K Number
K102815
Device Name
SURELIFT PROLAPSE SYSTEM
Date Cleared
2011-07-07

(282 days)

Product Code
Regulation Number
884.5980
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The SURELIFT PROLAPSE SYSTEM is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.
Device Description
The Surelift Prolapse System is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement. The kit is composed by a monofilament polypropylene mesh, two anchors with sutures to fix the mesh at the sacrospinose ligament, two anchoring handles to place the anchors and four passers to place the mesh through the obturator foramens. The mesh has six fixation points (two posterior fixation points and four arms): - Two posterior fixation points that are fixed to the sacrospinose ligaments. - Two middle arms that are passed through the arcus tendineus. - Two anterior arms that are passed through the anterior part of the obturator foramen. When placing the mesh, these six fixation points can be adjusted by the surgeon to leave the mesh flat at the proper tension avoiding wrinkles.
More Information

Not Found

No
The description details a surgical mesh kit with mechanical components and fixation points. There is no mention of software, algorithms, or data processing that would indicate the use of AI or ML.

Yes.

The device is intended for transvaginal surgical treatment to correct vaginal wall prolapse, which is a medical condition, making it a therapeutic device.

No.

The device description clearly states it is a "surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse." It is designed for treatment (surgical correction), not for diagnosing conditions.

No

The device description explicitly states it is a "surgical mesh kit" and lists physical components like mesh, anchors, sutures, handles, and passers. This indicates it is a hardware-based medical device, not software-only.

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

Here's why:

  • IVD Definition: In vitro diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening.
  • SURELIFT PROLAPSE SYSTEM Function: The SURELIFT PROLAPSE SYSTEM is a surgical mesh kit intended for the surgical treatment of anterior and posterior vaginal wall prolapse. It is a physical implant and associated tools used directly within the body during a surgical procedure.

The description clearly indicates it's a surgical device used for treatment, not for analyzing samples outside the body for diagnostic purposes.

N/A

Intended Use / Indications for Use

The Surelift Prolapse System is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.

Product codes

OTP

Device Description

The Surelift Prolapse System is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.

The kit is composed by a monofilament polypropylene mesh, two anchors with sutures to fix the mesh at the sacrospinose ligament, two anchoring handles to place the anchors and four passers to place the mesh through the obturator foramens.

The mesh has six fixation points (two posterior fixation points and four arms):

  • Two posterior fixation points that are fixed to the sacrospinose ligaments.
  • Two middle arms that are passed through the arcus tendineus.
  • Two anterior arms that are passed through the anterior part of the obturator foramen.

When placing the mesh, these six fixation points can be adjusted by the surgeon to leave the mesh flat at the proper tension avoiding wrinkles.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

vagina, pelvic floor

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)

Performance tests:
Sterilization
Bioburden
Ethylene oxide residuals
Ethylene chlorohydrins residuals
Sterility assurance level (SAL) determination
Packaging
Expiration dating test
Biocompatibility
Cytotoxicity
Implantation
Sensitization with polar and non-polar extract
Genotoxicity
Acute systemic toxicity
Irritation
Haemolysis
Extractable metallic ions
Pyrogen test
Mechanical tests
Suture pullout strength
Tensile break strength at break
Tear resistance
Burst strength
Stiffness
Pore size
Thickness
Density
Porosity
Prolapse anchor-mesh strength
Prolapse arm tensile strength
Results of verification testing indicate that the product meets the established performance requirements and standards.

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

Not Found

Predicate Device(s)

K080185, K071512

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 884.5980 Surgical mesh for transvaginal pelvic organ prolapse repair.

