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510(k) Data Aggregation
(29 days)
Devicor Medical Products, Inc.
The Mammotome AutoCore™ Single Insertion Core Biopsy System is indicated to obtain tissue samples from the breast or lymph nodes for diagnostic analysis of breast abnormalities. This instrument is for diagnostic use only and is not indicated for therapeutic use.
The extent of a histologic abnormality cannot always be reliably 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 benian, it is essential that the tissue marqins be examined for completeness of removal using standard surgical procedures.
The Mammotome AutoCore™ Single Insertion Core Biopsy System is an automated core needle biopsy system. It is a single insertion, multiple sample device that includes automated arming and automated sample collection. It is available in two gauge sizes (12G and 14G) and acquires soft tissue samples using a spring-loaded inner piercing stylet and outer cutting cannula in the probe needle.
The provided text does not contain detailed acceptance criteria or extensive study results that prove the device meets specific performance metrics. It primarily discusses the regulatory submission for the Mammotome AutoCore™ Single Insertion Core Biopsy System.
However, based on the limited information regarding performance testing, here's what can be extracted and inferred:
1. A table of acceptance criteria and the reported device performance:
The document mentions several performance tests were conducted. While specific acceptance criteria values are not provided, the table below lists the characteristics tested, which implies that the device met the internal acceptance criteria for each test to achieve substantial equivalence.
Characteristic | Acceptance Criteria (Not Explicitly Stated, but implied to be met for SE) | Reported Device Performance (Implied to meet criteria) |
---|---|---|
Static force to penetrate | Not provided | Comparison performed, substantial equivalence confirmed |
Lesion displacement | Not provided | Comparison performed, substantial equivalence confirmed |
Overmold bond strength | Not provided | Comparison performed, substantial equivalence confirmed |
Bend load | Not provided | Comparison performed, substantial equivalence confirmed |
Sample weight | Not provided | Appropriate sample weight achieved |
Sample acquisition | Not provided | Appropriate sample acquisition achieved |
Sample quality | Not provided | Appropriate sample quality achieved |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Bench Testing: The document does not specify sample sizes for the bench tests (static force, lesion displacement, overmold bond strength, bend load). It also does not specify data provenance or if it was retrospective or prospective.
- Animal Testing: The document does not specify sample sizes for the animal testing. It also does not specify data provenance or if it was retrospective or prospective.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):
The document does not describe any human expert involvement in establishing ground truth for the performance tests mentioned. The tests appear to be primarily engineering and animal model assessments.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
No information is provided about adjudication methods for the test sets, as the studies described are not clinical or interpretative in nature where adjudication would typically be relevant.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
Not applicable. The Mammotome AutoCore™ is a physical biopsy system, not an AI-powered diagnostic tool. Therefore, an MRMC study related to human reader performance with or without AI assistance would not be conducted for this device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
Not applicable, as this is a physical medical device and not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Bench Performance: For bench tests, the ground truth would be based on engineering specifications and physical measurements, rather than clinical or pathological ground truth as defined in diagnostic studies.
- Animal Performance: For animal testing, the ground truth for "appropriate sample weight, acquisition, and quality" would likely be determined by veterinary pathologists or other trained personnel assessing the biopsy samples obtained from the animal models, comparing them against established criteria for diagnostic-quality tissue samples.
8. The sample size for the training set:
Not applicable. This document describes the regulatory submission for a physical medical device, not an AI or machine learning algorithm that requires a training set.
9. How the ground truth for the training set was established:
Not applicable, as there is no training set for this device.
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(138 days)
Devicor Medical Products, Inc.
The HydroMARK™ Plus Breast Biopsy Site Marker is indicated to mark tissue during a percutaneous breast biopsy procedure, including axillary lymph nodes, be visible under ultrasound for at least six (6) weeks, and be permanently visible by x-ray and MRI.
The HydroMARK™ Plus Breast Biopsy Site Marker (Hummingbird, subject device) is a two-component marker that provides permanent marking of a breast biopsy or axillary lymph node biopsy site following a breast biopsy procedure. The implantable marker is made of a highly expandable solid cylinder of polymerized and desiccated hydrogel that has the permanent titanium marker embedded. Upon fluid contact (e.g., water, blood, etc.), the hydrogel material expands to an equilibrium point. Once the material hydrates, it is visible under ultrasound. Over time, the hydrogel is resorbed by the patient's body. The titanium wire is permanently visible under x-ray and MRI even after the hydrogel is resorbed. The HydroMARK™ Plus Breast Biopsy Site Marker is a permanent implant and is not intended to be removed unless the marked tissue requires surgical removal. The marker is supplied pre-loaded in a sterile, disposable applicator that is designed to fit into specified commercially available breast biopsy devices. During a breast biopsy procedure, the marker is deployed through a compatible introducer or by direct puncture into the biopsy cavity created by the breast biopsy device.
The HydroMARK™ Plus Breast Biopsy Site Marker (Hummingbird shape) does not involve AI. The provided text describes a medical device, a breast biopsy site marker, and its substantial equivalence to a predicate device. None of the listed points (acceptance criteria, device performance, sample size, ground truth, experts, adjudication, MRMC study, standalone performance, training set, or ground truth for training) are relevant to this type of device submission, especially concerning AI/ML aspects.
The submission focuses on establishing substantial equivalence to a legally marketed predicate device (HydroMARK™ Plus Breast Biopsy Site Marker with a Dragonfly shape, K221961) based on similar design, functionality, performance, and materials.
The key acceptance criteria and performance data for this device are related to its physical characteristics and biological compatibility, rather than AI model performance metrics.
