K Number
K141722
Device Name
CAREFUSION GOLD TISSUE MARKER
Manufacturer
Date Cleared
2015-01-23

(212 days)

Product Code
Regulation Number
878.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The CareFusion Gold Tissue Marker is indicated for use to radiographically mark soft tissue during a surgical procedure or for future surgical procedures.
Device Description
The Gold Tissue Marker is a sterile, single use device comprised of a gold marker and disposable delivery device. The delivery device has 1cm reference marks and echogenic marks on the distal tip to aid in ultrasound guided marker placement. The Gold Tissue Marker is placed into soft tissue during open, percutaneous, or endoscopic procedures to radiographically mark a surgical location.
More Information

Not Found

No
The device description and performance studies focus on the physical properties and placement of a gold tissue marker, with no mention of AI or ML for image analysis, diagnosis, or any other function.

No
The device is used to mark soft tissue for radiographic imaging during or after a surgical procedure, not to treat a disease or condition.

No

The device is used to mark soft tissue for radiographic visualization, not to diagnose a condition.

No

The device description explicitly states it is comprised of a gold marker and a disposable delivery device, which are physical components, not software.

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

Here's why:

  • Intended Use: The intended use is to "radiographically mark soft tissue during a surgical procedure or for future surgical procedures." This describes a device used in vivo (within the body) for marking purposes, not for testing samples in vitro (outside the body) to diagnose a condition.
  • Device Description: The description details a device for placing a marker into soft tissue. This is consistent with an in vivo application.
  • Lack of IVD Characteristics: The description does not mention any components or processes related to analyzing biological samples (blood, urine, tissue samples, etc.) or performing diagnostic tests in vitro.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This device's function is purely for marking a location within the body for imaging purposes.

N/A

Intended Use / Indications for Use

The CareFusion Gold Tissue Marker is indicated for use to radiographically mark soft tissue during a surgical procedure or for future surgical procedures.

Product codes

NEU

Device Description

The Gold Tissue Marker is a sterile, single use device comprised of a gold marker and disposable delivery device. The delivery device has 1cm reference marks and echogenic marks on the distal tip to aid in ultrasound guided marker placement. The Gold Tissue Marker is placed into soft tissue during open, percutaneous, or endoscopic procedures to radiographically mark a surgical location.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

ultrasound, radiography, Magnetic Resonance Imaging (MRI)

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

SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE:

  • Biocompatibility: AAMI/ANSI/ISO 10993-1:2009 Biological evaluation of Medical Devices Part 1: Evaluation and Testing; AAMI/ANSI/ISO 10993-6: 2007 (R) 2010 Biological Evaluation of Medical Devices - Part 6 Tests for Local Effects After Implantation; AAMI/ANSI/ISO 10993-11: 2006 Biological Evaluation of Medical Devices - Part 11 Tests for Systemic Toxicity; AAMI/ANSI/ISO 10993-18: 2006 Biological Evaluation of Medical Devices - Part 18 Chemical Characterization of Materials
  • Residuals: AAMI/ANSI/ISO 10993-7:2008 Biological evaluation of Medical Devices Part 7: Ethylene Oxide Sterilization Residuals
  • Performance: ISO 14630: 2012: Non-active Surgical Implants - General Requirements; ASTM F72: 2006 Section 4: Standard Specification for Gold Wire for Semiconductor Lead Bonding; ASTM F2052: 2006: Standard Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the MR Environment; ASTM F2119: 2007: Standard Test Method for the Evaluation of MR Image Artifacts from Passive Implants; ASTM F2182: 2011A: Standard Test Method for the Measurement of Radio frequency Induced Heating on or Near Passive Implants During MRI; ASTM F2213: 2006, RA 2011: Standard Test Method for the Measurement of Magnetically Induced Torque on Medical Devices in the MR Environment; BS EN ISO 9626:1995: Stainless Steel Needle Tubing for the Manufacture of Medical Devices; ISO 11737-1,2:2006 Sterilization of Medical Devices - Microbiological Methods Part 1 & 2; ISO 11135:2007 Medical Device, Validation and Routine Control of Ethylene Oxide Sterilization; AAMI TIR28:2009 Product Adoption and Process Equivalency for Ethylene Oxide Sterilization; Bench Top Testing – Marker securement, force to deploy, dimensional verification, and strength of connections; Simulated Use - Implantation, visualization under ultrasound, MRI and radiograph, marker integrity after repeated compression
    SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE AND/OR OF CLINICAL INFORMATION:
    N/A - No clinical tests were conducted for this submission.
    CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA:
    The results of the non-clinical tests show that the CareFusion Gold Tissue Marker meets or exceed all performance requirements, and is substantially equivalent to the predicate devices.

Key Metrics

Not Found

Predicate Device(s)

K070436

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

Image /page/0/Picture/1 description: The image contains the logo for the Department of Health and Human Services (HHS) in the United States. The logo features the department's name in a circular arrangement around a symbol. The symbol is a stylized representation of a human figure, with three profiles merging to form a single, unified image. The profiles are facing to the right and are meant to represent the department's commitment to health and well-being.

