K232462 · Usa Therm, Inc. · LHQ · Sep 14, 2023 · Obstetrics/Gynecology
Device Facts
Record ID
K232462
Device Name
ThermPix Thermovisual Camera
Applicant
Usa Therm, Inc.
Product Code
LHQ · Obstetrics/Gynecology
Decision Date
Sep 14, 2023
Decision
SESE
Submission Type
Special
Regulation
21 CFR 884.2980
Device Class
Class 1
Indications for Use
The ThermPix Thermovisual Camera is intended to view, measure, and record heat patterns and variations. It is intended for use as adjunctive diagnostic imaging for thermally significant indications stemming from heat emitted from the human body. The significance of these thermal patterns and variations is determined by professional investigation. This device is intended for use by qualified technical personnel. Clinical judgement and experience are required to review and interpret the information transmitted. The ThermPix Thermovisual Camera is only for use in addition to other diagnostic medical devices. It does not provide any absolute measurement of temperature and should not be used for sole screening or diagnosis for any disease or condition. The system is not intended to be used as a thermometry device.
Device Story
Telethermographic system; captures passive infrared emission via uncooled VOx microbolometer; consists of infrared camera, tablet, and molded case. Input: thermal radiation from human body. Processing: proprietary software converts infrared data into temperature distribution images. Output: thermal images displayed on tablet; data uploaded to secure cloud repository for clinician review. Used in hospitals, clinics, and healthcare settings by qualified technical personnel. Output serves as adjunctive diagnostic information; clinicians use images to identify thermal patterns requiring further investigation. Benefits: provides non-contact, non-invasive visualization of thermal variations to support clinical decision-making.
Clinical Evidence
Bench testing only. Validation performed using 2 cameras across 20°C-40°C range. Results confirmed 1°C temperature differences are discernible by trained users with 99% confidence. Accuracy verified at +/- 0.68°C (95% CI) and +/- 1.02°C (99% CI) with bias within +/- 0.1°C.
Indicated for adjunctive diagnostic imaging of heat patterns/variations emitted from the human body in adult patients. Intended for use by qualified technical personnel in clinical environments. Not for sole screening or diagnosis; not a thermometry device.
Regulatory Classification
Identification
A telethermographic system for adjunctive diagnostic screening for detection of breast cancer or other uses is an electrically powered device with a detector that is intended to measure, without touching the patient's skin, the self-emanating infrared radiation that reveals the temperature variations of the surface of the body. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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September 14, 2023
Image /page/0/Picture/1 description: The image shows the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration. The Department of Health & Human Services logo is on the left and features a stylized human figure. The FDA logo is on the right and features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
USA Therm, Inc. % Mary Vater 510(k) Consultant Medical Device Academy 345 Lincoln Hill Rd. SHREWSBURY VT 05387
Re: K232462
Trade/Device Name: ThermPix Thermovisual Camera Regulation Number: 21 CFR 884.2980 Regulation Name: Telethermographic system Regulatory Class: Class II Product Code: LHQ Dated: August 14, 2023 Received: August 15, 2023
Dear Mary Vater:
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
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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 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 (OS) 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,
# Yanna S. Kang -S
Yanna Kang Assistant Director Mammography and Ultrasound Team 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
Enclosure
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# Indications for Use
Submission Number (if known)
K232462
Device Name
ThermPix Thermovisual Camera
### Indications for Use (Describe)
The ThermPix Thermovisual Camera is intended to view, measure, and record heat patterns and variations. It is intended for use as adjunctive diagnostic imaging for thermally significant indications stemming from heat emitted from the human body. The significance of these thermal patterns and variations is determined by professional investigation. This device is intended for use by qualified technical personnel. Clinical judgement and experience are required to review and interpret the information transmitted.
The ThermPix Thermovisual Camera is only for use in addition to other diagnostic medical devices. It does not provide any absolute measurement of temperature and should not be used for sole screening or diagnosis for any disease or condition.
The system is not intended to be used as a thermometry device.
