K Number
K062528
Device Name
TISSUE SITE MARKING SYSTEM
Date Cleared
2007-01-26

(150 days)

Product Code
Regulation Number
878.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Tissue Site Marking System is indicated for the permanent radiographic marking of sites in soft tissue.
Device Description
The Tissue Site Marking System is supplied as a sterile device and is intended for single patient use only. The Tissue Site Marking System is composed of two elements: 1) an implantable device (marker) including a bioabsorable component and a permanent component and 2) a deployment device. The Tissue Site Marking System is intended for use with the manual method of deployment under the following imaging modalities: ultrasound, x-ray, magnetic resonance, nuclear, computed tomography, and direct visualization.
More Information

Not Found

Not Found

No
The summary describes a physical device for marking tissue and its deployment mechanism. There is no mention of software, algorithms, or any computational processing that would suggest the use of AI or ML.

No.
The device is indicated for permanent radiographic marking, which is a diagnostic aid, and its description does not suggest treating or preventing a disease or condition.

No
The device is described as a "Tissue Site Marking System" used for permanent radiographic marking of sites in soft tissue. Its function is to mark a site, not to diagnose a condition or disease.

No

The device description explicitly states it is composed of an implantable device (marker) and a deployment device, which are hardware components.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is "for the permanent radiographic marking of sites in soft tissue." This describes a device used in vivo (within the body) for marking purposes, not for testing samples in vitro (outside the body) to diagnose conditions.
  • Device Description: The description clearly states it's an "implantable device" and a "deployment device." This further reinforces its use within the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue samples, etc.), reagents, or any process typically associated with in vitro diagnostic testing.

Therefore, the Tissue Site Marking System is a medical device used for marking within the body, not an IVD.

N/A

Intended Use / Indications for Use

The Tissue Site Marking System is indicated for the permanent radiographic marking of sites in soft tissue.

Product codes

NEU

Device Description

The Tissue Site Marking System is supplied as a sterile device and is intended for single patient use only. The Tissue Site Marking System is composed of two elements: 1) an implantable device (marker) including a bioabsorable component and a permanent component and 2) a deployment device. The Tissue Site Marking System is intended for use with the manual method of deployment under the following imaging modalities: ultrasound, x-ray, magnetic resonance, nuclear, computed tomography, and direct visualization.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

ultrasound, x-ray, magnetic resonance, nuclear, computed tomography, and direct visualization.

Anatomical Site

soft 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

Not Found

Key Metrics

Not Found

Predicate Device(s)

Not Found

Reference Device(s)

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

SECTION I - 510(K) Summa FOI Re leasable

JAN 26 2007

Pursuant to § 513(i)(3)(A) of the Food, Drug, and Cosmetic Act, Suros Surgical Systems, Inc. is required to submit with this premarket notification " ... adequate summary of any information respecting safety and effectiveness or state that such information will be made available upon request of any person." Suros Surgical Systems, Inc. chooses to submit a summary of information respecting safety and effectiveness.

Classification Name:Marker, Radiographic Implantable
Common/Usual Name:Tissue Site Marking System
Proprietary Name:None at this time
Device Classification:Class II
DescriptionNumber21 CFR Ref
Implantable ClipNEU§ 878.4300

Owner/Operator: Suros Surgical Systems, Inc. - FDA Registration # 3003862400 Northwest Technology Center 6100 Technology Center Drive Indianapolis, IN 46278 317-344-7500

Contact: Heidi Strunk Director, Quality & Regulatory Suros Surgical Systems, Inc. Northwest Technology Center 6100 Technology Center Drive Indianapolis, IN 46278 317-344-7500

DESCRIPTION OF DEVICE

The Tissue Site Marking System is supplied as a sterile device and is intended for single patient use only. The Tissue Site Marking System is composed of two elements:

  1. an implantable device (marker) including a bioabsorable component and a permanent component and

1

SECTION I - 510(K) Summary

  1. a deployment device.

The Tissue Site Marking System is intended for use with the manual method of deployment under the following imaging modalities: ultrasound, x-ray, magnetic resonance, nuclear, computed tomography, and direct visualization.

INDICATIONS FOR USE

The Tissue Site Marking System is indicated for the permanent radiographic marking of sites in soft tissue.

CONTRAINDICATIONS

None known

2

Image /page/2/Picture/0 description: The image shows a logo for the Ministry of Health & Human Services. The logo is circular and contains the text "MINISTRY OF HEALTH & HUMAN" around the left side of the circle. To the right of the text is a stylized image of an eagle.

Food and Drug Administration 9200 Corporate Blvd. Rockville MD 20850

Ms. Heidi H. Strunk Director, Quality and Regulatory Suros Surgical Systems. Inc. 6100 Technology Center Drive INDIANAPOLIS IN 46278

Re: K062528

Trade/Device Name: Tissue Site Marking System Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: II Product Code: NEU Dated: December 22, 2006 Received: December 26, 2006

JAN 2 6 7007

Dear Ms. Strunk:

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 indiver 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 Cometic 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. TTo general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulter of de

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), 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.

Image /page/2/Picture/10 description: The image shows a circular logo with the letters "FDA" in bold, stylized font in the center. Above the letters, the years "1906 - 2006" are printed, indicating a centennial celebration. Below the letters, the word "Centennial" is written in a cursive font, and there are three stars underneath. The logo is surrounded by a dotted circle, and there are small star shapes placed around the perimeter of the circle.

Promoting and Promoting Public Health

3

Please be advised 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 electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 one of the following numbers, based on the regulation number at the top of this letter:

21 CFR 876.xxx(Gastroenterology/Renal/Urology)240-276-0115
21 CFR 884.xxx(Obstetrics/Gynecology)240-276-0115
21 CFR 894.xxx(Radiology)240-276-0120
Other240-276-0100

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 (240) 276-3150

or at its Internet address http://www.fda.gov/cdrl/industry/support/index.html.

Sincerely yours.

Nancy C. Hogdon

Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

510(k) Number (if known):

Device Name: Tissue Site Marking System

Indications for Use: The Tissue Site Marking System is indicated for the permanent radiographic marking of sites in soft tissue.

2528

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

David A. Ingram

(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Devices 510(k) Number ________________________________________________________________________________________________________________________________________________________________

Prescription Use:
(Per 21 CFE 801.109)

OR

Over-the Counter Use:

:

(Optional Format 1-2-96)