Anchored Beacon(R) transponder, Anchored transponder, Beacon Care Package - Lung
K170570 · Varian Medical Systems, Inc. · IYE · Apr 6, 2018 · Radiology
Device Facts
Record ID
K170570
Device Name
Anchored Beacon(R) transponder, Anchored transponder, Beacon Care Package - Lung
Applicant
Varian Medical Systems, Inc.
Product Code
IYE · Radiology
Decision Date
Apr 6, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.5050
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K170570 · Apr 6, 2018
Anchored Beacon(R) transponder, Anchored transponder, Beacon Care Package - Lung
Varian Medical Systems, Inc.
Clinical study cohort of lung cancer patients; Matched cohort of patients with commercially-available fiducial markers
Clinical data were used to demonstrate the device's ability to be localized for patient monitoring, positional stability in the airway, and safety as a permanent implant. A matched cohort analysis was used to compare stability against existing commercial markers.
Subset of study patients with anchored transponders
Matched cohort of patients with commercially-available fiducial markers (including superlock Cobra)
Stability over time
Indications for Use
The Calypso System is intended for use as an adjunct in treatment planning and radiation therapy, to align and/or monitor the patient's position relative to the isocenter of a radiation therapy system. The Calypso System provides accurate, precise, and continuous localization of a treatment isocenter by using two or more Beacon transponders. Anchored Beacon transponders are indicated for permanent implantation in small airways in the lung to align and/or monitor the internal position of targets that move with respiratory and other patient motion in real time during radiation therapy.
Device Story
Anchored Beacon transponder is a passive implant for permanent placement in lung airways; consists of glass-encapsulated electrical circuit (Beacon transponder) coupled to self-expanding 5-legged nitinol stability feature. Delivered via single-use catheter during bronchoscopy. Used with Calypso System to provide real-time, 4D localization of treatment targets during radiation therapy. System operator (physician/technician) uses transponder signals to align patient to linear accelerator isocenter and monitor target position during treatment. Enables precise radiation delivery by accounting for respiratory motion; benefits patient through improved target localization accuracy.
Clinical Evidence
Clinical study in 69 lung cancer patients undergoing radiation therapy demonstrated transponder localization capability, positional stability in the airway, and safety as a permanent implant. Long-term follow-up in a subset compared to a matched cohort with commercially available fiducial markers (including superlock Cobra) showed equivalent stability. Radiographic analysis of a separate cohort showed no association between transponders and pulmonary abnormalities. Safety profile consistent across cohorts.
Technological Characteristics
Passive implant; glass-encapsulated electrical circuit; self-expanding 5-legged nitinol stabilization feature (approx. 5 mm unconstrained diameter). Provided sterile via radiation sterilization. Single-use. Designed for bronchoscopic delivery via catheter.
Indications for Use
Indicated for permanent implantation in small airways in the lung for patients undergoing radiation therapy to align and/or monitor internal targets moving with respiratory or other patient motion in real time.
Regulatory Classification
Identification
A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.
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April 6, 2018
Varian Medical Systems, Inc. % Lisa Levine, Ph.D. Director, Clinical and Pre-Market Regulatory Affairs 3100 Hansen Way PALO ALTO CA 94304
Re: K170570
Trade/Device Name: Anchored Beacon® Transponder Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: IYE Dated: March 21, 2018 Received: March 23, 2018
Dear Dr. Levine:
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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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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Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael D. O'Hara For
Robert Ochs. Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K170570
Device Name
Anchored Beacon® transponder, Anchored transponder, Beacon Care Package - Lung
Indications for Use (Describe)
The Calypso System is intended for use as an adjunct in treatment planning and radiation therapy, to align and/or monitor the patient's position relative to the isocenter of a radiation therapy system. The Calypso System provides accurate, precise, and continuous localization of a treatment isocenter by using two or more Beacon transponders.
Anchored Beacon transponders are indicated for permanent implantation in small airways in the lung to align and/or monitor the internal position of targets that move with respiratory and other patient motion in real time during radiation therapy.
