GXR-Series Diagnostic X-Ray System

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue. January 7, 2025 DRGEM Corporation % Jongseon Park Regulatory Affairs | Engineer 7F, E-B/D Gwangmyeong Techno-Park, 60Haan-ro, GwangMyeong-si, Gyeonggi 14322 SOUTH KOREA Re: K242019 Trade/Device Name: GXR-series diagnostic x-ray system Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary X-Ray System Regulatory Class: Class II Product Code: KPR, MQB Dated: July 10, 2024 Received: December 3, 2024 Dear Jongseon Park: 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 (the 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 available 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. {1}------------------------------------------------ Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download). Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181). 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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050. All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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-regulatory {2}------------------------------------------------ assistance/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 Radiologic Imaging Devices and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure {3}------------------------------------------------ # Indications for Use 510(k) Number (if known) K242019 Device Name GXR-Series Diagnostic X-Ray System #### Indications for Use (Describe) The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays. 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> | #### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. #### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {4}------------------------------------------------ Image /page/4/Picture/0 description: The image shows the logo for DRGEM. The letters "DR" are in bold black font, while "GEM" is in a teal color. Below the logo is the text "Your Best Healthcare" in a smaller font size. # 510(k) Summary ### K242019 This 510(k) Summary of safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92. #### I. SUBMITTER [21 CFR 807.92(a) (1)] DRGEM Corporation 7F E-B/D Gwangmyeong Techno-Park 60, Haan-ro, Gwangmyeong-si, Gyeonggi-do, 14322 Korea Email: pjs98@drgem.co.kr TEL: +82-70-4285-3734, FAX: +82-2-869-8567 Contact Person: Mr. Jongseon PARK, Engineer | Regulatory Affairs Date Prepared: June 15, 2024 #### II. PROPOSED DEVICE INFORMATION [21 CFR 807.92(a) (2)] | Product Name: | GXR-Series Diagnostic X-Ray System | |--------------------------|------------------------------------| | Common Name: | Stationary X-Ray System | | Classification Name: | Stationary x-ray system | | Product Code: | KPR | | Regulation Number: | 892.1680 | | Associated Product Code: | MQB | | Regulatory Class: | II | Available Device Models : (Models: GXR32S, GXR-40S, GX 82S, GXR-C32S, GXR-C40S, GXR-C52S, GXR-U32S, GXR XR-52S, GXR-68S, GXR-R-U40S, GXR-32SD, GXR-40SD, GXR-52SD, GXR-68SD, GXR-82SD, GXR-C32SD, GXR-C40SD, GXR-C52SD, GXR-U32SD, GXR-U40SD, FDR Clinica FGXR-32S, FDR Clinica FGXR-40S, FDR Clinica FGXR-52S, FDR Clinica FGXR-68S, FDR Clinica FGXR-82S, FDR Clinica FGXR-C32S, FDR Clinica FGXR-C40S, FDR Clinica FGXR-C52S, FDR Clinica FGXR-U32S, FDR Clinica FGXR-U40S) #### III. PREDICATE DEVICES INFORMATION [21 CFR 807.92(a) (3)] | Product Name: | GXR-series Diagnostic X-Ray System, (Models GXR-S, GXR-SD series) | |----------------------|-------------------------------------------------------------------| | Common Name: | Stationary X-Ray System | | Classification Name: | Stationary x-ray system | | 510(k) Number: | K202572 | | Product Code: | KPR | | Regulation Number: | 892.1680 | | Regulatory Class: | II | {5}------------------------------------------------ #### IV. DEVICE DESCRIPTION [21 CFR 807.92(a) (4)] #### · Device Features: #### · GXR-S/CS/US 'Analog Diagnostic X-ray System' " GXR-S/CS/US" system provides excellent performance and stable operation while state-of-the-art image quality. The "GXR-S/CS/US" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility, and