Comfort Catheter System is intended for interstitial Brachytherapy procedures involving the Nucletron remote afterloading equipment: mHDR.
Device Story
Comfort Catheter System is an accessory for Nucletron remote afterloading equipment (mHDR) used in interstitial brachytherapy. The system includes a leader insertion needle, obturator, and flexible implant tubes. Clinicians insert the needle into the target volume (e.g., breast), replace the obturator with a flexible implant tube, and secure the tube with distal and proximal buttons against the skin. A flange molding tool fixes the proximal button. X-ray/CT markers are inserted for visualization and treatment planning. During treatment, a closed-end Proguide treatment needle is inserted into the implant tube and connected to the afterloader via transfer tubes. The afterloader performs a check cable run to ensure path patency before delivering the radioactive source. The system provides a closed path for the source, preventing contact with body fluids. The design allows catheters to be stored within a patient treatment box between fractions, improving patient comfort and staff workflow compared to protruding catheters.
Clinical Evidence
No clinical data provided; bench testing only.
Technological Characteristics
Accessory for remote afterloading brachytherapy. Components include insertion needles, flexible implant tubes, buttons, and flange molding tools. Closed system design prevents radioactive source contact with body fluids. Materials are consistent with previously cleared implantable devices. System is non-powered, mechanical, and used in conjunction with Nucletron mHDR afterloading equipment.
Indications for Use
Indicated for patients undergoing interstitial brachytherapy procedures using Nucletron mHDR remote afterloading equipment.
Regulatory Classification
Identification
A remote controlled radionuclide applicator system is an electromechanical or pneumatic device intended to enable an operator to apply, by remote control, a radionuclide source into the body or to the surface of the body for radiation therapy. This generic type of device may include patient and equipment supports, component parts, treatment planning computer programs, and accessories.
K020015 — IMPLANT GUIDANCE SYSTEM APPLICATOR SET · Nucletron Corp. · Mar 13, 2002
K060349 — PROGUIDE NEEDLE SET · Nucletron Corporation · Mar 10, 2006
K022635 — KUSKE BREAST APPLICATOR SET, MODEL 189.006 · Nucletron Corporation · Sep 6, 2002
K172533 — GM Implant Tubes, Length Cutting Gauge · Varian Medical Systems, Inc. · Oct 22, 2018
K130757 — KOBOLD SECURE LOCK TRANSFER GUIDE TUBE SET; KOBOLD LUER TRANSFER GUIDE TUBE SET · Spencer Fillmore · Apr 3, 2014
Submission Summary (Full Text)
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AUG 15 2003
K∅32372
Image /page/0/Picture/2 description: The image shows the word "Nucletron" in a bold, sans-serif font. To the left of the word is a square graphic. Inside the square is a black shape with two white circles on either side.
## NUCLETRON B.V.
Waardgelder 1 3905 TH Veenendaal P.O.Box 930 3900 AX Veenendaal The Netherlands Phone +31 318 557133 +31 318 550485 Fax
Department of Health and Human Services Centre of Device and Radiological Health Office of Device Evaluation Special 510(k) section
# 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS INFORMATION
as required by section 807.92(c)
#### Submitter of 510(k):
. ● .. .
| Company name: | Nucletron Corporation |
|----------------------|-----------------------------------------|
| Registration number: | 1121753 |
| Address: | 7080 Columbia Gateway Drive |
| | Columbia, MD 21046-2133 |
| Phone: | 410-312-4100 |
| Fax: | 410-312-4197 |
| Correspondent : | Lisa Dimmick |
| | Director Assurance & Regulatory Affairs |
#### Modified Device Name:
| Trade/Proprietary Name: | Comfort Catheter System |
|-------------------------|-----------------------------------------------------------------|
| Common/Usual Name: | Remote Afterloading for interstitial Brachytherapy applications |
| Classification Name: | Remote controlled radionucide applicator system accessory |
| Classification: | 21Cfr892.5700 Class II |
#### Legally Marketed Device(s)
Our device is substantially equivalent to the legally marketed predicate device cited in the table below:
| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------<br>Manufacturer<br>with the first and states and the different of the different to the distribution of the distribution of the distribution of the distribution of the discussion of the discussi | Device | 510(k) #<br>Party Comment of the free and reserved reality of the first of the first and the first and the first and the first and the first and the first and the first and the first and |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Nucletron BV | I Implant Guidance System | K020015 |
## Description:
The Nucletron Comfort Catheter System as described in this submission is designed as an accessory to the Nucletron remote afterloading equipment. mHDR and is intended for interstitial Brachytherapy procedures.
The device consists of a Leader insertion needle with an opturator which is inserted through the skin surface into the target volume. I.e. breast. The opturator is ther removed and the
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# K 43237Z
flexible implant tube is inserted into hollow needle, the hollow needle is retracted when the flexible implant tube is in place. Optional a template can be used for positioning the insertion needles.