Here's a summary of the relevant information provided, structured to respond to the prompt as closely as possible, even though AI/ML specific information is absent:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (General for device type) | Reported Device Performance (Summary from submission) |
---|---|
Indications for Use: | |
- Mark tissue during percutaneous breast biopsy (including axillary lymph nodes) | "Test Results: PASSED" - Device meets all system requirements as confirmed by performance testing. |
- Visible under ultrasound for at least 6 weeks | "Test Results: PASSED" - Device meets all system requirements as confirmed by performance testing. |
- Permanently visible by x-ray and MRI | "Test Results: PASSED" - Device meets all system requirements as confirmed by performance testing. |
Material/Design/Biocompatibility: | |
- Marker Material: Titanium and hydrogel | "Test Results: PASSED" - Biocompatibility testing met acceptance criteria. |
- Sterility | "Test Results: PASSED" - Device is sterile. |
- Single-Use | "Test Results: PASSED" - Device is single-use. |
- Biocompatibility (Chemical characterization, Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Pyrogenicity, Subacute/Chronic Toxicity, Implantation, Genotoxicity, Carcinogenicity) | "Test Results: PASSED" - Comprehensive biocompatibility testing confirmed safety. |
- MR Conditional Status (for marker) | "Test Results: PASSED" - Marker is MR Conditional. |
- MR Unsafe Status (for applicator) | "Test Results: PASSED" - Applicator is MR Unsafe. |
Performance Evaluations: | |
- Marker Size | "Test Results: PASSED" |
- Deployment Force | "Test Results: PASSED" |
- Visibility | "Test Results: PASSED" |
Risk Management: | "Results: All risks have been reduced as far as possible through allowed controls." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not detail specific sample sizes for performance testing. It states that "Performance Testing was conducted" and "The results of all performance testing met acceptance criteria." The provenance is not explicitly mentioned but is implied to be from the manufacturer's internal testing as part of their ISO 13485:2016 compliant Quality Management System. This type of device does not typically involve clinical data from patients or diverse populations for basic substantial equivalence claims like this.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. This device is a physical marker and its performance evaluation involves objective physical, chemical, and biological tests rather than interpretation by human experts to establish ground truth for a test set in the context of AI/ML.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods are typically relevant for human interpretation or multi-reader studies, which are not described for this device.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is not an AI-powered diagnostic tool, and therefore, no MRMC study was conducted in relation to AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is not an algorithm or software requiring standalone performance evaluation in the context of AI/ML.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for this device's performance would be derived from objective engineering, material, and biocompatibility testing standards. For instance:
- Visibility: Confirmed through imaging techniques (ultrasound, X-ray, MRI) in a controlled setting or phantom, comparing against known visual properties.
- Biocompatibility: Determined by adherence to ISO 10993 standards through laboratory assays and in-vivo animal studies.
- Deployment Force, Marker Size: Measured quantitatively using calibrated instruments.
8. The Sample Size for the Training Set
Not applicable. This device does not involve a training set for an AI/ML model.
9. How the ground truth for the training set was established
Not applicable. This device does not involve a training set for an AI/ML model.
Conclusion stated in the document: The applicant concluded that the HydroMARK™ Plus Breast Biopsy Site Marker (Hummingbird shape) is substantially equivalent to the predicate device (HydroMARK™ Plus Breast Biopsy Site Marker, K221961, Dragonfly shape) based on "similar functional and performance characteristics" and "substantially equivalent design, functionality, and performance characteristics." The "minor differences between the subject device and predicate device regarding marker shape do not raise concerns of safety and effectiveness."
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(137 days)
Devicor Medical Products, Inc.
The LumiMARK™ Biopsy Site Marker is indicated to mark tissue associated with a percutaneous breast biopsy procedure, including axillary lymph nodes, and be permanently visible under ultrasound, x-ray, and MRI.
The LumiMARK™ Biopsy Site Marker implant component [subject device] is composed of a nitinol (nickel/titanium alloy) material versus HydroMARK™ Breast Biopsy Site Marker [predicate device] which is composed of titanium or stainless steel encapsulated in resorbable hydrogel. The marker is not intended to be removed unless the marked tissue is determined to require surgical removal. The marker is supplied pre-loaded in a sterile, disposable applicator that allows the marker to be inserted with direct puncture under ultrasound. The applicator system is of similar design and materials as the currently marketed Devicor Medical Products Inc. HydroMARK™ Breast Biopsy Site Marker (K212158) [predicate device].
LumiMARK™ Biopsy Site Markers will be available in three different shapes. These permanently visible, implantable markers will allow the physician to identify different biopsied sites under ultrasound, x-ray, and MRI. A similar marker device commercialized by Devicor Medical Products, Inc. is already available (under K212158), and this HydroMARK™ Breast Biopsy Marker [predicate].
The deployment system used for the LumiMARK™ Biopsy Site Marker device [subject] will be similar to the HydroMARK™ Breast Biopsy Site Marker [predicate] delivery system with minor design changes to the plunger assembly and cannula. The nitinol markers will be intended for direct puncture or insertion through another introducer needle that is already in the breast or axillary lymph node.
The provided text describes the regulatory clearance of a medical device, the LumiMARK™ Biopsy Site Marker, and asserts its substantial equivalence (SE) to a predicate device, the HydroMARK™ Breast Biopsy Site Marker (K212158).
However, the text does not contain information about acceptance criteria, reported device performance in those criteria, sample sizes for test sets, data provenance, number or qualifications of experts, adjudication methods, MRMC studies, standalone algorithm performance, or how ground truth was established for training sets.
The document focuses on "Performance Testing" and "Biocompatibility Testing" as part of verification data to support substantial equivalence. For both categories, the reported result is "PASSED" and a general statement that "The results of all performance testing met acceptance criteria." However, the specific acceptance criteria themselves, and the quantitative performance metrics attained, are not detailed.
It also explicitly states that the "fundamental scientific technology when compared to the HydroMARK™ Breast Biopsy Site Marker (K212158) [predicate device] has not changed," and that the "minor differences between the subject device and predicate device do not raise concerns of safety and effectiveness." This suggests that the demonstration of substantial equivalence relies heavily on the similarity to the already cleared predicate device, rather than extensive de novo clinical studies with detailed performance metrics.
Therefore, based solely on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
Category | Acceptance Criteria | Reported Device Performance |
---|---|---|
Performance Testing | Not explicitly detailed, but implied to be related to meeting "all system requirements." | PASSED |
(e.g., Marker Size, Deployment Force, Visibility - criteria not specified in text) | Met acceptance criteria | |
LumiMARK™ Risk Management | All risks reduced as far as possible; no unacceptable residual risks; benefits > risks. | PASSED |
Biocompatibility | Not explicitly detailed, but aligned with ISO 10993 series standards. | PASSED |
(e.g., Chemical Characterization, Cytotoxicity, Sensitization, etc. - criteria not detailed) | Met acceptance criteria |
2. Sample size used for the test set and the data provenance:
- Not provided. The document states "Performance Testing was conducted," but does not specify sample sizes or data provenance (e.g., country of origin, retrospective/prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not provided. The testing described is primarily bench performance and biocompatibility, not clinical studies requiring expert ground truth establishment in the traditional sense for diagnostic AI tools.
4. Adjudication method for the test set:
- Not applicable/Not provided. No clinical test set requiring adjudication by experts is described.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No such study was done or mentioned. This device is an implantable biopsy site marker, not an AI-powered diagnostic tool, so MRMC studies for AI assistance are not relevant to its clearance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable/Not provided. This device is a physical implantable marker and does not involve an algorithm for standalone performance.
7. The type of ground truth used:
- For "Performance Testing" and "Biocompatibility Testing," the "ground truth" would be established by objective measurements and adherence to specified scientific and engineering standards (e.g., mechanical properties, chemical composition, biological response) rather than expert consensus on medical images or pathology. The text indicates use of standards like ISO 13485, ISO 14971, and ISO 10993 series for these tests.
