K Number
K170767
Device Name
Surgical Stainless Steel Suture, Stainless Steel Suture
Manufacturer
Date Cleared
2017-11-01

(232 days)

Product Code
Regulation Number
878.4495
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Stainless Steel Suture is indicated for use in abdominal wound closure, hernia repair, sternal closure and orthopaedic procedures including cerclage and tendon repair.
Device Description
Stainless Steel Suture is a sterile monofilament or multifilament, non-absorbable sterile surgical suture composed of 316L stainless steel. The suture is also available coated with polyethylene. Stainless Steel Suture is available in a range of gauge sizes and lengths, non-needled or attached to needles of various types and sizes. Stainless Steel Suture complies with the requirements of the European Pharmacopoeia (Ph. Eur.) for Sterile Non-Absorbable Strands and the United States Pharmacopoeia (USP) for Non Absorbable Surgical Sutures. The European Pharmacopoeia recognizes units of measure Metric and Ph. Eur. sizes as equivalent which is reflected on the labeling. Stainless Steel Suture elicits a minimal acute inflammatory reaction in tissue and is not absorbed. Implantation studies in animals show that no significant change in the retention of tensile strength of the suture occurs during the lifetime of the implantation.
More Information

K946173, Pre-amendment Device

Not Found

No
The 510(k) summary describes a standard surgical suture and does not mention any AI or ML components. The performance studies focus on material properties and standard medical device testing.

No.
The device is a surgical suture used for wound closure and repair, not for treating or curing a disease or condition.

No

Explanation: The device is a surgical suture used for wound closure and repairs, which is a therapeutic function, not a diagnostic one.

No

The device description clearly states it is a physical surgical suture made of stainless steel, not software. The performance studies also focus on physical properties and testing of the suture material.

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

Here's why:

  • Intended Use/Indications for Use: The intended use clearly describes the device's application in surgical procedures for wound closure, hernia repair, sternal closure, and orthopedic procedures. These are all in vivo applications, meaning they are used within the living body.
  • Device Description: The description details a surgical suture made of stainless steel, designed to be implanted in the body.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue samples, etc.) to provide information for diagnosis, monitoring, or screening.

IVD devices are specifically designed for testing in vitro (outside the living body) on biological samples. This device is a surgical implant used in vivo.

N/A

Intended Use / Indications for Use

Stainless Steel Suture is indicated for use in abdominal wound closure, hernia repair, sternal closure and orthopaedic procedures including cerclage and tendon repair.

Product codes

GAQ

Device Description

Stainless Steel Suture is a sterile monofilament or multifilament, non-absorbable sterile surgical suture composed of 316L stainless steel. The suture is also available coated with polyethylene. Stainless Steel Suture is available in a range of gauge sizes and lengths, non-needled or attached to needles of various types and sizes. Stainless Steel Suture complies with the requirements of the European Pharmacopoeia (Ph. Eur.) for Sterile Non-Absorbable Strands and the United States Pharmacopoeia (USP) for Non Absorbable Surgical Sutures. The European Pharmacopoeia recognizes units of measure Metric and Ph. Eur. sizes as equivalent which is reflected on the labeling.

Stainless Steel Suture elicits a minimal acute inflammatory reaction in tissue and is not absorbed. Implantation studies in animals show that no significant change in the retention of tensile strength of the suture occurs during the lifetime of the implantation.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Abdomen, Sternum

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)

Performance Data: The proposed device is identical with the predicate device in respect to technological characteristics. No changes to material, construction, design or specifications. Only device labeling is updated to reflect MRI safety information, updated "How Supplied" section and additional compliance to European Pharmacopeia requirement for non absorbable sutures per "Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Surgical Sutures".

The following Bench/Design Verification activities were performed on Stainless Steel Suture in compliance with design control requirements per 820.30 to demonstrate the continued conformance to respective FDA recognized standards for the proposed device:

Sutures - Needle Attachment per U.S.P. Tensile Strength per U.S.P. Sutures - Diameter per U.S.P.

