K182517 · Siemens Medi Cal Solutions, Inc. · KPR · Jan 11, 2019 · Radiology
Device Facts
Record ID
K182517
Device Name
MULTIX Impact
Applicant
Siemens Medi Cal Solutions, Inc.
Product Code
KPR · Radiology
Decision Date
Jan 11, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1680
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The MULTIX Impact system is a radiographic system used in hospitals, clinics, and medical practices. MULTIX Impact enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The MULTIX Impact system is not meant for mammography. The MULTIX Impact uses digital detectors for generating diagnostic images by converting x-rays into image signals. The MULTIX Impact is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.
Device Story
Radiographic X-ray system for hospitals/clinics; operated by healthcare professionals. Inputs: X-ray radiation attenuated by patient anatomy. System components: floor-mounted X-ray tube, Bucky wall stand, motorized floating table, X-ray generator, and wireless digital detectors (Trixell Pixium 3543 DR/EZh). Transformation: X-rays converted to digital signals via detectors; processed by system software (VA10) on Windows 10 platform. Output: Diagnostic images displayed on high-resolution touch screen monitor. Features: optional positioning assistance camera, wireless remote control, and grid suppression algorithm for 40-line grids. Clinical utility: aids in diagnostic assessment of skeletal and soft tissue structures. Benefits: enables high-quality radiographic imaging across diverse patient populations; improved workflow via motorized components and digital integration.
Clinical Evidence
Bench testing only. Verification and validation testing performed to support modifications. Testing included integration and functional testing, confirming performance is comparable to the predicate device. No clinical data presented.
Indicated for radiographic imaging of the whole body (skull, chest, abdomen, extremities) in pediatric, adult, and bariatric patients. Not indicated for mammography.
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.
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Siemens Medical Solutions USA, Inc. % Denise Adams, RAC Regulatory Affairs Specialist 40 Liberty Boulevard, Mail Code: 65-1A MALVERN PA 19355
Re: K182517
Trade/Device Name: MULTIX Impact Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: KPR Dated: November 28, 2018 Received: November 29, 2018
Dear Ms. Adams:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for
January 11, 2019
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael D. 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
510(k) Number (if known)
K182517
Device Name
MULTIX Impact
#### Indications for Use (Describe)
The MULTIX Impact system is a radiographic system used in hospitals, clinics, and medical practices. MULTIX Impact enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pedianc, adult and bariatic patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The MULTIX Impact system is not meant for mammography.
The MULTIX Impact uses digital detectors for generating diagnostic images by converting x-rays into image signals. The MULTIX Impact is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.
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K182517
Image /page/3/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the word "Healthineers" is a cluster of orange dots.
# 510(k) Summary: MULTIX Impact
Company: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355
Date Prepared: September 11, 2018
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR § 807.92.
# 1. General Information
Importer / Distributor Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 Establishment Registration Number 2240869
#### Location of Manufacturing Site
Siemens Shanghai Medical Equipment Ltd. 278 Zhou Zhu Road, Shanghai 201318. China Establishment Registration Number 3003202425
Siemens Healthcare GmbH Siemensstrasse 1 Forchheim, Germany 91301 Establishment Registration Number: 3004977335
#### 2. Contact Person
Denise Adams, RAC Regulatory Affairs Specialist Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355 610-448-6139 adams.denise@siemens-healthineers.com
Siemens Medical Solutions USA, Inc.
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Image /page/4/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange. To the right of the word "Healthineers" is a graphic of orange dots arranged in a circular pattern.