8. The sample size for the training set:
- Not applicable/Not provided. This device is a physical medical device, not an AI model, and therefore does not have a "training set" in the context of machine learning.
9. How the ground truth for the training set was established:
- Not applicable/Not provided. (As it's not an AI model, there's no training set or ground truth in this context.)
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(373 days)
Devicor Medical Products, Inc.
HydroMARK™ Plus Breast Biopsy Site Marker is intended to mark tissue during a percutaneous breast biopsy procedure, including axillary lymph nodes, be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI
The HydroMARK™ Plus Breast Biopsy Site Marker contains a two-component implantable marker that provides permanent marking of a breast biopsy or axillary lymph node biopsy site following a breast biopsy procedure. The implantable marker is made of a highly expandable solid cylinder of polymerized and desiccated hydrogel that has the permanent titanium marker embedded. Upon fluid contact (e.g., water, blood, etc.), the hydrogel material expands to an equilibrium point. Once the material hydrates, it is visible under ultrasound. Over time, the hydrogel is resorbed by the patient's body. The titanium wire is permanently visible under x-ray and MRI even after the hydrogel is resorbed. The implantable component of the HydroMARK™ Plus Biopsy Site Marker is supplied preloaded in a sterile, disposable applicator that is designed to fit into specified commercially available breast biopsy devices. During a breast biopsy procedure, the marker is deployed through a compatible introducer or by direct puncture into the biopsy cavity created by the breast biopsy device.
The provided text is a 510(k) Summary for the HydroMARK™ Plus Breast Biopsy Site Marker, seeking to establish substantial equivalence to a predicate device (HydroMARK™ Breast Biopsy Site Marker). It details various performance and biocompatibility tests conducted to demonstrate this equivalence, rather than providing the kind of robust clinical study data typically associated with an AI/ML device approval that would include information on expert reader performance, ground truth establishment, and training/test set details as requested in the prompt.
Therefore, much of the requested information regarding AI/ML-specific study design (such as number of experts, adjudication methods, MRMC studies, standalone performance of an algorithm, and training/test set details for AI models) is not applicable to this submission, as it describes a physical medical device (a biopsy site marker) and its performance, not an AI/ML diagnostic or assistive tool.
However, I can extract the relevant acceptance criteria and reported device performance from the provided document, relating to the physical device itself.
Here's the breakdown based on the provided text, focusing on the device's performance characteristics as a physical marker:
1. A table of acceptance criteria and the reported device performance:
Since this is a physical device and not an AI/ML algorithm, the "acceptance criteria" are derived from the "Indications for Use" and various performance tests aiming to demonstrate substantial equivalence to the predicate device. The performance is reported as meeting these criteria, often by demonstrating equivalence or acceptable results compared to the predicate or relevant standards.
Acceptance Criteria (Derived from Indications for Use / Bench Testing) | Reported Device Performance |
---|---|
Visibility under ultrasound for at least 6 weeks (from Indications for Use) | Verified. "Both immediate post-deployment testing and long-term migration performance of HydroMARK Plus Breast Biopsy Site Markers were confirmed." (While the specific "6 weeks" is not explicitly re-stated as a test result, the overall confirmation of long-term visibility supports this claim of equivalence to the predicate, which also states this.) Testing included "Time to Equilibrium" where "Testing proved both subject and predicate devices achieved hydrogel equilibrium within 24 hours, demonstrating substantial equivalence." |
Permanently visible by x-ray and MRI (from Indications for Use) | Verified. The predicate device claims this, and the subject device uses the same titanium marker for permanent visibility, with "MRI Status (Marker)" being "Conditional" for both predicate and subject. "Both immediate post-deployment testing and long-term migration performance of HydroMARK Plus Breast Biopsy Site Markers were confirmed." (Again, specific "permanently visible" not numeric, but implied by equivalence and material.) |
Safety and Effectiveness of Implantation | "Literature analysis was provided demonstrating product is safe and effective in both breast and lymph node." "HydroMARK™ Implantation Data: PASSED. All tests passed and no local tissue side effects were observed at both lymph node and intramuscular sites at 8 and 26 weeks. Applies only to implant portion of the device." "HydroMARK™ Plus Implantation Data: PASSED. All animals survived, and no abnormalities or adverse reactions were observed at necroscopy. Overall, the test article scored a relative score of '0' with a reactivity grade of 'minimal or no reaction' per Table E.3. of ISO 10993-6:2016 and met the requirements of the study." |
Residual Moisture (Substantial Equivalence to Predicate) | "RESULTS: Testing provided no statistical difference with 95% confidence comparing predicate and subject devices, proving substantial equivalence." |
Hydrogel Degradation (Substantial Equivalence to Predicate) | "RESULTS: Testing and existing clinical evidence of HydroMARK™ hydrogel was provided demonstrating substantial equivalence between predicate and subject devices." |
Biocompatibility (Meeting ISO 10993-1:2020 and other specific ISO standards) | "All the biocompatibility testing conducted on the HydroMARK™ device is applicable to HydroMARK™ Plus devices as well since it is an extension of the existing HydroMARK™ product family... The materials utilized in the HydroMARK™ and HydroMARK™ Plus Biopsy Site Marker devices have been evaluated against all applicable biological endpoints and are considered biocompatible in accordance with EN ISO 10993-1:2020..." Specific tests: Acute Systemic Toxicity (PASSED), Cytotoxicity (PASSED), Irritation (PASSED), Sensitization (PASSED), Pyrogenicity (PASSED). |
Sterilization (Meeting ISO 11135:2014) | "Sterilization: PASSED. Meets standard for ISO 11135:2014 Sterilization of Health Care Products; Ethylene Oxide Requirements for Development, Validation and Routine control of a sterilization process for medical devices." |
Shelf Life (Device: 18 months; Packaging: 36 months) | "Shelf Life [Device]: The shelf life for the HydroMARK™ Plus Breast Biopsy Site Marker [subject device] is 1.5 years/18 months." "Shelf Life [Packaging]: HydroMARK™ Plus Breast Biopsy Site Marker [subject device] has been assessed and passed for up to 36 months." |
Risk Management (Acceptable per ISO 14971:2019 and company policies) | "All risks have been reduced as far as possible through allowed controls. The product risk is acceptable in view of the benefits of the device." "Based on the clinical steps and failure modes tested on HydroMARK™ Plus vs. HydroMARK™, risks have been determined to be acceptable to risk management policies." |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not directly specified in terms of "cases" like in an AI/ML study, but performance and biocompatibility tests were conducted. For instance:
- Implantation Data: Refers to "All animals survived" and "no abnormalities or adverse reactions were observed at necroscopy" for the HydroMARK Plus Implantation Data. The specific number of animals is not provided in this summary. It mentions "standard muscle implantation and lymph node sites" for HydroMARK device data and "additional implantation study" for HydroMARK Plus.
