MammoScreen® BD is a software application intended for use with compatible full-field digital mammography and digital breast tomosynthesis systems. MammoScreen BD evaluates the breast tissue composition to provide an ACR BI-RADS 5th Edition breast density category. The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old. MammoScreen BD only produces adjunctive information to aid interpreting physicians in the assessment of breast tissue composition. It is not a diagnostic software. Patient management decisions should not be made solely based on analysis by MammoScreen BD.
Device Story
Software-only device (SaMD) using AI to assist radiologists in breast density assessment. Inputs: DICOM images (2D-mammograms, CC/MLO views of FFDM, or 2DSM from DBT). Processing: Deep learning modules analyze breast tissue composition; outputs ACR BI-RADS 5th Edition category as JSON file. Used in clinical settings by radiologists; integrates with third-party software (e.g., MammoScreen Suite) to display results in web UI, DICOM Structured Reports, or secondary capture images. Provides adjunctive information to support clinical decision-making; does not replace physician judgment. Benefits: Standardized, automated density assessment to aid screening interpretation.
Clinical Evidence
Bench testing only. Standalone performance validated against ground truth established by consensus of 5 breast radiologists (10+ years experience). Study included 1,155 studies (Hologic), 500 (Hologic Envision), and 490 (GE). Primary endpoint: Quadratically weighted Cohen's kappa. Results: Kappa 89.03 (Hologic), 89.54 (Hologic Envision), 93.19 (GE). All results met acceptance criteria (lower bound 95% CI > 0.85).
Technological Characteristics
Software-only (SaMD). Deep learning neural architecture. Inputs: DICOM images. Outputs: JSON breast density category. Connectivity: Integrates with third-party software via DICOM/JSON. Standards: IEC 62304 (software lifecycle), IEC 62366-1 (usability).
Indications for Use
Indicated for asymptomatic women aged 40+ undergoing screening mammography to provide ACR BI-RADS 5th Edition breast density categorization. Adjunctive tool for interpreting physicians; not for diagnostic use or sole patient management decisions.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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FDA U.S. FOOD & DRUG ADMINISTRATION
August 22, 2025
Therapixel
Pierre Fillard
Chief Scientific Officer
455 Promenade des Anglais
Nice, 06200
FRANCE
Re: K243685
Trade/Device Name: MammoScreen BD
Regulation Number: 21 CFR 892.2050
Regulation Name: Medical Image Management And Processing System
Regulatory Class: Class II
Product Code: QIH
Dated: July 23, 2025
Received: July 23, 2025
Dear Pierre Fillard:
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.
FDA's substantial equivalence determination also included the review and clearance of your Predetermined Change Control Plan (PCCP). Under section 515C(b)(1) of the Act, a new premarket notification is not required for a change to a device cleared under section 510(k) of the Act, if such change is consistent with an established PCCP granted pursuant to section 515C(b)(2) of the Act. Under 21 CFR 807.81(a)(3), a new
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
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K243685 - Pierre Fillard
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premarket notification is required if there is a major change or modification in the intended use of a device, or if there is a change or modification in a device that could significantly affect the safety or effectiveness of the device, e.g., a significant change or modification in design, material, chemical composition, energy source, or manufacturing process. Accordingly, if deviations from the established PCCP result in a major change or modification in the intended use of the device, or result in a change or modification in the device that could significantly affect the safety or effectiveness of the device, then a new premarket notification would be required consistent with section 515C(b)(1) of the Act and 21 CFR 807.81(a)(3). Failure to submit such a premarket submission would constitute adulteration and misbranding under sections 501(f)(1)(B) and 502(o) of the Act, respectively.
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 (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-reporting-combination-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-devices/device-advice-comprehensive-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
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K243685 - Pierre Fillard
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803), please go to https://www.fda.gov/medical-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory-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,
**MARJAN NABILI -S** for
Yanna Kang, Ph.D.
Assistant Director
Mammography and Ultrasound 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.
Submission Number (if known)
K243685
Device Name
MammoScreen BD
Indications for Use (Describe)
MammoScreen® BD is a software application intended for use with compatible full-field digital mammography and digital breast tomosynthesis systems. MammoScreen BD evaluates the breast tissue composition to provide an ACR BI-RADS 5th Edition breast density category. The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old.
MammoScreen BD only produces adjunctive information to aid interpreting physicians in the assessment of breast tissue composition. It is not a diagnostic software.
Patient management decisions should not be made solely based on analysis by MammoScreen BD.
Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)
# 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:
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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."
