K221281 · Siemens Medical Solutions · OWB · Nov 17, 2022 · Radiology
Device Facts
Record ID
K221281
Device Name
Multitom Rax
Applicant
Siemens Medical Solutions
Product Code
OWB · Radiology
Decision Date
Nov 17, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1650
Device Class
Class 2
Attributes
Pediatric
Indications for Use
Multitom Rax is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging from gastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography, and digital subtraction angiography (DSA). The system may be used on pediatric, adult, and bariatric patients. The True2scale Body Scan functionality (i.e., slot-scanning-based acquisition and reconstruction technique) of the Multitom Rax is intended to be used for the generation of a geometrically accurate (in scanning direction) 2-D representation of the spine, the lower limbs or the full body which may be used for the assessment of body axes and skeletal alignment. The True2scale Body Scan is not intended to be used for interventional purposes. The Real3D functionality (i.e., cone-beam CT acquisition and reconstruction technique) of the Multitom Rax is intended to be used for 3D bone imaging of the head, the upper and lower extremities as well as the lumbar spine. Real3D is not intended for imaging of the torso of patients with a Body Mass Index (BMI) exceeding 30 kg/m². Multitom Rax is not for mammography examinations.
Device Story
Multitom Rax is a stationary X-ray system for radiography and fluoroscopy; features floor-mounted table and ceiling-suspended X-ray tube/Solid State X-ray Imager (SSXI). System utilizes two telescopic arms to perform continuous scans. True2scale Body Scan uses slot-scanning acquisition for 2D skeletal alignment imaging. Real3D functionality performs circular cone-beam CT (CBCT) scans for 3D bone imaging. Operated by healthcare professionals in clinical settings. Output consists of 2D/3D images for diagnostic assessment of osseous structures, fractures, and bone angles. System includes error monitoring and visual/audible warnings. Benefits include comprehensive imaging modes and improved diagnostic quality for bone structures.
Clinical Evidence
Bench testing included high-contrast resolution (MTF), low-contrast detectability, CT number accuracy, uniformity, image noise, and slice sensitivity profile. Clinical evaluation involved a 3-month Customer Use Test and an image quality assessment of 21 anonymized clinical/phantom datasets (foot, ankle, knee, hip, lumbar spine, elbow, hand, head) by board-certified radiologists, confirming sufficient diagnostic quality for osseous assessment.
Technological Characteristics
Stationary X-ray system; SSXI with Cesium Iodide scintillator; 16-bit grayscale. High-frequency generator (65/80 kW); X-ray tube (820 KHU, 0.6/1.0 focal size). Two telescopic arms with 3 translational/2 rotational degrees of freedom. Connectivity: DICOM. Software: VF11. Standards: IEC 60601-1, 60601-1-2, 60601-1-3, 60601-2-54, 62304, 62366, ISO 14971.
Indications for Use
Indicated for pediatric, adult, and bariatric patients requiring radiographic and fluoroscopic imaging, including gastrointestinal, cranial, skeletal, thoracic, lung, urogenital, emergency, lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, and angiography. True2scale Body Scan indicated for 2D spine, lower limb, or full-body imaging for skeletal alignment assessment. Real3D indicated for 3D bone imaging of head, upper/lower extremities, and lumbar spine. Contraindications: Real3D not for torso imaging in patients with BMI > 30 kg/m²; not for mammography.
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
Multitom Rax With True2scale Body Scan Option (K212212)
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November 17, 2022
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Siemens Medical Solutions % Denise Adams Regulatory Affairs Professional 40 Liberty Boulevard MALVERN PA 19355
Re: K221281
Trade/Device Name: Multitom Rax Regulation Number: 21 CFR 892.1650 Regulation Name: Image-Intensified Fluoroscopic X-Ray System Regulatory Class: Class II Product Code: OWB, JAA, JAK Dated: October 18, 2022 Received: October 19, 2022
Dear Denise Adams:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Zhkke
Laurel Burk, Ph.D. Assistant Director Diagnostic X-Ray Systems Team DHT8B: Division of Radiological Imaging Devices and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K221281
Device Name Multitom Rax
### Indications for Use (Describe)
Multitom Rax is a device intended to visualize anatomical structures by converting an X- ray pattern into a visible image. The system has medical applications ranging from gastrointestinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications, lymphography, endoscopy, myelography, arthrography, interventional radiology, digital angiography, and digital subtraction angiography (DSA). The system may be used on pediatric, adult, and bariatric patients.