# 3. Device Name and Classification
| Trade Name: | MULTIX Impact |
|----------------------------|-------------------------|
| Classification Name: | Stationary X-Ray System |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR §892.1680 |
| Device Class: | Class II |
| Product Code: | KPR |
## 4. Legally Marketed Predicate Device
| Trade Name: | Multix Fusion Max |
|-----------------------|-------------------------|
| 510(k) #: | K162971 |
| Clearance Date: | November 22, 2016 |
| Classification Name: | Stationary X-Ray System |
| Classification Panel: | Radiology |
| CFR Section: | 21 CFR §892.1680 |
| Device Class: | Class II |
| Product Code: | KPR |
#### 5. Device Description
The MULTIX Impact Radiography X-ray system is a modular system of X-ray components (floor-mounted X-ray tube, Bucky wall stand, Bucky table, X-ray generator, portable wireless detectors) similar to the predicate the Multix Fusion Max. This 510(k) submission describes modifications to the predicate device the Multix Fusion Max cleared via K162971. The following modifications have been made to the cleared predicate device and the new system will be branded the MULTIX Impact:
- A new 43×35cm Wireless detector, 3543DR 1.
- 2. A new X-ray tube and a new generator
- 3. An optional 40 line grid with grid suppression algorithm
- 4. Wireless Remote Control Console
- ર. An optional All-in-one PC containing touch screen function
- An optional positioning assistance camera 6.
- Upgrade software to VA10 7.
- 8. Upgrade operator system from Windows XP to Windows 10
## 6. Indications for Use
The MULTIX Impact system is a radiographic system used in hospitals, clinics, and medical practices. MULTIX Impact enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The MULTIX Impact system is not meant for mammography.
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Image /page/5/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange. To the right of the words is a pattern of orange dots.
The MULTIX Impact uses digital detectors for generating diagnostic images by converting Xrays into image signals. The MULTIX Impact is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes.
# 7. Substantial Equivalence
The MULTIX Impact is a modification to the predicate device the Multix Fusion Max cleared via K162971. It is within the same classification with similar indications for use and the same mechanical design as the predicate device. The MULTIX Impact is substantially equivalent to the predicate device and documentation is provided to support a claim of substantial equivalence.
# 8. Summary of Technological Characteristics of the Subject Device as Compared with the Predicate Device
The MULTIX Impact is comparable in indications for use, design, material, functionality, technology, energy source and is substantially equivalent to the commercially available Siemens' Multix Fusion Max. It uses the same or similar components cleared in the Multix Fusion Max (e.g. collimator, patient table, Bucky wall stand).
The components of the subject device have many of the same technological characteristics as the ones from the predicate device. There are several technological characteristics that differ slightly as shown in the comparison tables.
Testing and validation have been successfully completed and test results show that the subject device MULTIX Impact with all of its components are comparable to the predicate device and therefore is substantially equivalent to the predicate device.
The modifications made to the subject device MULTIX Impact do not affect the intended use of the device nor do they alter its fundamental scientific technology from the 510(k) cleared predicate device the Multix Fusion Max.
The following tables compare the main performance data of the subject device with the predicate device to substantiate equivalence.
| Attribute | MULTIX Impact<br>(subject) | Multix Fusion Max<br>K162971<br>(predicate) | Comparison<br>Results |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------|
| Indications<br>for Use | The MULTIX Impact system<br>is a radiographic system used<br>in hospitals, clinics, and<br>medical practices. MULTIX<br>Impact enables radiographic<br>exposures of the whole body | The Multix Fusion Max<br>system is a radiographic<br>system used in hospitals,<br>clinics, and medical<br>practices. Multix Fusion Max<br>enables radiographic | Intended use is<br>the same.<br>Indications for<br>use have been<br>reworded to |
## Table 1: Indications for Use Comparison
Siemens Medical Solutions USA, Inc.
