K Number
K153709
Device Name
Mammotome elite Biopsy System-13G Probe, Mammotome elite Biopsy System-10G Probe, Mammotome elite Biopsy System-Holster, Mammotome elite Biopsy System-13G Introducer Stylet, Mammotome elite Biopsy System-10G Introducer Stylet
Date Cleared
2016-08-08

(229 days)

Product Code
Regulation Number
876.1075
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Mammotome elite® Biopsy System is indicated to obtain tissue samples from the breast or axillary lymph nodes for diagnostic analysis of breast abnormalities. • The Mammotome elite® Biopsy System is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality. · The Mammotome elite® Biopsy System 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 the 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 Mammotome elite® 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.
Device Description
The Mammotome elite® Biopsy System consists of a reusable Holster (MEH1) and a single-patient use, sterile Probe (MEP10 and MEP13) that is used with ultrasound imaging guidance to excise and collect diagnostic samples with a single insertion of the Probe. Introducer Stylets (MEI10 and MEI13) are also available as optional accessories that can be used with the Mammotome elite® Biopsy System. The components of the System are designed to operate safely when used together for diagnostic sampling of tissue during a biopsy procedure. The Holster is a self-contained, handheld, reusable electro-mechanical vacuum-assisted biopsy device that consists of a rechargeable lithium-polymer battery and includes a charging base with AC power adapter. The Probe consists of an outer trocar shaft, a telescoping inner hollow coaxial cutter and an integrated coaxial cannula. The Probe incorporates a distal needle aperture and a proximal specimen collection cup with a tissue sample basket and specimen collection cap. The Holster contains one alignment tab that inserts into the holster notch located on the body of the Probe. The Probe body also contains two locking tabs to secure the Probe into the Holster. The Holster creates vacuum inside the device to assist in pulling tissue into the aperture while the sharpened inner cutter rotates at high speeds and extends across the aperture to acquire targeted tissue. The tissue sample is transported by vacuum to the specimen collection cup at the proximal end of the Probe. The integrated coaxial cannula may be detached either after the biopsy and remain in the breast to retain a track to the biopsy site when placing a biopsy site identifier or prior to the procedure when used in conjunction with the Introducer Stylet. The Introducer Stylet/integrated coaxial cannula combination is an option that is available for those physicians who are trained in percutaneous needle techniques for tissue collection.
More Information

Not Found

No
The description focuses on the mechanical and vacuum-assisted aspects of the biopsy system and explicitly states "Not Found" for mentions of AI, DNN, or ML.

No.
This device is designed to obtain tissue samples for diagnostic analysis, not to treat a disease or condition.

No

The device is a biopsy system used to obtain tissue samples for diagnostic analysis. The diagnostic analysis itself is performed on the tissue samples, not by the device directly.

No

The device description clearly outlines physical hardware components including a reusable Holster (electro-mechanical vacuum-assisted device with battery and charging base) and a single-patient use, sterile Probe with mechanical parts (trocar shaft, cutter, cannula, etc.). While software verification and validation testing is mentioned, the device is fundamentally a hardware system with integrated software, not a software-only device.

Based on the provided information, the Mammotome elite® Biopsy System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body in vitro (outside the body) to provide information for diagnostic purposes. This typically involves tests performed on blood, urine, tissue samples, etc., in a laboratory setting.
  • The Mammotome elite® Biopsy System is a device used to obtain tissue samples from the breast or axillary lymph nodes. It is a tool for performing a biopsy procedure, which is an in vivo (within the body) process.
  • The intended use clearly states that the system is indicated to "obtain tissue samples... for diagnostic analysis". The diagnostic analysis itself is performed after the tissue is obtained, likely using IVD methods in a laboratory. The Mammotome elite® is the instrument for acquiring the sample, not for performing the diagnostic test on the sample.

In summary, the Mammotome elite® Biopsy System is a medical device used for tissue acquisition, which is a step that precedes in vitro diagnostic testing. It is not an IVD device itself.

N/A

Intended Use / Indications for Use

The Mammotome elite® Biopsy System is indicated to obtain tissue samples from the breast or axillary lymph nodes for diagnostic analysis of breast abnormalities.
• The Mammotome elite® Biopsy System is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality.
• The Mammotome elite® Biopsy System is intended to provide breast tissue for histologic examination with partial removal of a palpable abnormality.

