(261 days)
The CARDIOFLON® and CARDIOXYL® sutures are intended for use in general soft tissue approximation and/or ligation, including use in cardiovascular surgery, in ophthalmic surgery and in neurological surgery.
The synthetic non-absorbable surgical sutures CARDIOFLON® and CARDIOXYL® are composed of a polyester [poly(ethylene terephtalate)] braids, with or without PLEDGET of different sizes. CARDIOFLON® braids are coated with a polymer of tetrafluorethylene (PTFE) and CARDIOXYL® braids are coated with polysiloxane. CARDIOFLON® and CARDIOXYL® sutures are green dyed (D&C green nº6 CI 61565) and white (undyed). Some packs are composed of green and white II is to facilitate location during use. CARDIOFLON® and CARDIOXYL® sutures comply with the requirements of the United States Pharmacopoeia (USP) and the European Pharmacopoeia (EP) for nonabsorbable surgical sutures.
The provided text describes a 510(k) summary for the CARDIOFLON® and CARDIOXYL® sutures. This document focuses on demonstrating substantial equivalence to predicate devices, rather than presenting a study to prove a device meets specific acceptance criteria. Therefore, most of the requested information (related to a clinical study, sample sizes, ground truth establishment, expert involvement, and MRMC studies) is not applicable to this type of regulatory submission.
However, I can extract the relevant information from the document regarding acceptance criteria and performance as pertaining to the regulatory submission for substantial equivalence.
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria (Compliance with Standards) | Reported Device Performance |
|---|---|
| USP (United States Pharmacopoeia) requirements for nonabsorbable surgical sutures | Complies with USP Monographs for non-absorbable surgical sutures |
| EP (European Pharmacopoeia) requirements for nonabsorbable surgical sutures | Complies with EP Monographs for non-absorbable surgical sutures |
| Biocompatibility | Polyester material is commonly used in surgical applications and has been proven to be biocompatible. |
Study that proves the device meets the acceptance criteria:
The document states that "Non-clinical laboratory testing was performed demonstrating that the devices complied with the USP Monographs and with the EP Monographs for non-absorbable surgical sutures." This implies that a series of in-vitro and/or bench tests were conducted to verify the physical, chemical, and mechanical properties of the sutures against the established standards.
2. Sample size used for the test set and the data provenance:
- Sample size: Not specified. As this is non-clinical laboratory testing against pharmacopoeial monographs, specific sample sizes for clinical testing are not relevant here. The pharmacopoeias themselves would define the sample sizes for the specific tests required.
- Data provenance: Not specified, but implied to be from internal lab testing conducted by Peters Surgical, likely in France (country of origin of the company). This would be retrospective in the sense that the testing was performed to support the 510(k) submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable. Ground truth as typically defined for clinical studies (e.g., expert consensus on medical images) is not relevant for demonstrating compliance with pharmacopoeial monographs. The "ground truth" here is the established specifications and methods within the USP and EP.
4. Adjudication method for the test set:
Not applicable. Adjudication methods are relevant for subjective assessments, typically in clinical studies involving multiple reviewers. The testing against USP/EP monographs is objective.
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 medical device submission for surgical sutures, not an AI-powered diagnostic device.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a medical device submission for surgical sutures, not an algorithm.
7. The type of ground truth used:
The "ground truth" for the performance data mentioned is the specifications and testing methodologies detailed within the United States Pharmacopoeia (USP) and European Pharmacopoeia (EP) Monographs for nonabsorbable surgical sutures.
8. The sample size for the training set:
Not applicable. There is no "training set" in the context of this type of regulatory submission for a physical medical device.
9. How the ground truth for the training set was established:
Not applicable. See point 8.
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060163 1/3
Image /page/0/Picture/1 description: The image shows the logo for "Péters Surgical". The logo consists of a stylized ear on the left, followed by the name "Péters" in a cursive font. Below "Péters" is the word "SURGICAL" in smaller, block letters. The overall design is simple and professional, likely representing a company specializing in surgical products related to the ear.
Attachment 12
OCT 1 2006
510 (k) Summary
[As Required by 21 CFR 807.92(c)]
Information supporting claims of substantial equivalence, as defined under the Federal Food, drug and Cosmetic Act, respecting safety and effectiveness is summarized below.
510(k) Summary Date prepared
January 09, 2006
510(k) Submitter
PETERS SURGICAL Z.I. Les vignes 42 rue Benoît Frachon Bobigny, FRANCE 93013
Registration Number: 3004060107 Owner/Operator Number: 9009304 Phone: 33-148-106262 Fax: 33-148-912299
Official Correspondent
Annie LASSERRE Research & Development Manager PETERS SURGICAL Bobigny, FRANCE, 93013 Phone: 33-148-106259
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K06163 2/3
Image /page/1/Picture/1 description: The image shows the logo for Peters Surgical. The logo features a stylized ear shape in black on the left. To the right of the ear shape, the text "Peters" is written in a stylized font, with the accent mark over the "e". Below "Peters", the word "SURGICAL" is written in smaller, sans-serif capital letters.
