MAGNETOM Aera and MAGNETOM Skyra with Software syngo MR E11E with Ischemic Heart Disease (IHD) Workflow
K191050 · Siemens Medical Solutions USA, Inc. · LNH · Jul 12, 2019 · Radiology
Device Facts
Record ID
K191050
Device Name
MAGNETOM Aera and MAGNETOM Skyra with Software syngo MR E11E with Ischemic Heart Disease (IHD) Workflow
Applicant
Siemens Medical Solutions USA, Inc.
Product Code
LNH · Radiology
Decision Date
Jul 12, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1000
Device Class
Class 2
Indications for Use
Your MAGNETOM system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal and oblique cross sectional images and/or spectra, and that displays the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images and/or spectra may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images and/or spectra, when interpreted by a trained physician, yield information that may assist in diagnosis. Your MAGNETOM system may also be used for imaging during interventional procedures when performed with MR compatible devices such as in-room display and MR-Safe biopsy needles. Software syngo MR E11E with Ischemic Heart Disease (HD) Workflow, when used with a gadolinium-based contrast agent (GBCA) approved for cardiac MRI (CMRI) is indicated for the acquisition and display of images of myocardial perfusion (stress, rest) and late gadolinium enhancement (LGE) during post-contrast CMRI examination in patients with known or suspected coronary artery disease (CAD).
Device Story
MAGNETOM Aera and Skyra MRI systems utilize syngo MR E11E software with an Ischemic Heart Disease (IHD) Workflow. The device functions as an MRDD, acquiring and displaying cardiac images (perfusion and LGE) post-contrast administration. The IHD Workflow adds specific measurement protocols (DynamicTest, DynamicStress, DynamicRest, and high-resolution DE/LGE protocols) and a contrast injection prompt to the existing Cardiac Dot Engine. Operated by healthcare professionals in clinical settings, the system assists physicians in diagnosing CAD by providing standardized cardiac imaging sequences. The workflow guides the user through pre- and post-contrast CMRI examinations, facilitating consistent image acquisition. The output consists of cross-sectional images and derived physical parameters, which the physician interprets to assess myocardial function and structure, aiding in the clinical management of patients with suspected or known coronary artery disease.
Clinical Evidence
Evidence includes two prospective, multi-national, single-arm clinical studies (GadaCAD1 and GadaCAD2) involving 764 subjects with known or suspected CAD. Studies evaluated the efficacy of post-gadobutrol CMRI for CAD detection. Results supported the device's performance for the acquisition and display of myocardial perfusion and LGE images. Bench testing included image quality assessments of modified protocols and software verification/validation per FDA guidance.
Technological Characteristics
Magnetic resonance diagnostic device; 1.5T and 3T field strengths. Software-based workflow (IHD Workflow) added to Cardiac Dot Engine. Conforms to IEC 62304 (software lifecycle), IEC 60601-1 (safety), IEC 60601-1-2 (EMC), IEC 60601-2-33 (MR safety), and DICOM standards. Connectivity via standard hospital networks.
Indications for Use
Indicated for adult patients with known or suspected coronary artery disease (CAD) undergoing cardiac MRI (CMRI) examinations for myocardial perfusion (stress, rest) and late gadolinium enhancement (LGE) imaging using gadolinium-based contrast agents.
Regulatory Classification
Identification
A magnetic resonance diagnostic device is intended for general diagnostic use to present images which reflect the spatial distribution and/or magnetic resonance spectra which reflect frequency and distribution of nuclei exhibiting nuclear magnetic resonance. Other physical parameters derived from the images and/or spectra may also be produced. The device includes hydrogen-1 (proton) imaging, sodium-23 imaging, hydrogen-1 spectroscopy, phosphorus-31 spectroscopy, and chemical shift imaging (preserving simultaneous frequency and spatial information).
