYE · Feb 9, 2007 · Radiology

Device Facts

• Record ID: K070094
• Device Name: TRILOGY RADIOTHERAPY DELIVERY SYSTEM AND TRILOGY TX DELIVERY SYSTEM
• Applicant: Varian Medical Systems, Inc.
• Product Code: IYE · Radiology
• Decision Date: Feb 9, 2007
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 892.5050
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Trilogy ™ Delivery System and Trilogy Tx Delivery System are intended to provide stereotactic radiosurgery and precision radiotherapy for lesions, turnors and conditions anywhere in the body when radiation treatment is indicated.

Device Story

Trilogy and Trilogy Tx Delivery Systems are medical charged-particle radiation therapy systems. Modification introduces software algorithm for gradual acceleration and deceleration of gantry rotation with direct drive. System delivers stereotactic radiosurgery and precision radiotherapy for lesions, tumors, and conditions throughout the body. Operated by clinical staff in a radiation therapy environment. Output consists of controlled radiation delivery; modification optimizes mechanical motion of gantry to improve precision or operational efficiency. Clinical benefit derived from accurate, controlled radiation treatment of target tissues.

Clinical Evidence

No clinical data provided; bench testing only.

Technological Characteristics

Medical charged-particle radiation therapy system. Features direct drive gantry rotation. Modification involves software algorithm for motion control (gradual acceleration/deceleration).

Indications for Use

Indicated for stereotactic radiosurgery and precision radiotherapy for lesions, tumors, and conditions anywhere in the body requiring radiation treatment.

Regulatory Classification

Identification

A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.

Predicate Devices

• Varian Medical Systems Trilogy Tx Radiotherapy Delivery System (K061140)
• Varian Medical Systems Trilogy Radiotherapy Delivery System (K033343)

Submission Summary (Full Text)

{0}------------------------------------------------

K070094

## 510(k) Summary

The information below is provided for the Modifications to the Trilogy ™ Delivery System and Trilogy Tx Delivery System, following the format of 21 CFR 807.92.

FEB 9 2007

- Varian Medical Systems 1. Submitter: 3100 Hansen Way, M/S e110 Palo Alto, CA 94304 Contact Name: Vy Tran Phone: [phone] Fax: [phone] E-mail: [e-mail]
2. Name of the Device: Trilogy TM Delivery System and Trilogy Tx Delivery System Trade / Proprietary Name: Trilogy TM Delivery System and Trilogy Tx Delivery System Common or Usual Name: Trilogy ™ Delivery System and Trilogy Tx Delivery System Classification Name: Medical Charged Particle Radiation Therapy System 21 CFR §892.5050 Class II Product Code: 90 ГУЕ

- 3. Predicate Devices to claim substantial equivalence: Varian Medical Systems Trilogy Tx Radiotherapy Delivery System - K061140 and Varian Medical Systems Trilogy Radiotherapy Delivery System - K033343
- 4. Description of the Device:

The changes to the Trilogy Radiotherapy Delivery System and Trilogy Tx Delivery System provide a modified software algorithm that implements gradual acceleration and deceleration of gantry rotation with direct drive.

All other features of the Trilogy Radiotherapy Delivery System and Trilogy Tx Delivery System remain as cleared by K061140 and K033343, respectively.

- 5. Intended Use Statement
The Trilogy ™ Delivery System and Trilogy Tx Delivery System are intended to provide stereotactic radiosurgery and precision radiotherapy for lesions, turnors and conditions anywhere in the body when radiation treatment is indicated.

- 6. Indications for Use Statement
The Trilogy ™ Delivery System and Trilogy Tx Delivery System are indicated for stereotactic radiosurgery and precision radiotherapy for lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.

- Substantial Equivalence 7.
The Modifications to the Trilogy ™ Delivery System and Trilogy Tx Delivery System submission illustrates substantial equivalence to the predicate devices.

{1}------------------------------------------------

Image /page/1/Picture/0 description: The image shows a circular logo with text around the perimeter and a stylized graphic in the center. The text reads "DEPARTMENT OF HEALTH & HUMAN SERVICES" and is arranged around the top and left side of the circle. The graphic in the center consists of three curved lines that appear to be stylized representations of human figures or abstract shapes.

## DEPARTMENT OF HEALTH & HUMAN SERVICES

Food and Drug Administration 9200 Corporate Blvd. Rockville MD 20850

Ms. Vy Tran Corporate Director Regulatory Affairs Varian Medical Systems, Inc. 3100 Hansen Way, MS E-110 PALTO CA 94304-1038

9 2007

Re: K070094

Trade/Device Name: Trilogy™ Delivery System and Trilogy Tx Delivery System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: IYE Dated: January 8, 2007 Received: January 10, 2007

Dear Ms. Tran:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmelic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Image /page/1/Picture/10 description: The image shows a circular logo with the text "1906-2006" at the top. The letters "FDA" are prominently displayed in the center of the logo. Below the letters, the word "Centennial" is written in a stylized font. Three stars are arranged in a row at the bottom of the logo.

*Protecting and Promoting Public Health*

{2}------------------------------------------------

Page 2 -

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter:

| 21 CFR 876.xxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|----------------|----------------------------------|--------------|
| 21 CFR 884.xxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 894.xxx | (Radiology) | 240-276-0120 |
| Other | | 240-276-0100 |

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number [phone] or [phone]

or at its Internet address http://www.fda.gov/cdrl/industry/support/index.html.

Sincerely yours,

Nancy Cbrogdon

Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{3}------------------------------------------------

Image /page/3/Picture/0 description: The image shows the logo for Varian Medical Systems. The logo consists of the word "VARIAN" in a sans-serif font, with a stylized "I" that resembles a beam of light. Below the word "VARIAN" are the words "medical systems" in a smaller, sans-serif font. The logo is simple and modern, and it conveys a sense of innovation and technology.

Varian Medical Systems, Inc. 3100 Hansen Way Palo Alto, CA 94304-1038 USA Tel [phone] www.varian.com

## Indications for Use Statement

K070094

510(k) Number (if known):

Device Name:

Trilogy ™ Delivery System and Trilogy Tx Delivery System

Indications for Use: -

The Trilogy ™ Delivery System and Trilogy Tx Delivery System are indicated for stereotactic radiosurgery and precision radiotherapy for lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.

## (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

OR

Prescription Use (Per 21 CFR § 801.109)

Over-the-counter

Daniel Ch. Levinson

(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Devices 510(k) Number _