longterm stability. Automatic Calibration function of the generator will minimize calibration time and set correct calibration value. Also the control console of "GXR", "GXR-U" series offers graphic waveform and data of x-ray exposure. So, it is not needed to perform the manual calibration procedure with measurement equipment. Naturally, the generator supports Automatic, Semi-auto and Manual Calibration functions. Adaptable calibration function keeps up long-term stability and accuracy by trimming calibration data whenever xray exposed. The "GXR-C" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability with capacitor assisted general line power supply. Only 3KVA line power capacity is enough for x-ray generation up to 40KW, and "GXR-C" series provides minimum 100mAs output at maximum output rating without mA sliding down. Also, maximum interval for full charging is 10 seconds after maximum output x-ray generation. Only 900VA line power capacity is enough for the battery charging, and "GXR-U" series provides same output rating and performances of line-powered generators. The operator control console is designed in two types to be simple and user-friendly. The first type features a large graphic LCD panel display and a soft membrane switch to allow easy selection or change of X-ray parameters. The second type can be easily operated using the Touch function through a large graphic LCD panel display and intuitive GUI configuration. Remote Diagnosis Software can make report about information of system, user, service and error by the USB connection between PC and control console, and transfer report to manufacturer via internet. So this function enables fast and accurate diagnosis on problems and saves service cost and system downtime. The APR (Anatomical Programming) and the optional AEC (Automatic Exposure Control) features give you controlled exposure factors, automatically optimized for the radiological study selected. #### · GXR-SD/CSD/USD 'Digital Diagnostic X-ray System' "GXR-SD/CSD/USD" system provides excellent performance and stable operation while state-of-the-art image quality. The "GXR", "GXR-C", "GXR-U" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability. Automatic Calibration function of the generator will minimize calibration time and set correct calibration value. Also the control console of "GXR", "GXR-U" series offers graphic waveform and data of x-ray exposure. So, it is not needed to perform the manual calibration procedure with measurement equipment. Naturally, the qenerator supports Automatic, Semi-auto and Manual Calibration functions. Adaptable calibration function keeps up long-term stability and accuracy by trimming calibration data whenever xray exposed. The "GXR-C" Series High Voltage X-Ray Generator features excellent accuracy, reproducibility and long-term stability with capacitor assisted general line power supply. Only 3kVA line power capacity is enough for x-ray generation up to 40kW, and "GXR-C" series provides minimum 100mAs output at maximum output rating without mA sliding down. {6}------------------------------------------------ Also, maximum interval for full charging is 10 seconds after maximum output x-ray generation. Only 900VA line power capacity is enough for the battery charging, and "GXR-U" series provides same output rating and performances of line-powered generators. Remote Diagnosis Software can make report about information of system, user, service and error by transfer report to manufacturer via internet. So this function enables fast and accurate diagnosis on problems and saves service cost and system downtime. The APR (Anatomical Programming) and the optional AEC (Automatic Exposure Control) features give you controlled exposure factors, automatically optimized for the radiological study selected. "GXR-SD/CSD/USD" provides state-of-the-art image quality; image processing and user interface; making the system easy to use. "GXR-SD/CSD/USD" incorporates the digital flat panel detector technology. Direct radiography via flat panel detector improves your