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 K232462
This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of 21 CFR §807.92:
#### . SUBMITTER
USA Therm, Inc. 3100 Ray Ferrero Jr. Blvd, 5th Floor Fort Lauderdale FL 33314 United States Tel: +1.844.998.4376 Contact Person: Mr. Eric Heil Date Prepared: August 15, 2023
#### II. DEVICE
| Device Trade Name: | ThermPix Thermovisual Camera |
|------------------------------|------------------------------|
| Classification Name: | Telethermographic System |
| Regulation: | 21 CFR §884.2980 |
| Regulatory Class: | Class II |
| Device Panel: | Radiology |
| Product Classification Code: | LHQ |
#### PREDICATE DEVICE =
Predicate Manufacturer: USA Therm, Inc. Predicate Trade Name: ThermPix Thermovisual Camera Predicate 510(k): K213650
No reference devices were used in this submission.
#### DEVICE DESCRIPTION IV.
The ThermPix Thermovisual Camera is a Telethermographic system which consists of an infrared camera embedded in a Tablet case and a Commercial Off the Shelf Tablet (WIFF only). It is a non-contact, non-invasive, and non-radiating infrared system capable of imaging and storing thermal patterns generated by the human body. These images along with other patientspecific data are uploaded via WIFI to the ThermPix Cloud, a secure repository where clinicians can access and augment data from a 3rd party device or computer.
It employs passive infrared emission sensing technology to capture the thermal data and uses proprietary software to display the temperature distribution pattern as an image. It is suitable for imaging adult human targets and can be used in hospitals, acute and sub-acute healthcare settings, clinics, and any environment where healthcare is provided by a healthcare professional.
#### > INDICATIONS FOR USE
The ThermPix Thermovisual Camera is intended to view, measure, and record heat patterns and variations. It is intended for use as adjunctive diagnostic imaging for thermally significant indications stemming from heat emitted from the human body. The significance of these thermal patterns and variations is determined by professional investigation. This device is intended for
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use by qualified technical personnel. Clinical judgement and experience are required to review and interpret the information transmitted.
The ThermPix Thermovisual Camera is only for use in addition to other diagnostic medical devices. It does not provide any absolute measurement of temperature and should not be used for sole screening or diagnosis for any disease or condition.
The system is not intended to be used as a thermometry device.
#### COMPARISON WITH PREDICATE VI.
| | Predicate Device: | Subject Device: | Comments on<br>Substantial<br>Equivalence |
|------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | ThermPix Thermovisual<br>Camera | ThermPix Thermovisual<br>Camera | |
| Indications for Use | The ThermPix<br>Thermovisual Camera is<br>intended to view, measure,<br>and record heat patterns<br>and variations. It is<br>intended for use as<br>adjunctive diagnostic<br>imaging for thermally<br>significant indications<br>stemming from heat<br>emitted from the human<br>body. The significance of<br>these thermal patterns and<br>variations is determined by<br>professional investigation.<br>This device is intended for<br>use by qualified technical<br>personnel. Clinical<br>judgement and experience<br>are required to review and<br>interpret the information<br>transmitted.<br><br>The ThermPix<br>Thermovisual Camera<br>is only for use in addition<br>to other diagnostic medical<br>devices. It does not provide<br>any absolute measurement<br>of temperature and should<br>not be used for sole<br>screening or diagnosis for<br>any disease or condition. | The ThermPix<br>Thermovisual Camera is<br>intended to view, measure,<br>and record heat patterns and<br>variations. It is intended for<br>use as adjunctive diagnostic<br>imaging for thermally<br>significant indications<br>stemming from heat<br>emitted from the human<br>body. The significance of<br>these thermal patterns and<br>variations is determined by<br>professional investigation.<br>This device is intended for<br>use by qualified technical<br>personnel. Clinical<br>judgement and experience<br>are required to review and<br>interpret the information<br>transmitted.<br><br>The ThermPix<br>Thermovisual Camera<br>is only for use in addition to<br>other diagnostic medical<br>devices. It does not provide<br>any absolute measurement<br>of temperature and should<br>not be used for sole<br>screening or diagnosis for<br>any disease or condition. | Identical |
| | The system is not intended<br>to be used as a<br>thermometry device. | The system is not intended<br>to be used as a thermometry<br>device. | |
