SIEMENS K233539 Full Field Digital Mammography System Instructions
- June 1, 2024
- SIEMENS
Table of Contents
SIEMENS K233539 Full Field Digital Mammography System
SIEMENS K233539 Full Field Digital Mammography
Siemens Medical Solutions USA, Inc. Denise Adams Regulatory Affairs Professional 40 Liberty Boulevard MALVERN, PA 19355
Re: K233539
- Trade/Device Name : MAMMOMAT B.brilliant Regulation Number: 21 CFR 892.1715
- Regulation Name: Full-Field Digital Mammography System Regulatory Class: Class II
- Product Code : MUE
- Dated: February 23, 2024
- Received: February 23, 2024
Dear Denise Adams:
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 before
May 28, 1976, the enactment date of the Medical Device Amendments, or to
devices that have been reclassified by 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 control provisions of
the Act include requirements for annual registration, listing of devices, good
manufacturing practices, 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.
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 the FDA’s issuance of a substantial
equivalence determination does not mean that the FDA has determined 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 outlined 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. 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-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,
- Daniel M. Krainak, Ph.D. Assistant Director
- 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
Indications for Use
Submission Number (if known)
- K233539
- Device Name
- MAMMOMAT B.brilliant
- Indications for Use (Describe)
The digital mammography system MAMMOMAT B. brilliant is intended to be used for mammography exams, screening, diagnosis, biopsies, and dual-energy procedures under the supervision of medical professionals. Mammography images can be interpreted by either hard copy film or soft copy workstation. With Biopsy Option: The lnSpect feature for MAMMOMAT B. brilliant with HD Biopsy options is intended to provide digital X-ray images of core biopsy specimens to allow rapid verification that the correct tissue has been excised with the biopsy procedure.
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510(k) Summary: MAMMOMAT B.brilliant (K233539)
- Company: Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355
- Date Prepared: March 27, 2024
This 510(k) summary of safety and effectiveness information is being submitted by the requirements of SMDA 1990 and 21 CFR § 807.92.
General Information Importer / Distributor:
- Siemens Medical Solutions USA, Inc.
- 40 Liberty Boulevard
- Malvern, PA 19355
- Establishment Registration Number: 2240869
Location of Manufacturing Site
- Siemens Healthcare GmbH
- Siemensstr. 1
- 91301 Forchheim, Germany
- Establishment Registration Number: 3004977335
Contact Person:
- Denise Adams, RAC
- Regulatory Affairs Professional
- Siemens Medical Solutions USA, Inc.
- 40 Liberty Boulevard
- Malvern, PA 19355, USA
- adams.denise@siemens-healthineers.com
Alternate Contact Person
- Martin Rajchel
- Sr. Manager, Regulatory Affairs
- Siemens Medical Solutions USA, Inc.
- 40 Liberty Boulevard
- Malvern, PA 19355, USA
- martin.rajchel@siemens-healthineers.com
Device Name and Classification:
- Trade Name : MAMMOMAT B.brilliant
- Classification Name: Full Field Digital, System, X-Ray Mammographic
- Classification Panel : Radiology
- Classification Regulation : 21 CFR § 892.1715
- Device Class : II
- Product Code: MUE
Legally Marketed Predicate Device
- Trade Name: MAMMOMAT Revelation
- 510(k) #: K193166
- Classification Name: Full Field Digital, System, X-Ray Mammographic
- Classification Panel : Radiology
- Classification Regulation: 21 CFR §892.1715
- Device Class : II
- Product Code: MUE
Device Description:
MAMMOMAT B. Brilliant is a floor-mounted, full-field digital mammography
system for screening, diagnostic, and biopsy procedures on standing, seated,
or recumbent patients. The system consists of an examination stand with x-ray
generator, a gantry with tube housing assembly, and a mammography support
table, including a detector and an acquisition workstation with a radiation
shield. The MAMMOMAT B. brilliant comes with a variety of compression plates
and a biopsy attachment for diagnostic adjunct procedures. The MAMMOMAT B.
brilliant features an updated detector, a new image acquisition chain (tube,
filter, collimator), and improvements to the image acquisition workflow and
biopsy workflow. Adaptations have been made to the image processing due to the
new image acquisition hardware and the Soft- and hardware feature
improvements. Patient positioning features like a headrest have been added.
