(240 days)
The Biomet probes/guidewires and dilators are intended for tissue dilation and stimulation of peripheral nerves including spinal nerve roots for location and identification during spinal surgery.
The Biomet insulated probes/guidewires and dilators are intended to dilate tissue and be used as intraoperative neuromonitoring (IONM) stimulation accessories by connectially available IONM equipment for locating and identifying peripheral nerves including spinal nerve roots during spinal surgery. The Biomet insulated probes/guidewires have a length of 305mm, an exposed stimulation area of .167 cm², and an outer diameter of 2.6mm. The Biomet insulated dilators have a length ranging from 229mm to 254mm, an exposed stimulation are of .167 cm², an inner diameter ranging from 3.2mm to 9.8mm, and an outer diameter ranging from 5.8mm to 13.8mm.
This Biomet submission (K132373) is for nerve stimulation accessories (probes/guidewires and dilators), not for a device that relies on AI/ML. Therefore, the requested information elements related to AI/ML device performance (such as sample size for test set, number of experts, adjudication methods, MRMC studies, standalone performance, training set details, and ground truth establishment) are not applicable and are not present in this 510(k) summary.
The acceptance criteria and supporting studies for this device are focused on electrical and mechanical performance, as well as biocompatibility, to demonstrate substantial equivalence to previously cleared predicate devices.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Test/Evaluation | Acceptance Criteria (Implicit from Predicate Equivalence) | Reported Device Performance |
|---|---|---|---|
| Biocompatibility | Cytotoxicity | Non-cytotoxic (ISO 10993-5) | No evidence of cytotoxicity |
| Sensitization | Non-sensitizing (ISO 10993-10) | No evidence of sensitization | |
| Irritation | Non-irritant (ISO 10993-10) | No evidence of irritation | |
| Systemic Toxicity | No systemically toxic (ISO 10993-11) | No signs of toxicity | |
| Pyrogen Test | Non-pyrogenic | No signs of pyrogens | |
| Electrical Performance | Total Resistance | Equivalent to predicate devices | Results demonstrate equivalence |
| System Impedance | Equivalent to predicate devices | Results demonstrate equivalence | |
| Current Density | Equivalent to predicate devices | Results demonstrate equivalence | |
| Mechanical Performance | Mechanical Testing | Equivalent to predicate devices | Results demonstrate equivalence |
| Material Conformance | Wrought Stainless Steels | ASTM F899:2012 compliance | Device conforms to ASTM F899:2012 |
| Sterilization | Radiation Sterilization | AAMI/ANSVISO 11137-2:2006 compliance | Device conforms to AAMI/ANSVISO 11137-2:2006 |
| Ethylene Oxide Sterilization | ANSI/AAMI/ISO 11135-1:2007 compliance | Device conforms to ANSI/AAMI/ISO 11135-1:2007 | |
| Packaging | Performance Testing | ASTM D4169:2009 compliance | Device conforms to ASTM D4169:2009 |
2. Sample size used for the test set and the data provenance
The document does not specify the exact sample sizes for each bench test conducted (Total Resistance, System Impedance, Current Density, Mechanical/Electrical Testing) or for the biocompatibility tests. It states that "Biocompatibility testing was conducted" and "Bench testing was conducted," implying a sufficient number of samples were tested to gain confidence in the results, but the specific N is not provided. The data provenance is internal testing by Biomet Spine.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. The ground truth for this type of device (electrical stimulus and dilator) is based on objective measurements from bench testing and adherence to recognized standards, not subjective expert assessment of data like images or clinical outcomes.
4. Adjudication method for the test set
Not applicable. There was no expert adjudication process involved for the objective bench and biocompatibility testing. The outcomes are concrete measurements against defined standards or comparisons to predicate device performance.
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 device is not an AI/ML-driven diagnostic or assistive technology for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a physical medical instrument (probes/guidewires and dilators) used with commercially available neuromonitoring equipment during surgery. It does not have an "algorithm-only" or "standalone" performance in the AI/ML sense.
