(32 days)
Quill™ PDO Knotless Tissue-Closure Device comprised of Polydioxanone, is indicated for soft tissue approximation where use of an absorbable suture is appropriate.
The Quill™ PDO Knotless Tissue-Closure Device, Variable Loop Design (Polydioxanone) is a sterile, synthetic absorbable tissue-closure device that is intended for use in the closure of soft tissue. It is comprised of polyester [poly (p-dioxanone)], dyed with D&C Violet No. 2. The instrument is designed with small uni-directional barbs along the long axis of the suture monofilament which contains a welded primary loop and secondary loop design at the distal end. It is available in diameter Size 2 through 3-0 in various lengths affixed to various needle types.
The provided document is a 510(k) summary for a medical device, specifically a surgical suture. It describes the device, its intended use, and its substantial equivalence to predicate devices based on non-clinical laboratory performance testing. This type of regulatory submission does not typically include a clinical study with elements like human readers, ground truth consensus, or AI assistance as it's for a physical medical device, not a diagnostic algorithm.
Therefore, many of the requested categories are not applicable to the information contained within this 510(k) submission.
Here's a breakdown of the available information:
1. Table of Acceptance Criteria and Reported Device Performance
The submission refers to the USP monograph for absorbable sutures and FDA's Class II Special Controls Guidance Document: Surgical Sutures, Issued June 3, 2003 as the acceptance criteria. The specific quantitative acceptance criteria (e.g., minimum tensile strength values) are not provided in this summary.
| Acceptance Criteria (Standards referred to) | Reported Device Performance |
|---|---|
| USP monograph for absorbable sutures: | "The results of this testing demonstrates that the Quill™ PDO Knotless Tissue-Closure device, Variable Loop Design (Polydioxanone), is substantially equivalent to the predicate device." (Specific quantitative performance metrics against USP standards are not provided in this summary.) |
| - Tensile strength (as applicable) | |
| - Needle attachment | |
| FDA's Class II Special Controls Guidance Document: Surgical Sutures (June 3, 2003) | |
| In vitro post-hydrolysis tensile testing |
2. Sample size used for the test set and the data provenance:
This document describes non-clinical laboratory performance testing. It does not mention a "test set" in the context of human or patient data. The testing was likely performed on the suture devices themselves in a laboratory setting. No information on the number of devices tested or data provenance (country of origin, retrospective/prospective) for these laboratory tests is provided in this summary.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable. This is a non-clinical, laboratory-based study of a physical medical device. No expert ground truth establishment for a test set is mentioned.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
Not applicable. This is a non-clinical, laboratory-based study.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
Not applicable. This is a non-clinical study for a surgical suture and does not involve human readers, AI, or comparative effectiveness in a diagnostic imaging context.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
Not applicable. This submission relates to a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for the non-clinical testing of a surgical suture would be defined by the specific measurement standards and methodologies outlined in the USP monograph and FDA guidance documents for tensile strength, needle attachment, and post-hydrolysis performance. These are objective, quantifiable criteria.
8. The sample size for the training set:
Not applicable. There is no training set mentioned, as this is laboratory testing of a physical product, not a machine learning model.
9. How the ground truth for the training set was established:
Not applicable. As there is no training set, there is no ground truth for a training set to be established.
