K Number
K071704
Date Cleared
2007-09-17

(88 days)

Product Code
Regulation Number
888.3040
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Sleeve and Button Soft Tissue Devices utilizing ZipLoop™ Technology are intended for soft tissue to bone fixation for the following indications:

Shoulder
Bankart lesion repair, SLAP lesion repair, Acromio-clavicular repair, Capsular shift/capsulolabral reconstruction, Deltoid repair, Rotator cuff tear repair, Biceps tenodesis

Foot and Ankle
Medial/lateral repair and reconstruction, Mid- and forefoot repair, Hallux valgus reconstruction, Metatarsal ligament/tendon repair or reconstruction, Achilles tendon repair

Elbow
Ulnar or radial collateral ligament reconstruction, Lateral epicondylitis repair, Biceps tendon reattachment

Knee
Extra-capsular repair: MCL, LCL, and posterior oblique ligament Iliotibial band tenodesis, Patellar tendon repair, VMO advancement, Joint capsule closure

Hand and Wrist
Collateral ligament repair, Scapholunate ligament reconstruction, Tendon transfers in phalanx, Volar plate reconstruction

Hip
Acetabular labral repair

In addition to the aforementioned indications, the Button Soft Tissue Devices (all sizes) and size specific Sleeve Soft Tissue Devices (as shown in Table 1) are indicated for the following:

Knee
ACL/PCL repair/reconstruction ACL/PCL patellar bone-tendon-bone grafts Double-Tunnel ACL reconstruction

Device Description

The Sleeve and Button Soft Tissue Devices are comprised of a ZipLoop™ , a Button or a coreless Sleeve structure, and a passing suture. A ZipLoop™ is constructed from ultra high molecular weight polyethylene (UHMWPE) or polyester. It is passed through the Sleeve or Button, thus creating a soft tissue fixation device that bunches or locks against the bone when deployed.

AI/ML Overview

The Biomet Sleeve and Button Soft Tissue Devices received 510(k) clearance (K071704) based on substantial equivalence to legally marketed predicate devices, rather than through a study demonstrating direct achievement of specific performance acceptance criteria for a novel device. Therefore, the information provided in the document does not include a detailed table of acceptance criteria and reported device performance in the way typically seen for a new technology requiring such validation.

Instead, the submission relied on non-clinical testing and comparison to predicates.

Here's a breakdown based on the provided text:

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

This information is not explicitly available in the provided 510(k) summary. The submission states: "Non-clinical laboratory testing was performed to determine substantial equivalence. The results indicated that the device was functional within its intended use." This is a general statement rather than a detailed report of specific performance metrics against defined acceptance criteria. Without a specific new performance claim, the FDA typically assesses substantial equivalence based on materials, design, and intended use being similar enough to established predicates.

2. Sample size used for the test set and the data provenance

  • Sample Size for Test Set: Not applicable/not specified. Clinical testing was not provided as a basis for substantial equivalence. The non-clinical testing details are not provided.
  • Data Provenance: Not applicable, as no clinical studies were performed. The non-clinical testing details (e.g., in vitro, cadaveric) are not specified, nor is the country of origin.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable, as no clinical studies requiring expert ground truth establishment for a test set were conducted.

4. Adjudication method for the test set

Not applicable, as no clinical studies requiring adjudication were conducted.

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 device is a surgical fixation device, not an AI-assisted diagnostic or imaging tool.

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

Not applicable. This device is a physical surgical implant, not an algorithm.

7. The type of ground truth used

Not applicable for clinical studies for this submission. For the non-clinical testing, the "ground truth" would implicitly be relevant engineering standards, biomechanical properties, and the established performance of the predicate devices.

8. The sample size for the training set

Not applicable, as no machine learning algorithm was involved.

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

Not applicable, as no machine learning algorithm was involved.


Summary of the Study that Proves the Device Meets Acceptance Criteria:

The "study" that proves the device meets the acceptance criteria, in this context, is the non-clinical testing mentioned in the 510(k) summary. The nature of a 510(k) clearance for this type of device (soft tissue fixation) primarily relies on demonstrating that the new device is substantially equivalent to existing legally marketed predicate devices.

The document states: "Non-clinical laboratory testing was performed to determine substantial equivalence. The results indicated that the device was functional within its intended use."