- Residual Moisture, Time to Equilibrium, Toxicity, Pyrogenicity, Irritation, Sensitization: These are laboratory bench tests and animal studies. Specific sample sizes (e.g., number of test articles or animals per test) are not detailed in this summary document, but results are reported as "PASSED."
- Data Provenance: Not explicitly stated regarding country of origin. The studies are described as "Non-Clinical Bench Performance Data" and "Biological Evaluation Testing," which are typically laboratory or animal studies, not human clinical trials. They would be prospective in the sense of being planned tests on the device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not Applicable. This is a physical device submission, not an AI/ML diagnostic. "Ground truth" for this device relates to physical and biological properties (e.g., material composition, sterility, biocompatibility, physical expansion, visibility under imaging modalities) established through engineering specifications, laboratory tests, and animal studies, not human expert reader consensus on images.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. Adjudication methods are relevant for human reader studies, typically in AI/ML performance evaluations. The presented data is from bench and animal testing.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not Applicable. No MRMC study was done, as this is not an AI/ML device for diagnostic assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This refers to a physical medical device, not an algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- The "ground truth" for this medical device is established through:
- Physical and Chemical Benchmarking: Direct measurements of material properties, expansion rates, and stability.
- Biological/Toxicological Standards: Compliance with ISO 10993 series for biocompatibility, using laboratory assays and animal studies to assess absence of toxicity, irritation, sensitization, and pyrogenicity, and demonstration of acceptable local tissue effects upon implantation over time.
- Imaging Visibility: Demonstration of visibility under ultrasound (acute and long-term), x-ray, and MRI, likely through phantom studies or animal imaging.
- Engineering Specifications: Adherence to design requirements, manufacturing processes, and sterilization validation.
8. The sample size for the training set
- Not Applicable. This is a physical device, not an AI/ML system requiring a training set. The device was developed through traditional engineering and material science principles.
9. How the ground truth for the training set was established
- Not Applicable. No training set for an AI model. "Ground truth" for manufacturing and design would be established through material specifications, quality control, and adherence to established engineering principles and medical device standards.
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(283 days)
Devicor Medical Products, Inc.
The HydroMARK Breast Biopsy Site Marker is intended to mark tissue during a percutaneous breast biopsy procedure, including axillary lymph nodes, be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI.
The HydroMARK Breast Biopsy Site Marker [subject device] is a two-component marker that provides permanent marking of a breast biopsy site; a resorbable hydrogel component and a metallic component, and is not intended to be removed unless the marked tissue is determined to require surgical removal. The marker is supplied pre-loaded in a sterile, disposable applicator that is compatible with specified commercially available biopsy devices.
The HydroMARK Breast Biopsy Site Marker has a resorbable component that is a highly expandable solid cylinder of polymerized and desiccated hydrogel. The hydrogel has features that are unique and highly desirable for breast tissue marking. The hydrogels absorb fluid, they are readily visible by ultrasound imaging. During a breast biopsy procedure, the marker is deployed through a delivery tool into the cored-out space created by a breast biopsy device. Upon expansion, the hydrogel fills the space and conforms to the site of biopsy. Embedded in the hydrogel is a coiled metallic wire made of Titanium or Stainless Steel. The wire is coiled into loops to provide a unique identifier under ultrasound, x-ray, and MRI imaging. The embedded metallic wire coil is visible under ultrasound for up to 6 weeks and is permanently visible under X-ray and MRI.
The provided text describes the regulatory clearance of the HydroMARK Breast Biopsy Site Marker, primarily focusing on demonstrating substantial equivalence to a predicate device, especially with an expanded Indication for Use to include axillary lymph nodes. It does not contain information about a study proving the device meets specific acceptance criteria related to a machine learning or AI algorithm.
The document mainly covers:
- Acceptance Criteria for Device vs. AI Algorithm: The "acceptance criteria" here refer to regulatory requirements for demonstrating "substantial equivalence" of a medical device to a previously cleared predicate device, rather than criteria for an AI algorithm's performance. The performance criteria for the device itself are related to visibility under imaging and biocompatibility.
- Device Performance: The document states that the device meets "all system requirements" and is "substantially equivalent" to the predicate. The performance is assessed through non-clinical bench testing for biocompatibility and design verification, as well as a literature search and clinician survey for the expanded indication.
Based on the provided text, the device itself (HydroMARK Breast Biopsy Site Marker) is a physical marker, not an AI algorithm. Therefore, the questions related to AI algorithm performance (e.g., sample sizes for training/test sets, expert adjudication, MRMC studies, standalone performance, ground truth establishment) are not applicable to the information contained in this FDA 510(k) summary.
Therefore, I cannot provide the requested information regarding an AI algorithm's acceptance criteria and study data because the provided document describes a physical medical device (a biopsy site marker), not an AI-powered diagnostic or assistive tool.
The acceptance criteria discussed in the document are primarily related to:
- Safety and Effectiveness: Demonstrated through biocompatibility testing (Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Pyrogenicity, Subchronic Toxicity, Implantation, Genotoxicity, Carcinogenicity).
- Functional Performance: Visibility under ultrasound for at least 6 weeks, permanent visibility by x-ray and MRI.
- Substantial Equivalence: Comparison to a predicate device (Devicor Medical Products Inc. HydroMARK Breast Biopsy Site Marker K210752) in terms of Indications for Use, design, functionality, materials, packaging, and sterilization.
- Expanded Indication for Use (Axillary Lymph Nodes): Supported by a literature search and clinician survey to show that this expanded use does not raise new safety or effectiveness concerns.
To directly answer the prompt's implied request for AI algorithm-specific details based only on the provided text, the relevant sections are empty as this is not an AI device submission.
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(30 days)
Devicor Medical Products, Inc.
The HydroMARK Breast Biopsy Site Marker is intended to mark tissue during a percutaneous breast biopsy procedure, be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI.
The HydroMARK Breast Biopsy Site Marker [subject device] is a two-component marker that provides permanent marking of a breast biopsy site; a resorbable hydrogel component and a metallic component, and is not intended to be removed unless the marked tissue is determined to require surgical removal. The marker is supplied pre-loaded in a sterile, disposable applicator that is compatible with specified commercially available biopsy devices.
