Retrospective clinical datasets were used to train and validate the 'Deep Resolve Boost' AI feature. The data included 26,473 2D slices acquired from 1.5T and 3T MRI scanners in clinical settings.
AI/ML; Deep Resolve Boost; Retrospective data; Clinical settings
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Deep Resolve Boost Training and Validation Dataset; Retrospective training and validation of AI algorithm; Follow-up/Duration: Not applicable
Broad range of body regions; clinical patients (individual counts not recorded); Sample Size: 26,473 2D slices; Number of Sites: Not specified (in-house and collaboration partners)
Not applicable for this study
Peak signal-to-noise ratio (PSNR), structural similarity index (SSIM), and visual inspection for artifacts
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Image noise reduction
Deep learning neural network
—
—
Training: 24,599 slices; Validation: 1,874 slices
—
—
—
Indications for Use
MAGNETOM Free.Max system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head. body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician vield information that may assist in diagnosis. MAGNETOM Free.Max may also be used for imaging during interventional procedures when performed with MR-compatible devices such as MR Safe biopsy needles. MAGNETOM Free.Star system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician yield information that may assist in diagnosis.
Device Story
Magnetic resonance diagnostic devices (MRDD) producing cross-sectional images of head, body, or extremities; utilizes magnetic resonance imaging (MRI) technology. Inputs include RF signals and gradient magnetic fields; processed via syngo MR XA60A software to generate diagnostic images. Used in clinical settings by trained physicians/technicians. New features include Contour Knee coil, respiratory sensor, and various software applications (e.g., Deep Resolve Boost, myExam RT Assist, interventional needle support). Output images assist in clinical diagnosis and interventional guidance. Benefits include improved image quality, workflow efficiency, and expanded interventional capabilities.
Clinical Evidence
No clinical tests conducted. Evidence consists of bench testing, software verification and validation, and sample clinical images. AI feature 'Deep Resolve Boost' validated using 26,473 2D slices (in-house/collaboration data) with metrics including PSNR and SSIM.
Technological Characteristics
MR diagnostic system; 1.5T/3T field strengths. Hardware includes magnet, RF body coil, gradient system, patient table, host computer, MaRS, Contour Knee coil, and respiratory sensor. Software: syngo MR XA60A. Conforms to IEC 60601-1, IEC 60601-2-33, IEC 62304, ISO 14971, and NEMA standards. Connectivity via DICOM.
Indications for Use
Indicated for patients requiring MR imaging of the head, body, or extremities to assist in diagnosis. MAGNETOM Free.Max is also indicated for imaging during interventional procedures using MR-compatible devices.
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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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Siemens Medical Solutions USA, Inc. Alina Goodman Regulatory Affairs Professional 40 Liberty Boulevard Malvern, Pennsylvania 19355
November 9, 2023
#### Re: K231617
Trade/Device Name: MAGNETOM Free.Max; MAGNETOM Free.Star Regulation Number: 21 CFR 892.1000 Regulation Name: Magnetic Resonance Diagnostic Device Regulatory Class: Class II Product Code: LNH, MOS Dated: September 11, 2023 Received: September 11, 2023
Dear Alina Goodman:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,
# Julie Sullivan -S
Julie Sullivan, Ph.D. Director DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
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#### Indications for Use
Submission Number (if known)
#### K231617
Device Name
MAGNETOM Free.Max; MAGNETOM Free.Star
Indications for Use (Describe)
MAGNETOM Free.Max:
MAGNETOM Free.Max system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head. body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician vield information that may assist in diagnosis.
MAGNETOM Free.Max may also be used for imaging during interventional procedures when performed with MR-compatible devices such as MR Safe biopsy needles.
MAGNETOM Free.Star:
MAGNETOM Free.Star system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician yield information that may assist in diagnosis.
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)
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# 510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of the Safe Medical Devices Act 1990 and 21 CFR క్త 807.92.
