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510(k) Data Aggregation
(60 days)
The UltraCor® Twirl® Breast Tissue Marker is intended for use to attach to soft breast tissue, including axillary lymph nodes, to radiographically mark the location of the biopsy procedure.
The ULTRACOR® Twirl® Breast Tissue Marker consists of a disposable beveled needle applicator containing a nitinol radiographic ring wireform. The wireform is intended for longterm radiographic marking of the tissue site. The applicator has a beveled 17G x 10cm needle with 1cm depth marks and a locking plunger. The ring is deployed from the beveled needle tip into the tissue site.
The provided text describes a 510(k) premarket notification for the UltraCor Twirl Breast Tissue Marker. However, it explicitly states that no performance data (bench testing or clinical analysis) was warranted due to the nature of the change.
The key information regarding acceptance criteria and study details is as follows:
1. A table of acceptance criteria and the reported device performance:
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not applicable. | No new or increased risks identified from the updated Indications for Use. |
2. Sample size used for the test set and the data provenance:
- Sample Size: Not applicable. No test set was used for a performance study.
- Data Provenance: Not applicable.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Number of Experts: Not applicable.
- Qualifications of Experts: Not applicable.
4. Adjudication method for the test set:
- Adjudication Method: Not applicable.
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:
- MRMC Study: No. This device is not an AI-assisted diagnostic tool, but rather an implanted marker.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: No. This device is an implanted marker, not a diagnostic algorithm.
7. The type of ground truth used:
- Ground Truth Type: Not applicable. The submission is based on an update to the Indications for Use, supported by a literature review and physician statements on existing clinical practice, rather than a direct performance study to establish a ground truth.
8. The sample size for the training set:
- Sample Size: Not applicable. No training set was used.
9. How the ground truth for the training set was established:
- Ground Truth Establishment: Not applicable.
Explanation from the document:
The 510(k) submission (K180061) for the UltraCor Twirl Breast Tissue Marker focused on an update to its Indications for Use to include axillary lymph nodes. The manufacturer explicitly states:
- "The change to the Indications for Use described in this submission does not affect the design of the device and no new or increased risks have been identified, therefore additional bench performance testing was not warranted." (Page 5, Section 8. Performance Data)
- "The change to the Indications for Use is clinically supported by both a comprehensive literature review and physician statements." (Page 5, Section 9. Clinical Analysis)
Therefore, this submission did not involve a study to prove performance against specific acceptance criteria in the traditional sense of a diagnostic or therapeutic device. Instead, it leveraged existing knowledge and clinical practice to justify the expanded indication of an already cleared device.
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(254 days)
The UltraCor Twirl Breast Tissue Marker is intended for use to attach to soft breast tissue at the surgical site during an open surgical breast biopsy or a percutaneous breast biopsy to radiographically mark the biopsy procedure.
The UltraCor® Twirl™ Breast Tissue Marker consists of a disposable beveled needle applicator containing a Nitinol radiographic ring marker is intended for long-term radiographic marking of the tissue site. The applicator has a beveled 17q x 10cm needle with 1 cm depth marks and a locking plunger. The ring is deployed from the beveled needle tip into the tissue site.
The provided document describes the UltraCor® Twirl™ Breast Tissue Marker and its substantial equivalence to a predicate device, UltraClip® II US Wing and Coil. It outlines performance testing that was conducted, but it does not present acceptance criteria in a table format nor does it describe a study proving the device met specific performance metrics in a way that allows for a direct comparison table as requested.
The document focuses on design verification and validation testing, confirming that modifications from the predicate device do not impact safety or effectiveness. The conclusion states that the subject device "met all predetermined acceptance criteria of design verification and validation," but it does not list these criteria or the specific results against them.
Therefore, based on the provided text, I cannot complete parts 1, 2, 3, 4, 5, 6, 7, 8, and 9 of your request as these specific details are not present. The document summarizes the types of tests performed, rather than the quantitative results or the methodology for establishing ground truth, sample sizes, or expert involvement in those tests.
Here's a breakdown of what can be extracted and what is missing:
Information that can be extracted from the document:
- Device Name: UltraCor® Twirl™ Breast Tissue Marker
- Predicate Device: UltraClip® II US Wing and Coil (K090547)
- Types of Testing Performed (as listed in "Performance Testing Summary"):
- Marker shape distinguishability
- Ultrasound visibility
- Marker deployment accuracy
- Marker deployment force
- Marker deployment
- Marker retention
- Marker dimensional testing
- Applicator dimensional testing
- Applicator tensile testing
- Visual inspection of the product
- Visual integrity of the packaging
- Pouch seal strength of the packaging
- MRI testing (magnetic field interactions, MRI-related heating, artifact testing)
- Biocompatibility testing on the applicator and the marker implant
- Ground Truth for performance testing: The document implies that the ground truth for these tests was based on "applicable standards, guidance, test protocols and/or customer inputs," but the specifics of how this ground truth was established are not detailed.
Information that is NOT available in the document and therefore cannot be provided in response to your request:
- A table of acceptance criteria and the reported device performance: The document states that the device "met all predetermined acceptance criteria," but does not list these criteria or report the specific performance metrics achieved against them.
- Sample size used for the test set and the data provenance: Not specified for any of the performance tests. The nature of these tests (e.g., bench testing) suggests lab-based experiments, but details are missing.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not specified.
- Adjudication method for the test set: Not applicable and not mentioned, as this device's testing relates to physical properties, not diagnostic interpretation.
- 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 a breast tissue marker, not an AI diagnostic tool.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This device is a physical medical implant, not an algorithm.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): While the document mentions "applicable standards, guidance, test protocols and/or customer inputs," the specific type of ground truth (e.g., whether "ultrasound visibility" was assessed by expert consensus on images, or by quantitative metrics) is not detailed.
- The sample size for the training set: Not applicable, as this is not an AI/algorithm-based device requiring a training set.
- How the ground truth for the training set was established: Not applicable.
In summary, the document confirms that various design verification tests were conducted, and the device met its acceptance criteria, contributing to its substantial equivalence determination. However, it does not provide the granular detail requested concerning the specific acceptance criteria, test results, sample sizes, or expert involvement.
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