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THERAPIXEL
TRANSIER TRENTS
# 510(k) Summary
# K243685
This 510(k) summary of safety and effectiveness information is prepared in accordance with the requirements of 21 CFR § 807.92.
Applicant Information: Therapixel
455 Promenade des Anglais,
06200 Nice
France
Phone: +33 9 72 55 20 39
Submission Correspondent: Pierre Fillard
Chief Scientific Officer
Email: pfillard@therapixel.com
Phone: +33 6 83 71 28 09
Date Summary Prepared: Nov 20, 2024
# Device Information:
Trade Name: MammoScreen® BD
Common Name: Breast Density Assessment Software
Device Classification Name: Automated radiological image processing software
Regulation Number: 21 CFR §892.2050
Regulation Class: Class II
Product Code: QIH
Submission type: Traditional 510(k)
510(k) number: K243685
# Predicate Device:
The predicate device is MammoScreen® BD by Therapixel, cleared under K241561 (Product code QIH).
510(k) submission MammoScreen BD
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THERAPIXEL
TRADING·SERVING·INNOVATION·SERVICES
# Device Description:
MammoScreen BD is a software-only device (SaMD) using artificial intelligence to assist radiologists in the interpretation of mammograms. The purpose of the MammoScreen BD software is to automatically process a mammogram to assess the density of the breasts.
MammoScreen BD processes the 2D-mammograms standard views (CC and/or MLO of FFDM and/or the 2DSM from the DBT) to assess breast density.
For each examination, MammoScreen BD outputs the breast density following the ACR BI-RADS 5th Edition breast density category.
MammoScreen BD outputs can be integrated with compatible third-party software such as MammoScreen Suite. Results may be displayed in a web UI, as a DICOM Structured Report, a DICOM Secondary Capture Image, or within patient worklists by the third-party software.
MammoScreen BD takes as input a folder with images in DICOM formats and outputs breast density assessment in a form of a JSON file.
Note that the MammoScreen BD outputs should be used as complementary information by radiologists while interpreting breast density. Patient management decisions should not be made solely on the basis of analysis by MammoScreen BD, the medical professional interpreting the mammogram remains the sole decision-maker.
# Indication for Use:
MammoScreen® BD is a software application intended for use with compatible full-field digital mammography and digital breast tomosynthesis systems. MammoScreen BD evaluates the breast tissue composition to provide an ACR BI-RADS 5th Edition breast density category. The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old.
MammoScreen BD only produces adjunctive information to aid interpreting physicians in the assessment of breast tissue composition. It is not a diagnostic software.
Patient management decisions should not be made solely based on analysis by MammoScreen BD.
## Intended user population
Intended users of MammoScreen BD are physicians interpreting mammograms.
## Intended patient population
The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old.
510(k) submission MammoScreen BD
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THERAPIXEL
TRADING·SERVING·INDICT
Predicate device comparison:
| | Predicate device (MammoScreen BD – K241561) | Subject device (MammoScreen BD – K243685) |
| --- | --- | --- |
| Manufacturer | Therapixel | Therapixel |
| Regulation number | 892.2050 | 892.2050 |
| Product Code | QIH | QIH |
| Medical Class Device | Class II | Class II |
| Intended Use | MammoScreen® BD is a software application intended for use with compatible full-field digital mammography and digital breast tomosynthesis systems. MammoScreen BD evaluates the breast tissue composition to provide an ACR BI-RADS 5th Edition breast density category. The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old.
MammoScreen BD only produces adjunctive information to aid interpreting physicians in the assessment of breast tissue composition. It is not a diagnostic software.
Patient management decisions should not be made solely based on analysis by MammoScreen BD. | MammoScreen® BD is a software application intended for use with compatible full-field digital mammography and digital breast tomosynthesis systems. MammoScreen BD evaluates the breast tissue composition to provide an ACR BI-RADS 5th Edition breast density category. The device is intended to be used in the population of asymptomatic women undergoing screening mammography who are at least 40 years old.
MammoScreen BD only produces adjunctive information to aid interpreting physicians in the assessment of breast tissue composition. It is not a diagnostic software.