The HydroMARK Breast Biopsy Site Marker is a resorbable component that is a highly expandable solid cylinder of polymerized and desiccated hydrogel. The hydrogel has features that are unique and highly desirable for breast tissue marking. The hydrogels absorb fluid, they are readily visible by ultrasound imaging. During a breast biopsy procedure, the marker is deployed through a delivery tool into the cored-out space created by a breast biopsy device. Upon expansion, the hydrogel fills the space and conforms to the site of biopsy. Embedded in the hydrogel is a coiled metallic wire made of Titanium or Stainless Steel. The wire is coiled into loops to provide a unique identifier under ultrasound, x-ray, and MRI imaging. The embedded metallic wire coil is visible under ultrasound for up to 6 weeks and is permanently visible under X-ray and MRI.
This document describes a 510(k) premarket notification for the HydroMARK Breast Biopsy Site Marker. The notification is for modifications to the labeling of an already cleared device, not for a new device or significant changes to its fundamental scientific technology, materials, manufacturing, or intended use.
Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context are focused on demonstrating that the labeling changes do not raise new or different issues of safety and effectiveness compared to the previously cleared devices.
Acceptance Criteria and Reported Device Performance (Table):
Acceptance Criteria | Reported Device Performance |
---|---|
Device meets all system labeling requirements | Passed Document Analysis of Labeling Changes |
Device is as safe and effective as predicate | Demonstrated through verification testing by document analysis of labeling changes and comparison of technological characteristics |
Device performs as well as predicate | Demonstrated through verification testing by document analysis of labeling changes and comparison of technological characteristics |
No new or different issues of safety and effectiveness arise from labeling changes | Conclusion based on comparison of technological characteristics and verification testing |
Detailed Breakdown of the Study and Related Information:
-
Sample size used for the test set and the data provenance:
- Sample Size: Not applicable in the traditional sense of a clinical or performance study involving patient data. The "test set" here refers to the revised labeling documents.
- Data Provenance: The study involved document analysis of labeling changes to the existing HydroMARK Breast Biopsy Site Marker and its predicate/reference devices (K121113, K130537, K161021). No patient-specific data or data from a specific country of origin is mentioned for this particular submission, as it focuses on regulatory labeling compliance.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not explicitly stated. The "ground truth" for labeling changes would likely be established by the manufacturer's regulatory affairs and quality assurance teams, in consultation with relevant internal subject matter experts (e.g., medical, engineering) to ensure accuracy, clarity, and compliance with regulations. External regulatory consultants might also be involved. Specific numbers or qualifications of individual experts are not provided in this summary.
-
Adjudication method for the test set:
- Not applicable as this was a document analysis assessing compliance with regulatory and safety information, not a comparative review of clinical outcomes by multiple experts. The "adjudication" would be internal review and approval processes within the submitting company to ensure the labeling changes are justified and complete.
-
If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No, an MRMC comparative effectiveness study was not done. This submission is for a breast biopsy site marker (a physical device), not an AI-powered diagnostic tool. The concept of "human readers improve with AI" is not relevant to this device.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No, a standalone algorithm performance study was not done. This device is a physical implantable marker, not a software algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for this submission is regulatory compliance and demonstration that the modified labeling does not introduce new safety or effectiveness concerns, based on the established safety and performance of the physical device (which was previously cleared). This is primarily based on:
- Comparison to the predicate device's cleared labeling and performance.
- Internal design verification and risk assessment processes (implied by ISO 14971:2007 mention).
- Applicable regulatory standards and guidelines for medical device labeling.
- The "ground truth" for this submission is regulatory compliance and demonstration that the modified labeling does not introduce new safety or effectiveness concerns, based on the established safety and performance of the physical device (which was previously cleared). This is primarily based on:
-
The sample size for the training set:
- Not applicable. This is not a machine learning or AI-based device, so there is no "training set" in the context of data used to train an algorithm.
-
How the ground truth for the training set was established:
- Not applicable for the same reason as above.
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(63 days)
Devicor Medical Products, Inc
The HydroMARK® Breast Biopsy Site Marker is indicated to mark tissue during a percutaneous breast biopsy procedure, be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI.
The HydroMARK® Breast Biopsy Site Marker [subject device] is a two-component marker that provides permanent marking of a breast biopsy site; a resorbable hydrogel component and a metallic component and is not intended to be removed unless the marked tissue is determined to require surgical removal. The marker is supplied pre-loaded in applicator devices designed to fit into the following:
- 8G Flexible Applicator System fits into:
- O Mammotome revolve® 8G Probe (9cm with and without Specimen Management System and 12cm without Specimen Management System)
- EnCor 7G Directional Vacuum-Assisted Biopsy Devices o
- . 10G Flexible Applicator System fits into:
- Mammotome revolve® 10G Probe (9cm with and without Specimen Management O System and 12cm without Specimen Management System)
- EnCor 10G Directional Vacuum-Assisted Biopsy Devices o
- ATEC 9G Biopsy Handpiece Introducers O
The HydroMARK® Breast Biopsy Site Marker is a resorbable component that is a highly expandable solid cylinder of polymerized and desiccated hydrogel. The hydrogel has features that are unique and highly desirable for breast tissue marking. The hydrogels absorb fluid, they are readily visible by ultrasound imaging. During a breast biopsy procedure, the marker is deployed through a delivery tool into the cored-out space created by a breast biopsy device. Upon expansion, the hydrogel fills the space and conforms to the site of biopsy. Embedded in the hydrogel is a coiled metallic wire made of Titanium. The wire is coiled into loops to provide a unique identifier under ultrasound, x-ray and MRI imaging. The embedded metallic wire coil is visible under ultrasound for up to 6 weeks and is permanently visible under X-ray and MRI. The wire coil is available in (3) three shapes:
- Barrel Shape
- Open Coil Shape
- Butterfly Shape
The provided document is a 510(k) summary for the HydroMARK® Breast Biopsy Site Marker. It details the device's substantial equivalence to predicate devices and the non-clinical performance data supporting this claim.
Here's a breakdown of the requested information based on the document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state numerical acceptance criteria for each test in a table format. Instead, it describes general "In-House Testing Standards" and states that all tests "PASSED," concluding that the device is "as safe, as effective, and performs as well as, the legally marketed predicate device."
However, based on the descriptions of the tests, we can infer the performance criteria. The device aims to demonstrate substantial equivalence to its predicate for various aspects, including safety, effectiveness, and performance characteristics.
