K162487 · Bontech, Inc. · MQB · Oct 14, 2016 · Radiology
Device Facts
Record ID
K162487
Device Name
BSD3543 Digital Flat Panel X-ray Detector
Applicant
Bontech, Inc.
Product Code
MQB · Radiology
Decision Date
Oct 14, 2016
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.1680
Device Class
Class 2
Indications for Use
The BSD3543(BT-DA22-IA) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all general-purpose diagnostic procedures. It is not to be used for mammography.
Device Story
The BSD3543 is a digital X-ray flat panel detector that intercepts X-ray photons; a scintillator (Gadolinium Oxysulfide or Cesium Iodide) converts these into visible light, which is then captured by an amorphous silicon (a-Si) TFT array to generate electrical signals. These signals are converted to digital values and transmitted to an integrated PC and X-ray generator system. The device is used in clinical settings by healthcare professionals to digitize X-ray images for diagnostic review, information management, and network sharing. By replacing traditional film/screen systems, it enables efficient digital radiography, potentially improving diagnostic workflows and image management. The system produces raw image data, which is processed by viewing software for clinical interpretation.
Clinical Evidence
No clinical data. Substantial equivalence was established through bench testing, including electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), and performance metrics (MTF and DQE) comparing the subject device to the predicate.
Technological Characteristics
Digital flat panel detector using amorphous silicon (a-Si) TFT array. Scintillator options: Gadolinium Oxysulfide (Gdos) or Cesium Iodide (CsI). Imaging area: 14 x 17 inches. Pixel pitch: 140 μm. Resolution: 3.5 lp/mm. A/D conversion: 16-bit. Connectivity: Networked via PC/generator integration. Power: 100-240V AC/DC or battery. Standards: IEC 60601-1, IEC 60601-1-2, AAMI ANSI ES60601-1.
Indications for Use
Indicated for digital radiographic imaging of human anatomy in general-purpose diagnostic procedures. Not for use in mammography.
Regulatory Classification
Identification
A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
Predicate Devices
BSD4343 Digital Flat Panel X-ray Detector (K160204)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 14, 2016
Bontech Inc. % Mr. Dave Kim Medical Device Regulatory Affairs Mtech Group 8310 Buffalo Speedway HOUSTON TX 77025
Re: K162487
Trade/Device Name: BSD3543 Digital Flat Panel X-ray Detector Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: MQB Dated: September 2, 2016 Received: September 7, 2016
Dear Mr. Kim:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Michael D.'Hara
For
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K162487
Device Name BSD3543 Digital Flat Panel X-ray Detector
### Indications for Use (Describe)
The BSD3543(BT-DA22-IA) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all generalpurpose diagnostic procedures. It is not to be used for mammography.
| 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> □ Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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# 510(k) Summary
This summary of 510(k) information is being submitted in accordance with requirements of 21 CFR Part 807.92.
Date of Submission
September 2, 2016
#### SUBMITTER I.
| Submitter's Name | BONTECH Inc. |
|------------------------|---------------------------------------------------------------------------------------------------------------|
| Submitter's Address | Youngtong-gu Youngtong-dong 980-3,<br>Digital Empire D #1201,<br>Suwon city, Gyeonggi-do, South Korea 443-702 |
| Submitter's Telephone | +82 (31) 303-5254 |
| Contact person | Mr. Kwang S. Choi / RA Manager |
| Official Correspondent | Dave Kim (davekim@mtech-inc.net) |
| Address | 8310 Buffalo Speedway, Houston, TX 77025 |
| Telephone | +713-467-2607 |
| Fax: | +713-583-8988 |
#### II. DEVICE
| Trade/proprietary Name | BSD3543<br>Digital Flat Panel X-ray Detector |
|------------------------|------------------------------------------------------|
| Model No. | BT-DA22-IA / BT-DB22-IA |
| Common or Usual Name | Solid State X-ray Imager (Flat Panel/Digital Imager) |
| Regulation Name | Stationary X-ray System |
| Regulation Number | 21 CFR 892.1680 |
| Product Code | MQB |
| Regulatory Class | Class II |
| Over the Counter Use | |
#### III. PREDICATE DEVICE
| Primary Manufacturer | BONTECH Inc. |
|----------------------|-------------------------------------|
| Device Name | BSD3543 |
| | Digital Flat Panel X-ray Detector |
| 510(k) Number | K160204 |
| Regulation Name | Stationary X-ray System |
| Regulation Number | 21 CFR 892.1680 (Product Code: MQB) |
| Regulatory Class | Class II |
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#### IV. DEVICE DESCRIPTION
BSD3543(BT-DA22-IA/BT-DB22-IA) is a digital X-ray flat panel detector which intercepts x-ray photons and the scintillator (BT-DB22-IA(Gdos) / BT-DA22-IA(CsI)) emits visible spectrum photons that illuminate an array of photo (a-SI)-detector that creates electrical signals. After the electrical signals are generated, it is converted to digital values, and the images will be displayed on the monitor. This device should be integrated with an operating PC and an X-Ray generator. It can digitalize x-ray images and transfer them for radiography diagnostics. Advanced digital image processing allows considerably efficient diagnosis, all kinds of information management, and sharing of image information on network.