| 1. General Information | |
|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Establishment: | Siemens Medical Solutions USA, Inc.<br>40 Liberty Boulevard<br>Malvern, PA 19355, USA<br>Registration Number: 2240869 |
| Date Prepared: | May 31, 2023 |
| Manufacturer: | Siemens Shenzhen Magnetic Resonance<br>Ltd.<br>Siemens MRI Center, Gaoxin C. Ave., 2nd<br>Hi-Tech Industrial Park<br>518057 Shenzhen<br>PEOPLE'S REPUBLIC OF CHINA<br>Registration Number: 3004754211 |
| | Siemens Healthcare GmbH<br>Henkestrasse 127<br>91052 Erlangen<br>Germany<br>Registration Number: 3002808157 |
| 2. Contact Information | |
| | Alina Goodman<br>Regulatory Affairs Professional<br>Siemens Medical Solutions USA, Inc.<br>40 Liberty Boulevard<br>Malvern, PA 19355, USA<br>Phone: +1(224)526-1404<br>E-mail: alina.goodman@siemens-<br>healthineers.com |
| 3. Device Name and Classification | |
| Device/ Trade name: | MAGNETOM Free.Max<br>MAGNETOM Free.Star |
| Classification Name: | Magnetic Resonance Diagnostic Device<br>(MRDD) |
| Classification Panel: | Radiology |
| CFR Code: | 21 CFR § 892.1000 |
| Classification: | II |
| Product Code: | Primary: LNH<br>Secondary: MOS |
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#### 4. Legally Marketed Predicate Device
4.1 Predicate Device
Trade name: 510(k) Number: Classification Name:
Classification Panel: CFR Code: Classification: Product Code:
Trade name: 510(k) Number: Classification Name:
Classification Panel: CFR Code: Classification: Product Code:
4.2 Reference Device Trade name: 510(k) Number: Classification Name:
Classification Panel: CFR Code: Classification: Product Code:
Trade name: 510(k) Number: Classification Name:
Classification Panel: CFR Code: Classification: Product Code:
Trade name: 510(k) Number: Classification Name:
Classification Panel: CFR Code: Classification:
MAGNETOM Free.Max K220575 Magnetic Resonance Diagnostic Device (MRDD) Radiology 21 CFR § 892.1000 ll Primary: LNH Secondary: MOS
MAGNETOM Free.Star K220575 Magnetic Resonance Diagnostic Device (MRDD) Radiology 21 CFR § 892.1000 Primary: LNH Secondary: MOS
MAGNETOM Sola K221733 Magnetic Resonance Diagnostic Device (MRDD) Radiology 21 CFR § 892.1000 . Primary: LNH Secondary: LNI, MOS
MAGNETOM Amira K223343 Magnetic Resonance Diagnostic Device (MRDD) Radiology 21 CFR § 892.1000 ============================================================================================================================================================================== Primary: LNH Secondary: LNI, MOS
MAGNETOM Vida K213693 Magnetic Resonance Diagnostic Device (MRDD) Radiology 21 CFR § 892.1000
{5}------------------------------------------------
#### Product Code:
Primary: LNH Secondary: LNI, MOS
#### 5. Indications for Use
#### MAGNETOM Free.Max:
The indications for use for the subject device MAGNETOM Free.Max with syngo MR XA60A is extended to include MR imaging during interventional procedures compared to the predicate device MAGNETOM Free.Max with syngo MR XA50A:
MAGNETOM Free.Max system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head. body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician vield information that may assist in diagnosis.
MAGNETOM Free.Max may also be used for imaging during interventional procedures when performed with MR-compatible devices such as MR Safe biopsy needles.
#### MAGNETOM Free.Star:
The indications for use for the subject device MAGNETOM Free.Star with syngo MR XA60A is the same as the predicate device MAGNETOM Free.Star with syngo MR XA50A:
MAGNETOM Free.Star system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal, and oblique cross-sectional images that display the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images when interpreted by a trained physician vield information that may assist in diagnosis.
#### Indications for use modification rationale for MAGNETOM Free.Max:
The product features that support MR imaging during interventional procedures are released in subject device MAGNETOM Free.Max with syngo MR XA60A.
MR imaging during interventional procedures is already included in the reference device MAGNETOM Sola's indications for use and is 510(k) cleared (K221733, cleared on September 13, 2022).
This difference in indications for use does not alter the functionality in assisting diagnosis of the subject device as a magnetic resonance diagnostic device.
Therefore, this difference does not constitute a new intended use according to FDA Guidance "The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]".
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#### 6. Device Description
MAGNETOM Free.Max and MAGNETOM Free.Star with syngo MR XA60A include new and modified features compared to the predicate devices MAGNETOM Free.Max and MAGNETOM Free.Star with syngo MR XA50A (K220575, cleared on June 24, 2022).
