(91 days)
MEMO 3D™ device is intended for correction of mitral insufficiencies or stenoinsufficiencies.
The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae. the device implantation must be accompanied by corrective valvuloplasty.
The MEMO 3D™ Semirigid Annuloplasty Ring is supplied as a sterile, non- pyrogenic, non-ferromagnetic ring pre-mounted on a disposable holder. The annuloplasty ring is manufactured by embedding a metallic inner core with medical grade silicone. The resulting silicone sheath, around the metallic core, is then encased within a tubular knitted fabric coated with Carbofilm™, which is a thin layer of turbostratic carbon. The fabric is then sewn along its length with Carbofilm™ coated polyester thread.
The annuloplasty ring is attached to the disposable holder to maintain the shape of the ring during implantation and allow for measured plications of the mitral annulus. Suture guides are present on the holder to aid the surgeon during ring placement.
The MEMO 3D™ annuloplasty ring is available in sizes 24mm through 38mm in two millimeter increments. A complete set of accessory instrumentation is to be available separately to properly size the annulus and implant the annuloplasty ring.
The provided text is a 510(k) Summary for a medical device called the MEMO 3D™ Semirigid Annuloplasty Ring. It describes the device, its intended use, and indicates that non-clinical testing was performed to demonstrate substantial equivalence to predicate devices. However, it does not contain the specific details about "acceptance criteria" or a "study that proves the device meets the acceptance criteria" in the way one would describe a clinical trial or performance study with quantified metrics for a device's diagnostic or predictive capabilities.
This document is a premarket notification for a Class II medical device, which typically relies on demonstrating substantial equivalence to legally marketed predicate devices rather than proving de novo effectiveness through extensive clinical trials with acceptance criteria on specific outcomes, especially for mechanical devices like annuloplasty rings. The "performance testing" mentioned refers to non-clinical tests to ensure the device performs as expected and is comparable to existing devices, not a study to meet pre-defined acceptance criteria for, say, accuracy or sensitivity of a diagnostic algorithm.
Therefore, for the information requested, I will have to state that some points are "Not Applicable" or "Not Provided in the document" as the context of the document is a 510(k) summary for a mechanical annuloplasty ring, not an AI/algorithm-based diagnostic device.
Here's a breakdown based on the provided text:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not explicitly defined as quantitative performance criteria in this 510(k) summary. The acceptance criteria for 510(k) equivalence are generally related to demonstrating similar safety and effectiveness through technological characteristics and non-clinical testing to predicate devices. | The MEMO 3D™ Semirigid Annuloplasty Ring demonstrated substantial equivalence to predicate devices for repair of the mitral valve through non-clinical testing. |
| Technological Characteristics: Substantial equivalence to predicate devices in: | Substantially equivalent to predicate devices in: |
| - Intended use | - Intended use |
| - Anatomical site for implantation | - Anatomical site for implantation |
| - Product labeling | - Product labeling |
| - Physical characteristics | - Physical characteristics |
| - Target population | - Target population |
| - Performance testing | - Performance testing (Non-clinical) |
| - Safety characteristics | - Safety characteristics |
| Non-Clinical Testing: Demonstrate equivalence through various tests. | Included: ultimate tensile strength, suture pull-out, rigidity determination, computational stress analysis, fatigue and durability testing, corrosion resistance, biocompatibility, sterilization validation, pyrogenicity, and shelf-life. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is Not Provided in the document. The document refers to "non-clinical testing" which implies bench testing rather than patient-based data. If there were a test set of patient data, its size and provenance are not mentioned.
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)
This information is Not Applicable or Not Provided in the document. For a mechanical device like an annuloplasty ring, "ground truth" in the context of expert review of test data (e.g., images for an AI device) is not typically established. The performance is assessed through engineering and biocompatibility tests.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is Not Applicable or Not Provided in the document. Adjudication methods are typically relevant for human review of data, which is not described for the non-clinical testing of this device.
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
This information is Not Applicable. An MRMC study is relevant for diagnostic devices, particularly those involving human interpretation of data assisted by AI. This document pertains to a mechanical surgical implant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is Not Applicable. This device is a mechanical surgical implant, not an algorithm or AI system.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The concept of "ground truth" as typically defined for AI/diagnostic devices (e.g., pathology as ground truth for cancer detection) is Not Applicable in this context. The "truth" for this device's performance relies on engineering standards, material science, and mechanical testing results demonstrating safety and equivalence to predicate devices. For biocompatibility, animal studies or in vitro tests might be used, often with histological examination or cell viability as endpoints, but these are not referred to as "ground truth" in the AI sense.
8. The sample size for the training set
This information is Not Applicable. The device is a mechanical implant; there is no "training set" in the context of machine learning or AI models.
9. How the ground truth for the training set was established
This information is Not Applicable. Similar to point 8, there is no "training set" or corresponding "ground truth" establishment for this type of device.