7. The type of ground truth used
The "ground truth" for this device's performance is established through:
- Objective Bench Test Measurements: Electrical properties (resistance, impedance, current density) and mechanical integrity were measured and compared to predicate devices' known performances and acceptable ranges.
- Biocompatibility Standards: Adherence to international standards like ISO 10993 (Cytotoxicity, Sensitization, Irritation, Systemic Toxicity, Pyrogenicity) where "ground truth" is defined by the absence of adverse biological reactions as per the standard's methodologies.
- Material and Sterilization Standards: Compliance with recognized ASTM and AAMI/ISO standards for materials and sterilization processes.
8. The sample size for the training set
Not applicable. This is not an AI/ML device requiring a training set.
9. How the ground truth for the training set was established
Not applicable. This is not an AI/ML device.
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MAR 2 7 2014
Image /page/0/Picture/1 description: The image shows the words "BIOMET SPINE" stacked on top of each other. The word "BIOMET" is in a larger, bolder font than the word "SPINE". The words are black and the background is white.
510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR § 807.92.
| Preparation Date: | March 24, 2014 | |
|---|---|---|
| Applicant/Sponsor: | Biomet Spine399 Jefferson RoadParsippany, NJ 07054 | |
| Contact Person: | Debra BingDirector, Regulatory AffairsPhone: 973-299-9300 x3964Fax: 973-887-1347 | |
| Trade name: | Biomet Probes/Guidewires and Dilators | |
| Device Class | Class II | |
| Common Name: | Nerve Stimulator | |
| Classification Name/Product Code | Surgical Nerve Stimulator/Locator - ETN PDQ | |
| Device Panel - Regulation No.: | Ear, Nose & Throat - 21 CFR 874.1820 |
Device Description:
· The Biomet insulated probes/guidewires and dilators are intended to dilate tissue and be used as intraoperative neuromonitoring (IONM) stimulation accessories by connectially available IONM equipment for locating and identifying peripheral nerves including spinal nerve roots during spinal surgery. The Biomet insulated probes/guidewires have a length of 305mm, an exposed stimulation area of .167 cm², and an outer diameter of 2.6mm. The Biomet insulated dilators have a length ranging from 229mm to 254mm, an exposed stimulation are of .167 cm², an inner diameter ranging from 3.2mm to 9.8mm, and an outer diameter ranging from 5.8mm to 13.8mm.
| Predicate Device | Company Name | 510(k) # |
|---|---|---|
| Cadwell Disposable Probes | Cadwell Labs Inc. | K103128 |
| Cadwell Disposable Probes | Cadwell Labs Inc. | K123589 |
| AVS® ARIA Neuromonitoring Probe & Dilators | Stryker Spine | K110419 |
| Stimulation/Dissection Instruments | Nuvasive Inc. | K112709 |
Indications for Use:
The Biomet probes/guidewires and dilators are intended for tissue dilation and stimulation of peripheral nerves including spinal nerve roots for location and identification during spinal surgery.
Summary of Technologies:
The proposed nerve stimulators are substantially equivalent to the predicate systems with respect to intended use and indications, materials, technological characteristics, and principles of operation. The predicate nerve stimulators are used with commercially available neuromonitoring equipment to deliver an electrical stimulus to locate peripheral and spinal nerve roots during spinal surgery. They are fabricated from similar biocompatible materials and are coated with an insulating material.
