(7 days)
The EnCor Breast Biopsy System is indicated to provide breast tissue samples for diagnostic sampling of breast abnormalities. It is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality. It is intended to provide breast tissue for histologic examination with partial removal of a palpable abnormality. The extent of a histologic abnormality cannot always be readily determined from palpation or imaged appearance. Therefore, the extent of removal of the palpated or imaged evidence of an abnormality does not predict the extent of removal of a histologic abnormality, e.g., malignancy. When the sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures. In instances when a patient presents with a palpable abnormality that has been classified as benign through clinical and/or radiological criteria (e.g. fibroadenoma, fibrocystic lesion), the EnCor Breast Biopsy System may also be used to partially remove such palpable lesions. Whenever breast tissue is removed, histological evaluation of the tissue is the standard of care. When the sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures.
The EnCor Breast Biopsy System with its 7 and 10-Gauge biopsy probes has the following similarities with the predicate devices: same intended use; same design; same patient contacting materials; same operating principle; and same technological characteristics.
This 510(k) summary (K093512) for the SenoRx EnCor Breast Biopsy System does not contain a description of acceptance criteria or a study proving that the device meets specific performance criteria in the way a diagnostic or AI-enabled device submission would.
Instead, this submission is for a biopsy device and focuses on establishing substantial equivalence to previously cleared predicate devices, particularly for an expanded indication for use (palpable abnormalities). For a device like this, the assessment is typically based on design, operating principle, materials, and intended use being similar to existing cleared devices, rather than measuring performance against a predefined numerical acceptance criteria.
Therefore, many of the requested details about acceptance criteria, specific performance metrics, sample sizes for test sets, expert ground truth establishment, adjudication methods, or MRMC studies are not applicable or not present in this type of submission for a physical biopsy device.
Here's a breakdown of the available information based on your request, highlighting what is included and what is not:
1. Table of Acceptance Criteria and Reported Device Performance
Not applicable in the context of this 510(k) submission for a biopsy device. The basis for clearance is substantial equivalence to predicate devices, not performance against specific numerical acceptance criteria.
2. Sample Size Used for the Test Set and Data Provenance
Not applicable. There is no mention of a "test set" in the context of evaluating performance for this device, as the submission relies on substantial equivalence.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. There is no "ground truth" to be established by experts for performance evaluation in this submission. The device's function is to collect tissue, and its equivalence is deemed sufficient by comparison to predicates.
4. Adjudication Method for the Test Set
Not applicable. No test set or adjudication method is mentioned.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance
Not applicable. This is not an AI-enabled device or an image analysis device that would be subject to MRMC studies. It is a physical biopsy instrument.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Study Was Done
Not applicable. This is not an algorithm, but a physical medical device.
7. The Type of Ground Truth Used
Not applicable. As this is not a diagnostic device assessing an outcome, there isn't a "ground truth" in the typical sense of a diagnostic study (e.g., pathology, outcomes data). The basis for the device's function is its ability to retrieve tissue, and its safety and effectiveness are established via substantial equivalence.
8. The Sample Size for the Training Set
Not applicable. This device does not involve a "training set" as it is not a machine learning or AI algorithm.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As there is no training set, there is no ground truth establishment for it.
Summary of the Submission's Approach:
The 510(k) K093512 for the EnCor Breast Biopsy System establishes substantial equivalence to predicate devices (KNW K040842, K003297, K030472, K051158). The key argument for substantial equivalence is based on the following similarities:
- Same intended use (with a modification to include palpable abnormalities, which is justified by matching predicate device indications).
- Same design.
- Same patient contacting materials.
- Same operating principle.
- Same technological characteristics.
This approach allows the device to be marketed without requiring new clinical performance studies or specific numerical acceptance criteria, as its safety and effectiveness are inferred from the safety and effectiveness of the legally marketed predicate devices.
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510(K) SUMMARY 5.