Product codes

KNW

Device Description

The Mammotome elite® Biopsy System consists of a reusable Holster (MEH1) and a single-patient use, sterile Probe (MEP10 and MEP13) that is used with ultrasound imaging guidance to excise and collect diagnostic samples with a single insertion of the Probe. Introducer Stylets (MEI10 and MEI13) are also available as optional accessories that can be used with the Mammotome elite® Biopsy System. The components of the System are designed to operate safely when used together for diagnostic sampling of tissue during a biopsy procedure.
The Holster is a self-contained, handheld, reusable electro-mechanical vacuum-assisted biopsy device that consists of a rechargeable lithium-polymer battery and includes a charging base with AC power adapter. The Probe consists of an outer trocar shaft, a telescoping inner hollow coaxial cutter and an integrated coaxial cannula. The Probe incorporates a distal needle aperture and a proximal specimen collection cup with a tissue sample basket and specimen collection cap. The Holster contains one alignment tab that inserts into the holster notch located on the body of the Probe. The Probe body also contains two locking tabs to secure the Probe into the Holster. The Holster creates vacuum inside the device to assist in pulling tissue into the aperture while the sharpened inner cutter rotates at high speeds and extends across the aperture to acquire targeted tissue. The tissue sample is transported by vacuum to the specimen collection cup at the proximal end of the Probe. The integrated coaxial cannula may be detached either after the biopsy and remain in the breast to retain a track to the biopsy site when placing a biopsy site identifier or prior to the procedure when used in conjunction with the Introducer Stylet. The Introducer Stylet/integrated coaxial cannula combination is an option that is available for those physicians who are trained in percutaneous needle techniques for tissue collection.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

ultrasound imaging guidance

Anatomical Site

breast or axillary lymph nodes

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

Animal testing was conducted to validate the performance of the Mammotome elite® Biopsy System for acquisition of tissue, specifically for tissue sample weight, tissue transport reliability, and sample quality. An in vivo porcine animal model was used, which has historically been used to evaluate the ability for Mammotome biopsy devices for this purpose, and was used for both the predicate and proposed Mammotome elite® Biopsy Systems. All animal studies were conducted in compliance with 21 CFR Part 58, Good Laboratory Practices.
In these studies, acquisition of tissue samples from a single insertion site was evaluated against the following criteria and requirements:

  • Tissue sample weight: The Mammotome elite® Biopsy System should acquire tissue sample weights that are comparable to the predicate device.
  • Tissue transport efficiency: The Mammotome elite® Biopsy System should deliver similar performance as the predicate system in terms of the percent of samples acquired to the number of samples attempted.
  • Sample quality: The Mammotome elite® Biopsy System should not alter the characteristics of the acquired tissue in such a way as to affect the ability to achieve optimal histological assessment and is comparable to the predicate device.
    Additionally, bench testing was done to evaluate force to penetrate for the Mammotome elite® Biopsy System compared to the predicate System.
    The animal and bench testing results confirm that the Mammotome elite® Biopsy System performed comparable to that of the identified predicate device.

Key Metrics

Not Found

Predicate Device(s)

K112411

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

Image /page/0/Picture/1 description: The image is a black and white seal for the Department of Health & Human Services - USA. The seal is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is a stylized image of three faces in profile, one behind the other.

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

August 8, 2016

Devicor Medical Products, Inc. Ms. Shawna Rose Director, Regulatory Affairs 300 E-Business Way, Fifth Floor Cincinnati, OH 45241

Re: K153709

Trade/Device Name: Mammotome elite Biopsy System Regulation Number: 21 CFR 876.1075 Regulation Name: Gastroenterology-urology biopsy instrument Regulatory Class: II Product Code: KNW Dated: July 8, 2016 Received: July 11, 2016

Dear Ms. Rose:

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

1

CFR Part 807); labeling (21 CFR Part 801 and 809); 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 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/ResourcesforYou/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.

Sincerely vours.

Christopher J. Ronk -S

  • For 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) K153709

Device Name Mammotome elite® Biopsy System

Indications for Use (Describe)

The Mammotome elite® Biopsy System is indicated to obtain tissue samples from the breast or axillary lymph nodes for diagnostic analysis of breast abnormalities.

• The Mammotome elite® Biopsy System is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality.

· The Mammotome elite® Biopsy System 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 the 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 Mammotome elite® 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.

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

Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary - K153709

The following information is provided as required by 21 CFR § 807.92 for the Mammotome elite® Biopsy System 510(k) premarket notification. In response to the Safe Medical Devices Act of 1990 the following is a summary of the safety and effectiveness information upon which the substantial equivalence determination is based.

