Shoulder: Rotator Cuff Repair, Bankart Repair, SLAP Lesion Repair, Biceps Tenodesis, Acromio-Clavicular Scparation Repair, Deltoid Repair, Capsular Shift or Capsulolabral Reconstruction

Foot/Ankle: Lateral Stabilization, Medial Stabilization, Achilles Tendon Revair, Hallux Valgus Reconstruction, Mid-Foot Reconstruction, Metatarsal Ligament Repair, Flexor Hallucis Longus for Achilles Tendon Reconstruction, Tendon Transfer in the Foot and Ankle

Knee: Medial Collateral Ligament Repair, Lateral Collateral Ligament Repair, Patellar Tendon Repair, Posterior Oblique Ligament Repair, Iliotibial Band Tenodesis

Elbow: Biceps Tendon Reattachment, Tennis Elbow Repair, Ulnar or Radial Collateral Ligament Reconstruction

Hand/Wrist: Scapholunate Ligament Reconstruction, Ulnar Collateral Ligament Reconstruction, Radial Collateral Ligament Reconstruction, Carpal Ligament Reconstruction and Repair, Tendon Transfer in the Hand/Wrist

Device Description

The PRO Fixation™ System is a sterile single use device intended for the reattachment of soft tissue to bone. The PRO Fixation System is comprised of an implantable non-absorbable anchor and a disposable inserter. The anchor allows for placement, suture tensioning, and fixation of soft tissue into bone. Anchors will be available in a range of sizes.

AI/ML Overview

This submission is for a traditional 510(k) for the PRO Fixation™ System, a sterile single-use device intended for the reattachment of soft tissue to bone. Since this is a traditional 510(k), there is no AI/ML algorithm involved, therefore, questions regarding AI/ML studies are not applicable.

1. A table of acceptance criteria and the reported device performance

Test	Acceptance Criteria	Reported Device Performance
Biocompatibility	Equivalent biocompatibility profile to predicate devices.	Biocompatibility results indicate that the device biocompatibility profile is equivalent to the predicate devices.
Pull-out Strength	Meet mechanical performance requirements for intended use and be comparable to predicate devices.	All test results demonstrated that the performance of PRO Fixation™ System is equivalent to the predicate devices. Specific values not provided in this summary.
Suture Integrity/Tensile Strength (following anchor insertion)	Meet mechanical performance requirements for intended use and be comparable to predicate devices.	All test results demonstrated that the performance of PRO Fixation™ System is equivalent to the predicate devices. Specific values not provided in this summary.
Suture Slip Resistance	Meet mechanical performance requirements for intended use and be comparable to predicate devices.	All test results demonstrated that the performance of PRO Fixation™ System is equivalent to the predicate devices. Specific values not provided in this summary.
Anchor and Driver Integrity	Meet mechanical performance requirements for intended use and be comparable to predicate devices.	All test results demonstrated that the performance of PRO Fixation™ System is equivalent to the predicate devices. Specific values not provided in this summary.

2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

The submission does not specify the exact sample sizes used for the laboratory testing. The data provenance is laboratory testing focused on mechanical and biocompatibility properties of the device itself, rather than human or animal study data. Therefore, country of origin and retrospective/prospective designations are not applicable in the typical sense.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)

Not applicable. Ground truth in this context typically refers to clinical or image-based diagnoses. This submission is for a mechanical medical device, and the "ground truth" for its performance is established through objective laboratory testing against established engineering and material science standards and comparison to predicate devices, not expert consensus on medical conditions.

4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

Not applicable. Adjudication methods are typically used in clinical studies involving interpretation (e.g., by experts) where there might be disagreement. This submission involves laboratory testing with quantifiable results.

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

Not applicable. This is a traditional 510(k) for a medical implant (suture anchor system), not an AI/ML powered device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Not applicable. This is a traditional 510(k) for a medical implant (suture anchor system), not an AI/ML powered device.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The "ground truth" for the device's performance is based on established engineering and material science standards relevant to medical devices, as well as the performance characteristics of
legally marketed predicate devices. This includes:

Biocompatibility Standards: Evaluating the device's interaction with biological systems according to recognized standards.
Mechanical Performance Standards: Quantifiable metrics for pull-out strength, suture integrity/tensile strength, suture slip resistance, and anchor and driver integrity.
Predicate Device Comparison: Establishing equivalence to existing, legally marketed devices with a known safety and efficacy profile.

8. The sample size for the training set

Not applicable. This is a traditional 510(k) for a medical implant; there is no "training set" in the context of AI/ML or image processing.

9. How the ground truth for the training set was established

Not applicable. This is a traditional 510(k) for a medical implant; there is no "training set" or corresponding ground truth establishment in this context.

