(15 days)
The SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy is intended to provide brachytherapy when the physician chooses to deliver intracavitary radiation to the surgical margins following lumpectomy for breast cancer.
The SenoRad applicator consists of a multi-lumen catheter connected to an inflatable spherical balloon that can be attached to commercially available High Dose Rate remote afterloader equipment for passage of the radiation source delivery wire. Five radiation source wire lumens are provided; one central lumen located along the long axis of the applicator and four curved lumens symmetrically offset from the central lumen. The balloon is inflated to a 4 or 5 cm spherical shape by a controlled volume injection of physiological saline to approximately 32 or 55 ml, respectively.
The provided text describes the SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy, but it is a 510(k) summary focused on demonstrating substantial equivalence to predicate devices rather than a detailed study proving the device meets specific acceptance criteria in the way one might evaluate a diagnostic or AI-driven device.
Therefore, much of the requested information regarding acceptance criteria, specific device performance metrics, sample sizes, expert ground truth, adjudication methods, MRMC studies, and standalone algorithm performance, and training set information is not applicable or not present in this type of regulatory submission. This document aims to show that the new device is as safe and effective as existing legally marketed devices, rather than establishing novel performance benchmarks.
However, I can extract the information that is present:
1. Table of Acceptance Criteria and Reported Device Performance
As this is a substantial equivalence submission for a medical device rather than a performance study with explicit acceptance criteria for a diagnostic/AI tool, there isn't a table of statistical acceptance criteria (e.g., sensitivity, specificity, AUC) or corresponding reported performance metrics in the traditional sense.
Instead, the "acceptance criteria" are implied by the demonstration of substantial equivalence to predicate devices. The performance aspects evaluated were:
| Acceptance Criteria (Implied by Substantial Equivalence to Predicate Devices) | Reported Device Performance (Summary of Preclinical Testing) |
|---|---|
| Intended Use | Same as predicate devices |
| Indications for Use | Same as predicate devices: To provide brachytherapy when the physician chooses to deliver intracavitary radiation to the surgical margins following lumpectomy for breast cancer. |
| Intended Treatment Site | Same as predicate devices |
| Operating Principle | Same as predicate devices |
| Technological Characteristics | Same as predicate devices |
| Dosimetric Characteristics | Equivalent to current brachytherapy applicators. "Extensive preclinical testing was conducted to evaluate and characterize the performance... in vitro laboratory studies to demonstrate that the SenoRad applicator performed as intended under simulated use conditions. Biocompatibility testing was performed..." |
| Biocompatibility | Meets ISO 10993-1 requirements |
| Sterilization Method | Same as predicate devices |
| Materials of Construction | Materials vary but "have no impact on device safety." |
2. Sample size used for the test set and the data provenance
- Sample Size: Not specified in terms of a diagnostic test set with images/data for analysis. The preclinical testing involved "in vitro laboratory studies" and "biocompatibility testing," but the number of units or tests performed is not quantified.
- Data Provenance: The studies were "preclinical testing" and "in vitro laboratory studies." No information is provided on specific countries of origin or whether data was retrospective or prospective, as this isn't relevant for this type of device's submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. This device is a physical medical device (an applicator for brachytherapy), not a diagnostic or AI algorithm that requires expert-established ground truth on a test set (e.g., image annotations, clinical diagnoses). Its performance is evaluated through engineering and biocompatibility testing.
4. Adjudication method for the test set
- Not applicable. See point 3.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not applicable. This is not a diagnostic device or an AI-assisted device. It is an applicator for radiation therapy.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. See point 5.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for this device's evaluation is primarily based on engineering specifications, physical performance metrics (e.g., inflation to specific spherical shapes and volumes, source delivery wire passage), dosimetric characteristics (measured radiation dose profiles in a phantom, likely), and biocompatibility standards (ISO 10993-1). There is no "ground truth" from human expert consensus, pathology, or outcomes data in the context of this 510(k) submission.
8. The sample size for the training set
- Not applicable. This device is not an AI algorithm and does not have a "training set."
9. How the ground truth for the training set was established
- Not applicable. See point 8.
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Image /page/0/Picture/0 description: The image shows the text "SENORx" in a stylized font. The "O" in the word is replaced with a ribbon symbol, possibly representing a cause or awareness campaign. The font is bold and has serifs, giving it a classic and formal appearance.
