The Portable X-ray system (Model: EXARO, Xray2GO) is intended to be used by trained dentists and dental technicians as extra-oral x-ray source for producing diagnostic x-ray images using intra-oral image receptors or film. Its use is intended for both adult and pediatric subjects.
Device Story
Portable dental X-ray system; hand-held enclosure containing X-ray tube head, controller, and power source. Operates via 25.2V DC Li-Polymer battery; high-frequency inverter converts DC to AC to generate X-rays. X-rays penetrate tooth/jaw anatomy to produce images on intra-oral receptors (film or digital sensors). Used by dentists/technicians in clinical settings. User interface allows selection of tooth region, patient type (adult/child), and receptor type. Exposure controlled via panel or remote. Benefits include diagnostic imaging capability with small radiation dose.
Clinical Evidence
Bench testing only. No clinical data provided. Safety and performance verified via compliance with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-7, IEC 60601-2-28, and IEC 60601-2-32.
Indicated for adult and pediatric patients requiring diagnostic dental X-ray imaging of teeth and jaw, for use by trained dentists and dental technicians.
Regulatory Classification
Identification
An extraoral source x-ray system is an AC-powered device that produces x-rays and is intended for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures. The x-ray source (a tube) is located outside the mouth. This generic type of device may include patient and equipment supports and component parts.
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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 features the department's name encircling a symbol. The symbol is a stylized representation of three human profiles facing right, with flowing lines suggesting movement or connection. The text reads "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA".
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 26, 2014
Osstem Implant Co. Ltd. % Patrick Lim OA/RA Manager, Hiossen Inc. 85 Ben Fairless Drive FAIRLESS HILLS, PA 19030
Re: K141497
> Trade/Device Name: Portable X-Ray System (Model: EXARO, Xray2GO) Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral Source X-ray System Regulatory Class: II Product Code: EHD Dated: July 25, 2014 Received: July 28, 2014
Dear Mr. Lim:
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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/ResourcesforYou/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,
Smh.f)
for
Janine M. Morris 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): K141497/S001
Device Name: Portable X-ray System (Model: EXARO, Xray2GO)
Indications for Use: The Portable X-ray system (Model: EXARO, Xray2GO) is intended to be used by trained dentists and dental technicians as extra-oral x-ray source for producing diagnostic x-ray images using intra-oral image receptors or film. Its use is intended for both adult and pediatric subjects.
Prescription Use __ X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
### (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostics and Radiological Health (OIR)
(Division Sign-Off) Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health
510(k): K141497/S001
Page 1 of __
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## OSSTEM Implant Co., Ltd.
301ho, Korea Electronics Cooperation B/D 114 Gasandigital2ro, Geumcheon-gu, Seoul-si, Korea, #153-803 Tel: +82 70-4394-5029 Fax: +82 51 850-4341 www.osstem.com
## 510K Summary
### Portable X-Ray System / Model : EXARO, Xray2GO
| 1. | Company and Correspondent Making the Submission | | |
|----|-------------------------------------------------|-----------------------------------------------------------------------------------------------------------|--|
| | Submitter : | OSSTEM Implant Co,.Ltd. | |
| | Address : | 301ho, Korea Electronics Cooperation B/D 114<br>Gasandigital2ro, Geumcheon-gu, Seoul-si, Korea<br>153-803 | |
| | Tel : | 82-70-4394-5029 | |
| | Fax : | 82-2-863-3479 | |
| | E-mail : | qa@osstem.com | |
| | Contact : | Mr. Mooyong Park | |
- 2. US Agent for FDA Contact : Name : HIOSSEN Inc., Address : 85 Ben Fairless Dr. Fairless Hills, PA 19030 USA Contact : Patrick Lim, QA/RA manager. Telephone No.: 888-678-0001 Fax No.: 267-759-7004 Email: dtlim@osstem.com
- 3. Device Information Proprietary/Trade Name: Common/Usual Name: Classification Name: Product Code: Device Class:
Portable X-Ray System (Model: EXARO, Xray2GO) Portable X-Ray System Extraoral Source X-Ray System EHD Class II per regulation 21 CFR 872.1800
- 4. Equivalent Legally Marketed Device K number: K122124 Proprietary/Trade Name: Portable X-Ray System(Model:EXARO) Common/Usual Name: Portable X-Ray System Classification Name: Extraoral Source X-Ray System Product Code: EHD Class II per regulation 21 CFR 872.1800 Device Class:
- న. Date Prepared: 6/4/2014
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# OSSTEM Implant Co., Ltd.
301ho, Korea Electronics Cooperation B/D 114 Gasandigital2ro, Geumcheon-gu, Seoul-si, Korea, #153-803 Tel: +82 70-4394-5029 Fax: +82 51 850-4341 www.osstem.com
#### 6. Description of the Device
EXARO, Xray2GO, a portable dental X-ray system, operates on 25.2V DC supplied by a rechargeable Li-Polymer battery pack, The X-ray tube head, controls and power source are assembled into a single hand-held enclosure. The package includes a battery charger. The potable X-ray system, EXARO, Xray2GO, being composed of X-ray generator, controller, and beam limiting device is designed to diagnose tooth and jaw through generated and controlled X-ray. The operating principle of EXARO, Xray2GO starts from the generation of X-ray by high voltage electricity, which in turn penetrates tooth and jaw area after flowing through X-ray tube and produces X-ray images on X-ray receptors (i.e. chemical film or digital sensor)
This device contains a high frequency inverter that converts direct to alternating current. X-ray tube head, electrical protective devices, and other elements. The EXARO, Xray2GO produces sharp and clear images and prevents patients and dentists from radiation exposure with utilizing small dose of radiation.