New Device Name
Trade name: CARDIOFLON®, CARDIOXYL® Common/Usual name: Sterile Polyester Suture Classification name: Polyester Nonabsorbable Synthetic Suture
New Device Classification
Class II by the General and Plastic Surgery Devices Panel, Nonabsorbable Polyester Surgical Suture (GAS).
Predicate Device Name
PETERS CARDIOFLON® SUTURE, Nonabsorbable Polyester Synthetic Suture (K913101).
TI-CRON TM, Nonabsorbable Polyethylene Surgical Suture (K930591).
Statement of intended use
CARDIOFLON® and CARDIOXYL® sutures are intended for use in general soft tissue approximation and/or ligation, including use in cardiovascular surgery, in ophthalmic surgery, in plastic surgery and in neurological surgery.
New Device Description
The synthetic non-absorbable surgical sutures CARDIOFLON® and CARDIOXYL® are composed of a polyester [poly(ethylene terephtalate)] braids, with or without PLEDGET of different sizes. CARDIOFLON® braids are coated with a polymer of tetrafluorethylene (PTFE) and CARDIOXYL® braids are coated with polysiloxane.
CARDIOFLON® and CARDIOXYL® sutures are green dyed (D&C green nº6 CI 61565) and white (undyed). Some packs are composed of green and white II is to facilitate location during use.
CARDIOFLON® and CARDIOXYL® sutures comply with the requirements of the United States Pharmacopoeia (USP) and the European Pharmacopoeia (EP) for nonabsorbable surgical sutures.
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Image /page/2/Picture/0 description: The image shows the logo for "Peters Surgical". The logo consists of a stylized ear on the left and the text "Peters" above the word "Surgical" on the right. The word "Peters" is in a larger, italicized font, while "Surgical" is in a smaller, non-italicized font.
Summary of Technological Characteristics of New Device to Predicate Device
CARDIOFLON® and CARDIOXYL® sutures sutures similar technological Characteristics as the predicate devices and TI-CRON™ Like our previously cleared Polyester sutures PETERS CARDIOFLON® SUTURE and the currently marketed TI-CRON™ sutures, CARDIOFLON® and CARDIOXYL® are sterile synthetic nonabsorbable surgical sutures that conform to the requirements of the United States Pharmacopoeia (USP) and the European Pharmacopoeia (EP) for non-absorbable surgical sutures. The polyester [poly(ethylene terephtalate)] material used for these medical devices is commonly used in surgical applications and has been proven to be biocompatible.
Performance data
Non-clinical laboratory testing was performed demonstrating that the devices complied with the USP Monographs and with the EP Monographs for non-absorbable surgical sutures.
Conclusions
Based on the 510(k) summary (21 CFR 807) and the information provided herein, we conclude that CARDIOFLON® and CARDIOXYL® are substantially equivalent to the predicate devices PETERS CARDIOFLON® SUTURE and TI•CRON™ under the Federal Food, drug, and Cosmetic Act.
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health and Human Services (HHS). The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized graphic of three human profiles facing to the right, stacked on top of each other, and connected by flowing lines.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
OCT 1 1 2006
Peters Surgical % Ms. Annie Lasserre Research & Development Manager Z.I. Les vignes 42 rue Benoît Frachon Bobigny, France 93013
Re: K060163
Trade/Device Name: CARDIOFLON®, CARDIOXYL® Regulation Number: 21 CFR 878.5000 Regulation Name: Nonabsorbable poly(ethylene terephthalate) surgical suture Regulatory Class: II Product Code: GAT Dated: August 29, 2006 Received: September 11, 2006
Dear Ms. Lasserre:
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
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Page 2 - Ms. Annie Lasserre
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) 276-0115. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrb/industry/support/index.html.
Sincerely yours,
Mark N. Melkerson
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Image /page/5/Picture/1 description: The image shows a logo for a company called "Péters Surgical". The logo features a stylized eye on the left side, with the company name written in a handwritten-style font to the right of the eye. The word "Surgical" is written in smaller letters below the name "Péters".
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Attachment 10
Indications for Use Statement
| 510(k) Number (if known) | K060163 |
|---|---|
| Device Name | CARDIOFLON®, CARDIOXYL® |
| Indications for Use | The CARDIOFLON® and CARDIOXYL® sutures are intended for use in general soft tissue approximation and/or ligation, including use in cardiovascular surgery, in ophthalmic surgery and in neurological surgery. |
| Prescription Use (Per 21 CFR 801. 109) | X |
| OR Over-The-Counter Use |
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 General, Restorative, and Neurological Devices
PETERS CARDIOFLON SUTURE/Special 510(k)/January 2006 510(k) Number K060167
§ 878.5000 Nonabsorbable poly(ethylene terephthalate) surgical suture.
(a)
Identification. Nonabsorbable poly(ethylene terephthalate) surgical suture is a multifilament, nonabsorbable, sterile, flexible thread prepared from fibers of high molecular weight, long-chain, linear polyesters having recurrent aromatic rings as an integral component and is indicated for use in soft tissue approximation. The poly(ethylene terephthalate) surgical suture meets U.S.P. requirements as described in the U.S.P. Monograph for Nonabsorbable Surgical Sutures; it may be provided uncoated or coated; and it may be undyed or dyed with an appropriate FDA listed color additive. Also, the suture may be provided with or without a standard needle attached.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.