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510(k) Data Aggregation

    K Number
    K161021
    Date Cleared
    2016-05-05

    (23 days)

    Product Code
    Regulation Number
    878.4300
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    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.

    Device Description

    The HydroMARK® Breast Biopsy Site Marker contains a reabsorbable 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 HydroMARK® Breast Biopsy Site Marker is deployed by the delivery system and is left in the track created during the biopsy procedure.

    This Special 510(k) is being submitted for modifications to two models of the cleared device, HydroMARK® Breast Biopsy Site Marker. The fundamental scientific technology of the two models of the modified HydroMARK® Breast Biopsy Site Markers has not changed. This submission contains information to support:

    1. Modifications to the rigid delivery system of two models of the HydroMARK® Breast Biopsy Site Marker;
    2. Compatibility for use of those two models with the Mammotome revolve® biopsy system; and
    3. IFU updates related to the modifications noted for those two models.

    There are no changes to the supplier of the hydrogel material, or other materials of construction. There are no changes to the finished product manufacturing site. There are no changes to the sterilization location and method, no changes to packaging, no changes to shelf-life, and no changes to indications for use or intended use.

    Changes to labeling include rebranding and legal manufacturer name and address, as well as updates to the IFU to incorporate instructions for use related to the added compatibility with the Mammotome revolve® Biopsy System.

    AI/ML Overview

    The provided document is a 510(k) summary for the HydroMARK® Breast Biopsy Site Marker, specifically for modifications to an already cleared device. As such, it does not detail a full study establishing device acceptance criteria from scratch but rather demonstrates that the modifications do not alter the existing performance and safety profile, maintaining substantial equivalence to the predicate device.

    However, based on the information provided, we can extrapolate and structure the details as requested:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied)Reported Device Performance
    Mark tissue during a percutaneous breast biopsy procedureDevice performs as intended, accurately marking the biopsy site
    Visible under ultrasound for at least 6 weeksNo change from predicate; predicate is visible for at least 6 weeks
    Permanently visible by X-ray and MRINo change from predicate; predicate is permanently visible by X-ray and MRI
    Functions with specified commercially available biopsy devicesModifications tested for compatibility with Mammotome revolve® biopsy system
    Meets biocompatibility (ISO 10993-1)Device continues to meet ISO 10993-1 requirements
    Maintains original shelf-life (3 years/36 months)Shelf-life remains 3 years/36 months
    Maintains sterilization method (ETO)Sterilization method remains ETO
    Deployment as intendedDeployment testing conducted, devices performed as intended
    Ease of insertion and deployment (Usability)Usability testing conducted, devices performed as intended
    Visual and dimensional conformity to specificationsVisual and dimensional testing conducted, performed as intended

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a distinct "test set" in the traditional sense for a new device evaluation. Instead, it describes non-clinical performance data and comparison testing for the modified device against its predicate.

    • Sample Size for Non-Clinical Testing: Not explicitly stated for each test (Visual, Dimensional, Deployment, Usability).
    • Data Provenance: Not explicitly stated, but given it's a 510(k) submission by a US company, the testing is assumed to be conducted in a controlled lab/test environment, likely in the US. The tests are non-clinical (i.e., not performed on human subjects).

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    Not applicable. This submission concerns non-clinical performance and substantial equivalence based on material and design changes, not clinical outcomes requiring expert interpretation of human data.

    4. Adjudication Method for the Test Set

    Not applicable for this non-clinical testing. Performance was assessed against established specifications.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, an MRMC comparative effectiveness study was not done. The device is a physical marker, not an AI or imaging diagnostic tool that would typically involve a MRMC study.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    Not applicable. This device is not an algorithm. Performance tests related to deployment, visibility, and biocompatibility are reported.

    7. Type of Ground Truth Used

    For the non-clinical performance data:

    • Instrumental measurements/visual inspection for conformity: For visual and dimensional testing.
    • Engineering specifications/functional performance criteria: For deployment and usability testing.
    • ISO standards: For biocompatibility (ISO 10993-1).
    • Predicate device's established performance: For visibility (ultrasound, X-ray, MRI, and duration) as the modifications did not impact these characteristics.

    8. Sample Size for the Training Set

    Not applicable. This device does not involve machine learning or an 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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