| Characteristic | Proposed<br>OSSTEM Implant Co,. Ltd.<br>EXARO, Xray2GO | Predicate<br>OSSTEM Implant Co., Ltd.<br>EXARO | |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|
| 510(k) number | Not assigned yet | K122124 | |
| Anode current | 3mA | 2mA | |
| Expose time | 0.01~1.6 seconds, 0.01 increments | 0.01~2.0 seconds, 0.01 increments | |
| Battery | Battery part No. | SPB605060H4 | JBL7451251700100FJ |
| | Battery Current | Current : 12.0CmA | Current : 1.0CmA |
| | Battery Max. Current | Max. current : 1900mAh | Max. current : 950mAh |
| Battery case size | 87 x 111.9 x 42H (mm) | 87 x 111.9 x 36H (mm) | |
| | NEW | Predicate Device | |
| Manufacturer | OSSTEM IMPLANT Co., Ltd. | OSSTEM IMPLANT Co., Ltd. | |
| Model | EXARO, Xray2GO | EXARO | |
| 510(k)<br>Number | Not assigned yet | K122124 | |
| Energy<br>Source | Rechargeable 25.2V, DC Lithium<br>Polymer Battery pack | Rechargeable 25.2V, DC Lithium<br>Polymer Battery pack | |
| Expose Time | 0.01~1.6 seconds, 0.01 increments | 0.01~2.0 seconds, 0.01 increments | |
| Time Accuracy | ±(10%+1ms) | ±(10%+1ms) | |
| Heat Capacity | 8.5 KHU | 8.5 KHU | |
| Power Output | 100W | 100W | |
| mA | 3mA Fixed | 2mA Fixed | |
| kVp | 60kV Fixed | 60kV Fixed | |
| Focal Spot | 0.8mm | 0.8mm | |
| Wave Form | Constant Potential (DC) | Constant Potential (DC) | |
| Safety, EMC and<br>Performance | IEC 60601-1, IEC 60601-1-2, IEC<br>60601-2-7, IEC 60601-2-28, IEC<br>60601-2-32 | IEC 60601-1, IEC 60601-1-2, IEC<br>60601-2-7, IEC 60601-2-28, IEC<br>60601-2-32 | |
| Source to skin<br>Distance | 20cm | 20cm | |
| Cone Diameter | 6cm | 6cm | |
| User Interface | Exposure time: up, down.<br>Selection buttons of parts of teeth,<br>adult and child, film and sensor with<br>display. | Exposure time: up, down.<br>Selection buttons of parts of teeth,<br>adult and child, film and sensor with<br>display. | |
| Exposure switch | Control panel and remote controller | Control panel and remote controller | |
| Tubehead<br>Mounting | Yes | Yes | |
| Principle of<br>Operation | X-ray generated by high voltage<br>electricity into X-ray tube, which<br>penetrates hand, tooth and jaw, and<br>makes X-ray images on receptor<br>(Chemical Film or Digital Sensor) | X-ray generated by high voltage<br>electricity into X-ray tube, which<br>penetrates hand, tooth and jaw, and<br>makes X-ray images on receptor<br>(Chemical Film or Digital Sensor) | |
| Intended Use intended to be used by trained dentists and dental technicians as extra-oral x-<br>ray source for producing diagnostic x-ray images using intra-oral image<br>receptors or film. Its use is intended for both adult and pediatric subjects. | | | |
A list of modifications made to the subject device is below:
- 7. Indications for use (Intended Use) The Portable X-ray System (Model: EXARO, Xray2GO) is intended to be used by trained dentists and dental technicians as extra-oral x-ray source for producing diagnostic x-ray images using intra-oral image receptors or film. Its use is intended for both adult and pediatric subjects.
- 8. Safety, EMC and Performance Data No additional testing was added for this submission based on the modifications.
- 9. Safety and Effectiveness, comparison to Predicate The result of bench and clinical evaluation indicates that the new device is as safe and effective as the predicate devices.
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TEM®
# OSSTEM Implant Co., Ltd.
301ho, Korea Electronics Cooperation B/D 114 Gasandigital2ro, Geumcheon-gu, Seoul-si, Korea, #153-803 Tel: +82 70-4394-5029 Fax: +82 51 850-4341 www.osstem.com
#### 10. Substantial Equivalence Chart
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# OSSTEM Implant Co., Ltd.
301ho, Korea Electronics Cooperation B/D 114 Gasandigital2ro, Geumcheon-gu, Seoul-si, Korea, #153-803 Tel: +82 70-4394-5029 Fax: +82 51 850-4341 www.osstem.com
The subject and predicate devices are similar in indications, design, technology, functions, and principle of operation.
The differences between two devices are anode current, expose time, battery (part no., current, and maximum current) and battery case size.
Any differences do not raise different questions of safety and effectiveness than the predicate. Therefore, there is no difference between the subject and predicate with respect to the indications or technology.
- 11. Conclusion
In reference to the Federal Food, Drug, and Cosmetic Act, 21 CFR Part 807 and the comparison information provided substantial equivalent chart above, the OSSTEM IMPLANT Co., Ltd., believes that the portable X-ray system (Model: EXARO, Xray2GO) is substantially equivalent to its predicate device.
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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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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).
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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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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.
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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.