Once the catheter is in place the insertion needle is removed and a button is placed over the plastic catheter and slid into contact with the skin surface. .The Flexible implant tube is pulled in position until the distal button is in contact with the skin surface. The proximal button is pulled over the flexible implant tube, until the button is in contact with the skin surface. The flexible implant tubes are cut off. at a predetermined length with the cutter. A flange is molded on the flexible implant tube with the flange molding tool, to fixate the proximal button.
X-ray catheters or CT markers are inserted into the Proguide treatment needles for visualisation. Radiographic images, planar films or transverse slices, i.e. CT, MR is obtained to determine the precise location of the applicator within the body. This information is then used for Brachytherapy treatment planning purposes.
The Proguide treatment needles are a closed system to prevent the radioactive source from coming in contact with body fluids. The treatment catheter does not control the treatment unit; it strictly provides a treatment path for the radioactive source. The afterloader and the clinical staff verify that the applicator is properly attached prior to treatment.
For the first treatment a closed end Proguide treatment needle is inserted up to the distal end of the flexible implant tube. The Proguide treatment needle is immobilised with a stoptag. The Proquide treatment needle is attached to the afterloader (treatment head), using transfer tubes. When the applicator is attached, a check cable run is performed to ensure that the applicator is properly attached and that there are no obstructions, which will interrupt treatment, After the check cable run, the radioactive source will step through the applicator to deliver the prescribed dose of radiation.
After the treatment the Proguide treatment needles are disconnected from the attached transfer tubes and from the implant (flexible implant tubes) by using the stop tags. In between treatment fractions the Proquide treatment needle are stored in a patient treatment box. The Stop tags must remain fixed on the Proguide treatment needles for the next fraction. When the course of treatment is completed the flexible implant tubes and buttons are removed from the patient.
The device uses similar (implantable) materials as the legally marketed predicate device cited (Implant Guidance System). With respect to the legally marketed predicate device cited (MicroSelectron HDR V2: Breast Template), the implant technique has been optimised for interstitial techniques such as breast implants, no longer the catheters are protruding from the patients body in between fractions. This increases the patient comfort and flexibility. It is also easier for the hospital staff to apply and remove the catheters.
The Comfort Catheter System is used as an accessory to the Nucletron microSelectron.
#### Intended use:
The modified device has the same intended use as the legally marketed predicate device cited:
Comfort Catheter System is intended for interstitial Brachytherapy procedures involving the Nucletron remote afterloading equipment: mHDR.
Summary of tecnnological considerations:
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K032372
The Comfort Catheter System is substantially equivalent to the cleared predicate device, Comfort Catheter System, 510(k)#: K020015.
ts van Krieken
Name: Frits van Krieken Title: Business Segment Manager Nucletron B.V. Veenendaal, The Netherlands
13-06-2003
Date
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Image /page/3/Picture/1 description: The image shows a black and white logo for the Department of Health & Human Services - USA. The logo is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter of the circle. Inside the circle is an abstract symbol that resembles a stylized bird or a wing-like shape, composed of three curved lines.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
AUG 15 2003
Re: K032372
Trade/Device Name: Comfort Catheter System Regulation Number: 21 CFR 892.5700 Regulation Name: Remote controlled radionuclide applicator system Regulatory Class: II Product Code: 90 JAQ Dated: July 31, 2003 Received: August 1, 2003
Dear Mr. Ruys:
Nucletron B.V.
% Mr. Peter N. Ruys
KEMA Quality B.V.
NL-6812 AR Arnhem
THE NETHERLANDS
Utrechtseweg 310
Responsible Third Party Official
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA), You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (sections 531-542 of the Act); 21 CFR 1000-1050.
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This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of the letter:
| 8xx.1xxx | (301) 594-4591 |
|----------------------------------|----------------|
| 876.2xxx, 3xxx, 4xxx, 5xxx | (301) 594-4616 |
| 884.2xxx, 3xxx, 4xxx, 5xxx, 6xxx | (301) 594-4616 |
| 892.2xxx, 3xxx, 4xxx, 5xxx | (301) 594-4654 |
| Other | (301) 594-4692 |
Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97) you may obtain. Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.
Sincerely yours,
Nancy C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use Statement
510(k) Number
K\$\phi\$32372
Device Name
Comfort Catheter System
Indications for Use
Comfort Catheter System is intended for interstitial Brachytherapy procedures involving the Nucletron remote afterloading equipment: mHDR.
## PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109)
OR
Over-The-Counter Use__________________________________________________________________________________________________________________________________________________________
David A. Lyman
(Division Sign-Off) Division of Reproductive, Abdo and Radiological Devic 510(k) Numb
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