40 I iberty Boulevard Malvern PA 19355-9998 USA
Tel.: +1-888-826-9702 usa.siemens.com/healthineers
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Image /page/6/Picture/1 description: The image shows the Siemens Healthineers logo. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the word "Healthineers" is a series of orange dots that are arranged in a pattern.
| including: skull, chest,<br>abdomen, and extremities<br>and may be used on<br>pediatric, adult and bariatric<br>patients. Exposures may be<br>taken with the patient sitting,<br>standing, or in the prone<br>position. The MULTIX<br>Impact system is not meant<br>for mammography.<br><br>The MULTIX Impact uses<br>digital detectors for<br>generating diagnostic images<br>by converting X-rays into<br>image signals.<br><br>The MULTIX Impact is also<br>designed to be used with<br>conventional film/screen or<br>Computed Radiography (CR)<br>cassettes. | exposures of the whole body<br>including: skull, chest,<br>abdomen, and extremities<br>and may be used on<br>pediatric, adult and bariatric<br>patients. Exposures may be<br>taken with the patient sitting,<br>standing, or in the prone<br>position. The Multix Fusion<br>Max system is not meant for<br>mammography.<br><br>The Multix Fusion Max uses<br>a mobile (wired), or fixed<br>(integrated) or wireless<br>digital detector for<br>generating diagnostic images<br>by converting X-rays into<br>image signals.<br><br>The Multix Fusion is also<br>designed to be used with<br>conventional film/ screen or<br>Computed Radiography (CR)<br>cassettes. | simplify. |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
40 Liberty Boulevard
Malvern, PA 19355-9998
USA
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Image /page/7/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the word "Healthineers" are a series of orange dots that are arranged in a pattern.
| Attribute | MULTIX Impact<br>(subject) | Multix Fusion Max<br>K162971<br>(predicate) | Comparison<br>Results |
|-----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Operating<br>System | Windows 10 | Windows XP | New operating<br>system, does<br>not affect safety<br>or effectiveness |
| Suppression<br>algorithm for<br>low line grid | The new 40 low line grid<br>requires a suppression<br>algorithm to suppress line<br>artifacts | N/A | Performance<br>testing<br>concluded does<br>not affect image<br>quality. |
| Post-<br>processing<br>software | -Contrast<br>-Detail<br>-Latitude<br>-Noise<br>-WLShift<br>-WWShift | -Amplification<br>-Edge Enhancement<br>-Harmonization<br>-Noise Reduction<br>-Center Shift<br>-Width Factor | Performance<br>testing<br>concluded does<br>not affect image<br>quality. |
| Floor<br>mounted<br>support | Mechanical | N/A | Does not affect<br>safety or<br>effectiveness |
| X-ray tube<br>assembly | 80 kW<br><br>Two-focus | 80 kW<br><br>Two-focus | Same |
| Collimator | Standard collimator (ACSS) | Standard collimator(ACSS) | Same |
| Optional<br>collimator | Manual collimator | N/A | Does not affect<br>safety or<br>effectiveness |
| Optional<br>digital<br>camera | Camera on collimator to aid<br>in patient positioning | N/A | Does not affect<br>safety or<br>effectiveness |
| Attribute | MULTIX Impact<br>(subject) | Multix Fusion Max<br>K162971<br>(predicate) | Comparison<br>Results |
| Patient Table | Radiographic table<br>motorized with floating table<br>top and motorized Bucky<br>tray with charging in tray<br>function (wireless detector) | Radiographic table<br>motorized with floating table<br>top and manual Bucky tray<br>with charging in tray<br>function (wireless detector) | Improvement of<br>Bucky<br>movement to<br>motorized.<br>Does not affect<br>safety or<br>effectiveness |
