UNISCAN, PULMOSCAN, PULMOSCAN RADIOGRAPHIC SYSTEMS
Applicant
Medlink Imaging
Product Code
KPR · Radiology
Decision Date
Mar 18, 2005
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 892.1680
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The "Uniscan" model is a stationary general-purpose diagnostic (universal) system for obtaining standard planar X-ray images of the bone structure and soft tissues of a patient in the standing, sitting and lying position. The "Pulmoscan" model is a stationary specialized-purpose diagnostic system for mass examination (screening) of wide groups of population, first of all, in polyclinics at the stage of before-doctor examination with the purpose of early diagnostics of the thorax organs. The "Pulmoscan-T" model is a mobile specialized-purpose diagnostic system, particularly, for mass examination (screening) of wide groups of population directly at the places of their maximum concentration (in educational institutions and at enterprises), in remote areas (villages, military units), in institutions with the special access regime (refugees camps, penal jurisdiction) with the purpose of early diagnostics of the thorax organs.
Device Story
Digital Radiographic Systems (DRS) generate low-energy X-ray radiation (40-150 keV) via X-ray source and power supply. System uses adjustable diaphragm to form fan-shaped X-ray beam; scans patient area; projects magnified planar X-ray image onto linear matrix multielement semiconductor detector. Detector converts absorbed radiation into digital form. Software forms two-dimensional digital projection image on computer monitor for manipulation and archiving. Used in polyclinics, educational institutions, enterprises, remote areas, and special access facilities. Operated by qualified doctors or technicians. Output allows clinicians to perform diagnostic evaluations of bone structure and soft tissues or thorax organs, facilitating early diagnosis and mass screening.
Clinical Evidence
Bench testing and user testing performed. No clinical trial data provided. Testing confirmed safety and effectiveness equivalent to predicate device.
Technological Characteristics
Stationary and mobile X-ray systems. X-ray source (40-150 keV). Linear matrix multielement semiconductor detector. Fan-beam scanning geometry. Digital image acquisition and processing software. Electrical safety per UL-2601/IEC 60601 and UL187. Complies with 21 CFR 1020.30.
Indications for Use
Indicated for adult and pediatric patients requiring diagnostic radiographic imaging of bone structure and soft tissues (Uniscan) or thorax organ screening (Pulmoscan/Pulmoscan-T). Applicable for standing, sitting, or lying positions. No specific contraindications listed.
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
Siemens Multix FD and Thorax FD Stationary X-Ray System (K983732)
Submission Summary (Full Text)
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MAR 1 8 2005
EXHIBIT 2 Medlink Imaging Inc. 200 Clearbrook Rd Elmsford NY 10523 Tel 800-456-7800 Fax 888-437-9729 September 30, 2003 Contact: John Ciarcia
K073577
## 510(k) Summary
l. Identification of the Devices: ruentification of the Devices.
Proprietary-Trade Name: "Pulmoscan," "Uniscan," and "Pulmoscan-T" Digital Radiographic Systems Classification Name: Stationary X-Ray System, Product Code KPR and MKP Common/Usual Name: Stationary or Transportable X-Ray System
- 2. Equivalent legally marketed devices This product is similar in function to the Siemens Multix FD and Thorax FD Stationary X-Ray System (K983732)
- 3. Indications for Use (intended use) The "Uniscan" model is a stationary general-purpose diagnostic (universal) system for obtaining standard planar X-ray images of the bone structure and soft tissues of a patient in the standing, sitting and lying position .
and Tyng Position :
- The "Pulmoscan" model is a stationary specialized-purpose diagnostic system for mass examination (screening) of wide groups of population, first of all, in polyclinics at the stage of before-doctor examination with the purpose of early diagnostics of the thorax organs.
Giagnostics of the thorax organs.
- The "Pulmoscan-T" model is a mobile specialized-purpose diagnostic system, particularly, for mass examination (screening) of wide groups of population directly at the places of their maximum concentration (in educational institutions and at cnterprises), in remote areas (villages, military units), in institutions with the special access regime (refugees camps, penal jurisdiction) with the purpose of early diagnostics of the thorax organs.
- 4. Description of the Device: The principal of functioning of the DRS system is based on:
- generation of highly stable low-energy X-ray radiation (from 40 up to 150 keV) with controllable parameters (voltage, current, time, exposure duration) by means of an X-ray source connected to the X-ray power supply unit;
- formation of a flat narrow with the width D fan-shaped X-ray beam with the possibility of masking according to the radiation angle a by means of the adiustable diaphragm;
adgustere of the area of the patient's body to be examined (input dimensions A B) by scanning with a flat X-ray beam in the field of the scanning angle b with the possibility of specifying and visual control of the scanning (exposure) field; - magnification of the planar X-ray image of the patient with the specified enlargement by projecting it to the scanning X-ray detector located at a
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K0 33577
considerable distance from the patient;
- obtaining the digital X-ray image of the area to be examined by means of the scanning X-ray detector (on the basis of a linear matrix multiclement semiconductor detector), converting the absorbed X-ray radiation into digital form;
- formation of the two-dimensional digital projection image on the computer monitor with the possibility of manipulation and archiving by means of the special software
- 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 devices.
