The M2 Wrist MRI System is intended for use as a magnetic resonance imaging device for producing transverse, sagittal and coronal images of the internal structure of the wrist (in patients with an arm length > 320mm). When interpreted by a trained physician, the resultant MR images provide information that can be useful in determining a diagnosis.
Device Story
M2 Wrist MRI System is a 1 Tesla magnetic resonance imaging device designed for wrist imaging. System inputs include magnetic resonance signals from the wrist; processed via magnet subsystem, gradient system, and proprietary software to produce transverse, sagittal, and coronal images. Operated by trained clinicians in a clinical setting; no special shielded room required due to negligible external magnetic field. Output images are interpreted by physicians to aid in clinical diagnosis. Benefits include high-resolution (250 micron) imaging of small body parts using a compact, specialized system.
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical performance testing, including electrical/mechanical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), and MRI-specific standards (NEMA MS-1, MS-3, MS-4, MS-5, MS-8, MS-10, MS-11, MS-12, and IEC 60601-2-33).
Technological Characteristics
1 Tesla vertical field magnet (NdFeB material); 76 x 200 mm bore; 190 mT/m gradient strength; 400 T/m/sec slew rate. Includes magnet subsystem, wrist coil, electronics cabinet, computer, and isolation transformer. Software-based image processing. Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-33, and NEMA MS series standards.
Indications for Use
Indicated for patients with an arm length > 320mm requiring magnetic resonance imaging of the internal structure of the wrist to assist in diagnosis.
Regulatory Classification
Identification
A magnetic resonance diagnostic device is intended for general diagnostic use to present images which reflect the spatial distribution and/or magnetic resonance spectra which reflect frequency and distribution of nuclei exhibiting nuclear magnetic resonance. Other physical parameters derived from the images and/or spectra may also be produced. The device includes hydrogen-1 (proton) imaging, sodium-23 imaging, hydrogen-1 spectroscopy, phosphorus-31 spectroscopy, and chemical shift imaging (preserving simultaneous frequency and spatial information).
Special Controls
*Classification.* Class II (special controls). A magnetic resonance imaging disposable kit intended for use with a magnetic resonance diagnostic device only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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K120701
# 510(k) Summary
## 510(k) SUMMARY
FEB 7 2013 -
# ASPECT IMAGING's WRIST MRI SYSTEM
# Applicant's Name:
| Company name: | Aspect Imaging Ltd. |
|---------------|-------------------------------|
| Address: | 27 Shaked St. |
| | Industrial Area Hevel Modi'in |
| | P.O. Box 926 |
| | Shoham, 60850 |
| | ISRAEL |
| Tel: | +972-73-223-9000 |
| Fax: | +972-3-716-5606 |
## Contact Person:
| Official Correspondent: | Ahava Stein · |
|-------------------------|-------------------------------------------------------------------------------------|
| Company name: | A. Stein – Regulatory Affairs Consulting |
| Address: | Beit Hapaamon (Suite 213)<br>20 Hata'as Str. (Box 124)<br>Kfar Saba 44425<br>Israel |
| Tel: | + 972-9-7670002 |
| Fax: | +972-9-7668534 |
| E-mail: | ahava@asteinrac.com |
Date Prepared: September 19, 2012
Name of the device: M2 Wrist MRI System
Trade or proprietary name, if applicable: Magnetic Resonance Imaging System
Common or usual name: MRI System
Establishment Registration No.: TBD
Magnetic Resonance Imaging System Classification Name:
Classification: The subject of this 510(k) is the M2 Wrist MRI System, with the CFR classification sections 892.1000; Magnetic Resonance Imaging System with product code LNH.
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#### Predicate Devices:
ـــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــ
The M2 Wrist MRJ System is substantially equivalent to the Orthone MRI System (manufactured by Oni Inc. and the subject of 510(k) K001773). A comparison table and detailed discussion are presented in Section 12 of this application.