General ProvisionsSubmitter Name:Devicor® Medical Products, Inc.
Address:300 E-Business Way, Fifth Floor
45241 Cincinnati, OH
Establishment Registration Number:3008492462
Contact Person:Shawna Rose
Director, Regulatory Affairs
Telephone Number:513-864-9178
Fax Number:513-864-9011
E-mail Address:srose@mammotome.com
Date of Preparation:December 21, 2015
Subject DeviceTrade Name:Mammotome elite® Biopsy System
Classification Name:Instrument, Biopsy
Regulation:21 CFR §876.1075
Product Code:KNW
Classification:Class II
Predicate DeviceTrade Name:Mammotome® elite Biopsy System
Classification Name:Instrument, Biopsy
Premarket Notification #K112411
ManufacturerDevicor® Medical Products, Inc.
Device DescriptionThe Mammotome elite® Biopsy System consists of a reusable Holster (MEH1) and a
single-patient use, sterile Probe (MEP10 and MEP13) that is used with ultrasound
imaging guidance to excise and collect diagnostic samples with a single insertion of the
Probe. Introducer Stylets (MEI10 and MEI13) are also available as optional accessories
that can be used with the Mammotome elite® Biopsy System. The components of the
System are designed to operate safely when used together for diagnostic sampling of
tissue during a biopsy procedure.
The Holster is a self-contained, handheld, reusable electro-mechanical vacuum-assisted
biopsy device that consists of a rechargeable lithium-polymer battery and includes a
charging base with AC power adapter. The Probe consists of an outer trocar shaft, a
telescoping inner hollow coaxial cutter and an integrated coaxial cannula. The Probe
incorporates a distal needle aperture and a proximal specimen collection cup with a
body also contains two locking tabs to secure the Probe into the Holster. The Holster
creates vacuum inside the device to assist in pulling tissue into the aperture while the
sharpened inner cutter rotates at high speeds and extends across the aperture to
acquire targeted tissue. The tissue sample is transported by vacuum to the specimen
collection cup at the proximal end of the Probe. The integrated coaxial cannula may be
detached either after the biopsy and remain in the breast to retain a track to the biopsy
site when placing a biopsy site identifier or prior to the procedure when used in
conjunction with the Introducer Stylet. The Introducer Stylet/integrated coaxial
cannula combination is an option that is available for those physicians who are trained
in percutaneous needle techniques for tissue collection.
Intended UseThe Mammotome elite® Biopsy System is intended to provide breast or axillary lymph
node tissue samples for diagnostic analysis of imaged or palpated breast abnormalities.
Indications For
UseThe Mammotome elite® Biopsy System is indicated to obtain tissue samples from the
breast or axillary lymph nodes for diagnostic analysis of breast abnormalities. The Mammotome elite® Biopsy System is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality. Mammotome elite® Biopsy System 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 the 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 Mammotome elite® 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.
Performance
TestsThe following performance data were provided in support of the substantial
equivalence determination.
Biocompatibility Testing
The biocompatibility evaluation for the Mammotome elite® Biopsy System was
conducted in accordance with the FDA Blue Book Memorandum #G95-1 "Use of
International Standard ISO-10993, 'Biological Evaluation of Medical Devices Part 1:
Evaluation and Testing,'" May 1, 1995, and International Standard ISO 10993-1
"Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a

tissue sample basket and specimen collection cap. The Holster contains one alignment tab that inserts into the holster notch located on the body of the Probe. The Probe

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5

Risk Management Process," as recognized by FDA. The battery of testing included the following tests:

  • . Cytotoxicity
  • Sensitization ●
  • Irritation
  • Systemic toxicity ●

The Mammotome elite® Biopsy System is considered tissue contacting for a duration of less than 24 hours.

