K162394 · Capintec, Inc. · KPT · Mar 8, 2017 · Radiology
Device Facts
Record ID
K162394
Device Name
CRC-77tHR
Applicant
Capintec, Inc.
Product Code
KPT · Radiology
Decision Date
Mar 8, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1360
Device Class
Class 2
Intended Use
The CRC-77tHR is intended to be used by qualified radiopharmacists, radiochemists, radiation physicists, or other appropriately trained personnel in isotope production sites to measure a wide range of measure a wide range of high activity radiopharmaceuticals and radioactive materials, including high energy beta and gamma emitters. The device is not intended for use with brachytherapy sources. This device is also used in numerous research applications for measurement of high activity levels of radioactive materials.
Device Story
CRC-77tHR is a radionuclide dose calibrator used in isotope production and research facilities. It utilizes a sealed reentrant well ionization chamber as a detector to measure high-activity radiopharmaceuticals and radioactive materials. The system includes a readout unit with a touch screen interface. The device operates by measuring ionization current, which is converted to activity levels. The electrometer board is located in the readout unit to protect electronics from radiation. Compared to the predicate, the CRC-77tHR features lower gas fill pressure in the chamber, reducing sensitivity to allow for the measurement of higher activity levels (e.g., Tc-99m up to 400 Curies, F-18 up to 130 Curies). It is operated by trained personnel (radiochemists/physicists) in a laboratory setting. The output provides activity measurements, which are used by staff to verify radiopharmaceutical doses or material activity. The device does not have direct patient contact.
Clinical Evidence
Bench testing only. No clinical or animal studies performed. Performance data includes electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), and usability (IEC 60601-1-6). Technical specifications validated include measurement range (up to 400 Ci for Tc-99m), energy range (15 keV to 3 MeV), electrometer accuracy (+/- 2%), linearity (< 2%), and reproducibility (+/- 1%). Software verification and validation conducted per FDA guidance.
Technological Characteristics
Radionuclide dose calibrator; sealed reentrant well ionization chamber detector; touch screen readout. Electrometer board located in readout unit. Energy range: 15 keV to 3 MeV. Connectivity: cable-connected chamber and optional printer. Software life cycle: IEC 62304. Safety standards: IEC 60601-1 (Ed. 3), IEC 60601-1-2 (Ed. 4), AAMI ES60601-1, CSA C22.2#60601-1.
Indications for Use
Indicated for qualified radiopharmacists, radiochemists, radiation physicists, or trained personnel in isotope production/research sites to measure high activity radiopharmaceuticals and radioactive materials (beta/gamma emitters). Not for brachytherapy sources.
Regulatory Classification
Identification
A radionuclide dose calibrator is a radiation detection device intended to assay radionuclides before their administration to patients.
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Submission Summary (Full Text)
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the circle is an abstract symbol that resembles a stylized caduceus, with three human profiles facing to the right.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 8, 2017
Capintec, Inc. % Ms. Mary Yusko VP, Product Development and Regulatory Affairs 7 Vreeland Road FLORHAM PARK NJ 07932
Re: K162394
Trade/Device Name: CRC-77tHR Regulation Number: 21 CFR 892.1360 Regulation Name: Radionuclide Dose Calibrator Regulatory Class: II Product Code: KPT Dated: December 19, 2016 Received: December 21, 2016
Dear Ms. Yusko:
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 O'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) K162394
Device Name
CRC-77tHR
Indications for Use (Describe)
The CRC-77tHR is intended to be used by qualified radiochemists, radiation physicists, or other appropriately trained personnel in isotope production sites to measure a wide range of measure a wide range of high activity radiopharmaceuticals and radioactive materials, including high energy beta and gamma emitters. The device is not intended for use with brachytherapy sources. This device is also used in numerous research applications for measurement of high activity levels of radioactive materials.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the logo for CAPINTEC, INC. The logo consists of the letters "CII" stacked on top of each other inside of a square. Below the square is the text "CAPINTEC, INC."
RE: Summary of Safety and Effectiveness Information for the Capintec CRC-77tHR
### I. SUBMITTER
Capintec, Inc. 7 Vreeland Road Florham Park, NJ 07932 Phone 201-825-9500 201-825-1336 FAX
Contact Person: Mary Anne Yusko Date Prepared: February 12, 2017
- II. DEVICE Name of Device: CRC-77tHR
Common or Usual Name: Radionuclide Dose Calibrator Regulatory Class II, Product Code: KPT (90) 21 CFR 892.1360
- III. PREDICATE DEVICE CRC -55t Dose Calibrator series, which received FDA clearance under 510(k) number K101452. This predicate device has not been subject to a design related recall. The predicate devices, Capintec dose calibrator lines, upon which the CRC-77tHR is based, have a long history of over 30 years of safe, reliable, and effective use in the field.
