(34 days)
The ATS SIMULUS FC Annuloplasty Bands are for use in those patients undergoing surgery of diseased or damaged mitral or tricuspid valves in whom the surgeon determines that the valve can be preserved by employing the appropriate surgical repair. The annuloplasty bands provide support for the mitral or tricuspid annulus and restrict expansion of the annulus.
The ATS SIMULUS FC Annuloplasty Bands are implantable, fully flexible, annular bands (Figure 1). The bands reduce and stabilize the atrioventricular annulus in patients undergoing mitral or tricuspid valve repair. The body of the band is made of braided Polyester. The band contains a circumferential flexible radiopaque marker. The entire circumference of the band is radiopaque.
The annuloplasty bands and accessories are designed as an integrated system to ease implantation. Malleable stems connects the double ended sizers to their handle.
The bands are available in the following sizes: 23 mm, 27 mm, 29 mm, 31 mm, 33 mm and 35 mm. The size refers to the inner diameter of the band. Green trigone markers are spaced at 120° from the midpoint of the posterior segment, which is also indicated by a green marker.
Here's an analysis of the provided text regarding the acceptance criteria and supporting study for the ATS SIMULUS FC Annuloplasty Band:
The document (K052899) is a 510(k) premarket notification for a medical device. In this type of submission, the primary goal is to demonstrate substantial equivalence to a previously legally marketed device (predicate device), rather than proving stand-alone effectiveness or a specific clinical benefit beyond what the predicate offers. Therefore, the information provided focuses on comparative aspects and safety/performance characteristics relevant to the predicate.
Based on the provided text, there is no clinical study presented that demonstrates the device meets specific performance acceptance criteria in the way you've outlined for an AI/device performance study.
Instead, the submission relies on:
- Equivalence to a predicate device: The ATS SIMULUS FC Annuloplasty Band is deemed equivalent to the K905175, PTI Annuloplasty Ring (now Genesee BioMedical, Inc. Sculptor® Annuloplasty Ring) based on design, material composition, surgical technique, and intended use. This is the core "proof" of acceptability for a 510(k) submission.
- Non-clinical testing: Safety and fundamental performance are addressed through laboratory and bench tests.
Here's a breakdown of the requested information, indicating where the document provides (or lacks) the specific details:
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A table of acceptance criteria and the reported device performance
This specific type of table, with quantitative performance metrics against predefined acceptance criteria, is not provided in the document. The general acceptance criteria are implied by the successful completion of the listed tests and the demonstration of substantial equivalence.
Acceptance Criteria Reported Device Performance Functionality: Support mitral/tricuspid annulus, restrict expansion of the annulus Implied: Device description states it "reduce[s] and stabilize[s] the atrioventricular annulus in patients undergoing mitral or tricuspid valve repair." Indications for Use state it "provide[s] support for the mitral or tricuspid annulus and restrict[s] expansion of the annulus." Equivalence to predicate (K905175) based on design, material, surgical technique, and intended use implies similar functionality. Biocompatibility: Safe for implantation, no adverse biological reactions Reported: "Class IV Biocompatibility tests on the predicate device." "All test results were satisfactory." (The document states these tests were done on the predicate device, implying the new device, being substantially equivalent in materials, would also be biocompatible.) Sterility: Supplied sterile, nonpyrogenic Reported: "LAL, Sterility Validation" were performed. "All test results were satisfactory." "The ATS SIMULUS FC Annuloplasty Bands are supplied STERILE (sterilized by gamma radiation) and nonpyrogenic..." Mechanical Integrity/Durability: Withstand surgical implantation and in-vivo forces without failure Reported: "Mechanical testing was carried out on complete modified bands and band components." "All test results were satisfactory." (Specific criteria like tensile strength, fatigue life, etc., are not detailed, but implied to be acceptable based on the "satisfactory" statement and equivalence to predicate.) Radiopacity: Entire circumference visible for post-implant assessment (for the FC model) Reported: "The band contains a circumferential flexible radiopaque marker. The entire circumference of the band is radiopaque." (This is a design feature, and successful visualization would be implicitly confirmed by mechanical/design verification, though no specific imaging study is mentioned as a "performance test" in the summary.) Packaging Integrity: Maintain sterility until expiration date Reported: "The bands will remain sterile until at least the expiration date provided the package is unopened and undamaged." (Successful sterility validation would cover this, but specific packaging test data is not detailed as a separate item beyond sterility validation.) Substantial Equivalence: To predicate device (K905175) Reported: "Equivalence can be seen in the design, material composition, surgical technique and intended use." FDA confirmed: "...the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices..." This is the overarching "performance" criterion for a 510(k) and was met. -
Sample sized used for the test set and the data provenance
- Sample Size: Not specified for any of the tests (LAL, Sterility, Biocompatibility, Mechanical). These are typically laboratory or bench tests with samples taken from manufacturing lots, not patient-based test sets.
