K Number
K102608
Device Name
SECURMARK BIOPSY SITE MARKING SYSTEM
Date Cleared
2010-10-08

(28 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. The SecurMark Biopsy Site Marking System is intended for use with the manual method of deployment. It can be visualized under various imaging modalities such as ultrasound, x-ray, magnetic resonance, direct visualization, and others. This system is intended for single patient use only.
Device Description
The SecurMark Biopsy Site Marker is a sterile, single patient use device comprised of a single, biocompatible titanium or stainless steel marker surrounded by a bioabsorbable suture-like material and deployment device. The deployment device is a hand-held device that delivers the marker from the distal tip. The deployment device consists of a flexible cannula, handle, flexible push rod, and plunger. The marker is located at the deployment device.
More Information

Not Found

No
The summary describes a physical device for marking tissue sites and does not mention any software, algorithms, or data processing that would indicate the use of AI or ML.

No.
A therapeutic device is one that treats or prevents a disease or condition. This device is used for marking sites in soft tissue for radiographic purposes, which is a diagnostic or procedural aid, not a treatment.

No

This device is described as a "Tissue Site Marking System" used for "permanent radiographic marking of sites in soft tissue." It is a marker, not a device that analyzes or interprets medical data to diagnose a condition. Its function is to mark a location, not to provide diagnostic information about that location.

No

The device description explicitly states it is comprised of physical components (marker, suture-like material, deployment device) and is a sterile, single-patient use device, indicating it is a hardware medical device.

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

Here's why:

  • IVD definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device function: The described device is a physical marker implanted into soft tissue for radiographic visualization. It is a medical device used in vivo (within the body) for marking purposes, not for analyzing samples in vitro (outside the body).
  • Intended Use: The intended use clearly states "permanent radiographic marking of sites in soft tissue," which is an in vivo procedure.
  • Device Description: The description details a physical marker and a deployment device, not a system for analyzing biological samples.

Therefore, this device falls under the category of a medical device, specifically an implantable marker, and not an in vitro diagnostic.

N/A

Intended Use / Indications for Use

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

Product codes (comma separated list FDA assigned to the subject device)

NEU

Device Description

The SecurMark Biopsy Site Marker is a sterile, single patient use device comprised of a single, biocompatible titanium or stainless steel marker surrounded by a bioabsorbable suture-like material and deployment device.

The deployment device is a hand-held device that delivers the marker from the distal tip. The deployment device consists of a flexible cannula, handle, flexible push rod, and plunger. The marker is located at the deployment device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

ultrasound, x-ray, magnetic resonance, direct visualization, and others

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-Clinical Evaluation

The devices that are the subject of this submission have been evaluated through a number of test, or prior test results for predicate devices apply to the devices that are subject of this submission. Testing, evaluations, and/or analyses have been performed for: simulation, shelf life, tensile testing, functionality at specified temperatures, MRI compatibility and artifacts, X-ray distinctive visualization, calcification distinguishability, sterilization, biocompatibility, tolerance analyses, and viscosity and moisture.

The devices met or exceeded the acceptance criteria for all evaluations.

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.

K072913, K062528

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 for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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

K102608

SECTION 3 - 510(k) SUMMARY

DATE PREPARED: DATE REVISED:

ﮨﮯ
ﻣﯿ

August 27, 2010 (original submission) October 8, 2010

OWNER/OPERATOR:

Firm:Hologic, Inc.Contact Name: Alyssa M. Lobo
Address:6100 Technology Center Drive
Indianapolis, IN 46278Title: Senior Quality and Regulatory Consultant
(a full-time employee of Hologic, Inc.)
Phone Number:317-344-7500Phone Number: 317-344-7532
Fax Number:317-344-7697E-mail: alyssa.lobo@hologic.com
Registration Number:3003862400

DEVICE NAME:

Classification Name:Marker, Implantable Radiographic
Common/Usual Name:Tissue Site Marking System
Proprietary Name:SecurMark Biopsy Site Marking System
Device Class:Class II
Description:Implantable Clip
Number:NEU
21 CFR Ref:878.4300
Performance Standard:None established

