Who is the manufacturer of CuattroDR?

Cuattro, LLC filed the 510(k) submission for CuattroDR (K161937).

What is the FDA product code for CuattroDR?

KPR. It is classified under 21 CFR 892.1680 as a Class 2 device in the Radiology panel.

What is the regulatory pathway for CuattroDR?

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

Does CuattroDR use AI or machine learning?

Yes. CuattroDR (K161937) is flagged as an AI/ML-enabled medical device in the FDA's AI/ML device list.

What are the predicate devices for CuattroDR?

Visaris Avanse (K150725); UnoMD (CloudDR) (K093480).

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

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 CuattroDR 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.

CuattroDR

K161937 · Cuattro, LLC · KPR · Oct 6, 2016 · Radiology

Device Facts

Record ID	K161937
Device Name	CuattroDR
Applicant	Cuattro, LLC
Product Code	KPR · Radiology
Decision Date	Oct 6, 2016
Decision	SESE
Submission Type	Traditional
Regulation	21 CFR 892.1680
Device Class	Class 2
Attributes	AI/ML, Software as a Medical Device

Intended Use

The CuattroDR, when used with a cleared digital image capture device, provides for the capture of digital images in place of conventional film radiographic examinations. The device is intended to be available for retrofit on existing or planned x-ray machines with a cleared digital image capture device. The device is intended for use by trained and qualified personnel in the acquisition and review of radiographic images. The product is not intended for mammography or fluoroscopy applications.

Device Story

CuattroDR is a software application for Windows-based workstations that acquires, processes, and displays digital X-ray images; replaces conventional film radiography. Input: X-ray signals from cleared digital flat panel detectors. Operation: Software interfaces with X-ray generators (via RS-232) and detectors to capture images; processes images using Sharp View Image Enhancement System; presents images on touch screen monitors within 12 seconds. Output: Digital radiographic images for review, archival, and transmission to PACS/DICOM systems. Used in clinical settings by trained personnel (radiographers/radiologists). Benefits: Enables digital image acquisition on existing X-ray hardware; enhances image detail for clinical review; facilitates efficient workflow via DICOM connectivity and generator control.

Clinical Evidence

Bench testing only. Verification and validation testing performed per design control processes and FDA software guidance. Testing included basic functionality, communication, exposure feedback, and generator control (kVp, mAs, mA, time, focal spot) using a Sedecal SHFR generator and five different cleared digital detectors with anatomical phantoms. No clinical data presented.

Technological Characteristics

Software-based workstation application; Windows Embedded 8.1 Industry Pro OS. Connectivity: Ethernet, DICOM 3.0 compliant. Image processing: Sharp View Image Enhancement System. Generator control: RS-232 interface. Hardware: Compatible with fixed/portable, wired/wireless digital flat panel detectors. Form factor: Standalone software on PC workstation.

Indications for Use

Indicated for trained and qualified personnel for the acquisition and review of radiographic images using a cleared digital image capture device as a retrofit for existing or planned x-ray machines. Not for mammography or fluoroscopy.

Regulatory Classification

Identification

A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. 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). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary 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.

Predicate Devices

Visaris Avanse (K150725)
UnoMD (CloudDR) (K093480)

Reference Devices

Sharp View Image Enhancement System (K024028)

Related Devices

K093480 — CUATTRO UNOMD · Cuattro, LLC · Mar 5, 2010
K170729 — Examion X-AQS · Examion GmbH · Jul 18, 2017
K123650 — ARIX RAD ACQUISITION CONSOLE · Compania Mexicana DE Radiologia Cgr, S.A. DE C.V. · Feb 20, 2013
K193644 — E-COM DR-2000 DR · Livermoretech, Inc. · Feb 14, 2020
K182537 — RADMAX Digital Imaging Software · DRGEM Corporation · Mar 8, 2019

Submission Summary (Full Text)