Special Controls
*Classification.* Class II (special controls). A magnetic resonance imaging disposable kit intended for use with a magnetic resonance diagnostic device 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
MAGNETOM Aera, MAGNETOM Skyra, MAGNETOM Verio and MAGNETOM Avanto with Software syngo MR D13A (K121434)
Submission Summary (Full Text)
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Siemens Medical Solutions USA, Inc. Milind Dhamankar, M.D. Sr. Clinical Affairs Specialist 40 Liberty Boulevard, Mailcode 65-1A MALVERN PA 19355
July 12, 2019
## Re: K191050
Trade/Device Name: MAGNETOM Aera and MAGNETOM Skyra with Software syngo MR E11E with Ischemic Heart Disease (IHD) Workflow Regulation Number: 21 CFR 892.1000 Regulation Name: Magnetic resonance diagnostic device Regulatory Class: Class II Product Code: LNH, LNI, and MOS Dated: April 17, 2019 Received: April 19, 2019
## Dear Dr. Dhamankar:
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 devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
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https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K191050
## Device Name
MAGNETOM Aera and MAGNETOM Skyra with Software syngo MR E11E with Ischemic Heart Disease (IHD) Workflow
Indications for Use (Describe)
Your MAGNETOM system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal and oblique cross sectional images and/or spectra, and that displays the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images and/or spectra may also be produced. Depending on the region of interest, contrast agents may be used. These images and the physical parameters derived from the images and/or spectra, when interpreted by a trained physician, yield information that may assist in diagnosis.
Your MAGNETOM system may also be used for imaging during interventional procedures when performed with MR compatible devices such as in-room display and MR-Safe biopsy needles.
Software syngo MR E11E with Ischemic Heart Disease (HD) Workflow, when used with a gadolinium-based contrast agent (GBCA) approved for cardiac MRI (CMRI) is indicated for the acquisition and display of images of myocardial perfusion (stress, rest) and late gadolinium enhancement (LGE) during post-contrast CMRI examination in patients with known or suspected coronary artery disease (CAD).
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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K191050
### 510(k) Summary: MAGNETOM Aera and MAGNETOM Skyra
Company: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, 65-1A Malvern, PA 19355
Date Prepared: April 17th, 2019
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of the Safe Medical Device Act of 1990 and 21 CFR § 807.92.
## 1. General Information Importer/Distributor:
Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard, Mail Code 65-1A Malvern, PA 19355, USA Establishment Registration Number: 2240869
## Manufacturing Sites:
Siemens Healthcare GmbH Henkestrasse 127 91052 Erlangen, Germany Establishment Registration Number: 3002808157
SIEMENS SHENZHEN MAGNETIC RESONANCE LTD. Siemens MRI Center Hi-Tech Industrial park (middle) Gaoxin C. Ave., 2nd Shenzhen 518057, P.R. CHINA Establishment Registration Number: 3004754211
### 2. Contact Person:
Milind Dhamankar, M.D. Siemens Medical Solutions, USA, Inc. 40 Liberty Boulevard Mail Code: 65-1A Malvern, PA 19355, USA Phone: (610) 448-6467 Fax: (610) 448-6547
Email: milind.dhamankar@siemens-healthineers.com
Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard Mail Code 65-1A Malvern, PA 19355 USA
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## Device Name and Classification: 3.
| Device Name | MAGNETOM Aera and MAGNETOM Skyra with<br>Software syngo MR E11E with Ischemic Heart<br>Disease (IHD) Workflow |
|-------------------------|---------------------------------------------------------------------------------------------------------------|
| Trade Name | MAGNETOM Aera, MAGNETOM Skyra |
| Classification Name | Magnetic Resonance Diagnostic Device<br>(MRDD) |
| Classification Panel: | Radiology |
| Regulation Number: | 21 CFR § 892.1000 |
| Device Class: | II |
| Primary Product Code: | LNH |
| Secondary Product Code: | LNI, MOS |
### Legally Marketed Predicate Device: 4.
| Device Name | MAGNETOM Aera, MAGNETOM Skyra,<br>MAGNETOM Verio and MAGNETOM Avanto<br>with Software syngo MR D13A |
|-------------------------|-----------------------------------------------------------------------------------------------------|
| Trade Names: | MAGNETOM Aera, MAGNETOM Skyra,<br>MAGNETOM Verio and MAGNETOM Avanto |
| 510(k) Number: | K121434, cleared November 05, 2012 |
| Classification Name | Magnetic Resonance Diagnostic Device<br>(MRDD) |
| Classification Panel: | Radiology |
| Regulation Number: | 21 CFR § 892.1000 |
| Device Class: | II |
| Primary Product Code: | LNH |
| Secondary Product Code: | LNI, MOS |
#### 5. Intended Use
The indications for use for the subject devices are the same as the predicate devices; only a section has been added to address the IHD Workflow feature (modification for this submission):
Your MAGNETOM system is indicated for use as a magnetic resonance diagnostic device (MRDD) that produces transverse, sagittal, coronal and oblique cross sectional images, spectroscopic images and/or spectra, and
Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard Mail Code 65-1A Malvern, PA 19355 USA
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Image /page/5/Picture/0 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 arranged in a circular pattern.
that displays the internal structure and/or function of the head, body, or extremities. Other physical parameters derived from the images and/or spectra may also be produced. Depending on the region of interest, contrast agents may be used. These images and/or spectra and the physical parameters derived from the images and/or spectra, when interpreted by a trained physician, yield information that may assist in diagnosis.
