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AI Segmentation

Varian Medical Systems, Inc. • Radiology • 04/19/2021

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The AI Segmentation software employs a cloud-hosted, hybrid approach combining deep learning and classical algorithms to automate the delineation of organs at risk from CT images for radiation therapy planning. Its purpose is to provide an initial contouring framework for various anatomical sites, requiring subsequent review, potential modification, and approval by clinical experts within a separate treatment planning system to aid in the efficiency of the planning process.

Summary

Varian's AI Segmentation is a cloud-based, web application software designed to assist medical professionals in radiation therapy treatment planning. It utilizes a combination of deep learning and classical algorithms to automatically segment organs at risk from CT images across predefined anatomical regions: head and neck, thorax, pelvis, and abdomen. The software provides tools for visualizing these automatically generated structures, which are then intended for export into a compatible treatment planning system, such as Varian's Eclipse. The AI algorithms employed are static and non-adaptive, meaning their behavior does not change based on user input over time, and the system itself does not include manual editing or contouring tools. The primary function of AI Segmentation is to provide an initial set of anatomical contours derived from CT scans, thereby facilitating the radiation therapy planning workflow. It is explicitly stated that the software is not intended to provide clinical decisions, medical advice, or evaluations of radiation plans or treatment procedures. All segmentation results generated by the AI must be thoroughly reviewed, edited as necessary, and ultimately approved by qualified radiation therapy treatment planners and physicians within the external treatment planning system. The device's performance was established through software verification and validation testing according to industry standards, without the use of animal or clinical studies, demonstrating its capability to perform as intended under specified use conditions.

AI Regulatory Concerns

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Keywords

AI SegmentationDeep LearningRadiation TherapyTreatment PlanningOrgan SegmentationCT ImagesCloud-based SoftwareMedical Image AnalysisAutomated ContouringOrgans at Risk

Device Metadata

Submission Number
K203469
Company
Varian Medical Systems, Inc.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Intervention
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. What specific deep learning architectures and classical algorithms are combined in the AI Segmentation software, and how does this hybrid approach enhance segmentation accuracy or efficiency compared to standalone methods?; How does the AI Segmentation's performance, quantified by metrics like Dice Similarity Coefficient or Hausdorff Distance, vary across different anatomical regions (head/neck, thorax, pelvis, abdomen) and for specific organs at risk, particularly those with low contrast or complex boundaries?; Considering its cloud-based deployment, what are the specific data security, patient privacy (e.g., HIPAA compliance), and data integrity measures implemented for the transfer, storage, and processing of CT image data?; Given that the AI algorithms are static and non-adaptive, what is the proposed lifecycle for model updates or retraining to incorporate advancements, address newly identified limitations, or adapt to evolving imaging protocols?; How does the integration of AI Segmentation (which lacks internal manual editing tools) into the Eclipse Treatment Planning System specifically impact the overall workflow efficiency and time spent by radiation therapy planners on contouring tasks compared to traditional methods or the predicate device?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (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 Score35/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment✓ Detected 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(deep learning, algorithm, retraining)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, hosted)
✓ 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(deployment)
✓ 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, SaaSBOM, OBOM 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, HBOM, CBOM, VDR/VEX. These may be present in the full FDA submission.

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AI Segmentation - Varian Medical Systems, Inc. | ESL FDA AI Device Intelligence