K Number
K181845
Device Name
Pivot System Sterilization case
Manufacturer
Date Cleared
2019-11-25

(502 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The RP Medical Pivot System Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Pivot System surgical instruments within a healthcare facility when used in conjunction with a legally marketed, validated, FDA-cleared sterilization wrap for use in healthcare facilities in order to maintain sterility of the enclosed devices. The Pivot System Sterilization Tray System has been validated for use in the following sterilization cycles: Enclosure Pivot System Sterilization Tray Cycle Pre-Vacuum 132°C (270°F) Temperature Sterilization Time 4 minutes Pressure 2-15 PSIA Minimum Dry Time 30 minutes in chamber The maximum validated product loads for the trays in containers are as follows: 2-Level Rack, Level 2, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 3 each 39.1960.02, RP OST Tool Rod, 3 each 39.1960.51.01, RP OST Tool 1D RH 16mm, 1 each 39.1960.51.02 RP OST Tool 1D RH 22mm, 1 each 39.1960.20.01 RP OST Angle 162mm, 1 each 39.1960.20.02 RP OST Angle 19mm, 1 each 39.1960.20.03 RP OST Angle 21.5mm , 1 each 39.1960.40.01 RP TM Spike Blade, 1 each 39.1960.60.01 OST Reverse Blade 11mm, 1 each 39.1960.60.02 OST Reverse Blade 16mm, 1 each 39.1960.30.01 RP OST Tool Curve 16mm, 1 each 39.1960.30.02 RP OST Tool Curve 19mm, 1 each 39.1960.30.03 RP OST Tool Curve 21.5mm, 1 each 39.1960.10.01 RP OST Straight 20mm, 1 each 39.1960.10.02 RP OST Straight 40mm, 1 each 39.1960.10.03 RP OST Straight 43mm, 1 each 39.1960.10.04 RP OST Straight 47.5mm, 1 each 39.1960.52.01, RP OST Tool 1D LH 16mm, 1 each 39.1960.52.02 RP OST Tool 1D LH 22mm, 1 each 2-Level Rack - Level 1, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 1 each 39.1960.02, RP OST Tool Rod, 1 each 39.1960.05, Retractor, 1 each 39.1960.07, RP OST System, 1 each 39.1960.70.01 RP Curved Hip Long, 1 each 39.1960.70.02 RP Curved Hip Short, 1 each 39.1960.70.03 RP Curved Hip, 1 each
Device Description
The RP Medical Pivot System Sterilization Tray System platform is designed to be compatible with the RP Medical Pivot Implant Extraction Osteotome surgical instruments. The Pivot System Sterilization Tray is constructed from thermoplastic plastics, aluminum and stainless steel. Each tray has evenly distributed steam holes. Individuals instruments were designed to slide into 2 level storage racks. The racks have handles on the side to facilitate carrying. The Pivot System Sterilization Tray has a sliding latch mechanism to facilitate containment. Each storage rack is set to a specific configuration and have stainless steel and silicone brackets and silkscreened artwork to assist the end user in correct placement of the instruments. The rack is designed to fit in a standard autoclave. The Pivot System Sterilization Tray System is reusable and provided in a non-sterile condition.
More Information

Not Found

No
The device description and intended use focus on a physical sterilization tray system for surgical instruments, with no mention of software, data processing, or AI/ML capabilities.

No.
This device is a sterilization tray system intended to organize, enclose, sterilize, transport, and store surgical instruments, not to treat or therapeutically affect a patient.

No

Explanation: The device is a sterilization tray system designed to organize, enclose, sterilize, transport, and store surgical instruments. Its intended use is to maintain the sterility of enclosed devices, not to diagnose medical conditions or diseases.

No

The device description clearly states it is a physical system constructed from thermoplastic plastics, aluminum, and stainless steel, designed to organize and sterilize surgical instruments. It is a hardware device.

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

Here's why:

  • Intended Use: The intended use clearly states that the device is for organizing, enclosing, sterilizing, transporting, and storing surgical instruments. It is used in conjunction with a sterilization wrap to maintain the sterility of the enclosed devices.
  • Device Description: The device description details a tray system for holding surgical instruments during sterilization.
  • Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening. This device does not interact with human specimens or provide diagnostic information.

The device is a sterilization tray system for surgical instruments, which falls under the category of medical devices used in healthcare facilities for the preparation and handling of surgical tools.

