Who is the manufacturer of EmboGuide?

Philips Medical Systems Nederland B.V. filed the 510(k) submission for EmboGuide (K142273).

What is the FDA product code for EmboGuide?

OWB. It is classified under 21 CFR 892.1650 as a Class 2 device in the Radiology panel.

What is the regulatory pathway for EmboGuide?

510(k) clearance (submission type: Traditional).

Does EmboGuide use AI or machine learning?

Yes. EmboGuide (K142273) is flagged as an AI/ML-enabled medical device in the FDA's AI/ML device list.

Who can help prepare an FDA 510(k) submission like EmboGuide?

Innolitics — a medical-device software consultancy — provides regulatory and engineering support for FDA 510(k) submissions. See https://innolitics.com/services/510ks/ or contact https://innolitics.com/contact.

Can an AI/ML device like EmboGuide get a guaranteed FDA 510(k) clearance?

Yes. Innolitics offers a guaranteed FDA 510(k) clearance engagement for AI/ML Software as a Medical Device — combining engineering and regulatory execution under one agreement with a guaranteed clearance outcome. Eligibility: the device must be an AI/ML Software as a Medical Device (SaMD), and its performance must meet the criteria Innolitics determines during an initial regulatory strategy engagement to be necessary for FDA clearance. See https://innolitics.com/services/end-to-end-samd/ or contact https://innolitics.com/contact.

EmboGuide

K142273 · Philips Medical Systems Nederland B.V. · OWB · Jan 30, 2015 · Radiology

Device Facts

Record ID	K142273
Device Name	EmboGuide
Applicant	Philips Medical Systems Nederland B.V.
Product Code	OWB · Radiology
Decision Date	Jan 30, 2015
Decision	SESE
Submission Type	Traditional
Regulation	21 CFR 892.1650
Device Class	Class 2
Attributes	AI/ML, Software as a Medical Device

Intended Use

EmboGuide is a post processing software medical device intended to assist physicians in performing embolization of hypervascular tumors in the liver using interventional X-ray. It provides tools to help the user with the analysis of 3D rotational angiography images. Its output is intended as an adjunct means to help with the planning and guidance of the embolization procedure. It provides real time overlay of 3D rotational angiography images of the same anatomy to support device/catheter guidance.

Device Story

EmboGuide is post-processing software for Allura interventional X-ray systems; assists physicians in liver tumor embolization. Inputs: 3D volumes from rotational angiography; lesion segmentations from CT, MR, or XperCT. Processing: identifies/annotates feeding vessels; registers 3D volumes to live 2D X-ray images. Output: real-time 3D/2D fused overlay for catheter guidance; planning data display. Used in interventional suites by physicians. Benefits: improved visualization of tumor-feeding vasculature; supports precise navigation during embolization.

Clinical Evidence

Retrospective study of 44 patients. Compared EmboGuide Automatic Feeder Detection (AFD) and clinical practice (manual adjustment) against CBCT alone. Ground truth established by consensus of two radiologists. Primary endpoint: sensitivity and inter-reader agreement. Results: EmboGuide clinical practice sensitivity 83% (±8%); EmboGuide AFD and clinical practice showed higher sensitivity than CBCT. Inter-reader agreement for EmboGuide (AFD and clinical) >0.7 (consistent), whereas CBCT agreement was 0.69 (inconsistent).

Technological Characteristics

Post-processing software extension for Allura interventional X-ray systems. Uses 3D rotational angiography reconstruction. Connectivity: DICOM compliant. Standards: IEC 62304 (software lifecycle), IEC 62366 (usability), ISO 14971 (risk management).

Indications for Use

Indicated for physicians performing embolization of hypervascular liver tumors using interventional X-ray. Used as an adjunct for planning and guidance of embolization procedures.

Regulatory Classification

Identification

An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.