Patient management decisions should not be made solely based on analysis by MammoScreen BD. |
| Intended patient population | Asymptomatic women undergoing mammography | Asymptomatic women undergoing mammography |
| Intended user population | Interpreting physicians | Interpreting physicians |
| Anatomical Location | Breast | Breast |
| Design | Software-only device | Software-only device |
| Type of artificial intelligence | Supervised Machine Learning | Supervised Machine Learning |
| Input | Compatible full-field digital mammography and digital breast tomosynthesis systems (using Synthetic 2D (2DSM)) for Hologic. | Compatible full-field digital mammography and digital breast tomosynthesis systems (using Synthetic 2D (2DSM)) for Hologic and GE. |
| Output | Breast density assessment based on ACR BIRADS 5th edition category at the mammogram level. | Breast density assessment based on ACR BIRADS 5th edition category at the mammogram level. |
| Support of Hologic Envision system and GE mammograms | Not included | Included |
| Inclusion of PCCP | Predetermined Change Control Plan (PCCP) including: | Predetermined Change Control Plan (PCCP) including: |
510(k) submission MammoScreen BD
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THERAPIXEL
TRADING·SERVING·INSURANCE
| | • Support of GE mammograms (no re-training required)
• Support of Siemens mammograms (retraining required)
• Pre-training of backbone using Unsupervised Machine Learning (as opposed to Supervised Machine Learning) | • Support of Siemens mammograms (retraining required)
• Pre-training of backbone using Unsupervised Machine Learning (as opposed to Supervised Machine Learning) |
| --- | --- | --- |
The indication for the use of MammoScreen BD is similar to that of the predicate device. Both devices are intended for concurrent use by physicians interpreting breast images to help them with assessing the breast tissue composition. The devices are not intended as a replacement for the review of a physician or their clinical judgment.
The predicate device and the subject device are two software versions of MammoScreen BD. They both rely on the same fundamental scientific technology. The design changes of this new version of MammoScreen BD have been assessed at the software design level and do not raise different questions of safety and effectiveness than the previous version. For both devices, a choice of medical image processing and machine learning techniques are implemented. The system includes 'deep learning' modules for the assessment of the breast tissue composition. These modules are trained with very large databases of annotated mammograms.
The overall design of MammoScreen BD is the same than the design of the predicate device. Both versions assess the breast tissue composition in radiological breast images and provide information about the assessment of the breast density category to the user in the same manner. While MammoScreen BD has been evaluated on mammograms acquired with a wider range of systems to accept those, these modifications do not raise different questions about the safety and effectiveness of the device as compared to the predicate device. The devices have the same intended use. The modifications do not raise different questions about the safety and effectiveness of the device as compared to the predicate device. The safety and effectiveness of the device have been evaluated with a similar methodology as for the predicate device.
510(k) submission MammoScreen BD
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THERAPIXEL TRADING AND CO-OPERATING SYSTEMS
# Training dataset
De-identified screening mammograms used for training were retrospectively collected from 32,368 patients in 2 different US sites. A detailed description of the training data is available in the Table below:
| Total number of studies | 108,775 |
| --- | --- |
| Density distribution | A: 12.79% B: 34.58% C: 42.94% D: 9.38% Unknown (excluded): 0.31% |
| Patient ages | First quartile (Q1): 47.0 Mean: 56.0 Third quartile (Q3): 64.0 |
| Patient Race / Ethnicity | White: 49.13% Asian: 7.63% Black or African American: 0.43% Native Hawaiian or Pacific Islander: 0.09% Unknown: 42.72% |
| Manufacturer | Hologic: 61.63% GE: 38.37% |
# Non-Clinical Performance Testing
MammoScreen BD is a software-only device.
Tests have been performed in compliance with the following recognized consensus standards:
- IEC 62304:2006/A1:2016- Medical device software - Software life-cycle processes
- IEC 62366-1:2015+AMD1:2020- Medical devices - Application of usability engineering to medical devices.
MammoScreen BD has successfully completed integration and verification testing and beta validation. In addition, potential hazards have been evaluated and mitigated, and have acceptable levels.
As for the predicate device, the clinical validation of MammoScreen BD includes a standalone analysis of the software against a ground truth established by consensus among the visual assessment of 5 breast radiologists, results of this latter for Hologic Envision system are reported in Figure 1.
510(k) submission MammoScreen BD
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THERAPIXEL TRADING·MEDIA·PUBLIC
Accuracy = 85.40 with CI = [82.00, 88.40]
Cohen's Kappa (quadratic) = 89.54 with CI = [86.88, 91.69]
Cohen's Kappa (linear) = 83.75 with CI = [79.85, 87.00]
Accuracy = 93.00 with CI = [90.80, 95.20]
Cohen's Kappa (quadratic) = 86.00 with CI = [81.36, 90.25]
Cohen's Kappa (linear) = 86.00 with CI = [81.36, 90.25]

Figure 1 - (Left) Confusion matrix comparing the performance of MammoScreen-BD against the radiologist consensus assessment of breast density for the four-class BI-RADS breast density task on Hologic Envision. (Right) Confusion matrix comparing the performance of MammoScreen BD against the radiologist consensus assessment of breast density for the binary task. The number of exams within each bin is shown in parentheses.