Your MAGNETOM system may also be used for imaging during interventional procedures when performed with MR compatible devices such as in-room display and MR-Safe biopsy needles.
Software syngo MR E11E with Ischemic Heart Disease (IHD) Workflow, when used with a gadolinium-based contrast agent (GBCA) approved for cardiac MRI (CMRI) is indicated for the acquisition and display of images of myocardial perfusion (stress, rest) and late gadolinium enhancement (LGE) during post-contrast CMRI examination in patients with known or suspected coronary artery disease (CAD).
### 6. Device Description:
MAGNETOM Aera and MAGNETOM Skyra with Software syngo MR E11E with IHD Workflow are the subject devices. The Software syngo MR E11E with IHD Workflow, when used with a gadolinium-based contrast agent (GBCA) approved for CMRI, extends the capability of the cleared Cardiac Dot Engine (K121434) for post-contrast CMRI exams for patients with known or suspected coronary artery disease (CAD). Software syngo MR E11E with IHD Workflow is available for MAGNETOM Aera and MAGNETOM Skyra excluding the 24-channel configuration.
- A. The cleared Cardiac Dot Engine (syngo MR D13A, K121434) helps acquisition and display of cardiac morphology and function (noncontrast CMRI).
A comprehensive post-contrast CMRI exam includes stress/rest perfusion and late gadolinium enhanced (LGE) imaging. To accomplish post-contrast CMRI imaging, basic morphologic / functional imaging (noncontrast CMRI) is required. Therefore, the cleared Cardiac Dot Engine (syngo MR D13A, K121434) is a pre-requisite to the subject devices.
- B. The Cardiac Dot Engine together with the IHD Workflow and a GBCA approved for post-contrast CMRI provides for a complete (pre- and post-contrast) examination.
## Device Modifications:
The list below describes new software features. The primary predicate devices are modified to include a new Dot Workflow named "Ischemic Heart Disease" (IHD) Workflow for a post-contrast CMRI exam using pulse sequences already cleared in the USA (syngo MR D13A,
Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard
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Image /page/6/Picture/0 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.
K121434). A new Dot Workflow "Ischemic Heart Disease" is added in Cardiac Dot Engine dropdown list, under the region "heart". This Dot Workflow includes the following: six new post-contrast CMRI measurement protocols and one workflow step:
New Measurement protocols:
- 1. DynamicTest (test protocol for perfusion imaging without contrast agent)
- 2. DynamicStress (protocol for perfusion imaging under stress conditions)
- 3. DynamicRest (protocol for perfusion imaging under rest conditions)
- 4. DE overview (protocol for delayed enhancement (DE) or LGE with low spatial resolution as an overview)
- 5. DE_seg_high-res_LAX (protocol for DE or LGE with high spatial resolution in long axis view)
- 6. DE seg high-res SAX (protocol for DE or LGE with high spatial resolution in short axis view)
New workflow step:
- 1. Inject contrast agent. This step prompts the user to start the contrast agent injection for post-contrast CMRI exams.
## Technological Characteristics 7.
The subject devices. MAGNETOM Aera and MAGNETOM Skyra with syngo MR E11E Software with IHD Workflow, have the same fundamental technological characteristics as the primary predicate devices, MAGNETOM Aera, MAGNETOM Skyra, MAGNETOM Verio and MAGNETOM Avanto with syngo MR D13A (K121434 cleared November 05, 2012) as well as the secondary predicate devices (K153343) with regard to the operational environment, programming language, operating system, and performance.
The software was modified to implement a new Dot IHD Workflow. Cardiac Dot Engine with IHD Workflow with software syngo MR E11E is composed of the Cardiac Dot Engine cleared in the US (K121434) and an additional Dot IHD Workflow to support post-contrast CMRI exam.