| Characteristic | Siemens Multix FD and<br>Thorax FD Stationary | "Pulmoscan," "Uniscan,"<br>and "Pulmoscan-T" |
|----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------|
| | X-Ray System<br>(K983732) | Radiographic Systems |
| Intended Use: | Intended for use by a<br>qualified/trained doctor or<br>technician on both adult and<br>pediatric subjects for taking<br>diagnostic radiographic<br>exposures of the skull, spinal<br>column, chest, abdomen,<br>extremities, and other body<br>parts. Applications can be<br>performed with the patient<br>sitting, standing, or lying in<br>the prone or supine position. | SAME |
| Performance Standard | 21 CFR 1020.30 | SAME |
| Electrical safety | Electrical Safety per<br>Underwriters Laboratories<br>Standard UL-2601(IEC-<br>60601) and IEC 60601,<br>Underwriters Laboratories<br>Standard UL187: UL<br>Standard for Safety for X-<br>Ray Equipment, CE<br>Marking Requirements | SAME |
- 6. Substantial Equivalence Chart, "Pulmoscan," "Uniscan," and "Pulmoscan-T" Radiographic Systems
### 7. Conclusion
After analyzing both bench and user testing data, it is the conclusion of Medlink Imaging that the "Pulmoscan," "I Iniscan," and "Pulmoscan-T" Radiographic Systems are as safe and effective as the predicate device, has few technological differences, and has no new indications for use, thus rendering it substantially equivalent to the predicate device.
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Image /page/2/Picture/0 description: The image shows the logo of the Department of Health & Human Services. The logo consists of a symbol on the left and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES" on the right. The symbol is a stylized representation of a human figure, and the text is in a bold, sans-serif font. The logo is simple and professional, and it is easily recognizable.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002
Medlink Imaging, Inc. % Daniel Kamm, P.E. Regulatory Affairs Kamm & Associates PO Box 7007 DEERFIELD IL 60015
AUG 2 1 2013
Re: K033577
Trade/Device Name: "Pulmoscan", "Uniscan", and "Pulmoscan-T" Radiographic Systems Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray System Regulatory Class: II Product Code: KPR and MOB Dated: February 3, 2005 Received: February 22, 2005
Dear Mr. Kamm:
This letter corrects our substantially equivalent letter of March 18, 2005.
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 class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. 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 Parts 801 and 809); medical device reporting (reporting of
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medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). 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 Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely Yours,
Janine M. Morris
Acting Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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# i) Indications for Use
510(k) Number_K0335772_
Device Name: "Pulmoscan," "Uniscan," and "Pulmoscan-7" Radiographic Systems
### Indications for Usc:
Indications for Use:
- The DRS system of the "Uniscan" model is a stationary general-purpose diagnostic - The DRS system of the "Uniscal" model is a stationaly general particular particure and
(universal) system for obtaining standard planar X-ray images of the bone structure a (universal) system for obtaining saining, sitting and lying position
soft tissues of a patient in the standing, sharty and 15 mg procialized-purpose
- The DRS system of the "Pulmoscan" model is a stationary specialized-purpose - The DRS system of the "Pumpsean Intount is a stations of population, first of
diagnostic system for mass examination (screening) of with purpose of carly diagnostic system for mass examination (sereching) of theo group.
all, in polyclinics at the stage of before-doctor examination with the purpose of carly diagnostics of the thorax organs.
diagnostics of the thorax organs.
- The DRS system of the "Pulmoscan-T" model is a mobile specialized-purpose . The DRS system of the "Pumoscan-1" model is a moone operation of wide groups of
diagnostic system, particularly, for mass examination (screening) in educational diagnostic system, particularly, for their maximum concentration (in cducational
population directly at the places of their maximum concentration (in educational), in institu population directly at the places of them institutions military units), in institutions
institutions and at enterprises), in remote areas (virdiction) with the purpose of institutions and at enterprises), in remote areas (Vinages) million with the purpose of early diagnostics of the thorax organs.
Concurrence of CDRH, Office of Device Evaluation (ODE)
| Prescription Use | <span style="text-decoration: overline;">✓</span> |
|------------------|---------------------------------------------------|
|------------------|---------------------------------------------------|
OR
| Over the Counter Use | <span style="text-decoration: overline;"></span> |
|----------------------|--------------------------------------------------|
| (Per 21 CFR 801.109) | |
| (Division Sign-Off) | |
|---------------------------------------------------------------|---------|
| Division of Reproductive, Abdominal, and Radiological Devices | |
| 510(k) Number | K033577 |
Page 8 of 978
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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.
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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.
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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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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.
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Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
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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.
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.