K200917 · Philips Medical Systems Nederland B.V. · OWB · May 1, 2020 · Radiology
Device Facts
Record ID
K200917
Device Name
Azurion R2.1
Applicant
Philips Medical Systems Nederland B.V.
Product Code
OWB · Radiology
Decision Date
May 1, 2020
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.1650
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Azurion series (within the limits of the Operation Room table) are intended for use to perform · Image guidance in diagnostic, interventional and minimally invasive surgery procedures for the following clinical application areas: vascular, non-vascular, cardiovascular and neuro procedures. · Cardiac imaging applications including diagnostics, interventional and minimally invasive surgery procedures. Additionally: - · The Azurion series can be used in a hybrid Operation Room · The Azurion series contain a number of features to support a flexible and patient centric procedural workflow.
Device Story
Interventional fluoroscopic X-ray system; provides real-time visualization of patient anatomy during minimally invasive procedures. Inputs: X-ray signals captured via flat detectors (FD12, FD15, FD20). Processing: Image processing algorithms (optional ClarityIQ) assist visualization, post-processing, and storage of reference images. Output: Real-time fluoroscopic images displayed to clinicians. Used in ORs or hybrid ORs by physicians (interventional radiologists/cardiologists) and technicians. Supports flexible, patient-centric workflows. Benefits: Provides imaging information necessary for minimally invasive interventions; aids clinical decision-making through enhanced visualization and radiation safety controls.
Clinical Evidence
No clinical study data required. Substantial equivalence demonstrated via non-clinical performance testing, including software verification, usability validation in simulated environments with clinicians, and compliance with recognized consensus standards (IEC 62304, ISO 14971, IEC 60601-2-28, IEC 60601-2-43).
Indicated for image guidance in diagnostic, interventional, and minimally invasive surgery procedures (vascular, non-vascular, cardiovascular, neuro, and cardiac). Suitable for all human patients of all ages, subject to operating table weight limits.
Regulatory Classification
Identification
An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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Philips Medical Systems Nederland BV % Ms. Michelle Campbell Regulatory Affairs Specialist Veenpluis 4-6 Best. 5684PC NETHERLANDS
## Re: K200917
Trade/Device Name: Azurion R2.1 Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: Class II Product Code: OWB, JAA Dated: April 2, 2020 Received: April 6, 2020
Dear Ms. Campbell:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for
May 1, 2020
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
| 510(k) Number (if known) | |
|--------------------------|--|
|--------------------------|--|
K200917
Device Name Azurion R2.1
Indications for Use (Describe)
The Azurion series (within the limits of the Operation Room table) are intended for use to perform · Image guidance in diagnostic, interventional and minimally invasive surgery procedures for the following clinical application areas: vascular, non-vascular, cardiovascular and neuro procedures.
· Cardiac imaging applications including diagnostics, interventional and minimally invasive surgery procedures.
Additionally:
- · The Azurion series can be used in a hybrid Operation Room
· The Azurion series contain a number of features to support a flexible and patient centric procedural workflow.
## Patient Population
All human patients of all ages. Patient weight is limited to the specification of the patient table.
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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K200917
## 510(k) Summary
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR 807.92.
