K Number
K142668
Device Name
Lesion-Loc Iodine I-125 Seed/Needle
Date Cleared
2014-11-21

(63 days)

Product Code
Regulation Number
892.5730
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Lesion-Loc I-125 Seed/Needle is indication of lesions (as shown by mamnogram or ultrasound) in the breast or other tissue under the direct supervision of a qualified physician. The device is "single-use sterile device". Lesion-Loc I-125 Seed/needle is not intended for permanant implantation and should be removed in a few days after implantation. It us to be used in conjunction with the Gammaprobe® (IntraMedical Imaging) for localization of lesions (as shown by a mammogram or ultrasound images) in the breast and other tissues. The Lesion-Loc I-125 Seed/Needle is intended for clinical use in the marking of lesions with the seed in close proximity to or within the lesion site. The lesion (as seen in a mammogram or ultrasound image) is then located using an appropriate hand held gamma radiation detector.
Device Description
Lesion-Loc I-125 Seed/Needle contains a source 4.5 mm long and 0.8 mm in diameter. The source consists of a welded titanium capsule with a 0.05 mm thick wall and a silver rod, which is about 4 mm length with the active material as silver iodide on the surface, welded inside the titanium capsule. The seed is contained in a needle. The needles used are standard 18 gauges available commercially in lengths up to 15 cm. The I-125 seed is loaded inside the needle. The radioactive seeds are introduced into the lesion area as directed by a radiologist per Written Directive and prescription. The devices are packaged in a pouch with label and provided sterile.
More Information

No
The device description and intended use focus on a radioactive seed and needle for lesion localization, with no mention of AI or ML capabilities. The "Mentions AI, DNN, or ML" section explicitly states "Not Found".

No.
The device is used for marking and localizing lesions, not for treating them. It states that it's "not intended for permanent implantation" and is used in conjunction with a gamma radiation detector for localization.

No
The device is used to mark lesions for localization rather than to identify or characterize them, and its function is to facilitate the use of a gamma radiation detector, not to perform a diagnosis itself.

No

The device description clearly details a physical medical device consisting of a radioactive seed contained within a needle, intended for implantation. This is a hardware device, not software.

Based on the provided information, the Lesion-Loc I-125 Seed/Needle is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body. The Lesion-Loc I-125 Seed/Needle is a device that is implanted directly into the human body (breast or other tissue) to mark a lesion. It does not analyze or test a sample taken from the body.
  • The intended use is for localization within the body. The device is used in conjunction with a gamma radiation detector to physically locate a lesion within the patient's tissue. This is an in-vivo procedure, not an in-vitro (outside the body) diagnostic test.
  • The device description details an implanted radioactive source. The core of the device is a radioactive seed intended for temporary placement within the body.

Therefore, the Lesion-Loc I-125 Seed/Needle falls under the category of an implantable medical device used for localization, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Lesion-Loc I-125 Seed/Needle is indication of lesions (as shown by mamnogram or ultrasound) in the breast or other tissue under the direct supervision of a qualified physician. The device is "single-use sterile device". Lesion-Loc I-125 Seed/needle is not intended for permanant implantation and should be removed in a few days after implantation. It us to be used in conjunction with the Gammaprobe® (IntraMedical Imaging) for localization of lesions (as shown by a mammogram or ultrasound images) in the breast and other tissues.

The Lesion-Loc I-125 Seed/Needle is intended for clinical use in the marking of lesions with the seed in close proximity to or within the lesion site. The lesion (as seen in a mammogram or ultrasound image) is then located using an appropriate hand held gamma radiation detector.

Product codes

KXK

Device Description

Lesion-Loc I-125 Seed/Needle contains a source 4.5 mm long and 0.8 mm in diameter. The source consists of a welded titanium capsule with a 0.05 mm thick wall and a silver rod, which is about 4 mm length with the active material as silver iodide on the surface, welded inside the titanium capsule. The seed is contained in a needle. The needles used are standard 18 gauges available commercially in lengths up to 15 cm. The I-125 seed is loaded inside the needle. The radioactive seeds are introduced into the lesion area as directed by a radiologist per Written Directive and prescription. The devices are packaged in a pouch with label and provided sterile.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

mammogram or ultrasound

Anatomical Site

breast or other tissue

Indicated Patient Age Range

Not Found

Intended User / Care Setting

qualified physician, radiologist, licensed hospital or other medical institution

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

The Lesion-Loc I-125 Seed/Needle is based on Theragenics Corporation AgX100 seed (having a 510k number K103319) design and commercially available needle implant technology. Theragenics Corporation (Buford, GA, USA) contract manufactures the seed/needle device and provides the sterilized product to IntraMedical Imaging only after meeting all the performance qualification. A number of performance tests are done by Theragenics on the seed as per ISO 2919.

Key Metrics

Not Found

Predicate Device(s)

K122704

Reference Device(s)

K103319

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.5730 Radionuclide brachytherapy source.

(a)
Identification. A radionuclide brachytherapy source is a device that consists of a radionuclide which may be enclosed in a sealed container made of gold, titanium, stainless steel, or platinum and intended for medical purposes to be placed onto a body surface or into a body cavity or tissue as a source of nuclear radiation for therapy.(b)
Classification. Class II (special controls). A prostate seeding kit intended for use with a radionuclide brachytherapy source only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines connecting them.

