RCT800
Device Facts
| Record ID | K230753 |
|---|---|
| Device Name | RCT800 |
| Applicant | Ray Co., Ltd. |
| Product Code | OAS · Radiology |
| Decision Date | Apr 11, 2023 |
| Decision | SESE |
| Submission Type | Special |
| Regulation | 21 CFR 892.1750 |
| Device Class | Class 2 |
| Attributes | Pediatric |
Indications for Use
RCT800 is CBCT and panoramic x-ray imaging system with cephalometric. Which is intended to radiographic examination of the dento-maxillofacial, sinus, TMJ, Airway for diagnostic support for adult and pediatric patients. And a model scan is included as an option. Cephalometric image is also includes wrist to obtain carpus images for growth and maturity assessment for orthodontic treatment. The device is to be operated and used by dentists or other legally qualified health care professionals.
Device Story
RCT800 is a 3D CBCT and panoramic X-ray system for dental/maxillofacial imaging. Device uses a rotating C-arm with an integrated X-ray tube and detector to capture multi-angle projections, which are reconstructed into 3D volumes or 2D panoramic/cephalometric images. Operated by dentists or qualified professionals in clinical settings. System supports optional dental model scanning and carpus imaging for orthodontic assessment. Output consists of diagnostic X-ray images viewed by clinicians to support treatment planning and diagnosis. Device benefits patients by providing high-resolution anatomical visualization for dental and orthodontic procedures.
Clinical Evidence
Clinical evidence included sample images collected from two clinical sites using the new detectors. Images were obtained from patients of varying age, gender, and size. A licensed practitioner reviewed the images and confirmed they were of acceptable diagnostic quality. No formal clinical trial with primary endpoints was required; substantial equivalence is primarily supported by bench testing and performance specifications.
Technological Characteristics
CBCT/Panoramic/Cephalometric X-ray system. Components: X-ray tube, high-frequency generator, digital flat-panel detectors (e.g., FXDD-1724RA, FXDD-1012CHA, XID-C24DC). Connectivity: Giga-Ethernet, DICOM 3.0 compatible. Software: RayScan. Standards: IEC 60601-1, IEC 60601-1-3, IEC 60601-2-63, IEC 60601-1-2. Reconstruction: Filtered Back Projection (FBP).
Indications for Use
Indicated for radiographic examination of dento-maxillofacial, sinus, TMJ, and airway structures in adult and pediatric patients (recommended age >5 years). Includes optional model scanning and carpus imaging for orthodontic growth/maturity assessment.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
Submission Summary (Full Text)
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April 11, 2023
Ray Co., Ltd. % Changhwan Lee RA Manager 1F~3F, 4F(Part), 5F, 265, Daeji-Ro, Suji-gu Yongin-si, Gyeonggi-do 16882 SOUTH KOREA
Re: K230753
Trade/Device Name: RCT800 Regulation Number: 21 CFR 892.1750 Regulation Name: Computed Tomography X-Ray System Regulatory Class: Class II Product Code: OAS Dated: March 15, 2023 Received: March 17, 2023
Dear Changhwan Lee:
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
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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 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,
Lu Jiang
Lu Jiang, Ph.D. Assistant Director Diagnostic X-Ray Systems Team DHT8B: Division of Imaging Devices and Electronic Products OHT8: Office of 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) K230753
Device Name RCT800
Indications for Use (Describe)
RCT800 is CBCT and panoramic x-ray imaging system with cephalometric.
Which is intended to radiographic examination of the dento-maxillofacial, sinus, TMJ, Airway for diagnostic support for adult and pediatric patients. And a model scan is included as an option.
Cephalometric image is also includes wrist to obtain carpus images for growth and maturity assessment for orthodontic treatment.
The device is to be operated and used by dentists or other legally qualified health care professionals.
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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#### K230753 510(k) Summary
## 1. 510(k) Summary
The 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR Part 807.92.
