K Number
K161409
Device Name
M-Biopsy Semi-Automatic Biopsy Instrument M-Biopsy Coaxial Introducer Needle for Sem
Date Cleared
2016-08-02

(74 days)

Product Code
Regulation Number
876.1075
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
(N301) Disposable Semi-Automatic Biopsy Instrument used for obtaining percutaneous or surgical histological biopsy samples from soft tissue by cutting from lung, liver, spleen, kidney, prostate, lymph nodes, breast, thyroid, and pancreas, for microscopic examination. (N302) Coaxial Introducer Needle is used as a guiding needle for (N301)
Device Description
The M-Biopsy™ Semi-Automatic Biopsy Instrument is a disposable lightweight spring loaded biopsy instrument with a biopsy needle fitted into a plastic handle. The needle has a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound. The M-Biopsy™ Coaxial Introducer Needle has a trocar stylet and a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound. The device (M-Biopsy™ Semi-Automatic Biopsy Instrument) is sold as a single device and as a set combination (M-Biopsy™ Semi-Automatic Biopsy Instrument and M-Biopsy™ Coaxial Introducer Needle). The M-Biopsy™ Semi-Automatic Biopsy Instrument is used to obtain multiple core biopsy samples from soft tissue such as the liver, kidney, prostate, breast, lymph nodes, etc. The M-Biopsy™ Coaxial Introducer Needle is used as a guiding needle for the M-Biopsy™ Semi-Automatic Biopsy Instrument. The M-Biopsy™ device family can be used as transient use less than 60 minutes. The M-Biopsy™ device family is available from Gauge 14 to Gauge 20 in different lengths ranging from 6 cm to 30 cm. The M-Biopsy™ Semi-Automatic Biopsy Instrument consists of: Mandrill, Needle, House Lit, House base, Spring bushings, Spring, Cannula sledge, Trigger, Protecting sheath and Silicone coating. The M-Biopsy™ Coaxial Introducer Needle consists of: Mandrill, Needle, Luer, Hub, Stopper, Protecting sheath and Silicone coating. The M-Biopsy™ Semi Automatic Instrument and Coaxial Needle (set combination) consists of the above mentioned parts and a 3 Cavity clips to keep the part in place in the pouch.
More Information

Not Found

No
The device description and performance studies focus on mechanical aspects and material properties, with no mention of AI or ML for image analysis, sample analysis, or any other function.

No

The device is designed for obtaining biopsy samples for diagnostic purposes, not for treating a disease or condition.

Yes
The device is used to obtain biopsy samples for "microscopic examination," which is a diagnostic procedure used to determine the nature of a condition or disease.

No

The device description clearly outlines physical components like needles, handles, springs, and other hardware, indicating it is a physical medical device, not software-only.

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. They are used to provide information for diagnosis, monitoring, or screening.
  • Device Function: The M-Biopsy™ device is used to obtain a tissue sample (biopsy). It is a tool for collecting the specimen, not for analyzing it or performing a diagnostic test on it.
  • Intended Use: The intended use clearly states that the device is used for "obtaining percutaneous or surgical histological biopsy samples... for microscopic examination." The microscopic examination is the diagnostic step, which is performed after the sample is collected by this device.

The device is a surgical instrument used for tissue collection, which is a pre-analytical step in the diagnostic process, but it is not an IVD itself.

N/A

Intended Use / Indications for Use

(N301) Disposable Semi-Automatic Biopsy Instrument used for obtaining percutaneous or surgical histological biopsy samples from soft tissue by cutting from lung, liver, spleen, kidney, prostate, lymph nodes, breast, thyroid, and pancreas, for microscopic examination.
(N302) Coaxial Introducer Needle is used as a guiding needle for (N301)