N/A

Intended Use / Indications for Use

The RP Medical Pivot System Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Pivot System surgical instruments within a healthcare facility when used in conjunction with a legally marketed, validated, FDA-cleared sterilization wrap for use in healthcare facilities in order to maintain sterility of the enclosed devices. The Pivot System Sterilization Tray System has been validated for use in the following sterilization cycles:

Enclosure Pivot System Sterilization Case Cycle Pre-Vacuum 132°C (270°F) Temperature Sterilization Time 4 minutes Pressure 2-15 PSIA Minimum Dry Time 30 minutes in chamber

The maximum validated product loads for the trays in containers are as follows: 2-Level Rack, Level 2, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 3 each 39.1960.02, RP OST Tool Rod, 3 each 39.1960.51.01, RP OST Tool 1D RH 16mm, 1 each 39.1960.51.02 RP OST Tool 1D RH 22mm, 1 each 39.1960.20.01 RP OST Angle 162mm, 1 each 39.1960.20.02 RP OST Angle 19mm, 1 each 39.1960.20.03 RP OST Angle 21.5mm , 1 each 39.1960.40.01 RP TM Spike Blade, 1 each 39.1960.60.01 OST Reverse Blade 11mm, 1 each 39.1960.60.02 OST Reverse Blade 16mm, 1 each 39.1960.30.01 RP OST Tool Curve 16mm, 1 each 39.1960.30.02 RP OST Tool Curve 19mm, 1 each 39.1960.30.03 RP OST Tool Curve 21.5mm, 1 each 39.1960.10.01 RP OST Straight 20mm, 1 each 39.1960.10.02 RP OST Straight 40mm, 1 each 39.1960.10.03 RP OST Straight 43mm, 1 each 39.1960.10.04 RP OST Straight 47.5mm, 1 each 39.1960.52.01, RP OST Tool 1D LH 16mm, 1 each 39.1960.52.02 RP OST Tool 1D LH 22mm, 1 each

2-Level Rack - Level 1, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 1 each 39.1960.02, RP OST Tool Rod, 1 each 39.1960.05, Retractor, 1 each 39.1960.07, RP OST System, 1 each 39.1960.70.01 RP Curved Hip Long, 1 each 39.1960.70.02 RP Curved Hip Short, 1 each 39.1960.70.03 RP Curved Hip, 1 each

Product codes

KCT

Device Description

The RP Medical Pivot System Sterilization Tray System platform is designed to be compatible with the RP Medical Pivot Implant Extraction Osteotome surgical instruments. The Pivot System Sterilization Tray is constructed from thermoplastic plastics, aluminum and stainless steel. Each tray has evenly distributed steam holes.

Individuals instruments were designed to slide into 2 level storage racks. The racks have handles on the side to facilitate carrying. The Pivot System Sterilization Tray has a sliding latch mechanism to facilitate containment.

Each storage rack is set to a specific configuration and have stainless steel and silicone brackets and silkscreened artwork to assist the end user in correct placement of the instruments. The rack is designed to fit in a standard autoclave. The Pivot System Sterilization Tray System is reusable and provided in a non-sterile condition.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

healthcare facility

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)

Name of the Test Method: Agar Overlay Method per ISO 10993-5
Purpose: To evaluate an extract of the test article for cytotoxicity to mammalian cells in culture
Acceptance Criteria: Test articles scoring 0, 1 or 2 will be considered 'non-cytotoxic'
Results: The test article scored 0 at 24, 48 and 72 +/- 4 hours and is considered non-cytotoxic.

Name of the Test Method: AAMI ST77:2013, Containment Devices for Reusable Medical Device Sterilization. Handle Weight Capacity Test for the Sterilization Case
Purpose: Not Found
Acceptance Criteria: No visible deformation, cracking or other evidence of damage on the Handles after testing.
Results: There was no visible deformation, cracking or other evidence of damage on the Handles after testing.

Name of the Test Method: Reliability testing for the Sterilization Case
Purpose: Not Found
Acceptance Criteria: No significant wear after 100 sterilization cycles. Significant wear is defined as extreme discoloration, peeling and/or cracking of any component of the sterilization tray.
Results: A side by side comparison of a new vs the Sterilization Case sterilized 102 times. There was a slight yellowing of the case color and the white print within the Sterilization Case. The discoloration was minimum and none of the printing was erased or faded so that it could not be read. In addition, there was no peeling and/or cracking of any of the components of the sterilization case.

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

Not Found

Predicate Device(s)

K173615

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.6850 Sterilization wrap.

