K Number
K040706
Device Name
GEL MARK IV
Manufacturer
Date Cleared
2004-04-08

(21 days)

Product Code
Regulation Number
878.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Gel Mark IV is intended to radiographically and sonographically mark breast tissue prior to or during a breast biopsy procedure.
Device Description
Not Found
More Information

Not Found

Not Found

No
The 510(k) summary describes a physical marker for breast tissue and contains no mention of AI, ML, image processing, or any other computational analysis of data.

No
The device is used to mark breast tissue for imaging prior to or during a biopsy, which is a diagnostic procedure, not a therapeutic one.

No
The device is used to mark breast tissue for biopsy, which is an interventional procedure, not a diagnostic one. It aids in localization rather than providing a diagnosis.

No

The intended use describes a device that "mark[s] breast tissue prior to or during a breast biopsy procedure," which strongly implies a physical marker or implantable device, not software. The lack of a device description prevents definitive confirmation, but the function described is inherently hardware-based.

Based on the provided information, the Gel Mark IV is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to "radiographically and sonographically mark breast tissue prior to or during a breast biopsy procedure." This describes a device used in vivo (within the body) to aid in a medical procedure, not a test performed in vitro (outside the body) on biological samples to diagnose or monitor a condition.
  • Device Description (Not Found): While the description is missing, the intended use is the primary indicator.
  • Mentions image processing, AI, DNN, or ML (Not Found): These are often associated with IVDs that analyze images or data for diagnostic purposes. Their absence further supports it not being an IVD.
  • Input Imaging Modality: Radiography and sonography are imaging techniques used on the patient, not on a sample.
  • Anatomical Site: Breast tissue is the target in vivo.

IVDs are typically used to examine samples like blood, urine, tissue biopsies (after removal from the body), etc., to provide information about a patient's health status. The Gel Mark IV's function is to physically mark tissue within the body for guidance during a procedure.

N/A

Intended Use / Indications for Use

The Gel Mark IV is intended to radiographically and sonographically mark breast tissue prior to or during a breast biopsy procedure.

Product codes

NEU

Device Description

Not Found

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

breast tissue

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Not Found

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

Not Found

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.4300 Implantable clip.

(a)
Identification. An implantable clip is a clip-like device intended to connect internal tissues to aid healing. It is not absorbable.(b)
Classification. Class II.

0

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Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

APR - 8 2004

Ms. Amy Boucly Director, Regulatory Affairs and Quality Assurance SenoRx, Inc. 11 Columbia, Suite A Aliso Viego, California 92656

Re: K040706

Trade/Device Name: Gel Mark IV Tissue Marker Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: II Product Code: NEU Dated: March 17, 2004 Received: March 18, 2004

Dear Ms. Boucly:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be adviscd that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the clectronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

1

Page 2 - Ms. Amy Boucly

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Mark H. Milliman

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known): K040706

Device Name: Gel Mark IV Tissue Marker

Indications For Use:

The Gel Mark IV is intended to radiographically and sonographically mark breast tissue prior to or during a breast biopsy procedure.

Prescription Use × (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER, PAGE IF NEEDED)

Concurrence of CDRH, Office of Dévice Evaluation (ODE)

K04070

b. Mark A. Mellema

Division of General, Restorative, and Neurological Devices

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510(k) Number