K024149 · Accuimage Diagnostics Corp. · JAK · Feb 21, 2003 · Radiology
Device Facts
Record ID
K024149
Device Name
PRIMELUNG
Applicant
Accuimage Diagnostics Corp.
Product Code
JAK · Radiology
Decision Date
Feb 21, 2003
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1750
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
Comprehensive software package for visualization and analysis of thoracic CT datasets, which is intended to help the reading physician to analyze regions of the lung, such as nodules and other lung parameters, and to generate an automatic report.
Device Story
PrimeLung is a software module for thoracic CT image analysis; operates on PC workstations with Windows OS. Inputs consist of thoracic CT datasets (helical, multidetector, or electron beam). Device provides tools for visualization (MIP, MPR, 3D volume rendering), segmentation of lung nodules, volume measurement, and nodule matching. Physician uses these tools to analyze lung regions and generate automated reports containing patient information, images, and clinical recommendations. Intended for clinical use to assist in diagnostic decision-making regarding lung nodules.
Clinical Evidence
Bench testing only. Testing verified all functional specifications, including GUI, measurement tools, segmentation tools, and report generation. Comparison tool testing demonstrated 100% matching accuracy on specified datasets.
Technological Characteristics
Software-based image analysis module for PC workstations running Windows. Supports helical, multidetector, and electron beam CT scanners. Features include MIP, MPR, 3D volume rendering, nodule segmentation, volume measurement, and automated report generation.
Indications for Use
Indicated for use by physicians to visualize and analyze thoracic CT datasets, including lung nodules and other lung parameters, and to generate automatic reports.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
Siemens Medical Solutions Lungcare CT Software (K022013)
GE Medical Systems Advanced Lung Analysis (K013381)
AccuImage AccuView Workstation with AccuScore (K990241/K012106)
Submission Summary (Full Text)
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**Section 1**
Ko24149
## 510(K) Summary
(as required by 21 CFR § 807.92)
Date:
## A. Submitter's Information:
| Name: | Acculmage Diagnostics Corporation |
|--------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Address: | 400 Grandview Drive<br>South San Francisco, CA 94080 |
| Telephone Number: | (650) 875-0192 |
| Fax Number: | (650) 875-0194 |
| Contact Name: | Oscar Gils Carbó |
| Contact Email address: | oscar@accuimage.com |
| B. Device Information: | |
| Proprietary Name: | PrimeLung |
| Common or Usual Name: | Lung nodule visualization and analysis software<br>package. |
| Classification: | Class II 21 CFR 892.2050 LLZ |
| Substantial Equivalence: | The Acculmage PrimeLung option is Substantially<br>Equivalent to the Siemens Medical Solutions<br>Lungcare CT Software Package, to the GE Medical<br>Systems Advanced Lung Analysis, and to the<br>Acculmage AccuView Workstation with AccuScore<br>software module. |
| Device Description: | The Acculmage PrimeLung software module is an<br>additional software option to K990241, AccuView<br>Diagnostics Imaging Workstation with AccuScore,<br>AccuAnalyze, AccuShade, AccuVRT and AccuMIP<br>plug-ins. The AccuShade plug-in is not currently<br>marketed, the AccuMIP plug-in is currently<br>marketed with the name ProjectorPro. The<br>Acculmage PrimeLung plug-in provides<br>visualization and analysis tools for viewing regions<br>of the lung, and generating reports with patient<br>information, images, results and recommendations. |
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K02-4149
Intended Use:
PrimeLunq is a comprehensive software package for visualization and analysis of thoracic CT datasets, which is intended to help the user to analyze lunq nodules and other lung parameters, and to generate an automatic report.
#### C. Technological Characteristics of the Device as compared to Predicate Devices:
| Manufacturer | Siemens Medical<br>Solutions | GE Medical<br>Systems | Acculmage Diagnostics<br>Corp. | Acculmage<br>Diagnostics Corp. |
|-------------------------------------------------------------------|----------------------------------------------------|---------------------------------|---------------------------------------------------------|------------------------------------------------------------|
| Product Name | LungCare CT Software | Advanced Lung<br>Analysis | AccuView Workstation with<br>AccuScore, etc. | PrimeLung |
| 510(k) Number | K022013 | K013381 | K990241/ K012106 | |
| Computer Platform | PC Workstation with<br>Windows Operating<br>System | Sun Workstation | PC Workstation with<br>Windows Operating System | PC Workstation with<br>Windows Operating<br>System |
| Type of CT Scanner<br>for which it is<br>applicable | Standard or low-dose<br>spiral CT scanners | At least helical CT<br>scanners | Helical, Multidetector and<br>Electron Beam CT scanners | Helical, Multidetector<br>and Electron Beam CT<br>scanners |
| Draw, Edit, Delete<br>ROI (possible<br>nodules | Yes | Yes | Yes | Yes |
| Image Processing<br>Tools | MIP, MPR, 3D Volume<br>Rendering | Yes | MIP, MPR, 3D Volume<br>Rendering | MIP, MPR, 3D Volume<br>Rendering |
| Segmentation of lung<br>nodule | Yes | Yes | n/a | Yes |
| Volume<br>measurements,<br>Comparator tool for<br>nodule matching | Yes | Yes | n/a | Yes |
| Report Generator | Yes | Unknown | Yes | Yes |
#### Substantial Equivalence Comparison Chart
#### D. Brief Discussion of Test Results Submitted:
The test plan covers all aspects of the functionality, exercising every user interface button, all menus and submenus, as well as all configurable items, including the measurement tool, segmentation tool and report generator tool.
#### E. Conclusions from Test Results:
From the Graphic User Interface test results: The Graphic User Interface, its menus and buttons conform as per the PrimeLung functional specification.
From a functionality point of view, all functionality works as described in the PrimeLung Functional Specification.
From Comparison Tool test results:
The testing performed showed that auto-matching comparison tool provides very reliable results with 100% of matching accuracy on the specified data sets.
From Report Generator Test results:
ests results show that the report generator can be created and results can be printed.
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## DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
# FEB 2 1 2003
Mr. Oscar Gils Carbó Vice President Acculmage Diagnostics Corporation 400 Grandview Drive SOUTH SAN FRANCISCO CA 94080 Re: K024149
Trade/Device Name: PrimeLung Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: II Product Code: 90 JAK Dated: December 6, 2002 Received: December 16, 2002
Dear Mr. Carbó:
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.
Image /page/2/Picture/11 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the top half of the circle. Inside the circle is an abstract image of an eagle.
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This letter will allow you to begin marketing your device as des
This letter will allow you to begin marketing your device as described in your Section 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 contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of the 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 Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97) you may obtain. Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer 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 yours,
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
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Section 1.1
Ko2449
#### INDICATIONS FOR USE
Applicant:
Acculmage Diagnostics Corporation
510(k) Number: K024149
PrimeLung Device Name:
Indications for Use:
Comprehensive software package for visualization and analysis of thoracic CT datasets, which is intended to help the reading physician to analyze regions of the lung, such as nodules and other lung parameters, and to generate an automatic report.
**Prescription Use**
**(Per 21 CFR 801.109)**
Nancy Hodsdon
(Division Sig Division of Re and Radiolog 510(k) Num
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1. Search: exact and fuzzy
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You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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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.