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K07/327
| 510(k) Summarv of Safety and Effectiveness | |
|---|---|
| Submitter | Sorin Biomedica Cardio S.r.l.I-13040 Saluggia (VC) ItalyVia Crescentino+39.0161.4871 [voice] |
| Contact | Heather Crawford, RACRegulatory Affairs Project ManagerCarboMedics, Inc.1300 East Anderson LaneAustin, Texas 78752512.435.3266 [voice] |
| 512.435.3350 [facsimile]heather.crawford@sorin.com [email] | |
| Date | May 10, 2007 |
| Device | Trade Name: MEMO 3D™ Semirigid Annuloplasty Ring 21 CFR 870.3800: Annuloplasty Ring Product Code: KRH - Class II - Special Controls Medical Specialty: Cardiovascular |
| PredicateDevices | K926138: Baxter Healthcare Corporation Carpentier-Edwards Physio Annuloplasty Ring K970375 and K021051: Carbomedics AnnuloFlo™ System K023185: Carbomedics AnnuloFlex™ Annuloplasty System |
AUG 1 0 2007
Continued on next page
v - Page 1 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio.
Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
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510(k) Summary of Safety and Effectiveness, Continued
| Indicationsfor Use | The MEMO 3D™ device is intended for correction of mitral insufficienciesor steno-insufficiences. The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae, the device implantation must be accompanied by corrective valvuloplasty. |
|---|---|
| Contra-indications | The annuloplasty rings should not be used in the case of: Severe organic lesions with retraction of chordae tendinaeCongenital malformations with limited valvular tissueExtensive calcification of valve leafletsEvolving bacterial endocarditis |
| DeviceDescription | The MEMO 3D™ Semirigid Annuloplasty Ring is supplied as a sterile, non- pyrogenic, non-ferromagnetic ring pre-mounted on a disposable holder. The annuloplasty ring is manufactured by embedding a metallic inner core with medical grade silicone. The resulting silicone sheath, around the metallic core, is then encased within a tubular knitted fabric coated with Carbofilm™, which is a thin layer of turbostratic carbon. The fabric is then sewn along its length with Carbofilm™ coated polyester thread. The annuloplasty ring is attached to the disposable holder to maintain the shape of the ring during implantation and allow for measured plications of the mitral annulus. Suture guides are present on the holder to aid the surgeon during ring placement. The MEMO 3D™ annuloplasty ring is available in sizes 24mm through 38mm in two millimeter increments. A complete set of accessory instrumentation is to be available separately to properly size the annulus and implant the annuloplasty ring. |
| Continued on next page | |
| K071327 |
v - Page 2 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio. Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
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510(k) Summary of Safety and Effectiveness, Continued
The MEMO 3D™ Semirigid Annuloplasty Ring is considered to be Technological Characteristics substantially equivalent in technological characteristics and intended use to the predicate devices. Equivalency is supported by multiple characteristics, including:
- Intended use 。一
- Anatomical site for implantation -
- Product labeling -
- Physical characteristics -
- Target population -
- Performance testing -
- Safety characteristics -
Non-Clinical Testing demonstrated that the MEMO 3D™ Semirigid Annuloplasty Ring is Testing substantially equivalent to the predicate devices for repair of the mitral valve. Non-clinical testing included: ultimate tensile strength, suture pull-out, rigidity determination, computational stress analysis, fatigue and durability testing, corrosion resistance, biocompatibility, sterilization validation, pyrogenicity, and shelf-life.
- Conclusion The MEMO 3D™ Semirigid Annuloplasty Ring has been demonstrated as safe and effective for its intended use. With respect to intended use and technological characteristics, the MEMO 3DTM Semirigid Annuloplasty Ring is substantially equivalent to the legally marketed predicate devices.
071327
v - Page 3 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio. Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
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Public Health Service
Image /page/3/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features the department's name arranged in a circular fashion around a symbol. The symbol is a stylized depiction of an eagle or bird-like figure, with three curved lines representing its wings or body.
AUG 1 0 2007
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Sorin Biomedica Cardio S.R.L. C/O Heather Crawford, RAC Project Manager, Regulatory Affairs Carbomedics, Inc. 1300 East Anderson Lane Austin, TX 78752-1793
Re: K071327
Trade/Device Name: MEMO 3D™ Semirigid Annuloplasty Ring Regulation Number: 21 CFR 870.3800 Regulation Name: Annuloplasty Ring Regulatory Class: Class II Product Code: KRH Dated: May 10, 2007 Received: May 11, 2007
Dear Ms Crawford:
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
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Page 2 - Ms. Crawford
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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance. please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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,
Blyminmar for
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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Indications for Use
510(k) Number (if known):
07/327
Device Name: MEMO 3D™ Semirigid Annuloplasty Ring
Indications for Use:
MEMO 3D™ device is intended for correction of mitral insufficiencies or stenoinsufficiencies.
The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae. the device implantation must be accompanied by corrective valvuloplasty.
Prescription Use X (Part 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)
B. Hemmerm
Division Sign-Off Division of Cardlovascular Devices 510(k) Number
Page 1 of 1
§ 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.”