The performance testing results indicate that the version MammoScreen BD algorithm does not pose any concerns regarding safety or effectiveness on a wider range of mammogram system. MammoScreen BD behaves equally well on CC and MLO views (Figure 2) and between different age groups and breast thicknesses.

Figure 2 - Contingency matrix comparing the breast density assessment (four-class BI-RADS breast density) of MammoScreen BD on CC and MLO views of the same patient (Hologic Envision). Individual assessments for CC (left) and MLO (right) are given. The number of exams within each bin is shown in parentheses.


Additionally, it was established that MammoScreen BD is non-inferior to the targeted performance.
510(k) submission MammoScreen BD
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THERAPIXEL
TRADING INSTITUTE FOR THE
THERAPIXEL
The standalone performance testing carried out to validate the device is summarized in what follows:
| | Hologic | Hologic Envision | GE |
| --- | --- | --- | --- |
| Statistics tests for primary objective | Superiority in standalone performance for density assignment of MammoScreen BD compared to a pre-determined reference value (KappaReference = 0.85). | | |
| Primary endpoint | No change from previous clearance. Quadratically weighted Cohen's kappa between the density assessment of MammoScreen BD and the established ground truth. Kappa quadratic = 89.03 [95% CI: 87.43 – 90.56] | Quadratically weighted Cohen's kappa between the density assessment of MammoScreen BD and the established ground truth. Kappa quadratic = 89.54 [95% CI: 86.88 – 91.69] | Quadratically weighted Cohen's kappa between the density assessment of MammoScreen BD and the established ground truth. Kappa quadratic = 93.19 [95% CI: 90.50 – 94.92] |
| Acceptance criteria | The one-sided p-value for the test H0: Kappa ≤ 0.85 is less than the significance level (α=0.05) and the lower bound of the 95% confidence interval for Kappa > 0.85 indicating that the observed weighted Kappa is statistically significantly greater than 0.85. | | |
| Number of included patients | 922 | 500 | 376 |
| Number of included studies | 1,155 | 500 | 490 |
| Age distribution | Range: [40 – 90] First quartile (Q1): 50.0 Mean: 58.5 Third quartile (Q3: 66.0 • Age < 55: 570 • 55 ≤ Age < 65: 308 • Age ≥ 65: 269 | Range: [36 – 86] First quartile (Q1): 48.0 Mean: 56.0 Third quartile (Q3): 65.0 • Age < 55: 234 • 55 ≤ Age < 65: 130 • Age ≥ 65: 136 | Range: [31 -86] First quartile (Q1): 47.0 Mean: 57.2 Third quartile (Q3): 67.0 • Age < 55: 234 • 55 ≤ Age < 65: 130 • Age ≥ 65: 136 |
| Race and Ethnicity distribution | White: 273 Asian: 102 Black or African American: 88 American indian or alaska native: 4 Native Hawaiian or pacific islander: 4 | Asian: 6 White: 401 Black or African American: 40 Hispanic: 23 Not Hispanic: 388 | Asian: 48 White: 48 Black: 41 Other (including American Indian, Alaska Native, Native Hawaiian or Other Pacific Islander): 83 Hispanic: 88 |
| Considered subgroups | Age | | |
| | Age < 55: A(53), B(182), C(239), D(96) 55 ≤ Age < 65: A(26), B(115), C(129), D(38) Age ≥ 65: A(34), B(138), C(83), D(14) | Age < 55: A(21), B(73), C(103), D(37) 55 ≤ Age < 65: A(14), B(59), C(52), D(4) Age ≥ 65: A(15), B(68), C(45), D(8) | Age < 55: A(9), B(44), C(118), D(37) 55 ≤ Age < 65: A(15), B(73), C(41), D(9) Age ≥ 65: A(18), B(83), C(41), D(4) |
| | Race | | |
| | Asian: A(2), B(52), C(61), D(17) White: A(59), B(176), C(137), D(34) | Asian: A(0), B(2), C(2), D(2) White: A(42), B(163), C(159), D(37) | Asian: A(1), B(31), C(28), D(8) White: A(11), B(17), C(21), D(7) Black: A(8), B(21), C(16), D(3) Other: A(9), B(59), C(48), D(10) |
510(k) submission MammoScreen BD
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THERAPIXEL
TRADING OIL & REACT
| | Black: A(20), B(32), C(34), D(9)
Other: A(1), B(3), C(4), D(0) | Black: A(3), B(16), C(18), D(3)
Hispanic: A(1), B(8), C(12), D(2)
Not Hispanic: A(39), B(160), C(148), D(41) | Hispanic: A(5), B(13), C(11), D(3) |
| --- | --- | --- | --- |
| | Data provenance | | |
| | USA: A(85), B(269), C(241), D(63)
EU: A(28), B(169), C(214), D(86) | USA: A(50), B(200), C(200), D(50) | USA: A(38), B(155), C(139), D(31)
EU: A(4), B(45), C(61), D(19) |
| | Breast thickness | | |
| | Thick. < 50: A(7), B(80), C(145), D(87)
50 ≤ Thick. < 70: A(43), B(272), C(252), D(58)
Thick. ≥ 70: A(63), B(86), C(58), D(4) | Thick. < 50: A(4), B(25), C(47), D(28)
50 ≤ Thick. < 70: A(25), B(104), C(115), D(20)
Thick. ≥ 70: A(21), B(71), C(38), D(2) | Thick. < 50: A(33), B(135), C(142), D(46)
50 ≤ Thick. < 70: A(4), B(51), C(49), D(3)
Thick. ≥ 70: A(5), B(14), C(9), D(1) |