{0}------------------------------------------------ Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus or a series of interconnected human profiles. Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002 October 6, 2016 Cuattro, LLC % Mr. Matthew Taylor Director, Quality Assurance/Regulatory 3760 Rocky Mountain Avenue LOVELAND CO 80538 Re: K161937 Trade/Device Name: CuattroDR Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: KPR, LLZ Dated: September 14, 2016 Received: September 15, 2016 Dear Mr. Taylor: 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 Ochs Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ ## 4. Indications for Use (Form 3881) DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration #### Indications for Use 510(k) Number (if known) K161937 Device Name CuattroDR Indications for Use (Describe) The CuattroDR, when used with a cleared digital image capture device, provides for the capture of digital images in place of conventional film radiographic examinations. The device is intended to be available for retrofit on existing or planned x-ray machines with a cleared digital image capture device. The device is intended for use by trained and qualified personnel in the acquisition and review of radiographic images. The product is not intended for mammography or fluoroscopy applications. Type of Use (Select one or both, as applicable) > Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C) #### CONTINUE ON A SEPARATE PAGE IF NEEDED. 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." FORM FDA 3881 (8/14) Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below. {3}------------------------------------------------ Image /page/3/Picture/0 description: The image shows the word "cuattro" in a lowercase sans-serif font, with a green four-leaf clover above it. The clover is stylized, with rounded leaves and a single stem extending downwards. The word "cuattro" is in a muted blue-green color, contrasting with the brighter green of the clover. The overall design is simple and clean, suggesting a modern and possibly eco-friendly brand. # 510(k) summary ## 510(k) Owner | Cuattro, LLC | | |----------------------------|-----------------| | 3760 Rocky Mountain Avenue | | | Loveland, CO 80538 | | | Phone: | 970-775-2247 | | Facsimile: | 970-775-2247 | | Registration Number: | 3008364043 | | Date Prepared: | August 30, 2016 | ## 510(k) Submitter | Cuattro, LLC | | |----------------------------|----------------| | 3760 Rocky Mountain Avenue | | | Loveland, CO 80538 | | | Phone: | 970-775-2247 | | Facsimile: | 970-775-2247 | | Contact: | Matthew Taylor | | Device Trade Name: | CuattroDR | |----------------------|-------------------------| | Common Name: | Stationary X-Ray System | | Classification Name: | Stationary X-Ray system | | Regulation Number: | 21 CFR 892.1680 | | Product Code: | KPR. LLZ | Substantial equivalence is claimed to the following Legally Marketed Devices: Primary predicate K150725: | Manufacturer: | VISARIS | |----------------------|-------------------------| | Device | Visaris Avanse | | 510(k) Number: | K150725 | | Classification Name: | Stationary X-Ray system | | Regulation Number: | 21 CFR 892.1680 | | Product Code: | KPR, LLZ | {4}------------------------------------------------ Secondary predicate K093480: | Manufacturer: | Cuattro | |----------------------|---------------------------------------------| | Device | UnoMD (CloudDR) | | 510(k) Number: | K093480 | | Classification Name: | Picture Archiving and Communications System | | Regulation Number: | 21 CFR 892.2050 | | Product Code: | LLZ | #### Device Description The CuattroDR device is a software application capable of acquiring x-ray images from commonly commercialized digital flat panels on a Windows based computer workstation. The software can use traditional mouse and keyboard inputs as well as touch screen monitors as an alternative. The use of the CuattroDR software enables the user to use a traditional x-ray generator and capture x-rav images without film. The images are processed and then presented to the user on a touch screen computer monitor, within 12 seconds after the x-ray exposure. The software also has capabilities to send images to hospital medical PACS systems and digital media for archival. In addition to this functionality, the CuattroDR software provides a user interface for generator control in the process of acquiring digital images. ### Indications for Use The CuattroDR, when used with a cleared digital image capture device, provides for the capture of digital images in place of conventional film radiographic examinations. The device is intended to be available for retrofit on existing or planned x-rav machines with a cleared digital image capture device. The