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510(k) Data Aggregation

    K Number
    K190689
    Date Cleared
    2019-08-14

    (149 days)

    Product Code
    Regulation Number
    878.4300
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    View Point Medical, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SignalMark Breast Marker is intended to provide accuracy in marking a surgical site and/or a biopsy location for visualization during surgical resection.

    Device Description

    The SignalMark Breast Marker is a medical device used by a physician to percutaneously place a small implantable hydrogel marker in breast tissue to "mark" the location of the biopsy or surgical site. It is intended to be used on adults undergoing open surgical breast biopsy or percutaneous breast biopsy, in a surgical setting, such as a hospital or medical clinic with operating suites. The SignalMark Breast Marker consists of two components:

    • . Applicator: Component made of plastic and stainless steel that pushes the marker into the tissue.
    • Marker Pad: Component made of USP-grade porcine gelatin-based hydrogel with methylene blue-colored silicon dioxide microspheres. The marker aids in the visualization of tissue allowing surgeons to readily locate the biopsy site for subsequent tissue or tumor resection.
    AI/ML Overview

    The provided document, a 510(k) summary for the SignalMark Breast Marker, describes non-clinical testing performed to demonstrate substantial equivalence to predicate devices, rather than a study designed to prove the device meets specific acceptance criteria in the context of clinical performance or diagnostic accuracy. Therefore, a table of acceptance criteria and reported device performance in those terms is not available from this document.

    However, the document does detail other aspects of the testing performed, which can be extracted and summarized.

    No clinical studies involving human patients, multi-reader multi-case (MRMC) comparative effectiveness studies, or standalone algorithm performance studies are described in this 510(k) summary, as it focuses on non-clinical (bench and animal) testing. The device is a physical marker and not an AI/algorithm-based diagnostic tool, so certain sections of your request (e.g., effect size of human readers improving with AI, standalone performance, training set details) are not applicable.


    1. A table of acceptance criteria and the reported device performance

    As mentioned, this document does not provide a table of acceptance criteria for diagnostic performance or clinical effectiveness, nor does it report device performance against such criteria. The testing focused on demonstrating equivalence to predicate devices through physical and biological testing.

    The document lists the following non-clinical tests performed:

    Test CategorySpecific TestsReported Device Performance and Acceptance Criteria
    BiocompatibilityISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing with a risk management processPatient-contacting material was subjected to biocompatibility testing in compliance with ISO 10993-1. This implies the device met the requirements of this standard.
    Performance (Bench)Visual Inspection of the ApplicatorNot explicitly stated, but implied to meet internal specifications for visual quality.
    Applicator Deployment TestNot explicitly stated, but implied to meet internal specifications for proper deployment.
    Applicator Dimensional InspectionNot explicitly stated, but implied to meet internal specifications for dimensions.
    Applicator Stroke Length TestNot explicitly stated, but implied to meet internal specifications for stroke length.
    Applicator Compression TestNot explicitly stated, but implied to meet internal specifications for compression limits.
    Applicator Tensile TestNot explicitly stated, but implied to meet internal specifications for tensile strength.
    Visual Inspection of the Marker PadNot explicitly stated, but implied to meet internal specifications for visual quality.
    Marker Pad DiameterNot explicitly stated, but implied to meet internal specifications for diameter.
    Marker Pad HydrationNot explicitly stated, but implied to meet internal specifications for hydration properties and expansion.
    Marker Pad Ultrasound Visual TestThe document states both the subject device and predicate are visible under ultrasound, implying the test confirmed this visibility.
    Labeling wipe test with 70% IPANot explicitly stated, but implied to meet internal specifications for labeling durability.
    Packaged Contents VerificationNot explicitly stated, but implied to meet internal specifications for package integrity and contents.
    Performance (Animal)Biodistribution in rodentsNot explicitly stated, but implied to demonstrate acceptable biodistribution without adverse effects or to be comparable to predicate.
    Safety and efficacy in porcineNot explicitly stated, but implied to demonstrate safety and function in an animal model, comparable to predicate.
    Biologic response in porcineNot explicitly stated, but implied to demonstrate an acceptable biological response in an animal model.

    Note: The document states, "No FDA performance standards have been established for the SignalMark Breast Marker." This indicates that the equivalence was demonstrated against the predicate's known performance for these non-clinical aspects, rather than against specific regulatory performance metrics for this type of device.


    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: The document does not specify the exact sample sizes for each of the bench and animal tests. It only lists the types of tests conducted. For example, for "Biodistribution in rodents" and "Safety and efficacy in porcine," the specific number of animals used is not provided.
    • Data Provenance: The document does not mention the country of origin of the data. The studies were non-clinical (bench and animal), so the terms "retrospective" or "prospective" as they apply to human clinical studies are not directly relevant. These were experimental studies.

    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)

    This section is not applicable as the document describes non-clinical (bench and animal) testing, not a diagnostic accuracy study requiring expert establishment of ground truth.


    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This section is not applicable as the document describes non-clinical (bench and animal) testing, not a diagnostic accuracy study requiring adjudication.


    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

    This section is not applicable. The SignalMark Breast Marker is a physical implantable marker, not an AI or imaging diagnostic device. No MRMC study or AI assistance is mentioned or relevant to this device's 510(k) submission.


    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    This section is not applicable. The SignalMark Breast Marker is a physical implantable marker, not an algorithm, and therefore does not have "standalone performance" in the context of AI or software.


    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    For the non-clinical tests described:

    • For Biocompatibility, the ground truth is adherence to the ISO 10993-1 standard.
    • For Bench Performance tests (e.g., dimensional inspection, deployment, hydration, ultrasound visibility), the ground truth would be the pre-defined engineering specifications, material properties, and expected physical behaviors of the device, often compared to the predicate device's characteristics.
    • For Animal Performance tests (biodistribution, safety, efficacy, biologic response), the ground truth is derived from the observed biological reactions, histology, and functional outcomes in the animal models, compared to established norms or the predicate device's effects.

    8. The sample size for the training set

    This section is not applicable. The SignalMark Breast Marker is a physical medical device, not a machine learning or AI model, and therefore does not have a "training set" in that context. The device's design and manufacturing processes are developed through traditional engineering and material science principles.


    9. How the ground truth for the training set was established

    This section is not applicable for the same reason as point 8.

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