| Date Prepared: | April 2nd 2020 | |
|-------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|
| Manufacturer: | Philips Medical Systems Nederland B.V.<br>Veenpluis 4-6<br>5684 PC Best<br>The Netherlands<br>Establishment Registration Number: 3003768277 | |
| Primary Contact<br>Person: | Michelle Campbell<br>Regulatory Affairs Officer<br>Phone: +31 618345786<br>E-mail: michelle.campbell@philips.com | |
| Secondary Contact<br>Person: | Michael Konings<br>Director of Regulatory IGT Systems<br>Phone: +31 619864032<br>E-mail: michael.konings@philips.com | |
| Device: | Trade Name: | Azurion R2.1 |
| | Classification Name: | Image-intensified fluoroscopic x-ray system |
| | Classification Regulation: | 21 CFR, Part 892.1650 |
| | Classification Panel: | Radiology |
| | Device Class: | Class II |
| | Product Code: | Primary Code: OWB<br>Subsequent Code: JAA |
| Predicate Device: | Trade Name: | Azurion R1.2 |
| | Manufacturer: | Philips Medical Systems Nederland B.V. |
| | 510(k) Clearance: | K172822 (November 22, 2017) |
| | Classification Name: | Image-intensified fluoroscopic x-ray system |
| | Classification Regulation: | 21 CFR, Part 892.1650 |
| | Classification Panel: | Radiology |
| | Device Class: | Class II |
| | Product Code: | Primary Code: OWB<br>Subsequent Code: JAA |
| Secondary Predicate<br>Device | Trade Name: | Azurion R2.0 |
| | Manufacturer: | Philips Medical Systems Nederland B.V. |
| | 510(k) Clearance: | K181830 (August 02, 2018) |
| Classification Name: | Image-intensified fluoroscopic x-ray system | |
| Classification Regulation: | 21 CFR, Part 892.1650 | |
| Classification Panel: | Radiology | |
| Device Class: | Class II | |
| Product Code: | Primary Code: OWB<br>Subsequent Code: JAA | |
| Device description: | The Azurion R2.1 is classified as an interventional fluoroscopic X-ray system.<br>The primary performance characteristics of the Azurion R2.1 interventional<br>fluoroscopic X-ray system include:<br>Real-time image visualization of patient anatomy during procedures Imaging techniques and tools to assist interventional procedures Post processing functions after interventional procedures Storage of reference/control images for patient records Compatibility to images of other modalities via DICOM Built in radiation safety controls This array of functions offers the physician the imaging information needed to perform minimally invasive interventional procedures.<br>The Azurion R2.1 is available in comparable models and configurations as the currently marketed and predicate device Azurion R1.2.<br>Configurations are composed of detector type (monoplane and biplane), floor or ceiling mounted geometry, standard or OR table type and available image processing. The FlexArm option is available for the 7M20 configuration in Azurion R2.1 The monoplane (single C-arm) and biplane (dual arm) X-ray system configurations are differentiated by the following features: 12 inch Flat Detector (FD12) 15 inch Flat Detector (FD15) 20 inch Flat Detector (FD20) Additionally, identical to the predicate device, Azurion R2.1 can be used in a hybrid operating room when supplied with a compatible operating room table, and can be optionally equipped with the ClarityIQ image processing algorithms. | |
| Indications for Use: | The Azurion series (within the limits of the used Operating Room table) are intended for use to perform: Image guidance in diagnostic, interventional and minimally invasive surgery procedures for the following clinical application areas: vascular, non-vascular, cardiovascular and neuro procedures. Cardiac imaging applications including diagnostics, interventional and minimally invasive surgery procedures. Additionally: The Azurion series can be used in a hybrid Operating Room. | |
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# PHILIPS
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• The Azurion series contain a number of features to support a flexible and patient centric procedural workflow.
Patient Population:
All human patients of all ages. Patient weight is limited to the specification of the patient table.
Based on the information provided above, the Azurion R2.1 is considered substantially equivalent to the currently marketed and predicate device Azurion R1.2 in terms of Indications for Use.
Technological The Azurion R2.1 has similar technological characteristics compared to the characteristics: predicate device. The same hardware and software is used in the predicate and subject device, with exception of the following modifications implemented in the Azurion R2.1:
- Multi Modality Touch Screen Module which is an incremental development of the current Touch Screen Module
- Replacement of Windows 7 with Windows 10 OS ●
- An update of the graphics boards in all PCs
- . Introduction of the Pixium 2121S detector as an alternative 12" detector for monoplane systems
- Inclusion of an optical imaging system within the FD20 detector outer frame. This option will not be enabled until the relevant application becomes available.
