MARKIT TISSUE MARKER-1ML MARKIT TISSUE MARKER-3ML MARKIT TISSUE MARKER-10ML

K121964 · Augmenix, Inc. · NEU · Jan 23, 2013 · General, Plastic Surgery

Device Facts

• Record ID: K121964
• Device Name: MARKIT TISSUE MARKER-1ML MARKIT TISSUE MARKER-3ML MARKIT TISSUE MARKER-10ML
• Applicant: Augmenix, Inc.
• Product Code: NEU · General, Plastic Surgery
• Decision Date: Jan 23, 2013
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4300
• Device Class: Class 2

Indications for Use

TraceIT Tissue Marker is indicated for use to radiographically mark soft tissue during a surgical procedure or for future surgical procedures. TracelT hydrogel is intended to mark tissue for at least 3 months after injection.

Device Story

TraceIT Tissue Marker is a sterile, single-use, polymerized polyethylene glycol (PEG) hydrogel. It is delivered to a surgical site via needle or cannula. The hydrogel provides radiographic visibility under MRI, CT, and ultrasound for at least three months. The material is designed to hydrolyze and clear from the body approximately six months after injection. It is used by clinicians to mark soft tissue for surgical planning or follow-up. The device benefits patients by providing a temporary, visible marker for precise localization of surgical sites.

Clinical Evidence

Bench testing only. In vitro and in vivo preclinical tests were performed to verify and validate safety and effectiveness and demonstrate substantial equivalence to predicate devices.

Technological Characteristics

Polymerized polyethylene glycol (PEG) hydrogel. Sterile, single-use. Delivered via needle or cannula. Radiopaque/visible under MRI, CT, and ultrasound. Hydrolyzes and clears from the body in approximately 6 months.

Indications for Use

Indicated for radiographic marking of soft tissue during or for future surgical procedures. Intended to remain visible for at least 3 months post-injection.

Regulatory Classification

Identification

An implantable clip is a clip-like device intended to connect internal tissues to aid healing. It is not absorbable.

Predicate Devices

• BiomarC Tissue Marker (K001807)
• Coaptite Tissue Marker (K012955)

Submission Summary (Full Text)

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#### Augmenix, Inc. Supplement 001 to K121964 TracelT Tissue Marker

## JAN 2 3 2013

SECTION 5.0:

## 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

## A. Submitter Information

Submitter's Name:

Address:

Augmenix, Inc

781-902-1613

781-895-3236 ·

November 19, 2012

Tissue Marker

204 Second Avenue Waltham, MA 02451

Telephone:

Fax:

Contact Person:

#### Date of Preparation

- B. Subject Device:
- Trade Name:

Common/Usual Name:

Class:

- C. Predicate Device Name(s):
Trade Name(s)

Product Code:

BiomarC Tissue Marker, K001807 Coaptite Tissue Marker, K012955

Eric Ankerud, Executive Vice President

Clinical, Regulatory, Quality

TraceIT™ Tissue Marker

## D. Indications for Use:

TraceIT™ Tissue Marker is indicated for use to radiographically mark soft tissue during a surgical procedure or for future surgical procedures. TracelT hydrogel is intended to mark tissue for at least 3 months after injection

NEU

#### E. Device Description

TracelT Tissue Marker is a sterile, single use, polymerized polyethylene glycol (PEG) hydrogel that is delivered to mark a surgical location via a needle or cannula. The hydrogel material is visible under MRI, CT, and ultrasound for up to three months after the injection: The material hydrolyzes and is cleared from the body approximately six (6) months after injection.

#### F. Predicate Device(s) Reference

TracelT Tissue Marker was shown to be substantially equivalent in intended use, principle of operation, and technological characteristic to the following previously cleared devices: BiomarC Tissue Marker (K001807) and Coaptite Tissue Marker (K012955)

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K121964

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#### Augmenix, Inc. Supplement 001 to K121964 TraceIT Tissue Marker

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:

#### G. Performance Data:

In vitro and in vivo preclinical tests were performed to verify and válidate the safety and effectiveness of TracelT Tissue Marker and assure substantial equivalence to the predicate devices.

## H. Basis for Determination of Substantial Equivalence

Upon reviewing the safety and efficacy information provided in the submission and comparing intended, principal of operation, and overall technological characteristics, TraceIT Tissue Marker is determined to be substantially equivalent to existing legally marketed devices.

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## DEPARTMENT OF HEALTH & HUMAN SERVICES

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#### Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

Augmenix, Incorporated % Mr. Eric Ankerud Executive Vice President, Clinical, Regulatory, Quality 204 Second Avenue, Lower Level Waltham, Massachusetts 02451

Re: K121964

Trade/Device Name: TraceIt Tissue Marker Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: Class II Product Code: NEU Dated: November 19, 2012 Received: November 20, 2012

January 23, 2013

Dear Mr. Ankerud:

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 for association 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it your device is exactive al 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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Page 2 – Mr. Eric Ankerud

forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic forth in the quand provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 11 you dosite specific ad risboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part note the regulation entined, the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the I ou may ocain other geticational and Consumer Assistance at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

# Peter D. Rumm -S

Mark N. Melkerson Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Augmenix, Inc. Supplement 001 to K121964 Tracelt Tissue Marker

INDICATION FOR USE STATEMENT SECTION 4.0:

K121964 510(k) Number:

Indication For Use: TraceIT Tissue Marker is indicated for use to radiographically mark soft maleation of OSC. Trucer - noced wfor future surgical procedures. TracelT hydrogel is intended to mark tissue for at least 3 months after injection.

× Prescription Use _ (Part 21 CFR 801 SubpartD)

AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

# (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

# David Krause

(Division Sign-Off) Division of Surgical Devices 510(k) Number: K121964