K231052 · Brainlab AG · IYE · May 11, 2023 · Radiology
Device Facts
Record ID
K231052
Device Name
ExacTrac Dynamic 1.1.2
Applicant
Brainlab AG
Product Code
IYE · Radiology
Decision Date
May 11, 2023
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.5050
Device Class
Class 2
Indications for Use
ExacTrac Dynamic is intended to position patients at an accurately defined point within the treatment beam of a medical accelerator for stereotactic radiosurgery or radiotherapy procedures, to monitor the patient position and to provide a beam hold signal in case of a deviation in order to treat lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.
Device Story
ExacTrac Dynamic is an add-on system for linear accelerators used in radiotherapy environments. It utilizes patient planning CT data, oblique X-ray images, and surface/thermal camera tracking to align patients at a defined treatment isocenter. The system monitors patient position during treatment; if deviations occur, it provides a beam hold signal to the accelerator. It includes Deep Inspiration Breath-Hold (DIBH) functionality for breast cancer treatment, allowing monitoring of breath-hold phases to maximize distance from critical structures like the heart. The system is operated by clinical staff in a radiotherapy suite. Outputs include calculated correction shifts for patient alignment and real-time monitoring data. The device benefits patients by ensuring precise radiation delivery and minimizing exposure to healthy tissue through automated beam control and motion management.
Clinical Evidence
Bench testing only. The submission relies on verification testing of software bug fixes and modified specifications. No clinical data was required or provided.
Technological Characteristics
Add-on system for linear accelerators. Components: Varex G-892 X-ray sources, Varex PaxScan 3030DX flat panel detectors, Cognex A5060 3D cameras, Flir A65 F25 thermal cameras. Connectivity: Networked within radiotherapy suite. Software: Windows-based, rule-based logic for patient positioning, surface tracking, and beam hold signaling. Calibration: Thermal-to-3D phantom. No changes to hardware or core architecture from predicate.
Indications for Use
Indicated for patients requiring stereotactic radiosurgery or radiotherapy for lesions, tumors, and conditions anywhere in the body where radiation treatment is indicated.
Regulatory Classification
Identification
A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.
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May 11, 2023
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Brainlab AG % Sadwini Suresh QM Consultant Olof-Palme-Str.9 Munich, 81829 GERMANY
Re: K231052
Trade/Device Name: ExacTrac Dynamic (1.1.2) Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: Class II Product Code: IYE Dated: April 11, 2023 Received: April 13, 2023
Dear Sadwini Suresh:
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
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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.
Image /page/1/Picture/5 description: The image shows a digital signature. The signature is for Lora D. Weidner -S. The date of the signature is 2023.05.11, and the time is 11:34:19 -04'00'.
Lora D. Weidner, Ph.D. Assistant Director Radiation Therapy Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices 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) K231052
Device Name
ExacTrac Dynamic (1.1.2)
Indications for Use (Describe)
ExacTrac Dynamic is intended to position patients at an accurately defined point within the treatment beam of a medical accelerator for stereotactic radiosurgery or radiotherapy procedures, to monitor the patient position and to provide a beam hold signal in case of a deviation in order to treat lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.
Type of Use (Select one or both, as applicable)
| <div> <span></span>Prescription Use (Part 21 CFR 801 Subpart D) </div> |
|---------------------------------------------------------------------------|
| <div> <span></span>Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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## 510(k) Summary
K231052
May 11, 2023
| General Information | |
|----------------------------|---------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Brainlab AG; Olof-Palme Str.9; 81829, Munich, Germany |
| Establishment Registration | 8043933 |
| Device Name | Medical charged-particle radiation therapy system |
| Trade Name | ExacTrac Dynamic 1.1.2 |
| Product Code | IYE |
| Regulation Number | 892.5050 |
| Regulatory Class | II |
| Panel | Radiology |
| Predicate Devices | ExacTrac Dynamic 1.1 (K220338) |
| Contact Information | |
| Primary Contact | Sadwini Suresh<br>QM Consultant, Regulatory Affairs<br>Phone: +49 89 99 15 68 0<br>Email: regulatory.affairs@brainlab.com |
| Alternate Contact | Chiara Cunico<br>Senior Manager Regulatory Affairs<br>Phone: +49 89 99 15 68 0<br>Email: chiara.cunico@brainlab.com |
#### 1. Indications for Use
ExacTrac Dynamic is intended to position patients at an accurately defined point within the treatment beam of a medical accelerator for stereotactic radiosurgery or radiotherapy procedures, to monitor the patient position and to provide a beam hold signal in case of a deviation in order to treat lesions, tumors and conditions anywhere in the body when radiation treatment is indicated.
