PCH-2500 is digital extra oral source x-ray system intended to take panoramic and cephalometric images of the oral and maxillofacial anatomy to provide diagnostic information for adult and pediatric patients. The device should be operated and used by dentists, and x-ray technicians and other professionals licensed by the law of the state in which the device is used.
Device Story
PCH-2500 is a digital extraoral X-ray imaging system for dental applications. It captures panoramic and cephalometric images of oral and maxillofacial anatomy. The system utilizes dedicated sensors: Xmaru1501CF (panoramic), Xmaru2301CF (cephalometric scan type), and 1210SGA (cephalometric one-shot type). Operated by dentists or X-ray technicians in clinical settings, the device transforms X-ray exposure into digital diagnostic images. These images assist clinicians in treatment planning and diagnostic assessment. The system supports DICOM standards for image communication. It provides a non-invasive method for visualizing dental structures, benefiting patients through improved diagnostic accuracy.
Clinical Evidence
No clinical trials were conducted. Substantial equivalence was supported by non-clinical performance testing, including electrical, mechanical, and environmental safety (IEC 60601 series), EMC testing (IEC 60601-1-2), and image quality performance testing (IEC 61223-3-4 and 61223-3-5). Expert review of image comparisons between the subject and predicate devices was performed.
Indicated for adult and pediatric patients requiring panoramic and cephalometric radiographic imaging of oral and maxillofacial anatomy for diagnostic purposes.
Regulatory Classification
Identification
An extraoral source x-ray system is an AC-powered device that produces x-rays and is intended for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures. The x-ray source (a tube) is located outside the mouth. This generic type of device may include patient and equipment supports and component parts.
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K113672
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# MAR 2 7 2012
510(k) Submission - PCH-2500
# 510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 872.1800.
#### Date
レ 12/8/2011
## Manufacturer
Vatech Co., Ltd.
23-4, Seogu-Dong, Hwaseong-Si, Gyeonggi-Do, 445-170, Korea Republic
Tel: +82-31-379-9585 Fax: +82-31-379-9638 Contact person: Mr. Sonny Park
## Official Correspondent (U.S. Designated agent)
Mtech Group 12946 Kimberley Ln, Houston, TX 77079 Tel: +713-467-2607 Fax: +713-464-8880 Contact person: Mr. Dave Kim (davekim@mtech-inc.net)
## Trade/Proprietary Name:
PCH-2500
## Common Name:
. Digital X-ray Imaging System
## Classification Name:
System, X-Ray, Extra oral Source, Digital (21CFR 872.1800, Product code MUH, class2)
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## 510(k) Submission - PCH-2500
### Description:
PCH-2500 is a dental digital radiographic imaging system which is available in two different image acquisition modes. Specifically designed for dental radiography of the teeth or jaws, PCH-2500 can be equipped with three dedicated sensors, each for two X-ray modalities : panoramic (Xmarul 501CF), cephalometric scan type (Xmaru2301CF) and oneshot ceph sensor type (1210SGA).
PCH-2500 offers the digital panoramic and cephalometric X-ray modality for dental radiographs. The multi platforms of PCH-2500 imaging mode provides a wide range of imaging option based on the customer's diagnostic needs.
#### Indication for use:
PCH-2500 is digital extra oral source x-ray system intended to take panoramic and cephalometric images of the oral and maxillofacial anatomy to provide diagnostic information for adult and pediatric patients. The device should be operated and used by dentists, x-ray technicians and other professionals licensed by the law of the state in which the device is used.
## · Predicate Device:
| Manufacturer | : Vatech Co., Ltd |
|---------------|----------------------------------------|
| Device | : PaX-Flex3D |
| 510(k) Number | : K 102259 (Decision Date - 2/18/2011) |
#### Substantial Equivalence:
PCH-2500 described in this 510(k) has the similar intended use and technical characteristics as PaX-Flex3D of Vatech Co., Ltd.