Sterilization and Biocompatibility testing

EO residual testing per AAMI/ANSI/ISO 10993-7 Biological Evaluation of Medical devices. Pyrogenicity testing - Bacterial Endotoxin Test (BET) per ANSI/AAMI ST72:2011- Bacterial Endotoxins - Test Methods, routine monitoring and alternatives to batch testing USP Transfusion and Infusion Assemblies and Medical Devices Bacterial Endotoxin Testing (BET) as defined in USP

MRI specific Testing:

Magnetic field interactions at 3-Tesla considering worst case for magnetic field interactions: Deflection Angle test for Translational Attraction and Qualitative Assessment of Torque MRI-related Heating, 1.5-Tesla and 3.0 Tesla MR Image Artifacts at 3-Tesla considering worst case for artifacts

Above MRI tests are in compliance with below ASTM Standards: F2503 Standard Practice for Marking Medical Devices and Other Items for Safety in the Magnetic Resonance Environment F2052 Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the Magnetic Resonance Environment F2119 Test Method for Evaluation of MR Image Artifacts from Passive Implants F2182 Test Method for Measurement of Radio Frequency Induced Heating On or Near Passive Implants during Magnetic Resonance Imaging F2213 Test Method for Measurement of Magnetically Induced Torque on Medical Devices in the Magnetic Resonance Environment

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K946173, Pre-amendment Device

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.4495 Stainless steel suture.

(a)
Identification. A stainless steel suture is a needled or unneedled nonabsorbable surgical suture composed of 316L stainless steel, in USP sizes 12-0 through 10, or a substantially equivalent stainless steel suture, intended for use in abdominal wound closure, intestinal anastomosis, hernia repair, and sternal closure.(b)
Classification. Class II (special controls). The device, when it is a steel monofilament suture that is uncoated and does not incorporate barbs, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 878.9. The special control for this 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.

0

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

November 1, 2017

Ethicon Incorporated Mr. Hrishikesh Khatav, RAC Senior Regulatory Affairs Specialist U.S. Route 22 West, P.O. Box 151 Somerville, New Jersey 08876-0151

Re: K170767

Trade/Device Name: Stainless Steel Suture Regulation Number: 21 CFR 878.4495 Regulation Name: Stainless Steel Suture Regulatory Class: Class II Product Code: GAQ Dated: March 13, 2017 Received: March 14, 2017

Dear Mr. Khatav:

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 Part 801); medical device reporting (reporting of medical devicerelated 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.

1

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 (DICE) 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 (DICE) 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,

David Krause -S

for

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Form Approved: OMB No. 0910-0120

Expiration Date: January 31, 2017 See PRA Statement below.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) к170767

Device Name Stainless Steel Suture

Indications for Use (Describe)

mainless Steel Suture is indicated for use in abdominal wound closure, hernia repair, sternal closure and orthopaedic procedures including cerclage and tendon repair.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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510(k) SUMMARY