Indications for Use:
The digital mammography system MAMMOMAT B. brilliant is intended to be used
for mammography exams, screening, diagnosis, biopsies, and dual-energy
procedures under the supervision of medical professionals. The Mammography
images can be interpreted by either hard copy film or soft copy workstation.
With Biopsy Option: The InSpect feature for MAMMOMAT B. brilliant with HD
Biopsy options is intended to provide digital X-ray images of core biopsy
specimens to allow rapid verification that the correct tissue has been excised
with the biopsy procedure.
Substantial Equivalence:
The Siemens MAMMOMAT B. Brilliant with VA10 is substantially equivalent to the
commercially available Siemens MAMMOMAT Revelation with VC20 (K193166).
Table 1: Comparison of the Subject to the Primary Predicate
Attributes| Predicate device MAMMOMAT
Revelation VC20, K193166
| Subject device MAMMOMAT
B.brilliant
| Remarks
---|---|---|---
Indications for Use| The MAMMOMAT
Revelation is intended to be
| The digital mammography
system MAMMOMAT
| Same
Attributes| Predicate device MAMMOMAT
Revelation VC20, K193166
| Subject device MAMMOMAT
B.brilliant
| Remarks
---|---|---|---
| used for mammography exams, screening, diagnostics, biopsies, and dual-
energy procedures under the supervision of medical professionals.
The Mammography images can be interpreted by either hard copy film or soft copy
workstation.
| B. brilliant is intended to be used for mammography exams, screening, diagnosis, biopsies, and dual-energy procedures under the supervision of medical professionals.
Mammography images can be interpreted by
either hard copy film or soft copy workstation.
|
With Biopsy Option: The InSpect feature for MAMMOMAT
Revelation with HD Biopsy options is intended to provide digital X-ray images of core biopsy specimens to allow rapid verification that the correct tissue has been excised with the
biopsy procedure.
| With Biopsy Option: The InSpect feature for MAMMOMAT
B. Brilliant with HD Biopsy options is intended to provide digital X-ray images of core biopsy specimens to allow rapid verification that the correct tissue has been excised with the biopsy procedure.
Product Code| MUE| MUE| Same
System configuration
X-ray Stand| Floor mounted X-ray system| Floor-mounted X-ray system|
Different; housing design
changed; new Collision detection zone;
fixed headrest and ComfortGuide Display added to
support patient
Attributes| Predicate device MAMMOMAT
Revelation VC20, K193166
| Subject device MAMMOMAT
B.brilliant
| Remarks
---|---|---|---
| | | positioning and technologist
X-ray Generator kV range| 5 kW
23 kV to 35 kV
45 kV to 49 kV
| 5 kW
23 kV to 40 kV
45 kV to 49 kV
| Different;
Increased kV range for FFDM
X-ray Tube| P49| STTA _P49_FFS| Different;
increased x-ray output
Anode-filter combinations| W / Rh (50 μm), W/Ti (1.0 mm)| W / Al (1.0 mm)
W / Ti (1.3 mm) W/AI (0.7 mm)
| Different;
Thickness and material changed.
