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Second Opinion

Pearl Inc. • Radiology • 03/04/2022

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

Second Opinion® is an AI-driven software utilizing cloud-based computer vision and machine learning to analyze dental radiographs for nine types of dental features, serving as a second reader to aid dental professionals. Clinical validation, including MRMC studies with wAFROC analysis, scientifically demonstrates that the device significantly improves detection accuracy for pathologies such as caries and periapical radiolucency when used as an assistive tool by clinicians.

Summary

Second Opinion® is a computer-aided detection (CADe) software designed to assist dental health professionals in analyzing bitewing and periapical radiographs for patients aged 12 and older. It utilizes cloud-based computer vision and machine learning algorithms to identify and highlight regions suspected of containing nine dental findings, including pathologies like caries, margin discrepancies, calculus, and periapical radiolucencies, as well as restorations such as crowns, fillings, and implants, functioning as a second reader. The system architecture consists of an in-office client application, a cloud-hosted Application Programming Interface (API), and Computer Vision (CV) Models; these models process radiographic images, generate metadata detailing detected features and their properties, and the API delivers this information to the client interface for clinician review. The clinical efficacy and safety of Second Opinion® were assessed through standalone performance tests and a multi-reader, multi-case (MRMC) clinical study involving 25 readers and 2,010 images, with ground truth established by expert consensus using four expert readers. This MRMC study, employing the Weighted Alternative Free-Response Receiver Operating Characteristic (wAFROC) figure of merit, demonstrated a statistically significant improvement in detection accuracy when readers were aided by the software across all four targeted pathologic features: caries, margin discrepancy, calculus, and periapical radiolucency. Results indicated improved sensitivity for aided readers (ranging from 0.9% to 11.7% increases depending on the pathology) and, for most pathologies, a reduction in false positives per image, with no statistically significant degradation in reader performance, supporting its effectiveness as an assistive tool in dental radiographic interpretation.

AI Regulatory Concerns

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Keywords

Dental RadiographyComputer-Aided Detection (CADe)Machine LearningArtificial IntelligenceDental PathologyCaries DetectionPeriapical RadiolucencyMargin DiscrepancyCalculus DetectionSecond Reader

Device Metadata

Submission Number
K210365
Company
Pearl Inc.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection

Relevant Clinical Questions

  • Q1. The document highlights performance variations based on Jaccard Index (JI) thresholds (0.4 vs. 0.5); does the underlying study data, summarized here, provide a detailed rationale or sensitivity analysis for selecting JI ≥ 0.4 as optimal for both unaided reader lesion localization and device standalone performance evaluation across all detected features?; Regarding the 'open-source models' foundational to the Computer Vision algorithms, to what extent does the summarized technical documentation describe the specific models, the nature and volume of training data used for supervised machine learning, and the validation process for these adapted algorithms?; The MRMC study showed 100% of readers improved sensitivity for periapical radiolucency (PR) with aid, yet only 36% improved their false positive per image rate for PR. Does the clinical evaluation section provide further analysis on this specific outcome, such as common characteristics of PR false positives generated by the device or reader interpretations?; The device accepts multiple image formats (RVG, DICOM, JPEG, TIFF, PNG). Does the non-clinical testing summary detail the range of image acquisition equipment (e.g., different sensor brands, X-ray machine settings) from which these formats were sourced and tested to ensure consistent Computer Vision Model performance?; The document notes the software has a 'moderate level of software concern.' Does the software verification and validation testing summary elaborate on the specific risk mitigations implemented and tested, particularly concerning the cloud-based API and CV model interactions, to address potential failures or inaccuracies in a clinical setting?

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 Score40/100
SBOM Evidence✓ Detected 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(open-source)
✓ Detected
ML-BOMMachine Learning Bill of Materials(training data, machine learning, algorithm, ground truth, model performance)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, hosted)
✓ Detected
HBOMHardware Bill of Materials(sensor)
✓ 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 SBOM, ML-BOM, SaaSBOM, HBOM 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: CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Second Opinion - Pearl Inc. | ESL FDA AI Device Intelligence