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IRISeg

Intuitive Surgical Inc. • Radiology • 12/10/2024

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

IRISeg is a standalone software application that leverages machine learning and manual tools to process contrast-enhanced kidney CT images, automatically segmenting key kidney structures to generate virtual 3D models. This device is primarily intended for visual, non-diagnostic use in preoperative surgical planning and intraoperative display, aiming to enhance visualization for qualified clinicians.

Summary

IRISeg, a new Class II medical image management and processing system by Intuitive Surgical Inc., has been determined substantially equivalent to legally marketed devices, allowing its market entry under general regulatory controls. This standalone software processes contrast-enhanced kidney CT images to support preoperative surgical planning and intraoperative display, providing visual output that is non-diagnostic and requires review by qualified clinicians. The device integrates both manual and machine learning-enabled tools for image analysis and segmentation, specifically designed to automatically segment four key kidney structures: parenchyma, artery, vein, and collecting system, while requiring manual input for masses. Performance testing, including rigorous software verification, machine learning algorithm evaluation using 81 clinical kidney CT scans, and cybersecurity assessments, confirmed that IRISeg's design output meets requirements without raising new safety or effectiveness concerns.

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

IRISegMedical deviceImage managementImage processingKidney CT imagesMachine learningSegmentationPreoperative surgical planningIntraoperative display3D models

Device Metadata

Submission Number
K242461
Company
Intuitive Surgical Inc.
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. How does the manual segmentation tool compare in accuracy and efficiency to the machine learning algorithm for complex kidney pathologies not automatically segmented?; What specific clinical benefits and improvements in surgical outcomes are anticipated from using IRISeg for preoperative planning and intraoperative display?; Given its non-diagnostic use, what are the precise guidelines or recommendations for clinicians to integrate IRISeg's 3D models with diagnostic imaging for comprehensive patient assessment?; Could the machine learning algorithm be expanded in future iterations to include automated segmentation of renal masses or other pathological structures?; What were the specific metrics and thresholds used to evaluate the performance of the machine learning algorithm on the 81 clinical kidney CT scans, and how do these benchmark against current clinical standards?

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 Score25/100
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(machine learning, algorithm)
✓ 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
- 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 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, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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IRISeg - Intuitive Surgical Inc. | ESL FDA AI Device Intelligence