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CT CoPilot

ZEPMED, LLC. • Radiology • 12/07/2016

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

CT CoPilot™ is a software application designed to automate the post-acquisition analysis of brain CT images, providing quantitative volumetric measurements, visualizations, and longitudinal comparison of anatomical structures. Its methodology involves proprietary algorithms for image segmentation, registration to a neuroanatomic atlas and prior patient scans, and the calculation of subtraction maps, with performance validated through laboratory testing demonstrating high accuracy in registration and segmentation for patients aged 18 and older.

Summary

CT CoPilot™ is a software tool designed for the automated analysis of CT brain images in patients aged 18 and older. Its primary purpose is to automate the traditionally manual tasks of identifying, labeling, visualizing, and quantifying the volume of segmentable brain structures by processing sets of CT images and providing automated registration and reformatting of the imaging data for use by trained personnel in Neuro CT imaging, though it is not intended for sole use in patient management decisions. The CT CoPilot™ system performs post-acquisition quantitative analysis by automatically reformatting images, labeling structures with color overlays, and calculating their numerical volumes, with outputs provided in standard DICOM format. For longitudinal studies, it co-registers current CT data to the patient's most recent prior processed exam, facilitating comparison through generation of voxel-by-voxel subtraction maps of Hounsfield Unit changes; this process relies on registration, alignment, and segmentation algorithms benchmarked against a reference neuroanatomic Atlas, and includes a 'measurement index' as a safety feature to ensure alignment quality. Laboratory testing demonstrated registration accuracy with inter-subject variability less than 15 degrees for yaw, roll, and pitch, and segmentation accuracy showing high correlation coefficients against expert manual segmentation for key structures: Lateral Ventricle Volume (98%), Total CSF Volume (98%), Intra-Cranial Volume (99%), and Midline Shift Index (95%), though performance can be affected by motion, artifacts, or significant anatomical deviations from the Atlas.

AI Regulatory Concerns

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Keywords

CT CoPilotBrain CTVolumetric QuantificationImage SegmentationAutomated LabelingNeuroanatomic AtlasDICOMImage RegistrationSubtraction MapsQuantitative Analysis

Device Metadata

Submission Number
K161322
Company
ZEPMED, LLC.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the 'measurement index' quantitatively define the limits of acceptable anatomic alignment variance, and what is the clinical impact of studies terminated due to exceeding this index?; What specific algorithms are used for segmentation and registration, and how do they compare in robustness to variations in CT scanner protocols or image quality?; The system generates voxel-by-voxel subtraction maps; how are these maps validated for clinical utility in tracking subtle pathological changes over time?; How does the performance of CT CoPilot™ vary across different types of brain pathologies not explicitly present in the reference neuroanatomic Atlas?; Given the reliance on a reference neuroanatomic Atlas, what is the process for updating or adapting the Atlas to account for diverse patient populations or newly identified anatomical variations?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score5/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan⚠ Not mentioned in summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(algorithm, labeling)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• Not detected in AI-generated device summary: SBOM, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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CT CoPilot - ZEPMED, LLC. | ESL FDA AI Device Intelligence