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

November 21, 2014

IntraMedical Imaging, LLC % Farhad Daghighian, Ph.D. President 12569 Crenshaw Blvd. HAWTHORNE CA 90250

Re: K142668

Trade/Device Name: Lesion-Loc I-125 Seed/Needle Regulation Number: 21 CFR 892.5730 Regulation Name: Radionuclide brachytherapy source Regulatory Class: II Product Code: KXK Dated: September 30, 2014 Received: October 1, 2014

Dear Dr. Daghighian:

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 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.

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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" (21 CFR 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.

Sincerely yours.

Michael D. O'Hara
for

Janine M. Morris Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: December 31, 2013 See PRA Statement on last page.

510(k) Number (if known) K142668

Device Name Lesion-Loc I 125 Seed/Needle

Indications for Use (Describe)

Lesion-Loc I-125 Seed/Needle is indication of lesions (as shown by mamnogram or ultrasound) in the breast or other tissue under the direct supervision of a qualified physician. The device is "single-use sterile device". Lesion-Loc I-125 Seed/needle is not intended for permanant implantation and should be removed in a few days after implantation. It us to be used in conjunction with the Gammaprobe® (IntraMedical Imaging) for localization of lesions (as shown by a mammogram or ultrasound images) in the breast and other tissues.

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

x Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 807 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

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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."

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Appendix A: 510(k) Summary of Safety and Effectiveness

| Statement | Information supporting claims of substantial equivalence, as defined under
the Federal Food, Drug and Cosmetic Act, respecting safety and
effectiveness is summarized below. |
|-------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | For the convenience of the Reviewer, this summary is formatted in
accordance with the Agency's final rule “…510(k) Summaries and 510(k)
Statements…” (21 CFR §807) and can be used to provide a substantial
equivalence summary to anyone requesting it from the Agency. |
| Device Name: Lesion-Loc I-125 Seed/Needle | |
| Device Model
Number: | LL 125-XX (XX indicates length of needle – 05, 07, 10 &15 cm) |
| Device
Classification
Name: | Source, Brachytherapy, Radionuclide (KXK) 21 CFR 892.5730 |
| Device
Classification: | Class II (Radiology) |
| Predicate
Device: | Best® Localization Needle with I-125 Source (K122704) |
| | Manufacturer: IntraMedical Imaging
12569 Crenshaw Blvd.
Hawthorne, CA 90250 |
| Establishment
Registration
Number: | 2031874 |
| Official
Contact: | Farhad Daghighian
President and Chief Scientist Farhad Daghighian, Ph.D.
Tel: (424) 456-7316, Mobile: (310) 428-4101
Email: fd@intra-medical.com |
| Intended Use: | The Lesion-Loc I-125 Seed/Needle is intended for clinical use in the
marking of lesions with the seed in close proximity to or within the lesion
site. The lesion (as seen in a mammogram or ultrasound image) is then
located using an appropriate hand held gamma radiation detector. |

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  • Lesion-Loc I-125 Seed/Needle contains a source 4.5 mm long and 0.8 mm in Device Description: diameter. The source consists of a welded titanium capsule with a 0.05 mm thick wall and a silver rod, which is about 4 mm length with the active material as silver iodide on the surface, welded inside the titanium capsule. The seed is contained in a needle. The needles used are standard 18 gauges available commercially in lengths up to 15 cm. The I-125 seed is loaded inside the needle. The radioactive seeds are introduced into the lesion area as directed by a radiologist per Written Directive and prescription. The devices are packaged in a pouch with label and provided sterile.
  • Technological The Lesion-Loc I-125 Seed/Needle uses the Theragenics Corporation AgX100 characteristics (having a 510k number K103319) seed that typically has less radioactive strength than those used for brachytherapy. I-125 has a half-life of about 60 days and decays by electron capture with the emission of characteristic photons and electrons. The titanium walls of the seed absorb the electrons but the photons continue through the walls. An appropriate hand held gamma radiation detector probe is used to locate the seed and therefore also the lesion (as seen in a mammogram or ultrasound image).
  • Performance The Lesion-Loc I-125 Seed/Needle is based on Theragenics Corporation AgX100 seed (having a 510k number K103319) design and commercially data available needle implant technology. Theragenics Corporation (Buford, GA, USA) contract manufactures the seed/needle device and provides the sterilized product to IntraMedical Imaging only after meeting all the performance qualification. A number of performance tests are done by Theragenics on the seed as per ISO 2919. IntraMedical Imaging distributes the Seed/Needle device for localization only as prescribed by a physician at a licensed hospital or other medical institution.
  • Conclusion The technological characteristics and intended use of the Lesion-Loc I-125 Seed/Needle is substantially equivalent as the predicate device: Best® Localization Needle with I-125 Source.

Please note that the predicate Best Medical is identical in shape and size and the indication for use is also localization. Further conclusion is that also the OEM Theragenics Corporation Model AgX100 has been certified as safe, biocompatible and has been in clinical use for radiation therapy use without complaints.