The MAGNETOM Aera and MAGNETOM Skyra with syngo MR E11E Software with IHD Workflow conforms to the standard for software medical devices (IEC 62304:2015) and other relevant IEC and NEMA standards.
While there are some differences in technological characteristics between the subject devices and predicate devices, including new software features, these differences have been tested and the conclusions from the non-clinical data suggests that the features bear an equivalent safety and performance profile to that of the predicate devices.
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Image /page/7/Picture/0 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 cluster of orange dots arranged in a pattern.
### 8. Nonclinical Tests
The following performance testing was conducted on the subject devices:
- 1. Image quality assessments of the modified measurement protocols
- 2. Software verification and validation testing was completed in accordance with the FDA guidance document, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (May 11, 2005)
The results from each set of tests demonstrate that the device performs as intended and is thus substantially equivalent to the predicate devices to which it has been compared.
### 9. Clinical Tests
Extensive clinical testing was performed to ensure the safety and efficacy of the subject devices.
Verification and validation of the subject devices with IHD Workflow in Software syngo MR E11E without contrast agent usage were completed; all tests passed. In addition, the validation with contrast agent usage for device performance and indications for use is supported by clinical images from the GadaCAD studies. Refer to Section 14.4 "Clinical Studies - Cardiac MRI" of the GADAVIST™ (gadobutrol) injection U.S. package insert for additional description of GadaCAD results.
Two prospectively controlled, multi-national, single-arm clinical studies (GadaCAD1 and GadaCAD2) were performed by Bayer HealthCare AG to evaluate efficacy of post-gadobutrol cardiac MRI (CMRI) for the detection of coronary artery disease (CAD) in adult subjects with known or suspected CAD.
A total of 764 subjects with suspected or known CAD were evaluated in the GadaCAD studies: 376 subjects in GadaCAD1 and 388 subjects in GadaCAD2.
A standard total dose of 0.1 mmol/kg BW of gadobutrol administered in 2 bolus injections (0.05 mmol/kg at peak stress, followed ~10 minutes later by 0.05 mmol/kg at rest) was used in both GadaCAD1 and GadaCAD2. No additional gadobutrol was administered for LGE imaging.
Investigational sites performed CMRI in 1.5T and 3T MAGNETOM scanners that were running the Cardiac Dot Engine Pro software on syngo MR VD13A (Siemens Healthineers).
Cardiac Dot Engine Pro software used in the GadaCAD studies had two components: a Cardiac Dot Engine component for non-contrast CMRI that is cleared in the United States (syngo MR VD13A, K121434) and an investigational component for post-contrast CMRI specific measurement protocols and workflow that was released by Siemens Healthineers as a Works in Progress (WIP) component (syngo MR VD13A) to support post-gadobutrol CMRI examinations (stress and rest perfusion and LGE). The
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Image /page/8/Picture/0 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.
Works in Progress (WIP) component (syngo MR VD13A) of
Cardiac Dot Engine Pro used to support post-gadobutrol CMRI examinations in the GadaCAD clinical studies is identical to the IHD Workflow of the subject devices, except for the addition of a real-time wall-motion CMRI measurement after pharmacologic stress agent administration and prior to contrast injection in the GadaCAD studies. In addition, in the GadaCAD studies, inversion time (TI) for LGE acquisition was fixed at a pre-specified value, and flexibility for per-patient adjustment in the subject devices and for the use of other GBCAs approved for CMRI was not employed.
In the GadaCAD studies, the devices generated CMRI images (stress and rest perfusion and LGE) that were interpreted by qualified independent readers (radiologists and cardiologists experienced in CMRI). The post-gadobutrol CMRI specific acquisition protocols supported adequate detection of CAD in two multi-center, multinational clinical studies.
Efficacy results of GadaCAD studies support the device performance and the indication of "acquisition and display of images of myocardial perfusion (stress, rest) and late gadolinium enhancement (LGE) during post-contrast cardiac MR (CMRI) examination".
Select GadaCAD case studies are provided to illustrate acquired perfusion and LGE imaging.
### 10. Safety and Effectiveness
The device labeling contains instructions for use and any necessary cautions and warnings to ensure safe and effective use of the device.