### 2. Device Description
ExacTrac Dynamic is a patient positioning device used in a radiotherapy environment as an addon system to standard linear accelerators. It uses patient planning and CT data to determine the patient's planned position and compares it via oblique x-ray images to the actual patient position. The calculated correction shift will then be transferred to the treatment machine to align the patient correctly at the machine's treatment position. During treatment is monitored with a surface camera and X-ray to ensure no misalignment due to patient movement.
ExacTrac Dynamic 1.1.2 is a modification of the previously cleared device ExacTrac Dynamic 1.1 that features a Deep Inspiration Breath-Hold (DIBH) functionality to treat breast cancer. This functionality helps correctly position the patient to a deep inspiration breath-hold level and then to monitor this position using surface tracking and x-ray positioning technology. The aim of this technology is to treat the patient only during breath-hold phases where the breast is at a defined
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position with a maximum distance to critical structures like the heart. Additionally the surface tracking functionality was extended, which monitors the patient after an initial 3rd party positioning.
The main functionalities has remained same for the Subject Device. The modifications are done on a specification level to implement additional measures.
#### 3. Performance Data
In order to address the identified bugs, certain specifications and tests related to the bug fixes (as detailed in Section 4) with ExacTrac Dynamic 1.1.2 were modified to include additional measures. These modified specifications were verified via incremental tests. All tests were passed.
#### 4. Substantial Equivalence
The Subject Device has similar functionality, intended use, technological characteristics, and typical users as the predicate device. The change was performed to correct the identified bugs in the predicate device ExacTrac Dynamic 1.1.
The bug fix did not require any change to the existing software architecture.
The following critical bug was identified:
| Short name /<br>Specification | Bugzilla ID | Description |
|-------------------------------------------------------------------------------|-------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| procedure without beam<br>hold control – Amiens<br>(Case-20221124-<br>451154) | Bug 154505 | In the Treatment application it is possible to treat<br>a DIBH patient with disabled beam control, i.e. if<br>a DIBH plan is prepared with disabled beam<br>control, treatment is not blocked. |
The following specifications were added for this bug:
- . In the Prep Application the software shall check the setting "Beam Control" of a DIBH Patient and shall not allow to save a DIBH patient with beam control disabled.
- . In the Template Editor it shall not be possible to save a new customer template if the DIBH workflow is selected and automatic "Beam Control" is disabled.
- In the Treatment App during the patient opening the setting "Beam Control" of a DIBH Patient ● shall be checked and in case Beam Control is disabled the patient shall not be loaded.
In addition, the following bugs were also fixed for the Subject Device version:
#### Table 1: List of Bugfixes
| Short name | Bugzilla ID | Description |
|-------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| No deletion is possible<br>although archiving proxy is<br>configured | 155619 | it is not possible to delete patient without previously<br>have pressed archive button although the data is<br>already archived automatically through the<br>implementation of the bug 154028. |
| Possibility to achieve<br>Monitoring having positioned<br>with a setup beam which has<br>different isocenter | 155252 | For plans containing an additional setup beam with<br>a "virtual" isocenter, i.e. an isocenter different than<br>the isocenter of the treatment beam, it is possible to<br>position and treat the patient on the virtual isocenter<br>instead on the treatment isocenter. |
| Short name | Bugzilla ID | Description |
| There is a wrong<br>dependency/rule that<br>excludes ContentManager<br>2.8 | 155034 | Wrong dependency in the top level package |
| DIBH procedure without<br>beam hold control – Amiens<br>(Case-20221124-451154) | 154506 | In the Template Editor it is possible to prepare a<br>DIBH template with disabled beam control, i.e. that<br>ETD has no beam control. |
| X-ray shifts missing in the<br>localized PDF printout | 151144 | In the localized (translated) pdf printout, no X-ray<br>shifts are printed. |
| PDF not created after treat | 154556 | PDF not created after treatment, wrongly created<br>with RepeatExport<br>Bug related to 153990 from testing of RC2 |
| Too many DRRs saved | 153990 | ETD saves 3 DRRs per X-ray Each DRR is 1MB<br>approx. This is a huge amount of data saved that<br>actually the users do not use but occupies hard disc<br>making the search of patient and loading a patient<br> |
| Surfaces are saved every<br>time the surface goes OoT | 152130 | Surfaces are saved every time the surface goes out-<br>of-tolerance (OOT) during patient monitoring, even if<br>only for a fraction of a second. |