# 2. Date
March 6, 2023
| Applicant | | Ray Co., Ltd. |
|----------------|---------|-------------------------------------------------------------------------|
| Address | | 1F~3F, 4F(Part), 5F, 265, Daeji-ro, Suji-gu, Yongin-si,<br>16882, Korea |
| Manufacturer | Name | Ray Co., Ltd. |
| | Address | 1F~3F, 4F(Part), 5F, 265, Daeji-ro, Suji-gu, Yongin-si,<br>16882, Korea |
| | Tel | +82-31-605-1000 |
| | Fax | +82-2-6280-5534 |
| Contact Person | Name | Changhwan Lee |
| | Email | ch0406.lee@raymedical.co.kr |
#### 3. Administrative Information
# 4. Device Information
| Trade/Proprietary Name | RCT800 | |
|------------------------|---------------------------------------------------------------|------------------------------------|
| Common Name | Dental Panoramic/Tomography and Cephalometric X-ray<br>System | |
| Classification<br>Name | Device | X-ray tomography, computed, dental |
| | Regulation<br>Number | 21 CFR 892.1750 |
| | Class | 2 |
| | Product Code | OAS |
| | Review Panel | Radiology |
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| Parameter | Predicate Device-1 | Predicate Device-2 | |
|--------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | RCT800 | RCT700 | |
| Manufacturer | Ray Co., Ltd | Ray Co., Ltd | |
| 510(K) Number | K192737 | K213226 | |
| Classification<br>name | Computed tomography x-ray system | Computed tomography x-ray system | |
| Regulation<br>number | 892.1750 | 892.1750 | |
| Primary product<br>code | OAS | OAS | |
| Parameter | Proposed Device | Predicate Device-1 | Predicate Device-2 |
| Manufacturer | Ray Co., Ltd. | Ray Co., Ltd. | Ray Co., Ltd. |
| Device name | RCT800 | RCT800 | RCT700 |
| 510(K) Number | (Special 510K) | K192737<br>(Traditional 510K) | K213226<br>(Traditional 510K) |
| Common Name | Dental panoramic/tomography and<br>cephalometric x-ray system | Dental panoramic/tomography and<br>cephalometric x-ray system | Dental panoramic/tomography and<br>cephalometric x-ray system |
| Indications for use | RCT800 is CBCT and panoramic x-ray<br>imaging system with cephalometric.<br>Which is intended to radiographic<br>examination of the dento-maxillofacial,<br>sinus, TMJ, Airway for diagnostic<br>support for adult and pediatric patients.<br>And a model scan is included as an<br>option.<br>Cephalometric image is also includes<br>wrist to obtain carpus images for growth<br>and maturity assessment for orthodontic<br>treatment.<br>The device is to be operated and used<br>by dentists or other legally qualified<br>health care professionals. | RCT800 is CBCT and panoramic x-ray<br>imaging system with cephalometric.<br>Which is intended to radiographic<br>examination of the dento-maxillofacial,<br>sinus, TMJ, Airway for diagnostic<br>support for adult and pediatric patients.<br>And a model scan is included as an<br>option.<br>Cephalometric image is also includes<br>wrist to obtain carpus images for growth<br>and maturity assessment for orthodontic<br>treatment.<br>The device is to be operated and used<br>by dentists or other legally qualified<br>health care professionals. | RCT700 is CBCT and panoramic x-ray<br>imaging system with cephalometric.<br>Which is intended to radiographic<br>examination of the dento-maxillofacial,<br>sinus, TMJ, Airway and ENT structure<br>for diagnostic support for adult and<br>pediatric patients. And a model scan is<br>included as an option. Cephalometric<br>image is also includes wrist to obtain<br>carpus images for growth and maturity<br>assessment for orthodontic treatment.<br>The device is to be operated and used<br>by dentists or other legally qualified<br>health care professionals. |
| Mode of Operation | Same as predicate device #1 | Continuous operation with intermittent,<br>stated permissible loading | Same as predicate device #1 |
| 3D technology | Same as predicate device #1 | CBCT Cone beam<br>Computed Tomography | Same as predicate device #1 |
| reconstruction algorithm | Same as predicate device #1 | FBP(Filtered Back Projection) | Same as predicate device #1 |
#### 5. Predicate device
## 6. Device Description
The system's purpose is RCT800, a 3D computed tomography scanner for scanning hard tissues like bones and teeth. By rotating the c-arm, which is embedded with an all-in-one x-ray tube and a detector on each end, CBCT images of the dental maxillofacial area can be attained by recombining data from the same level that is scanned from different angles. Additionally, the system includes a panoramic image scanning function for attaining images of the whole teeth, a cephalometric scanning option for attaining a cephalic image, and a Model Scan option for attaining a dental model CBCT image.
#### 7. Indication for use
RCT800 is CBCT and panoramic x-ray imaging system with cephalometric. Which is intended to radiographic examination of the dento-maxillofacial, sinus, TMJ, Airway for diagnostic support for adult and pediatric patients. And a model scan is included as an option.
Cephalometric image is also includes wrist to obtain carpus images for growth and maturity assessment for orthodontic treatment.
The device is to be operated and used by dentists or other legally qualified heath care professionals.