- Data Provenance: Not specified, but generally, for a 510(k), these would be internal laboratory tests conducted by the manufacturer or contracted third-party labs. They are not clinical studies in the sense of patient data.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- This question is not applicable as there is no "test set" in the context of human data or expert review mentioned. The tests are lab-based.
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Adjudication method for the test set
- Not applicable. No expert adjudication of a test set is mentioned.
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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. This device is an annuloplasty band (implantable medical device for valve repair), not an AI-powered diagnostic or assistive tool. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is entirely irrelevant to this submission.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- No. This question is not applicable as the device is not an algorithm or AI system.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the non-clinical tests:
- Biocompatibility: Established scientific standards for biological reactivity (e.g., ISO 10993 series).
- Sterility: Established microbiology standards (e.g., USP, ISO 11137 for gamma sterilization).
- Mechanical Testing: Engineering specifications and performance comparisons to the predicate device, likely based on established ASTM or ISO standards for medical device materials and components.
- Functionality: Implied by design, material, and equivalence to the predicate device.
- For the non-clinical tests:
-
The sample size for the training set
- Not applicable. There is no "training set" as this is not an AI/machine learning device.
-
How the ground truth for the training set was established
- Not applicable. There is no "training set."
In summary:
The K052899 submission for the ATS SIMULUS FC Annuloplasty Band relies on demonstrating substantial equivalence to an existing predicate device (K905175, PTI Annuloplasty Ring / Sculptor® Annuloplasty Ring) and fulfilling standard non-clinical safety and performance testing requirements. The device is a physical implant, not an AI or diagnostic software, so many of the questions regarding clinical studies, expert review, training sets, and AI performance are not relevant to this type of device submission.
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K$\phi$52899
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| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------510(k) Summary Information | Genesee BioMedical, Inc. |
| Premarket Notification, Section 510(k) | JUNE 28, 2005 |
Safe Medical Devices Act of 1990, 21 CFR 807.92 Regulatory Authority:
Device Name: 1.
ATS SIMULUS FC Annuloplasty Band Model 700FC Trade Name:
Common Annuloplasty Ring Name(s):
Classification Ring, Annuloplasty Name(s):
Establishment Name & Registration Number: 2.
Genesee BioMedical, Inc. Name: 1723241 Number:
Classification(s): 3.
Class II Device Class: Cardiovascular Devices Panel Classification Panel: KRH Product Code(s):
Equivalent Predicate Device: 4
K905175, PTI Annuloplasty Ring (Sterile), Now called the Genesee BioMedical, Inc. Sculptor& Annuloplasty Ring.
Equivalence can be seen in the design, material composition, surgical technique and intended use.
5. Device Description:
The ATS SIMULUS FC Annuloplasty Bands are implantable, fully flexible, annular bands (Figure 1). The bands reduce and stabilize the atrioventricular annulus in patients undergoing mitral or tricuspid valve repair. The body of the band is made of braided Polyester. The band contains a circumferential flexible radiopaque marker. The entire circumference of the band is radiopaque.
The annuloplasty bands and accessories are designed as an integrated system to ease implantation. Malleable stems connects the double ended sizers to their handle.