(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

November 25, 2019

RP Medical, Inc. Jim Barley Director of RA/OA 22715 Holyrood Avenue Maple Ridge, V2X 6E7 Ca

Re: K181845

Trade/Device Name: Pivot System Sterilization case Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: KCT Dated: August 19, 2019 Received: August 27, 2019

Dear Jim Barley:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Elizabeth Claverie, M.S. Assistant Director for THT4B2 Acting Assistant Director for THT4B1 DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K181845

Device Name Pivot System Sterilization Case

Indications for Use (Describe)

The RP Medical Pivot System Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Pivot System surgical instruments within a healthcare facility when used in conjunction with a legally marketed, validated, FDA-cleared sterilization wrap for use in healthcare facilities in order to maintain sterility of the enclosed devices. The Pivot System Sterilization Tray System has been validated for use in the following sterilization cycles:

Enclosure Pivot System Sterilization Case Cycle Pre-Vacuum 132°C (270°F) Temperature Sterilization Time 4 minutes Pressure 2-15 PSIA Minimum Dry Time 30 minutes in chamber

The maximum validated product loads for the trays in containers are as follows: 2-Level Rack, Level 2, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 3 each 39.1960.02, RP OST Tool Rod, 3 each 39.1960.51.01, RP OST Tool 1D RH 16mm, 1 each 39.1960.51.02 RP OST Tool 1D RH 22mm, 1 each 39.1960.20.01 RP OST Angle 162mm, 1 each 39.1960.20.02 RP OST Angle 19mm, 1 each 39.1960.20.03 RP OST Angle 21.5mm , 1 each 39.1960.40.01 RP TM Spike Blade, 1 each 39.1960.60.01 OST Reverse Blade 11mm, 1 each 39.1960.60.02 OST Reverse Blade 16mm, 1 each 39.1960.30.01 RP OST Tool Curve 16mm, 1 each 39.1960.30.02 RP OST Tool Curve 19mm, 1 each 39.1960.30.03 RP OST Tool Curve 21.5mm, 1 each 39.1960.10.01 RP OST Straight 20mm, 1 each 39.1960.10.02 RP OST Straight 40mm, 1 each 39.1960.10.03 RP OST Straight 43mm, 1 each 39.1960.10.04 RP OST Straight 47.5mm, 1 each 39.1960.52.01, RP OST Tool 1D LH 16mm, 1 each 39.1960.52.02 RP OST Tool 1D LH 22mm, 1 each

2-Level Rack - Level 1, Pivot System Sterilization Tray 39.1960.01, RP OST Tool Handle, 1 each 39.1960.02, RP OST Tool Rod, 1 each 39.1960.05, Retractor, 1 each 39.1960.07, RP OST System, 1 each 39.1960.70.01 RP Curved Hip Long, 1 each 39.1960.70.02 RP Curved Hip Short, 1 each 39.1960.70.03 RP Curved Hip, 1 each

3

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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4

RP Medical

510(k) Summary (As required by 21 CFR 807.92(a)) K181845

Date Prepared: November 22, 2019

A. Applicant and Correspondent

| Applicant Name and Address: | RP Medical, Inc.
22715 Holyrood Avenue
Maple Ridge, BC V2X 6E7 Canada |
|-----------------------------|-----------------------------------------------------------------------------|
| Contact Person: | Ross Paul
President |
| Phone: | 604-418-4554 |
| Manufacturer | RP Medical, Inc.
22715 Holyrood Avenue
Maple Ridge, BC V2X 6E7 Canada |

B. Name of Device

• Trade/Proprietary/Model Name:Pivot System Sterilization Tray System
• Common Name of Devices:Sterilization Tray
• Panel:General Hospital and Personal Use

II

КСТ

21 CFR 880.6850

  • Classification Number: .
  • Classification Name: Sterilization wrap .
  • Regulatory Class: .
  • . Product Code:

C. Predicate Device

Device Name:Stryker Universal Select Sterilization Tray System
Manufacturer:Paragon Medical
Reference:K173615

5

510(k) SUMMARY (Continued)

D. Device Description

The RP Medical Pivot System Sterilization Tray System platform is designed to be compatible with the RP Medical Pivot Implant Extraction Osteotome surgical instruments. The Pivot System Sterilization Tray is constructed from thermoplastic plastics, aluminum and stainless steel. Each tray has evenly distributed steam holes.

Individuals instruments were designed to slide into 2 level storage racks. The racks have handles on the side to facilitate carrying. The Pivot System Sterilization Tray has a sliding latch mechanism to facilitate containment.