device is intended for use by trained and qualified personnel in the acquisition and review of radiographic images. The product is not intended for mammography or fluoroscopy applications. ### Technological Characteristics The technological characteristics are essentially the same as the legally marketed predicate devices: - All three of the devices (the subject device as well as the predicate devices) provide for features used by personnel in the acquisition and review of radiographic images. - . All three of the devices (the subject device as well as the predicate devices) utilize software on a workstation computer with Ethernet capability, and provide DICOM 3.0 compliant connectivity. - All three of the devices (the subject device as well as the predicate devices) are a ● software solution intended for use with already cleared digital image capture devices, utilizing fixed or portable digital image capture devices and wired or wireless digital image capture devices - All three of the devices (the subject device as well as the predicate devices) provide for ● image processing of acquired images to enhance images to help clinicians see more detail in the digital X-Ray image {5}------------------------------------------------ - All three of the devices (the subject device as well as the predicate devices) are stand-. alone software products. - All three of the devices (the subject device as well as the predicate devices) have . essentially the same workstation requirements. - The new CuattroDR device as well as the Visaris Avance® device, in addition to the . image acquisition, processing and viewing, provides a user interface for generator control in the acquisition of images. The Cuattro UnoMD (CloudDR) device does not provide an interface for generator control | Technical Characteristic | CuattroDR (this submission) | Cuattro UnoMD - (Name was changed to CloudDR on FDA registration page 6/30/11) | Visaris Visaris Avanse® | Equivalence / Rationale | |--------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | FDA 510(k) # | K161937 | K093480 | K150725 | | | Indications for Use | The CuattroDR, when used with a cleared digital image capture device, provides for the capture of digital images in place of conventional film radiographic examinations. The device is intended to be available for retrofit on existing or planned x-ray machines with a cleared digital image capture device. The device is intended for use by trained and qualified personnel in the acquisition and review of radiographic images. The product is not intended for mammography or fluoroscopy applications. | The Cuattro UnoMD, when used with a cleared digital image capture device, provides for the capture of digital images in place of conventional film radiographic examinations. The device is intended to be available for retrofit on existing or planned x-ray machines with a cleared digital image capture device. The device is intended for use by trained and qualified personnel in the acquisition and review of radiographic images. The product is not intended for mammography or fluoroscopy applications. | The purpose of Visaris Avanse® is to acquire, store, communicate, display and process medical X-ray images. It offers features (e.g. window leveling, zoom, measurements, annotations etc.) routinely used by medical professionals, such as radiologists and radiographers. Visaris Avanse supports printing to DICOM compatible printers. Within a network environment Visaris Avanse may provide other modalities with a DICOM worklist and a DICOM worklist service. Images and worklists can be sent and received using the DICOM protocol. Visaris Avanse has a modular system architecture. It consists of the basic application for image acquisition, processing and viewing as well as a number of other modules for image and worklist management, archiving, search and display. Beside the basic functionality Visaris Avanse also provides a user interface for generator control and image acquisition of medical images DR detectors. | Equivalent - Both devices are intended to be used to provide for the acquisition of digital X-ray images in place of conventional film for radiographic examinations. | | Image acquisition | Cleared digital image capture device (DR), utilizing fixed or portable digital image capture devices and wired or wireless digital image capture devices. | Cleared digital image capture device (DR), utilizing fixed or portable digital image capture devices and wired or wireless digital image capture devices. | Cleared digital image capture device (DR), utilizing fixed or portable digital image capture devices and wired or wireless digital image capture devices. | Equivalent | | Features for use by personnel in the acquisition and review