Below is a high-level summary of the new and modified hardware and software features compared to the predicate devices MAGNETOM Free.Max and MAGNETOM Free.Star with syngo MR XA50A:
#### Hardware
New hardware features:
- Contour Knee coil -
- -Respiratory Sensor
Modified hardware features:
- myExam 3D Camera -
- -Host computer
- -MaRS
#### Software
New Features and Applications:
- -Injector coupling
- Respiratory Sensor Support -
- myExam RT Assist (only for MAGNETOM Free.Max) -
- myExam Autopilot Hip -
- -Deep Resolve Boost
- Complex Averaging -
- HASTE_Interactive (only for MAGNETOM Free.Max) -
- BEAT_Interactive (only for MAGNETOM Free.Max) -
- -Needle Intervention AddIn (only for MAGNETOM Free.Max)
Modified Features and Applications:
- Deep Resolve Sharp -
- Deep Resolve Gain -
- -SMS Averaging
#### Other Modifications:
- -Indications for Use (only for MAGNETOM Free.Max)
- MAGNETOM Free.Max RT Edition marketing bundle (only for MAGNETOM -Free.Max)
Below Table 1 shows an executive summary of training and validation dataset of Al feature Deep Resolve Boost in subject devices:
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| | Deep Resolve Boost |
|----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Sample size | 26,473 2D slices |
| | Note: due to reasons of data privacy, we did not record how many<br>individuals the datasets belong to. Gender, age and ethnicity distribution<br>was also not recorded during data collection. Due to the network<br>architecture, attributes like gender, age and ethnicity are not relevant to<br>the training data. |
| Sample source | in-house measurements and collaboration partners |
| Dataset slipt | Training: 24,599 slices |
| | Validation: 1,874 slices |
| | Note: Data split maintained similar data distribution (e.g. contrast,<br>orientation, field strength, ...) in both training and validation datasets. |
| Equipments | 1.5T and 3T MRI scanners [1] |
| Protocols | Representative protocols (T1, T2 and PD with and without<br>fat saturation) which have been altered (e.g. to increase<br>SNR, increase resolution or reduced acceleration). |
| Body regions | a broad range of different body regions |
| Clinical<br>subgroups | No clinical subgroups have been defined for the datasets. |
| Counfouders | The input and output variables of the network have been<br>derived from the same dataset so that no confounders exist<br>for the training methodology. |
| Test statistics<br>and test<br>results | The impact of the network has been characterized by several<br>quality metrics such as peak signal-to-noise ratio (PSNR) and<br>structural similarity index (SSIM). Additionally, images were<br>inspected visually to ensure that potential artefacts are detected<br>that are not well captured by the metrics listed above.<br>After successful passing of the quality metrics tests, work-in-<br>progress packages of the network were delivered and evaluated in<br>clinical settings with cooperation partners. |
| Reference<br>standard | The acquired datasets represent the ground truth for the training<br>and validation. Input data was retrospectively created from the<br>ground truth by data manipulation and augmentation. This process<br>includes further under-sampling of the data by discarding k-space<br>lines, lowering of the SNR level by addition of noise and mirroring<br>of k-space data. |
Table 1. Training and validation dataset of Al feature
[1] According to assessment, the network can be transferred to subject devices without the need of retraining with additional data sets.
# 7. Substantial Equivalence
MAGNETOM Free.Max and MAGNETOM Free.Star with software syngo MR XA60A are substantially equivalent to the predicate devices listed in Table 2:
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| Predicate Device | FDA Clearance Number<br>and Date | Product<br>Code | Manufacturer |
|-------------------------------------------|-------------------------------------------|---------------------|---------------------------------------------|
| MAGNETOM Free.Max<br>with syngo MR XA50A | K220575,<br>cleared on June 24, 2022 | LNH,<br>MOS | Siemens Shenzhen<br>Magnetic Resonance Ltd. |
| MAGNETOM Free.Star with<br>syngo MR XA50A | K220575,<br>cleared on June 24, 2022 | LNH,<br>MOS | Siemens Shenzhen<br>Magnetic Resonance Ltd. |
| Reference Device | FDA Clearance Number<br>and Date | Product<br>Code | Manufacturer |
| MAGNETOM Sola with<br>syngo MR XA51A | K221733, cleared on<br>September 13, 2022 | LNH,<br>LNI,<br>MOS | Siemens Healthcare GmbH |
| MAGNETOM Amira with<br>syngo MR XA50M | K223343, cleared on March<br>23, 2023 | LNH,<br>LNI,<br>MOS | Siemens Shenzhen<br>Magnetic Resonance Ltd. |
| MAGNETOM Vida with<br>syngo MR XA50A | K213693, cleared on<br>Feburary 25, 2022 | LNH,<br>LNI,<br>MOS | Siemens Healthcare GmbH |
Table 2. Predicate devices and reference devices
#### 8. Technological Characteristics
The subject devices, MAGNETOM Free.Max and MAGNETOM Free.Star with software syngo MR XA60A, are substantially equivalent to the predicate devices with reqard to the operational environment, programming language, operating system and performance.