Special Controls

*Classification.* Class II (special controls). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

Predicate Devices

3D Roadmap Rel. 1 (K121772)

Reference Devices

FlightPlan for Liver (K121200)
Allura interventional X-ray system (K133292)

Related Devices

K201583 — SmartCT R1.0 · Philips Medical Systems Nederland B.V. · Feb 9, 2021
K193261 — FlightPlan for Embolization · GE Medical Systems SCS · Jan 24, 2020
K151598 — VesselNavigator Rel. 1.0 · Philips Medical Systems Nederland B.V. · Aug 17, 2015
K163285 — syngo Application Software · Siemens Medical Solution USA, Inc. · Feb 14, 2017
K182601 — Vitrea Software Package, VSTP-001A · Canon Medical Systems Corporation · Dec 14, 2018

Submission Summary (Full Text)

{0}------------------------------------------------ Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002 January 30, 2015 Philips Medical Systems Nederland B.V. % Ms. Liselotte Kornmann Regulatory Affairs Manager Veenpluis 4-6 Best, 5684 PC THE NETHERLANDS Re: K142273 Trade/Device Name: EmboGuide Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OWB, LLZ, JAK Dated: December 16, 2014 Received: January 12, 2015 Dear Ms. Kornmann: 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, 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), it may be subject to 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. 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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. {1}------------------------------------------------ If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education 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. 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 Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Sincerely yours, Robert A Ochs Robert Ochs. Ph.D. Acting Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ # Indications for Use 510(k) Number (if known) K142273 Device Name EmboGuide Indications for Use (Describe) EmboGuide is a post processing software medical device intended to assist physicians in performing embolization of hypervascular tumors in the liver using interventional X-ray. It provides tools to help the user with the analysis of 3D rotational angiography images. Its output is intended as an adjunct means to help with the planning and guidance of the embolization procedure. It provides real time overlay of 3D rotational angiography images of the same anatomy to support device/catheter guidance. ### Type of Use (Select one or both, as applicable) 2 Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C) ## PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED. ### FOR FDA USE ONLY Concurrence of Center for Devices and Radiological Health (CDRH) (Signature) This section applies only to requirements of the Paperwork Reduction Act of 1995. ### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ # 510(k) Summary of Safety and Effectiveness This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR §807.92. | Date Prepared: | December 16, 2014 | | |------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------| | Manufacturer: | Philips Medical Systems Nederland B.V. Veenpluis 4-6 5684 PC Best The Netherlands Establishment Registration Number: 3003768277 | | | Contact Person: | Mr. Hans Venings Director of Regulatory Affairs Phone: +31 611348827 E-mail: hans.venings@philips.com | | | Device: | Trade Name: | EmboGuide | | | Device Name: | EmboGuide Rel. 1.0 | | | Classification Name: | Image-intensified fluoroscopic x-ray system | | | Classification Regulation: | 21CFR §892.1650 | | | Classification Panel: | Radiology | | | Device Class: | Class II | | | Primary Product Code: Secondary Product Code: | OWB (Interventional x-ray system) LLZ (system, image processing, radiological), JAK (system, x-ray, tomography, computed) | | Primary Predicate Device: | Trade Name: | 3D Roadmap Rel. 1 | | | Manufacturer: | Philips Medical Systems Nederland B.V. | | | 510(k) Clearance: | K121772 (March 21, 2013) | | | Classification Regulation: | 21 CFR, Part 892.1650 | | | Classification Name: | Image-intensified fluoroscopic x-ray system | | | Classification Panel: | Radiology | | | Device Class: | Class II | | | Primary Product Code: Secondary Product Code: | OWB (Interventional x-ray system) LLZ (system, image processing, radiological), JAK (system, x-ray, tomography, computed) | {4}------------------------------------------------ Image /page/4/Picture/0 description: The image shows the word "PHILIPS" in a bold, sans-serif font. The color of the text is a medium blue. The background is white, providing a clear contrast that makes the brand name easily visible. | Reference Device: | Trade Name: Manufacturer: 510(k) Clearance: Classification Regulation: Classification Name: Classification Panel: Device Class: Product Code: | FlightPlan for Liver GE Healthcare K121200 (November 2, 2012) 21 CFR, Part 