| Sponsor: | ETHICON, Inc.
P.O. Box 151
Route 22 West
Somerville, New Jersey 08876 |
|-----------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Hrishikesh Khatav, RAC
ETHICON, Inc.
P.O. Box 151
Route 22 West
Somerville, New Jersey 08876
Phone: 908-218-2348
Fax: 908-218-2595
Email: hkhatav@its.jnj.com |
| Date of Submission: | March 13, 2017 |
| Trade/ Proprietary
Name: | Stainless Steel Suture |
| Common Name: | Surgical Stainless Steel Suture
Suture, Non-absorbable, Steel, Monofilament and Multifilament,
Sterile |
| Regulation Number: | 21 CFR 878.4495 |
| Regulatory Class: | II |
| Product Code: | GAQ |
| Predicate Devices: | Surgical Stainless Steel Suture; K946173, cleared January 9, 1995; Labeling Changes for Generic Suture Types, by Ethicon, Inc., Surgical Stainless Steel Suture; Pre-amendment Device by Ethicon, Inc.; marketed prior to May 28, 1976 |
| Device Description: | Stainless Steel Suture is a sterile monofilament or multifilament, non-
absorbable sterile surgical suture composed of 316L stainless steel.
The suture is also available coated with polyethylene. Stainless Steel
Suture is available in a range of gauge sizes and lengths, non-needled
or attached to needles of various types and sizes. Stainless Steel Suture
complies with the requirements of the European Pharmacopoeia (Ph.
Eur.) for Sterile Non-Absorbable Strands and the United States
Pharmacopoeia (USP) for Non Absorbable Surgical Sutures. The
European Pharmacopoeia recognizes units of measure Metric and Ph.
Eur. sizes as equivalent which is reflected on the labeling. |
| | Stainless Steel Suture elicits a minimal acute inflammatory reaction in
tissue and is not absorbed. Implantation studies in animals show that no
significant change in the retention of tensile strength of the suture
occurs during the lifetime of the implantation. |
| Indications for Use: | Stainless Steel Suture is indicated for use in abdominal wound closure,
hernia repair, sternal closure and orthopaedic procedures including
cerclage and tendon repair. |
| Contraindications: | The use of this suture is contraindicated in patients with known
sensitivities or allergies to 316L stainless steel, or constituent metals
such as chromium and nickel |
| Summary of
Technological
Characteristics of
Proposed Device to
Predicate- Labeling
changes only: | The principle of operation and fundamental scientific technology of the
proposed device are equivalent to the predicate device. The
performance modification was accomplished via testing in MRI
environment and update labeling per FDA guidance "Establishing
Safety and compatibility of Passive implants in the Magnetic
Resonance (MR) environment" dated December 11, 2014. |

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A comparison between the proposed and the predicate device is given below

Predicate DeviceProposed Device
510(k)
NumberK946173K170767
Product
CodeGAQSame
Regulation21 CFR 878.4495Same
AbsorbableNoSame
Trade
NameSurgical Stainless Steel
SutureStainless Steel Suture
Intended
UseSurgical Stainless Steel
Suture is indicated for use
in abdominal wound
closure, hernia repair,
sternal closure and
orthopaedic procedures
including cerclage and
tendon repair.Same
Contraindic
ationThe use of this suture is
contraindicated in
patients with known
sensitivities or allergies to
316L stainless steel, or
constituent metals such as
chromium and nickelSame
MRI Safety
Information
in
Warnings
SectionN/AImage: MR Conditional symbol
MR Conditional
Non-clinical testing has
demonstrated that
Stainless Steel Suture is
MR Conditional. A patient
with this device can be
safely scanned in an MR
system meeting the
following conditions:
• Static magnetic field of
1.5 T or 3.0 T
• Maximum spatial field
gradient of 2000 gauss/cm
(20 T/m)
• Maximum MR system
reported, whole body
averaged specific
absorption rate (SAR) of 1
W/kg
• Under the scan
conditions defined, the
Stainless Steel Suture is
expected to produce a
maximum temperature
rise of less than 4.5°C
after 15 minutes of
continuous scanning,
using RF coils running in
quadrature mode.
In non-clinical testing, the
image artifact caused by
the Stainless Steel Suture
extends approximately 20
mm from the device when
imaged with a gradient
echo pulse sequence and a
2.0 T MRI system.
How
SuppliedSurgical Stainless steel
sutures are available in
sizes 10-0 through 7
(metric sizes 0.2 -9.0) in a
variety of lengths with
and without permanently
attached needles in one,
two and three dozen
boxes.Stainless steel sutures are
available in sizes 5-0
through 7 (metric sizes 1.0
  • 9.0) in a variety of
    lengths with and without
    permanently attached
    needles in one, two and
    three dozen boxes. |
    | Color | Undyed | Same |
    | Material | 316L Stainless Steel | Same |
    | Sterilization | Sterilized by Gamma
    Irradiation OR Ethylene
    Oxide | Same |
    | Packaging | Surgical Stainless Steel
    Suture is packaged in
    paper folders. The folders
    are packaged in
    poly/paper and/or
    poly/Tyvek overwraps.
    The overwraps are then
    packed into cartons with
    IFU's. The cartons are
    then wrapped with a film
    or closed with a security
    label. | Same |
    | U.S.P.
    continued
    Compliance
    Additional
    Compliance
    to
    European
    Pharmacop
    eia | Surgical Stainless steel
    suture complies with all
    the requirements of the
    United States
    Pharmacopoeia U.S.P.
    Monograph 861, 871 and
    881 for Non Absorbable
    Surgical Sutures | Stainless Steel Suture
    complies with all the
    requirements of the
    European Pharmacopoeia
    (Ph. Eur.) for Sterile Non-
    Absorbable Strands and
    the United States
    Pharmacopoeia (U.S.P.)
    Monograph 861, 871 and
    881 for non-absorbable
    surgical sutures. |