#### 8. Patient population
This device is intended to acquire diagnostic x-ray images of adult and pediatric individuals/patients without restriction on ethnic group, gender, weight, health status, or condition.
We recommend that patients who undergo X-ray diagnostic radiation exposure be over 5 years old.
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# 9. Comparison with predicate device
The following table provides the summary of the technological characteristics of RCT800 compared to the predicate device.
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| | Performance Specification | | 1) CBCT Computed tomography<br>- Patient<br>- Dental Model Scan(Optional)<br>2) Panoramic<br>3) Cephalometric(optional)<br>- One shot type<br>- Scan type | 1) CBCT Computed tomography<br>- Patient<br>2) Panoramic<br>3) Cephalometric(optional)<br>- One shot type<br>- Scan type | |
|--|---------------------------|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|-----------------------------|
| | Functional Option | | Base<br>CT+PANO<br>Option(CEPH)<br>CT + PANO + SCAN CEPH<br>CT + PANO + One shot(One shot,<br>Standard Type)<br>CT + PANO + One shot(One shot,<br>Large Type). | Same as predicate device #1 | |
| | Detector<br>Type | CT | FXDD-1724RA | FXDD-0606CA | Same as predicate device #1 |
| | | | Same as predicate device #1 | FXDD-1012CHA | Jupi0606X |
| | | PANO | FXDD-1724RA | FXDD-0606CA | Same as predicate device #1 |
| | | | Same as predicate device #1 | FXDD-1012CHA | Jupi0606X |
| | Detector<br>Type | Ceph (Scan) | Same as predicate device #1 | XID-C24DC | Same as predicate device #1 |
| | | Ceph (One shot) | Same as predicate device #2 | 1717SCC | FXRD-1717VA |
| | | | Same as predicate device #2 | PaxScan 2530C | FXDD-1012CA |
| | Exposure switch Type | | Same as predicate device #1 | "Deadman" Button type | Same as predicate device #1 |
| | Main Components | | Same as predicate device #1 | Ceph Apparatus | Same as predicate device #1 |
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| | | | | Automatic Collimator | Same as predicate device #1 | CT exams<br>Panoramic exams<br>Cephalometric exams | Same as predicate device #1 |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|-----------------------------|----------------------------------------------------------------|----------------------------------------------------------------|-----------------------------|
| Same as predicate device #1 | Vertical Carriage | Same as predicate device #1 | | Display Type | Same as predicate device #1 | TFT LCD type(Normally black)<br>*1280x800 pixel | Same as predicate device #1 |
| Same as predicate device #1 | Rotator | Same as predicate device #1 | | Class | Same as predicate device #1 | Class I with type B applied parts<br>according to IEC 60601-1 | Same as predicate device #1 |
| Same as predicate device #1 | X-RAY Generator | Same as predicate device #1 | | Focal size | Same as predicate device #2 | Patient 0.5<br>Model scan 0.04 (Optional) | 0.5 |
| Same as predicate device #1 | X-ray tube | Same as predicate device #1 | | Field of View(CT) | FXDD-1724RA : Max.180x160 mm<br>FXDD-1012CHA : Max. 200x200 mm | FXDD-0606CA : Max.160x100 mm<br>FXDD-1012CHA : Max. 200x200 mm | Max. 160x100 mm |
| Same as predicate device #1 | High Frequency Generator | Same as predicate device #1 | | X-ray Voltage | Same as predicate device #1 | 60~100kVp | Same as predicate device #1 |
| Same as predicate device #1 | Column | Same as predicate device #1 | | X-ray Current | Same as predicate device #2 | 4~17mA | 1~17mA |
| Same as predicate device #1 | Touch monitor (panel) | Same as predicate device #1 | | Total Filtration | Same as predicate device #1 | Min. 2.8 mm Al equivalent | Same as predicate device #1 |
| Detector<br>-CT<br>FXDD-1724RA<br>FXDD-1012CHA<br>-PANO<br>FXDD-1724RA<br>FXDD-1012CHA<br>-Ceph<br>XID-C24DC(Scan)<br>FXRD-1717VA(Oneshot, Large Size)<br>FXDD-1012CA(One shot, Standard<br>Size) | Detector<br>- CT<br>FXDD-0606CA<br>FXDD-1012CHA<br>- PANO<br>FXDD-0606CA<br>FXDD-1012CHA<br>- Ceph<br>XID-C24DC(Scan)<br>1717SCC(One shot, Large Size)<br>PaxScan 2530C(One shot, Standard<br>Size) | Detector<br>-CT<br>FXDD-0606CA<br>Jupi0606X<br>-PANO<br>FXDD-0606CA<br>Jupi0606X<br>-Ceph<br>XID-C24DC(Scan)<br>FXRD-1717VA(Oneshot, Large Size)<br>FXDD-1012CA(One shot, Standard<br>Size) | Detector<br>Pixel size | CT | FXDD-1724RA: 95µm | FXDD-0606CA: 119µm | Same as predicate device #1 |
