(232 days)
Desara SL is intended to be used in females to position a mesh for the treatment of Genuine Stress Urinary Incontinence (SUI), mixed incontinence resulting from urethral hypermobility or intrinsic sphincter deficiency.
Desara® SL is a sterile, single-use pubourethral 1.1 x 12cm silng used to provide support in the pelvic region to treat stress urinary Incontinence or mixed Incontinence. The device is manufactured out of a monofilament polypropylene yarn, which is knitted into a mesh. The device has a mid-line marker, integral sleeves, tips and sutures to assist the surgeon in placement of the device. The sleeves, tips and sutures are removed after placement of the device.
Desara® SL Is designed to work with Caldera Medical's reusable transobturator helical, hook, and Inside-out introducers, which utilize a Universal Connection System offering surgeons the flexibility to choose their preferred surgical approach.
Here's a breakdown of the acceptance criteria and study information for the Desara SL device, based on the provided 510(k) summary:
This device is a surgical mesh, therefore many of the typical AI/ML-related questions (like MRMC studies, training sets, etc.) are not applicable here. The focus is on material properties, biocompatibility, and functional performance, often demonstrated through bench testing and comparison to predicate devices, rather than diagnostic accuracy.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Criteria Assessed (Examples) | Reported Device Performance (How Criteria Were Met) |
|---|---|---|
| Mechanical & Material Characteristics | Mesh thickness, knit characteristics, pore size, mesh density, tensile strength, mesh stiffness, flexural rigidity, tear resistance, burst strength, suture pullout. | Assessed against these characteristics, with results demonstrating equivalent device function to the primary predicate device (Desara® Mesh) for its intended use. The Desara SL is comprised of the same mesh as the predicate device, Desara® Mesh, implying that its material characteristics are inherently equivalent. |
| Functional Bench Testing | Sleeve to tip pull-off force, suture loop pull-out force, device mesh break strength. | All testing met predefined acceptance criteria. Results of both mechanical bench and validation testing demonstrate equivalent device function based upon its intended use to the primary predicate device, Desara® Mesh. |
| Biocompatibility | Absence of adverse biological reactions. | Desara® (the mesh material used in Desara SL) has passed all biocompatibility testing as per FDA guidance documents (FDA Device Advice, Guidance Documents, Biocompatibility and FDA Blue Book Memorandum #G95-1 Entitled "Use of International Standard ISO-10993, "Biological Evaluation of Medical Devices Part-1: Evaluation and Testing"). ASTM F899-09 was referenced for instrument biocompatibility. |
| Reprocessing & Sterilization | Validated reprocessing instructions for reusable instrumentation; validation of aging, shelf life, transportation, and sterilization. | Reprocessing instructions for Desara SL instrumentation (reusable) were validated per FDA Guidance "Draft Guidance for Industry and FDA Staff - Processing Medical Devices in Health Care Settings: Validation Methods and Labeling" (May 2, 2011) and are similar to Desara Mini instrumentation (K103418). Testing documentation from Desara was used to support aging, shelf life, transportation, and sterilization of Desara® SL, as it comprised the same materials, packaging, manufacturing, and sterilization processes as Desara®. This aligns with FDA Guidance, Updated 510(k) Sterility Review Guidance K90-1; Final Guidance for Industry, FDA, FDA Device Advice, Guidance Documents, and ASTM F-1980-07. |
| Clinical Effectiveness & Safety | Comparison of clinical outcomes (e.g., efficacy, post-operative complications like groin pain). | A prospective randomized trial (de Leval, J, et al.) found that a modified inside-out transobturator tape procedure using a 12 cm sling (like Desara SL) was as safe and efficacious as the original transobturator technique at one-year follow-up, and was associated with less immediate post-operative groin pain. This study directly supports the safety and effectiveness of the surgical approach enabled by a device of this length and design. |
2. Sample Size Used for the Test Set and Data Provenance
- For material and functional bench testing: The specific sample sizes for each mechanical test (e.g., "sleeve to tip pull-off force") are not explicitly stated in the summary. The summary indicates that "all testing met predefined acceptance criteria."
- For clinical effectiveness: The summary refers to a "prospective randomized trial by de Leval J, et al." The sample size for this trial is not explicitly stated in the 510(k) summary, although the study itself (cited as Int Urogynecol J (2011) 22:145-156) would contain this information.
- Data Provenance:
- Bench Testing: Likely internal Caldera Medical testing.
- Clinical Study: The cited study by de Leval, J, et al. would be the source. The article's title "Int Urogynecol J (2011)" suggests it's a published, peer-reviewed study, likely conducted in a clinical setting (country of origin not noted in the summary). It is explicitly stated as a "prospective randomized trial."