(a)
Identification. Surgical mesh for transvaginal pelvic organ prolapse repair is a prescription device intended to reinforce soft tissue in the pelvic floor. This device is a porous implant that is made of synthetic material, non-synthetic material, or a combination of synthetic and non-synthetic materials. This device does not include surgical mesh for other intended uses (§ 878.3300 of this chapter).(b)
Classification. Class III (premarket approval).(c)
Date premarket application approval or notice of completion of a product development protocol is required. A premarket application approval or notice of completion of a product development protocol for a device is required to be filed with the Food and Drug Administration on or before July 5, 2018, for any surgical mesh described in paragraph (a) of this section that was in commercial distribution before May 28, 1976, or that has, on or before July 5, 2018, been found substantially equivalent to a surgical mesh described in paragraph (a) of this section that was in commercial distribution before May 28, 1976. Any other surgical mesh for transvaginal pelvic organ prolapse repair shall have an approved premarket application or declared completed product development protocol in effect before being placed in commercial distribution.

0

| 510K AMENDMENT
July 6th 2011 | K102815 | SURELIFT PROLAPSE
SYSTEM | page 1 of 4 |
|---------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|-------------|
| 510K Summary: | JUL - 7 2011 | | |
| SUBMITTER: | Neomedic International, S.L.
C/ Maestrat 41-43 1º
08225 Terrassa (Barcelona)
Spain | | |
| DATE PREPARED: | September 12th, 2010 | | |
| DEVICE NAME: | Surelift Prolapse System | | |
| CLASSIFICATION NAMES: | Mesh, Surgical, Polymeric | | |
| PREDICATE DEVICES: | AMS ELEVATE WITH INTERPRO LITE PROLAPSE REPAIR
SYSTEM, AMS ELEVATE WITH INTEXEN LP PROLAPSE
REPAIR SYSTEM
GYNECARE PROLIFT +M* PELVIC FLOOR REPAIR SYSTEMS | | |

Device Description:

The Surelift Prolapse System is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.

The kit is composed by a monofilament polypropylene mesh, two anchors with sutures to fix the mesh at the sacrospinose ligament, two anchoring handles to place the anchors and four passers to place the mesh through the obturator foramens.

The mesh has six fixation points (two posterior fixation points and four arms):

  • Two posterior fixation points that are fixed to the sacrospinose ligaments.
  • Two middle arms that are passed through the arcus tendineus.
  • Two anterior arms that are passed through the anterior part of the obturator foramen.

When placing the mesh, these six fixation points can be adjusted by the surgeon to leave the mesh flat at the proper tension avoiding wrinkles.

Description of material components and physical properties:

ComponentMaterial
Monofilament polypropylene meshPolypropylene monofilament
Monofilament polypropylene suturesPolypropylene monofilament
AnchorsPEEK
Anchoring HandleStainless steel AISI 303
POM
PassersStainless steel AISI 303
POM

1

| 510K AMENDMENT
July 6th 2011 | K102815 | SURELIFT PROLAPSE
SYSTEM |
|------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|
| Component | Properties | |
| Monofilament polypropylene mesh | Knitted mesh
Monofilament diameter = 0,12 mm
Tensile break strength = 81,87 Newton
Pore size = 1,12 mm
Thickness = 0,41 mm
Density = 41,60 g/m²
Porosity = 54,63 % | |
| Monofilament polypropylene sutures | USP 0 | |
| Anchors | Diameter: 3 mm
Length: 7 mm | |
| Anchoring Handles | Anchoring Handle tube diameter = 6 mm
Anchoring Handle tube length = 204 mm | |
| Passers | Passers diameter = 4 mm | |

:

.

:

2

| 510K AMENDMENT
July 6th 2011 | K102815. | SURELIFT PROLAPSE
SYSTEM |

------------------------------------------------------------------------

Predicate Devices:

The following two devices have been previously cleared by the FDA in the following 510(K)

| Device | 510 (K)
document
number | Date Cleared | Indications |
|--------------------------------------------------------------------------------------------------------------------|-------------------------------|---------------|-------------------------------|
| AMS ELEVATE WITH INTERPRO LITE
PROLAPSE REPAIR SYSTEM, AMS
ELEVATE WITH INTEXEN LP PROLAPSE
REPAIR SYSTEM | K080185 | April 10 2008 | Pelvic Floor
Repair System |
| GYNECARE PROLIFT +M* PELVIC
FLOOR REPAIR SYSTEMS | K071512 | May 15 2008 | Pelvic Floor
Repair System |

Intended Use:

The Surelift Prolapse System is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.