| Same as predicate device #1 | Chinrest | Chinrest | | | Same as predicate device #1 | FXDD-1012CHA: 124µm | Jupi0606X : 100µm |
| Same as predicate device #1 | Head rest | Head rest | | PANO | FXDD-1724RA: 95µm | FXDD-0606CA: 119µm | Same as predicate device #1 |
| Same as predicate device #1 | Automatic Collimator | Automatic Collimator | | | Same as predicate device #1 | FXDD-1012CHA: 124µm | Jupi0606X : 100µm |
| Same as predicate device #1 | Exposure switch | Exposure switch | | Ceph (Scan) | Same as predicate device #1 | XID-C24DC: 100µm | Same as predicate device #1 |
| Same as predicate device #1 | Emergency stop switch | Emergency stop switch | | Ceph(One shot) | Same as predicate device #2 | 1717SCC: 127µm | FXRD-1717VA : 140µm |
| Same as predicate device #1 | Console PC set | Console PC set | | | Same as predicate device #2 | PaxScan 2530C: 139µm | FXDD-1012CA : 124µm |
| Magnification | CT | Same as predicate device #2 | 1.44(Patient)<br>1.91(Model Scan) | 1.44 | | | |
| | PANO | Same as predicate device #2 | 1.3 | 1.31 | | | |
| | Ceph (Scan) | Same as predicate device #1 | 1.11 | Same as predicate device #1 | | | |
| | Ceph(One shot) | Same as predicate device #1 | Large Type: 1.13 | Same as predicate device #1 | | | |
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| | | Same as predicate device #1 | Standard Type: 1.12 | Same as predicate device #1 |
|------------------------|--|------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| Scan time | | CT : below 20sec | CT : below 20sec(Patient)<br>CT : below 180sec(Model Scan) | CT : below 14sec |
| | | Same as predicate device #1 | Pano : below 14sec | Same as predicate device #1 |
| | | Same as predicate device #2 | Ceph[Scan size] : below 19sec | Ceph[Scan size] : below 20sec |
| | | Same as predicate device #1 | Ceph[One shot size]: below 2sec | Same as predicate device #1 |
| Format compatible | | Same as predicate device #1 | DICOM 3.0 Format compatible | Same as predicate device #1 |
| Image Viewing Software | | RayScan<br>(Cleared under K192737) | RayScan<br>(Cleared under K192737) | RayScan<br>(Cleared under K182614) |
| Image acquisition | | Same as predicate device #1 | Giga-Ethernet Network | Same as predicate device #1 |
| Total Height | | Same as predicate device #1 | Max 2,296mm | Same as predicate device #1 |
| | | | 1) Computed Tomography(CT) +<br>Panoramic(PANO)=189kg(416.6lb) ±<br>10% | 1) Computed Tomography(CT) +<br>Panoramic(PANO)=185kg(407.9lb) ±<br>10% |
| Weight | | Same as predicate device #1 | 2) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(Scan type)= 219kg (482.8lb) ± 10% | 2) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(Scan type)= 212.5kg (468.5lb) ± 10% |
| | | | 3) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(One shot type, installed in Standard<br>size)= 217kg (478.4lb) ± 10% | 3) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(One shot type, installed in Standard<br>size)= 211kg (465.2lb) ± 10% |
| | | | 4) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(One shot type, installed in Large size)<br>212kg (467.3lb) ± 10% | 4) Computed Tomography(CT) +<br>Panoramic(PANO) + Ceph<br>(One shot type, installed in Large size)<br>211kg (465.2lb) ± 10% |
| | | | Type of installation | |
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| Patient position | Same as predicate device #1 | Standing / Wheelchair | Same as predicate device #1 |
|----------------------|-----------------------------|-----------------------------------------------------------------|-----------------------------|
| Applicable Standards | Same as predicate device #1 | IEC 60601-1<br>IEC 60601-1-3<br>IEC 60601-2-63<br>IEC 60601-1-2 | Same as predicate device #1 |
The product is principally just the same as in the previous 510(k) #K192737 and #K213226.