This indicates that Biomet performed tests (likely mechanical, biomechanical, and material characterization tests) to ensure the physical properties and performance characteristics of the Sleeve and Button Soft Tissue Devices were comparable to the predicate devices. The "acceptance criteria" were therefore implicitly that the new device's performance would fall within ranges deemed acceptable and safe, consistent with the performance of the chosen predicate devices, for the stated indications for use.

The predicates listed are:

  • Multitak SS Suture System™ (K973015) - Bonutti Research
  • BioRaptor™ (K053344) - Smith & Nephew
  • Cruciate Ligament Button (PolySuture Button) (K813581) - Biomet Sports Medicine

The "study" was a set of non-clinical tests designed to show that the new device's materials, design, sizing, and ability to perform soft tissue to bone fixation did not raise new questions of safety or effectiveness when compared to these existing devices. The specifics of these tests (e.g., pull-out strength, fatigue testing, material biocompatibility) are not detailed in this summary but would have been part of the full 510(k) submission.

In essence, for a 510(k) based on substantial equivalence and non-clinical data alone for a device like this, the "acceptance criteria" are that the device performs functionally within its intended use and is comparable enough to predicates that it doesn't require a new PMA.

{0}------------------------------------------------

K07'704

Image /page/0/Picture/1 description: The image shows the logo for Biomet Inc. The logo is in black and white and features the company name in a stylized font. The letters are bold and blocky, with the "T" extending to the top and bottom of the other letters. The word "INC" is written vertically to the right of the "T".

510(k) Summary

28 2 2000

Preparation Date: June 20, 2007

Applicant/Sponsor: Biomet Sports Medicine (Formerly known as Arthrotek, Inc.)

Contact Person: Elizabeth Wray

Proprietary Name: Sleeve and Button Soft Tissue Devices

Common Name: Soft tissue fixation device

Classification Name:

  • MAI (888.3030): Fastener, fixation, biodegradable, soft tissue .
  • MBI (888.3040): Fastener, fixation, nondegradable, soft tissue #

Legally Marketed Devices To Which Substantial Equivalence Is Claimed:

DeviceMultitak SS SutureSystem™BioRaptor™Cruciate LigamentButton (PolySutureButton)
ManufacturerBonutti ResearchSmith & NephewBiomet Sports Medicine*
510(k) NumberK973015K053344K813581

Device Description: The Sleeve and Button Soft Tissue Devices are comprised of a ZipLoop™ , a Button or a coreless Sleeve structure, and a passing suture. A ZipLoop™ is constructed from ultra high molecular weight polyethylene (UHMWPE) or polyester. It is passed through the Sleeve or Button, thus creating a soft tissue fixation device that bunches or locks against the bone when deployed.

Indications for Use/Intended Use:

The Sleeve and Button Soft Tissue Devices utilizing ZipLoop™ Technology are intended for soft tissue to bone fixation for the following indications:

Shoulder

Bankart lesion repair, SLAP lesion repair, Acromio-clavicular repair, Capsular shift/capsulolabral reconstruction, Deltoid repair, Rotator cuff tear repair, Biceps tenodesis

Foot and Ankle

Medial/lateral repair and reconstruction, Mid- and forefoot repair, Hallux valgus reconstruction, Metatarsal ligament/tendon repair or reconstruction, Achilles tendon repair

Elbow

Ulnar or radial collateral ligament reconstruction, Lateral epicondylitis repair, Biceps tendon reattachment

Image /page/0/Picture/23 description: The image is a low-resolution picture that is mostly white. There are some black spots scattered throughout the image. The black spots are concentrated in the upper left and upper right corners of the image. The black spots are more sparse in the center of the image.