#### INDICATIONS FOR USE: V.
The BSD3543(BT-DA22-IA/BT-DB22-IA) detector is indicated for digital imaging solution designed for general radiographic system for human anatomy. It is intended to replace film or screen based radiographic system in all general-purpose diagnostic procedures. It is not to be used for mammography.
| Characteristic<br>510(k) number | Proposed<br>BONTECH<br>BSD3543<br>(BT-DA22-IA/BT-DB22-IA)<br>-K162487 | Predicate<br>BONTECH<br>BSD4343<br>K160204 | Remark |
|---------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|
| Indications<br>for Use | The BSD3543(BT-DA22-IA/BT-DB22-IA) detector is indicated for<br>digital imaging solution designed for<br>general radiographic system for<br>human anatomy. It is intended to<br>replace film or screen based<br>radiographic system in all general-<br>purpose diagnostic procedures. It is<br>not to be used for mammography. | The BSD4343 detector is<br>indicated for digital imaging<br>solution designed for general<br>radiographic system for<br>human anatomy. It is intended<br>to replace film or screen<br>based radiographic system in<br>all general-purpose diagnostic<br>procedures. It is not to be<br>used for mammography. | Same |
| Detector Type | Amorphous Silicon, TFT | Amorphous Silicon, TFT | Same |
#### VI. PREDICATE COMPARISON
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| Scintillator | BT-DB22-IA(Gdos) / BT-DA22-IA(CsI) | Gadolinium Oxysulfide (Gdos) | Similar | |
|--------------------------|---------------------------------------------------------------------|---------------------------------------------------------------------|--------------------|---------|
| Imaging Area | 14 x 17 inches | 17 x 17 inches | Similar | |
| Pixel matrix | 2500 x 3052 | 3072 x 3072 | Similar | |
| Pixel pitch | 140 μm | 140 μm | Same | |
| Resolution | 3.5 lp/mm | 3.5 lp/mm | Same | |
| A/D conversion | 16 bit | 16 bit | Same | |
| Grayscale | 65,536 (16bit) | 16384 (14bit) | Similar | |
| Data output | RAW<br>*The RAW files are convertible into DICOM 3.0 by console S/W | RAW<br>*The RAW files are convertible into DICOM 3.0 by console S/W | Same | |
| Viewing SW | Raw Image Viewer | Raw Image Viewer | Same | |
| Dimensions | 384 x 460 x 15 mm | 460 x 460 x 15 mm | Similar | |
| MTF (Spatial Resolution) | GDOS | CsI | GDOS | |
| | % @1 lp.mm<br>58.7 | % @1 lp.mm<br>60 | % @1 lp.mm<br>52.3 | |
| | % @2 lp.mm<br>27.2 | % @2 lp.mm<br>28.1 | % @2 lp.mm<br>23 | |
| % @3.5 lp.mm<br>11.2 | % @3.5 lp.mm<br>12.4 | % @3.5 lp.mm<br>10 | | |
| DQE | GDOS | CsI | GDOS | Similar |
| | % @0 lp.mm<br>37.9 | % @0 .lp.mm<br>70 | % @0 lp.mm<br>39.1 | |
| | % @ 1 lp.mm<br>29.7 | % @ 1 lp.mm<br>59.4 | % @1 lp.mm<br>24.7 | |
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| | % @2 lp.mm | 22.4 | % @2 lp.mm | 51.4 | % @2 lp.mm | 16.3 | |
|--------------|-------------------------------------------------------------------------------------|------|-----------------|-------------------------------------------------------------------------------------|--------------|------|---------|
| | % @3.5 lp.mm | 10.8 | % @3.5 lp.mm | 28 | % @3.5 lp.mm | 10 | |
| Power Supply | Input: 100~240 V, 50/60 Hz, Output:<br>12 V, 6 A | | | Input: 100~240 V, 50/60 Hz,<br>Output: 12 V, 6 A | | | Same |
| Application | General Radiology system<br>Available with upright stand, table,<br>universal stand | | | General Radiology system<br>Available with upright stand,<br>table, universal stand | | | Same |
| picture | Image: detector with cable | | Image: detector | | | | Similar |
When compared to the predicate device (K160204), the BSD3543(BT-DA22-IA/BT-DB22-IA) presented in this submission has the same characteristics in the following:
- Intended Use
- Pixel pitch
- · Resolution
- · Operating principle
- · Basic design
- · Viewing software
The imaging area and pixel matrix of BSD3543(BT-DA22-IA/BT-DB22-IA) and the predicate device are different but they would not adversely affect the use of the product. Both devices are substantially equivalent in basic design, function, operational principles and intended use.
#### SUMMARY OF NON-CLINICAL TESTS VII.
The bench testing performed to compare the subject devices to the predicate followed FDA's guidance document: "Guidance for the Submission of 510(k)s for Solid State Xray Imaging Devices."
To minimize electrical and mechanical hazards, BONTECH adheres to recognized and established industry practice, and all equipment complies with the relevant FDA and international standards. For example, electrical, mechanical, environmental safety and
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performance testing according to standard EN60601-1:2006+A1:2013 or IEC60601-1:2005 3.0 was performed and EMC testing was conducted in accordance with standard IEC 60601-1-2: 2007, EN 60601-1-2:2007
Through verification and validation activities, engineering testing and standards compliance testing were successfully conducted and did not raise any new safety questions or concerns or identify new risks.
The instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner :
Electrical Safety:
Testing was conducted in accordance with AAMI ANSI ES60601-1:2005/(R)2012 and A1:2012. Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD)
## Electromagnetic Compatibility:
Testing was conducted in accordance with IEC 60601-1-2:2007 Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility - Requirements And Tests
## Software:
The viewing software for the subject device is identical to the predicate device. Software verification and validation testing as recommended in FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." (May 11, 2005)
Performance testing was conducted to show that the subject device performs as intended and equally or better than the performance of the predicate device.
The non-clinical performance testing constrains that the main physical values for comparison of X-ray devices like DQE and MTF are basically equivalent to the predicate device BSD4343 (K160204). The results show that BSD3543(BT-DA22-IA/BT-DB22-IA) offer similar or better resolution performance than BSD4343 at 0 ~ 3.5lp/mm spatial frequencies. Moreover, the ability of BSD3543(BT-DA22-IA/BT-DB22-IA) to utilize the input image signal are more efficient than BSD4343 at same patient exposure as shown in the detective quantum efficiency graph.
These tests were conducted under conditions of single and double pumping mode and for the varying power sources (e.g., AC/DC power vs. battery power).
The Detector is tested for the integration to a generator and viewing software as below. -Generator:
- > kV Range: 40~125kV, 1kV step (Optional 40~150kV)
- > mA Range: 10 to 500mA
- > Timer Range: 0.001 to 10 sec, 38 steps
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-Viewing Software: S/W name: Raw Image Viewer, Version: 1.1 ▷ Data format: raw
#### VIII. SUMMARY OF CLINICAL TESTS
Images reviewed were not necessary to establish substantial equivalence based on the modifications to the device as evidenced in the laboratory performance data to show that the subject device operates as the indicated.
#### IX. CONCLUSIONS
Based on the information above, BSD3543(BT-DA22-IA/BT-DB22-IA) digital flat panel detector is substantially equivalent to the predicate device.
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.