K Number
K191049
Device Name
Stryker MIS and Footed Attachments
Date Cleared
2019-06-18

(60 days)

Product Code
Regulation Number
882.4310
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The MIS Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the MIS Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, shaping, dissecting, shaving, and smoothing for the following medical applications: Neuro; Spine; Ear, Nose, and Throat (ENT)/ Otorhinolaryngology; and Endoscopic applications. Specific applications include Craniectomy, Laminotomy/Laminectomy, Minimally Invasive Surgery (MIS) Spine, Expanded Endonasal Approach (EEA)/Anterior Skull Base/ Endoscopic/Transnasal/Transphenoidal, and Orthopedic Spine. These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices. The Footed Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the Footed Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, dissecting, and shaping for the following medical applications: Neuro: Spine; Ear. Nose, and Throat (ENT) /Otology/Neurotology/ Otorhinolaryngology; Craniofacial and Maxillofacial; and Sternotomy. Specific applications include Craniotomy, Pterional Craniotomy, Sub Occipital/Retro Sigmoid/Posterior Fossa Craniotomy, Sphenoid Wing Dissection, Laminotomy / Laminectomy, and Orthopedic Spine. These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices. It is also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.
Device Description
The Stryker MIS and Footed Attachments are used within a system consisting of a variety of devices, including a console, powered motors, and cutting accessories. The attachments connect to the motors and the cutting accessories to complete the system for physician use. The Stryker MIS and Footed Attachments are offered for prescription use only. The MIS and Footed Attachments are intended to serve as interfaces between powered motors and cutting accessories for the purposes of: - Cutting bone, bone cement, and teeth; - Placing or cutting screws, metal, wires, pins, and other fixation devices; and - Providing a location for the user to hold and grip the device system. The Stryker MIS Attachments are available in straight, curved and angled styles. The Stryker Footed attachments are available as fixed footed, rotating footed, and nonfooted attachments The MIS and Footed Attachments are made of stainless steel (SST). All MIS and Footed Attachments have a color band on the proximal end of the outer surface to aid the user in correct system assembly. The color band serves to enhance the distinction of attachment and cutting accessory compatibility. The purpose of this submission is to gain clearance for the color band modifications for the Subject Device Attachments color band that exceeds the threshold as per FDA Guidance, "Deciding When to Submit a 510(k) for a Change to an Existing Device".
More Information

Not Found

No
The document describes mechanical attachments and cutting accessories for surgical motors. There is no mention of any software, algorithms, or data processing that would indicate the use of AI or ML. The submission is for a modification related to a color band.

No.
The device is described as an accessory (attachments and cutting accessories) for cutting bone and preparing for fixation devices, which suggests it is a surgical tool rather than a device intended for direct therapeutic treatment.

No

The device is described as surgical attachments and cutting accessories intended to cut bone and prepare for the placement of fixation devices. Its function is to perform physical modifications to the body, not to diagnose conditions.

No

The device description explicitly states it is made of stainless steel and serves as an interface between powered motors and cutting accessories, indicating it is a physical hardware component. The submission is for a modification to a color band on these physical attachments.

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

Here's why:

  • Intended Use: The intended use clearly describes the device as being used for cutting bone and preparing for the placement of fixation devices during surgical procedures. This is an in vivo application (within a living organism).
  • Device Description: The device description details the physical components and their function in a surgical setting, connecting to motors and cutting accessories for bone manipulation.
  • 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) to provide information for diagnosis, monitoring, or screening.

IVD devices are used outside the body to analyze samples. This device is used inside the body during surgery.

N/A

Intended Use / Indications for Use

The MIS Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the MIS Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, shaping, dissecting, shaving, and smoothing for the following medical applications: Neuro; Spine; Ear, Nose, and Throat (ENT)/ Otorhinolaryngology; and Endoscopic applications.

Specific applications include Craniectomy, Laminotomy/Laminectomy, Minimally Invasive Surgery (MIS) Spine, Expanded Endonasal Approach (EEA)/Anterior Skull Base/ Endoscopic/Transnasal/Transphenoidal, and Orthopedic Spine.

These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

The Footed Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the Footed Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, dissecting, and shaping for the following medical applications: Neuro: Spine; Ear. Nose, and Throat (ENT) /Otology/Neurotology/ Otorhinolaryngology; Craniofacial and Maxillofacial; and Sternotomy.