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

January 23, 2015

CareFusion Ms. Joy Greidanus Manager, Regulatory Affairs 75 North Fairway Drive Vernon Hills, Illinois 60061

Re: K141722

Trade/Device Name: CareFusion Gold Tissue Marker Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: Class II Product Code: NEU Dated: December 11, 2014 Received: December 15, 2014

Dear Ms. Greidanus:

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 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

1

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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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 Industry and Consumer Education 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.

for

Sincerely yours,

David Krause -S

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K141722

Device Name CareFusion Gold Tissue Marker

Indications for Use (Describe)

The CareFusion Gold Tissue Marker is indicated for use to radiographically mark soft tissue during a surgical procedure or for future surgical procedures.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

510(k) SUMMARY K141722

SUBMITTER INFORMATION
NameCareFusion
Address75 North Fairway Drive, Vernon Hills, IL 60061 USA
Phone number(847) 362-8103
Fax number(312) 949-0583
Establishment Registration
Number1423507
Name of contact personJoy Greidanus
Date preparedJanuary 14, 2015
DESCRIPTION OF DEVICE
Trade or proprietary nameCareFusion Gold Tissue Marker
Common or usual nameTissue Marker
Classification nameImplantable Clip
Classification panelGeneral & Plastic Surgery
RegulationClass II per 21CFR §878.4300, Procode NEU
Product Code(s)Multiple
Legally marketed device(s) to
which equivalence is claimedK070436 Carbon Medical Technologies
Reason for 510(k) submissionNew product.
Device descriptionThe Gold Tissue Marker is a sterile, single use device comprised of a gold
marker and disposable delivery device. The delivery device has 1cm
reference marks and echogenic marks on the distal tip to aid in ultrasound
guided marker placement. The Gold Tissue Marker is placed into soft
tissue during open, percutaneous, or endoscopic procedures to
radiographically mark a surgical location.
Intended use of the deviceThe Gold Tissue Marker is indicated for use to radiographically mark soft
tissue during a surgical procedure or for future surgical procedures.
SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE COMPARED
TO THE PREDICATE DEVICE
CharacteristicNew DevicePredicates
Delivery deviceManual mechanism (plunger
action) with stylet and
cannulaSame as predicate: K070436 Carbon
Medical Technologies
Tissue markerImplanted, goldSame as predicate: K070436 Carbon
Medical Technologies
VisualizationVisible on standard
radiographs, Magnetic
Resonance Imaging (MRI)
and ultrasoundSame as predicate: K070436 Carbon
Medical Technologies

A summary of 510(k) safety and effectiveness information in accordance with 21 CFR 807.92.

4

CONCLUSION OF DEVICE COMPARISON
The technological characteristics of the proposed devices are substantially equivalent to the predicate.
PERFORMANCE DATA
SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF
SUBSTANTIAL EQUIVALENCE
CharacteristicStandard/Test/FDA Guidance
BiocompatibilityAAMI/ANSI/ISO 10993-1:2009 Biological evaluation of Medical Devices Part 1:
Evaluation and Testing
BiocompatibilityAAMI/ANSI/ISO 10993-6: 2007 (R) 2010 Biological Evaluation of Medical Devices -
Part 6 Tests for Local Effects After Implantation
ResidualsAAMI/ANSI/ISO 10993-7:2008 Biological evaluation of Medical Devices Part 7:
Ethylene Oxide Sterilization Residuals
BiocompatibilityAAMI/ANSI/ISO 10993-11: 2006 Biological Evaluation of Medical Devices - Part 11
Tests for Systemic Toxicity
BiocompatibilityAAMI/ANSI/ISO 10993-18: 2006 Biological Evaluation of Medical Devices - Part 18
Chemical Characterization of Materials
PerformanceISO 14630: 2012: Non-active Surgical Implants - General Requirements
PerformanceASTM F72: 2006 Section 4: Standard Specification for Gold Wire for Semiconductor
Lead Bonding
PerformanceASTM F2052: 2006: Standard Test Method for Measurement of Magnetically Induced
Displacement Force on Medical Devices in the MR Environment
PerformanceASTM F2119: 2007: Standard Test Method for the Evaluation of MR Image Artifacts
from Passive Implants
PerformanceASTM F2182: 2011A: Standard Test Method for the Measurement of Radio frequency
Induced Heating on or Near Passive Implants During MRI
PerformanceASTM F2213: 2006, RA 2011: Standard Test Method for the Measurement of
Magnetically Induced Torque on Medical Devices in the MR Environment
PerformanceBS EN ISO 9626:1995: Stainless Steel Needle Tubing for the Manufacture of Medical
Devices.
PerformanceISO 11737-1,2:2006 Sterilization of Medical Devices - Microbiological Methods Part 1
& 2
PerformanceISO 11135:2007 Medical Device, Validation and Routine Control of Ethylene Oxide
Sterilization
PerformanceAAMI TIR28:2009 Product Adoption and Process Equivalency for Ethylene Oxide
Sterilization
PerformanceBench Top Testing – Marker securement, force to deploy, dimensional verification, and
strength of connections
PerformanceSimulated Use - Implantation, visualization under ultrasound, MRI and radiograph,
marker integrity after repeated compression
SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL
EQUIVALENCE AND/OR OF CLINICAL INFORMATION
N/A - No clinical tests were conducted for this submission
CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA

The results of the non-clinical tests show that the CareFusion Gold Tissue Marker meets or exceed all performance requirements, and is substantially equivalent to the predicate devices.