Models SP-HF-2.8 and SP-HF-4.0 are intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position.
Device Story
Portable X-ray units (SP-HF-2.8 and SP-HF-4.0) designed for diagnostic imaging; utilizes high-frequency inverter technology; operates on 90-285 VAC power. Device is portable, mountable on tripods/support arms, or handheld. Operated by qualified physicians or technicians in clinical settings. Input: electrical power; Output: diagnostic X-ray exposures. User interface features pushbuttons for kVp and mAs selection with LED indicators. Healthcare providers use X-ray output to visualize internal anatomy for diagnostic purposes, facilitating clinical decision-making for various body parts. Benefits include portability for point-of-care imaging.
Clinical Evidence
Bench testing only. No clinical data provided. Safety and effectiveness established through comparison of technical specifications and performance testing against the predicate device.
Technological Characteristics
Portable X-ray system; high-frequency inverter; 90-285 VAC power input. Dimensions: 8.7"H x 10.4"W x 16.5"D; Weight: 33 lbs. User interface: pushbuttons for kVp/mAs. Compliance: 21 CFR 1020.30, UL 2601, IEC 60601-1. kVp range: 110-115 kVp. Exposure times: 0.001-10 seconds.
Indications for Use
Indicated for adult and pediatric patients requiring diagnostic radiographic exposures of the skull, spine, chest, abdomen, and extremities. Used by qualified physicians or technicians with patients in sitting, standing, prone, or supine positions.
Regulatory Classification
Identification
A mobile x-ray system is a transportable device system intended to be used to generate and control x-ray for diagnostic procedures. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
MinXray HF100H
Submission Summary (Full Text)
{0}------------------------------------------------
## FEB 2 2 2002
K020436
Page 142
EXHIBIT 2 510(k) Summary of Safety and Effectiveness
| SEDECAL SA | SEDECAL USA, Inc. |
|--------------------------------------|----------------------------------|
| Pelaya 9- Poligono Industrial Rio De | 2910 N. Arlington Heights Rd. |
| Janeiro | Arlington Heights Illinois 60006 |
| 28110-Algete | Tel 847-394-6960 |
| Madrid Spain | Fax 847-394-6966 |
| Tel (34) 91-628 0544/91-628 1592 | (Initial Importer) |
| Fax (34) 91-628 0574 | Contact: Gary Fromberg |
| (Foreign Manufacturer) | |
February 5, 2002
510(k) Summary of Safety and Effectiveness
- 1. Identification of the Device: Proprietary-Trade Name: Models SP-HF-2.8 and SP-HF-4.0 Portable X-ray Units Classification Name: Mobile X-ray system, Product Code 90 IZL Common/Usual Name: Portable general purpose diagnostic X-ray Unit.
- 2. Equivalent legally marketed devices: This product is similar in function to the MinXray HF100H (a pre-amendments device)
- 3. Indications for Use (intended use) Models SP-HF-2.8 and SP-HF-4.0 are intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts. Applications can be performed with the patient sitting, standing, or lying in the prone or supine position.
- 4. Description of the Device: Models SP-HF-2.8 and SP-HF-4.0 are a portable units which operate from 120 V 50-60~ AC. The unit utilizes a newly designed high frequency inverter and can be either mounted to a tripod or support arm or can be hand held. The usual safety precautions regarding the use of x-rays must be observed by the operator.
- 5. Safety and Effectiveness, comparison to predicate device. The results of bench and user testing indicates that the new device is as safe and effective as the predicate device.