Collimator| Automatic for all sizes| Automatic for all sizes| Different; more compact:
Gain more space
below collimator e.g. for Biopsy
Compression unit| Automatic and manual operation| Automatic and manual operation| Different; Redesign for better access to
emergency release
Object table| Carbon fiber mammography support system| Carbon fiber mammography support system| Minor;
Lower contour adapted;
same material, same supplier
Detector| LMAM2v2| LMAM3-DS85| Minor;
a new generation of the detector; same supplier, same
technology;
Detector software| PEGASUS| PEGASUS| Minor;
new SW Revision
Detector
manufacturer
| Analogic Canada| Analogic Canada| Same
Detector TFT| Amorphous Silicon (a-Si)| Amorphous Silicon (a-Si)| Same
Detector size| 24 cm x 30 cm| 24 cm x 30 cm| Same
Array size| 2816 x 3584| 2816 x 3584| Same
Pixel size| 85 µm x 85 µm| 85 µm x 85 µm| Same
Grid| Reciprocating 5:1 ratio| Reciprocating 5:1 ratio| Same
Magnification table| Magnification 1.5
and 1.8
| Magnification 1.5 and
1.8
| Minor;
Lower contour adapted;
same material
Attributes| Predicate device MAMMOMAT
Revelation VC20, K193166
| Subject device MAMMOMAT
B.brilliant
| Remarks
---|---|---|---
Biopsy attachment| Yes| Yes| Minor;
Design change and Lower contour adapted;
same material
Tomo-guided biopsy| Yes| Yes| Different;
lateral biopsy optional with tomo pre- and
postfire;
Monitor/ Display| 19” and 21” TFT
display
| 19” and 21” TFT
display
| Same
Software controlled functions
System software| VC20| VA10| Different;
Improved functionality
TiCEM| Dual-energy imaging W/Ti 1,0 mm HE| Dual-energy imaging
W/Ti 1,3 mm HE
| Different;
The algorithm is the same; Parameters adapted due to X-ray spectra; increased mean energy of the X-ray
spectrum
AEC
Calculation
| AEC calculation| AEC calculation| Different;
The algorithm is the same. AEC parameters were adjusted due to x-ray spectra.
AEC pre-shot acquired
for Tomo biopsy adapted
Operating System| Windows 10| Windows 10| Same
Image processing algorithms| Preview| Preview| Different;
Same algorithms; different implementation (now on GPU) to accelerate the process; state of the art on GPU as higher performance.
Parameter adjustments due to new tube /x-ray spectra
DICOM| Yes| Yes| Same
Attributes| Predicate device MAMMOMAT
Revelation VC20, K193166
| Subject device MAMMOMAT
B.brilliant
| Remarks
---|---|---|---
Anti Scatter Grid| Yes| Yes| Same
Headrest Face shield| Face shield mounted on the tube head| Separate
stationary headrest with optional face shield| Different;
New to support patient positioning;
The face shield material is identical.
PRIME| yes| yes| Different; Functionality same; adjustments due to new filter; Application range
reduced.
other
Accessories| Compression plate holders| Compression plate holders|
Different for Biopsy and magnification; Adapted as travel path distance for
compression unit is changed;
other holders are the same
Accessories| Compression
plates
| Compression
plates
| same
Summary of Technological Characteristics of the Subject Device as compared
with the Predicate Devices:
The MAMMOMAT B.brilliant is based on the same principle of operation. It
features an updated detector, a new image acquisition chain (tube, filter,
collimator), and improvements to the image acquisition workflow and biopsy
workflow. The image processing algorithms for FFDM are identical to those of
the predicate with parameter adjustments due to the new image acquisition
chain.
The subject device does introduce improvements to the present features. These
improvements are:
- New software version
- Improvements to the positioning of patients with ComfortMove functionality
- Improvements to the Biopsy workflow
- Improvements to the Contrast Enhanced Mammography
In addition, hardware changes are made compared to the MAMMOMAT Revelation
- A new generation of detector
- New tube with flying focal spot
- New and changed filter materials
- New AWS-PC with state-of-the-art performance
- Improved comfort for patients due to new positioning support
- Improvements concerning usability like a ComfortGuide Display and the adapted lighting concept.