workflow, exam speed and comfort with efficiency. Digital flat panel detector provides excellent spatial resolution, MTF, DQE and stability based on fine pixel pitch. Selection of an anatomical study on the imaging software automatically sets up the x-ray generator's preprogrammed exposure technique setting and post image processing for selected study. Also, high resolution grid supplies excellent image quality. A high performance imaging workstation and "RADMAX" software serves you a convenient interface and easy operation. Anatomical view-based digital image processing automatically optimizes and enhances the quality of the captured images. Automatic image storage and print with DICOM 3.0 networking capability increases exam throughput and decreases examination time. Remote diagnosis function enables fast and accurate diagnosis on problems and saves service cost and system downtime. #### · Device Identification: The GXR Series Diagnostic X-ray System consists of a combination of an x-ray generator, and associated equipment such as tube stand, patient table, and, digital imaging system. #### · Device Characteristics: #### Software The subject device 'GXR-Series Diagnostic X-ray System' use software (including firmware). [GXR-S, CS, US 'Analog Diagnostic X-ray System'] Its S/W (X-CON) can perform system control such as the collimation size, filter selection, Control of Generator. [GXR-SD, CSD, USD 'Digital Diagnostic X-ray System'] Its S/W (RADMAX) can perform processing the radiological image acquired from Solid State X-ray Imaging Device. Both software being used is identical to the predicate device "GXR-series Diagnostic X-ray System", and its LOC (Level of Concern) is 'Moderate'. Accordingly, this software (X-CON) is based on predicate device 'GXR-S series Diagnostic system. {7}------------------------------------------------ #### Software Level Determination (Moderate Level of Concern) The device does not contact the patient, nor does it control any life sustaining devices. A physician. providing ample opportunity for competent human intervention, interprets all images and information being displayed and printed. #### · Environment of Use: This "GXR-series Diagnostic X-ray System" is for use by medical professional Facility. To prevent excess radiation exposure to patient and operator from either primary or secondary radiation, this "GXR-Series Diagnostic X-ray System" must be operated and serviced by trained personnel who are familiar with the safety precautions required. #### · Brief Written Description of the Device: The operating principles are as follows. The irradiation conditions are 40 to 125 (150) kVp at the photographing site, and the tube current is 10 to 400 (500) mA. When X-rays generated under X-ray irradiation conditions enter the X-ray Film or Flat Panel detector, the film or flat panel detects X-rays incident through the incident surface during X-ray irradiation, and finally generates a radiographic image when X-ray irradiation is completed (in case of Digital Diagnostic X-ray System, After Image processing, Digital Image for Diaqnosis has been generated). #### V. INDICATION FOR USE [21 CFR 807.92(a) (5)] The GXR-Series Diagnostic X-ray System is intended for use in obtaining human anatomical images for medical diagnostic by using X-rays. #### VI. TECHNOLOGICAL CHARACTERISTICS [21 CFR 807.92(a) (6)] The Subject device 'GXR-Series Diagnostic X-ray System' (Model: GXR-S, GXR-SD series) is based on the Predicate Device (GXR-series, K202572) including the system control, Indication for use and mechanical design. The differences between the subject device and the predicate device have been thoroughly tested and verified for safety and effectiveness by an accredited Safety and EMC testing laboratory. This 510(k) submission describes some modifications to the previously cleared predicate devices the 'GXR-SD Series' (K202572). The changes to the predicate 'GXR-SD series' (K202572) include: {8}------------------------------------------------ ### System Imaging Software 'RADMAX' · Graphical user interface (GUI): GUI of system software updated in order to improve the look and feel of user interface for better visibility & faster workflow. · Image Processing Module added (Module 4): We conducted performance verification of Flat Panel detectors compared to existing image processing modules. Verification and Validation testing concluded no impact on safety and effectiveness. ### Component Change #### ·10x12 inch Wireless Flat Panel detectors have been added ·Luna1012X manufactured by IRAY Technoloqy, FDA Cleared K221345 #### ·14x17 inch Wireless Flat Panel detectors have been added ·Mars1417X manufactured by IRAY Technology, FDA Cleared K210316 ·A1417MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930 ·F1417MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930 #### ·17x17 inch Wireless Flat Panel detectors have been added ·Mars1717X manufactured by IRAY Technology, FDA Cleared K210314 ·A1717MCW manufactured by H&abyz Co., Ltd., FDA Cleared K223930 ### ·Patient Table option has been added · PBT-6 (Deluxe) option manufactured by DRGEM #### ·Wall Bucky stand option has been added ·WBS (Manual Plus) option manufactured by DRGEM ·WBS-TA (Actuator) option manufactured by DRGEM ·WBS-TA (Deluxe) option manufactured by DRGEM #### ·Tube Stand option has been added ·TS-CSP (15inch LCD Panel) option manufactured by DRGEM #### ·Tube Housing Assembly models have been added ·RTM90HS Tube Housing Assembly option manufactured by IAE ·RTM101HS Tube Housing Assembly option manufactured by IAE ·RTC600HS Tube Housing Assembly option manufactured by IAE ·UH-6FC-31E Tube Housing Assembly option manufactured by Fujifilm #### ·GXR-Series Diagnostic X-ray System's 'Variant models' have been added : Variant models (FDR Clinica FGXR-S, CS, US) of Subject Device have been added. These models are manufactured for OEM Contractor (Fujifilm Corporation). Difference between predicate device (GXR-S, CS, US 'Analog Diagnostic X-ray System') and OEM Model (FDR Clinica FGXR-S, CS, US) has only label, exterior color, model name. {9}------------------------------------------------ Image /page/9/Picture/0 description: The image is a logo for DRGEM, a healthcare provider. The logo features the text "DRGEM" in a bold, sans-serif font, with "DR" in black and "GEM" in teal. Below the company name is the tagline "Your Best Healthcare" in a smaller, lighter font. # Substantial Equivalence Comparison ### VII.SUBSTANTIAL EQUIVALENCE [21 CFR 807.92(b)] ## Substantial Equivalence Comparison Table | Item | Subject Device | Predicate Device | Impact of Differences | | | | |--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Device Name | GXR-Series<br>Diagnostic X-ray System | GXR-Series<br>Diagnostic X-ray System | Same | | | | | 510(k) number | K242019 | K202572 | - | | | | | Indication for use | The GXR-Series Diagnostic X-ray System is intended<br>for use in obtaining human anatomical images for<br>medical diagnostic by using X-rays. | GXR-Series Diagnostic X-ray<br>System is a stationary X-ray<br>imaging system, for the<br>purpose of acquiring X-ray<br>images of the desired parts of<br>a patient's anatomy. This<br>device is not intended for<br>mammography or bone<br>density applications. | Both devices are<br>fundamentally intended to<br>acquire anatomical images of<br>patients for medical<br>diagnostic purposes.<br>This means they essentially<br>share the same indication for<br>use. Some contents<br>mentioned in the predicate<br>device's Indication for use are<br>described in the<br>IFU(operation<br>Manual)_Contraindication<br>section of the subject device. | | | | | Manufacturer | DRGEM Corporation | DRGEM Corporation | Same | | | | | | Analog Diagnostic<br>X-ray System | Digital Diagnostic<br>X-ray System | Analog<br>Diagnostic<br>X-ray System | Digital<br>Diagnostic<br>X-ray System | | | | | DRGEM | Fujifilm | DRGEM | DRGEM | DRGEM | Variant models (FDR Clinica<br>FGXR-S, CS, US) of Subject<br>Device have been added. | | Model<br>Name | •GXR-32S | •FDR Clinica<br>FGXR-32S | •GXR-32SD | •GXR-32S | •GXR-32SD | These models are<br>manufactured for OEM<br>Contractor (Fujifilm<br>Corporation). | | | •GXR-40S | •FDR Clinica<br>FGXR-40S | •GXR-40SD | •GXR-40S | •GXR-40SD | Difference between predicate<br>device (GXR-S, CS, US<br>'Analog Diagnostic X-ray<br>System') and OEM Model<br>(FDR Clinica FGXR-S, CS,<br>US) has only label, exterior<br>color.