GammaTile

K190839 · Gt Medical Technologies · KXK · Jan 23, 2020 · Radiology

Device Facts

• Record ID: K190839
• Device Name: GammaTile
• Applicant: Gt Medical Technologies
• Product Code: KXK · Radiology
• Decision Date: Jan 23, 2020
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 892.5730
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

GammaTile is indicated as a treatments with newly diagnosed malignant intracranial neoplasms and patients with recurrent intracranial neoplasms

Device Story

GammaTile is a brachytherapy device consisting of Cesium-131 radioactive sources embedded in a collagen matrix. It is used by neurosurgeons during surgical resection of brain neoplasms. The device is placed directly into the resection cavity immediately following tumor excision. It provides adjuvant radiation therapy to eliminate residual neoplastic cells in the cavity proximity. The device is intended for both newly diagnosed malignant and recurrent intracranial neoplasms. By delivering localized radiation, it aims to treat remaining tumor cells while sparing surrounding healthy tissue.

Clinical Evidence

No new clinical trials were conducted. The manufacturer relied on an assessment of dosimetry to organs at risk and case study data to support the expanded indication. The assessment concluded that the cumulative radiation dose delivered to organs at risk is within ranges acceptable in clinical practice and that the therapy adds no additional risk to the expanded patient population.

Technological Characteristics

Radionuclide brachytherapy source; Cesium-131 radioactive sources; collagen matrix carrier; Class II; Product Code KXK; Regulation 892.5730. Identical to predicate K190296.

Indications for Use

Indicated for patients with newly diagnosed malignant intracranial neoplasms and patients with recurrent intracranial neoplasms requiring surgical resection.

Regulatory Classification

Identification

A radionuclide brachytherapy source is a device that consists of a radionuclide which may be enclosed in a sealed container made of gold, titanium, stainless steel, or platinum and intended for medical purposes to be placed onto a body surface or into a body cavity or tissue as a source of nuclear radiation for therapy.

Special Controls

*Classification.* Class II (special controls). A prostate seeding kit intended for use with a radionuclide brachytherapy source only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

Predicate Devices

• GammaTile (K190296)

Submission Summary (Full Text)

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January 23, 2020

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left side of the logo is the Department of Health & Human Services logo. To the right of that is the FDA logo, with the letters FDA in a blue box, followed by the words "U.S. FOOD & DRUG" in large blue letters, and the word "ADMINISTRATION" in smaller blue letters below.

GT Medical Technologies % Ms. Jessica Newhard Regulatory Affairs Specialist 1809 S Holbrook Lane, Suite 107 TEMPE AZ 85281

Re: K190839

Trade/Device Name: GammaTile™ Regulation Number: 21 CFR 892.5730 Regulation Name: Radionuclide brachytherapy source Regulatory Class: Class II Product Code: KXK Dated: December 20, 2019 Received: December 23, 2019

Dear Ms. Newhard:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmp/pmn.cfm identifies combination product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see

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https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

For

Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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## Indications for Use

510(k) Number (if known) K190839

Device Name GammaTile™

Indications for Use (Describe)

GammaTile is indicated as a treatments with newly diagnosed malignant intracranial neoplasms and patients with recurrent intracranial neoplasms

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)

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## 510(k) Summary III.

| Submitter | GT Medical Corporation |
|---------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Address | 1809 S Holbrook Drive<br>Suite 107<br>Tempe, AZ 85281 |
| Telephone Number | 480-276-8609 |
| Contact Person | Jessica Newhard<br>Regulatory Affairs Specialist<br>[e-mail] |
| Date of Preparation | December 20, 2019 |
| Device Trade Name | GammaTile™ |
| Device Common Name | Radionuclide Brachytherapy Seeds |
| Device Classification Name | Radionuclide Brachytherapy Source (per<br>21CFR §892.5730) |
| Device Regulation Number | 892.5730 |
| Product Code | KXK |
| Predicate Device(s) | Predicate: GammaTile that is the subject of<br>this submission is substantially equivalent to<br>GammaTile as described in 510(k) K190296. |
| Predicate Product Code | KXK |
| Predicate Regulation Number | 892.5730 |
| Product Description | GammaTile is a device intended for the<br>treatment of intracranial neoplasms which uses<br>cesium-131 radioactive sources embedded in a<br>collagen matrix. GammaTile™ is designed to<br>provide "adjuvant" radiation therapy - therapy<br>to eliminate any remaining neoplastic cells - to<br>patients who require surgical resection of brain<br>neoplasms.<br>GammaTile is positioned within the resection<br>cavity immediately after surgical excision of<br>the brain neoplasm to deliver radiation therapy<br>to any neoplastic cells that remain in proximity<br>of the resection cavity. |
| Indication for Use statement compared to<br>currently marketed predicate device | The Indication for Use is being revised to<br>include initial treatment of intracranial<br>neoplasms.<br>The currently marketed indication for use is:<br>"GammaTile is intended to deliver radiation<br>therapy (brachytherapy) in patients with<br>recurrent intracranial neoplasms”<br>The proposed indication for use statement is:<br>"GammaTile is indicated as a treatment for |
| | patients with newly diagnosed malignant<br>intracranial neoplasms and patients with<br>recurrent intracranial neoplasms” |
| Patient Population | This premarket submission expands the patient<br>population from patients requiring radiation<br>therapy after excision for recurrent intracranial<br>neoplasms to include patients requiring<br>radiation therapy after<br>excision of newly diagnosed malignant<br>intracranial neoplasms. |
| Statement of Technological Characteristics | The technological characteristics of the<br>proposed device, GammaTile, are identical to<br>those of the predicate, GammaTile as<br>described in 510(k) K190296 |
| Assessment of Non-clinical Performance Data | No changes have been made to the<br>technological characteristics of the proposed<br>device since clearance of the primary predicate<br>device (K190296). The indication expansion<br>proposed does not change the anatomical site<br>of the indication but expands the target<br>population to include newly diagnosed patients<br>with malignant intracranial neoplasms. An<br>assessment of dosimetry to organs at risk using<br>GammaTile in recurrent intracranial<br>neoplasms has been completed. The<br>assessment resulted in a determination the<br>cumulative radiation dose delivered to the<br>OARs was within ranges acceptable in clinical<br>practice. |
| Conclusion Drawn from Testing | No additional testing was completed. The data<br>obtained from the case studies suggest that<br>GammaTile therapy adds no additional risk to<br>the proposed patient population. |
| Safety and Effectiveness | To ensure that the devices are safe and effective, all finished products must meet all |
| | acceptance criteria required by the product specification before distribution. The required testing is defined in documented procedures that conform to the product design specifications. |

Table 1. Tabular Summary of 510 (k)

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