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MSKai

MSKai • Radiology • 12/16/2024

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

The MSKai device is a Class II Medical Image Management and Processing System designed to provide qualitative viewing and quantitative lumbar spine measurements from T2-weighted MRI. Its functionality relies on image identification and post-processing algorithms, validated through non-clinical performance testing which demonstrated accuracy for anatomical segmentations and measurements, affirming its safety and effectiveness for assisting medical professionals.

Summary

The MSKai device is categorized as a Class II Medical Image Management and Processing System, and following a comprehensive review, it was deemed substantially equivalent for its intended indications, permitting its marketing under general regulatory controls. These controls ensure ongoing compliance with requirements such as annual registration, device listing, adherence to good manufacturing practices, specific labeling, and strict prohibitions against misbranding or adulteration, all while conforming to the Quality System regulation. The MSKai software functions as an advanced tool for image identification, post-processing, measurement, and reporting, specifically designed to provide qualitative viewing and quantitative spine measurements from pre-acquired T2-weighted DICOM lumbar spine MRI images. While it is not intended for diagnostic purposes, it significantly aids physicians, radiologists, and other medical professionals in their review, evaluation, and analysis. Rigorous non-clinical performance testing, including software design verification, a standalone performance assessment study, and cybersecurity evaluations, confirmed the software's accuracy for anatomical segmentations and measurements within specified margins, thereby affirming its safety and effectiveness.

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

MSKai deviceMedical Image ManagementImage ProcessingT2-weighted MRILumbar SpineQuantitative MeasurementsSoftwareDICOMNon-clinical TestingSubstantial Equivalence

Device Metadata

Submission Number
K240793
Company
MSKai
Panel
Radiology
Product Code
N/A
Data Type
N/A
Clinical Function
N/A
AI Function
N/A
AI Subclass
N/A

Relevant Clinical Questions

  • Q1. Given it is not a diagnostic device, how is the MSKai intended to integrate into clinical workflows without leading to misinterpretation or over-reliance by physicians?; What are the specific "defined margins" for accuracy of anatomical segmentations and measurements, and how do these compare to inter-reader variability or established clinical benchmarks?; Beyond general "cybersecurity evaluations," what specific vulnerabilities were tested, and what detailed measures are in place to protect patient data managed by the system?; What types of T2-weighted DICOM lumbar spine MRI images (e.g., specific sequences, field strengths, patient populations) were used in the non-clinical performance testing, and does the device perform consistently across such variations?; Are there plans for post-market surveillance or clinical validation studies to further assess the device's utility and impact on patient outcomes or diagnostic efficiency in real-world settings?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Post-§524B but no clear network capability detected

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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 Score45/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment✓ Detected in Summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

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(algorithm, labeling)
✓ 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(vulnerab)
✓ 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, VDR/VEX detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Not detected in AI-generated device summary: SBOM, SaaSBOM, HBOM, CBOM, OBOM. These may be present in the full FDA submission.

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MSKai - MSKai | ESL FDA AI Device Intelligence