- The next release of the Certeray generator (Certeray release 5)
- The next release of the Poly-G geometry (Poly-G3) ● Extension of the Nicol V4 collimator for the Poly-G3 geometry (already introduced by release R2.0 for FlexArm options)
- . Extension of the range with the introduction of additional Azurion 5 configurations
- . Field feedback and minor updates from earlier releases
The differences between the Azurion R2.1 and the predicate device do not raise any new questions regarding safety or effectiveness. Based on the information provided in this 510(k) submission. Azurion R2.1 is considered substantially equivalent to the currently marketed predicate Azurion R1.2 in terms of fundamental scientific technology.
Summary of Non-Non-clinical performance testing has been performed on the Azurion R2.1 and Clinical Performance demonstrates compliance with the following International and FDA-recognized Data: consensus standards and FDA guidance documents:
- . IEC 62304 Medical device software – Software life cycle processes (Edition 1.1, 2015-06). FDA/CDRH recognition number 13-79.
- ISO 14971 Medical devices – Application of risk management to medical devices (Edition 2.0, corrected version 2007-10-01). FDA/CDRH recognition number 5-40.
- . IEC 60601-2-28 - Particular requirements for the basic safety and essential performance of X-ray tube assemblies for medical diagnosis (Edition 3.0, 2017-06). FDA/CDRH recognition number 12-309.
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- . IEC 60601-2-43 - Particular requirements for the safety of X-Rav equipment for interventional procedures (Edition 2.0, 2010-03).
- . Guidance for Industry and FDA Staff - Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 11, 2005 (document number 337).
- "Guidance for Industry and FDA Staff – The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]", July 28, 2014 (document number 1766).
- Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices
Software verification testing of the functional and non-functional requirements as well as performance, reliability and safety has been performed to verify that all the requirements of System Requirements Specification as well as the safety risk control measures from the Detailed Risk Management Matrix and the Privacy and Security requirements have been implemented. Results demonstrated that all executed verification tests were passed.
Non-clinical validation testing has been performed to validate that Azurion R2.1 conforms to the intended use, claims, user and service needs, effectiveness of safety measures and instructions for use. The validation consisted of the following activities:
Usability validation was performed with both interventional radiologists / cardiologists (physicians) and nurse/technicians in a simulated use environment. Azurion R2.1 was found to be safe and effective for the intended use, users and use environment.
A simulated use design validation was undertaken with participants who fulfill the intended user profile. The participants executed validation protocols in the form of a clinical workflow to validate user needs, intended use, claims and effectiveness of the safety and instructions for use. Results demonstrated that all executed validation protocols were passed.
All these tests were used to support substantial equivalence of the subject device and demonstrate that Azurion R2.1:
- complies with the above-mentioned international and FDA-recognized consensus standards and FDA guidance documents, and
- . meets the acceptance criteria and is adequate for its intended use.
Therefore, Azurion R2.1 is substantially equivalent to the currently marketed Azurion R1.2 in terms of safety and effectiveness.
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Summary of Clinical Performance Data:
The Azurion R2.1 did not require clinical study data since substantial equivalence to the currently marketed predicate device Azurion R1.2 was demonstrated with the following attributes:
- Indication for use;
- . Technological characteristics;
- . Non-clinical performance testing; and
- . Safety and effectiveness.
These attributes demonstrated that the clinical performance of the modified device is substantially equivalent to the predicate device.
Substantial Equivalence Conclusion:
The Azurion R2.1 is substantially equivalent to the currently marketed predicate device Azurion R1.2 in terms of indications for use, technological characteristics and safety and effectiveness.
The modification of the Azurion R2.1 is within the controls and predetermined specifications. Additionally, substantial equivalence was demonstrated by non-clinical performance tests provided in this 510(k) premarket notification. These tests demonstrate that Azurion R2.1 complies with the user need requirements as well as the requirements specified in the FDA-recognized consensus standards and guidance documents.
Therefore Azurion R2.1 is as safe and effective as its predicate device and does not raise any new safety and/or effectiveness concerns.
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.