K Number
K102539
Device Name
ICUFF REPAIR PLATE, RIGHT; CUFF REPAIR PLATE. LEFT; ANCHOR BOLT, 10MM THROUGH 50MM
Date Cleared
2011-02-24

(174 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Cuff Repair Plate™ is intended for augmentation of transosseous rotator cuff repair, especially in massive tears and reruptures in proximity to osteopenic bone.
Device Description
The Cuff Repair Plate (CRP) is a fixable suture anchor plate that is designed to improve anchorage-to-bone strength during rotator cuff tendon-to-bone repair. When assembled, the device consists of a contoured, D-shaped buttress bone plate that is coupled to two anchor bolts. The plate is available in both right and left configurations. Anchor bolts are available in various lengths. Both the plate and the anchor bolts are manufactured from Ti-6Al-4V (ASTM F136). The components are provided non-sterile for single-use. The CRP is for use with #2 or #5 polyethylene-based high-strength non-absorbable braided suture.
More Information

Not Found

No
The device description and performance studies focus on the mechanical properties and structural integrity of a physical implant, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is intended for augmentation of rotator cuff repair, which is a therapeutic intervention aimed at restoring function and alleviating symptoms.

No

Explanation: The device description states that the Cuff Repair Plate is a "fixable suture anchor plate that is designed to improve anchorage-to-bone strength during rotator cuff tendon-to-bone repair." Its intended use is for "augmentation of transosseous rotator cuff repair." This clearly indicates it is a therapeutic/surgical device, not a diagnostic one.

No

The device description clearly states it is a "fixable suture anchor plate" made of Ti-6Al-4V, consisting of a bone plate and anchor bolts. This describes a physical, implantable hardware device, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states it's for "augmentation of transosseous rotator cuff repair." This is a surgical procedure performed on the human body.
  • Device Description: The description details a physical implantable device (plate, anchor bolts, suture) used for mechanical fixation.
  • Lack of IVD Characteristics: There is no mention of analyzing samples from the human body (blood, urine, tissue, etc.) to provide information about a disease, condition, or state of health.

IVD devices are used in vitro (outside the body) to examine specimens. This device is used in vivo (inside the body) as a surgical implant.

N/A

Intended Use / Indications for Use

The Cuff Repair Plate™ is intended for augmentation of transosseous rotator cuff repair, especially in massive tears and reruptures in proximity to osteopenic bone.

Product codes

MBI

Device Description

The Cuff Repair Plate (CRP) is a fixable suture anchor plate that is designed to improve anchorage-to-bone strength during rotator cuff tendon-to-bone repair. When assembled, the device consists of a contoured, D-shaped buttress bone plate that is coupled to two anchor bolts. The plate is available in both right and left configurations. Anchor bolts are available in various lengths. Both the plate and the anchor bolts are manufactured from Ti-6Al-4V (ASTM F136). The components are provided non-sterile for single-use. The CRP is for use with #2 or #5 polyethylene-based high-strength non-absorbable braided suture.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

rotator cuff

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

Testing of the CRP device to demonstrate substantial equivalence included construct pull-out testing, CRP static three-point bending, and testing to evaluate the anchor bolt's torsional strength, insertion driving torque, and axial pull-out.

Key Metrics

Not Found

Predicate Device(s)

K994364

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

107539

8. 510(k) Summary

    1. Applicant
      FEB 2 4 2011

Shoulder Options, Inc. 3284 Scenic Drive Boise, ID 83703

Contact Person:

Mike Alexander, CEO Tel: (208)761-1176 Fax: (888)760-2993 Email: alexander@shoulderoptions.com

Application Correspondent:

Kapstone Medical, LLC 100 E. South Main St. P.O. Box 1458 Waxhaw, NC 28173

John Kapitan, President, Kapstone Medical LLC Contact Person: Tel: (704) 843-7852 Fax: (704) 831-5316 E-mail: jkapitan@kapstonemedical.com

Date Prepared: September 1, 2010

2. Device Name

Common/Usual Name: Fastener, Fixation, Nondegradable, Soft Tissue Smooth or threaded bone fixation fastener Classification Name: Regulation Number: 888.3040 MBI Product Code: ll Classification: Orthopedic Panel:

3. Predicate Devices

The Cuff Repair Plate™ (CRP) is substantially equivalent to the following device:

510(k) NumberDeviceManufacturer
K994364Synthes Button PlateSynthes

1

K102539

4. Description of the Device

The Cuff Repair Plate (CRP) is a fixable suture anchor plate that is designed to improve anchorage-to-bone strength during rotator cuff tendon-to-bone repair. When assembled, the device consists of a contoured, D-shaped buttress bone plate that is coupled to two anchor bolts. The plate is available in both right and left configurations. Anchor bolts are available in various lengths. Both the plate and the anchor bolts are manufactured from Ti-6Al-4V (ASTM F136). The components are provided non-sterile for single-use. The CRP is for use with #2 or #5 polyethylene-based high-strength non-absorbable braided suture.

5. Indications for Use

The Cuff Repair Plate is intended for augmentation of transosseous rotator cuff repair, especially in massive tears and reruptures in proximity to osteopenic bone.

6. Summary of Performance Data

Testing of the CRP device to demonstrate substantial equivalence included construct pull-out testing, CRP static three-point bending, and testing to evaluate the anchor bolt's torsional strength, insertion driving torque, and axial pull-out.

7. Safety & Effectiveness

The Cuff Repair Plate™ (CRP) is substantially equivalent to the Synthes Button Plate (SBP) (K994364). Both devices have the same "Indications for Use," are available by prescription only, and are provided non-sterile for single-use only. The CRP differs from the SBP in that the CRP uses anchor bolts for fixation, has a different plate design, and is made from titanium alloy. These differences do not negatively impact the overall safety and effectiveness of the device. Therefore, it can be concluded that the CRP is both a safe and effective device and is substantially equivalent to the SBP.

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 circle of text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA". Inside the circle is an image of an eagle with its wings spread.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

Shoulder Options, Inc. % Kapstone Medical. LLC Mr. John Kapitan 100 E. South Main Street P.O. Box 1458 Waxhaw, North Carolina 28173

FEB 2 4 2011

Re: K102539

Trade/Device Name: Cuff Repair Plate™ Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI Dated: December 22, 2010 Received: December 27, 2010

Dear Mr. Kapitan:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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

3

Page 2 - Mr. John Kapitan

CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803). please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biomctrics/Division of Postmarket Surveillance.

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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely vours.

Aty B. R. h
for.

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

Enclosure

4

7. Indications for Use Statement

510(k) Number (if known): __

Device Name: Cuff Repair Plate™

Indications for Use:

The Cuff Repair Plate™ is intended for augmentation of transosseous rotator cuff repair, especially in massive tears and reruptures in proximity to osteopenic bone.

Prescription Use X Over-The-Counter Use AND/OR (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

for M. Melkerson

(Division Sign-Off) (Division of Surgical, Orthopedic, Divisionative Devices

510(k) Number K102539