Each storage rack is set to a specific configuration and have stainless steel and silicone brackets and silkscreened artwork to assist the end user in correct placement of the instruments. The rack is designed to fit in a standard autoclave. The Pivot System Sterilization Tray System is reusable and provided in a non-sterile condition.

E. Indications for Use

The RP Medical Pivot System Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Pivot System surgical instruments within a healthcare facility when used in conjunction with a legally marketed, validated, FDA-cleared sterilization wrap for use in healthcare facilities in order to maintain sterility of the enclosed devices. The Pivot System Sterilization Tray System has been validated for use in the following sterilization cycles:

EnclosurePivot System Sterilization Tray
Pre-Vacuum
Temperature132°C (270°F)
Sterilization Time4 minutes
Pressure2-15 PSIA
Minimum Dry Time30 minutes in chamber

6

ConfigurationMaximum Validated Load Set Contents
2-Level Rack,
Level 2
Pivot System
Sterilization Tray39.1960.01, RP OST Tool Handle, 3 each
39.1960.02, RP OST Tool Rod, 3 each
39.1960.51.01, RP OST Tool 1D RH 16mm, 1 each
39.1960.51.02, RP OST Tool 1D RH 22mm, 1 each
39.1960.20.01 RP OST Angle 162mm, 1 each
39.1960.20.02 RP OST Angle 19mm, 1 each
39.1960.20.03 RP OST Angle 21.5mm, 1 each
39.1960.40.01 RP TM Spike Blade, 1 each
39.1960.60.01 OST Reverse Blade 11mm, 1 each
39.1960.60.02 OST Reverse Blade 16mm, 1 each
39.1960.30.01 RP OST Tool Curve 16mm, 1 each
39.1960.30.02 RP OST Tool Curve 19mm, 1 each
39.1960.30.03 RP OST Tool Curve 21.5mm, 1 each
39.1960.10.01 RP OST Straight 20mm, 1 each
39.1960.10.02 RP OST Straight 40mm, 1 each
39.1960.10.03 RP OST Straight 43mm, 1 each
39.1960.10.04 RP OST Straight 47.5mm, 1 each
39.1960.52.01, RP OST Tool 1D LH 16mm, 1 each
39.1960.52.02 RP OST Tool 1D LH 22mm, 1 each
2-Level Rack –
Level 1
Pivot System
Sterilization
Tray39.1960.01, RP OST Tool Handle, 1 each
39.1960.02, RP OST Tool Rod, 1 each
39.1960.05, Retractor, 1 each
39.1960.07, RP OST System, 1 each
39.1960.70.01 RP Curved Hip Long, 1 each
39.1960.70.02, RP Curved Hip Short, 1
each 39.1960.70.03 RP Curved Hip, 1 each

The maximum validated product loads for the trays in containers are as follows:

7

F. Technological Characteristics:

The following chart compares the technological characteristics of the subject and predicate devices:

Subject DevicePredicate DeviceComparison
Device NamePivot System Sterilization Tray SystemStryker Universal Select Sterilization Tray SystemN/A
510(k) NumberK181845K173615N/A
Product CodeKCTKCTSame
Indications for UseThe RP Medical Pivot System Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Pivot System surgical instruments within a healthcare facility when used in conjunction with a legally marketed, validated, FDA-cleared sterilization wrap for use in healthcare facilities in order to maintain sterility of the enclosed devices.. The Pivot System Sterilization Tray System has been validated for use in the following sterilization cycles:The Stryker Universal Select Sterilization Tray System is intended to organize, enclose, sterilize, transport and store Stryker implantable devices and surgical instruments within a healthcare facility when used in conjunction with a validated, FDA cleared rigid sterilization container in order to maintain sterility of the enclosed devices.

The Stryker Universal Select Sterilization Tray System has been validated for use in the following sterilization cycles:
Pre-Vacuum Steam Enclosure Rigid Container² Rigid Container² Temperature 132°C (270°F) 135°C (275°F) Sterilization Time 4 minutes 3 minutes Minimum Dry Time 30 minutes 30 minutes Maximum Weight 25 lbs / 11.36 kgs 25 lbs / 11.36 kgs Tray System has been validated in the following Aesculap SterilContainer cleared for pre-vacuum steam sterilization under K792558: Full DIN JK444 (base) and JK489 (lid) and ½ DIN JK346 (base) and JK389 (lid) | | | | | | | | | | | | | | | | | | Different |