Specific applications include Craniotomy, Pterional Craniotomy, Sub Occipital/Retro Sigmoid/Posterior Fossa Craniotomy, Sphenoid Wing Dissection, Laminotomy / Laminectomy, and Orthopedic Spine.

These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices. It is also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

Product codes (comma separated list FDA assigned to the subject device)

HBE, ERL

Device Description

The Stryker MIS and Footed Attachments are used within a system consisting of a variety of devices, including a console, powered motors, and cutting accessories. The attachments connect to the motors and the cutting accessories to complete the system for physician use. The Stryker MIS and Footed Attachments are offered for prescription use only. The MIS and Footed Attachments are intended to serve as interfaces between powered motors and cutting accessories for the purposes of:

  • Cutting bone, bone cement, and teeth;
  • Placing or cutting screws, metal, wires, pins, and other fixation devices; and
  • Providing a location for the user to hold and grip the device system.

The Stryker MIS Attachments are available in straight, curved and angled styles.

The Stryker Footed attachments are available as fixed footed, rotating footed, and nonfooted attachments

The MIS and Footed Attachments are made of stainless steel (SST). All MIS and Footed Attachments have a color band on the proximal end of the outer surface to aid the user in correct system assembly. The color band serves to enhance the distinction of attachment and cutting accessory compatibility.

The Subject Devices Stryker MIS attachments and Stryker Footed attachments are cleared under two separate 510(k)s. Since the modification to the color band is identical for both attachment types (MIS and Footed), this premarket notification is being submitted as bundled submission in accordance with guidance document issued by FDA on June 22, 2007, "Bundling Multiple Devices or Multiple Indications in a Single Submission".

The purpose of this submission is to gain clearance for the color band modifications for the Subject Device Attachments color band that exceeds the threshold as per FDA Guidance, "Deciding When to Submit a 510(k) for a Change to an Existing Device".

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

bone, teeth, Neuro, Spine, Ear, Nose, Throat (ENT)/Otorhinolaryngology, Craniofacial, Maxillofacial, Sternotomy

Indicated Patient Age Range

Not Found

Intended User / Care Setting

physician, surgeon (Prescription Use)

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)

Verification testing was performed on the Subject Devices as dictated by the results of the Risk Analysis, and no new questions of safety and effectiveness were raised. The Subject Device met all pre-defined acceptance criteria. The results of the tests mention in the Table 3, support the substantial equivalence of the Subject Device to the Predicate Device. Testing data from the following was provided in support of the substantial equivalence determination.

TABLE 3. LIST IF TESTS PERFORMED
Colorfastness and Durability test - Passed
Colorfastness Test - Passed

Biocompatibility evaluation was performed following the recommendations of ISO 10993-1: 2018 and FDA Guidance (Use of International Standard ISO- 10993, "Biological Evaluation of Medical Devices Part 1: Evaluation and Testing" June 2016) as appropriate for limited exposure (

§ 882.4310 Powered simple cranial drills, burrs, trephines, and their accessories.

(a)
Identification. Powered simple cranial drills, burrs, trephines, and their accessories are bone cutting and drilling instruments used on a patient's skull. The instruments are used with a power source but do not have a clutch mechanism to disengage the tip after penetrating the skull.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows 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 is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".

June 18, 2019

Stryker Corporation Paminder Khurmi Staff Regulatory Affairs Specialist 4100 E Milham Ave Kalamazoo, Michigan 49001

Re: K191049

Trade/Device Name: Stryker MIS and Footed Attachments Regulation Number: 21 CFR 882.4310 Regulation Name: Powered Simple Cranial Drills, Burrs, Trephines, And Their Accessories Regulatory Class: Class II Product Code: HBE, ERL Dated: April 18, 2019 Received: April 19, 2019

Dear Paminder Khurmi:

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

1

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 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 (QS) 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 medical devices and radiation-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,

Matthew Krueger, M.S.E. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K191049

Device Name Stryker MIS attachments

Indications for Use (Describe)

The MIS Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the MIS Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, shaping, dissecting, shaving, and smoothing for the following medical applications: Neuro; Spine; Ear, Nose, and Throat (ENT)/ Otorhinolaryngology; and Endoscopic applications.

