HydroMARK Breast Biopsy Site Marker

K161021 · Devicor Medical Products, Inc. · NEU · May 5, 2016 · General, Plastic Surgery

Device Facts

• Record ID: K161021
• Device Name: HydroMARK Breast Biopsy Site Marker
• Applicant: Devicor Medical Products, Inc.
• Product Code: NEU · General, Plastic Surgery
• Decision Date: May 5, 2016
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 878.4300
• Device Class: Class 2

Intended Use

The HydroMARK® Breast Biopsy Site Marker is intended to mark tissue during a percutaneous breast biopsy procedure, to be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI.

Device Story

HydroMARK is an implantable breast biopsy site marker. It consists of a reabsorbable hydrogel component and a metallic (titanium or stainless steel) coil. The device is pre-loaded in a sterile, disposable rigid applicator. During a percutaneous breast biopsy, the clinician deploys the marker into the biopsy track. Upon contact with fluid, the hydrophilic hydrogel expands to fill the track, anchoring the marker at the biopsy site and providing temporary ultrasound visibility. Over time, the hydrogel degrades via hydrolysis, leaving the metallic coil for permanent x-ray and MRI visualization. The device is used in clinical settings by physicians. It aids in long-term localization of the biopsy site for follow-up imaging or surgical planning, benefiting patients by ensuring accurate identification of the biopsied area.

Clinical Evidence

Bench testing only. Performance was validated through visual and dimensional testing, deployment testing, and usability testing for insertion and deployment. Biocompatibility was confirmed per ISO 10993-1 requirements.

Technological Characteristics

Implantable marker with polymerized/desiccated hydrogel and titanium or stainless steel coil. Delivery system uses a rigid cannula (304 stainless steel) and rigid plunger rod (302 stainless steel). Hydrogel expands via fluid contact; degrades via hydrolysis. Sterilization via ETO. Packaging includes foil pouch with Tyvek® vent. No software or electronic components.

Indications for Use

Indicated for marking tissue during percutaneous breast biopsy procedures; provides ultrasound visibility for at least 6 weeks and permanent visibility via x-ray and MRI.

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

• Biopsy Sciences HydroMark Breast Biopsy Site Marker (K121113)
• Biopsy Sciences HydroMark Breast Biopsy Site Marker (K130537)

Submission Summary (Full Text)

{0}------------------------------------------------

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract image of three faces in profile, stacked on top of each other, resembling a stylized human figure.

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

May 5, 2016

Devicor Medical Products, Inc. Ms. Shawna Rose Director, Regulatory Affairs 300 E-Business Way, Fifth Floor Cincinnati, Ohio 45241

Re: K161021

Trade/Device Name: HydroMARK Breast Biopsy Site Marker Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: Class II Product Code: NEU Dated: April 8, 2016 Received: April 12, 2016

Dear Ms. Rose:

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. 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 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); medical device reporting (reporting of medical

{1}------------------------------------------------

device-related adverse events) (21 CFR 803); 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding 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 Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

# David Krause -S

- Binita S. Ashar, M.D., M.B.A., F.A.C.S. for Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure

{2}------------------------------------------------

# Indications for Use

510(k) Number (if known) K161021

Device Name HydroMARK® Breast Biopsy Site Marker

Indications for Use (Describe)

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.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

#### CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff [e-mail]

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

# 510(K) SUMMARY (21 CFR 807.92)

## HYDROMARK® BREAST BIOPSY SITE MARKER

- 510(k) Owner: Devicor Medical Products, Inc. 300 E-Business Way, Fifth Floor Cincinnati, Ohio 45241 Tel: [phone] Fax: [phone]
- Contact Person: Shawna Rose Tel: [phone] E-mail: [e-mail]

Date Prepared: April 8, 2016

HydroMARK® Breast Biopsy Site Marker Trade Name:

Common Name: Biopsy Site Marker

Classification: Class II

Implantable clip per 21 CFR 878.4300, NEU Classification Name:

- Predicate Devices: Biopsy Sciences HydroMark Breast Biopsy Site Marker, K121113 Biopsy Sciences HydroMark Breast Biopsy Site Marker, K130537
- 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

{4}------------------------------------------------

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.