| Truthing process | The reference standard for breast density value was established by majority rule among the assessment of 5 breast radiologists with at least 10 years of experience in breast imaging interpretation. | | |
| Independence of test data from training data | Data sources are separated into the training/tuning group and the test group. Sources in the training/tuning group may only be used for model training and tuning. Sources in the test group may only be used for external validation of the model’s performances on unseen data (i.e., from sources entirely left out during training and tuning).
Data used for the standalone performance testing only belongs to the test group. | | |
# Predetermined Change Control Plan (PCCP)
MammoScreen BD is powered by machine-learning neural architectures. Therapixel will make future algorithm improvements under a PCCP. The plan describes the future modifications, assesses their impact, and a modification protocol details how data management, re-training, performance evaluation and update procedures will be handled. The table below lists the anticipated modifications.
| | Modification #1
Support of Siemens Mammograms
(retraining required) | Modification #2
Pre-training of backbone using
Unsupervised Machine Learning (as
opposed to Supervised Machine
Learning) |
| --- | --- | --- |
| Data used for development and modifications, representing the target population | Siemens, FFDM
Siemens, 2DSM. | No new data collection is foreseen for this change. |
| Statistics tests for primary objective | Superiority in standalone performance for density assignment of MammoScreen BD compared to a pre-determined reference value (Kappa reference = 0.85). | |
510(k) submission MammoScreen BD
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THERAPIXEL
TRANSPORT AND LABORATORY
| Primary endpoints | Quadratically weighted Cohen’s kappa between the density assessment of MammoScreen and the established ground truth |
| --- | --- |
| Acceptance criteria | Lower bound of the 95% confidence interval > 0.85 |
| Validation activities | Upon demonstration of the superiority through the standalone performance testing, changes will be documented in a minor release amending:
• The Algorithm test protocol and results documents
• The Device Label, including the User Guide |
| Communication plan | Upcoming updates are communicated through advisory notices sent by email at least 2 weeks before deployment. Advisory notices contain:
• The new version identification,
• A summary of the change,
• The schedule for the application of the change,
• Statement that the Support team will contact the customer and/or user for acceptance, training or scheduling of the change, if necessary,
• A link to access the updated User Guide, where the changes mentioned are reflected.
Users may decide to opt out of the update during the 2-week notice period.
MammoScreen BD does not have its own user interface. The new labelling for MammoScreen BD will be available on the compatible third-party software once the update is activated. |
| Characterization of the device before and after implementation of changes | The device will be accessible to more centers, and thus to more woman. Prevents obsolescence of MammoScreen BD. Better representation of breast tissue diversity leading to higher overall performances and a better generalization on unseen data. |
| Monitoring, detection, and response to deviations in device performance | Therapixel monitors customer sites. The distribution of breast density assessment obtained is determined on a representative screening distribution, which serves as a Reference Distribution. Device monitoring compares breast density assessment in real conditions to the reference distribution and alerts of any deviations. The investigation can result in a field-safety notice, a Medical Device Report. |
# Conclusions
Performance testing results demonstrated that the device is safe and effective.
Therapixel has applied a risk management process following FDA-recognized standards to identify, evaluate, and mitigate all known hazards related to MammoScreen BD. All identified risks are effectively mitigated, and it can be concluded that the residual risk is outweighed by the benefits. Considering all data in this submission, the data provided in these 510(k) supports the safe and effective use of MammoScreen BD for its indications for use and substantial equivalence to the predicate device.
510(k) submission MammoScreen BD
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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.