Specific applications include Craniectomy, Laminotomy/Laminectomy, Minimally Invasive Surgery (MIS) Spine, Expanded Endonasal Approach (EEA)/Anterior Skull Base/ Endoscopic/Transnasal/Transphenoidal, and Orthopedic Spine.

These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

Type of Use (Select one or both, as applicable)X 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."

3

Indications for Use

510(k) Number (if known) K191049

Device Name Stryker Footed attachments

Indications for Use (Describe)

The Footed Attachments and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the Footed Attachments and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, dissecting, and shaping for the following medical applications: Neuro: Spine; Ear. Nose, and Throat (ENT) /Otology/Neurotology/ Otorhinolaryngology; Craniofacial and Maxillofacial; and Sternotomy.

Specific applications include Craniotomy, Pterional Craniotomy, Sub Occipital/Retro Sigmoid/Posterior Fossa Craniotomy, Sphenoid Wing Dissection, Laminotomy / Laminectomy, and Orthopedic Spine.

These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices. It is also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

Type of Use (Select one or both, as applicable)
-------------------------------------------------

|X 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 onlyto 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 regardingthis burden estimate or any other as pect 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."

4

Stryker Instruments 4100 Milham Ave. Kalamazoo, MI 49001 t: 269 389 7700 f: 269-324-5412 www.stryker.com

510(k)Summary

This section provides a summary of 510(k) information in accordance with the requirements of 21 CFR 807.92.

SUBMITTER l.

| 510(k) Owner: | Stryker Instruments
4100 E. Milham Avenue
Kalamazoo, Michigan 49001 USA
Ph: +1-269-323-7700
Fax: +1-269-324-5412 |
|---------------------------------------|------------------------------------------------------------------------------------------------------------------------------|
| Submitter/ Contact
Person: | Paminder Khurmi
Staff Regulatory Affairs Specialist
Phone: +1-269-389-2264
Paminder.Khurmi@Stryker.com |
| FDA Establishment
Registration No. | 1811755 |
| Date Submitted: | April 18, 2019 |

DEVICE II.

Trade Name:Stryker® MIS and Footed Attachments
Common Name:Surgical Drill Handpieces
Primary ClassificationDrills, Burs, Trephines & Accessories (Simple, Powered)
(21 CFR 882.4310, Product code HBE)
Secondary ClassificationDrill, Surgical ENT (Electric or Pneumatic) including Handpiece
(21 CFR 874.4250, Product code ERL)
Classification:II

5

Stryker Instruments 4100 Milham Ave. Kalamazoo, MI 49001 t: 269 389 7700 f: 269-324-5412 www.stryker.com

lll. PREDICATE DEVICE

510 (K) NumberProduct codeTrade nameManufacturer
K143540HBE, ERLStryker® MIS
Attachments and
cutting accessoriesStryker Instruments
K143399HBE, ERLStryker® Footed
Attachments and
cutting accessoriesStryker Instruments

IV. SUBJECT DEVICE DESCRIPTION

The Stryker MIS and Footed Attachments are used within a system consisting of a variety of devices, including a console, powered motors, and cutting accessories. The attachments connect to the motors and the cutting accessories to complete the system for physician use. The Stryker MIS and Footed Attachments are offered for prescription use only. The MIS and Footed Attachments are intended to serve as interfaces between powered motors and cutting accessories for the purposes of:

  • Cutting bone, bone cement, and teeth;

  • A Placing or cutting screws, metal, wires, pins, and other fixation devices; and
  • Providing a location for the user to hold and grip the device system.

The Stryker MIS Attachments are available in straight, curved and angled styles.

The Stryker Footed attachments are available as fixed footed, rotating footed, and nonfooted attachments

The MIS and Footed Attachments are made of stainless steel (SST). All MIS and Footed Attachments have a color band on the proximal end of the outer surface to aid the user in correct system assembly. The color band serves to enhance the distinction of attachment and cutting accessory compatibility.

The Subject Devices Stryker MIS attachments and Stryker Footed attachments are cleared under two separate 510(k)s. Since the modification to the color band is identical for both attachment types (MIS and Footed), this premarket notification is being submitted as bundled submission in accordance with guidance document issued by FDA on June 22, 2007, "Bundling Multiple Devices or Multiple Indications in a Single Submission".

