K Number
K193092
Device Name
TunneLoc Tibial Fixation Device
Manufacturer
Date Cleared
2020-01-02

(57 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
To provide fixation of soft-tissue grafts within the tibial tunnel during anterior cruciate ligament (ACL) and/or posterior cruciate ligament (PCL) reconstruction.
Device Description
The TunneLoc Tibial Fixation Devices are an implant and inserter instrument system that offers components for treatment of patients that require fixation of soft tissue to bone.
More Information

Not Found

No
The summary describes a mechanical fixation device and its associated instruments, with no mention of AI, ML, image processing, or data-driven decision-making. The performance studies are mechanical and functional tests.

No
The device is used for fixation during reconstruction, which is a structural support function rather than a therapeutic treatment of a disease or condition.

No

The device is an implant and inserter instrument system used for fixation of soft-tissue grafts, which is a therapeutic function, not a diagnostic one.

No

The device description explicitly states it is an "implant and inserter instrument system," which are hardware components.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Description and Intended Use: The provided information clearly states that this device is an implant and inserter instrument system used for fixation of soft-tissue grafts within the tibial tunnel during ACL and PCL reconstruction. This is a surgical procedure performed directly on the patient's body, not a test performed on a sample outside the body.
  • Lack of IVD Characteristics: The description does not mention any analysis of biological samples, detection of biomarkers, or diagnostic purposes.

Therefore, based on the provided information, the TunneLoc Tibial Fixation Device is a surgical implant and instrument system, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

To provide fixation of soft-tissue grafts within the tibial tunnel during anterior cruciate ligament (ACL) and/or posterior cruciate ligament (PCL) reconstruction.

Product codes

MBI, HWC

Device Description

The TunneLoc Tibial Fixation Devices are an implant and inserter instrument system that offers components for treatment of patients that require fixation of soft tissue to bone.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Tibial tunnel (related to ACL and PCL reconstruction)

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)

Non-Clinical Tests:
FEA (finite element analysis) and Mechanical Testing supports that the modified tensioning yoke with support ribs demonstrate greater stiffness than the predicate yoke design.
TunneLoc Assembly Insertion Functional Testing was completed to evaluate functional performance when under simulated use using bone and graft substitutes. Testing demonstrates the tensioner instrument possesses sufficient mechanical strength to support the loads experienced during use and is capable of successfully completing its intended use
Bacterial Endotoxins Test (BET) per ANSI/AAMI ST 72:2011 as a part of cleaning validation was performed, demonstrating that the device meets the limit of ≤20 Endotoxin units (EU)/Device per USP41-NF36 Chapter Medical Devices – Bacterial Endotoxin and Pyrogen Tests.
Clinical Tests: None provided

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

Not Found

Predicate Device(s)

K103145

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc)

Not Found

§ 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.

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square are the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" below it.

January 2, 2020

Biomet Inc. Haley Pioch Regulatory Affairs Specialist 56 East Bell Drive, PO Box 587 Warsaw, Indiana 46582

Re: K193092

Trade/Device Name: TunneLoc® Tibial Fixation Device Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: MBI, HWC Dated: November 5, 2019 Received: November 6, 2019

Dear Ms. Pioch:

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,

for

Laura Rose, Ph.D. Acting Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known)

K193092

Device Name TunneLoc® Tibial Fixation Device

Indications for Use (Describe)

To provide fixation of soft-tissue grafts within the tibial tunnel during anterior cruciate ligament (ACL) and/or posterior cruciate ligament (PCL) reconstruction.

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)

cription 300 (Part 21 CFR 601 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

510(k) Summary

In accordance with 21 CFR §807.92 and the Safe Medical Devices Act of 1990, the following information is provided for the TunneLoc Tibial Fixation Device 510(k) premarket notification. The submission was prepared in accordance with the FDA guidance document, 'Format for Traditional and Abbreviated 510(k)s', issued on September 13, 2019.

| Sponsor: | Biomet Inc.
56 East Bell Drive
PO Box 587
Warsaw, IN 46581
Establishment Registration Number: 1825034 |
|---------------------------|-------------------------------------------------------------------------------------------------------------------|
| Primary Contact Person: | Haley Pioch
Regulatory Affairs Specialist
Telephone: (412-376-2510 extension 214) |
| Secondary Contact Person: | Jared Cooper
Regulatory Affairs Manager
Telephone: (574-372-1941) |
| Date: | November 5, 2019 |
| Subject Device: | Trade Name: TunneLoc® Tibial Fixation Device
Common Name: Soft Tissue Fixation Device |
| Classification Name: | MBI- fastener, fixation, nondegradable, soft tissue (21 CFR 888.3040)HWC- screw, fixation, bone (21 CFR 888.3040) |

Predicate Device(s):

Primary Predicate510(k) Number
TunneLoc Tibial Fixation DeviceK103145

| Purpose and Device Description: | The purpose of this submission is:
• To submit a 510(k) for cumulative changes made to the system since original clearance;
o The subject device includes an updated device naming convention;
o Modifications made to the subject device inserter to improve ergonomics for the end user, improve surgeon visualization during |
|---------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | implant insertion, and inserter yoke
component dimensional modification; To update labeling to bring the Instructions for Use up to current practices. |
| | The TunneLoc Tibial Fixation Devices are an implant and inserter instrument system that offers components for treatment of patients that require fixation of soft tissue to bone. |
| Indications for Use: | To provide fixation of soft-tissue grafts within the tibial tunnel during anterior cruciate ligament (ACL) and/or posterior cruciate ligament (PCL) reconstruction. |
| Summary of Technological
Characteristics: | The rationale for substantial equivalence is based on consideration of the following characteristics: Intended Use: Identical to predicate Indications for Use: Identical to predicate Materials: Identical to predicate Design Features: Similar to predicate Sterilization: Identical to predicate |
| Summary of Performance Data:
(Nonclinical and/or Clinical) | Non-Clinical Tests: FEA (finite element analysis) and Mechanical Testing supports that the modified tensioning yoke with support ribs demonstrate greater stiffness than the predicate yoke design. TunneLoc Assembly Insertion Functional Testing was completed to evaluate functional performance when under simulated use using bone and graft substitutes. Testing demonstrates the tensioner instrument possesses sufficient mechanical strength to support the loads experienced during use and is capable of successfully completing its intended use Bacterial Endotoxins Test (BET) per ANSI/AAMI ST 72:2011 as a part of cleaning validation was performed, demonstrating that the device meets the limit of ≤20 Endotoxin units (EU)/Device per USP41-NF36 Chapter Medical Devices – Bacterial Endotoxin and Pyrogen Tests. Clinical Tests: None provided |
| Substantial Equivalence | The subject TunneLoc Tibial Fixation Devices have the |

4

5

Conclusion:

same intended use and indications for use as the predicate devices. The subject devices have similar technological characteristics to the predicates, and the information provided herein demonstrates that:

  • any differences do not raise new questions of safety . and effectiveness; and
  • . the subject devices are at least as safe and effective as the legally marketed predicate devices.