| Crash during closing app in<br>Monitoring (after<br>SurfaceTrackingOutOfTolera<br>nceTreatmentEvent) | 154422<br>(Consequence out<br>of Bug 152130) | Crash when closing application in monitoring. |
| Crash during closing app in<br>Monitoring (during treatment<br>session saving) | 154423<br>(Consequence out<br>of Bug 152130) | Crash when closing application in monitoring. |
| Improve 'send shift'/'Go to<br>Treatment' behavior for<br>verification with excluded and<br>zeroed out big rotations in<br>ImplM WF | 151687 | In the implanted marker WF it is possible to exclude<br>big rotations and zero them out in surface tracking.<br>However, if the rotational shifts are higher than 5°,<br>they will always cause an 'Out of Tolerance' in<br>monitoring (even if they are excluded and zeroed<br>out), causing a beam hold event, which forces a<br>verification and sending a (minimal) shift is<br>always required to continue the treatment.<br>This causes many problems for Users that do have<br>an internal rule to always verify the position again<br>after the couch has been moved. |
| toplevelbips of ETD 1.1.2 do<br>not install all required<br>packages | 154327 | When performing a new installation using the ETD<br>toplevelbip the following bip packages are not<br>selected for installation |
| Upgrade ContentManager<br>2.7/2.8 with custom settings | 154333 | - |
| SW Crash on Sending Shift in<br>OAR Verification | 154385 | - |
| TC test: different reference<br>pictures because of different<br>fusion matrix | 154449 | - |
| Short name | Bugzilla ID | Description |
| Gantry angle based X-ray<br>triggered too early (Elekta) | 154093 | Gantry angle based X-ray is triggered too early for<br>Elekta. |
| Usergroup check is<br>performed on current user,<br>not user communicated by<br>PDM | 125826 | ETD uses Windows users instead of PDM users. |
| Patient deletion fails for<br>certain data sets | 152829 | - |
| Patient positioning based on<br>wrong isocenter possible in<br>Verification after Monitoring in<br>rare cases | 154002 | A Setup Beam that was scheduled for the previous<br>patient and was not used, however it was loaded at<br>the end of the treatment by an automatic function of<br>the Linac. Exactrac detected the beam loading at<br>the Linac and waited for user's confirmation.<br>Instead, the user closed the plan and the patient at<br>the Linac. ExacTrac software seems to expect no<br>plan closing event at the Linac while ETD is in<br>Monitoring. The user was informed via message that<br>"Beam has changed on the Linac" and confirmed it.<br>At this point the software could either crash or<br>proceed, presumably depending on the memory<br>state,<br>In case the software proceeds, the beam is loaded<br>and the user can proceed with the X-Ray<br>Verification. In this case the shift would be based on<br>the isocenter of the mistaken loaded beam, from the<br>previous patient. |
| Crash after X-ray acquisition<br>on X-ray Correction or<br>Acquisition page | 154035 | Crash after X-ray acquisition on X-ray Correction or<br>Acquisition page. |
| [DIBH] ETD Crashes when<br>clicking twice fast on "<br>Confirm level of today" | 148088 | By click twice fast on "Confirm Level of Today" the<br>software crash. |
| Wrong level of drawn Gating<br>Window in Frozen View of<br>DIBH Navigation | 148462 | Having acquired an X-ray in DIBH Navigation<br>causes the view to freeze. All information as<br>available in the point in time of X-ray acquisition is<br>visualized / summarized. |
| Too sensitive Couch<br>Movement Check for Elekta<br>Precise couches | 154087 | Too sensitive Couch Movement Check for Elekta<br>Precise couches in the DIBH workflow. |
| [PrePos] [DIBH]<br>Prepositioning fails after<br>DIBH treatment | 150403 | For every patient that is loaded on ETD immediately<br>after a DIBH treatment, the Prepositioning contour is<br>not shown. |
| ETD can treat despite<br>overdue Thermal to 3D<br>calibration | 150600 | Patients can be treated despite overdue thermal-to-<br>3D camera calibration in case the following<br>conditions are fulfilled: first treatment section of this<br>patient, unprepared patient, and first ETD patient of<br>the day. |
| Wrong x-ray shift for beams<br>with different PSA in<br>implanted marker monitoring | 150933 | Wrong x-ray shift in Monitoring for beams with<br>different PSA in implanted marker monitoring |
| Short name | Bugzilla ID | Description |
| Surfaces are saved every<br>time the surface goes OoT | 152130 | Surfaces are saved every time the surface goes out-<br>of-tolerance (OOT) during patient monitoring, even if<br>only for a fraction of a second. |
| Missed following automatic X-<br>ray trigger acquisition(s)<br>(counter-clockwise beam) | 154022 | first X-ray at 90° is triggered correctly when gantry is<br>at 96.9° following acquisitions (0° and 270°) are<br>missed, as the SW does not expect more<br>acquisitions beyond the gantry angle of 96.6° |
| Support Archiving Service | 154028 | Currently ETD applications are not supporting the<br>Archiving Proxy feature of archiving in a network<br>disk feature of the DICOMProxy. |
| Gantry angle based X-ray<br>was triggered too early | 154093 | Automatically gantry-triggered X-rays were acquired<br>too early due to one-time variations of the gantry<br>velocity. |
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There was no change of intended use, technological characteristics or typical users.