The bands are available in the following sizes: 23 mm, 27 mm, 29 mm, 31 mm, 33 mm and 35 mm. The size refers to the inner diameter of the band. Green trigone markers are spaced at 120° from the midpoint of the posterior segment, which is also indicated by a green marker.
Packaging: 6.
The ATS SIMULUS FC Annuloplasty Bands are supplied STERILE (sterilized by gamma radiation) and nonpyrogenic, packaged in inner and outer blister trays with peelable lids. Each band is mounted on a disposable holder. The bands will remain sterile until at least the expiration date provided the package is unopened and undamaged.
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$\beta$ 2042
Indications for Use: 7.
The ATS SIMULUS FC Annuloplasty Bands are for use in those patients undergoing surgery of diseased or damaged mitral or tricuspid valves in whom the surgeon determines that the valve can be preserved by employing the appropriate surgical repair. The annuloplasty bands provide support for the mitral or tricuspid annulus and restrict expansion of the annulus
Testing Summary: 8.
Testing included LAL, Sterility Validation, Class IV Biocompatability tests on the predicate device. Mechanical testing was carried out on complete modified bands and band components. All test results were satisfactory.
Applicant Name & Address: 9.
John T. M. Wright, Ph.D. Genesee BioMedical, Inc. 1308 So Jason Street, Denver, CO 80223 Phone (303) 777-3000 extension 111 (303) 777-8866 Fax Email jwright@geneseebiomedical.com
10. Registration Number:
1723241
Company Contact: 11.
John Wright, Ph.D. Genesee BioMedical, Inc.
12. Submission Correspondent:
John T. M. Wright, Ph. D. Chief Executive Officer Genesee BioMedical, Inc.
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Image /page/2/Picture/1 description: The image shows the seal for the Department of Health and Human Services (HHS). The seal is circular and contains the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES. USA" around the perimeter. In the center of the seal is a stylized image of three human figures, representing health and well-being.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
NOV 1 7 2005
Genesee BioMedical, Inc. c/o John T. M. Wright, Ph.D. Chief Executive Officer 1308 S. Jason Street Denver, CO 80223-3408
Re: K052899
ATS SIMULUS FC Annuloplasty Band Model 700FC Regulation Number: 21 CFR 870.3800 Regulation Name: Annuloplasty Ring Regulatory Class: Class II (Two) Product Code: KRH Dated: October 12, 2005 Received: October 14, 2005
Dear Dr. Wright:
We have reviewed your Section 510(k) premarket notification of intent to market the device we nave roviewed your became in ind the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for ass surfal to May 28, 1976, the enactment date of the Medical Device Amendments, or to conimered prior to rial) 2011-07-2014 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 I ou may, increre, mains 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.
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Page 2 - John T. M. Wright, Ph.D.
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. 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), please contact the Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours.
Dummer R. Viener
1 Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Page 1
| 510(k) Number : | K052899 |
|---|---|
| ----------------- | --------- |
Device Name(s): ATS SIMULUS Annuloplasty Band
Indications For Use:
The Genesee BioMedical ATS SIMULUS 700FC Annuloplasty Bands are for use in those patients undergoing surgery of diseased or damaged mitral or tricuspid valves in whom the surgeon determines that the valve can be preserved by employing the appropriate surgical repair. The annuloplasty bands provide support for the mitral or tricuspid annulus and restrict expansion of the annulus.
Prescription Use __ X ________________________________________________________________________________________________________________________________________________________ OR Over-The-Counter Use PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY Concurrence of CDRH, Office of Device Evaluation (ODE)
(Per 21 CFR 801.109)
(Optional format 1-2-96)
Donna himes
(Division Sign-Off) Division of Cardiovascular Devices
K652899 510(K) Number_
§ 870.3800 Annuloplasty ring.
(a)
Identification. An annuloplasty ring is a rigid or flexible ring implanted around the mitral or tricuspid heart valve for reconstructive treatment of valvular insufficiency.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Guidance for Annuloplasty Rings 510(k) Submissions.”