The True2scale Body Scan functionality (i.e., slot-scanning-based acquisition and reconstruction technique) of the Multitom Rax is intended to be used for the genetrically accurate (in scanning direction) 2-D representation of the spine, the lower limbs or the full body which may be used for the assessment of body axes and skeletal alignment. The True2scale Body Scan is not intended to be used for interventional purposes.
The Real3D functionality (i.e., cone-beam CT acquisition and reconstruction technique) of the Multitom Rax is intended to be used for 3-D bone imaging of the head, the upper and lower extremities as well as the lumbar spine. Real3D is not intended for imaging of the torso of patients with a Body Mass Index (BMI) exceeding 30 kg/m².
Multitom Rax is not for mammography examinations.
Type of Use (Select one or both, as applicable)
| <div> <span> <span style="font-size:16px">✖</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> |
|-----------------------------------------------------------------------------------------------------------------------|
| <div> <span> <span style="font-size:16px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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## 510(k) Summary: Multitom Rax
Company: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355
Date Prepared: November 16, 2022
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of SMDA of 1990 and 21 CFR § 807.92.
#### 1. General Information:
## Importer / Distributor:
Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Establishment Registration Number: 2240869
## Location of Manufacturing Site:
Siemens Healthcare GmbH Siemensstr. 1 91301 Forchheim, Germany Establishment Registration Number: 3004977335
#### 2. Contact Person:
Denise Adams, RAC Regulatory Affairs Professional Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355, US adams.denise@siemens-healthineers.com
## Alternate Contact Person:
Martin Rajchel Senior Regulatory Affairs Manager Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355, US martin.rajchel @siemens-healthineers.com
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- 3. Device Name and Classification:
Trade Name: Multitom Rax Classification Name: Image-intensified fluoroscopic x-ray system Classification Panel: Radiology Classification Regulation: 21 CFR §892.1650 Device Class: II Product Code: OWB Secondary Product Code: JAA, JAK
#### 4. Legally Marketed Predicate Device:
| Trade Name | Multitom Rax With True2scale Body Scan Option |
|--------------------------------|-----------------------------------------------|
| Company | Siemens Medical Solutions USA, Inc. |
| 510(k) Number | K212212 |
| Device Classi-<br>ficationName | Interventional Fluoroscopic X-ray System |
| Regulation<br>Number | 892.1650 |
| Review Panel | Radiology |
| Product Code | OWB |
| Secondary<br>Product Code | JAA |
| Device Class | 2 |
#### 5. Legally Marketed Reference Device:
| Trade Name | LineUP |
|--------------------------------|----------------------------------|
| Company | CurveBeam, LLC |
| 510(k) Number | K180727 |
| Device Classi-<br>ficationName | Computed tomography X-ray System |
| Regulation<br>Number | 892.1750 |
| Review Panel | Radiology |
| Product Code | JAK |
| Device Class | 2 |
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Image /page/5/Picture/0 description: The image shows the Siemens Healthineers logo. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the words is a graphic of orange dots.
#### 6. Device Description:
Multitom Rax is a stationary X-ray system for radiography and fluoroscopy. Multitom Rax consists of a floor mounted patient table (option) and ceiling suspended X-ray tube, and a ceiling suspended Solid State X-ray Imager (SSXI). Together with an X-ray generator and a digital imaging system, Multitom Rax provides comprehensive image acquisition modes to support radiographic and fluoroscopic imaging procedures.