Product codes

KNW

Device Description

The M-Biopsy™ Semi-Automatic Biopsy Instrument is a disposable lightweight spring loaded biopsy instrument with a biopsy needle fitted into a plastic handle.
The needle has a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound.
The M-Biopsy™ Coaxial Introducer Needle has a trocar stylet and a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound.
The device (M-Biopsy™ Semi-Automatic Biopsy Instrument) is sold as a single device and as a set combination (M-Biopsy™ Semi-Automatic Biopsy Instrument and M-Biopsy™ Coaxial Introducer Needle).
The M-Biopsy™ Semi-Automatic Biopsy Instrument is used to obtain multiple core biopsy samples from soft tissue such as the liver, kidney, prostate, breast, lymph nodes, etc.
The M-Biopsy™ Coaxial Introducer Needle is used as a guiding needle for the M-Biopsy™ Semi-Automatic Biopsy Instrument.
The M-Biopsy™ device family can be used as transient use less than 60 minutes.
The M-Biopsy™ device family is available from Gauge 14 to Gauge 20 in different lengths ranging from 6 cm to 30 cm.
The M-Biopsy™ Semi-Automatic Biopsy Instrument consists of: Mandrill, Needle, House Lit, House base, Spring bushings, Spring, Cannula sledge, Trigger, Protecting sheath and Silicone coating.
The M-Biopsy™ Coaxial Introducer Needle consists of: Mandrill, Needle, Luer, Hub, Stopper, Protecting sheath and Silicone coating.
The M-Biopsy™ Semi Automatic Instrument and Coaxial Needle (set combination) consists of the above mentioned parts and a 3 Cavity clips to keep the part in place in the pouch.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray, CT or ultrasound

Anatomical Site

soft tissue by cutting from lung, liver, spleen, kidney, prostate, lymph nodes, breast, thyroid, and pancreas

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

The performance test is a simulated biopsy test performed according to the IFU. The Biopsy needle is fired into two different medias as listed below. Each product has been fired 10 times each. Form and length of the biopsy sample was recorded.

Key Metrics

Not Found

Predicate Device(s)

SuperCore™ Biopsy Instrument (K974814)

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 shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, with three human profiles facing to the right.

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

August 2, 2016

Mermaid Medical A/S % Ms. Rhonda Alexander Registrar Corp. 144 Research Drive Hampton, Virginia 23666

Re: K161409

Trade/Device Name: M-Biopsy Semi-Automatic Biopsy Instrument (N301) M-Biopsy Coaxial Introducer Needle for Semi-automatic Biopsy Instrument (N302) M-Biopsy Semi-Automatic Instrument and Coaxial Introducer Needle Set (NS301) Regulation Number: 21 CFR 876.1075 Regulation Name: Gastroenterology-Urology-Biopsy Instrument Regulatory Class: Class II Product Code: KNW Dated: July 18, 2016 Received: July 20, 2016

Dear Ms. Alexander:

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

1

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 devicerelated 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" (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,

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

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known)

K161409

Device Name

(N301) M-BiopsyTM Semi-Automatic Biopsy Instrument

(N302) M-Biopsy™ Coaxial Introducer Needle for Semi-Automatic Biopsy Instrument (N301)

(NS301) M-BiopsyTM Semi Automatic Instrument and Coaxial Introducer Needle Set

Indications for Use (Describe)

(N301) Disposable Semi-Automatic Biopsy Instrument used for obtaining percutaneous or surgical histological biopsy samples from soft tissue by cutting from lung, liver, spleen, kidney, prostate, lymph nodes, breast, thyroid, and pancreas, for microscopic examination.

(N302) Coaxial Introducer Needle is used as a guiding needle for (N301)

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)

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."

FORM FDA 3881 (8/14)

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Image /page/3/Picture/1 description: The image shows the logo for Mermaid Medical. The logo features a large, red letter "M" at the top. Below the "M" are the words "MERMAID" and "MEDICAL" stacked on top of each other in a smaller, black font. A thin, red line is underneath the word "MEDICAL", and the words "CROSSING EXPERTISE" are below the line in a smaller, black font.

