The implantable device Elite SPK is intended for the attachment of soft tissue to bone during arthroscopic or open treatment of rotator cuff tears. It is intended to be implanted using the Compasso surgical instruments.

Compasso is a series of surgical instruments intended for use for the implantation of the Elite SPK or the Sharc-FT bone anchor.

Device Description

The Elite SPK is an implantable bone anchor device designed to ensure the fixation of soft tissues (especially tendons) to bone, during the repair of injuries to the shoulder performed with open or arthroscopic technique. The implantable anchor is made of polyether ether ketone (PEEK), and allows the surgeon to attach the injured tendon to the humerus using a transosseous "double row" technique. The ELITE SPK anchor is suitable for a 3 mm in diameter hole, and is provided sterile for single use.

The Compasso is a series of manual surgical instruments to implant the Elite SPK. Instruments in contact with human body are made of Stainless Steel in conformity with ISO 5832-1, while other components not in contact with the patient are made of stainless steel, aluminum and laser sintering polyamide.

The Elite SPK may be provided in a kit form with sutures for physician convenience. The sutures are provided in their final, sterile form in the original packaging from the manufacturer. FDA has previously cleared the provided sutures in 510(k) application K100006; specifically, the kit includes the HS Fiber Sutures.

AI/ML Overview

This document is a 510(k) Pre-market Notification for the Elite SPK, Compasso, and Elite SPK Kit, seeking clearance from the U.S. Food and Drug Administration (FDA). This notification declares the substantial equivalence of the new device to previously cleared predicate devices.

Here's an analysis of the provided information concerning acceptance criteria and supporting studies:

Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria	Reported Device Performance
Sterilization	The sterilization cycles have been validated following international standards. (Implied acceptance: device is terminally sterilized and meets sterility assurance level standards).
Shelf Life	The shelf life of the devices has been established through stability studies. (Implied acceptance: device maintains its properties and safety over its declared shelf life).
Biocompatibility	Biocompatibility evaluation has been performed to show the device materials are safe, biocompatible and suitable for their intended use. Both ISO 10993 and FDA Draft Guidance "Use of International Standard ISO 10993. Biological Evaluation of Medical Devices Part 1: Evaluation and Testing" have been taken into account. (Implied acceptance: materials are non-toxic, non-irritating, non-sensitizing, etc., as per ISO 10993 standards for medical devices in contact with tissue).
Fixation Strength (Elite SPK)	Performance testing was performed to evaluate the fixation strength of the Elite SPK compared to the predicate device. These tests showed that the Elite SPK has adequate fixation strength and is comparable to the predicate devices. (Implied acceptance: fixation strength is non-inferior to or demonstrably equivalent to the predicate device, meeting clinically relevant biomechanical requirements for soft tissue to bone attachment).
Functional Equivalence (Compasso instruments)	Implied (but not explicitly stated as a quantified acceptance criterion): The Compasso instruments are intended for use with the Elite SPK or Sharc-FT bone anchor, suggesting functionality and usability for their intended purpose. The substantial equivalence argument relies on their ability to implant the Elite SPK similar to how instruments implant the predicate.

Sample Size Used for the Test Set and Data Provenance

The document does not specify the sample size used for any of the performance tests (sterilization, shelf life, biocompatibility, or fixation strength). The data provenance (e.g., country of origin, retrospective/prospective) is also not mentioned. These details would typically be found in the technical reports for each test, which are summarized here.
Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts

This type of information is not applicable to the performance tests described for this device. The tests are primarily engineering, materials science, and biological safety evaluations, not diagnostic accuracy studies that require expert-established ground truth.
Adjudication Method for the Test Set

Not applicable for the engineering and biological safety tests performed.
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No, a MRMC comparative effectiveness study was not done. This type of study is typically performed for diagnostic devices or AI algorithms where human interpretation is involved. The Elite SPK and Compasso are surgical implants and instruments, respectively, and thus do not involve human readers interpreting cases.
Standalone Performance (Algorithm Only without Human-in-the-Loop Performance)

Not applicable. This device is not an algorithm or AI-driven system. Its performance is related to its physical and material properties and its function in a surgical context, with a human surgeon always in the loop.
Type of Ground Truth Used

The "ground truth" for the tests mentioned would be based on:
- Sterilization: Established international standards (e.g., ISO 11137 series for radiation sterilization, ISO 17665 series for moist heat sterilization).
- Shelf Life: Real-time or accelerated aging studies with defined acceptance criteria for physical, chemical, and functional properties over time.
- Biocompatibility: In vitro and in vivo testing endpoints defined by ISO 10993 standards (e.g., cytotoxicity, sensitization, irritation, systemic toxicity, genotoxicity, implantation effects).
- Fixation Strength: Biomechanical testing protocols (e.g., cyclic loading, pull-out strength, stiffness) with acceptance criteria often established relative to predicate devices or clinically accepted performance benchmarks.
Sample Size for the Training Set

Not applicable. This is not a machine learning or AI device that requires a training set.
How the Ground Truth for the Training Set Was Established

Not applicable. As mentioned above, this is not an AI/ML device.

