K Number
K200632
Device Name
TCAT TKA Instrument Tray Set
Date Cleared
2020-04-08

(29 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The THINK Surgical TCAT® TKA Instrument Tray Set is intended to protect, organize, and deliver to the surgical field TCAT® tools, instruments and accessories. The trays allow sterilization of tools, instruments and accessories, and maintain sterility of the enclosed devices until used. The trays are wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.
Device Description
The TCAT® TKA Instrument Tray Set is intended only for use with TSolution One® Total Knee Application instruments, tools and accessories. These trays are used to enclose and hold the instruments tools and accessories in an organized manner during the sterilization process and subsequent storage and transportation to and from the surgical suite. The trays are designed to fit any standard autoclave and are constructed primarily of anodized aluminum meeting biocompatibility requirements and are compatible with repeated steam sterilizations. The trays have perforations to facilitate sterilant penetration, evacuation and drying. Since the trays are perforated, an FDA-cleared sterilization wrap must be used to maintain sterility of the contents. The trays have the same size and same basic configuration of the predicate device: a rectangular base with a latchable lid. The trays have perforations with an evenly distributed hole pattern on the lid, bottom, and sides to allow sterilant penetration. The bottom surface and interior shelves of the trays contain stanchions designed to separately hold each individual instrument, tool and accessory for effective sterilant exposure, evacuation and drying during the entire duration of the sterilization process, as well as ease of locating each instrument when placing in or removal from the tray. The sterilization trays have been tested only with THINK Surgical instruments, tools and accessories for a 4 minute sterilization cycle of pre-vacuum steam sterilization at 132°C, with a 45 minute dry time. While reuseable, these trays will not be serviced or repaired.
More Information

Not Found

No
The device is a set of instrument trays for sterilization and organization, with no mention of AI or ML capabilities in the description or performance studies.

No.

The device is described as an instrument tray set intended to protect, organize, and deliver tools and instruments, allowing for their sterilization and maintaining sterility. It does not perform a therapeutic function on the patient.

No

The device is an instrument tray set designed to organize, protect, and facilitate the sterilization and transport of surgical tools and instruments. It does not perform any diagnostic functions.

No

The device is a physical instrument tray set made of anodized aluminum, designed to hold and sterilize surgical instruments. It is not software.

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

Here's why:

  • Intended Use: The intended use is to "protect, organize, and deliver to the surgical field TCAT® tools, instruments and accessories." It also facilitates sterilization and maintains sterility. This is a function related to surgical instruments and their handling, not the examination of specimens derived from the human body.
  • Device Description: The description focuses on the physical characteristics of the trays, their materials, and their function in holding and sterilizing surgical instruments. There is no mention of analyzing biological samples or providing diagnostic information.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological specimens (blood, urine, tissue, etc.)
    • Detecting or measuring substances in specimens
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions

The device is clearly designed to support surgical procedures by managing the instruments used in those procedures.

N/A

Intended Use / Indications for Use

The THINK Surgical TCAT® TKA Instrument Tray Set is intended to protect, organize, and deliver to the surgical field TCAT® tools, instruments and accessories. The trays allow sterilization of tools, instruments and accessories, and maintain sterility of the enclosed devices until used. The trays are wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.

Product codes

KCT

Device Description

The TCAT® TKA Instrument Tray Set is intended only for use with TSolution One® Total Knee Application instruments, tools and accessories. These trays are used to enclose and hold the instruments tools and accessories in an organized manner during the sterilization process and subsequent storage and transportation to and from the surgical suite. The trays are designed to fit any standard autoclave and are constructed primarily of anodized aluminum meeting biocompatibility requirements and are compatible with repeated steam sterilizations. The trays have perforations to facilitate sterilant penetration, evacuation and drying. Since the trays are perforated, an FDA-cleared sterilization wrap must be used to maintain sterility of the contents.

The trays have the same size and same basic configuration of the predicate device: a rectangular base with a latchable lid. The trays have perforations with an evenly distributed hole pattern on the lid, bottom, and sides to allow sterilant penetration. The bottom surface and interior shelves of the trays contain stanchions designed to separately hold each individual instrument, tool and accessory for effective sterilant exposure, evacuation and drying during the entire duration of the sterilization process, as well as ease of locating each instrument when placing in or removal from the tray.

The sterilization trays have been tested only with THINK Surgical instruments, tools and accessories for a 4 minute sterilization cycle of pre-vacuum steam sterilization at 132°C, with a 45 minute dry time. While reuseable, these trays will not be serviced or repaired.

