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CoLumbo

Smart Soft Healthcare • Radiology • 08/15/2024

510(k)IEC 62304 Class B§524B Cyber Device
FDA Summary PDF

Device Purpose

CoLumbo is an advanced software tool that utilizes a deep convolutional neural network to provide quantitative measurements and feature segmentation from lumbar spine MR images, aiding clinicians in their analysis and reporting workflow. The system emphasizes user control and responsibility, requiring clinicians to validate all software-generated outputs and apply their medical judgment, thereby functioning as a sophisticated measurement aid rather than an autonomous diagnostic system.

Summary

CoLumbo is a software medical device designed for radiologists and neuro- and spine surgeons to assist in the post-processing and analysis of lumbar spine Magnetic Resonance (MR) images. It processes previously-acquired DICOM images from adult patients aged 18 and above, excluding cases involving pregnancy, MRI scans with contrast media, post-operational complications, tumors, or infections. The software provides quantitative measurements of various spinal features by enabling feature segmentation, precise measurement, and threshold-based labeling of out-of-range values. Its primary output is an exportable report of these measurements, which users must review, potentially revise, and approve, intended to aid in visualizing, measuring, and documenting findings rather than for direct diagnosis or treatment recommendation. The core technology of CoLumbo utilizes a Deep Convolutional Image-to-Image Neural Network for its analytical capabilities, semi-automatically initiating adjustable measurements derived from anatomical segmentations. These segmentations serve as visual aids and a basis for calculation, not as final diagnostic outputs. Users retain full control and responsibility by defining individualized software settings including thresholds for identifying out-of-range measurements, confirming or modifying all software-generated segmentations and measurements, and ultimately interpreting the comprehensive data using their medical judgment and discretion. The software's performance has been validated through non-clinical testing, including a standalone assessment study involving 100 MR images compared against a ground truth established by three radiologists, and it incorporates cybersecurity measures to protect data integrity.

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

CoLumboLumbar Spine MRIQuantitative ImagingImage Post-processingFeature SegmentationSpine MeasurementsDICOMNeural NetworkClinical Decision SupportRadiologist Tool

Device Metadata

Submission Number
K241211
Company
Smart Soft Healthcare
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. What specific deep learning architecture is employed in the "Deep Convolutional Image-to-Image Neural Network," and how was it trained and validated for diverse patient anatomies and pathologies not explicitly excluded?; How does the CoLumbo software handle variability in MR image acquisition parameters (e.g., sequence types, slice thickness, field strength) from different scanners, and what is its performance robustness across these variations?; The standalone performance assessment study compared CoLumbo outputs to a ground truth from 3 radiologists; what was the inter-rater reliability among these radiologists, and what were the specific performance metrics (e.g., Dice coefficient for segmentation, mean absolute error for measurements) achieved by the software?; How does the "rule-based algorithm" for modifiers interact with the neural network outputs, and to what extent can users customize these rules beyond simple threshold adjustments for identifying out-of-range measurements?; Given the exclusion of "post-operational complications, tumors, infections," what is the software's behavior or error handling when such conditions are inadvertently present in the input images, and are there any visual cues or warnings provided to the user in such scenarios?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Qualifies as a cyber device under §524B (post-Dec 2023, networked)

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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 in summary - likely in full submission per §524B
Cyber Risk Assessment✓ Detected in Summary
Postmarket Plan⚠ Not in summary - likely in full submission per §524B
§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(deep learning, neural network, algorithm, ground truth, labeling)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(network)
✓ 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(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.

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

• 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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CoLumbo - Smart Soft Healthcare | ESL FDA AI Device Intelligence