| Features | ExacTrac Dynamic 1.1 K220338<br>(Primary Predicate) | ExacTrac Dynamic 1.1.2 (Subject<br>Device) | Comments |
|----------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|
| Indications<br>for Use | ExacTrac Dynamic is intended to<br>position patients at an accurately<br>defined point within the treatment<br>beam of a medical accelerator for<br>stereotactic radiosurgery or<br>radiotherapy procedures, to<br>monitor the patient position and to<br>provide a beam hold signal in case<br>of a deviations in order to treat<br>lesions, tumors and conditions<br>anywhere in the body when<br>radiation treatment is indicated. | ExacTrac Dynamic is intended to<br>position patients at an accurately<br>defined point within the treatment<br>beam of a medical accelerator for<br>stereotactic radiosurgery or<br>radiotherapy procedures, to<br>monitor the patient position and to<br>provide a beam hold signal in case<br>of a deviations in order to treat<br>lesions, tumors and conditions<br>anywhere in the body when<br>radiation treatment is indicated. | No<br>changes |
| Localization<br>technique | The camera detects both the<br>patient surface and the patient<br>thermal surface which together, can<br>be used to track the patient<br>geometries.<br>Stereo X-ray is acquired and<br>compared with the planned position<br>(room based).<br>CBCT data are imported from a<br>from 3rd party CBCT Device and<br>compared with the planned<br>position. | The camera detects both the<br>patient surface and the patient<br>thermal surface which together, can<br>be used to track the patient<br>geometries.<br>Stereo X-ray is acquired and<br>compared with the planned position<br>(room based).<br>CBCT data are imported from a<br>from 3rd party CBCT Device and<br>compared with the planned<br>position. | Same as<br>the<br>predicate<br>device. |
| Features | ExacTrac Dynamic 1.1 K220338<br>(Primary Predicate) | ExacTrac Dynamic 1.1.2 (Subject<br>Device) | Comments |
| General<br>workflow:<br>Patient<br>preparation<br>before using<br>ExacTrac | Uses implanted radio opaque<br>fiducial markers or using Body<br>Markers Performing CT scan<br>Data import from treatment<br>planning system | Uses implanted radio opaque<br>fiducial markers or using Body<br>Markers Performing CT scan<br>Data import from treatment<br>planning system | Same<br>patient<br>preparation method<br>as the<br>predicate |
| Software<br>User<br>Management | Done via Windows user<br>management according to our<br>instructions | Done via Windows user<br>management according to our<br>instructions | Identical to<br>the<br>predicate |
| Deep<br>Inspiration<br>Breath-Hold<br>(DIBH) | ExacTrac Dynamic 1.1 features a<br>Deep Inspiration Breath-Hold<br>(DIBH) functionality to treat breast<br>cancer. This functionality includes<br>special features and workflows to<br>correctly position the patient to a<br>deep inspiration breath-hold<br>level and then to monitor this<br>position using the ExacTrac surface<br>tracking and x-ray positioning<br>technology. The aim of this<br>technology is to treat the patient<br>only during breath-hold phases<br>where the breast is at a defined<br>position with a maximum distance<br>to critical structures like the heart.<br>These feature results in an optional<br>use of the patient feedback system | ExacTrac Dynamic 1.1.2 features a<br>Deep Inspiration Breath-Hold<br>(DIBH) functionality to treat breast<br>cancer. This functionality includes<br>special features and workflows to<br>correctly position the patient to a<br>deep inspiration breath-hold<br>level and then to monitor this<br>position using the ExacTrac surface<br>tracking and x-ray positioning<br>technology. The aim of this<br>technology is to treat the patient<br>only during breath-hold phases<br>where the breast is at a defined<br>position with a maximum distance<br>to critical structures like the heart.<br>These feature results in an optional<br>use of the patient feedback system. | No change |