Table 1: Device Comparison Table

5

6

Performance Data: The proposed device is identical with the predicate device in respect to technological characteristics. No changes to material, construction, design or specifications. Only device labeling is updated to reflect MRI safety information, updated "How Supplied" section and additional compliance to European Pharmacopeia requirement for non

7

absorbable sutures per "Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Surgical Sutures".

The following Bench/Design Verification activities were performed on Stainless Steel Suture in compliance with design control requirements per 820.30 to demonstrate the continued conformance to respective FDA recognized standards for the proposed device:

Sutures - Needle Attachment per U.S.P. Tensile Strength per U.S.P. Sutures - Diameter per U.S.P.

Sterilization and Biocompatibility testing

EO residual testing per AAMI/ANSI/ISO 10993-7 Biological Evaluation of Medical devices. Pyrogenicity testing - Bacterial Endotoxin Test (BET) per ANSI/AAMI ST72:2011- Bacterial Endotoxins - Test Methods, routine monitoring and alternatives to batch testing USP Transfusion and Infusion Assemblies and Medical Devices Bacterial Endotoxin Testing (BET) as defined in USP

MRI specific Testing:

Magnetic field interactions at 3-Tesla considering worst case for magnetic field interactions: Deflection Angle test for Translational Attraction and Qualitative Assessment of Torque MRI-related Heating, 1.5-Tesla and 3.0 Tesla MR Image Artifacts at 3-Tesla considering worst case for artifacts

Above MRI tests are in compliance with below ASTM Standards: F2503 Standard Practice for Marking Medical Devices and Other Items for Safety in the Magnetic Resonance Environment F2052 Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the Magnetic Resonance Environment F2119 Test Method for Evaluation of MR Image Artifacts from Passive Implants F2182 Test Method for Measurement of Radio Frequency Induced Heating On or Near Passive Implants during Magnetic Resonance Imaging F2213 Test Method for Measurement of Magnetically Induced Torque on Medical Devices in the Magnetic Resonance Environment

Conclusions: For the purposes of determining substantial equivalence per FD&C Act Section 510(k), the proposed device is compared with the same device and design that is currently being marketed. The proposed Stainless

8

Steel Suture is identical to the legally marketed predicate device. Surgical Stainless Steel Suture except for labeling and trade name modifications. The modification does not change the intended use or the fundamental scientific technology. The proposed device uses the same operating principle, incorporates the same basic design and is packaged, manufactured and sterilized using the same materials and processes.

In summary, the Stainless Steel Suture described in this submission is, in our opinion, substantially equivalent to the predicate device which is legally marketed, by Ethicon, Inc. class II device with FDA product code (GAQ), regulatory definition (21 CFR 878.4495) and intended use.