- The indications for use and the intended use are the same for the predicate Intended Use: and the modified devices.
The indications for use are:

"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."

The intended use is:

"The HydroMARK® Breast Biopsy Site Marker is intended to mark tissue during a percutaneous breast biopsy procedure, to be visible under ultrasound for at least 6 weeks, and be permanently visible by x-ray and MRI."

Technological

- Characteristics: The hydrogel component expands on fluid contact to fill the track of the biopsy needle anchoring the marker at the exact location of biopsy.

{5}------------------------------------------------

Because the hydrogel is hydrophilic, it is clearly distinct from normal breast structure under ultrasound imaging. The hydrogel material degrades via hydrolysis over time leaving the internal stainless steel or titanium coil which provides permanent visibility under x-ray and MRI.

The modifications to the HydroMARK® Breast Biopsy Site Markers delivery system for the two models, the device compatibility testing, and the associated IFU and label changes represent minor updates to the products. The changes do not raise new questions of safety or efficacy. The technological characteristics are identical to those of the predicate devices.

Non-Clinical Performance Data: Non-clinical testing included the following:

- Visual and Dimensional Testing
- Deployment Testing
- Usability testing for ease of insertion and deployment ●

The devices performed as intended according to the specifications established for the finished device. The device continues to meet the ISO 10993-1 requirements for biocompatibility.

### Summary of

Substantial Equivalence:

Side-by-Side Comparison to Legally Marketed Device

HydroMARK® Breast Biopsy Site Marker

| Device<br>Characteristics | Marketed Device HydroMARK®<br>Breast Biopsy Site Marker | Modified Device HydroMARK®<br>Breast Biopsy Site Marker |
|------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | To mark tissue during a<br>percutaneous breast biopsy<br>procedure, be visible under<br>ultrasound for at least 6 weeks,<br>and be permanently visible by x-<br>ray and MRI. | To mark tissue during a<br>percutaneous breast biopsy<br>procedure, be visible under<br>ultrasound for at least 6 weeks,<br>and be permanently visible by x-<br>ray and MRI. |
| Device Composition | | |
| Marker Composition | Polymerized and desiccated<br>hydrogel | Polymerized and desiccated<br>hydrogel |
| Coil (Marker)<br>Composition | Titanium or Stainless Steel | Titanium or Stainless Steel |
| Coil (Marker) Shapes | Barrel (T1)<br>Open Coil (T3) | Barrel (T1)<br>Open Coil (T3) |

{6}------------------------------------------------

| Device<br>Characteristics | Marketed Device HydroMARK®<br>Breast Biopsy Site Marker | Modified Device HydroMARK®<br>Breast Biopsy Site Marker |
|-----------------------------|---------------------------------------------------------|---------------------------------------------------------|
| Cannula Type | Rigid Cannula | Rigid Cannula |
| Cannula Material | 304 Stainless Steel | 304 Stainless Steel |
| Plunger Rod Type | Rigid Plunger Rod | Rigid Plunger Rod |
| Plunger Rod Material | 302 Stainless Steel | 302 Stainless Steel |
| Plunger Rod Tip | Welded Flexible Tip | Welded Spring |
| Packaging and Sterilization | | |
| Sterile Packaging | Foil pouch with Tyvek® vent | Foil pouch with Tyvek® vent |
| Sterilization Method | ETO | ETO |
| Shelf Life | 3 years/36 months | 3 years/36 months |

- The comparison testing, including functionality, usability testing, as well as Conclusions: side-by-side comparison of technological characteristics of design, components and materials of construction, and clinical application, demonstrates that the two modified models of the HydroMARK® Breast Biopsy Site Markers perform as intended, accurately marking the biopsy site in the cavity of the breast biopsy. The two modified devices work in an identical manner to previously cleared HydroMARK® Breast Biopsy Site Markers. Thus, the two modified devices can be considered substantially equivalent.