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Subtantial Equivalee:
The proposed probes/guident and dilizors are substantialy equily marked neves in unakted aceves in regards to
intended use, findamental technology, mar
| Substantial Equivalency Table | ||||
|---|---|---|---|---|
| Biomet Access System | Cadwell Disposable Probes | AVS® ARIA Neuromon. Probe & Dilators | Stimulation/Dissection Instruments | |
| Device Information | Subject Device | Predicate Device | Predicate Device | Predicate Device |
| Manufacturer | Biomet Spine (EBI LP) | Cadwell Labs, Inc. | Stryker Spine | Nuvasive, Inc |
| 510(k) Number | K132373Pending | K103128 / K123589 | K110419 | K112709 |
| Nerve Stimulation | ✓ | ✓ | ✓ | ✓ |
| Tissue dilation/dissection | ✓ | ✓ | ✓ | ✓ |
| Shaft Diameter | Ø2.6mm | Ø2.3mm | Ø2.1mm | n/a |
| Overall Length | 305mm | 215mm to 330mm | n/a | n/a |
| Electrical Connection | Passive | DIN | DIN | Passive |
| Monopolar | ✓ | ✓ | ✓ | ✓ |
| Outer Diameter | Ø5.8mm to Ø13.8mm | n/a | Ø6.4mm to Ø22.5mm | Ø6mm to Ø12mm |
| Inner Diameter | Ø3.2mm to Ø9.8mm | n/a | unknown | unknown |
| Overall Length | 229mm to 254mm | n/a | ~186mm to 206mm | unknown |
| Direct Electrical Connection | Passive | n/a | DIN | Passive |
| Monopolar | ✓ | n/a | ✓ | ✓ |
| Materials | ||||
| Stainless steel | ✓ | ✓ | ✓ | ✓ |
| Polymeric dielectric coating | ✓ | ✓ | ✓ | n/a |
| Plastic handle | ✓ | n/a | n/a | n/a |
| Sterility Information | ||||
| Sterile packed | ✓ | ✓ | ✓ | ✓ |
| Sold non-sterile | ✓ | ✓ | ✓ | ✓ |
| Principles of Operation | ||||
| Single use | ✓ | ✓ | ✓ | ✓ |
| Neuromonitoring during surgery | ✓ | ✓ | ✓ | ✓ |
| Tissue dilation/dissection during surgery | ✓ | ✓ | ✓ | ✓ |
| Uncoated Conducting Surface Area | .167 cm² | .167 cm² | unknown | unknown |
| Charge Density Average (max) | 6.21 µC/in² | 6.21 µC/in² | unknown | unknown |
| Current Density Average (max) | 6.21 mA/in² | 6.21 mA/in² | unknown | unknown |
n/a=not applicabl denotes substantial equivalence
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Biocompatibility:
Biocompatibility testing was conducted on the Biomet insulated probes/guidewires and dilators in accordance with the testing recommendations in ISO 10993-1 (Biological Evaluation of Medical Devices Part 1: Evaluation and Testing). The test results are summarized in the table below.
| Tests | Results | Conclusion |
|---|---|---|
| Cytotoxicity | No evidence of cytotoxicity | Non-cytotoxic |
| Sensitization | No evidence of sensitization | Non-sensitizing |
| Irritation | No evidence of irritation | Non-irritant |
| Systemic Toxicity | No signs of toxicity | No systemically toxic |
| Pyrogen Test | No signs of pyrogens | Non-pyrogenic |
As shown in the table, biocompatibility testing found the Biomet insulated probes/guidewires and dilators to be non-cytotoxic, non-irritant, non-sensitizing, no systemically toxic, and non-pyrogenic.
Performance Data:
Bench testing was conducted to demonstrate that the subject nerve stimulators are substantially equivalent to the predicate devices. The following bench testing was performed:
- . Total Resistance,
- . System Impedance,
- Current Density, and .
- Mechanical/Electrical Testing .
The results demonstrate that the subject nerve stimulators are equivalent the predicate device and do not raise any issues of safety or effectiveness. In addition, biocompatibility testing was conducted and has demonstrated that the subject nerve stimulators are biocompatible.