With the True2scale Body Scan technology, Multitom Rax performs a continuous scan that moves along the patient's vertical axis with a highly collimated radiation beam along a line trajectory using the system's two telescopic arms. The projections, which are acquired during the scanning process, form the basis for a reconstruction to obtain a 2D representation of the scanned object.
With the Real3D technology, Multitom Rax performs a continuous, circular scan around the patient using the system's two telescopic arms. The projections, which are acquired during the scanning process, form the basis for a reconstruction to obtain a 3D representation of the scanned object.
#### 7. Indication for Use:
Multitom Rax is a device intended to visualize anatomical structures by converting an X-ray pattern into a visible image. The system has medical applications ranging fromgastrointestinal examinations to cranial, skeletal, thoracic and lung exposures as well as examinations of the urogenital tract. The unit may also be used in emergency applications.lymphography, endoscopy, myelography, venography, arthrography, interventional radiology, digital angiography, and digital subtraction angiography (DSA). The system may be used on pediatric, adult, and bariatric patients.
The True2scale Body Scan functionality (i.e., slot-scanning-based acquisition and reconstruction technique) of the Multitom Rax is intended to be used for the generation of a geometrically accurate (in scanning direction) 2-D representation of the spine, the lower limbs or the full body which may be used for the assessment of body axes and skeletal alignment. The True2scale Body Scan is not intended to be used for interventional purposes.
The Real3D functionality (i.e., cone-beam CT acquisition and reconstruction technique) of the Multitom Rax is intended to be used for 3D bone imaging of the head, the upper and lower extremities as well as the lumbar spine.
Real3D is not intended for imaging of the torso of patients with a Body Mass Index (BMI) exceeding 30 kg/m².
Multitom Rax is not for mammography examinations.
#### 8. Substantial Equivalence:
The subject device is the same as the predicate device. The software was updated and new CBCT trajectories have been introduced. The Real3D (CBCT) functionality has been tested and does not raise any new concerns of safety and effectiveness. A comparison to a legally marketed CBCT device was done and supports substantial equivalence.
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Image /page/6/Picture/0 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange. To the right of the words is a graphic of orange dots arranged in a circular pattern.
The device remains within the same classification regulation for the same technology as the predicate device with the addition of computed tomography. The system software design was completed in accordance with Siemens Quality Management System Design Controls. The scope of internationally recognized standards compliance remains the same.
- Summary of Technological Characteristics of the Subject Device as Compared with 9. the Predicate Device:
The software of the subject device was updated and new CBCT trajectories have been added.
Comparison of the Subject Device (Multitom Rax) to the PredicateDevice (Multitom Rax With True2scale Body Scan Option)
| Feature | Predicate device<br>Multitom Rax With<br>True2scale Body Scan Op-<br>tion | Subject device<br>Multitom Rax | Comment |
|----------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulation De- | Image-intensified fluoro- | Image-intensified fluoro- | Same |
| scription | scopic X-ray system | scopic X-ray system | |
| Regulation<br>Number | 892.1650 | 892.1650 | Same |
| Classification<br>Product Code | OWB | OWB | Same |
| Secondary<br>Product Code | JAA | JAA, JAK | New product<br>code for CBCT |