Electrical safety and electromagnetic compatibility (EMC)

Electrical safety and EMC testing were conducted on the Mammotome elite® Biopsy System, which consists of a reusable, rechargeable Holster, a single-patient use Probe (10G or 13G), and an optional single-patient use Introducer Stylet (MEI10 or MEI13). The system was tested in accordance to, and complies with, the applicable portions of the following electrical/electromagnetic standards:

Second Edition:

  • IEC 60601 -1:1988 + A1:1991 + A2:1995
  • · UL 60601-1:2003
  • · CAN/CSA-C22.2 No. 601.1-M90
  • EN 60601-1:1990 +A1+A2+A3
  • · IEC 60601-1-2:2004

Third Edition:

  • IEC 60601-1: 2005 + CORR. 1:2006 + CORR. 2:2007
  • AAMI ES 60601-1:2005
  • · CSA C22.2 No. 60601-1:2008
  • EN 60601-1:2006
  • · EN/IEC 60601-1-2:2007
  • IEC 60601-1-6:2010
  • · IEC 62366:2007

Software Verification and Validation Testing

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "moderate" level of concern, since prior to mitigations of the hazards, a failure of the device Software could result in Minor Injury, either to a patient or to a user of the device.

Animal Testing

Animal testing was conducted to validate the performance of the Mammotome elite® Biopsy System for acquisition of tissue, specifically for tissue sample weight, tissue transport reliability, and sample quality. An in vivo porcine animal model was used,

6

which has historically been used to evaluate the ability for Mammotome biopsy devices for this purpose, and was used for both the predicate and proposed Mammotome elite® Biopsy Systems. All animal studies were conducted in compliance with 21 CFR Part 58, Good Laboratory Practices.

In these studies, acquisition of tissue samples from a single insertion site was evaluated against the following criteria and requirements:

  • Tissue sample weight: The Mammotome elite® Biopsy System should acquire tissue sample weights that are comparable to the predicate device.
  • . Tissue transport efficiency: The Mammotome elite® Biopsy System should deliver similar performance as the predicate system in terms of the percent of samples acquired to the number of samples attempted.
  • Sample quality: The Mammotome elite® Biopsy System should not alter the characteristics of the acquired tissue in such a way as to affect the ability to achieve optimal histological assessment and is comparable to the predicate device.

Additionally, bench testing was done to evaluate force to penetrate for the Mammotome elite® Biopsy System compared to the predicate System.

The animal and bench testing results confirm that the Mammotome elite® Biopsy System performed comparable to that of the identified predicate device.

| Device
Comparison to
Predicate
Device | The Mammotome elite® Biopsy System, used with ultrasound imaging guidance, facilitates the diagnostic removal of tissue through a combination of vacuum and rotational/translational cutting functions. The Mammotome elite® Biopsy System utilizes the same primary components as identified in the predicate device to achieve its intended use: a Probe, Holster, and Charging Base with AC power adapter.

The Mammotome elite® Biopsy System is identical to the predicate device in the following ways:
• Intended Use
• Indications for Use
• Target Population
• Fundamental Scientific Technology
• Operating Principles
• Driver Mechanical Design
• Performance Characteristics
• Product Requirements
• Packaging
• Sterility
• Biocompatibility |

-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

7

The subject device and the predicate device are different in the following ways:
• Addition of a 10G Probe (MEP10)
• Addition of a 10G (MEI10) and 13G (MEI13) Introducer Stylet
• Updates to the Holster (MEH1) battery configuration for increased performance
reliability
These changes provide more product offerings for physician preference and improved
system reliability.