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MAY 1 8 2007
5. 510(K) SUMMARY
| Prepared date | April 20, 2007 |
|---|---|
| 510(k) owner | SenoRx, Inc.11 ColumbiaAliso Viejo, CA 92656P. 949.362.4800 F. 949.362.3200 |
| Contact person | Eben Gordon |
| Device name | SenoRad Multi-Lumen Balloon Source Applicator forBrachytherapy |
| Common name | Multi-lumen balloon source applicator |
| Classification name | Remote controlled radionuclide source applicator |
| CFR classification | 21 CFR 892.570090 JAQ |
| Predicate device | Adjustable Multi-Catheter Source Applicator (K062241)MammoSite Radiation Therapy System (K041929) |
| Decision date | 11/9/2006 (K062241)8/26/2004 (K041929) |
| Device description | The SenoRad applicator consists of a multi-lumen catheterconnected to an inflatable spherical balloon that can be attachedto commercially available High Dose Rate remote afterloaderequipment for passage of the radiation source delivery wire.Five radiation source wire lumens are provided; one centrallumen located along the long axis of the applicator and fourcurved lumens symmetrically offset from the central lumen. Theballoon is inflated to a 4 or 5 cm spherical shape by a controlledvolume injection of physiological saline to approximately 32 or55 ml, respectively. |
| Indications for use | The SenoRad Multi-Lumen Balloon Source Applicator forBrachytherapy is intended to provide brachytherapy when thephysician chooses to deliver intracavitary radiation to thesurgical margins following lumpectomy for breast cancer. |
| Summary of substantial equivalence | Extensive preclinical testing was conducted to evaluate andcharacterize the performance of the SenoRad Multi-LumenBalloon Source Applicator. Preclinical studies conductedincluded in vitro laboratory studies to demonstrate that theSenoRad applicator performed as intended under simulated useconditions. Biocompatibility testing was performed to |
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SENORx
demonstrate that the materials meet ISO 10993-1 requirements. The dosimetry of the SenoRad applicator was characterized. Based on these findings, it was concluded that the SenoRad applicator could deliver an equivalent radiation dose as the current brachytherapy applicators.
The SenoRad applicator has the following similarities to the previously cleared predicate devices: same indications for use; same intended use; same intended treatment site; same operating principle; same technological characteristics; equivalent dosimetric characteristics; and same sterilization method. The materials of construction vary in a manner that has no impact on device safety.
In summary, the SenoRad Multi-Lumen Balloon Source Applicator as described in this submission is substantially equivalent to the predicate devices.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the circle is an image of an eagle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
OCT 2 2 2007
SenoRx, Inc. % Mr. Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1393 25th Street NW BUFFALO MN 55313
Re: K071229
Trade/Device Name: SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy Regulation Number: 21 CFR 892.5700 Regulation Name: Remote controlled radionuclide applicator system Regulatory Class: II Product Code: JAQ Dated: May 2, 2007 Received: May 3, 2007
Dear Mr. Job:
This letter corrects our substantially equivalent letter of May 18, 2007.
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). You may, therefore, market the device, subject to the general controls provisions of the Act and the limitations described below. 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.
The Office of Device Evaluation has determined that there is a reasonable likelihood that this device will be used for an intended use not identified in the proposed labeling and that such use could cause harm. Therefore, in accordance with Section 513(i)(1)(E) of the Act, the following limitation must appear in the Warnings section of the device's labeling:
The safety and effectiveness of the SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy as a replacement for whole breast irradiation in the treatment of breast cancer has not been established.
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The Warning must be presented within a black box, and the font should be bold and the same size as any surrounding text. The Warning should be the first item in your list of warnings.
Please note that the above labeling limitations are required by Section 513(i)(1)(E) of the Act. Therefore, a new 510(k) is required before these limitations are modified in any way or removed from the device's labeling.
The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and permits your device to proceed to the market. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification if the limitation statement described above is added to your labeling.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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 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.
If you desire specific information about the application of other labeling requirements to your device (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0100. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/cdrh/industry/support/index.html.
Sincerely yours,
Donna-Bea Tillman, Ph.D., M.P.A. Director Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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4. INDICATIONS FOR USE
510(k) Number (if known): 《071229
SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy _ Device Name:
Indications for Use:
The SenoRad Multi-Lumen Balloon Source Applicator for Brachytherapy is intended to provide brachytherapy when the physician chooses to deliver intracavitary radiation to the surgical margins following lumpectomy for breast cancer.
Prescription Use __ X (Part 21 CFR 801 Subpart D) AND/OR
Over the Counter Use
(21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Nancy C broador
productive, Abdominal, Radiological Device 510(k) Number
Page of
11
§ 892.5700 Remote controlled radionuclide applicator system.
(a)
Identification. A remote controlled radionuclide applicator system is an electromechanical or pneumatic device intended to enable an operator to apply, by remote control, a radionuclide source into the body or to the surface of the body for radiation therapy. This generic type of device may include patient and equipment supports, component parts, treatment planning computer programs, and accessories.(b)
Classification. Class II.