#### Intended Use:
The M2 Wrist MRI System is intended for use as a magnetic resonance imaging device for producing transverse, sagittal and coronal images of the internal structure of the wrist (in patients with an arm length > 320mm). When interpreted by a trained physician, the resultant MR images provide information that can be useful in determining a diagnosis.
## Technological Characteristics:
The Wrist MRI is a 1 Tesla high-performance solution, using NdFeB magnetic material, providing routinely 250 micron or better resolution. The system is Eddy - currents free with gradients which have high strength and a fast slew rate.
The Wrist MRI is designed to ensure maximum safety of operation. Its negligible external magnetic-field eliminates the need for a specially shielded room and other limiting operational procedures.
The Wrist MRI system's main components are:
- Magnet Sub-system ■
- I Wrist Coil
- l Electronics Cabinet
- Aspect Imaging Proprietary Software 에
- Computer
- · Isolation Transformer
Technical Description of magnet subsystem:
- Field strength: 1.05 +/- 2% Tesla vertical Field, horizontal bore 트
- Bore opening size(H x W) 76 x 200 mm ■
- 트 Magnet size: approx. 79 x 79 x 114 cm
- approx. 930 kg 트 Magnet weight:
- Passive B0 shim system ■
- Field of View - 115 x 80 x 50 mm
- Resolution Better than 250um area pixel 트
Technical Description of gradient system:
- Type: Special purpose gradient system
- No Eddy current 트
- Gradient strength: 190 mT/m 트
- 1 Slew rate: 400 T/m/sec
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# Comparison of Technological Characteristics with the predicate device:
The M2 Wrist MRI System has the same technological characteristics as the predicate device, i.e., the Orthone MRI System. Both devices contain the same basic components consisting of a magnet, a coil, a separate electronic cabinet or unit containing a control unit, a RF power amplifier, gradient amplifier, power distribution unit, and spectrometer. Furthermore, both devices contain a computer PC component and system software. Both the M2 MRJ Wrist System and the Orthone MRI System are large devices with similar large dimensions and weight, although both of them a relatively compact MRI Systems as they are intended for small body parts as opposed to full body MRI systems.
The component specifications are comparable between the new MRI device and the predicate device. Both MRI devices use a 1 Tesla magnet as the basic scientific technology of the device. The basic device performance of the M2 Wrist MRJ System and the Orthone MRI System are similar. There are some minor differences between the M2 Wrist MRI System and the Orthone MRI System, including slice thickness.
Though there are some minor differences in the characteristics of the two systems, these differences do not raise new questions of safety or efficacy. Furthermore, the M2 Wrist MRI System has passed all the required tests and standards for MRI devices, as did the Orthone MRI System. These tests include compliance with electrical and mechanical safety according to IEC 60601-1, electromagnetic compatibility according to IEC 60601-1-2 and specific testing for MRI devices according to the IEC 60601-2-33 and testing according to the applicable NEMA standards.
#### Non-Clinical Performance Data:
See Performance Standards
#### Performance Standards:
The following performance tests were performed on the M2 Wrist MRI System or its components:
- Electrical & Mechanical Safety (IEC 60601-1) .
- 트 Electromagnetic Compatibility (IEC 60601-1-2)
- 트 Software Validation
- 트 MR Image Quality Testing
- NEMA MS-1-2008 Determination of Signal-to-Noise Ratio (SNR) in Diagnostic . Magnetic Resonance Imaging
- NEMA MS 3-2008 Determination of Two-Dimensional Geometric Distortion in I Diagnostic Magnetic Resonance Images (Image Uniformity Test)
- NEMA MS 4 (2006) Acoustic Noise Measurement Procedure for Diagnosing ■ Magnetic Resonance Imaging Devices
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- NEMA MS 5-2010 Determination of Slice Thickness in Diagnostic Magnetic . Resonance Imaging
- NEMA MS 8 (2006) Characterization of the Specific Absorption Rate (SAR) for . MRI Systems
- NEMA MS 10-2006 Determination of Local Specific Absorption Rate (SAR) in ■ Diagnostic Magnetic Resonance Imaging
- NEMA MS 11-2006 Determination of Gradient-Induced Electric Fields in ■ Diagnostic Magnetic Resonance Imaging
- NEMA MS 12-2006 Quantification and Mapping of Geometric Distortion for Special Applications
- IEC 60601-2-33 Medical electrical equipment Part 2-33: Particular requirements I for the basic safety and essential performance of magnetic resonance equipment for medical diagnostic (2007 (Second Edition) + A1:2005 + A2:2007)
- High Contrast Spatial Resolution Testing .