| | Radiographic table<br>motorized with floating table<br>top and motorized Bucky<br>tray (wireless detector) | Radiographic table<br>motorized with floating table<br>top and manual Bucky tray<br>with charging in tray<br>function (wireless detector) | Improvement of<br>Bucky<br>movement to<br>motorized<br>without<br>charging<br>function in tray<br>Does not affect<br>safety or<br>effectiveness |
| | Fixed radiographic table with<br>floating table top and manual<br>Bucky tray (portable wireless<br>detector) | N/A | Does not affect<br>safety or<br>effectiveness |
| Bucky Wall<br>Stand | BWS for wireless detector<br>Vertical motorized and<br>charging in tray | BWS for wireless detector<br>Vertical motorized and<br>charging in tray | Same |
| | BWS for wireless detector<br>Vertical motorized | BWS for wireless detector<br>Vertical motorized and<br>charging in tray | No charging<br>tray. Does not<br>affect safety or<br>effectiveness |
| | BWS for wireless detector<br>Manual movement in z-axis | N/A | Does not affect<br>safety or<br>effectiveness |
| Attribute | MULTIX Impact<br>(subject) | Multix Fusion Max<br>K162971<br>(predicate) | Comparison<br>Results |
| Touch<br>Interface | Graphical user interface | Graphical user interface | Same |
| X-ray<br>generator | 55kW, 65kW or 80kW | 55kW, 65 kW or 80 kW | Same |
| Operating<br>modes | RAD Single Exposure | RAD Single Exposure | Same |
| Imaging<br>System | All in one PC based<br>high resolution digital<br>touch screen function as<br>option | Fluorospot Compact PC<br>based<br>high resolution digital | Addition of<br>touch screen<br>function as<br>option. Does<br>not affect safety<br>or effectiveness |
| Display | Black & White<br>Color<br>Size Ratio 16:9 | Black & White<br>Color<br>Size Ratio 4:3 | Different size<br>ratio. Does not<br>affect safety or<br>effectiveness |
| DICOM 3<br>Functions | Send, StC, Print,<br>Query/Retrieve, Get<br>Worklist, MPPS | Send, StC, Print,<br>Query/Retrieve, Get<br>Worklist, MPPS | Same |
| Radiographic<br>Grid | 92-line grid<br>(ratio 13:1)<br>40-line grid<br>(ratio 13:1) | 92-line grid<br>(ratio 13:1)<br>85-line grid<br>(ratio 5:1) (optional) | Same ratio<br>with new<br>addition of 40-<br>line grid.<br>Performance<br>testing<br>concluded that<br>combined with<br>suppression<br>algorithm does<br>not affect image<br>quality |
| Accessory | Wireless Remote Control<br>Console via bluetooth | Remote Control console | Improvement of<br>wireless<br>function. Does |
#### Table 2: Subject Device Compared to the Predicate
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Image /page/8/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the word "Healthineers" is a series of orange dots that form a curved line.
40 Liberty Boulevard
Malvern, PA 19355-9998
USA
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Image /page/9/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange. To the right of the word "Healthineers" is a graphic of orange dots.
Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard
Malvern, PA 19355-9998
USA
Tel.: +1-888-826-9702
usa.siemens.com/healthineers
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Image /page/10/Picture/1 description: The image contains the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the word "Healthineers" is a graphic of orange dots.
| Attribute | MULTIX Impact<br>(subject) | Multix Fusion Max<br>K162971<br>(predicate) | Comparison<br>Results |
|-----------|----------------------------|---------------------------------------------|---------------------------------------|
| | | | not affect safety<br>or effectiveness |
40 Liberty Boulevard
Malvern, PA 19355-9998
USA
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Image /page/11/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the text is a graphic of orange dots arranged in a circular pattern.