| Surface<br>Only | A separate workflow offers the<br>possibility to position the patient<br>with a third party positioning device<br>e.g. CBCT. The patient position<br>defined by the third party device<br>can be set as a reference for<br>ExacTrac Dynamic which allows<br>monitoring the patient using<br>ExacTracs surface camera and X-<br>ray system relative to this position.<br>ExacTrac Dynamic 1.1 shall offer<br>performing this third party<br>positioning and ExacTrac Dynamic<br>monitoring workflow by only using<br>the surface tracking system -<br>contrary to ExacTrac Dynamic 1.0<br>where it was necessary to acquire<br>X-ray images to set the third party<br>defined patient position as a<br>reference for ExacTrac Dynamic | A separate workflow offers the<br>possibility to position the patient<br>with a third party positioning device<br>e.g. CBCT. The patient position<br>defined by the third party device<br>can be set as a reference for<br>ExacTrac Dynamic which allows<br>monitoring the patient using<br>ExacTracs surface camera and X-<br>ray system relative to this position.<br>ExacTrac Dynamic 1.1.2 shall offer<br>performing this third party<br>positioning and ExacTrac Dynamic<br>monitoring workflow by only using<br>the surface tracking system. | No change |
| Features | ExacTrac Dynamic 1.1 K220338<br>(Primary Predicate) | ExacTrac Dynamic 1.1.2 (Subject<br>Device) | Comments |
| ExacTrac<br>Console | ExacTrac Console (System<br>start/shut down, X-ray acquisition)<br>Image: ExacTrac Console | ExacTrac Console (System<br>start/shut down, X-ray acquisition)<br>Image: ExacTrac Console | No change |
| X-ray<br>Sources | Varex G-892 Sources (Housing:<br>Varex B-130) | Varex G-892 Sources (Housing:<br>Varex B-130) | No change |
| Flat Panel<br>Detector<br>including<br>Power<br>Supply | Flat Panel Detector<br>Varex PaxScan 3030DX | no change compared to predicate | No change |
| Cameras | 3D and Thermal Cameras<br>Manufacturer (3D): Cognex Ireland<br>Limited Type: A5060<br>Manufacturer (Thermal): Flir<br>Systems AB Type: A65 F25<br>Image: Camera<br>The camera is used to detect the<br>patient's thermal and spatial<br>surface. The thermal topology is<br>used to prevent the surface<br>registration algorithm from falling<br>into local minima. Thus both<br>surfaces are used to track patient's<br>position. | 3D and Thermal Cameras<br>Manufacturer (3D): Cognex Ireland<br>Limited Type: A5060<br>Manufacturer (Thermal): Flir<br>Systems AB Type: A65 F25<br>Image: Camera<br>The camera is used to detect the<br>patient's thermal and spatial<br>surface. The thermal topology is<br>used to prevent the surface<br>registration algorithm from falling<br>into local minima. Thus both<br>surfaces are used to track patient's<br>position. | no change |
| Features | ExacTrac Dynamic 1.1 K220338<br>(Primary Predicate) | ExacTrac Dynamic 1.1.2 (Subject<br>Device) | Comments |
| Wall<br>mounted<br>Touch<br>Screen<br>Monitor | Image: ExacTrac Dynamic 1.1 K220338 | Image: ExacTrac Dynamic 1.1.2 | No change |
| On Floor X-<br>ray sources<br>covers | X-ray tubes within On-Floor Boxes<br>X-ray Tubes within Floor | X-ray tubes within On-Floor Boxes<br>X-ray Tubes within Floor | No change |
| Patient<br>Feedback<br>System | The Patient Feedback System<br>helps patients visualize their own<br>respiration and to achieve a correct<br>breath hold.<br>Therefore the mirror is attached the<br>patient head and they can see the<br>in Room Monitor.<br>The Monitor shows a the live<br>respiratory status and the DIBH<br>Gating Window. The System is only<br>for supporting the patients, a<br>treatment without is also possible | The Patient Feedback System<br>helps patients visualize their own<br>respiration and to achieve a correct<br>breath hold.<br>Therefore the mirror is attached the<br>patient head and they can see the<br>in Room Monitor.<br>The Monitor shows a the live<br>respiratory status and the DIBH<br>Gating Window. The System is only<br>for supporting the patients, a<br>treatment without is also possible. | No<br>change. |
| Features | ExacTrac Dynamic 1.1 K220338<br>(Primary Predicate) | ExacTrac Dynamic 1.1.2 (Subject<br>Device) | Comments |
| X-ray<br>Calibration | Image: X-ray Calibration…
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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.