8

Subject DevicePredicate DeviceComparison
CycleTemp.Exposure
Time
(min)Dry Time
(min)
Pre-vacuum132 °C430
The maximum validated product loads for the
sterilization case are as follows:The maximum validated product loads for
the tray system in containers are as follows:Different
Configuration1MaximumConfiguration1 Maximum Validated
Load Set Contents2,5
Indications for
Use
(continued)2-Level Rack,
Level 2
Rigid Sterilization Container3
39.1960.01, RP OST Tool Handle
39.1960.02, RP OST Tool Rod
39.1960.51.01, RP OST Tool 1D RH 16mm
39.1960.51.02 RP OST Tool 1D RH 22mm
39.1960.20.01 RP OST Angle 162mm
39.1960.20.02 RP OST Angle 19mm
39.1960.20.03 RP OST Angle 21.5mm
39.1960.40.01 RP TM Spike Blade
39.1960.60.01 OST Reverse Blade 11mm
39.1960.60.02 OST Reverse Blade 16mm
39.1960.30.01 RP OST Tool Curve 16mm
39.1960.30.02 RP OST Tool Curve 19mm
39.1960.30.03 RP OST Tool Curve 21.5mm
39.1960.10.01 RP OST Straight 20mm
39.1960.10.02 RP OST Straight 40mm
39.1960.10.03 RP OST Straight 43mm
39.1960.10.04 RP OST Straight 47.5mm
39.1960.52.01, RP OST Tool 1D LH 16mm
39.1960.52.02 RP OST Tool 1D LH 22mm
2-Level Rack -
Level 1
Rigid Sterilization Container4
39.1960.01, RP OST Tool Handle
39.1960.02, RP OST Tool Rod
39.1960.05, Retractor
39.1960.07, RP OST System
39.1960.70.01 RP Curved Hip Long
39.1960.70.02 RP Curved Hip Short
39.1960.70.03 RP Curved Hip29-12900 1.2 Upper-Face
Plates/Screws Module
with Lid (29-13941)
29-12901 1.2 Orbital
Plates/Mesh Module with
Lid (29-13941)
29-17900 1.7 Mid-Face
Plates/Screws Module with
Lid (29-13941)
29-17901 1.7 Mid-Face
Plates Module with Lid (29-

3-Level Rack -Qty.23
29-17903 1.7 Orthognathic
Plates Inlay
29-13901 Upper-/Mid-Face
Instrument Tray with Lid
(29-13921)
29-13920 ¼ DIN
Instrument/Accessory
Tray with Lid (29-13921)
29-23900 2.0/2.3
Mandible Screws Module
with Lid (29- 13941)
29-23901 2.0/2.3 Mandible
Plates Module with Lid
(29- 13941)
29-23905 2.0/2.3 Mini Plates
Inlay, Large
29-13904 Mandible Fracture
Instrument Tray with Lid
(29- 13921)
29-13905 Trocar Instrument | |

9

Tray with Lid (29-13921)
29-23900 2.0/2.3 Mandible
Screws Module with Lid
(29-13941)
29-23903 2.0/2.3 Mandible
Recon Plates Module with
Lid (29-13941)
3-Level Rack – Qty. 14
29-23904 2.0/2.3 Mandible
Recon Primary Plates Inlay
29-13904 Mandible Fracture
Instrument Tray with Lid
(29-13921)
29-13905 Trocar Instrument
Tray with Lid (29- 3921)
29-13920 $\frac{1}{4}$ DIN
Instrument/Accessory Tray
with Lid (29- 13921)
1 Model numbers shown in table are Stryker®
model numbers
2 Contents in the validated Tray System
included: Single-use implants (plates,
meshes, bone screws, etc.), single-use
instruments (drills), and reusable surgical
instruments (benders, forceps, handles, depth
gauges, trocars, etc.)
3 Tray system components part of the worst-
case configuration in a full DIN Rigid
Sterilization Container validation in an
Aesculap SterilContainer Base (JK446) and
Lid (JK489) cleared under K792558
4 Tray system components part of the worst-
case configuration in a 1/2 DIN Rigid
Sterilization Container validation in an
Aesculap SterilContainer Base (JK346) and
Lid (JK389) cleared under K792558
5 No lumened devices were validated within
the tray system as part of the product load.
The Stryker Universal Select Sterilization
Tray System does have any lumen claims.