| Intended User | Healthcare Professionals | Healthcare Professionals | Identical |
| Environment of Use | Clinical Environment | Clinical Environment | Identical |
| Device Components | Camera Swivel Drum Micro SD Card Infrared Camera Visual Camera Touch Screen and Screen<br>Driver Computing PCB Lithium Polymer Battery Anti-Bacterial Case | Commercial Off the<br>Shelf Tablet (WIFI<br>Only). Testing to be<br>performed on<br>Samsung Galaxy S6<br>Lite WIFI Only<br>(Model SM-<br>P610NZAAXAR) SEEK Infrared<br>camera Molded Tablet case USB C Hub Pen Stylus | The device<br>components are<br>the key differences<br>between device<br>generations.<br>The changes to<br>design do not<br>impact the<br>device's<br>performance<br>capabilities or the<br>user's interactions<br>with the device. |
| Imaging | | | |
| Detector Type | Uncooled VOx<br>microbolometer | Uncooled VOx<br>microbolometer | Identical |
| Pixel Pitch | 12 μm | 12 μm | Identical |
| Spectral Range | Longwave infrared; 7.8 µm<br>to 14 μm | Longwave infrared; 7.8 µm<br>to 14 μm | Identical |
| Frame Rate | 9 Hz and 27 Hz | 9 Hz | Substantially<br>Equivalent |
| Thermal Sensitivity | 65 mK (typical) | 65 mK (typical) | Identical |
| Accuracy | +/- 1°C (for temperature<br>difference) | +/- 1°C (for temperature<br>difference) | Identical |
| Optics | | | |
| Array Format | 320 x 240 with 56° (H) and<br>42° (V) field of view | 320 x 240 with 56° (H) and<br>42° (V) field of view | Identical |
| Electrical | | | |
| Video Channels | USB-2 | USB-2 | Identical |
| Control Channels | USB | USB | Identical |
| Input Voltage | 3.3 VDC to 5 VDC (5V<br>used) | 5VDC | Results in no<br>practical<br>performance<br>difference |
| Environmental | | | |
| Operating<br>Temperature Range | -10°C to +60°C (15°C to<br>24°C recommended for<br>best results) | -10°C to +60°C (15°C to<br>24°C recommended for best<br>results) | Identical |
| Non-Operating<br>Temperature Range | -40°C to 60°C | --40°C to 60°C | |
| Performance Testing | | | |
| Temperature<br>Difference Accuracy | The ThermPix<br>Thermovisual Camera<br>temperature difference | The subject device was<br>validated using identical<br>methods. | Identical |
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| accuracy was calculated | |
|-------------------------------|--|
| and verified to be +/- | |
| 0.68°C at 95% confidence | |
| (1.02°C at 99%) with a | |
| measurement bias within | |
| +/-0.1 °C. To determine | |
| these values, data was | |
| collected over multiple | |
| cameras, multiple users, | |
| and multiple temperatures | |
| ranging from 20-40 ℃. A | |
| traceable certified reference | |
| black body calibrator and | |
| thermocouples were | |
| employed in order to | |
| establish the temperature | |
| difference accuracy and | |
| bias, and a Gage | |
| Repeatability & | |
| Reproducibility was run to | |
| assess the variation of the | |
| measurement system. The | |
| root sum of squares method | |
| was employed to compute | |
| the overall uncertainty of | |
| the system at the given | |
| confidence interval. | |
# VII. PERFORMANCE DATA
The following performance data were provided in support of the substantial equivalence determination.
# Electrical safety and electromagnetic compatibility (EMC)
The subject device passed equivalent electrical safety and EMC testing in accordance with:
- । IEC 60601-1-2 Edition 4.1 2020-09 CONSOLIDATED VERSION General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
- -IEC 60601-1 Edition 3.2 2020-08 CONSOLIDATED VERSION Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and Essential Performance IEC 60601-1-6 Edition 3.2 2020-07 CONSOLIDATED VERSION
### Software Verification and Validation Testing
Software verification and validation according to IEC 62304 Edition 1.1 2015-06 Medical device software - Software life cycle processes and FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices
### Performance Validation Testing
The subject device was validated using identical methods to the predicate device. The ability of
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the ThermPix Thermovisual System to enable users to distinguish temperature differences of 1°C with a thermal image was tested using image data collected from 2 cameras at temperatures ranging from 20°C to 40°C in increments of 2°C. Results indicate that with 99% confidence temperature differences in 1 °C or more are discernible by a trained user. The results indicate that the device performance is comparable to that of the proposed 510(k) predicate device.
### VIII. CONCLUSIONS
Based on the technological characteristics and non-clinical testing, it is the conclusion of USA Therm, Inc. that the ThermPix Thermovisual Camera is substantially equivalent to the predicate device and raises no new issues of safety.
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.