Summary

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

April 20, 2016

NCS Lab Srl % Christine Brauer. Ph.D. Regulatory Affairs Consultant Brauer Device Consultants, LLC 7 Trail House Court Rockville, Maryland 20850

Re: K160500

Trade/Device Name: Elite SPK. Compasso. Elite SPK Kit Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI Dated: February 22, 2016 Received: February 23, 2016

Dear Dr. Brauer:

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 CFR Part 807); labeling (21 CFR Parts 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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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 Industry and Consumer Education 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. 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 Industry and Consumer Education 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,

Lori A. Wiggins -S

for

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

Enclosure

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Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K160500

Device Name Elite SPK, Elite SPK Kit and Compasso

Indications for Use (Describe)

Compasso is a series of surgical instruments intended for use for the Elite SPK or the Sharc-FT bone anchor.

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) (Signature)

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510(k) SUMMARY OF SAFETY AND EFFECTIVENESS

1 GENERAL INFORMATION

Submitter and Owner of the 510(k) Application 1.1

NCS Lab Srl Via Pola Esterna 4/12 Carpi (MO), Italy 41012

1.2 Official Correspondent

Christine L. Brauer, PhD Regulatory Affairs Consultant Brauer Device Consultants, LLC 7 Trail House Court Rockville, MD 20850

Telephone: (301) 545-1990 Fax: (301) 545-1992 E-mail: chris.brauer(@comcast.net

Devices Subject of this 510(k) 1.3

Elite SPK Compasso Elite SPK Kit

Date of Preparation 1.4

April 18, 2016

2 NAME OF THE DEVICE AND CLASSIFICATION INFORMATION

Trade/Proprietary Name 2.1

This 510(k) application is for the following devices:

Elite SPK, a sterile, single-use implantable suture anchor;
. Compasso, a series of reusable surgical instruments used to implant the Elite SPK; and,
. Elite SPK Kit, a sterile, single-use implantable suture anchor and sutures.

2.2 Common/Usual Name

Bone Anchor

Orthopedic Manual Surgical Instruments to Implant the Bone Anchor

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2.3 Classification Information

Classification Name:	Smooth or Threaded Metallic Bone Fixation Fastener
Classification Regulation:	888.3040
Regulatory Class:	II
Product Code:	MBI – Fastener, Fixation, Nondegradable, Soft Tissue
Panel:	Orthopedic

3 PREDICATE DEVICE

The predicate device is as follows:

. NCS Lab Srl's NCS Sharc FT System, which was cleared through 510(k) application K120356.
The following reference device was considered in analysis of the technological characteristics of the device materials and certain design aspects.
. Reference device for discussion of device materials and partially threaded design: Quattro Link Knotless Anchors, manufactured by Cayenne Medical, and cleared via K122314
The Elite SPK may be provided in a kit form with sutures. The sutures have previously received clearance from FDA (Riverpoint Medical Force Fiber, K100006), and are provided in their final, sterilized form to NCS Lab Srl.

DEVICE DESCRIPTION 4

1 The tradename of the device was changed from the NCS Fish-Fit MD System to the NCS Sharc FT System after clearance.

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ഗ INDICATION FOR USE

The indication for use statement is provided below.

Compasso is a series of surgical instruments intended for use for the implantation of the Elite SPK or the Sharc-FT bone anchor.

COMPARISON OF THE INTENDED USE WITH THE PREDICATE DEVICE 6

The Elite SPK and the predicate device share the same intended use. Both devices are intended for use during arthroscopic or open surgeries to repair rotator cuff injuries. Both devices serve the same primary function: namely, to secure the tendons to the bone during healing. Both devices are used by the same health care professionals (orthopedic surgeons) in the same target patient population: adults who require surgical repair of rotator cuff injuries. Both devices are implanted into a cavity drilled into the bone, are implanted using the same surgical instruments and remain implanted in the bone.

COMPARISON OF THE TECHNOLOGICAL CHARACTERISTICS WITH THE 7 PREDICATE DEVICE

The Elite SPK and the predicate share certain technological features, but also have some differences. The primary difference between the Elite SPK and the Sharc FT are in materials and design. The Elite SPK is made from polyether ether ketone (PEEK) whereas the Sharc FT is made of titanium. The Elite SPK incorporates a screw type design with a wider contact head and partially threaded (referred to as side flaps or wings), whereas the Sharc FT consists of a deformable U-shape body design. Both devices have heads with eyelets to pass sutures.

Other bone anchors are made from PEEK and are available in a variety of designs included "threaded" (either full or partially) or "smooth" screw-shape designs. One such bone anchor, the, Quattro Link Knotless Anchors, manufactured by Cayenne Medical, and cleared via K 122314, is cited here as a reference predicate device for materials and general design shape.

8 PERFORMANCE DATA

This 510(k) submission provided performance data to establish the substantial equivalence of the Elite SPK and Compasso to the predicate devices. The following is a summary of the performance data.

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Sterilization and Shelf Life: The devices are sterilized using standard methods and the sterilization cycles have been validated following international standards. The shelf life of the devices has been established through stability studies.

Biocompatibility: Biocompatibility evaluation has been performed to show the device materials are safe, biocompatible and suitable for their intended use. Both ISO 10993 and FDA Draft Guidance "Use of International Standard ISO 10993. Biological Evaluation of Medical Devices Part 1: Evaluation and Testing" have been taken into account to evaluate the biocompatibility of the device materials.

Performance Testing: Performance testing was performed to evaluate the fixation strength of the Elite SPK compared to the predicate device. These tests showed that the Elite SPK has adequate fixation strength and is comparable to the predicate devices.

The performance data demonstrate that the Elite SPK and Compasso are substantially equivalent to the predicate devices.

Regulation Number and Section

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.