Summary of Non-Clinical Tests:
The Siemens MAMMOMAT B. brilliant was tested and complies with the voluntary
standards listed in the table below.
Table 2: List of Standards
DICOM standard| Digital Imaging and Communications in Medicine
Health informatics – Digital imaging and communication in medicine (DICOM) including workflow and data management (ISO 12052); English version EN ISO 12052 / NEMA PSE3
---|---
IEC 60601-1:2005 + A1:2012
Edition 3.1
+ ANSI/AAMI ES
60601-1 /AMENDMENT
1: 2012
C1:2009/(R)2012 + A2:2010/(R)2012
| Medical electrical equipment – Part 1: General requirements for basic safety
and essential performance
IEC 60601-1-2:2014
Edition 4.0
| Medical electrical equipment – Part 1-2: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic disturbances – Requirements and tests / Endorsement notice (EN 60601-1-2 Edition 4.0 / IEC 60601-1-
2:2014)
IEC 60601-1-3: 2008 +
A1: 2013
| Medical electrical equipment – Part 1: General requirements for safety – 3rd
collateral standard: General requirements for radiation protection in
diagnostic X-ray equipment (IEC 60601-1- 3:2008)
IEC 60601-1-6 Edition
3.2 2020-07
| Medical electrical equipment – Part 1-6: General requirements for basic
safety and essential performance – Collateral standard: Usability (IEC
60601-1-2:2013)
IEC 60601-2-28:2017
Edition 3.0
| Medical electrical equipment Part 2-28: Particular requirements for the
basic safety and essential performance of Xray tube assemblies for medical
diagnosis (IEC 60601-2-28:2017)
IEC 60601-2- 45:2011+A1:2015 Ed 3.1| Medical electrical equipment Part 2-45:
Particular requirements for the basic safety and essential performance of
mammographic X-ray equipment and mammographic stereotactic devices
(IEC 60601-2-45:2011 + A1:2015)
---|---
ISO 10993-1:2018| Biological evaluation of medical devices – Part 1:
Evaluation and testing within a risk management process
ISO 14971:2019| Medical devices – Application of risk management to medical
devices
IEC 60825-1:2014| Safety of laser products – Part 1: Equipment Classification
and Requirements
IEC 62304:2006 + A1:2015
Edition 1.1
| Medical device software – Software life cycle processes
IEC 62366-1 Edition 1.1
2020-06
| Medical devices – Part 1: Application of usability engineering to medical
devices
ISO 17664-2:2021| Processing of health care products — Information to be
provided by the
medical device manufacturer for the processing of medical devices —
Part 2: Non-critical medical devices
In addition, the following tests were conducted:
Table 3: Summary of Non-clinical Tests
Test | Objective | Test Method | Acceptance Criteria | Results |
---|---|---|---|---|
Detector characteristics | Ensure non-inferiority to predicate | As described in |
FDA’s Class II Special Controls Guidance Document: Full-Field Digital Mammography
System
| Same or better than the predicate| passed
Dual-energy imaging| Ensure non-inferiority to predicate| Performance tests|
Same or better than the predicate| passed
Targeting accuracy| Ensure the accuracy of the biopsy
device
| Accuracy tests with phantom and calibration needle.| The needle tip must be no more than +/-1
mm in x, y, z
| passed
| | | direction from
the selected target point.
|
---|---|---|---|---
Biopsy images| Ensure non- inferiority to predicate| Performance tests| Same
or better than predicate| passed
PRIME| Ensure non- inferiority to
predicate
| Performance tests| Same or better than predicate| passed
The following quality assurance measures were applied to the development of the system:
- Risk Analysis
- Requirement Specification Reviews
- Design Reviews
- Integration testing (System verification)
The data demonstrates continued conformance with special controls for medical devices containing software. Non-clinical tests (integration and functional) were conducted on the MAMMOMAT B.brilliant during product development. The risk analysis was completed, and risk controls were implemented to mitigate identified hazards. The test results support that all the software specifications have met the acceptance criteria. Verification and validation testing were found acceptable to support the claim of substantial equivalence.