Type of Use (Select one or both, as applicable)
| <input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) | <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# varian
| 510(k) Summary | |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter's name: | Varian Medical Systems Inc 3100 Hansen Way Palo Alto, CA 94304 USA |
| Contact person: | Lisa Levine, PhD Director, Clinical and Pre-Market Regulatory Affairs Phone: 206-254-0600 Fax: 206-254-0606 |
| Date summary prepared: | March 21, 2018 |
| Trade name(s): | Anchored Beacon® transponder Anchored transponder Beacon® Care Package - Lung |
| Common name: | Fiducial marker |
| Classification name: | Medical charged-particle radiation therapy system |
| Classification number: | CFR 892.5050 |
| Class: | Class II |
| Product code: | IYE |
| Predicate: | Permanent Beacon transponder (K140823) |
## Device description:
The Anchored Beacon® transponder is a small passive implant, intended for permanent implantation in small airways in the lung. It is provided pre-loaded in a single-use delivery catheter for bronchoscopic implantation in a lung airway.
The Anchored Transponder is comprised of a Permanent Beacon Transponder (glassencapsulated electrical circuit) coupled to a stability feature (self-expanding 5-legged structure in a shell assembly). When implanted in a small diameter airway, the anchor legs of the stability feature expand independently to contact the airway wall.
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When used with the Calypso® System, the Anchored Transponder signals enable realtime, objective measurement of the location of the treatment target in four dimensions. The system operator uses this information to align the patient's treatment target to the isocenter of the linear accelerator prior to radiation therapy and/or to monitor the position of the treatment target during treatment.
### Intended use/Indications for use:
The Calypso System is intended for use as an adjunct in treatment planning and radiation therapy, to align and/or monitor the patient's position relative to the isocenter of a radiation therapy system. The Calypso System provides accurate, and continuous localization of a treatment isocenter by using two or more Beacon transponders.
Anchored Beacon transponders are indicated for permanent implantation in small airways in the lung to align and/or monitor the internal position of targets that move with respiratory and other patient motion in real time during radiation therapy.
### Predicate discussion:
This 510(k) notification is for a new Beacon transponder called the Anchored Beacon transponder, designed to be permanently implanted in the lung. The selected predicates are the following fiducial markers: the Soft Tissue Transponder 14G (K140823) and the superlock cobra marker (K120796). A comparison of the similarities and differences of the intended use/indications for use, technology, and other characteristics between the new device and the predicates is shown in the table below and discussed in the text following the table.
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| | New Device: | Predicate #1: | Predicate #2: |
|-----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Item | Anchored Beacon | Soft Tissue transponder | superlock cobra marker |
| | transponder | (K140823) | (K120796) |
| Intended<br>use/indications for use | The Calypso System is<br>intended for use as an<br>adjunct in treatment<br>planning and radiation<br>therapy, to align and/or<br>monitor the patient's<br>position relative to the<br>isocenter of a radiation<br>therapy system. The<br>Calypso System provides<br>accurate, precise, and<br>continuous localization of<br>a treatment isocenter by<br>using two or more Beacon<br>transponders. | The Calypso System is<br>intended for use as an<br>adjunct in treatment<br>planning and radiation<br>therapy, to align and/or<br>monitor the patient's<br>position relative to the<br>isocenter of a radiation<br>therapy system. The<br>Calypso System provides<br>accurate, precise, and<br>continuous localization of<br>a treatment isocenter by<br>using two or more Beacon<br>transponders. | The superDimension<br>superLock Cobra is<br>intended to be used to<br>radiographically mark soft<br>tissue for future surgical or<br>therapeutic purposes. |
