(35 days)
The Bard CruraSoft Patch is indicated for use in the reconstruction of soft tissue deficiencies, such as for the repair of chest wall defects and hernias, including diaphragmatic/hiatal hernias.
The proposed device is heart shaped and has a porous polytetrafluoroethylene (PTFE) side and an expanded polytetrafluoroethylene (ePTFE) side that are connected to each other on the edge with an interlocking monofilament PTFE stitch. There is also a row of stitching that is in a "V" shape which allows the device to be tailored. The prosthesis may be trimmed to the outside of the "V" stitching. The "V" stitching will continue to keep the two layers of the device together if it is tailored. An ePTFE flap is sewn to the superior edge of the patch to minimize the possibility of the device adhering to undesired structures, such as the esophagus. The proposed device is preshaped and presized to offer maximum ready-to-use benefits.
The provided text describes the Bard CruraSoft Patch, a surgical mesh, and its 510(k) summary for regulatory clearance. It focuses on device description, intended use, and similarities/differences with predicate devices. The "Performance Data" section briefly mentions bench testing but does not provide detailed acceptance criteria or a study proving that the device meets those criteria.
Therefore, many of the requested details cannot be extracted from this document, as they are not present. This document is a regulatory submission summary, not a detailed scientific study report.
Here is what can be inferred or stated based on the provided text, and what cannot:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not specified in document | "Laboratory test results demonstrate that the materials chosen and the design utilized in manufacturing the Bard CruraSoft Patch will meet the established specifications necessary for consistent performance during their intended use..." |
Missing Information: The document states that performance data from bench testing "supports the safety and effectiveness" and that the device "will meet the established specifications." However, it does not list what those established specifications (acceptance criteria) are, nor does it provide specific quantitative results of the bench testing.
2. Sample size used for the test set and the data provenance:
- Sample size: Not specified.
- Data provenance: Not specified (presumably internal laboratory testing, but no country of origin or retrospective/prospective nature is mentioned).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as no clinical study or human reader assessment is described.
4. Adjudication method for the test set:
- Not applicable as no clinical study or human reader assessment is described.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No MRMC study was done. This device is a surgical patch, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is a physical medical device, not an algorithm/AI.
7. The type of ground truth used:
- For the bench testing mentioned, the "ground truth" would be established engineering specifications and material science standards for the physical properties and performance of the patch (e.g., tensile strength, biocompatibility, porosity, attachment integrity). The document confirms that "laboratory test results demonstrate that the materials chosen and the design utilized... will meet the established specifications."
8. The sample size for the training set:
- Not applicable. This is a physical medical device, not a machine learning model requiring a training set.
9. How the ground truth for the training set was established:
- Not applicable.
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AUG 2 3 2002
510(K) SUMMARY OF SAFETY AND EFFECTIVENESS FOR THE BARD CRURASOFT PATCH
A. Submitter Information
Davol, Inc. Submitter's Name: Subsidiary of C. R. Bard, Inc. Address: 100 Sockanossett Crossroad Cranston, RI 02920 401-463-7000 ext. 2642 Telephone: Fax: 401-463-3845 Contact Person: Brian A. Kanerviko Date of Preparation: July 18, 2002
B. Device Name
Bard CruraSoft Patch
C. Predicate Device Name
Bard Composix E/X mesh, PTFE mesh, Gore Trade name: SEAMGUARD Staple Line Reinforcement Material
D. Device Description
The proposed device is heart shaped and has a porous polytetrafluoroethylene (PTFE) side and an expanded polytetrafluoroethylene (ePTFE) side that are connected to each other on the edge with an interlocking monofilament PTFE stitch. There is also a row of stitching that is in a "V" shape which allows the device to be tailored. The prosthesis may be trimmed to the outside of the "V" stitching. The "V" stitching will continue to keep the two layers of the device together if it is tailored. An ePTFE flap is sewn to the superior edge of the patch to minimize the possibility of the device adhering to undesired structures, such as the esophagus. The proposed device is preshaped and presized to offer maximum ready-to-use benefits.
E. Intended Use
The Bard CruraSoft Patch is indicated for use in the reconstruction of soft tissue deficiencies, such as for the repair of chest wall defects and hernias. including diaphragmatic/hiatal hernias.
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F. Summary of Similarities and Differences in Technological Characteristics, Performance and Intended Use
The proposed and predicate devices are similar in that all three devices are surgical implants. One of the predicates is comprised entirely of PTFE, while the other is a combination of polypropylene and ePTFE. The proposed product is taking the existing PTFE from the predicate preamendment device and attaching it to the same ePTFE as used in predicate Composix E/X. The PTFE monofilament thread used to attach the ePTFE to PTFE is the same as the thread used in predicate Composix E/X.
The difference between the proposed and predicate devices includes the shape and the attachment of PTFE to ePTFE. The proposed device is heart shaped with ePTFE on one side and PTFE on the other. An ePTFE flap is sewn to the superior edge of the PTFE side of the device with an interlocking monofilament PTFE stitch. The ePTFE runs slightly over the top corners of the PTFE side of the device. The device is sewn together using an interlocking monofilament PTFE stitch.
The Gore SEAMGUARD Staple Line Reinforcement Material (K001789) indication includes the repair of hernias, including diaphragmatic hernias. This indication is the same as the proposed device indication statement.
The proposed device is indicated for use in the reconstruction of soft tissue deficiencies, such as for the repair of chest wall defects and hernias. including diaphragmatic/hiatal hernias. The predicate Composix E/X and the proposed device are both intended for use to reinforce soft tissues where weakness exists. Both devices give examples of chest wall defects and hernias.
The predicate PTFE mesh is indicated for use primarily in the repair of hernias and defects resulting from the surgical wounds of extensive cancer resections. The proposed device indication for use does not include the repair of defects strictly caused from surgical wounds of extensive cancer resections. Instead, it focuses on the repair of hernias and defects. The proposed device and predicate PTFE mesh share this in their indication for use.
G. Performance Data
Bench testing has been completed and supports the safety and effectiveness of the Bard CruraSoft Patch for its intended use.
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Laboratory test results demonstrate that the materials chosen and the design utilized in manufacturing the Bard CruraSoft Patch will meet the established specifications necessary for consistent performance during their intended use and support substantial equivalence to the predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/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 text "DEPARTMENT OF HEALTH & HUMAN SERVICES · USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing right, with three horizontal bars above them.
Food and Drug Administration
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
AUG 2 3 2002
Brian A. Kanerviko Regulatory and Clinical Affairs Associate Davol, Inc. 100 Sockanossett Crossroad P. O. Box 8500 Cranston, Rhode Island 02920
Re: K022350
Trade/Device Name: Bard Crurasoft Patch Regulation Number: 878.3300 Regulation Name: Surgical Mesh Regulatory Class: Class II Product Code: FTL Dated: July 11, 2002 Received: July 19, 2002
Dear Mr. Kanerviko:
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 such 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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Page 2 - Mr. Brian A. Kanerviko
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 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. 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" (21 CFR Part 807.97). 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,
Mark H. Milken
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known):
Device Name: Bard CruraSoft Patch
Indications for Use:
The Bard CruraSoft Patch is indicated for use in the reconstruction of soft tissue deficiencies, such as for the repair of chest wall defects and hernias, including diaphragmatic/hiatal hernias.
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Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109)
OR
Over-the Counter Use __
§ 878.3300 Surgical mesh.
(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.