### IV. DEVICE DESCRIPTION
The Capintec CRC-77tHR is dose calibrator which uses a touch screen user interface and sealed reentrant well chamber as the detector. The gas fill pressure has been lowered in order to extend the maximum activity range for isotope manufacturing and radiopharmaceutical production environments. A diagram of the system is shown below.
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Image /page/4/Figure/0 description: The image shows a diagram of a CRC-77t Readout system. The system includes a CRC-77t Readout device, a dipper, a liner, an ionization chamber, a line cord, and an optional printer. The CRC-77t Readout device is connected to the ionization chamber and the optional printer via cables. The dipper and liner are separate components of the system.
#### V. INDICATIONS FOR USE
The CRC-77tHR is intended to be used by qualified radiopharmacists, radiochemists, radiation physicists, or other appropriately trained personnel in isotope production sites to measure a wide range of measure a wide range of high activity radiopharmaceuticals and radioactive materials, including high energy beta and gamma emitters. The device is not intended for use with brachytherapy sources. This device is also used in numerous research applications for measurement of high activity levels of radioactive materials.
VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE
DEVICE The CRC -77tHR series is identical to the predicate device, the CRC-55t series, in terms of scientific technology, principles of operations, radiation detectors, measurement processes, calibration, algorithms, calculations, user interface, and basic circuitry design. There are two basic differences between models. The first difference is that CRC-77tHR has a lower fill gas pressure, which reduces the sensitivity of the chamber in order to extend maximum activity which the device can measure. This change allows the 77tHR to be used in isotope and radiopharmaceutical production facilities which need to measure higher activity levels. The second difference is that the electrometer board, which is located in the base of the ionization chamber for the 55t models, has been relocated to the readout of the 77tHR. This was done to protect the electronics from radiation damage by removing them from the radiation field. Otherwise, the technical characteristics of the models are the same.
The predicate device includes brachytherapy measurements as an intended use. The CRC-77tHR, with lower fill pressure and reduced sensitivity, has not been validated for LDR measurements at this time. Therefore, brachytherapy source measurements were not included in the listed intended use. The removal of this intended use does not affect safety or effectiveness of the CRC-77tHR for its listed applications.
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- VII. PERFORMANCE DATA The CRC-77tHR The following performance data were provided in support of the substantial equivalence determination
- Electrical safety, electromagnetic compatibility (EMC) and Usability Compliance IEC 60601-1-2 (2014):Ed. 4. Medical Electrical Equipment – Part 1-2: General Requirements for Safety - Collateral Standard: Electromagnetic Compatibility -Requirements and Tests
IEC 60601-1: Issued: 2005/12/15 Ed. 3 Medical Electrical Equipment – Part 1: General Requirements for Basic Safety & Essential Performance; Corr. 1: 2006, Corr. 2: 2007. Amd. 1: 2012
IEC 60601-1-6: Issue:2010/01/27 Ed:3 Medical electrical equipment – Part 1-6: General requirements for safety - Collateral Standard: Usability Review of usability per 60601-1 3rd Edition
AAMI ES60601-1: Issued: 2012/08/20 Medical Electrical Equipment – Part 1: General Requirements for Basic Safety and Essential Performance, Amendment 1. Product safety evaluation to AAMI 60601-1 3rd Edition, Amendment 1
CSA C22.2#60601-1: Issued: 2014/03/01 Ed: 3 Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and Essential Performance
IEC 62304: Issue:2006/05/09 Ed:1 Medical Device Software - Software Life Cycle Processes
Technical Specifications:
Measurement Range: Maximum activity for Tc-99m is approximately 400 Curies Maximum activity for F-18 is approximately 130 Curies Resolution: .01 mCi (10 µCi) Minimum activity range > 100 µCi This model should not be used for activity measurements less than 100 µCi Energy Range: 15 keV to 3 MeV Electrometer Accuracy: + 2% NOTE: Overall accuracy is determined by the specific nuclide and sample configuration, geometry difference between the reference source and sample, and accuracies of the reference sources used for calibration. Electrometer Linearity: < 2% over a dynamic range of 10115 A to 106 A Reproducibility: + 1% in 24 hours with unit powered at all times.
### Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The level of concern is moderate because a failure or latent design flaw could directly result in minor injury to the patient or operator. The level of concern is also moderate because a failure or latent flaw could indirectly result in minor injury to the patient through incorrect or delayed information or through the action of a care provider.
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The CRC-77tHR was also evaluated at an isotope production site. Animal, clinical and biocompatibility studies are not applicable and were not performed. The CRC-77tHR is used in a laboratory bench top setting and has no direct patient contact.
## SUMMARY
Summary Based on documented performance, the CRC-77tHR was found to have a safety and effectiveness profile that is similar to the predicate device.
- CONCLUSIONS The data demonstrate that the CRC-77tHR device performs comparably to VIII. the predicate device at a higher activity range.
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