892.2050 Picture Archiving and Communications System Radiology Class II LLZ | |--------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Device description: | EmboGuide is a post processing software medical device intended to assist physicians in performing embolization of hypervascular tumors in the liver using interventional X-ray. EmboGuide is an extension of XperCT and intended to be used in combination with an Allura interventional X-ray system. Like the primary predicate device 3D Roadmap, EmboGuide adds specific functionality to the Allura system but does not change the overall intended use of the Allura system or the overall risk profile. EmboGuide uses a 3D volume reconstructed from 3D rotational angiography images acquired on the Allura X-ray system and the segmentation of lesions on previously acquired CT, MR or XperCT datasets as input data for the planning of the embolization. The physician can use this input data to analyze the vasculature of lesions, and to identify and annotate the blood vessels that shall be embolized (feeding vessels). The real-time overlay and registration of the 3D volume on live 2D X-ray images from the Allura X-ray system of the same anatomy can be used as additional 3D image guidance to support the navigation of the device/catheter. Planning data, like the earlier annotated feeding vessels and/or 3D landmarks can be displayed on 2D-3D fused images as supporting information. | | | Indications for Use: | EmboGuide is a post processing software medical device intended to assist physicians in performing embolization of hypervascular tumors in the liver using interventional X-ray. It provides tools to help the user with the analysis of 3D rotational angiography images. Its output is intended as an adjunct means to help with the planning and guidance of the embolization procedure. It provides real time overlay of 3D rotational angiography images on live 2D X-ray images of the same anatomy to support device/catheter guidance. EmboGuide has similar indications for use as its primary predicate device 3D Roadmap: Similar to 3D Roadmap, EmboGuide is a supportive tool to help the physician with performing an interventional procedure on the Allura X-ray Xper system.Similar to 3D Roadmap, EmboGuide provides the real time overlay of 3D rotational angiography images on live 2D X-ray images of the same anatomy to support device/catheter guidance. | | | • | Both EmboGuide and 3D Roadmap are extensions of the Allura interventional X-ray system (K133292). | | | • | Both EmboGuide and 3D Roadmap use 3D volumes reconstructed from 3D rotational angiography images as input. | | | • | Both EmboGuide and 3D Roadmap provide the overlay of 3D volume on live fluoroscopic images acquired from the Allura X-ray system. | | | • | Both EmboGuide and 3D Roadmap provide dynamic update to changes of the position of the X-ray equipment; the 3D volume is automatically adjusted to any gantry changes and any lateral or longitudinal table movements. | | | • | EmboGuide provides additional functionality to assist the clinical user with identifying arteries that are feeding into hypervascular tumors and to plan for the embolization treatment of these tumors. This is functionality to further support the clinician in performing interventions and does not raise new questions related to safety and effectiveness. Furthermore, the scientific method is comparable to reference device FlightPlan for Liver which also implements an algorithm for detecting vessels leading to a lesion. | | | Summary of Non-clinical Performance Data: | Non-clinical performance testing has been performed on EmboGuide and demonstrates compliance with the following International and FDA-recognized consensus standards and FDA guidance document: | | | • | IEC 62304 Medical device software – Software life cycle processes (Ed. 1.0, 2006), | | | • | IEC 62366 Medical devices – Application of usability engineering to medical devices (Ed. 1.0, 2007), | | | • | ISO 14971 Medical devices – Application of risk management to medical devices (Ed. 2.0, 2007), | | | • | NEMA PS 3.1-3.20 Digital Imaging and Communications in Medicine (DICOM) Set (2011), and | | | • | Guidance for Industry and FDA Staff – Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (issued May 11, 2005, document number 337). | | | | Verification and validation tests have been performed to address intended use, the technical claims, requirement specifications and the risk management results. The test results in this 510(k) premarket notification demonstrate that | | {5}------------------------------------------------ Image /page/5/Picture/0 description: The image shows the word "PHILIPS" in a bold, sans-serif font. The color of the text is a medium blue. The letters are evenly spaced and fill most of the frame. The background is white. Technological characteristics: EmboGuide employs the