| Table 3: Comparison of Trixell Pixium 3543 DR to the Predicate Trixell Pixium | | |
|-------------------------------------------------------------------------------|--|--|
| 3543 EZh | | |
| Technical<br>Specifications | Trixell Pixium<br>3543 DR<br>detector<br>(wireless)<br>(subject) | Trixell Pixium<br>3543 EZh<br>detector<br>(wireless)<br>(subject) | Trixell Pixium<br>3543 EZh<br>detector<br>(wireless)<br>(predicate) | Comparison<br>Results |
|----------------------------------------------|------------------------------------------------------------------|-------------------------------------------------------------------|---------------------------------------------------------------------|-------------------------------------|
| Dimensions | 345 mm x 426 mm | 348 mm x 424 mm | 349 mm x 425 mm | Difference not significant |
| Resolution | 2156 x 2662 pixels | 2350 x 2866 pixels | 2356 x 2872 pixels | Difference not significant |
| Pixel size | 160 $ \mu $ m | 148 $ \mu $ m | 148 $ \mu $ m | Difference not significant/<br>Same |
| Semiconductor<br>Material | Amorphous silicon, a-Si | Amorphous silicon, a-Si | Amorphous silicon, a-Si | Same |
| Scintillator | Cesium iodide (CsI) | Cesium iodide (CsI) | Cesium iodide (CsI) | Same |
| Acquisition<br>depth | 16 bit | 16 bit | 16 bit | Same |
| DQE (Detective<br>Quantum<br>Efficiency) | DQE @ 1 lp/mm (2 $ \mu $ Gy), 51% | DQE @ 1 lp/mm (2 $ \mu $ Gy), 51% | DQE @ 1 lp/mm (2 $ \mu $ Gy), 51% | Same |
| MTF<br>(Modulations<br>transfer<br>function) | MTF @ 1 lp/mm,62% | MTF @ 1 lp/mm, 63% | MTF @ 1 lp/mm,63% | Difference not significant/<br>Same |
## 9. Nonclinical Performance Testing
Non-clinical tests were conducted for the MULTIX Impact during product development. The modifications described in this Premarket Notification are supported with verification and validation testing.
MULTIX Impact conforms to the following standards: IEC 60601-1:2012; IEC 60601-1-2:2014; IEC 60601-1-3:2008+A1:2013; IEC 62366-1:2015; ISO 14971:2007; IEC 60601-1-6:2013; IEC 62304:2015; IEC 60601-2-28:2010-03; IEC 60601-2-54:2015-04; NEMA PS 3.1 - 3.20 (2016) and ISO 10993-1:2009.
Software Documentation for a Moderate Level of Concern software per FDA's Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" issued on May 11, 2005 is also included as part of this submission. The performance data demonstrates continued conformance with special controls for medical devices containing software. Non-clinical tests (integration and functional) were conducted on the MULTIX Impact during product development.
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Image /page/12/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the words is a graphic of orange dots.
The Risk analysis was completed and risk control implemented to mitigate identified hazards. The testing results support that all the software specifications have met the acceptance criteria. Testing for verification and validation for the device was found acceptable to support the claims of substantial equivalence.
## 10. General Safety and Effectiveness Concerns
Instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner. Several safety features including visual and audible warnings are incorporated into the system design. In addition, the MULTIX Impact Radiography X-ray system is continually monitored, and if an error occurs, the system functions will be blocked and an error message will be displayed.
Risk management is ensured via a hazard analysis which is used to identify potential hazards. These potential hazards are controlled via software development, verification and validation testing. To minimize electrical, and radiation hazards, Siemens adheres to recognized and established industry practice, and all equipment is subject to final performance testing. Furthermore the operators are health care professionals familiar with and responsible for the X-ray examinations to be performed.
#### 11. Conclusion as to Substantial Equivalence
The MULTIX Impact has similar indications for use as the predicate Multix Fusion Max. The operating environment and mechanical design are similar. It is Siemens opinion, that the MULTIX Impact is substantially equivalent to the Multix Fusion Max, cleared in K162971 on November 22, 2016.
Verification and validation testing demonstrates that the MULTIX Impact should perform as intended. The non-clinical test data demonstrate that the MULTIX Impact device performance is comparable to the predicate device that is currently marketed for the same intended use.
In summary, Siemens is of the opinion that the MULTIX Impact does not introduce any new potential safety risk and is substantially equivalent to and performs as well as the predicate device.
#### 12. Guidance documents
The following FDA guidance documents were utilized in the documentation of this Premarket Notification:
- Content of Premarket Submissions for Management of Cybersecurity in ● Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014
- Information to Support a Claim of Electromagnetic Compatibility (EMC) of Electrically-Powered Medical Devices Guidance for Industry
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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.