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Not Applicable in the traditional sense for a medical device 510(k) for surgical mesh. Ground truth for bench testing is established by engineering specifications and objective measurements against predefined acceptance criteria.
- For the clinical study: The "ground truth" would be the clinical outcomes (patient symptoms, objective measures of SUI, reported complications) as assessed by the researchers and clinicians involved in that specific published trial. The expertise would be that of the medical professionals conducting the trial and evaluating patients.
4. Adjudication Method for the Test Set
- Not Applicable in the traditional sense for a medical device 510(k) for surgical mesh. Bench testing results are compared directly to engineering specifications.
- For the clinical study: The methods for assessing clinical outcomes and patient follow-up within the de Leval, J, et al. study would define any adjudication process for clinical endpoints. This is not detailed in the 510(k) summary.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC study was NOT done. This type of study is typically used for diagnostic imaging devices where different readers evaluate the same cases with and without AI assistance to measure improvement in diagnostic performance. The Desara SL is a surgical mesh implant, not a diagnostic device.
6. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop Performance)
- No, a standalone performance study (in the context of an AI/ML algorithm) was NOT done. This device is a physical surgical implant, not an algorithm. Its performance is evaluated through material science, mechanical testing, and clinical outcomes, not algorithmic accuracy.
7. Type of Ground Truth Used
- For material and functional bench testing: Engineering specifications, material standards, and validated mechanical test methods provide the "ground truth."
- For biocompatibility: Established regulatory guidelines (ISO 10993) and historical data on the predicate mesh material (Desara®) serve as the ground truth.
- For the clinical study (de Leval, J, et al.): Clinical outcomes data, including physician assessments, patient-reported symptoms, and objective measures of incontinence, as well as complication rates (e.g., groin pain), serve as the ground truth for safety and efficacy.
8. Sample Size for the Training Set
- Not Applicable. This is a physical, non-AI medical device. There is no "training set" in the context of machine learning. The device's design is based on established engineering principles and the predicate device.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As there is no "training set" for an AI/ML algorithm, this question is not relevant. The "ground truth" for the device's design and manufacturing is established through well-defined engineering, material science, and regulatory standards.
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510(k) Summary #K121928
| Date of Summary: | February 18, 2013 | FEB 19 2013 |
|---|---|---|
| Applicant: | Caldera Medical, Inc.5171 Clareton DriveAgoura Hills, CA 91301P (818) 879-6555F (818) 879-6556 | |
| Contact: | Vicki GailQA/RA and Operations ManagerP (818) 483-7602F (818) 736-9083E vgail@calderamedical.com | |
| Trade Name:Device Class:Product Code:C.F.R Section:Common name:Classification Panel: | Desara® SLClass IIOTN21 CFR 878.3300Surgical Mesh, Gynecologic, For Stress Urinary Incontinence, FemaleObstetrics/Gynecology Panel | |
| Predicate Devices: | Desara Mesh, K112609 (Primary)Gynecare TVT Abbrevo Continence System, K100936 (Secondary) |
Description of Device:
Desara® SL is a sterile, single-use pubourethral 1.1 x 12cm silng used to provide support in the pelvic region to treat stress urinary Incontinence or mixed Incontinence. The device is manufactured out of a monofilament polypropylene yarn, which is knitted into a mesh. The device has a mid-line marker, integral sleeves, tips and sutures to assist the surgeon in placement of the device. The sleeves, tips and sutures are removed after placement of the device.
Desara® SL Is designed to work with Caldera Medical's reusable transobturator helical, hook, and Inside-out introducers, which utilize a Universal Connection System offering surgeons the flexibility to choose their preferred surgical approach.
Intended Use of Device:
Desara SL is intended to be used in females to position a mesh for the treatment of Genuine Stress Urlnary Incontinence (SUI), mixed incontinence resulting from urethral hypermobility or Intrinsic sphincter deficiency.
Summary of Technological Characteristics:
The Desara SL and Desara Mesh do not have the same technological characteristics. The new technological characteristics of the Desara SL include its comparatively shorter length (12 cm versus 45 cm), and therefore, different surgical procedure. Specifically, Desara SL mesh does not exit or reach the upper thigh/groin incisions like the Desara Mesh. The upper thigh/groin incisions required are only used to adjust the mesh position during the surgical procedure. The new technological characteristics of the Desara SL could affect safety and effectiveness because the Desara SL does not extend beyond the obturator foramen like the Desara Mesh. Therefore, no tissue ingrowth or granulation will occur between the obturator foramen and upper thigh/groin Incisions to provide additional support to the implant. This could affect the effectiveness of the Desara SL compared to the Desara Mesh. In regards to safety, the Desara SL requires less dissection than Desara Mesh. The new technological characteristics of Desara SL do not ralse new Issues of safety and effectiveness because the FDA has previously cleared a
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K121928
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hybrid sling, the TVT Abbrevo. TVT Abbrevo has the same length and nearly the identical implantation procedure as the Desara SL.