The subject devices conform to the standard for medical device software (IEC 62304) and other relevant IEC and NEMA standards.
There are some differences in technological characteristics between the subject devices and predicate devices, including new and modified hardware and software features, and extended indications for use for MAGNETOM Free.Max. These differences have been tested and the conclusion from the non-clinical data suggests that the features bear an equivalent safety and performance profile to that of the predicate devices.
Please see below Table 3 and Table 4 for the comparison between subject devices and predicate/ reference devices.
| | Subject Devices | | Predicate Devices | |
|---------------------------------------------|---------------------------------------------------------|----------------------------------------------------------|---------------------------------------------------------------------------------|----------------------------------------------------------------------------------|
| Hardware | MAGNETOM<br>Free.Max with<br>software syngo MR<br>XA60A | MAGNETOM<br>Free.Star with<br>software syngo MR<br>XA60A | MAGNETOM<br>Free.Max with<br>Error! Reference<br>source not found.<br>(K220575) | MAGNETOM<br>Free.Star with<br>Error! Reference<br>source not found.<br>(K220575) |
| Magnet<br>System | Yes, same as predicate device | | Yes | |
| RF System | Yes, same as predicate device | | Yes | |
| Transmission<br>technique -<br>RF Body Coil | Yes, same as predicate device | | Yes | |
| Gradient<br>System | Yes, same as predicate device | | Yes | |
Table 3. Hardware Comparison
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| Patient Table | Yes, same as predicate device | Yes |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------|-----|
| Computer | Yes, modified compared to predicate<br>device:<br>-new host computer hardware<br>-new MaRS hardware | Yes |
| Coils | Yes,<br>new coil compared to predicate device:<br>Contour Knee coil | Yes |
| Other HW<br>components | Yes,<br>Modified compared to predicate device:<br>-myExam 3D Camera<br>New compared to predicate device:<br>-Respiratory Sensor | Yes |
# Table 4. Software Features Comparison
| | Subject Devices | | Predicate Devices | |
|-------------------------------|------------------------------------------------------------------------------------------------------------|----------------------------------------------------------|----------------------------------------------------------------------|-----------------------------------------------------------|
| Software | MAGNETOM<br>Free.Max with<br>software syngo MR<br>XA60A | MAGNETOM<br>Free.Star with<br>software syngo<br>MR XA60A | MAGNETOM<br>Free.Max with<br>software syngo<br>MR XA50A<br>(K220575) | MAGNETOM<br>Free.Star with<br>syngo MR XA50A<br>(K220575) |
| Injector coupling | Yes,<br>new feature migrated from reference device<br>MAGNETOM Sola with syngo MR XA51A<br>(K221733) | | No | |
| Respiratory Sensor<br>Support | Yes,<br>new feature migrated from reference device<br>MAGNETOM Amira with syngo MR XA50M<br>(K223343) | | No | |
| myExam RT Assist | Yes,<br>new feature migrated<br>from reference device<br>MAGNETOM Sola with<br>syngo MR XA51A<br>(K221733) | No | No | |
| myExam AutoPilot<br>Hip | Yes, new feature | | No | |
| Deep Resolve<br>Boost | Yes,<br>new feature migrated from reference device<br>MAGNETOM Vida with syngo MR XA50A<br>(K213693) | | No | |
| Complex<br>Averaging | Yes, new feature | | No | |
| HASTE_Interactive | Yes,<br>new feature migrated<br>from reference device<br>MAGNETOM Sola with<br>syngo MR XA51A<br>(K221733) | No | No | |
| BEAT_Interactive | Yes,<br>new feature migrated<br>from reference device<br>MAGNETOM Sola with<br>syngo MR XA51A<br>(K221733) | No | No | |
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| Needle<br>Intervention AddIn | Yes, new feature migrated<br>from reference device<br>MAGNETOM Sola with<br>syngo MR XA51A<br>(K221733) | No | No |
|------------------------------|---------------------------------------------------------------------------------------------------------|----|-----|
| Deep Resolve<br>Sharp | Yes, modified compared to predicate<br>device | | Yes |
| Deep Resolve<br>Gain | Yes, modified compared to predicate<br>device | | Yes |
| SMS Averaging | Yes, modified compared to predicate<br>device | | Yes |
# 9. Nonclinical Tests
The following performance testing was conducted on the subject devices.
| Performance Test | Tested Hardware or Software | Source/Rationale for test |
|--------------------------------------|----------------------------------------------------------|----------------------------------------------------------------------------------------------|
| Sample clinical images | New and modified software features, pulse sequence types | Guidance for Submission of Premarket Notifications for Magnetic Resonance Diagnostic Devices |
| Software verification and validation | New and modified software features | Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices |
The results from each set of tests demonstrate that the devices perform as intended and are thus substantially equivalent to the predicate device to which it has been compared.