<br>All Specification is same as<br>predicate device (GXR-S, CS,<br>US). | | | •GXR-52S | •FDR Clinica<br>FGXR-52S | •GXR-52SD | •GXR-52S | •GXR-52SD | | | | •GXR-68S | •FDR Clinica<br>FGXR-68S | •GXR-68SD | •GXR-68S | •GXR-68SD | | | | •GXR-82S | •FDR Clinica<br>FGXR-82S | •GXR-82SD | •GXR-82S | •GXR-82SD | | | | •GXR-C32S | •FDR Clinica<br>FGXR-C32S | •GXR-C32SD | •GXR-C32S | •GXR-C32SD | | | | •GXR-C40S | •FDR Clinica<br>FGXR-C40S | •GXR-C40SD | •GXR-C40S | •GXR-C40SD | | | | •GXR-C52S | •FDR Clinica<br>FGXR-C52S | •GXR-C52SD | •GXR-C52S | •GXR-C52SD | | | | •GXR-U32S | •FDR Clinica<br>FGXR-U32S | •GXR-U32SD | •GXR-U32S | •GXR-U32SD | | | | •GXR-U40S | •FDR Clinica<br>FGXR-U40S | •GXR-U40SD | •GXR-U40S | •GXR-U40SD | | {10}------------------------------------------------ Image /page/10/Picture/0 description: The image shows the logo for DRGEM. The letters "DR" are in black, and the letters "GEM" are in teal. Below the logo is the text "Your Best Healthcare" in a smaller font. | 1. High Frequency X-ray Generator | | | | | |----------------------------------------------------------------------------|------------------------------|------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Output Power Rating (kW) | 32kW, 40kW, 52kW, 68kW, 82kW | 32kW, 40kW, 52kW, 68kW, 82kW | | | | Generator models (manufactured by DRGEM) | •GXR-32 | •GXR-32 | | | | | •GXR-40 | •GXR-40 | | | | | •GXR-52 | •GXR-52 | | | | | •GXR-68 | •GXR-68 | | | | | •GXR-82 | •GXR-82 | | | | | •GXR-C32 | •GXR-C32 | | | | | •GXR-C40 | •GXR-C40 | | | | | •GXR-C52 | •GXR-C52 | | | | | •GXR-U32 | •GXR-U32 | | | | | •GXR-U40 | •GXR-U40 | | | | Line voltage | 220~230VAC<br>380/400/480VAC | 220~230VAC<br>380/400/480VAC | | | | 2. Solid State X-ray Imaging Device (Digital Diagnostic X-ray System Only) | | | | | | Flat panel Detector | •PaxScan4343R v3 / VAREX | •PaxScan4343R v3 / VAREX | Additional Solid State X-ray<br>Image detectors from the<br>predicate can be used with<br>the system. The system has<br>been tested and there is "No<br>negative impact on safety or<br>effectiveness".<br>And also, All modified flat<br>panel detector have been<br>verified according to "SSXI<br>non-clinical performance<br>data"<br>There is no new potential or<br>increased safety risks<br>concerning were raised<br>because of this difference. | | | | •PaxScan4343RC / VAREX | •PaxScan4343RC / VAREX | | | | | •PaxScan4336W v4 / VAREX | •PaxScan4336W v4 / VAREX | | | | | •4343W (Basic) / VAREX | •4343W / VAREX | | | | | •XRpad2 3025 HWC-M / VAREX | •XRpad2 3025 HWC-M / VAREX | | | | | •XRpad2 4343 HWC-M / VAREX | •XRpad2 4343 HWC-M / VAREX | | | | | •XRpad2 4336 HWC-M / VAREX | •XRpad2 4336 HWC-M / VAREX | | | | | •Mano4343T / IRAY | •Mano4343T / IRAY | | | | | •Mano4343X / IRAY | •Mano4343X / IRAY | | | | | •Mano4336W / IRAY | •Mano4336W / IRAY | | | | | •Mano4343W / IRAY | •Mano4343W / IRAY | | | | | •Mars1417X / IRAY | •VIVIX-S1417N / VIEWWORKS | | | | | •Mars1717X / IRAY | •VIVIX-S1717N / VIEWWORKS | | | | | •Luna1012X / IRAY | | | | | | •A1417MCW / H&abyz | | | | | A1717MCW / H&abyz | | | | | | F1417MCW / H&abyz | | | | | | <b>3. Patient table</b> | | | | | | | PBT-4 (Motorized) | | PBT-4 (Motorized) | Yes, there is a difference. Models have been tested against International Safety and EMC Standards. Any differences between the subject device and predicate device do not change or add new potential safety risks. It is our determination that there is "No negative impact on safety or effectiveness" and there are no new potential or increased safety risks concerning this difference | | | PBT-6 (Motorized) | | PBT-6 (Motorized) | | | | PBT-6 (Deluxe) | | PBT-1 | | | | Table Top | Longitudinal | $1,100(\pm550)mm \pm10mm$ | | | | | | $840(\pm420)mm \pm10mm$ | | | | | | $640(\pm320)mm \pm10mm$…