Summary of Clinical Tests
Siemens conducted a clinical image evaluation to determine if the FFDM images, when reviewed by expert radiologists, are of acceptable quality for mammographic usage. The image evaluation was carried out according to FDA’s Class II Special Controls Guidance Document: Full-Field Digital Mammography System. The image sets consisted of 19 FFDM cases including 4 cases with biopsy, 2 with PRIME, 3 with contrast-enhanced mammography cases (TiCEM), 3 of those cases with magnification views. The radiologists found all image sets to be of acceptable overall clinical image quality. The clinical image evaluation performed by 3 expert readers, together with the nonclinical testing conducted to support the change, demonstrates that the image quality of the MAMMOMAT B.brilliant with VA10 is substantially equivalent to the predicate device, the MAMMOMAT Revelation with VC20. The clinical image evaluation showed that the new MAMMOMAT B.brilliant system generates high-quality images. In summary, this clinical image evaluation, serving as supporting evidence, together with the non-clinical testing, has met the objective in demonstrating substantial equivalence when comparing the Siemens MAMMOMAT B.brilliant with VA10 to the Siemens MAMMOMAT Revelation with VC20.
General Safety and Effectiveness Concerns:
Instructions for use are included within the device labeling, and the
information provided will enable the user to operate the device safely and
effectively. Several safety features, including visual and audible warnings,
are incorporated into the system design.In addition, the MAMMOMAT B.brilliant
is continuously monitored and if an error occurs the system functions will be
blocked and an error message will be displayed. Furthermore, the operators are
health care professionals familiar with and responsible for the x-ray
examinations to be performed. To minimize electrical, mechanical, and
radiation hazards, Siemens adheres to recognized and established industry
practice and all equipment is subject to final performance testing.
Conclusion as to Substantial Equivalence:
The MAMMOMAT B. brilliant with VA10 has the same intended use, fundamental
scientific technology, and performance characteristics as the predicate,
MAMMOMAT Revelation with VC20 (K193166). Therefore, the MAMMOMAT B.brilliant
with VA10 is substantially equivalent to the predicate MAMMOMAT Revelation
with VC20.
Guidance documents
The following FDA guidance documents were utilized in this Premarket
Notification:
- Electromagnetic Compatibility (EMC) of Medical Devices Guidance for Industry and Food and Drug Administration Staff Document issued on June 6, 2022.
- Guidance for Industry and Food and Drug Administration Staff – Class II Special Controls Guidance Document: Full-Field Digital Mammography System Document issued on March 27, 2012
- Guidance for Industry and FDA Staff – Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on June 14, 2023
- Appropriate Use of Voluntary Consensus Standards in Premarket Submissions for Medical Devices – Guidance for Industry and Food and Drug Administration Staff Document issued on September 14, 2018.
- The 510(k) Program: Evaluation Substantial Equivalent in Premarket Notifications 510(k) – Guidance for Industry and Food and Drug Administration Staff Document issued on July 28, 2014
- Electronic Submission Template for Medical Device 510(k) Submissions Guidance for Industry and Food and Drug Administration Staff Document issued October 2, 2023
- Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions Guidance for Industry and Food and Drug Administration Staff Document issued on September 27, 2023.
References
- Siemens Healthineers | Corporate Home
- HHS Accessibility & Section 508 | HHS.gov
- U.S. Food and Drug Administration
- U.S. Food and Drug Administration
- 510(k) Premarket Notification
- Postmarketing Safety Reporting for Combination Products | FDA
- Device Advice: Comprehensive Regulatory Assistance | FDA
- Contact Us – Division of Industry and Consumer Education (DICE) | FDA
- Medical Device Reporting (MDR): How to Report Medical Device Problems | FDA
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