Performance Summary
Desara® SL Is comprised of the same mesh as the predicate device, Desara® Mesh, (K112609), also a product of Caldera Medical. In accordance with the FDA's Guidance for the Preparation of a Premarket Notification Application for Surgical Mesh, the following mesh characteristics were assessed: mesh thickness, mesh knit characteristics, pore size, mesh density, tensile strength, mesh stiffness, flexural rigidity, tear resistance, burst strength, suture pullout and pyrogen levels.
The Desara® device was used as a reference for Desara® SL biocompatibility since both are comprised of the same materials. Desara® has passed all biocompatibility testing as indicated per the FDA quidance documents, FDA Device Advice, Guidance Documents (Medical Device and Radiation Emitting Product), 3. Biocompatibility and FDA Blue Book Memorandum #G95-1 Entitled "Use of International Standard ISO-10993, "Biological Evaluation of Medical Devices Part-1: Evaluation and Testing". In addition, ASTM F899-09 Standard Specification for Wrought Stainless Steels for Surgical Instruments, was referenced to support the biocompatibility of the Desara SL instrumentation.
Desara® SL instrumentation is reusable and physician labeling for the Desara SL instrumentation includes reprocessing instructions validated per the Guidance Document "Draft Guidance for Industry and FDA Staff - Processing Medical Devices in Health Care Settings: Validation Methods and Labeling" issued on May 2, 2011. The reprocessing instructions for the Desara SL Instrumentation are similar to those of the Desara Mini instrumentation (K103418)
Results of both mechanical bench and validation testing demonstrate equivalent device function based upon its intended use to the primary predicate device, Desara® Mesh. The following failure modes were assessed during mechanical and validation testing: sleeve to tip pull-off force, suture loop pull-out force and device mesh break strength and all testing met predefined acceptance criteria.
Testing documentation from Desara was used to support the aging, shelf life, transportation and sterlization Desara® SL In accordance with the FDA Guidance, Updated 510(k) Sterlilty Review Guidance K90-1; Final Guidance for Industry, FDA, FDA Device Advice, Guidance Documents (Medical Device and Radiation Emitting Product), 4. Labeling and FDA Consensus standard, ASTM F-1980-07, Standard Guide for Accelerated Aging of Sterlie Barrier Systems for Medical Devices as It is comprised of the same materials, packaging, manufacturing and sterlization processes as that of Desara®.
One year results of the prospective randomized trial by de Leval J, et al' found that at one year follow-up a modified inside-out transobturator tape procedure utilizing a 12 cm sling or 'tape' length like Desara SL was as safe and efficacious as the original transobturator technique but associated with less immediate post-operative groin pain.
Summary of Substantial Equivalence
The conclusions drawn from the non-clinical and clinical tests demonstrate that the Desara SL is substantially equivalent to its proposed predicate devices.
¹ de Leval, J, Waltregny TD. The original versus a modified inside-out transobturator procedure: 1-year results of a prospective randomized trial. Int Urogynecol J (2011) 22:145-156. DOI 10.1007/s00192-010-1264-4.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 19, 2013
Caldera Medical, Inc. % Ms. Vicki Gail QA/RA Manager 5171 Clareton Drive AGOURA HILLS CA 91301
Re: K121928
Trade/Device Name: Desara SL Regulation Number: 21 CFR& 878.3300 Regulation Name: Surgical mesh Regulatory Class: II Product Code: OTN Dated: January 29, 2013 Received: January 31, 2013
Dear Ms. Gail:
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.
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Page 2 - Ms. Vicki Gail
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 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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Benjamin R.A.Fisher -S
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
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Indications for Use
510(k) Number (if known): K121928
Device Name: Desara SL
Indications for Use:
Desara SL is intended to be used in females to position a mesh for the treatment of Genuine Stress Urinary Incontinence (SUI), mixed incontinence resulting from urethral hypermobility or intrinsic sphincter deficiency.
| Prescription Use |
|---|
| ------------------ |
AND/OR
Over-The-Counter Use
| (21 CFR 801 Subpart D) |
|---|
| ------------------------ |
x
(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)
Benjamin R. Fisher -S 2013.02.19 18:10:06 -05'00'
(Division Sign-Off) Division of Reproductive, Gastro-Renal, and Urological Devices K121928 510(k) Number_
§ 878.3300 Surgical mesh.
(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.