In all instances, the M2 Wrist MRI System functioned as intended and/or met the requirements of the standard.
## Clinical Performance Data:
Not Applicable
# Conclusions Drawn from Non-Clinical and Clinical Tests:
The performance tests demonstrate that M2 Wrist MRI System may be safely and effectively used in acquiring wrist MR images. The software validation and performance tests demonstrate that the M2 Wrist MRI System meets its design and performance specifications and is substantially equivalent to the cleared Orthone MRI System.
#### Substantial Equivalence:
In summary, the indications for use of the M2 Wrist MRI System are substantially equivalent to the Orthone MRI system. Furthermore, the basic technological characteristics of the M2 Wrist MRI System are similar to the Orthone MRI System. The differences in the technological characteristics do not raise new questions of safety and effectiveness. Consequently, the M2 Wrist MRI System is substantially equivalent to the predicate device.
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Image /page/4/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized graphic of an eagle or bird-like figure with three curved lines representing its wings or body.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 7, 2013
Aspect Imaging Ltd. c/o Ms. Ahava Stein Regulatory Consultant 20 HATA'AS ST (BOX 124) KFAR SABA 44425 ISRAEL
Re: K120701
Trade/Device Name: M2 Wrist MRI System Regulation Number: 21 CFR 892.1000 Regulation Name: Magnetic Resonance Diagnostic Device Regulatory Class: II Product Code: LNH Dated: January 20, 2013 Received: January 25, 2013
Dear Ms. Stein:
We have reviewed your Section 510(k) premarket notification of intent to market the devices indication we have teviewed your Section 3 re(i) pe 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 American Co., Continents, or to commerce provision way 20, 1976, the enaonance with the provisions of the Federal Food, DDVA A and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). and Costience Act (Act) that do not require approval controls provisions of the Act. The r ou may, ulcretore, manot the Act include requirements for annual registration, listing of general controls provisions of the fice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability additeration. Tease note: ODICP assess that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), If your device is classified (300 above) in Existing major regulations affecting your device can be It may be subject to additions, Title 21, Parts 800 to 898. 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 and of the other Flease be advised that I Dris issuance of or device complies with other requirements of the Act that I DA has made a decertifications administered by other Federal agencies. You must or ally it ederal statures and regulations and limited to: registration and listing (21 comply with an the Act 31equirements, montals, medical device reporting (reporting of medical Cr K Fall 607), labeling (21 OFR 803); good manufacturing practice requirements as set
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Page 2-Ms. Stein
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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 11 you desire specific advisoutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Division 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/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Michael D. O'Hara
Janine M. Morris Director, Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use Form
# 510(k) Number (if known): K120701 Device Name: M2 Wrist MRI System
#### Indications for Use:
The M2 Wrist MRI System is indicated for use as a magnetic resonance imaging device for The MZ Wrist MIKI System is indicated for assess of the internal structure of the wrist (in patients producing transverse, sagital and coronal mages of attained physician, the resultant MR images with an arm length - 520cm
provide information that can be useful in determining a diagnosis.
Prescription Use V (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostic Devices (OIVD)
Michael D. O'Hara
Division Sign-Off Office of In Vitro Diagnostic Device Evaluation and Safety
510(k) K120701
Page i of I
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.