{1}------------------------------------------------
| Characteristic | MinXray HF100H | Models SP-HF-2.8 | Model SP-HF-4.0 |
|---------------------------------------------|--------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| Intended Use: | Potable general<br>purpose diagnostic<br>X-ray unit | SAME | SAME |
| Physical<br>characteristics: | | | |
| Size | 8.75"H x 9.5" W x<br>15.35" D. | 8.7 H x 10.4" W x<br>16.5" D | 8.7 H x 10.4" W x<br>16.5" D |
| Weight | 40.9 lbs | 33 lb | 33 lb |
| Energy Source: | 120 v 50-60~ AC | 90 to 285 VAC (50-<br>60 Hz) | 90 to 285 VAC (50-<br>60 Hz) |
| User Interface | Up-Down<br>pushbuttons for<br>three kVp selections<br>and exposure time<br>selections with LED<br>indicators | Up-Down<br>pushbuttons for kVp<br>and mAs. kVp<br>adjustable in 1 kVp<br>steps | Up-Down<br>pushbuttons for kVp<br>and mAs. kVp<br>adjustable in 1 kVp<br>steps |
| Exposure times | 0.08-2.00 Sec. In<br>192 steps | 0.002-10 sec 38<br>steps | 0.001-10 sec 41<br>steps |
| Ma. | 20 mA | 5, 6.4, 8, 10, 12.5,<br>16, 20, 25, 32, 40,<br>50 | 5, 6.4, 8, 10, 12.5,<br>16, 20, 25, 32, 40,<br>50, 64, 80, 100 |
| KvP | 100 KvP | 110 KvP | 115 KvP |
| Standards and<br>Safety<br>characteristics: | | | |
| Performance<br>Standard | 21 CFR 1020.30 | SAME | SAME |
| Electrical safety: | UL 2601, IEC<br>60601-1 | SAME | SAME |
Chart, Models SP-HE-2 8 and SP-HF-4.0
## 7. Conclusion
After analyzing both bench and user testing data, it is the conclusion of Sedecal that the Models SP-HF-2.8 and SP-HF-4.0 are as safe and effective as the predicate device, have few technological differences, and has no new indications for use, thus rendering it substantially equivalent to the predicate device.
{2}------------------------------------------------
Image /page/2/Picture/1 description: The image is a black and white seal. The seal is circular and contains the words "HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is an abstract image of an eagle with its wings spread.
## Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
FEB 2 2 2002
SEDECAL USA, Inc. % Mr. Daniel Kamm, P.E. Kamm & Associates PO Box 7007 DEERFIELD IL 60015
Re: K020436
Trade/Device Name: Models SP-HF-2.8 and SP-HF-4.0 Portable X-ray Unit Regulation Number: 21 CFR 892.1720 Regulation Name: Mobil x-ray system Regulatory Class: II Product Code: 90 IZL Dated: February 6, 2002 Received: February 8, 2002
Dear Mr. Kamm:
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.
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); 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.
{3}------------------------------------------------
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please If you desire specific at one of the following numbers, based on the regulation number at the top of this letter:
| 8xx.1xxx | (301) 594-4591 |
|----------------------------------|----------------|
| 876.2xxx, 3xxx, 4xxx, 5xxx | (301) 594-4616 |
| 884.2xxx, 3xxx, 4xxx, 5xxx, 6xxx | (301) 594-4616 |
| 892.2xxx, 3xxx, 4xxx, 5xxx | (301) 594-4654 |
| Other | (301) 594-4692 |
Additionally, for questions on the promotion and advertising of your device, please contact the Additionally, relate at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). Other general information on by received to premained from the Division of Small Manufacturers, Jour responsiblements assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.
Sincerely vours,
Nancy C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{4}------------------------------------------------
j) Indications for Use
510(k) Number KD204366
Device Name: Models SP-HF-2.8 and SP-HF-4.0 Portable X-ray Units
Indications for Use: Models SP-HF-2.8 and SP-HF-4.0 Portable X-ray Units are intended financills for Soor Meaned physician or technician on both adult and pediatric subjects for taking diagnostic x-rays.
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use ✓ OR
Over the Counter Use (Per 21 CFR 801.109)
Nancy Srogdon
(Division Sign-Off)
Division of Reproductive, Abdominal,
and Radiological Devices
510(k) Number K020436
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Learn the FDA Browser
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.