K Number
K111153
Device Name
SORBAFIX (TM) ABSORBABLE FIXATION SYSTEM, PERMAFIX (TM) FIXATION SYSTEM
Manufacturer
Date Cleared
2011-05-24

(29 days)

Product Code
Regulation Number
878.4750
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The SorbaFix Absorbable Fixation System is indicated for the approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair. The PermaFix Fixation System is indicated for the approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair.
Device Description
The proposed SorbaFix Absorbable Fixation System is a sterile single use device that delivers either 15 or 30 synthetic absorbable fasteners. The fasteners are dyed with D & C Violet No. 2 in accordance with 21 CFR 74.1602. The shaft of the SorbaFix Absorbable Fixation System is 36 cm in length, including a piloting tip. The fasteners are 6.7 mm in length and are manufactured from Poly (D, L)-lactide. The fixation instrument shafts have an outer diameter of 5 mm, and may be used in open procedures or with most 5 mm trocars in laparoscopic procedures. The device includes a fastener gauge located on the back of the handpiece for user convenience only. The gauge will move right to left as the fasteners are deployed and indicates the approximate level of fasteners remaining in the device. The proposed PermaFix Fixation System is a sterile single use device that delivers fasteners manufactured from a non-absorbable acetal copolymer material. The other patient contacting components in the delivery system are all made from the same stainless steel as that of the predicates.
More Information

Not Found

No
The summary describes a mechanical fixation system and does not mention any AI or ML components or functionalities.

No.
The device is used for soft tissue approximation and fixation of surgical mesh, which is a surgical tool, not a therapeutic device.

No

The device is a fixation system used for soft tissue approximation and surgical mesh fixation, not for diagnosing medical conditions. Its function is to deliver fasteners, which is a therapeutic or surgical action, not a diagnostic one.

No

The device description clearly outlines physical components such as fasteners, a shaft, a handpiece, and a fastener gauge, indicating it is a hardware device, not software-only.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the "approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair." This describes a surgical device used in vivo (within the body) for mechanical fixation.
  • Device Description: The description details a system that delivers fasteners made of absorbable or non-absorbable materials. This is consistent with a surgical fixation device, not a diagnostic test performed in vitro (outside the body) on biological samples.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information about a patient's health status.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device clearly falls outside of that definition.

N/A

Intended Use / Indications for Use

SorbaFix™ Absorbable Fixation System
Indications for Use: The SorbaFix Absorbable Fixation System is indicated for the approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair.

PermaFix™ Fixation System
Indications for Use: The PermaFix Fixation System is indicated for the approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair.

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

GDW

Device Description

The proposed SorbaFix Absorbable Fixation System is a sterile single use device that delivers either 15 or 30 synthetic absorbable fasteners. The fasteners are dyed with D & C Violet No. 2 in accordance with 21 CFR 74.1602. The shaft of the SorbaFix Absorbable Fixation System is 36 cm in length, including a piloting tip. The fasteners are 6.7 mm in length and are manufactured from Poly (D, L)-lactide. The fixation instrument shafts have an outer diameter of 5 mm, and may be used in open procedures or with most 5 mm trocars in laparoscopic procedures. The device includes a fastener gauge located on the back of the handpiece for user convenience only. The gauge will move right to left as the fasteners are deployed and indicates the approximate level of fasteners remaining in the device.

The proposed PermaFix Fixation System is a sterile single use device that delivers.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

soft tissue; surgical mesh

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)

Design verification and validation testing were conducted and demonstrated that the proposed SorbaFix and PermaFix met the requirements set up in the product performance specifications for their respective predicate devices (SorbaFix K082396 and PermaFix K092483).

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.

K082396, K092483

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

§ 878.4750 Implantable staple.

(a)
Identification. An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.(b)
Classification. Class II.

0

510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

MAY 2 4 2011 This 510(k) Summary is provided per the requirements of section 807.92(c).

Submitter Information

Submitter's Name:Davol, Inc., Subsidiary of C. R. Bard, Inc.
Address:100 Crossings Boulevard
Warwick, RI 02886
Contact Person:Zheng Liu
Regulatory Affairs Project Manager
Tel: (401) 825-8671
Fax: (401) 825-8765
Email: jane.liu@crbard.com
Device Name
Trade Name:SorbaFix™ Absorbable Fixation System
PermaFix™ Fixation System
Device Common Name:Staple, Implantable
Classification Code:Class II, §878.4750, Product Code GDW

Predicate Device Names

  • K082396 Davol Absorbable Fastener System, cleared on January 02, 2009 - K092483 PermaFix Fixation System, cleared on December 18, 2009

Device Description

The proposed SorbaFix Absorbable Fixation System is a sterile single use device that delivers either 15 or 30 synthetic absorbable fasteners. The fasteners are dyed with D & C Violet No. 2 in accordance with 21 CFR 74.1602. The shaft of the SorbaFix Absorbable Fixation System is 36 cm in length, including a piloting tip. The fasteners are 6.7 mm in length and are manufactured from Poly (D, L)-lactide. The fixation instrument shafts have an outer diameter of 5 mm, and may be used in open procedures or with most 5 mm trocars in laparoscopic procedures. The device includes a fastener gauge located on the back of the handpiece for user convenience only. The gauge will move right to left as the fasteners are deployed and indicates the approximate level of fasteners remaining in the device.