# 10.Clinical Tests / Publications
No clinical tests were conducted to support substantial equivalence for the subject device; however, as stated above, sample clinical images were provided.
# 11.Safety and Effectiveness
The device labeling contains instructions for use and any necessary cautions and warnings to ensure safe and effective use of the device.
Risk Manaqement is ensured via a risk analysis in compliance with ISO 14971, to identify and provide mitigation of potential hazards early in the design cycle and continuously throughout the development of the product. Siemens adheres to recognized and established industry standards, such as the IEC 60601-1 series, to minimize electrical and mechanical hazards. Furthermore, the devices are intended for healthcare professionals familiar with and responsible for the acquisition and post processing of magnetic resonance images.
MAGNETOM Free.Max and MAGNETOM Free.Star with software syngo MR XA60A conform to the following FDA recognized and international IEC, ISO and NEMA standards:
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| Recognition<br>Number | Product<br>Area | Title of Standard | Reference<br>Number and date | Standards<br>Development<br>Organization |
|-----------------------|----------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|------------------------------------------|
| 19-4 | General II<br>(ES/<br>EMC) | C1:2009/(R)2012 and<br>A2:2010/(R)2012 (Consolidated<br>Text) Medical electrical<br>equipment - Part 1: General<br>requirements for basic safety<br>and essential performance (IEC<br>60601-1:2005, MOD) | ES60601-<br>1:2005/(R)2012<br>and A1:2012 | ANSI AAMI |
| 19-36 | General | Medical electrical equipment -<br>Part 1-2: General requirements<br>for basic safety and essential<br>performance - Collateral<br>Standard: Electromagnetic<br>disturbances - Requirements<br>and tests | 60601-1-2:2014 +<br>AMD1:2020 | IEC |
| 12-295 | Radiology | Medical electrical equipment -<br>Part 2-33: Particular<br>requirements for the basic<br>safety and essential<br>performance of magnetic<br>resonance equipment for<br>medical diagnosis | 60601-2-33 Ed. 3.2<br>b:2015 | IEC |
| 5-125 | General I<br>(QS/<br>RM) | Medical devices - Application of<br>risk management to medical<br>devices | 14971 Third Edition<br>2019-12 | ISO |
| 5-129 | General I<br>(QS/<br>RM) | Medical devices - Part 1:<br>Application of usability<br>engineering to medical devices | 62366-1: 2015 +<br>AMD1:2020 | ANSI AAMI<br>IEC |
| 13-79 | Software/<br>Informatics | Medical device software -<br>Software life cycle processes<br>[Including Amendment 1 (2016)] | IEC 62304:2006 +<br>AMD1:2015 | ANSI AAMI<br>IEC |
| 12-232 | Radiology | Acoustic Noise Measurement<br>Procedure for Diagnosing<br>Magnetic Resonance Imaging<br>Devices | MS 4-2010 | NEMA |
| 12-288 | Radiology | Standards Publication<br>Characterization of Phased<br>Array Coils for Diagnostic<br>Magnetic Resonance Images | MS 9-2008 (R2014) | NEMA |
| 12-342 | Radiology | Digital Imaging and<br>Communications in Medicine<br>(DICOM) Set 03/16/2012<br>Radiology | PS 3.1 - 3.20<br>(2021e) | NEMA |
| 2-258 | Biocompati<br>bility | biological evaluation of medical<br>devices - part 1: evaluation and<br>testing within a risk<br>management process<br>(Biocompatibility) | 10993-1:2018 | AAMI<br>ANSI<br>ISO |
# 12.Conclusion as to Substantial Equivalence
MAGNETOM Free.Max and MAGNETOM Free.Star with software syngo MR XA60A have the same basic technological characteristics as the predicate device systems, MAGNETOM Free.Max and MAGNETOM Free.Star with syngo MR XA50A (Cleared with K220575 on June 24, 2022), with respect to the magnetic resonance features and functionalities. While there are some differences in technical features compared to the predicate devices, the differences have been tested and the conclusions from
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all verification and validation data suggest that the features bear an equivalent safety and performance profile to that of the predicate devices and reference devices.
Siemens believes that MAGNETOM Free.Max and MAGNETOM Free.Star with software syngo MR XA60A are substantially equivalent to the currently marketed device MAGNETOM Free.Max and MAGNETOM Free.Star with syngo MR XA50A.
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.