Summary

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JUL 1 2 2011

510(K) SUMMARY

l Submitter Information

A.	Company Name:	Synovis Orthopedic and Woundcare, Inc
B.	Company Address:	6 Jenner, Suite 150Irvine, CA 92618
C.	Company Phone:	(949) 502-3240
D.	Company Facsimile:	(949) 502-3241
E.	Contact Person:	Amy BouclyManager, Regulatory Affairs
Device Identification

A. Device Trade Name:	PRO Fixation™ System
-----------------------	----------------------

B. Common Name: Suture Anchor
ੁੱ Classification Name(s): Screw, Fixation, Bone
Classification Regulation: 888.3040 D.
E. Device Class: Class II
HWC, MBI ان . Device Code(s):
ੁ. Advisory Panel: Orthopedic

Identification of Predicate Devices ﺪ ﺍﻟﻤﺪﻳﻨﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤ

The PRO Fixation™ System is substantially equivalent to the following devices, which are cleared for commercial distribution in the United States:

· PushLock™, Arthrex, Inc., K051219
· Arthrex Tenodesis Family, Arthrex, Inc, K051726
· Corkscrew FT, Arthrex, Inc., K050358, K061665
· FOOTPRINT Ultra PK Suture Anchor, Smith & Nephew, Inc., Endoscopy Division, K073509/ K093897

4 Device Description

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KI10538

5 Statement of Intended Use

Intended for the reattachment of soft tissue to bone in the shoulder, foot/ankle, knee, elbow and hand/wrist for the following indications:

Shoulder: Rotator Cuff Repair. Bankart Repair, SLAP Lesion Repair, Biceps Tenodesis. Acromio-Clavicular Separation Repair, Deltoid Repair, Capsular Shift or Capsulolabral Reconstruction

Foot/Ankle: Lateral Stabilization, Medial Stabilization, Achilles Tendon Repair. Hallux Valgus Reconstruction, Mid-Foot Reconstruction. Metatarsal Ligament Repair, Flexor Hallucis Longus for Achilles Tendon Reconstruction, Tendon Transfer in the Foot and Ankle

Knee: Medial Collateral Ligament Repair, Lateral Collateral Ligament Repair. Patellar Tendon Repair, Posterior Oblique Ligament Repair, Iliotibial Band Tenodesis

Elbow: Biceps Tendon Reattachment, Temis Elbow Repair, Ulnar or Radial Collateral Ligament Reconstruction

6 Non-Clinical Testing

Testing has been conducted to evaluate the biological safety and performance characteristics of PRO Fixation™ System.

Biocompatibility results indicate that the device biocompatibility profile is equivalent to the predicate devices.

Laboratory testing was performed to verify that pull-out strength, suture integrity/tensile strength following anchor insertion, suture slip resistance, and anchor and driver integrity meet mechanical performance requirements for the product's intended use and are comparable to predicate devices.

7 Comparison with Predicate Devices

The PRO Fixation™ System is comparable to the predicate devices in terms of intended use, technology, design, materials and biocompatibility and performance: It is similar to the predicate devices in that it has the same intended use of soft tissue to bone reattachment. is comprised of similar materials and is similar in design. All test results demonstrated that the performance of PRO Fixation™ System is equivalent to the predicate devices.

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

Synovis Orthopedic and Woundcare, Inc. % Ms. Amy Boucly 6 Jenner Street Suite 150 Irvine, CA 92618 .

JUL 1 2 2011

Re: . K110538

Trade/Device Name: PRO Fixation System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: II Product Code: HWC, MBI Dated: June 17. 2011 Received: June 20, 2011

Dear Ms. Boucly:

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

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Page 2 - Ms. Amy Boucly

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 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. If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm] 15809.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 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.html

Sincerely yours. Mark N. Melkerson

Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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INDICATIONS FOR USE

510(k) Number (if known): KIIO538

Device Name:

PRO Fixation™ System

Indications for Use:

Intended for the reattachment of soft tissue to bone in the shoulder, foot/ankle, knee, elbow and hand/wrist for the following indications:

Shoulder: Rotator Cuff Repair, Bankart Repair, SLAP Lesion Repair, Biceps Tenodesis, Acromio-Clavicular Scparation Repair, Deltoid Repair, Capsular Shift or Capsulolabral Reconstruction

Knee: Medial Collateral Ligament Repair, Lateral Collateral Ligament Repair, Patellar Tendon Repair, Posterior Oblique Ligament Repair, Iliotibial Band Tenodesis

Elbow: Biceps Tendon Reattachment, Tennis Elbow Repair, Ulnar or Radial Collateral Ligament Reconstruction

Prescription Use X (21 CFR 801 Subpart D) AND/OR

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

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)
---------------------	--

Division of Surgical, Orthopedic,
and Restorative Devices

510(k) Number	K110538
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Regulation Number and Section

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.