10

Process

Subject DevicePredicate DeviceComparison
DesignThe Pivot System Sterilization Tray platform is designed to be compatible with the Pivot system surgical instrumentation. Individual components were designed to slide in to 2-level storage racks. Racks have handles on the side to facilitate carrying. The tray lids have sliding latch mechanism to facilitate containmentThe Stryker Universal Select Sterilization Tray System platform is designed to be compatible with Stryker implantable devices and surgical instrumentation. Individual components were designed to slide in to 2- and 3-level storage racks. Racks have handles on the side to facilitate carrying. Module and tray lids have sliding latch mechanism to facilitate containment.Similar
Materials of ConstructionStainless Steel, Anodized Aluminum, Silicone and Thermoplastic PolymersStainless Steel, Anodized Aluminum, Silicone, PPSU, PolypropyluxSimilar
Configuration and DimensionsPerforated 2-level and 3-level Racks that house the following tray components:

Case - double Outer
19.51" x 9.13" x 3.125"

Lid - Generic Outer Lid
20.00"x 9.60" x 0.437" | Perforated 2-level and 3-level Racks that house the following tray components:

2-level Rack 9.80 x 9.70 x 5.27 inches
3-level Rack 9.80 x 9.70 x 7.57 inches
1/4 DIN Instrument/Accessory 9.31 x 4.09 x 1.54 inches Tray
¼ DIN Instrument/Accessory 9.29 x 4.30 x 0.51 inches Tray Lid
1/2 DIN Instrument/Accessory 9.31 x 8.55 x 1.54 inches Tray
1/2 DIN Instrument/Accessory 9.29 x 8.71 x 0.55 inches Tray Lid | Different |
| | | | |
| Material Compatibility with Sterilization | Performance testing demonstrated that the materials of construction are compatible with repeated steam | Performance testing demonstrated that the materials of construction are compatible with repeated steam | Same |

sterilization cycles.

of construction are compatible with repeated steam

sterilization cycles.

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Subject DevicePredicate DeviceComparison
Different
CycleTempExposureCycleTempExposure
Sterilization
Parameters
(Pre-Vacuum)Pre-Vacuum132° C
(270°F)4 MinPre-Vacuum132° C
(270°F)4 MinDifferent
135°C
(275°F)4 Min
PerforationEvenly distributed perforated steam hole pattern.Evenly distributed perforated steam hole pattern.Similar
Sterilization
MethodPre-vacuumPre-vacuumSame
ReusableYesYesSame
Patient
ContactNo direct patient contactNo direct patient contactSame
Air
PermeanceYesYesSame

G. Summary of Non-clinical Testing

Shown below is a listing of the non-clinical test that was performed to verify that the subject device met the standards recommendation.

Name of the Test MethodPurposeAcceptance CriteriaResults
Agar Overlay Method per ISO 10993-5To evaluate an extract of the test article for cytotoxicity to mammalian cells in cultureTest articles scoring 0, 1 or 2 will be considered 'non-cytotoxic'The test article scored 0 at 24, 48 and 72 +/- 4 hours and is considered non-cytotoxic.
AAMI ST77:2013, Containment Devices for Reusable Medical Device Sterilization.Handle Weight Capacity Test for the Sterilization CaseNo visible deformation, cracking or other evidence of damage on the Handles after testing.There was no visible deformation, cracking or other evidence of damage on the

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Handles after testing.
Reliability testing for the
Sterilization CaseNo significant wear after
100 sterilization cycles.
Significant wear is defined
as extreme discoloration,
peeling and/or cracking of
any component of the
sterilization tray.A side by side comparison of a
new vs the Sterilization Case
sterilized 102 times.
There was a slight yellowing of
the case color and the white print
within the Sterilization Case.
The discoloration was minimum
and none of the printing was
erased or faded so that it could
not be read. In addition, there
was no peeling and/or cracking of
any of the components of the
sterilization case.

The Pivot System Sterilization Tray met the appropriate requirements contained in the following standards:

    1. AAMI ST77:2013, Containment devices for reusable medical device sterilization
    1. AAMI TIR 30, A compendium of processes, materials, test methods, and acceptable criteria for cleaning reusable medical devices
    1. ANSI/AAMI/ISO 17665-1. Sterilization of health care products-Moist heat-Part 1: Requirements for the development validation and routine control of a sterilization process for medical devices
    1. ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process.
    1. ANSI AAMI ISO 14971:2007/(R)2010, Medical Devices Application of Risk Management to Medical Devices

H. Conclusion

Based on the intended use, technological characteristics, and non-clinical performance data, the RP Medical Pivot System Sterilization Tray System is as safe, as effective, and performs as well as or better than the legally marketed predicate, Stryker Universal Select Sterilization Tray System, cleared under K173615, Class II (21 CFR 880.6850, product code KCT).