Test Category | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Non-Clinical Performance Bench Testing | ||
Design Verification | Meet all design and functional requirements. | PASSED |
FEA (Safety Factor of Cannula) | Demonstrate comparable or improved safety factor compared to predicate/reference cannula to reduce tip shear. | PASSED |
Hydrogel Verification (Hydration, Moisture) | Meet established in-house standards for hydrogel hydration and moisture content, based on and more stringent than predicate. | PASSED |
Compatibility Verification (Deployment/Removal) | Successful deployment and removal of markers in each compatible probe, based on and more stringent than predicate. | PASSED |
Mechanical Verification (Deployment, Self-Retraction, Bond Strength) | Meet established in-house standards for marker deployment, pushrod self-retraction, and bond strength, based on and more stringent than predicate. | PASSED |
Human Factors/Usability Testing | ||
Simulated Use Testing | Safe and effective interaction for intended users, uses, and environments per FDA recognized standards (IEC 62366-1, IEC 60601-1-6, FDA Guidance). | PASSED |
Formative Studies | Findings support safe and effective use. | PASSED |
Biocompatibility Testing | ||
Cytotoxicity (MEM Elution) | No unacceptable adverse biological response. Comply with ISO 10993-1, 10993-5. | PASSED |
Chemical Characterization Testing | ||
Exhaustive Extractables | No unacceptable adverse biological response from leachable substances. Comply with ISO 10993-12, 10993-18. | PASSED |
Toxicological Risk Assessment | No unacceptable toxicological risks. Comply with ISO 10993-1, 10993-18, 10993-17. | PASSED |
Sterilization & Shelf-Life Testing | ||
Bioburden Testing | Meet established bioburden limits. Comply with ANSI/AAMI/ISO 11737-1. | PASSED |
Sterilization Testing | Effective sterilization. Comply with ANSI/AAMI/ISO 11737-1. | PASSED |
Sterility Testing (Natural Product/BI) | Demonstrate product sterility. Comply with ANSI/AAMI/ISO 11737-1. | PASSED |
Endotoxin Testing | Meet endotoxin limits. Comply with USP , ANSI/AAMI ST72. | PASSED |
Residual Analysis Testing | Meet residual limits related to sterilization. Comply with USP , ANSI/AAMI ST72. | PASSED |
Shelf-Life / Transit Verification (12-month) | Maintain integrity, sterility, and performance after 12 months simulated aging. Comply with ASTM F1980-16, F2095-11, F38/F88M-15. | PASSED |
Shelf-Life / Transit Verification (18-month) | Maintain integrity, sterility, and performance after 18 months simulated aging. Comply with ASTM F1980-16, F2095-11, F38/F88M-15. | PASSED |
2. Sample sizes used for the test set and data provenance
The document provides a summary of non-clinical bench testing. It does not specify sample sizes for individual tests. The data provenance is "In-House Testing Standards as established by Devicor Medical Products, Inc." which indicates retrospective testing performed by the manufacturer, relying on internal procedures and industry best practices. There is no mention of country of origin for the data beyond the manufacturer being in Cincinnati, OH, U.S.A.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document focuses on non-clinical (bench, human factors, biocompatibility, sterilization) tests, not clinical studies. Therefore, there is no mention of experts establishing ground truth for a test set in the context of clinical outcomes or imaging interpretation. The "ground truth" for these engineering and safety tests is defined by the established testing standards and internal design requirements.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This document describes non-clinical testing for substantial equivalence, not a clinical study involving human readers or interpretation of medical images. Hence, there is no adjudication method described for the test set. The results are reported as "PASSED" against established testing standards.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No MRMC comparative effectiveness study was done or mentioned. This document is for a medical device (breast biopsy site marker), not an AI-powered diagnostic tool. Therefore, there's no discussion of human readers improving with or without AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This point is not applicable as the device is a physical breast biopsy site marker, not an algorithm or AI.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical tests described:
- Design Verification, FEA, Hydrogel, Mechanical, Compatibility Testing: The "ground truth" is defined by the device's design requirements and the manufacturer's internal testing standards, often based on industry best practices for physical properties, functionality, and performance.
- Human Factors/Usability Testing: The "ground truth" relates to compliance with recognized standards (IEC 62366-1, IEC 60601-1-6, FDA Guidance) for user safety and effectiveness through simulated use and formative studies.
- Biocompatibility, Chemical Characterization, Bioburden, Sterilization, Endotoxin, Residual Analysis, Shelf-Life Testing: The "ground truth" is adherence to recognized international and national standards (e.g., ISO 10993 series, ANSI/AAMI, ASTM, USP) which define acceptable biological response, chemical safety, sterility, and material stability.
8. The sample size for the training set
This document describes the testing for a physical medical device (breast biopsy site marker), not an AI algorithm. Therefore, there is no concept of a "training set" in this context.
9. How the ground truth for the training set was established
As there is no training set mentioned, this question is not applicable.
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(28 days)
Devicor Medical Products, Inc.
The Mammotome revolve Dual Vacuum Assisted Biopsy (VAB) System is indicated to provide tissue samples for diagnostic sampling of breast abnormalities.
· The Mammotome revolve Dual Vacuum Assisted Biopsy (VAB) System is intended to provide breast tissue for histologic examination with partial or complete removal of the imaged abnormality.
· The Mammotome revolve Dual Vacuum Assisted Biopsy (VAB) 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 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 benign through clinical and/or radiological criteria (e.g., fibroadenoma, fibrocystic lesion), the Mammotome revolve Dual Vacuum Assisted Biopsy (VAB) 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.
The Mammotome revolve EX System is an electromechanical breast biopsy device indicated to provide tissue samples for diagnostic sampling of beast abnormalities for histologic examination.
The Mammotome revolve EX System is comprised of three primary subsystems:
-
- a sterile, single-use Probe
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- a reusable Holster, and
-
- a reusable control unit.
The Mammotome revolve EX System is an electromechanical breast biopsy device. The provided text describes conformity with various performance tests, but it does not contain details of a clinical study with acceptance criteria for diagnostic performance (e.g., sensitivity, specificity, or accuracy) or a comparative effectiveness study involving human readers.
Here's an analysis of the provided information, focusing on what is available and explicitly noting the absence of details requested in some points:
1. Table of Acceptance Criteria and Reported Device Performance
The document describes several non-clinical bench performance tests where the acceptance criterion was "PASSED." The specific numerical acceptance criteria for each test (e.g., maximum acceptable bacterial count for sterility) are not detailed, only the outcome.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Sterility Testing | PASSED |
Biocompatibility Testing | PASSED |
Software Verification and Validation Testing | PASSED |
Electrical Safety and Electromagnetic Compatibility (EMC) Testing | PASSED |
Animal Lab Study (Tissue Sample Testing - Sample Weight, Sample Reliability, Sample Quality) | PASSED |
Usability Testing | PASSED |
Note: This table reflects the non-clinical tests reported. Clinical diagnostic performance acceptance criteria (e.g., sensitivity/specificity for abnormality detection) are not provided or assessed in this document.
2. Sample Size Used for the Test Set and Data Provenance
The document describes non-clinical bench testing, animal lab studies, and software verification/validation. It does not refer to a "test set" in the context of human patient data for diagnostic performance.
- Test Set Sample Size: Not applicable for diagnostic performance as described in the provided text, which focuses on device functionality and safety.
