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Clarification of Radiation Control Regulations For Manufacturers of Diagnostic X-Ray Equipment: Guidance for Industry and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health,Office of Product Evaluation and Quality,Office of In Vitro Diagnostics and Radiological Health09/27/2024
RecordkeepingData IntegrityQuality control testing programPerformance Standards

Description

FDA is issuing this guidance to provide clarification to industry and FDA staff of the Federal regulations that relate to diagnostic x-ray equipment. The Federal Food, Drug, and Cosmetic Act (FD&C Act) defines diagnostic x-ray systems as both a medical device and an electronic product, therefore these systems are subject to the provisions of the FD&C Act that apply to both medical devices and to electronic products, and their implementing regulations. This guidance document only addresses the requirements that apply to diagnostic x-ray equipment under the electronic product provisions of the FD&C Act and the regulations implementing those provisions. These regulations pertain to the recordkeeping, reporting, manufacturing, importing, and installation of electronic products. It does not address requirements that may apply to diagnostic x-ray equipment as medical devices. This guidance supersedes FDA's guidance entitled “Clarification of Radiation Control Regulations for Diagnostic X-Ray Equipment” (HHS Publication FDA 89-8221 issued in March 1989).

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

10
Diagnostic X-Ray Equipment

Guidance for manufacturers of diagnostic x-ray equipment regarding radiation control regulations.; Subject of the radiation control regulations; Clarification of Radiation Control Regulations For Manufacturers of Diagnostic X-Ray Equipment; General category of equipment covered by the guidance; subject of the radiation control regulations

Cephalometric systems

special purpose x-ray system

Podiatry

special purpose x-ray system

Mammography

special purpose x-ray system

Dental x-ray systems

designed for use with intraoral image receptors

Panoramic dental system

Laminographic view equipment using a rotating source

Fluoroscopic x-ray systems

Systems requiring LIH and air kerma displays

Fluoroscopic imaging device

Example of device where tube failure is a serious safety issue

Cone-Beam Computed Tomography

Devices subject to CT performance standards under 21 CFR 1020.33

Diagnostic x-ray systems

considered to be both medical devices and electronic products

Stakeholders

4
Manufacturer

Entity responsible for submitting NDINs

Importer

Must comply with registration if meeting facility/responsible person definitions

assembler

responsibilities provided in FDA's guidance regarding installation; Personnel who install equipment and must follow manufacturer instructions.; Reports installation of diagnostic x-ray systems; Defined as any person engaged in the business of assembling, replacing, or installing components into a diagnostic x-ray system.; Person who installs, adjusts, and tests equipment

Certifying Manufacturer

Entity responsible for designing systems to guarantee compliance; entity that certifies compliance with performance standards

Regulatory Context

Regulatory Activities

4
Public Comment

Process for submitting suggestions to docket FDA-2018-D-4115.

510(k)

Premarket notification submission type

certification

manufacturer must furnish certification that product conforms to all applicable standards

Investigational Device Exemption

A medical device submission type (IDE).

Document Types

5
identification label

must include the name and address of the manufacturer, the place and month and year of manufacture; Label containing manufacturer and model info

Assembly Instructions

Instructions provided to verify component labels and ensure compliance during installation.

Warning Label

Required safety statement on x-ray controls

Certification Label

Label denoting compliance with performance standards

Maintenance Schedule

Required documentation to keep equipment in compliance

Attributes

10
Date of Manufacture

Specific topic of importance for diagnostic x-ray equipment.; Required on identification labels in Month and Year format.; Determines which performance standards are applicable; required on identification labels

Illumination intensity

must be equal to or greater than 160 lux

Last image hold

Required display feature for fluoroscopic equipment

Air kerma rate

Measurement required to be displayed in fluoroscopy

Line-voltage regulation

Electrical parameter that must be specified by the manufacturer for compliant operation.

Date of Installation

The date the x-ray system is released to the facility for use on humans.

Technique factors

Peak tube potential, tube current, etc.

Readily accessible to view

Requirement for label placement

Aluminum Equivalence

Maximum requirements for front panels of cassette holders

model number

identification label must include the model number and serial number

Technical Details

Testing Methods

2
Final Compliance Tests

Tests performed after installation to ensure the system meets performance standards.

Certification testing

performed to confirm compatibility and compliance

Identified Hazards

Hazards

3
Accidental Radiation Occurrence

Safety concern addressed in the guidance.; Reportable event involving unintended radiation emission

X-ray leakage

radiation hazard limited by performance standards

Leakage radiation

Radiation emanating from the diagnostic source assembly except for the useful beam

Standards & References

External Standards

4
IEC 60417

Graphical symbols for use on equipment

IEC 60601-2-68

Standard for x-ray-based image-guided radiotherapy equipment

FDA Recognized Consensus Standards

Standards referenced in the document for compliance

IEC Standards

International Electrotechnical Commission standards for medical x-ray imaging devices

Specifications

7
Action limits

More stringent than regulatory limits to assure equipment meets standards

2 percent of the SID

alignment and indication tolerance

160 lux

minimum light intensity at 100 cm

Half-value layer

minimum HVL requirements for beam quality

Focal-spot size

Design specification for x-ray tubes

Technique factors

Prescribed parameters for radiation emission

Performance Standards

Regulatory requirements for the output and safety of x-ray equipment.

Related CFR Sections (17)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Failure to ensure proper monitoring of the investigation
2
Failure to adequately establish and maintain procedures for implementing CAPA
1
Misbranding under Section 502(t)(2) for Failure to Submit Required Information to GUDID
1
Failure to notify the Secretary of electronic product defects
1
Failure to report a medical device correction or removal to FDA
1
Misbranding under Section 502(c) for Failure to Have Compliant Labeling
1
Failure to adequately ensure complaints are evaluated for MDR reportability
1
Failure to adequately establish and maintain procedures for implementing corrective and preventative action (CAPA)
1
Failure to adequately establish and maintain procedures for validating the device design
1
Failure to establish and maintain procedures for validating the device design
1

Related Warning Letters (9)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)