| | Anchored Beacon<br>transponders are indicated<br>for permanent<br>implantation in small<br>airways in the lung to<br>align and/or monitor the<br>internal position of targets<br>that move with respiratory<br>and other patient motion in<br>real time during radiation<br>therapy. | Implanted Beacon<br>transponders are indicated<br>for use to radiographically<br>and electromagnetically<br>mark soft tissue for future<br>therapeutic procedures.<br><br>Permanent Beacon<br>transponders are indicated<br>for implantation in the<br>body, specifically in the<br>prostate and peri-prostatic<br>tissue (i.e., prostatic bed),<br>and in soft tissue to align<br>and monitor the treatment<br>isocenter in real time<br>during radiation therapy | |
| Item | New Device:<br>Anchored Beacon<br>transponder | Predicate #1:<br>Soft Tissue transponder<br>(K140823) | Predicate #2:<br>superlock cobra marker<br>(K120796) |
| Technology<br>(design and<br>materials) | The anchored transponder<br>is constructed by adding a<br>self-expanding nitinol<br>stabilization feature to<br>Predicate #1. The<br>unconstrained diameter of<br>the nitinol stabilization<br>feature is approximately 5<br>mm. | Cylinder consisting of<br>small electrical circuit<br>encased in biocompatible<br>glass.<br>No stabilization feature. | Gold cylinder with self-<br>expanding nitinol<br>stabilization feature. The<br>unconstrained diameter of<br>the nitinol stabilization<br>feature is 4.1 mm. |
| Permanent<br>implant | Yes | Yes | Yes |
| Sterility | Provided sterile (radiation<br>sterilized). | Provided sterile (radiation<br>sterilized). | Provided sterile (radiation<br>sterilized). |
| Single use | Yes | Yes | Yes |
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The new device and the two predicates are intended to be used as fiducial markers. The Anchored transponder is intended for implantation in small airways in the lung, while the predicates are intended for implantation in soft tissue, and additionally in the prostate/prostatic bed for Predicate #2.
The Anchored transponder is constructed by adding a self-expanding nitinol stabilization feature to Predicate #1, so both the new transponder and Predicate #1 have this predicate in common. The Anchored transponder and Predicate #2 both have a cylindrical body with an attached self-expanding nitinol stabilization feature. The stabilization features prevent migration based on the same principle: the stabilization features expand against the surrounding tissue and hold the fiducial marker in place. The unconstrained diameters of the two stabilization features are similar.
The new device and the two predicates are permanent implants, provided radiation sterilized for single use.
Bench testing was performed and demonstrated: (1) the Anchored transponder satisfied the established performance requirements, including related to use in the lung; (2) biocompatibility testing in conformance with ISO 10993 supports safety of the Anchored transponder materials and the delivery catheter materials; and (3) the packaging provides protection and a sterile barrier.
Clinical study data obtained in lung cancer patients undergoing radiation therapy (69patient cohort) showed the Anchored transponders can be localized to monitor patient
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position, that the Anchored transponder is positionally stable in the airway, and that the Anchored transponder is safe as a permanent implant in the lung.
A long-term follow-up analysis comparing the stability of the anchored transponders in a subset of study patients to a matched cohort of patients with commercially-available fiducial markers implanted in lung (including the predicate, the superlock Cobra) showed equivalence of stability over time.
An analysis was performed of the long term radiographic changes in a separate cohort of patients treated with implanted anchored transponders who had undergone thoracic radiotherapy. The analysis shows that the presence of the transponders is unassociated with radiographic pulmonary abnormalities attributable to the transponder. Analysis of the clinical safety of the device in this expanded cohort confirms the safety profile is consistent with the original study patient data.
The clinical data show that the Anchored transponders can be localized to monitor patient position, that the Anchored transponder is positionally stable in the airway, and that the Anchored transponder is safe as a permanent implant in the lung.
Overall, the bench, biocompatibility, and clinical testing have demonstrated the Anchored transponder to be safe and effective for use in the lung.
After comparing the devices and considering the bench, biocompatibility, and clinical data, no new questions of safety and effectiveness are raised.
Thus, the new device is shown to be substantially equivalent to the predicates.