K Number
K062820
Device Name
UNITY ALPHA SYSTEM
Date Cleared
2007-03-15

(176 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Unity Alpha PLLA System consists of single patient use absorbable (PLLA) implants intended for use as fasteners (anchors) in the fixation of tissue, ligament, tendon, and bone. The system is indicated in general soft tissue approximation/ligation.
Device Description
The Unity Alpha PLLA System is designed for the fixation of tissue, ligament, tendon. and bone. Absorbable poly-1.-lactic acid (PLLA) implant materials are ultrasonically welded to secure tissue, ligament, tendon, and bone at a repair site. An electrical generator provides ultrasonic energy to the end effector of a handpiece to weld the two pieces of implant material together and secure tissue, ligament, tendon. and/or bone. The system provides a means of sutureless fixation that facilitates overall suture management.
More Information

Not Found

Not Found

No
The summary describes a mechanical fixation system using ultrasonic welding and absorbable implants, with no mention of AI or ML technologies.

No.
The device is used to fix tissue, ligament, tendon, and bone, which is a supportive function rather than a direct therapeutic treatment of a disease or condition.

No

Explanation: The device is described as an absorbable implant system used for the fixation of tissue, ligament, tendon, and bone. Its purpose is to secure these anatomical structures, not to identify or diagnose a disease or condition.

No

The device description explicitly mentions physical components like "absorbable poly-1.-lactic acid (PLLA) implant materials," an "electrical generator," a "handpiece," and "end effector," indicating it is a hardware-based medical device system.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states the device is for "fixation of tissue, ligament, tendon, and bone" and "general soft tissue approximation/ligation." This describes a surgical or procedural device used in vivo (within the body) to physically secure tissues.
  • Device Description: The description details a system that uses absorbable implants and ultrasonic welding to fix tissues. This is a mechanical process performed directly on the patient's body.
  • Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue samples) in vitro (outside the body) to provide information for diagnosis, monitoring, or screening. The provided information contains none of these elements. There is no mention of analyzing biological samples or providing diagnostic information.

Therefore, the Unity Alpha PLLA System is a surgical fixation device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The Unity Alpha PLLA System consists of single patient use absorbable (PLLA) implants intended for use as fasteners (anchors) in the fixation of tissue, ligament, tendon, and bone. The system is indicated in general soft tissue approximation/ligation.

Product codes

HWC

Device Description

The Unity Alpha PLLA System is designed for the fixation of tissue, ligament, tendon. and bone. Absorbable poly-1.-lactic acid (PLLA) implant materials are ultrasonically welded to secure tissue, ligament, tendon, and bone at a repair site. An electrical generator provides ultrasonic energy to the end effector of a handpiece to weld the two pieces of implant material together and secure tissue, ligament, tendon. and/or bone. The system provides a means of sutureless fixation that facilitates overall suture management.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

tissue, ligament, tendon, and bone

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Design verification testing identified and conducted as part of the risk analysis assessment compared the mechanical strengths and failure modes of the Unity Alpha PLLA System to predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

Not Found

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

Koba820 page 14

MAR 1 5 2007

fingham, IL 62401

Phone: 217 342 34 217,342,3460 http://www.bonuttitec.com

Bonutti Research, Inc. Unity Alpha PLLA System 510(k) Premarket Motification

510(k) SUMMARY

The following information is submitted in accordance with the requirements of 21 CFR 807.92:

Patrick Balsmann, MBA, MS, RAC Contact Person: Director, Regulatory/Clinical Affairs & QA Bonutti Research, Inc., P.O. Box 1367 Effingham, Illinois 62401 Phone: (217) 342-3412, ext. 321 Fax: (217) 342-1043

Date Prepared: March 13, 2007

Proprietary Name: Unity Alpha PLLA System

Common Name: Fixation Device

Classification Name: Fastener, Fixation, Biodegradable, Soft Tissue.

Device Description: The Unity Alpha PLLA System is designed for the fixation of tissue, ligament, tendon. and bone. Absorbable poly-1.-lactic acid (PLLA) implant materials are ultrasonically welded to secure tissue, ligament, tendon, and bone at a repair site. An electrical generator provides ultrasonic energy to the end effector of a handpiece to weld the two pieces of implant material together and secure tissue, ligament, tendon. and/or bone. The system provides a means of sutureless fixation that facilitates overall suture management.

1

page 2 of 2

Bonutti Research, Inc. - Unity Alpha PLLA System 510(k) Summary -- March 13, 2007 Page 2

Indications for Use: The Unity Alpha PLLA System consists of single patient use absorbable (PLLA) implants intended for use as fasteners (anchors) in the lixation of tissue, ligament, tendon, and bone. The system is indicated in general soft tissue approximation/ligation.

Predicate Device(s): The Unity Alpha PLLA System is similar in design and intended use to existing Bonutti Research, Inc., fixation products and various other suture anchors determined to be substantially equivalent and that are commonly used in tissue and bone fixation.

Predicate Comparison: Design verification testing identified and conducted as part of the risk analysis assessment compared the mechanical strengths and failure modes of the Unity Alpha PLLA System to predicate devices.

Submitted by:

A. A. Peterson?

Patrick Balsmann, MBA, MS, RAC Director, Regulatory/Clinical Affairs & QA

2

Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the top half of the circle. In the center of the seal is an abstract image of an eagle.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Bonutti Research, Inc. % Patrick G. Balsmann, M.B.A., M.S., R.A.C. Director, Regulatory/Clinical Affairs and Quality Assurance P.O. Box 1367 Effingham, Illinois 62401

MAR 1 5 2007

Re: K062820 Trade/Device Name: Unity Alpha PLLA System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II

Product Code: HWC Dated: March 8, 2007 Received: March 9, 2007

Dear Mr. Balsmann:

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.

3

Page 2 - Patrick G. Balsmann, M.B.A., M.S., R.A.C.

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" (21 CFR 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/cdrh/industry/support/index.html.

Sincerely yours,

Barbara Bochum

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

Indications for Use

510(k) Number: K062820

Device Name: Unity Alpha PLLA System

Indications For Use: The Unity Alpha PLLA System consists of single patient use absorbable (PLLA) implants intended for use as fasteners (anchors) in the fixation of tissue, ligament, tendon, and bone. The system is indicated in general soft tissue approximation/ligation.

Prescription Use_ X (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use NO
(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)

Page I of __ 1 __

Oarbaea bucuup

(Division Sign-Off) Division of General, Bostorative, and Neurological Devaces

510(k) Number K0612820