- Data Provenance: The animal lab study uses an animal model, but no specific country of origin is mentioned. The other tests are bench tests or software validation. All are likely controlled laboratory or in-house tests. The studies are described as "Non-Clinical Bench Performance Testing," implying retrospective analysis of these tests was performed for this submission.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not provided in the document. For a diagnostic device, ground truth would typically be established by expert interpretation or pathology, which is not described.
4. Adjudication Method for the Test Set
This information is not provided because a clinical test set with diagnostic adjudication is not described.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No Multi-Reader Multi-Case (MRMC) comparative effectiveness study is mentioned in the provided text. The document focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance and safety testing.
6. Standalone Performance Study
No standalone diagnostic performance study (algorithm only without human-in-the-loop performance) is described. The device is a biopsy system, meaning it collects samples for diagnosis, but its own diagnostic performance (like an AI system for image interpretation) is not assessed here. The standalone performance studies relate to the device's functional integrity (e.g., sterility, electrical safety, software function, tissue sampling in an animal model).
7. Type of Ground Truth Used
For the animal lab study's tissue sample testing, the "ground truth" implicitly relates to the properties of the tissue samples collected (e.g., weight, reliability, quality). However, the specific method for establishing this ground truth (e.g., histological examination of collected animal tissue, quantitative measurements) is not explicitly detailed beyond "Tissue Sample Testing - Sample Weight - Sample Reliability - Sample Quality."
For other tests (sterility, biocompatibility, software, electrical safety), the ground truth is defined by the technical specifications and recognized standards (e.g., ISO standards for sterility and biocompatibility).
8. Sample Size for the Training Set
Not applicable. This document describes a medical device, not an AI/ML model that requires a training set of data for diagnostic purposes. The software mentioned is for controlling the device's functions, not for diagnostic interpretation based on learned patterns from a dataset.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for an AI/ML model described in this document.
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(90 days)
Devicor Medical Products, Inc.
The HydroMARK® Breast Biopsy Site Marker is indicated to mark tissue during a percutaneous breast biopsy procedure, be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI.
The HydroMARK® Breast Biopsy Site Marker contains a resorbable hydrogel component and a metallic component for permanent marking. The hydrogel has features that are unique and highly desirable for breast tissue marking. The HydroMARK® Breast Biopsy Site Marker is provided pre-loaded in a sterile, disposable applicator that is compatible with specified commercially available biopsy devices. The marker is deployed by the delivery system and is left in the tract created during the biopsy procedure. This Traditional 510(k) addresses the qualification and validation of a new source of raw material polymer of the same original formulation, produced in a new facility and in smaller batch sizes, to be used by the manufacturer of the hydrogel component of the HydroMARK® Breast Biopsy Site Marker. The hydrogel component is manufactured by Coldstream Laboratories, Inc. The new source of polymer for the hydrogel is Corden Pharma, replacing Genzyme polymer.
The provided text describes a 510(k) premarket notification for a medical device called the HydroMARK® Breast Biopsy Site Marker. The notification aims to demonstrate substantial equivalence to previously cleared predicate devices, primarily due to a change in the raw material polymer supplier for the hydrogel component.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" alongside "reported device performance" in a quantitative manner for specific benchmarks (e.g., "Visibility under ultrasound: >95% detected"). Instead, it lists various tests performed and states that the device "met all original finished product specifications" or "performed as intended according to the specifications established for the original device."
However, we can infer the acceptance criteria from the tests conducted and the statements of equivalence:
Acceptance Criteria Category | Specific Criteria / Test Description | Reported Device Performance (New Device) |
---|---|---|
Material Equivalence | Polymer Raw Material: | |
- Gel Permeation Chromatography (GPC): Equivalent molecular weight distribution (Number Average (Mn) and Weight Average (Mw)) and polydispersity between old and new polymer sources. No evidence of changed polymer composition. | "Results show the number (Mn) and weight averaged (Mw) molecular weights obtained from both sources are comparable. The polymer molecular weight distributions for both manufacturers are equivalent. There is no evidence of changed polymer composition..." | |
- Nuclear Magnetic Resonance (NMR): Equivalent ratios of chemicals from first and second reaction steps, indicating no new chemical entities. | "Ratios of chemicals from the first reaction step demonstrate equivalency. NMR was also used to determine molar ratios of the secondary reaction step and also showed equivalency. ...No different or new chemical entities are identified." | |
- Degradation Profiles: Hydrolysis products of both old and new polymers contain the same components in the same proportions. | "Finally, hydrolysis of both predicate and new polymers contained the same components, in the same proportions. Both raw material polymers are chemically equivalent." | |
Finished Product Quality | Physical Characteristics: | |
- Visual Inspection: Free of visual defects. | "met all original finished product specifications including visual inspection..." | |
- Critical Dimensions: Outer diameter and length (0.070 inches and 0.20 inches for marker, 0.035-0.0625 inches for coil length, 0.039 inches for coil width). | "met all original finished product specifications including... dimensions..." (Implied to match the predicate device dimensions listed in the comparison table: 0.070 inches OD, 0.20 inches length, 0.035-0.0625 inches coil length, 0.039 inches coil width). | |
- % Moisture: Within specified range pre- and post-sterilization. | "met all original finished product specifications including... % moisture..." | |
- Functional Deployment: Deploys as intended. | "met all original finished product specifications including... functional deployment..." | |
- Hydration Rate: Within specified range. | "met all original finished product specifications including... hydration rate..." | |
Imaging Visibility | - Visibility under Ultrasound: Visible for at least 6 weeks. | "met all original finished product specifications including... visibility by ultrasound..." (The Indications for Use state "be visible under ultrasound for at least 6 weeks"). |
- Visibility under X-ray: Permanently visible. | "met all original finished product specifications including... visibility by... x-ray..." (The Indications for Use state "be permanently visible by x-ray"). | |
- Visibility under MRI: Permanently visible and safe in an MRI environment (no significant radio frequency induced heating, image artifacts, magnetically induced torque, or displacement force). | "met all original finished product specifications including... visibility by... MRI..." (The Indications for Use state "be permanently visible by... MRI." This implies compliance with ASTM F2182-11a, ASTM F2119-07, ASTM F2213-06, ASTM F2503-13, ASTM F2052-15). The document states the "Finished devices performed as intended according to the specifications established for the original device." concerning these tests. | |
Biocompatibility | - Sterility: Sterile, meeting ISO 11135 requirements. | "met all original finished product specifications including... sterility..." |
- Bioburden: Within acceptable limits. | "met all original finished product specifications including... bioburden..." | |
- Pyrogens: Apyrogenic. | "met all original finished product specifications including... pyrogens..." | |
- EO Residuals: Within acceptable limits (if Ethylene Oxide sterilized). | "met all original finished product specifications including... ethylene oxide residuals." | |
- Biological Evaluation: Meeting ISO 10993 requirements (Cytotoxicity, Systemic Toxicity, Chemical Characterization). | The document lists the ISO 10993 standards and states that the "Finished devices performed as intended according to the specifications established for the original device," implying that these criteria were met. |
2. Sample size used for the test set and the data provenance
- Test Set Sample Size: For the polymer equivalence testing, "Three samples each of the predicate polymer and the new polymer" were tested by GPC. The same number seems implied for NMR and degradation profiles. For finished product testing, "The three manufacturing batches [of the new polymer] were combined and used to prepare HydroMARK® Breast Biopsy Site Markers which met all original finished product specifications". The exact number of finished devices tested is not specified, but it was enough to represent these combined batches.