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510(k) Summary
| Date Prepared: | July 19, 2013 | ||
|---|---|---|---|
| Company: | Surgical Specialties Corporation, dba Angiotech100 Dennis Dr.Reading, PA 19606 | ||
| Contact: | Kirsten StowellRegulatory Affairs ManagerPhone: 610-404-3367Fax: 610-404-3924Email: kstowell@angio.com | AUG 2 3 2013 | |
| Device trade name: | Quill™ PDO Knotless-Tissue Closure Device, Variable LoopDesign (Polydioxanone) | ||
| Device Common Name: | Polydioxanone Absorbable Surgical Suture | ||
| Device classification: | Absorbable polydioxanone surgical sutureProduct code, NEW21 CFR 878.4840Class II | ||
| Legally marketeddevice to which thedevice is substantiallyequivalent: | K113744 | Quill™ PDO Knotless Tissue-Closure Device,Variable Loop Design, Size -0- | |
| K123877 | Quill™ PDO Knotless Tissue-Closure Device,Variable Loop Design, Size 2-0 and 3-0 | ||
| Description of thedevice: | The Quill™ PDO Knotless Tissue-Closure Device, Variable LoopDesign (Polydioxanone) is a sterile, synthetic absorbable tissue-closure device that is intended for use in the closure of soft tissue.It is comprised of polyester [poly (p-dioxanone)], dyed with D&CViolet No. 2. The instrument is designed with small uni-directional barbs along the long axis of the suture monofilamentwhich contains a welded primary loop and secondary loop designat the distal end. It is available in diameter Size 2 through 3-0 invarious lengths affixed to various needle types. | ||
| Indications for Use: | Quill™ PDO Knotless Tissue-Closure Device comprised ofPolydioxanone is indicated for soft tissue approximation whereuse of an absorbable suture is appropriate. |
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K132268 p. 2 of 2
Substantial Equivalence: The QuillTM Knotless Tissue-Closure Device, Variable Loop Design (Polydioxanone) has the same design and materials as the Ouill™ PDO Knotless Tissue-Closure Device predicate device, including the same intended use and technological characteristics as the predicate device. The only difference between the proposed and predicate device is the suture diameter.
Non-clinical laboratory performance testing was conducted to Performance tests: confirm that the Quill™ PDO Knotless Tissue-Closure device, Variable Loop Design (Polydioxanone), conforms to the USP monograph for absorbable sutures for tensile strength (as applicable) and needle attachment. This testing was performed in accordance with FDA's Class II Special Controls Guidance Document: Surgical Sutures, Issued June 3, 2003. Additional performance testing was conducted in order to demonstrate substantial equivalence to the predicate device including in vitro post-hydrolysis tensile testing.
The results of this testing demonstrates that the QuillTM PDO Knotless Tissue-Closure device, Variable Loop Design (Polydioxanone), is substantially equivalent to the predicate device.
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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three lines representing its wings and body. The eagle is enclosed in a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
August 23, 2013
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
Kirsten Stowell Regulatory Affairs Manager Surgical Specialties Corporation, dba Angiotech 100 Dennis Drive Reading, Pennsylvania 19606
Re: K132268
Trade/Device Name: Ouill PDO Knotless-Tissue Closure Device, Variable Loop Design (Polydioxanone) Regulation Number: 21 CFR 878.4840 Regulation Name: Absorbable polydioxanone surgical suture Regulatory Class: Class II Product Code: NEW Dated: July 26, 2013 Received: July 29, 2013
Dear Ms. Stowell:
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
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Page 2 - Kirsten Stowell
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/ucm 1 1 5809.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.
Mark N. Melkerson -S
Mark N. Melkerson Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Section 4 - Indications for Use Statement
K132268 510k number if known:
QuillTM PDO Knotless Tissue-Closure Device, Variable Loop Design
Polydioxanone
Indications for Use:
Device Name:
Quill™ PDO Knotless Tissue-Closure Device comprised of Polydioxanone, is indicated for soft tissue approximation where use of an absorbable suture is appropriate.
Prescription Use × (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)
Jiyoung Dang -S
(Division Sign-Off) Division of Surgical Devices 510(k) Number: K132268
Quill™ PDO Device Special 510(k)
CONFIDENTIAL
§ 878.4840 Absorbable polydioxanone surgical suture.
(a)
Identification. An absorbable polydioxanone surgical suture is an absorbable, flexible, sterile, monofilament thread prepared from polyester polymer poly (p-dioxanone) and is intended for use in soft tissue approximation, including pediatric cardiovascular tissue where growth is expected to occur, and ophthalmic surgery. It may be coated or uncoated, undyed or dyed, and with or without a standard needle attached.(b)
Classification. Class II (special controls). The special control for the device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.