Technological Characteristics comparison:

The Surelift prolapse system and the two predicate devices are substantially equivalent:

The two predicate devices are intended for pelvic floor prolapse repair.

The two predicate devices use monofilament polypropylene mesh and have multi-arm design for mesh adjustment and fixation.

The two predicate devices include accessories to aid in mesh placement.

One of the predicate devices (AMS) uses anchors to fixate the mesh to the sacrospinose ligament. The two predicate devices are sterilized by ETO.

There are differences compared to the predicate devices:

    1. The design of the arms is different: The Surelift has six fixation points (two posterior fixation points and four arms), the AMS Elevate has four fixation points (two posterior fixation points and two arms) and the Prolift has four fixation points (four arms). Surelift fixation points: two posterior fixation points (sacrospinose ligament), two medium arms (Arcus tendineus) and two anterior arms (anterior obturator foramen). AMS Elevate fixation points: two posterior fixation points (Sacrospinose ligament) and two anterior arms (anterior obturator foramen). Prolift fixation points: two medium arms (Arcus tendineus) and two anterior arms (anterior obturator foramen).
    1. The anchor material of the AMS Elevate is polypropylene, and the anchor material of the Surelift is PEEK.

The differences between the three devices do not raise new questions on the safety and effectiveness. We consider the proposed device is substantially equivalent to the predicate devices.

3

| 510K AMENDMENT
July 6th 2011 | K102815 * | SURELIFT PROLAPSE
SYSTEM |

-------------------------------------------------------------------------

Performance tests:

| 2

Performance testTest description
SterilizationBioburden
Ethylene oxide residuals
Ethylene chlorohydrins residuals
Sterility assurance level (SAL) determination
PackagingExpiration dating test
BiocompatibilityCytotoxicity
Implantation
Sensitization with polar and non-polar extract
Genotoxicity
Acute systemic toxicity
Irritation
Haemolysis
Extractable metallic ions
Pyrogen test
Mechanical testsSuture pullout strength
Tensile break strength at break
Tear resistance
Burst strength
Stiffness
Pore size
Thickness
Density
Porosity
Prolapse anchor-mesh strength
Prolapse arm tensile strength

Results of verification testing indicate that the product meets the established performance requirements and standards.

Conclusions:

Based on the 510(k) summaries and 510(k) statements (21 CFR 807) and the information provided herein, we conclude that the proposed device is substantially equivalent to the existing legally marketed device under the Federal Food, Drug and Cosmetic Act.

4

Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three stripes forming its body and wings. The eagle is enclosed within a circle, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged around the upper portion of the circle.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Neomedic International S.L. c/o Jeffrey R. Shideman, Ph.D. President International Medical Products Corporation 7307 Glouchester Drive EDINA MN 55435

SEP 2 8 2012

Re: K102815 Trade Name: Surelift Prolapse System Regulation Number: 21 CFR 8878.3300 Regulation Name: Surgical Mesh Regulation Class: II Product Code: OTP Dated: June 28, 2011 Received: June 30, 2011

Dear Dr. Shideman:

This letter corrects our substantially equivalent letter of July 7, 2011.

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 (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 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

5

Page 2 -

comply with all the Act's requirements, including, but not limited to: registration and listing (21 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/CDRH0ffices/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" (21 CFR 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 Biometrics/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 yours,

Benjamin R. Civiletti

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

6

Indications for Use

510(k) Number (if known): K102815

Device Name: SURELIFT PROLAPSE SYSTEM

Indications for Use:

The SURELIFT PROLAPSE SYSTEM is a surgical mesh kit intended for transvaginal surgical treatment to correct anterior vaginal wall prolapse and posterior vaginal wall prolapse. The kit includes instrumentation for transvaginal placement.

Prescription Use X (Part 2) 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 OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Page I of I

Tom M. Whig