| Characteristic | Proposed<br>Vatech Co., Ltd.<br>PCH-2500 | Predicate<br>Vatech Co., Ltd.<br>PaX-Flex3D |
|-------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) number | - | K102259 |
| Indications<br>for use | PCH-2500 is digital extra oral<br>source x-ray system intended | PaX-Flex3D is a computed<br>tomography x-ray system intended to |
| | to take panoramic and<br>cephalometric images of the<br>oral and maxillofacial anatomy<br>to provide diagnostic<br>information for adult and<br>pediatric patients. The device<br>should be operated and used<br>by dentists, x-ray technicians<br>and other professionals<br>licensed by the law of the state<br>in which the device is used. | produce panoramic, cephalometric or<br>cross-sectional images of the oral<br>anatomy on a real time basis by<br>computer reconstruction of X-ray<br>image data from the same axial plane<br>taken at different angles. It<br>provides diagnostic details of the<br>anatomic structures by acquiring 360<br>rotational image sequences of oral<br>and maxillofacial area for a precise<br>treatment planning in adult and<br>pediatric dentistry. The device is<br>operated and used by physicians,<br>dentists, and X-ray technicians. |
| Performance<br>Specification | Panoramic and cephalometric | Panoramic and cephalometric<br>and compute tomography |
| Input Voltage | AC 100-120 / 200-240 V | AC 110 / 230 V |
| Tube Voltage | 50-90 kV | 50-90 kV |
| Tube Current | 4-10 mA | 4-10 mA |
| Focal Spot Size | 0.5 mm | 0.5 mm |
| Exposure Time | Max 20.2 s | 9-24 s |
| Total Filtration | 2.8 mmAl | 2.8 mmAl |
| Pixel Resolution | Panoramic : 5 lp/mm | Panoramic : 5 lp/mm |
| | Cephalometric (scan type)<br>5 lp/mm : | Cephalometric (scan type)<br>5 lp/mm : |
| | Cephalometric (one shot type)<br>3.9 lp/mm : | |
| | CT – N/A | CT - 3.3 lp/mm |
| Pixel Size | Panoramic : 100 x 100 µm | Panoramic - 100 x 100 µm |
| | Cephalometric (scan type):<br>100 x 100 µm : | Cephalometric (scan type):<br>100 x 100 µm : |
| Cephalometric (one shot type) | | |
| 127 x 127 µm : | | |
| | CT - N/A | CT : 150 x 150 µm/200 x 200 µm |
| Image Receptor | CMOS photodiode array –<br>panoramic (Xmaru1501CF) &<br>cephalometric<br>(Xmaru2301CF)<br>Amorphous silicon TFT with<br>scintillator – Cephalometric<br>(1210SGA) | CMOS photodiode array –<br>panoramic (Xmaru1501CF) &<br>cephalometric (Xmaru2301CF) |
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## 510(k) Submission – PCH-2500
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K 1111672
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#### 510(k) Submission - PCH-2500
Indications for use, safety characteristics, and non-clinical performance for panoramic and cephalometric sensors (scan type) of PCH-2500 and PaX-Flex3D are similar. The primary differences are as follows: PCH-2500 lacks the cone beam CT mode. PCH-2500 offers optional solid state X-ray sensor for cephalometric mode. (The non-clinical performance and clinical consideration report for the SSXI detector, 1210SGA, are provided separately in this submission). Based on the non-clinical and clinical consideration and the outcome of an expert review of image comparisons for both devices, we can claim the substantial equivalence of PCH-2500 in comparison with PaX-Flex3D, the predicate device, in terms of safety and effectiveness.
#### Safety, EMC and Performance Data:
Electrical, mechanical, environmental safety and performance testing according to standard IEC 60601-1(A1+A2, 1995), IEC 60601-1-1 (2001), IEC 60601-1-3 (Ed. 1, 1994), IEC 60601-2-7 (1998), IEC 60601-2-28 (Ed. 1, 1993) and IEC 60601-2-32 (Ed. 1, 1994) were performed, and EMC testing were conducted in accordance with standard IEC 60601-1-2.
PCH-2500 also meets the provisions of NEMA PS 3.1-3.18, Digital Imaging and Communications in Medicine (DICOM) Set.
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K1111672
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## 510(k) Submission - PCH-2500
Clinical considerations according to FDA Guidance Non-clinical & & "Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices" were performed.
Acceptance test according to IEC 61223-3-4 and IEC 61223-3-5 was performed.
All test results were satisfactory.
## Conclusion:
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this premarket notification. Vatech Co., Ltd. concludes that PCH-2500 is safe and effective and substantially equivalent to predicate device as described herein.
END
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Image /page/5/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is a stylized image of an eagle with its wings spread, with three lines representing the eagle's feathers. The logo is black and white.
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002
MAR 2 7 2012
Vatech Co., Ltd. Mr. Dave Kim Official Correspondent Mtech Group 12946 Kimberly Lane HOUSTON TX 77079
Re: K113672
Trade/Device Name: PCH-2500 Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral source x-ray system Regulatory Class: II Product Code: MUH and MOB Dated: February 14, 2012 Received: February 16, 2012
## Dear Mr. Kim:
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 Cosmetic 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 class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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 Parts 801 and 809); medical device reporting (reporting of
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### Page 2
medical device-related adverse events) (21 CFR 803); and good manufacturing practice mcuirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). This letter requirences as set form in the quarty, I device as described in your Section 510(k) premarket will anow you to begin marketing your covivalence of your device to a legally marketed nontication. The I Dr I mailing of succion 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 Parts 801 and 11 you decire operitio da research Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Tou may of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely Yours,
Janine M. Morris
Acting Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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## KIN672
# Indications for Use
510(k) Number(if known):
Device Name: PCH-2500
Classification: System, X-Ray, Extraoral Source, Digital (21 CFR 872.1800, Product code MUH, Class2)
Indications for Use:
PCH-2500 is digital extra oral source x-ray system intended to take panoramic and cephalometric images of the oral and maxillofacial anatomy to provide diagnostic information for adult and pediatric patients. The device should be operated and used by dentists, and x-ray technicians and other professionals licensed by the law of the state in which the device is used.
Prescription Use
(Part 21 CFR 801 Subpart D)
Over-The-Counter Use_ AND/OR (Part 21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF
NEEDED)
(Division Sign-Off)
Division of Radiological Devices
Office of in Vitro Diagnostic Device Evaluation and Safety
510K. K113672
Concurrence of CDRH, Office of Device Evaluation(ODE)
Page 1 of 1
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.