5-1

{1}------------------------------------------------

Knee

Extra-capsular repair: MCL, LCL, and posterior oblique ligament Iliotibial band tenodesis, Patellar tendon repair, VMO advancement, Joint capsule closure

Hand and Wrist

Collateral ligament repair, Scapholunate ligament reconstruction, Tendon transfers in phalanx, Volar plate reconstruction

Hip

Acetabular labral repair

In addition to the aforementioned indications, the Button Soft Tissue Devices (all sizes) and size specific Sleeve Soft Tissue Devices (as shown in Table 1) are indicated for the following:

Knee

ACL/PCL repair/reconstruction ACL/PCL patellar bone-tendon-bone grafts Double-Tunnel ACL reconstruction

Table 1

Sleeve Size
UHMWPE/PolypropylenePolyesterUHMWPE/PolypropylenePolyester
#2-0 or >--#2 or >--
#2-0 or >----#0 or >
--#2 or >--#5 or >

Example: The following sleeve device combination may be used for ACL/PCL indications: #2-0 UHMWPE/Polypropylene Loop + #2 UHMWPE/Polypropylene Sleeve

Note: The loop and sleeve sizes denote the diameter of the original UHMWPE/Polypropylene or polyester braided fiber.

Summary of Technologies: The technological characteristics (materials, design, sizing, and indications) of the Sleeve and Button Soft Tissue Devices are similar or identical to the predicate device or other previously cleared devices.

Non-Clinical Testing: Non-clinical laboratory testing was performed to determine substantial equivalence. The results indicated that the device was functional within its intended use.

Clinical Testing: None provided as a basis for substantial equivalence.

All trademarks are property of Biomet, Inc. except Multitak SS Suture System™ of BloRaptor™ of Smith & Nephew.

{2}------------------------------------------------

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized depiction of an eagle or bird-like figure with three curved lines representing its body and wings. The logo is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Biomet Manufacturing Corp. % Ms. Elizabeth Wray Regulatory Affairs Specialist P.O. Box 587 Warsaw, Indiana 46581-0587

SEP 1 7 2007

Re: K071704

Trade/Device Name: Biomet Sleeve and Button Soft Tissue Devices Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI, JDR Dated: June 20, 2007 Received: June 21, 2007

Dear Ms. Wray:

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 -

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). 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 toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely vours,

Sincerely yours,

Barbara Buettner

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 (if known):__K ●フレフ●4

Sleeve and Button Soft Tissue Devices ________________________________________________________________________________________________________________________________________ Device Name: ________________________________________________________________________________________________________________________________________________________________

Indications For Use:

The Sleeve and Button Soft Tissue Devices utilizing ZipLoop™ Technology are intended for soft tissue to bone fixation for the following indications:

Shoulder

Bankart lesion repair, SLAP lesion repair, Acromio-clavicular repair, Capsular shift/capsulolabral reconstruction, Deltoid repair, Rotator cuff tear repair, Biceps tenodesis

Foot and Ankle

Medial/lateral repair and reconstruction, Mid- and forefoot repair, Hallux valgus reconstruction, Metatarsal ligament/tendon repair or reconstruction, Achilles tendon repair

Elbow

Ulnar or radial collateral ligament reconstruction, Lateral epicondylitis repair, Biceps tendon reattachment

Knee

Extra-capsular repair: MCL, LCL, and posterior oblique ligament Iliotibial band tenodesis, Patellar tendon repair, VMO advancement, Joint capsule closure

Hand and Wrist

Collateral ligament repair, Scapholunate ligament reconstruction, Tendon transfers in phalanx, Volar plate reconstruction

Hip

Acetabular labral repair

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

Over-The-Counter Use NO (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Durkare buen

Restorative. and Neurological Devices

510(k) Number K071704 4-1

Page 1 of 2

{5}------------------------------------------------

In addition to the aforementioned indications, the Button Soft Tissue Devices (all sizes) and size specific Sleeve Soft Tissue Devices (as shown in Table 1) are indicated for the following:

Knee

ACL/PCL repair/reconstruction ACL/PCL patellar bone-tendon-bone grafts Double-Tunnel ACL reconstruction

Table 1


Loop SizeSleeve Size
UHMWPE/PolypropylenePolyesterUHMWPE/PolypropylenePolyester
#2-0 or >--#2 or >--
#2-0 or >----#0 or >
--#2 or >--#5 or >

The following sleeve device combination may be used for ACL/PCL indications: Example: #2-0 UHMWPE/Polypropylene Loop + #2 UHMWPE/Polypropylene Sleeve

The loop and sleeve sizes denote the diameter of the original Note: UHMWPE/Polypropylene or polyester braided fiber.

Prescription UseYES
(Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter UseNO
(21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

§ 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.