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Page 6 of 9

| Table 1: Mammotome elite® Biopsy System Holster and Probe Side-by-Side

Comparison to Legally Marketed Device
Device
CharacteristicsMarketed Device
Mammotome® elite
Biopsy SystemProposed Device
Mammotome elite®
Biopsy SystemChanges
510KK112411Proposed
Indications for UseBreast Biopsy & Axillary
Lymph Nodes/
complete, partial
removal of imaged
abnormality/ partial
removal of palpated
abnormalityBreast Biopsy & Axillary
Lymph Nodes/
complete, partial
removal of imaged
abnormality/ partial
removal of palpated
abnormalityNo change
Holster Assembly
Mechanical Drive
TypeOnboard electrical
motors and drive trainOnboard electrical
motors and drive trainNo change
Electrical Power
SourceTetherless,
rechargeable, lithium
battery, charging base
with AC power adapterTetherless,
rechargeable, lithium
battery, charging base
with AC power adapterNo change
VacuumSelf-contained,
reusable
electromechanically
created sourceSelf-contained,
reusable
electromechanically
created sourceNo change
Software VersionV. 2.70V.2.94.7.0Battery
charging and
communication
improvements
Firmware VersionV.2.92.3V.4.1.9Battery
charging and
communication
improvements
Probe Needle Subassembly
Needle Insertion
MethodManualManualNo change
Tip TypeBladed trocarBladed trocarNo change
Tip MaterialStainless SteelStainless SteelNo change
Needle
ConfigurationSingle LumenSingle LumenNo change
Needle MaterialStainless SteelStainless SteelNo change
Sample Aperture
ConfigurationLateral ApertureLateral ApertureNo change
Needle Rotation
MethodManualManualNo change
Device
CharacteristicsMarketed Device
Mammotome® elite
Biopsy SystemProposed Device
Mammotome elite®
Biopsy SystemChanges
510KK112411Proposed
Probe Needle Dimensions
Gauge13G13G, 10GAddition of
Probe
(MEP10/10G)
Needle Length - tip
to Needle Rotation
Knob (mm)136mm136mmNo Change
Needle Length - Tip
to Coaxial Release
(mm)122mm122mmNo Change
Aperture Length
(mm)19.1mm19.1mm (13G),
18.4mm (10G)Slight
difference due
to additional
gauge size
Tip length (mm)10.0mm10.0mm (13G),
10.4mm (10G)Slight
difference due
to additional
gauge size
Probe Housing
Specimen Retrieval
MethodAutomaticAutomaticNo change
Housing MaterialPlasticPlasticNo change
Probe Cutter Subassembly
Cutting MethodRotation and
Translation of Inner
CutterRotation and
Translation of Inner
CutterNo change
Tissue Transport
MethodVacuumVacuumNo change
Cutter MaterialStainless SteelStainless SteelNo change
Cutter Sealing
MechanismYesYesNo change
Cutter Sealing
MaterialElastomer/Thermoplast
icElastomer/Thermoplast
icNo change
Site Marker Access
Marking MethodThrough Probe Coaxial
CannulaThrough Probe Coaxial
CannulaNo change
Sterilization (both Probe and Introducer Stylet)
MethodCobalt 60 IrradiationCobalt 60 IrradiationNo change
Device
CharacteristicsMarketed Device
Mammotome® elite
Biopsy SystemProposed Device
Mammotome elite®
Biopsy SystemChanges
510KK112411Proposed
Indications for UseN/ABreast Biopsy &
Axillary Lymph
Nodes/ complete,
partial removal of
imaged abnormality/
partial removal of
palpated abnormalityNo change with
addition of
Introducer
Stylets
Introducer Needle Dimensions
GaugeN/A13G, 10GAddition of Two
Introducer
Stylets
(MEI13/13G and
MEI10/10G)
Needle Length - tip
to Needle Rotation
Knob (mm)N/A136mmNo Difference
between Probe
and Introducer
Stylet
Needle Length - Tip
to Coaxial Release
(mm)N/A122mmNo Difference
between Probe
and Introducer
Stylet
Aperture Length
(mm)N/AN/ANo aperture as
not used for
tissue
acquisition; used
to aid in tissue
penetration
Tip length (mm)N/A8.0mm (13G), 8.4mm
(10G)Difference
between Probe
Needle Tip and
Introducer
Needle Tip due
to aperture
opening in Probe
– longer tip
needed for
strength
Device
CharacteristicsMarketed Device
Mammotome® elite
Biopsy SystemProposed Device
Mammotome elite®
Biopsy SystemChanges
510KK112411Proposed
Introducer Stylet Needle Subassembly
Needle Insertion
MethodN/AManualNo change
between Probe
and Introducer
Stylet
Tip TypeN/ABladed trocarNo change
between Probe
and Introducer
Stylet
Tip MaterialN/AStainless SteelNo change
between Probe
and Introducer
Stylet
Needle
ConfigurationN/ASingle LumenNo change
between Probe
and Introducer
Stylet
Needle MaterialN/AStainless SteelNo change
between Probe
and Introducer
Stylet
Sample Aperture
ConfigurationN/ANoneNo aperture as
not used for
tissue
acquisition; used
to aid in tissue
penetration
Sterilization
MethodN/ACobalt-60 IrradiationSame as for
Probes

Summary of Substantial Equivalence

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10

Table 2: Mammotome elite® Biopsy System Introducer Side-by-Side Comparison to Legally Marketed Device

11

Side-by-side comparison of the Mammotome elite® Biopsy System to the predicate Conclusion device was performed on the technical characteristics of design, product components, materials of construction, system functionality, and clinical application through bench and animal testing (specifically, tissue sample characteristics).

Follow up communication with the FDA during review of this application confirmed that the performance testing conducted on the Mammotome elite® Biopsy System is acceptable and supports a substantial equivalency determination.