PREDICATE DEVICES:

510(k) NumberDevice NameDevice ManufacturerLocation
K072913SecurMark Biopsy Site
Identification SystemHologic, Inc.
(formerly Suros Surgical Systems, Inc.)Indianapolis, IN
K062528Tissue Site Marking
SystemHologic, Inc.
(formerly Suros Surgical Systems, Inc.)Indianapolis, IN

Description of the Device

The SecurMark Biopsy Site Marker is a sterile, single patient use device comprised of a single, biocompatible titanium or stainless steel marker surrounded by a bioabsorbable suture-like material and deployment device.

The deployment device is a hand-held device that delivers the marker from the distal tip. The deployment device consists of a flexible cannula, handle, flexible push rod, and plunger. The marker is located at the deployment device.

Indications for Use and Intended Use

Indications for Use

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

Intended Use

The SecurMark Biopsy Site Marking System is intended for use with the manual method of deployment. It can be visualized under various imaging modalities such as ultrasound, x-ray, magnetic resonance, direct visualization, and others. This system is intended for single patient use only.

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Comparison of 510(k) Cleared Tissue Site Marking Systems

The SecurMark Biopsy Site Marker that is the subject of this submission is comprised of two 510(k) cleared devices. The first is an implantable component, covered by K062528, held by Hologic, Inc. which is composed of a bioabsorbable component and a permanent marking component (316 stainless steel or titanium). The second is a deployment device, covered by K072913, held by Hologic, Inc. The subject of this 510(k) is similar to the predicate devices in the following areas: Indications for Use, Intended Use, Scientific Technology, biocompatibility, sterilization (dose, method, and SAL), marker materials, deployment device materials, packaging materials, deployment device manufacturing site, deployment device manufacturing methods, deployment device dimensions, marker dimensions, shelf life, and deployment method. The product is also supplied sterile for single patient use, like the predicate devices.

The subject of this 510(k) is different from the device cleared in K072913 in that the permanent marker material in that 510(k) was listed only as titanium. The subject of this 510(k) is different from the device cleared in K062528 in that the deployment device is constructed from different materials. The shapes of the permanent marking components in this submission are different from the shapes of the marking components that were cleared in both K072913 and K062528. All other aspects of the subject of this 510(k) submission are the legally marketed devices.

Non-Clinical Evaluation

The devices that are the subject of this submission have been evaluated through a number of test, or prior test results for predicate devices apply to the devices that are subject of this submission. Testing, evaluations, and/or analyses have been performed for: simulation, shelf life, tensile testing, functionality at specified temperatures, MRI compatibility and artifacts, X-ray distinctive visualization, calcification distinguishability, sterilization, biocompatibility, tolerance analyses, and viscosity and moisture.

The devices met or exceeded the acceptance criteria for all evaluations.

Conclusion

Based on the information presented in this Special 510(k) submission, the SecurMark Biopsy Site Marking System is substantially equivalent to the presently marketed Hologic, Inc. Tissue Site Marking System (K062528) and the SecurMark Biopsy Site Identification System (K072913).

No new safety or efficacy questions are raised with the SecurMark Biopsy Site Marking System that is the subject of this submission.

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Image /page/2/Picture/0 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the circumference. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three stylized lines.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Hologic, Inc. % Ms. Alyssa M. Lobo Senior Quality and Regulatory Consultant 6100 Technology Center Drive Indianapolis, Indiana 46278

OCT O & 2010

Re: K102608

Trade/Device Name: SecurMark Biopsy Site Marking System Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: Class II Product Code: NEU Dated: August 27, 2010 Received: September 13, 2010

Dear Ms. Lobo:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.

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

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Page 2 - Ms. Alyssa M. Lobo

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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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 advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH0ffices/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/MedicalDevices/Safety/ReportaProblem/default.htm 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/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Mark N. Melkerson

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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Indications for Use

510(k) Number (if known): K102608

Device Name: SecurMark Biopsy Site Marking System

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

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 Device Evaluation (ODE)

Daniel Kroeber for MXM
Division Sign Off

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K102608

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