same fundamental scientific technology as its primary predicate device 3D Roadmap. ## EmboGuide: - complies with the aforementioned international and FDA-recognized ● consensus standards and FDA guidance document, and - . meets the acceptance criteria and is adequate for its intended use. {6}------------------------------------------------ Image /page/6/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters. The letters are evenly spaced and fill most of the frame. The background is plain white, which makes the blue letters stand out. # Summary of Clinical Performance Data: Clinical testing of EmboGuide included an initial reading study to validate the user interaction in the embolization planning workstep and a clinical validation study to validate the correctness and consistency of EmboGuide to identify feeding vessels leading to previously segmented lesions. Substantial equivalence was based in part on the clinical validation study of the EmboGuide software. Clinical Validation Study The clinical validation study of EmboGuide was based on a retrospective image collection of 63 patients (outside the United States) and included a prospective review of randomized images; 44 subjects were included in the study and 19 were excluded. First, feeding vessels of the lesions were defined by consensus of two experienced interventional radiologists (located outside the United States) who also performed the procedures by using all available information (2D angiography, MR and /or CT, Cone Beam CT (CBCT) and EmboGuide). This was used as the "ground truth". Another three independent interventional radiologists (located out- and inside the United States) determined the feeding vessels based on CBCT, EmboGuide automatic feeder detection (AFD) and by subsequent review i.e., adding and deleting feeding vessels. Finally, the "ground truth" was compared with the determination of feeding vessels by the three independent readers for CBCT, EmboGuide AFD alone, and EmboGuide used in normal clinical practice (i.e., adding or removing vessels). The performance of EmboGuide was evaluated by the sensitivity. The study also evaluated whether consistent results could be obtained across multiple users. The study showed that: - the sensitivity of EmboGuide in clinical routine use for identification of . tumor feeding vessels is 83+/- 8% with a CI of 95% for HCC patients with diagnostic quality CBCT images and no tumors or feeding vessels outside the volume imaged with CBCT. - . EmboGuide as it will be used in normal clinical practice provides for a higher sensitivity to identify feeding vessels compared to CBCT, - EmboGuide AFD alone provides for a higher sensitivity to identify feeding vessels compared to CBCT, - . the overall agreement among readers for identification of feeding vessels using both the EmboGuide AFD and EmboGuide as it will be used in clinical practice was greater than the pre-selected acceptance criteria of 0.7 (i.e., 70%) indicating that for both approaches results in a consistent identification of feeding vessels for different readers, - . the agreement among readers for identification of feeding vessels using the EmboGuide AFD alone was close to one (i.e., 0.99 with the lower bound of the 95% CI of 0.986), and - the overall agreement among readers for identification of feeding vessels using the CBCT (i.e., 0.69 with lower 95%CI of 0.648) was less than the preselected acceptance criteria of 0.7 (i.e., 70%) indicating that identification of feeding vessels using this method may not be consistent for different readers. The clinical performance data as documented in the clinical validation study demonstrate that EmboGuide performs comparably to the reference device FlightPlan for Liver that is currently marketed. {7}------------------------------------------------ Image /page/7/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters. The font is sans-serif and the letters are evenly spaced. The word is centered and takes up most of the frame. The background is plain white. Substantial Equivalence Conclusion: Based on the information and comparison presented in the aforementioned sections, the proposed EmboGuide Rel. 1.0 software medical device is considered substantially equivalent to the currently marketed predicate device: 3D Roadmap, in terms of design features, fundamental scientific technology, indications for use, and safety and effectiveness. For specific functionality to assist the clinical user in analyzing the 3D images of the vascular tree to plan for the embolization treatment, EmboGuide Rel. 1.0 is comparable to the currently marketed reference device FlightPlan for Liver. The (non-)clinical performance tests provided in this 510(k) premarket notification demonstrates that the proposed EmboGuide Rel. 1.0 is as safe and effective as its predicate device without raising any new safety and/or effectiveness concerns