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Automatic Anatomy Recognition (AAR)

Quantitative Radiology Solutions, LLC • Radiology • 04/20/2021

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The Automatic Anatomy Recognition (AAR) system is a cloud-based, software-only medical device employing deep learning to automatically generate anatomical contours of organs at risk from non-contrast CT studies for radiation therapy planning in adult head & neck and thoracic oncology cases. It operates without human intervention for initial segmentation and requires DICOM 3.0 compatible third-party systems for contour display and modification, with its accuracy validated by DICE similarity coefficients and Hausdorff Distance metrics.

Summary

The Automatic Anatomy Recognition (AAR) system by Quantitative Radiology Solutions, LLC, is a software-only medical device operating on a Linux, cloud-based platform, intended for technicians and trained physicians. Its core purpose is to automatically derive contours of anatomical structures, specifically "organs at risk" (OAR), from non-contrast computed tomography (CT) studies. These DICOM 3.0 compliant contours serve as input for radiation treatment planning systems. AAR is designed for adult patients (18 years and older) and focuses on anatomical structures within the head & neck and thoracic body regions. It functions independently of the specific radiation treatment delivery method (e.g., photons, protons), modality (e.g., 3D-CRT, IMRT), therapeutic intent (e.g., curative, palliative), or the underlying disease process being treated. AAR employs deep learning algorithms to automatically process CT studies and generate contours without human intervention during the segmentation phase; it can receive, add/edit/delete, transmit, and input/export medical images and DICOM data. A crucial operational aspect is that AAR does not include tools for modifying the generated contours. Any required adjustments or display of contours must be performed using compatible third-party treatment planning systems, which must also adhere to DICOM 3.0 standards, similar to the CT scanners. The system's performance in automated segmentation accuracy was validated through tests using DICE similarity coefficients and mean 95% Hausdorff Distance (HD) calculations. Furthermore, comprehensive software verification and validation were conducted following the IEC 62304 standard, covering unit, integration, and system-level testing.

AI Regulatory Concerns

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Keywords

Automatic Anatomy Recognition (AAR)Radiation Therapy PlanningAnatomical ContouringOrgans at Risk (OAR)Computed Tomography (CT)Deep LearningCloud-based SoftwareHead and Neck OncologyThoracic OncologyDICOM 3.0

Device Metadata

Submission Number
K203610
Company
Quantitative Radiology Solutions, LLC
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 architecture is employed by AAR, and how was its training dataset curated to ensure robustness across diverse patient populations and CT scanner variations within the head & neck and thoracic regions?; Could you provide the quantitative results (e.g., mean DICE scores, Hausdorff distances with standard deviations) for specific organs at risk (e.g., spinal cord, lungs, parotid glands) achieved during the segmentation performance tests?; Given that AAR does not allow for contour modification, what is the anticipated clinical workflow adjustment, and what is the typical percentage of contours requiring modification in a downstream system based on pre-market evaluations?; How does the cloud-based deployment of AAR address data security, patient privacy (HIPAA compliance in the US context), and system latency, particularly when processing large CT datasets?; What are the documented failure modes or scenarios where AAR's automated contouring accuracy might be compromised (e.g., presence of metallic artifacts, significant anatomical anomalies, poor image quality), and are there any built-in quality indicators for the generated contours?

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(training data, deep learning, algorithm, dataset, model validation)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, platform)
✓ 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, operational)
✓ 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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Automatic Anatomy Recognition (AAR) - Quantitative Radiology Solutions, LLC | ESL FDA AI Device Intelligence