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TruPlan Computed Tomography (CT) Imaging Software

Circle Cardiovascular Imaging, Inc. • Radiology • 01/18/2023

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

TruPlan CT Imaging Software assists in pre-procedural planning and post-procedural evaluation of Left Atrial Appendage Closure (LAAC) by providing advanced visualization, segmentation, and measurement tools from CT scans. The device leverages machine learning algorithms, trained on diverse datasets, for automated left heart segmentation and initial landing zone detection, which are then subject to user verification and refinement.

Summary

TruPlan Computed Tomography (CT) Imaging Software is a medical device designed to assist qualified users with image-based pre-procedural planning, sizing, and post-procedural evaluation for Left Atrial Appendage Closure (LAAC) procedures in adult patients. It utilizes pre-existing CT data, manually uploaded by the user, to enable visualization and measurement of heart and vessel structures. The software provides functionalities such as segmentation of cardiovascular structures, various image reconstruction and visualization techniques (2D review, Volume Rendering, MPR), simulation of TEE, ICE, and fluoroscopic views, along with measurement and annotation tools (distance, perimeter, area, angle, signal intensity, coordinates), and reporting capabilities. TruPlan is intended as an aid to the existing standard of care, not a replacement for current planning or follow-up applications. The software incorporates machine learning for two key functions: Left Heart Segmentation, which generates a 3D rendering of the left heart (left ventricle, left atrium, LAA) for visualization, and Landing Zone Detection, which initializes the landing zone for LAAC device sizing, requiring user review and correction. The Left Heart Segmentation algorithm was trained on 113 cases and validated on 533 anonymized patient images, achieving 99.81% bone removal and 97.37% LAA visualization. The Landing Zone Detection algorithm was trained on 273 cases and validated on 100 samples, with landing zone plane distance within 10 mm in 97% of cases and contour center distance within 12 mm in 99% of cases. Training data for these models was sourced from multiple clinical sites and CT scanner vendors to ensure model generalization.

AI Regulatory Concerns

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Keywords

TruPlanComputed Tomography (CT)Left Atrial Appendage Closure (LAAC)Cardiovascular ImagingImage ProcessingMachine LearningSegmentationVisualizationPre-procedural PlanningPost-procedural Evaluation

Device Metadata

Submission Number
K222593
Company
Circle Cardiovascular Imaging, 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. How does the performance of TruPlan's machine learning algorithms for Left Heart Segmentation and Landing Zone Detection vary across different CT scanner manufacturers and imaging protocols not extensively represented in the training/validation datasets?; What is the typical learning curve for clinicians to become proficient in using TruPlan, particularly the manual correction of machine learning-generated initializations?; Beyond the reported accuracy metrics for segmentation and detection, what is the quantifiable impact of TruPlan on procedural planning time and inter-observer variability compared to traditional methods?; Are there any known anatomical variations of the LAA or patient characteristics where the machine learning algorithms exhibit reduced performance or require more significant manual user adjustment?; Could the machine learning models in TruPlan be adapted or retrained for pre-procedural planning of other cardiovascular interventions beyond LAAC?

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 Score30/100
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, machine learning, algorithm, dataset, annotation)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(server)
✓ 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, SaaSBOM 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, OBOM. These may be present in the full FDA submission.

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TruPlan Computed Tomography (CT) Imaging Software - Circle Cardiovascular Imaging, Inc. | ESL FDA AI Device Intelligence