Risk management is ensured via ISO 14971:2007 compliance to identify and provide mitigation to potential hazards in a risk analysis beginning early in the design phase and continuing throughout the development of the product. These risks are controlled via measures realized in hardware and software development, testing, and product labeling. To minimize risks, Siemens adheres to recognized and established industry practices and standards, such as the IEC 60601-1 series, to minimize electrical and mechanical risk. Software development is carried out according to the IEC 62304 standard for medical device software. Furthermore, the device is intended for healthcare professionals familiar with and responsible for the acquisition and post processing of magnetic resonance images.
The MAGNETOM Aera and MAGNETOM Skyra with syngo MR E11E Software with IHD Workflow conforms to the applicable FDA recognized and international IEC, ISO and NEMA.
| Recognition<br>Number | Product Area | Title of Standard | Reference<br>Number and date | Standards<br>Development<br>Organization |
|-----------------------|--------------|-------------------|------------------------------|------------------------------------------|
|-----------------------|--------------|-------------------|------------------------------|------------------------------------------|
Siemens Medical Solutions USA, Inc.
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| Recognition<br>Number | Product<br>Area | Title of Standard | Reference<br>Number and date | Standards<br>Development<br>Organization |
|-----------------------|-----------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|------------------------------------------|
| 19-4 | General | C1:2009/(R)2012 and A2:2010/(R)2012<br>(Consolidated Text) Medical electrical<br>equipment - Part 1: General<br>requirements for basic safety and<br>essential performance<br>(IEC 60601-1:2005, MOD) | ES60601-<br>1:2005/(R)2012<br>and A1:2012 | AAMI ANSI |
| 19-8 | General | Medical electrical equipment - Part 1-2:<br>General requirements for basic safety<br>and essential performance - Collateral<br>Standard: Electromagnetic disturbances<br>- Requirements and tests | 60601-1-2<br>Edition<br>2014-02 | IEC |
| 12-295 | Radiology | Medical electrical equipment - Part 2-33:<br>Particular requirements for the basic<br>safety and essential performance of<br>magnetic resonance equipment for<br>medical diagnostic | 60601-2-33<br>3.2 B:2015 | Ed. IEC |
| 5-40 | General | Medical devices - Application of risk<br>management to medical devices | 14971 Second<br>edition 2007-03-<br>01 | ISO |
| 5-89 | General | Medical electrical equipment - Part 1-6:<br>General requirements for basic safety<br>and essential performance - Collateral<br>standard: Usability | 60601-1-6<br>Edition<br>2013-10 | IEC |
| 5-114 | General | Medical devices - Application of usability<br>engineering to medical devices | 62366-1:2015 | AAMI<br>ANSI<br>IEC |
| 13-79 | Software | Medical device software - Software life<br>cycle processes | 62304 Edition<br>1.1 2015-06 | IEC |
| 12-300 | Radiology | Digital Imaging and Communications in<br>Medicine (DICOM) Set 03/16/2012<br>Radiology | PS 3.1 - 3.20<br>(2016) | NEMA |
### 11. Substantial Equivalence and Conclusion
The subject devices, MAGNETOM Aera and MAGNETOM Skyra with syngo MR E11E Software with IHD Workflow, have the same intended use as the primary predicate devices, MAGNETOM Aera, MAGNETOM Skyra, MAGNETOM Verio and MAGNETOM Avanto with syngo MR D13A (K121434).
The software was modified to implement a new Dot workflow called IHD Workflow. Cardiac Dot Engine with IHD Workflow with software syngo MR E11E is composed of the Cardiac Dot Engine cleared in the USA (K121434) and an additional Dot IHD Workflow to support post-contrast CMRI examination.
While there is a difference in technological characteristics between the subject devices and predicate devices (the new software workflow), this difference
40 Liberty Boulevard Mail Code 65-1A Malvern, PA 19355 USA
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Image /page/10/Picture/0 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 arranged in a circular pattern.
has been tested and the conclusions from the non-clinical tests have shown that there were no additional questions of safety and effectiveness raised.
Siemens believes that the subject devices, MAGNETOM Aera and MAGNETOM Skyra with syngo MR E11E Software with IHD Workflow are substantially equivalent to the predicate devices, MAGNETOM Aera, MAGNETOM Skyra, MAGNETOM Verio and MAGNETOM Avanto with syngo MR D13A and syngo MR E11E for MAGNETOM Aera and MAGNETOM Skyra.
40 Liberty Boulevard Mail Code 65-1A Malvern, PA 19355 USA
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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.