The Biomet probes/guidewires and dilators conform to the following standards:
Materials
ASTM F899:2012 - Standard Specification for Wrought Stainless Steels for Surgical Instruments (Recognition List 030, Recognition No. 332)
Sterilization
AAMI/ANSVISO 11137-2:2006 - Sterilization of Healthcare Products: Radiation- Part 2: Establishing Sterilization Dose (Recognition List 028, Recognition No. 14-225)
ANSI/AAMI ST79: 2010 & A1:2010 (Consolidated Text) - Comprehensive Guide to Steam Sterilization and Sterility Assurance in Health Care Facilities (Recognition List 027. Recognition No. 14-312)
AAMI TIR 30: 2003 - A Compendium of Processes, materials, Test Methods, and Acceptance Criteria for Cleaning Reusable Medical Devices (Note: This not a FDA recognized standard but it is considered a relevant standard.)
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ANSI/AAMI/ISO 11135-1:2007 - Sterilization of health care products - Ethylene oxide - Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices (Recognition List 028, Recognition No. 14-228)
Testing
ASTM D149: 2009 - Standard Test Method for Dielectric Breakdown Voltage and Dielectric Strength of Solid Electrical Insulating Materials at Commercial Power Frequencies (Not recognized)
ASTM D4169: 2009 - Standard Practice for Performance Testing of Shipping Containers and Systems (Recognition List 030, Recognition No. 14-300) 9-8 ASTM D5276: 1998 (2009) - Standard Test Method for Drop Test of Loaded Containers by Free Fall (Not recognized)
ASTM D999: 2008 - Standard Test Methods for Vibration Testing of Shipping Containers (Not recognized)
Biocompatibility
ISO 10993-5, Biological Evaluation of Medical Devices - Part 5: Tests for in vitro cytotoxicity
ISO 10993-10, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization
ISO 10993-11, Biological Evaluation of Medical Devices, Part 11: Tests for Systemic Toxicity
FDA Good Laboratory Practice (GLP) Regulations, 21 CFR 58
"ISO 10993-1. Biological Evaluation of Medical Devices, Part 1: Evaluation and Testing Within a Risk Management Process. 4tt ed. 2009-10-15"
Conclusion:
The subject devices are substantially equivalent to the predicates, when used in as tissue dilators and nerve stimulators. Mechanical and electrical testing along with other supporting information sufficiently demonstrates the substantial equivalence of the subject device to the other commercially available nerve stimulators. Based on this information, the subject devices do not raise any new issues regarding the safety or efficacy, when used to dilate tissue or as a nerve locator.
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Image /page/4/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 text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20903-0002
March 27, 2014
Biomet Spine Ms. Vivian Kelly Regulatory Affairs Project Manager 399 Jefferson Road Parsippany, New Jersey 07054
Re: K132373
Trade/Device Name: Biomet Access System Regulation Number: 21 CFR 874.1820 Regulation Name: Neurosurgical Nerve Locator Regulatory Class: Class II Product Code: PDQ Dated: 2/6/2014 Received: 2/7/2014
Dear Ms. Kelly:
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 mislcading.
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 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practive requirements as set
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Page 2 - Ms. Vivian Kelly
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 contact the Division of Small Manufacturers. International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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,
Joyce M. Whang -S
for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Slatement on last page.
510(k) Number (if known) K132373
Device Name
Biomet Probes/Guidewires and Dilators
Indications for Use (Describe)
The Biomet probestguidewires and dilators are intended for tissue dilation of peripheral nerves including spinal nerve roots for location and identification during spinal surgery.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
[] Over-The-Counter Use (21 CFR 801 Subpart C)
Please do not write below this line – continue on a separate page if needed.
FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signalure)
FORM FDA 3881 (1/14)
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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
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§ 874.1820 Surgical nerve stimulator/locator.
(a)
Identification. A surgical nerve stimulator/locator is a device that is intended to provide electrical stimulation to the body to locate and identify nerves and to test their excitability.(b)
Classification. Class II.