. NOV 2 0 2009 November 5, 2009 Date prepared Name SenoRx, Inc. 3 Morgan Irvine, CA 92618 T. 949.362.4800; F. 949.362.0300 Contact person Eben Gordon Vice President, RA/QA SenoRx, Inc. T. 949.362.4800; F. 949.362.0300 EnCor Breast Biopsy System Device name Biopsy device Common name Classification name Gastroenterology-urology biopsy instrument Classification regulation 21 CFR 876.1075 KNW K040842 (4/30/2004); K003297 (1/18/2001); K030472 (10/9/2003); K051158 Predicate devices (5/16/2005) Modify indications for use to add for use with palpable abnormalities. Device Description already cleared for imaged abnormalities. The new indication matches predicate device. Indications for use The EnCor Breast Biopsy System is indicated to provide breast tissue samples for diagnostic sampling of breast abnormalities. It is intended to provide breast tissue for histologic examination with . partial or complete removal of the imaged abnormality. . It is intended to provide breast tissue for histologic examination with partial removal of a palpable abnormality. The extent of a histologic abnormality cannot always be readily determined from palpation or imaged appearance. Therefore, the extent of removal of the palpated or imaged evidence of an abnormality does not predict the extent of removal of a histologic abnormality, e.g., malignancy. When the sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures. In instances when a patient presents with a palpable abnormality that has been
classified as benign through clinical and/or radiological criteria (e.g. fibroadenoma, fibrocystic lesion), the EnCor Breast Biopsy System may also be used to partially remove such palpable lesions. Whenever breast tissue is removed, histological evaluation of the tissue is the standard of care. When the
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Kva 3512
sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures.
Summary of substantial equivalence
The EnCor Breast Biopsy System with its 7 and 10-Gauge biopsy probes has the following similarities with the predicate devices: same intended use; same design; same patient contacting materials; same operating principle; and same technological characteristics.
Therefore, the EnCor Breast Biopsy System with its 7 and 10-Gauge probes has the same capability of partial removal of palpable masses as does using either of the predicate devices.
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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized eagle with its wings spread, facing left. The eagle is enclosed within a circular border. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged around the upper portion of the circle. The text is in all capital letters and is evenly spaced around the curve.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-066-0609 Silver Spring, MD 20993-0002
NOV 2 0 2009
SenoRx, Inc. % Mr. Eben Gordon Vice President, Regulatory Affairs & Quality Assurance 3 Morgan Irvine, California 92618
Re: K093512
Trade/Device Name: EnCor Breast Biopsy System Regulation Number: 21 CFR 876.1075 Regulation Name: Gastroenterology-urology biopsy instrument Regulatory Class: Class II Product Code: KNW Dated: November 12, 2009 Received: November 13, 2009
Dear Mr. Gordon:
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 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
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Page 2 -- Mr. Eber Gordon
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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 advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHQffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/cdrh/mdr/ for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Mark M Millerson
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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4. INDICATIONS FOR USE
510(k) Number (if known):
Device Name:
Indications for Use:
The EnCor Breast Biopsy System is indicated to provide breast tissue samples for diagnostic sampling of breast abnormalities.
It is intended to provide breast tissue for histologic examination with partial or complete removal t of the imaged abnormality.
- It is intended to provide breast tissue for histologic examination with partial removal of a . palpable abnormality.
The extent of a histologic abnormality cannot always be readily determined from palpation or imaged appearance. Therefore, the extent of removal of the palpated or imaged evidence of an abnormality does not predict the extent of removal of a histologic abnormality, e.g., malignancy. When the sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures.
In instances when a patient presents with a palpable abnormality that has been classified as benign through clinical and/or radiological criteria (e.g. fibroadenoma, fibrocystic lesion), the EnCor Breast Biopsy System may also be used to partially remove such palpable lesions. Whenever breast tissue is removed, histological evaluation of the tissue is the standard of care. When the sampled abnormality is not histologically benign, it is essential that the tissue margins be examined for completeness of removal using standard surgical procedures.
Prescription Use (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)
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Division of Surgical, Orthopedic, and Restorative Devices
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510(k) Number K093512
I O
§ 876.1075 Gastroenterology-urology biopsy instrument.
(a)
Identification. A gastroenterology-urology biopsy instrument is a device used to remove, by cutting or aspiration, a specimen of tissue for microscopic examination. This generic type of device includes the biopsy punch, gastrointestinal mechanical biopsy instrument, suction biopsy instrument, gastro-urology biopsy needle and needle set, and nonelectric biopsy forceps. This section does not apply to biopsy instruments that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification. (1) Class II (performance standards).(2) Class I for the biopsy forceps cover and the non-electric biopsy forceps. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.