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OTIS 2.1 Optical Coherence Tomography System, THiA Optical Coherence Tomography System

Perimeter Medical Imaging AI, Inc. • Radiology • 02/25/2021

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

The Perimeter OTIS™ 2.1 system is an imaging tool utilizing optical coherence tomography to provide real-time, high-resolution, cross-sectional subsurface visualization of excised human tissue microstructure. It operates by detecting changes in tissue optical properties via an interferometric comparison of reference and backscattered light, enabling standardized image acquisition, review, and annotation for detailed tissue evaluation.

Summary

The Perimeter OTIS™ 2.1 is an optical coherence tomography (OCT) system designed as an imaging tool for the ex vivo evaluation of human tissue microstructure. Its methodology is based on OCT, which, similar to ultrasound, generates images but utilizes non-ionizing, low-power optical radiation. The system employs an interferometer to compare a reference light beam with light backscattered from the tissue sample. Image contrast is derived from variations in the tissue's optical properties, such as scattering, absorption, and index of refraction, allowing for high-resolution, sub-surface visualization. The OTIS™ 2.1 automates the OCT scanning process across the specimen surface, standardizing image collection. The device provides two-dimensional, cross-sectional, real-time depth visualization and includes image review manipulation software for identifying and annotating regions of interest. It allows for concurrent image review and acquisition. Key imaging specifications include a center wavelength of 1325 ± 15 μm, lateral resolution of 20 μm, and axial resolution of 10–15 μm in tissue, with a scan acquisition time of less than one minute for a 5x5 cm area. The OTIS™ 2.1 represents an updated version of the OTIS 2.0, featuring a smaller cart footprint, a faster PC, design improvements for manufacturability, component updates, optimized image acquisition and processing, and an improved graphical user interface. These enhancements do not alter the fundamental scientific technology or intended use, and performance testing confirmed its capabilities for evaluating excised tissue.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

Optical Coherence Tomography (OCT)Excised Human TissueMicrostructure ImagingInterferometerBackscattered LightSub-surface ImagingReal-time VisualizationImage AnnotationNon-ionizing RadiationTissue Optical Properties

Device Metadata

Submission Number
K203578
Company
Perimeter Medical Imaging AI, Inc.
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 10-15 μm axial resolution of the OTIS™ 2.1 system correlate with the detection limits for specific microstructural features relevant to pathological assessment in different tissue types (e.g., breast, skin, prostate)?; What is the maximum imaging depth achievable by the OTIS™ 2.1 in various types of excised human tissue, and how does tissue density or composition affect this depth and image quality?; Can the image annotation and manipulation software be integrated with existing digital pathology workflows or AI-driven diagnostic tools to enhance or expedite tissue analysis?; Beyond identifying regions of interest, what quantitative metrics, if any, can be derived from the OTIS™ 2.1 images (e.g., tissue scattering coefficients, layer thickness) that might provide objective measures for tissue characterization?; How does the "concurrent image review and acquisition" feature impact the workflow efficiency in a clinical or research setting, particularly during procedures like intraoperative margin assessment?

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(annotation)
✓ 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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OTIS 2.1 Optical Coherence Tomography System, THiA Optical Coherence Tomography System - Perimeter Medical Imaging AI, Inc. | ESL FDA AI Device Intelligence