K Number
K102982
Device Name
ENDOBUTTON DIRECT
Date Cleared
2011-01-05

(90 days)

Product Code
Regulation Number
888.3030
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Smith & Nephew ENDOBUTTON DIRECT Fixation Device is used for fixation of tendons and ligaments during orthopedic reconstruction procedures such as Anterior Cruciate Ligament (ACL).
Device Description
The ENDOBUTTON DIRECT is a machined titanium implant designed to provide cortical fixation in the repair of tendons and ligaments. The design of the ENDOBUTTON DIRECT allows for the device to be endoscopically delivered from a single access point. The harvested graft is looped through the closed portion of the ENDOBUTTON DIRECT and by pulling on a lead suture attached to the top of the ENDOBUTTON DIRECT the construct is moved through the tunnel. The trailing suture located distal to the graft is then used to flip the device into position, lying flat across the tunnel opening on top of the femoral cortex.
More Information

Not Found

No
The device description and performance studies focus on the mechanical properties and fixation method of a titanium implant, with no mention of AI or ML.

Yes
The device is used for fixation during orthopedic reconstruction procedures which are therapeutic interventions.

No
The device description states it is a "fixation device" used for "fixation of tendons and ligaments during orthopedic reconstruction procedures," indicating it is a therapeutic or surgical device, not one that measures or interprets physiological data to make a diagnosis.

No

The device description clearly states it is a "machined titanium implant," indicating it is a physical 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 "fixation of tendons and ligaments during orthopedic reconstruction procedures." This is a surgical implant used in vivo (within the body).
  • Device Description: The description details a "machined titanium implant" designed for "cortical fixation." This is a physical device implanted into the body.
  • IVD Definition: In Vitro Diagnostics are devices used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health. This device does not interact with such specimens.

The information provided strongly indicates this is a surgical implant, not an IVD.

N/A

Intended Use / Indications for Use

The Smith & Nephew ENDOBUTTON DIRECT is used for fixation of tendons and ligaments during orthopedic reconstruction procedures such as Anterior Cruciate Ligament (ACL).

The Smith & Nephew ENDOBUTTON DIRECT Fixation Device is used for fixation of tendons and ligaments during orthopedic reconstruction procedures such as Anterior Cruciate Ligament (ACL).

Product codes (comma separated list FDA assigned to the subject device)

MAI

Device Description

The ENDOBUTTON DIRECT is a machined titanium implant designed to provide cortical fixation in the repair of tendons and ligaments. The design of the ENDOBUTTON DIRECT allows for the device to be endoscopically delivered from a single access point. The harvested graft is looped through the closed portion of the ENDOBUTTON DIRECT and by pulling on a lead suture attached to the top of the ENDOBUTTON DIRECT the construct is moved through the tunnel. The trailing suture located distal to the graft is then used to flip the device into position, lying flat across the tunnel opening on top of the femoral cortex.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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)

The performance testing conducted demonstrates substantial equivalence to the Smith & Nephew Endobutton CL, cleared in K980155. The bench top testing included tensile testing and demonstrates that the differences in the new device and the predicate device do not raise any new issues of safety and efficacy.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K980155

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 888.3030 Single/multiple component metallic bone fixation appliances and accessories.

(a)
Identification. Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.

0

SECTION V 510(k) SUMMARY OF SAFETY AND EFFECTIVENESS INFORMATION

as required by the Safe Medical Devices Act of 1990 and codified in 21 CFR 807.92 upon which the substantial equivalence is based.

Smith & Nephew ENDOBUTTON DIRECT

Date Prepared: January 5, 2011

A. Submitter's Name:

Smith & Nephew, Inc., Endoscopy Division 150 Minuteman Road Andover MA, 01810

B. Company Contact

Deana Boushell Principle Regulatory Affairs Specialist (508) 337-4036 Phone: (508) 261-3620 FAX:

C. Device Name

Trade Name:Smith & Nephew ENDOBUTTON Direct
Classification Name:Fastener, Fixation, Nondegradable, Soft Tissue
Regulation Name:Single/multiple component metallic bone fixation
appliances and accessories
Regulation Number:21 CFR 888.3030
Product Code:MAI

D. Predicate Devices

The Smith & Nephew ENDOBUTTON DIRECT is substantially equivalent in Intended Use and Fundamental Scientific Technology to the following legally marketed device in commercial distribution: The Smith & Nephew Endobutton CL (K980155).

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K102952 p. 2 of 2

E. Description of Device

The ENDOBUTTON DIRECT is a machined titanium implant designed to provide cortical fixation in the repair of tendons and ligaments. The design of the ENDOBUTTON DIRECT allows for the device to be endoscopically delivered from a single access point. The harvested graft is looped through the closed portion of the ENDOBUTTON DIRECT and by pulling on a lead suture attached to the top of the ENDOBUTTON DIRECT the construct is moved through the tunnel. The trailing suture located distal to the graft is then used to flip the device into position, lying flat across the tunnel opening on top of the femoral cortex.

F. Intended Use

The Smith & Nephew ENDOBUTTON DIRECT is used for fixation of tendons and ligaments during orthopedic reconstruction procedures such as Anterior Cruciate Ligament (ACL).

G. Comparison of Technological Characteristics

The Smith & Nephew ENDOBUTTON DIRECT is substantially equivalent in design, materials, function and intended use to the Smith & Nephew Endobutton CL, cleared in K980155. The proposed and the predicate devices both have the same intended use, button material and are offered in a range of sizes.

H. Summary Performance Data

The performance testing conducted demonstrates substantial equivalence to the Smith & Nephew Endobutton CL, cleared in K980155. The bench top testing included tensile testing and demonstrates that the differences in the new device and the predicate device do not raise any new issues of safety and efficacy.

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Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circle with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an image of an eagle.

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

Smith & Nephew Inc. c/o Ms. Deana Boushell Principal Regulatory Specialist 150 Minuteman Road Andover, Massachusetts 01810

JAN - 5 2011

Re: K102982

Trade/Device Name: Smith & Nephew ENDOBUTTON DIRECT Regulation Number: 21 CFR 888,3030 Regulation Name: Single/multiple component metallic bone fixation appliances and accessories Regulatory Class: Class II Product Code: MAI Dated: October 6, 2010 Received: October 7, 2010

Dear Ms. Boushell:

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 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. Deana Boushell

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.

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 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/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Sincerely yours,

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

Enclosure

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Indications for Use

K102982 510(k) Number (if known):

Device Name: Smith & Nephew ENDOBUTTON DIRECT

JAN - 5 2011

Indications For Use:

The Smith & Nephew ENDOBUTTON DIRECT Fixation Device is used for fixation of tendons and ligaments during orthopedic reconstruction procedures such as Anterior Cruciate Ligament (ACL).

Prescription Use _____________________________________________________________________________________________________________________________________________________________

(Per 21 CFR 801 Subpart D)

Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________ AND/OR

(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)

M. Melkeron
(Division Sign-Off)

Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K102982

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