6

Stryker Instruments 4100 Milham Ave. Kalamazoo, MI 49001 t: 269 389 7700 f: 269-324-5412 www.stryker.com

stryker

The purpose of this submission is to gain clearance for the color band modifications for the Subject Device Attachments color band that exceeds the threshold as per FDA Guidance, "Deciding When to Submit a 510(k) for a Change to an Existing Device".

V. INDICATIONS FOR USE

As the subject premarket notification is a bundled submission, there are 2 proposed indications for use, and are broken in 2 tables for each attachment type for easy navigation. See Table 1 below for Indications for Use for Stryker MIS attachments and Table 2 for Indications for Use for Stryker Footed attachments.

TABLE 1: COMPARISON OF INDICATIONS FOR USE FOR MIS ATTACHMENTS
Subject Device- Stryker MIS attachments
Indications
for UseThe MIS Attachments and Cutting Accessories are intended to be used with the
Stryker Consolidated Operating Room Equipment (CORE®) Console and electric
and pneumatic motors. When used with these motors, the MIS Attachments
and Cutting Accessories are intended to cut bone in the following manner:
drilling, reaming, decorticating, shaping, dissecting, shaving, and smoothing for
the following medical applications: Neuro; Spine; Ear, Nose, and Throat
(ENT)/Otorhinolaryngology; and Endoscopic applications.
Specific applications include Craniotomy/Craniectomy,
Laminotomy/Laminectomy, Minimally Invasive Surgery (MIS) Spine, Expanded
Endonasal Approach (EEA)/Anterior Skull Base/
Endoscopic/Transnasal/Transphenoidal, and Orthopedic Spine.
These devices are also usable in the preparation for the placement of screws,
metal, wires, pins, and other fixation devices.

TABLE 2: COMPARISON OF INDICATIONS FOR USE FOR FOOTED ATTACHMENTS

Subject Device- Stryker Footed attachments
Indications
for UseThe Footed Attachments and Cutting Accessories are intended to be used with
the Stryker Consolidated Operating Room Equipment (CORE®) Console and
electric and pneumatic motors. When used with these motors, the Footed
Attachments and Cutting Accessories are intended to cut bone in the following
manner: drilling, reaming, decorticating, shaping, dissecting, shaving and
smoothing for the following medical applications: Neuro; Spine; Ear, Nose, and
Throat (ENT) /Otology /Neurotology/Otorhinolaryngology; Craniofacial and
Maxillofacial; and Sternotomy.

7

Specific applications include Craniotomy/Craniectomy, Pterional Craniotomy, Sub Occipital/Retro Sigmoid/Posterior Fossa Craniotomy, Sphenoid Wing Dissection, Laminotomy / Laminectomy, and Orthopedic Spine. These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

The Subject Device Indications for Use remains identical to the Predicate Devices. The modification described to the Subject Device in this 510(k) does not change the Indications for Use.

VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

The Subject Device is compared to the Predicate Device for substantial equivalence of technological characteristics based on the modification described in this submission.

Technological Characteristics

The only change in the Subject and Predicate Devices is the different color band.

The Color Band location, Attachment to Cutting Accessory Locking Mechanism, and Attachment to Motor Locking Mechanism are identical when comparing the Subject and Predicate Device and, all other technological characteristics, remains the same between the Subject and Predicate Devices.

The technological characteristics that are not the same between the Subject and Predicate Devices are the color band material and colorant. However, the Subject Device color band material and colorant are similar to those cleared for the Predicate Device, and the different characteristics do not raise different questions of safety and effectiveness.

VII. PERFORMANCE DATA

The following testing were performed, and the data was provided in support of the substantial equivalence determination:

Verification testing was performed on the Subject Devices as dictated by the results of the Risk Analysis, and no new questions of safety and effectiveness were raised. The Subject Device met all pre-defined acceptance criteria. The results of the tests mention in the Table 3, support the substantial equivalence of the Subject Device to the Predicate Device. Testing data from the following was provided in support of the substantial equivalence determination.

8

TABLE 3. LIST IF TESTS PERFORMED

Tests performedResults
Colorfastness and Durability testPassed
Colorfastness TestPassed

Biocompatibility Testing

A biocompatibility evaluation was performed following the recommendations of ISO 10993-1: 2018 and FDA Guidance (Use of International Standard ISO- 10993, "Biological Evaluation of Medical Devices Part 1: Evaluation and Testing" June 2016) as appropriate for limited exposure (