| Indications for<br>use | Multitom Rax is a device<br>intended to visualize ana-<br>tomical structures by con-<br>verting an X-ray pattern<br>into a visible image. The<br>system has medical appli-<br>cations ranging from gas-<br>trointestinal examinationsto<br>cranial, skeletal, thoracic<br>and lung exposures as well<br>asexaminations of the uro-<br>genital tract. The unit may<br>also be used in emergency<br>applications, lymphogra-<br>phy, endoscopy, myelog-<br>raphy, venography, ar-<br>thrography, interventional<br>radiology, digital angi-<br>ography, and digital sub-<br>traction angiography<br>(DSA). The system may be | Multitom Rax is a device<br>intended to visualize ana-<br>tomical structures by con-<br>verting an X-ray pattern<br>into a visible image. The<br>system has medical applica-<br>tions ranging from gastroin-<br>testinal examinationsto cra-<br>nial, skeletal, thoracic and<br>lung exposures as well as<br>examinations of the urogen-<br>ital tract. The unit may also<br>be used in emergency appli-<br>cations, lymphography, en-<br>doscopy, myelography, ve-<br>nography, arthrography, in-<br>terventional radiology, digi-<br>tal angiography, and digital<br>subtraction angiography<br>(DSA). The system may be<br>used on pediatric, adult, and | Real3D added to<br>Indications for<br>Use |
| | | | |
| | used on pediatric, adult,<br>and bariatric patients.<br><br>The True2scale Body Scan<br>functionality (i.e., slot-<br>scanning-based acquisition<br>and reconstruction tech-<br>nique) of the Multitom Rax<br>is intended to be used for<br>the generation of a geomet-<br>rically accurate (in scan-<br>ning direction) 2-D repre-<br>sentation of the spine, the<br>lower limbs or the full body<br>which may be used for the<br>assessment of body axes<br>and skeletal alignment. The<br>True2scale Body Scan is<br>not intended to be used for<br>interventional purposes.<br><br>Multitom Rax is not for<br>mammography examina-<br>tions. | bariatric patients.<br><br>The True2scale Body Scan<br>functionality (i.e., slot-<br>scanning-based acquisition<br>and reconstruction tech-<br>nique) of the Multitom Rax<br>is intended to be used for<br>the generation of a geomet-<br>rically accurate (in scan-<br>ning direction) 2-D repre-<br>sentation of the spine, the<br>lower limbs or the full body<br>which may be used for the<br>assessment of body axes<br>and skeletal alignment. The<br>True2scale Body Scan is<br>not intended to be used for<br>interventional purposes.<br><br>The Real3D functionality<br>(i.e., cone-beam CT acqui-<br>sition and reconstruction<br>technique) of the Multitom<br>Rax is intended to be used<br>for 3D bone imaging of the<br>head, the upper and lower<br>extremities as well as the<br>lumbar spine.<br><br>Real3D is not intended for<br>imaging of the torso of pa-<br>tients with a Body Mass In-<br>dex (BMI) exceeding 30<br>kg/m².<br><br>Multitom Rax is not for<br>mammography examina-<br>tions. | |
| Scan axis | Horizontal and Vertical | Horizontal and Vertical | Same |
| Mechanical<br>System design | Tube and detector both<br>move on rails with three<br>translational and two rota-<br>tional degrees of freedom.<br>They can move on defined<br>paths (trajectories) around<br>the patient to acquire the<br>projections. | Tube and detector both move<br>on rails with three transla-<br>tional and two rotational de-<br>grees of freedom. They can<br>move on defined paths (tra-<br>jectories) around the patient<br>to acquire the projections. | Same |
| | projections. | | |
| High voltage<br>generator | High frequency generator<br>65 or 80 kW | High frequency generator<br>65 or 80 kW | Same |
| X-Ray Tube | Max anode heat capacity<br>820 KHU<br>(Nominal) Focal size: 0.6 /<br>1.0 | Max anode heat capacity<br>820 KHU<br>(Nominal) Focal size: 0.6 /<br>1.0 | Same |
| Image detector | SSXI with Cesium Iodide<br>scintillator | SSXI with Cesium Iodide<br>scintillator | Same |
| Gray scale | 16 bit | 16 bit | Same |
| Patient<br>Support<br>Structure | Floor mounted patient ta-<br>ble for supine examina-<br>tions. Patient support de-<br>vice for standing patient. | Floor mounted patient table<br>for supine examinations.<br>Patient support device for<br>standing patient. | Same |