of images | Window leveling Zoom Measurements Annotations / Markers Image Stitching Image flip Image rotate Image crop Image shutter Receptor selection Invert (reverses gray scale) Image reject, with reason selection Add/Delete procedure to study Radiology report Patient search and entry | Window leveling Zoom Measurements Annotations / Markers Image Stitching Image flip Image rotate Image crop Image shutter Receptor selection Invert (reverses gray scale) Image reject, with reason selection Add/Delete procedure to study Radiology report Patient search and entry | Window leveling Zoom Measurements Annotations Image Stitching Patient search and entry Etc. | Equivalent | | Technical Characteristic | CuattroDR (this submission) | Cuattro UnoMD - (Name was changed to CloudDR on FDA registration page 6/30/11) | Visaris Visaris Avanse® | Equivalence / Rationale | | Image Processing | Incorporates Sharp View Image Enhancement System manufactured by Context Vision, AB (K024028) Context Vision is used to enhance images after X-Ray acquisition to help clinicians see more detail in the digital X-Ray image. | Incorporates Sharp View Image Enhancement System manufactured by Context Vision, AB (K024028) Context Vision is used to enhance images after X-Ray acquisition to help clinicians see more detail in the digital X-Ray image. | Advanced anatomy driven image processing (From marketing literature) | Equivalent - Both devices use proprietary image processing | | Generator Control | The CuattroDR device does provide, through an RS-232 interface, the ability to provide control for select X-Ray generators, including AEC - Validated with Sedecal Generators | NONE | Control compatibility with select X-Ray generators - Validated with Sedecal and other generators | Equivalent | | CPU Workstation Requirements | Microsoft Windows Embedded 8.1 Industry Pro Operating system that meets minimum system requirements. | Microsoft Windows XP/7/8.1/8 Embedded Operating system that meets minimum system requirements. | MS Windows XP/7/8 operating system on any hardware platform meeting the minimum system requirements | Equivalent - All devices run on a Windows platform | | Integration | HIS/RIS - import of Modality Worklist information from the institution HIS/RIS | HIS/RIS - import of Modality Worklist information from the institution HIS/RIS | Images and worklists can be sent and received using the DICOM protocol. | Equivalent | | External Connectivity | DICOM 3.0 Compatible - Export to external PACS, View Stations, CD, DICOM Print | DICOM 3.0 Compatible - Export to external PACS, View Stations, CD, DICOM Print | Images and worklists can be sent and received using the DICOM protocol. | Equivalent | {6}------------------------------------------------ ### Determination of Substantial Equivalence The determination of substantial equivalence is based upon non-clinical performance data. Bench testing has been performed on the device following Cuattro's design control processes, as well as the applicable FDA guidance documents, in particular the guidance on Content of Premarket Submissions for Software Contained in Medical Devices. Bench testing has been performed by a member of the team not directly responsible for software development undertook verification testing of the device. The verification test was in accordance with the following documents: Cuattro Design Output Document, "Design_Output_SWR_00069_MD" Cuattro Design Verification Document, "Design_Verification_SWR_00069_MD" Cuattro Design Validation Document, "Design Validation SWR 00069 MD" Validation testing for the new device included a focus on the difference between the Cuattro UnoMD (CloudDR) device and the new CuattroDR device. This testing, utilizing a Sedecal SHFR generator, five different cleared wired digital image detectors from two manufacturers, and appropriate anatomical phantoms, included: ### Basic Functionality, Establishing/Maintaining Communications, Exposure Feedback kVp Control mAs Control Focal Spot Control mA and Time Controls Unintentional Exposure Prevention Generator Technique Validation Feature {7}------------------------------------------------ Advanced Functionality, AEC Control Workstation Assignment Patient Size Adjustment The results of this bench testing have demonstrated that the device is substantially equivalent to the referenced predicate device. The details of this testing and test results are in this submission in section 18, Performance Testing – Bench #### Conclusion Based upon the analysis of the Indications for Use, Technological Characteristics, and the results of the Bench Testing performed on the device, we have determined that the CuattroDR is safe and effective, and substantially equivalent to the Predicate Device.