The complete of differences of the subject device to the predicate device #K192737 is as follows
- The minimum X-ray current of the tube has been changed from 4mA to 1mA
- The Magnification of Panorama has been changed from 1.3 to 1.31
- Detector (using for CT, Pano, One-shot Ceph), Field of view.
However, X-ray current, magnification and one-shot ceph detector was identified in #K213226.
The 510(k) for the existing detector used in our equipment is provided below.
| Modality | Detector Model | Cleared | 510(k) No. |
|---------------|----------------|---------|------------|
| CT | FXDD-1724RA | No PMA | K222219 |
| | FXDD-1012CHA | No PMA | K182805 |
| Pano | FXDD-1724RA | No PMA | K222219 |
| | FXDD-1012CHA | No PMA | K182805 |
| Scan Ceph | XID-C24DC | No PMA | K181452 |
| One shot Ceph | FXRD-1717VA | No PMA | K213226 |
| One shot Ceph | FXDD-1012CA | No PMA | K213226 |
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#### 10. Safety and Effectiveness Information
The RCT800 system described in this 510(k) is similar to the predicate device in terms of indications for use, materials, safety characteristics and X-ray source. The following information further substantiates the substantial equivalence between the subject device and predicate device. The fundamental technological characteristics of the subject and predicate devices are similar. The imaging modes are similar; PANO, CEPH (Optional), CBCT. All viewing software programs have been cleared with previous 510k submissions; RAYSCAN (K192737). The sponsor tested the subject device in a laboratory and provided a non-clinical performance report. The same test protocol was used to test the performance of the subject and predicate devices for comparison. The sponsor certifies that adequate design and development controls (according to 21 CFR 820.30) were in place for manufacturing the subject device.
The differences are as follows.
- The minimum X-ray current of the tube has been changed from 4mA to 1mA
- The Magnification of Panorama has been changed from 1.3 to 1.31
- Detector (using for CT, Pano and One-shot Ceph), Field of view.
However, X-ray current, magnification and one-shot ceph detector was identified in #K213226.
Electrical, mechanical and environmental safety testing according to the standard of IEC 60601-1:2005/AMD1:2012 (3.1 Edition), IEC 60601-1-3:2008/AMD1:2013 (Second Edition), IEC 60601-1-6:2010 (Third Edition), and IEC 60601-2-63:2012 (First Edition) were performed.
EMC testing was conducted in accordance with the standard IEC 60601-1-2:2014 (Edition 4.0).
The software of RCT800 saves patient and image data and offers an inquiry function. In addition, it supports the image generate function intended to obtain images using the RCT800 equipment and various sensors for diagnosis. That has been validated according to the FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" and "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" to assure substantial equivalence. The software for this device was considered a "moderate" level of concern since a failure or latent flaw in the software would not directly result in serious injury or death to the patient or operator. As a result, we identified the level of concern associated with a new device and provided documentation consistent with that level. Based on our risk analysis of software, the difference does not affect its safety and effectiveness.
Bench testing was conducted according to the FDA Guidance "Format for Traditional and Abbreviated 510(k)s," Section 18, "Performance Testing - Bench." Bench testing is used to assess whether the parameters required to describe functionalities related to imaging properties of the dental X-ray device and patient dosage satisfy the designated tolerance.
Performance (Imaging performance) testing was conducted according to the standards of IEC 61223-3-4 and IEC 61223-3-7. All test results were satisfactory.
Non-clinical considerations were conducted in accordance with the FDA Guidance
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"Guidance for the Submissions of 510(k)'s for Solid State X-ray Imaging Devices." Because the subject device uses the same detector as the predicate device, there are no significant differences between the two devices as a result of non-clinical testing.
Clinical considerations were conducted according to the FDA Guidance "Format for Traditional and Abbreviated 510(k)s," Section 20. Clinical images were provided, and while these images were not necessary to establish substantial equivalence based on the modifications to the device, they provide further evidence, in addition to the laboratory performance data, to show that the complete system works as intended.
The features of RCT800 were clinically tested and approved by two licensed practitioners/clinicians. Clinical imaging samples were collected from new detectors on the proposed device at the two offices where the predicate device was installed for the clinical test images. These images were gathered from all detectors installed with RCT800 using protocols with random patient age, gender, and size. A licensed practitioner reviewed the sample clinical images and deemed them to be of acceptable quality for the intended use.
#### 11. Conclusions
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this premarket notification. Ray Co., Ltd. concludes that the newly RCT800 is safe, effective and substantially equivalent to the predicate device as described herein.