- Data Provenance:
- Polymer Raw Material: The new polymer batches were from the Corden Pharma Liestal, Switzerland facility. The predicate polymer was from Genzyme (original supplier/process).
- Finished Product: The finished devices were manufactured using the new Corden Pharma polymer. The testing protocols were "identical to the tests used in the original 510(k)". The study is retrospective in the sense that it aims to demonstrate equivalence to previously established specifications and predicate devices.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This type of information (number of experts, their qualifications, and their role in establishing ground truth) is not applicable to this submission. This 510(k) is not for a diagnostic algorithm or a device requiring expert interpretation for performance evaluation. It's a submission for a physical medical device (breast biopsy site marker) that primarily relies on objective chemical, physical, and imaging characteristic tests, not human interpretive performance.
4. Adjudication method for the test set
Not applicable for the same reasons as #3. There was no "ground truth" established by expert consensus or adjudication in the context of human interpretation. The "ground truth" here is adherence to objective engineering, material science, and biological specifications.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This submission is for a physical medical device (a biopsy site marker), not an AI/CAD system or a device that directly assists human readers in interpreting images. Therefore, an MRMC study or evaluation of human reader improvement with AI assistance is irrelevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. As stated above, this is a physical medical device, not an algorithm.
7. The type of ground truth used
The "ground truth" in this context refers to the established specifications and performance characteristics of the predicate device and relevant industry standards (e.g., ISO, ASTM). Specifically:
- Chemical Equivalence: Established by comparing molecular weight distribution, NMR spectra, and degradation profiles to the known composition and characteristics of the original Genzyme polymer.
- Physical/Functional Performance: Established by existing specifications for visual inspection, critical dimensions, moisture content, functional deployment, hydration rate, invisibility under various imaging modalities, and biological safety (sterility, biocompatibility).
- Imaging Visibility/Safety: Established by adherence to specific ASTM standards for MRI compatibility.
8. The sample size for the training set
Not applicable. This is not an AI/machine learning device that requires a training set. The "training" in this context refers to the qualification and validation of the manufacturing process for the new polymer source, which involved testing "3 consecutive test batches" from the new facility.
9. How the ground truth for the training set was established
Not applicable in the AI/ML sense. However, if interpreting "training set" as the batches used to qualify the new polymer manufacturing process:
The "ground truth" for qualifying these batches was established by comparison to the "original specifications" designed for the predicate device's polymer. This means the acceptable parameters (e.g., molecular weight range, chemical ratios) were already defined based on the performance of the previously approved device.
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(229 days)
DEVICOR MEDICAL PRODUCTS, INC.
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.
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.
The provided FDA 510(k) summary for the Mammotome elite® Biopsy System details its performance testing. However, it does not explicitly state numerical acceptance criteria for many of the tests, nor does it provide detailed quantitative results for the device performance against those criteria. Instead, it generally states that the device is "comparable to the predicate," or "complies with" certain standards.
Below is an attempt to extract the available information and structure it as requested, acknowledging the limitations of the provided document.
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria Category | Specific Criteria (Implicit or Explicit in Document) | Reported Device Performance |
---|---|---|
Biocompatibility | - Cytotoxicity: Acceptable | Complies with ISO 10993-1. |
- Sensitization: Acceptable | Complies with ISO 10993-1. | |
- Irritation: Acceptable | Complies with ISO 10993-1. | |
- Systemic toxicity: Acceptable | Complies with ISO 10993-1. | |
Electrical Safety & EMC | - Compliance with specified standards (e.g., IEC 60601-1, AAMI ES 60601-1, IEC 60601-1-2) | Complies with applicable portions of listed electrical/electromagnetic standards. |
Software V&V | - Mitigated hazards such that failure of device software does not result in minor injury to patient or user. | Software verification and validation testing conducted, documentation provided as recommended by FDA guidance. Considered "moderate" level of concern. |
Animal Testing | ||
- Tissue Sample Weight | Acquire tissue sample weights comparable to the predicate device. | Performed comparable to the identified predicate device. |
- Tissue Transport Efficiency | Deliver similar performance as the predicate system in terms of the percent of samples acquired to the number of samples attempted. | Performed comparable to the identified predicate device. |
- Sample Quality | 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. | Performed comparable to the identified predicate device; comparable to predicate. |
Bench Testing | Force to penetrate comparable to the predicate system. | Bench testing confirmed comparable performance to the predicate device. |
2. Sample size used for the test set and the data provenance
The document explicitly mentions "In these studies, acquisition of tissue samples from a single insertion site was evaluated..." but does not provide specific numerical sample sizes for the animal testing. It also does not provide details on the data provenance (e.g., country of origin, retrospective/prospective). It only states an "in vivo porcine animal model was used."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document does not provide information on the number of experts used or their qualifications for establishing ground truth, particularly for the histological assessment of sample quality. It states, "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" and "Whenever breast tissue is removed, histological evaluation of the tissue is the standard of care," implying histological assessment is handled by standard professional practice, but not specifying details for this particular study.
4. Adjudication method for the test set
The document does not describe any specific adjudication method for the test set.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No MRMC comparative effectiveness study was done, nor does the device involve AI. The device is a biopsy system and the testing involved evaluating its physical performance (e.g., tissue acquisition, transport, quality) compared to a predicate device, not diagnostic effectiveness with human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The device is a physical biopsy system, not a software algorithm. Therefore, a standalone algorithm-only performance study is not applicable and was not conducted.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the tissue sample quality evaluation in animal testing, the ground truth was histological assessment (implied by "optimal histological assessment"). For other performance aspects like sample weight and transport efficiency, the "ground truth" was direct measurement and comparison to the predicate device's measured performance.
8. The sample size for the training set
No training set is mentioned or applicable as this is a physical medical device, not an AI or machine learning algorithm.
9. How the ground truth for the training set was established
Not applicable as there is no training set for this physical device.
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