Date prepared: July 21, 2016

I.Submitter
Submitters Name:Mermaid Medical A/S
Address:Frydensbergvej 25, DK-3660 Stenloese, Denmark
Phone:+45 47 10 85 70
Fax:+45 47 10 85 71
E-mail:pwj@mermaidmedical.com
Contact:Pia Wissing Jensen (Vice President QA & Regulatory Affairs)
Consultant Contact:Rhonda Alexander, Senior Regulatory Specialist, Medical Device Division
Registrar Corp
144 Research Drive, Hampton, VA 23666 US
1 (757) 224-0177 [voice]
1 (757) 224-0179 [fax]
ralexander@registrarcorp.com
II.Device
Trade name:M-Biopsy™ Semi-Automatic Biopsy Instrument (N301)
M-Biopsy™ Coaxial Introducer Needle for Semi-Automatic Biopsy
Instrument (N302)
M-Biopsy™ Semi Automatic Instrument and Coaxial Introducer Needle
Set (NS301)
Regulation Number:876.1075
Classification Name:Gastroenterology-Urology Biopsy Instrument
Product Code:KNW
Classification Panel:Gastroenterology/Urology
Regulatory Class:Class II
Predicate Device:SuperCore™ Biopsy Instrument (K974814)

Device Description lll.

The M-Biopsy™ Semi-Automatic Biopsy Instrument is a disposable lightweight spring loaded biopsy instrument with a biopsy needle fitted into a plastic handle.

The needle has a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound.

4

Image /page/4/Picture/1 description: The image shows the logo for Mermaid Medical. The logo features a large, red letter "M" at the top. Below the "M" are the words "MERMAID" in a larger font and "MEDICAL" in a smaller font. Underneath the words "MERMAID MEDICAL" is a thin, horizontal line, and below that are the words "CROSSING EXPERTISE" in a smaller font.

The M-Biopsy™ Coaxial Introducer Needle has a trocar stylet and a distal echogenic marker and centimeter markings to facilitate precise depth placement and may be visualized by X-ray, CT or ultrasound.

The device (M-Biopsy™ Semi-Automatic Biopsy Instrument) is sold as a single device and as a set combination (M-Biopsy™ Semi-Automatic Biopsy Instrument and M-Biopsy™ Coaxial Introducer Needle).

The M-Biopsy™ Semi-Automatic Biopsy Instrument is used to obtain multiple core biopsy samples from soft tissue such as the liver, kidney, prostate, breast, lymph nodes, etc.

The M-Biopsy™ Coaxial Introducer Needle is used as a guiding needle for the M-Biopsy™ Semi-Automatic Biopsy Instrument.

The M-Biopsy™ device family can be used as transient use less than 60 minutes.

The M-Biopsy™ device family is available from Gauge 14 to Gauge 20 in different lengths ranging from 6 cm to 30 cm.

The M-Biopsy™ Semi-Automatic Biopsy Instrument consists of: Mandrill, Needle, House Lit, House base, Spring bushings, Spring, Cannula sledge, Trigger, Protecting sheath and Silicone coating.

The M-Biopsy™ Coaxial Introducer Needle consists of: Mandrill, Needle, Luer, Hub, Stopper, Protecting sheath and Silicone coating.

The M-Biopsy™ Semi Automatic Instrument and Coaxial Needle (set combination) consists of the above mentioned parts and a 3 Cavity clips to keep the part in place in the pouch.

IV. Indication for Use

(N301) Disposable Semi Automatic Biopsy Instrument is used for obtaining percutaneous or surgical histological biopsy samples from soft tissue by cutting from lung, liver, spleen, kidney, prostate, lymph nodes, breast, thyroid, and pancreas for microscopic examination.

(N302) Coaxial Introducer Needle is used as a guiding needle for (N301).

V. Technological and Substantial Equivalence Summary

The M-Biopsy™ Semi-Automatic Biopsy Instrument is similar in fundamental design, function, device materials, sterilization, operating principle, intended use and technology as the predicate device "SuperCore™ Biopsy Instrument".