The proposed PermaFix Fixation System is a sterile single use device that delivers

PREMARKET NOTIFICATION FOR THE SORBAFIX™ ABSORBABLE FIXATION SYSTEM AND PERMAFIXTM FIXATION SYSTEM

-CONFIDENTIAL-SECTION 8

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  • have the same implantable fastener design and similar delivery system design:
  • have the same materials as the predicate device:
  • have the same shelf life;
  • use the same sterilization method; and
  • are packaged and sterilized using the same materials and processes.

The contraindication statement was expanded to the proposed SorbaFix and PermaFix IFU's as a remedial action taken following the internal investigation of the medical device reports from one incidence on one patient during one procedure. The proposed SorbaFix Absorbable Fixation System and PermaFix Fixation System are made from materials identical to their respective predicates (SorbaFix K082396 and PermaFix K092483). The SorbaFix fasteners are composed of an absorbable polymer material, i.e. poly (D, L) lactide, dyed with D&C Violet No. 2 in accordance with 21 CFR 74.1602. The PermaFix fasteners are manufactured from a non-absorbable acetal copolymer material. The other patient contacting components in the delivery system are all made from the same stainless steel as that of the predicates.

Full biocompatibility testing was conducted on both the predicate SorbaFix and PermaFix fasteners, the long term implants, in accordance with the ISO 10993 series requirements. The results of these tests were submitted under K082396 (Davol Absorbable Fastener System) and K092483 (PermaFix Fixation System) respectively. The biocompatibility data has ensured that the devices are safe for their intended use.

No further biocompatibility testing is necessary because the proposed devices incorporate the same materials as their respective predicates.

Other modifications covered under this Special 510(k) include:

  • labeling changes to remove the word "laparoscopic" from the 36 cm shaft devices for clarity purposes;
  • Modification of component dimensional specifications in the delivery system by removing the location of the clutch component from the end of the drive train towards the trigger to improve the drive mechanism:
  • Addition of a fastener gauge to the back of the ergonomic handle for user convenience.

Tables summarizing the similarities and differences between the proposed devices and their respective predicates are provided in Section 15.0.

Substantial Equivalence:

Design verification and validation testing were conducted and demonstrated that the proposed SorbaFix and PermaFix met the requirements set up in the product performance specifications for their respective predicate devices (SorbaFix K082396 and

PREMARKET NOTIFICATION FOR THE SORBAFIX™ ABSORBABLE FIXATION SYSTEM AND PERMAFIXTM FIXATION SYSTEM

-CONFIDENTIAL-SECTION 8

2

PermaFix K092483). A summary of the design control activities are provided in Section 18.0 of this Premarket Notification.

In summary, based on the performance data and the substantial equivalence comparison tables (reference Section 15.0), Davol Inc. believes that the proposed SorbaFix Absorbable Fixation System and PermaFix Fixation System are substantially equivalent to their respective predicates (SorbaFix K082396 and PermaFix K092483).

PREMARKET NOTIFICATION FOR THE SORBAFIX™ ABSORBABLE FIXATION SYSTEM AND PERMAFIXTM FIXATION SYSTEM

-CONFIDENTIAL-SECTION 8

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES · USA" around the perimeter. Inside the circle is an abstract image of an eagle or bird-like figure.

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

C. R. Bard, Inc. % Davol, Inc. Ms. Zheng Liu Regulatory Affairs Project Manager 100 Crossings Boulevard Warwick, Rhode Island 02886

MAY 2 4 2011

Re: K111153

Trade/Device Name: SorbaFix™ and PermaFix™ Absorbable Fixation Systems Regulation Number: 21 CFR 878.4750 Regulation Name: Implantable staple Regulatory Class: Class II Product Code: GDW Dated: April 22, 2011 Received: April 25, 2011

Dear Ms. Liu:

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.

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Page 2 - Ms. Zheng Liu

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); 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 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.

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

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 STATEMENT

510(k) Number (if known):

SorbaFix™ Absorbable Fixation System Device Name: The SorbaFix Absorbable Fixation System is indicated for Indications for Use: the approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair. PermaFix™ Fixation System Device Name: The PermaFix Fixation System is indicated for the Indications for Use: approximation of soft tissue and fixation of surgical mesh to tissues during open or laparoscopic surgical procedures, such as hernia repair.

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)

Daniel Kacor for MXM
(Division Sign Off)

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K111153