| Cone-beam CT<br>functionality | N/A | Trajectories for CBCT im-<br>age acquisition<br>allowing various Source-to-<br>Imager and Source-to-Iso-<br>center Distances parallel to<br>axis of rotation.<br>The X-ray beam is colli-<br>mated to a rectangular shape<br>matching the 43 cm x 43 cm<br>flat panel detector (with a<br>narrow unexposed margin).<br>For the high-resolution<br>mode, the beam size is lim-<br>ited to 21 cm x 21 cm.<br>Scans available for upper<br>and lower extremities, head,<br>and lumbar spine.<br>Filtered backprojection-<br>based reconstruction for<br>CBCT, which accounts for<br>the acquisition geometry.<br>Metal Artifact Reduction for<br>CBCT | Added support<br>for CBCT func-<br>tionality |
| Feature | CurveBeam LineUp | Multitom Rax Real3D | Comment |
| kVp | 100 - 120 | 60 - 130 | Better for Multitom Rax Real3D |
| Voxel size | 0.3 mm | 0.2 mm - 0.5 mm (depending on chosen reconstruction kernel) | Better for Multitom Rax Real3D |
| Slice spacing | 0.3 mm | 0.2 mm - 0.5 mm (depending on chosen reconstruction kernel | Better for Multitom Rax Real3D |
| FOV (diameter, height) | Regular:<br>20 cm x 20 cm (d, h)<br>Extended:<br>35 cm x 20 cm (d, h) | Real 3D Hi-Res:<br>15 cm x 15 cm (d, h)<br>Real3D:<br>23 cm x 23 cm (d, h) | Extended FOV not available at Multitom Rax<br>Regular FOV is bigger for Multitom Rax Real3D |
| Scan time* | 23s or 26s | Real3D Hi-Res: 14s<br>Real3D: 12s or 16s (depending on anatomy) | Better for Multitom Rax Real3D and Real3D Hi-Res<br>*Scan time is defined as the duration in which the exposure alarm (buzzer) is ON and X-ray ON light is illuminated |
| High-contrast resolution (10% MTF) | 12 lp/cm | Real 3D Hi-Res:<br>up to 25 lp/cm (very sharp kernel)<br>Real 3D:<br>up to 15 lp/cm (sharp kernel) | Better for Multitom Rax Real3D |
| Low-contrast detectability | n/a | 20 HU @ 4 mm (smooth kernel)<br>10 HU @ 8 mm (smooth kernel) | Not reported for CurveBeam LineUp.<br>Also, the intended use of Real3D is high-contrast bone imaging, therefore the low-contrast detectability is not of as high importance as it would be for hemorrhage detection |
| Slice Sensitivity Profile / z-axis point spread function | The LineUP has a fixed and rigid patient positioning platform that does not incorporate any table motion or indexing (no "table pitch"). The detector panel has a square shape, while the pixels on the panels are square shaped as well. The raw projections are acquired in a single 360° orbit, thus covering the entire Field of View (FOV) height in one rotation. This results in isotropic voxels in the reconstructed volume, hence the same spatial resolution in the z-axis as in the x-y plane. Due to this projection geometry, calculation of a separate z-axis point spread function should not be applicable. | $0.42 \text{ mm } \pm 0.1 \text{ mm}$ (Real3D)<br>$0.31 \text{ mm } \pm 0.1 \text{ mm}$ (Real 3D Hi-Res) | Not reported for CurveBeam LineUp.<br>Isotropic resolution for Multitom Rax Real3D. |
| Image noise | n/a | Smooth: $20 \pm 15 \text{ HU}$<br>Medium: $60 \pm 40 \text{ HU}$<br>Sharp: $100 \pm 60 \text{ HU}$<br>Very sharp: $300 \pm 150 \text{ HU}$ | Not reported for CurveBeam LineUp.<br>Also, as noise depends on both, radiation dose and the imaged object and the used post-processing (reconstruction kernel), a direct comparison of two devices is mostly not feasible. |
| Uniformity (in-plane) | < 100 HU | < 150 HU | Better for CurveBeam LineUp<br>Justification: Intended use of Real3D is high-contrast bone imaging, therefore the in-plane uniformity should at least allow to apply standard viewing windowing functions (typical bone windows are, for instance, 2000 HU / 300 HU (W/C) or 1500 HU/ 450HU (W/C)), which is fulfilled for the CBCT functionality |
| | |…
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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.