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Image /page/5/Picture/1 description: The image shows the logo for Mermaid Medical. The logo features a large, red letter "M" at the top. Below the "M" is the text "MERMAID MEDICAL" in a smaller, sans-serif font. Underneath the text is a thin, red line, and below that is the text "CROSSING EXPERTISE" in a smaller font.

The modification from the predicate device includes:

  • Shorter mandrill length than the predicate device
  • Gauge size/length size print on the device. The predicate device does not have this.
  • Loading and shooting force test 10 mm and 20 mm better or equal than the predicate device
  • Lighter than the predicate device

The above mentioned differences do not raise new questions of safety and effectiveness.

VI. Performance Data

The following bench testing was conducted for design elements and performance characteristics deemed appropriate to demonstrate equivalence to the predicate device. The device conformed to and/or passed the testing standard.

The M-Biopsy™ device family including packaging and sterilization met the predetermined acceptance criteria ensuring substantial equivalence to the predicate device. No new safety or effective or performance issues were raised during the testing.

Design:Geometric:
Handle designNeedle gauge
Loading handle and triggerNeedle size
Echogenic band on the distal end of the cannulaStilet size
Cannula and Mandrill grindNeedle advancement / penetration depth
Mandrill protrudes from the cannulaSample notch size
ID of the product Color codeNumber of samples
Gauge size/length size print on the deviceSpring operated
Visibility during incursion (Fluoroscopic, Ultrasound)Single puncture and sample
Visualization of the insertion debt of the cannula. cmSafety features
markers on the cannula shaft.
Biopsy harvest methodMaterials in contact with patient
Biopsy sample sizeTarget organs (anatomical)
Optional stroke length which the operator choosesTarget population justification
prior to use (10mm and 20mm)
Spring operatedVisualization techniques
Method placement

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Image /page/6/Picture/1 description: The image shows the logo for Mermaid Medical. The logo features a large, red letter "M" at the top. Below the "M" are the words "MERMAID MEDICAL" in a smaller, black font. Underneath the words "MERMAID MEDICAL" is a thin, red line, and below that are the words "CROSSING EXPERTISE" in a smaller, black font.

Mechanical test and Product comparisons test:Performance tests:
Tensile pull testingThe performance test is a simulated biopsy test performed according to the IFU. The Biopsy needle is fired into two different medias as listed below. Each product has been fired 10 times each. Form and length of the biopsy sample was recorded.
Loading and shooting force test 10mm
Loading and shooting force test 20mm
Trigger firing force test
Weight comparison test
Packaging test:Sterilization:
Sterile barrier IntegrityEO sterilization
Transportation testBiocompatibility
World Wide Condition testAccording to ISO 10993. See below.
Shelf life

Biocompatibility VII.

The biocompatibility evaluation for the Semi-Automatic Biopsy Instrument and Coaxial Needle was conducted with the FDA and European standard ISO 10993-1"Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk Management Process" as recognized by the FDA. The subject device conformed to or passed the following standards:

  • MEM elution cytotoxicity test according to ISO 10993-5
  • Sensitization test for delayed hypersensitivity or sensitization according to ISO 10993-10
  • Irritation or Intracutaneous reactivity according to ISO 10993-10
  • Acute Systemic Toxicity according to ISO 10993-11
  • Haemocompatibility test according to ISO 10993-4

Conclusion

The subject devices, M-Biopsy™ Semi-Automatic Biopsy Instrument (N301), M-Biopsy™ Coaxial Introducer Needle for Semi-Automatic Biopsy Instrument (N302), and M-Biopsy™ Semi Automatic Instrument and Coaxial Introducer Needle Set (NS301), are similar to the predicate device in terms of materials, design, intended use, and performance. There are no differences, which negatively affect a finding of substantial equivalence. Thus, the subject device is considered to be substantially equivalent to the predicate.