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

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

Non-Clinical Performance Testing:

  • Sterilization Efficacy: The TCAT® TKA Instrument Tray Sets containing the maximum load were inoculated with biological indicators placed in areas of the trays deemed to be most difficult for sterilant (steam) to penetrate. Following inoculation, the trays were wrapped in FDA-cleared sterilization wraps. The trays indicated that the BI Overkill method provided a six-log reduction of the indicator organism. Results: -All biological indicators (BIs) must be incubated for a minimum of 7 days at 55°C-60°C -The positive control for the SAL testing must show characteristic growth of the indicator organism -Valid temperature data must be collected for each product probe location -Temperature probes used during profiling of the test article must be within ±0.5°C of at least one post calibration reference temperature that is representative of the profiling cycles -All directly-inoculated test article components must demonstrate to contain no bacteriostatic properties by showing growth of G. stearothermophilus during method suitability testing.
  • Packaging (ASTM D4169-16 - Standard Practice for Performance Testing of Shipping Containers and Systems): The TCAT® TKA Instrument Tray Sets were evaluated with maximum load, wrapped according to use instructions and in the shipping configuration according to a shipping validation test. The results indicate packaging requirements were met. Results: PASS (Accepted if Is the packaging or parts of the Application Tray damaged; Is the Packaging or parts of the Base Tray damaged; Are the labels and packing list still affixed and legible.)
  • Reprocessing: The TCAT® TKA Instrument Tray Sets were evaluated for cleanability according to the user instructions. The results indicated cleanability requirements were met. Results: PASS. (Accepted if Observer shall provide each participant with an IFU; Observer shall ask each participant to read the IFU carefully; Observer shall ask each user to simulate the reprocessing steps according to the IFU; Observer shall fill out the data collection sheet; indicates all reprocessing steps PASS).
  • Biocompatibility (ANSI/AAMI/ISO 10993-5:2009 - Biological Evaluation of Medical Devices - Part 5: Tests for In Vitro Cytotoxicity): The TCAT® TKA Instrument Tray Sets were evaluated for biocompatibility according to ISO 10993-1. The results indicated biocompatibility requirements were met. Results: PASS (Accepted if MEM Elution Study -Test article meets a passing score of 2 or below; test article is not considered to have a cytotoxic potential.)
  • Use and Sterile Processing Guide: The TCAT® TKA Instrument Tray Sets were evaluated in accordance with the appropriate guidances. The results indicated use and Sterile Processing Guide requirements were met. Results: PASS (Accepted if Participant is able to load components in the tray; Participant is able to load components in the tray with the aid of visual indications showing storage location of each instrument; Participant is able to carry one Instrument Tray; Participant is able to load all components in the tray without requiring an additional tool; Participant is able to remove all components in the tray without requiring an additional tool).

No clinical or animal testing were required.

Key Metrics

Not Found

Predicate Device(s)

K180127

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 & 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 blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

April 8, 2020

THINK Surgical, Inc. George Prendergast Manager, Regulatory Affairs 47201 Lakeview Blvd Fremont, California 94538

Re: K200632

Trade/Device Name: TCAT® TKA Instrument Tray Set Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: KCT Dated: March 9, 2020 Received: March 10, 2020

Dear George Prendergast:

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,

For Christopher K. Dugard, MS Acting Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality 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)

K200632 Device Name TCAT® TKA Instrument Tray Set

Indications for Use (Describe)

The THINK Surgical TCAT® TKA Instrument Tray Set is intended to protect, organize, and deliver to the surgical field TCAT® tools, instruments and accessories. The trays allow sterilization of tools, instruments and accessories, and maintain sterility of the enclosed devices until used. The trays are wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.

[See the following page for the THINK Surgical compatible devices, sterilization parameters and description of the TCAT® TKA Instrument Tray Set.]

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

_ Prescription Use (Part 21 CFR 801 Subpart D)

X 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."

FORM FDA 3881 (7/17)

er PSC Publishing Services (301) 443-6740

3

FORM FDA 3881 (CONTINUED)

The following is the continuation of FORM FDA 3881 for the TCAT® TKA Instrument Tray Indications for Use

Table 1 lists the lists the THINK Surgical compatible devices:

Intended instrument tray set contentsDescription
TCAT General Instruments, Tools and AccessoriesInstruments, tools and accessories intended
for general use with the TSolution One®
Surgical System (TCAT®)
TCAT TKA Instruments, Tools, and AccessoriesInstruments, tools and accessories intended
for TKA use with the TSolution One®
Surgical System (TCAT®)

Table 2 lists the sterilization parameters under which the TCAT® TKA Instrument Tray Set was validated:

CycleCycle TemperatureExposure TimeDry Time
Pre-vacuum132°C (270°F)4 minutes45 minutes

Table 3 provides a description of the TCAT® TKA Instrument Tray Set (109154):

Table 3: Dimensions and weights
Tray NameDimensions (inches) L x W x HWeight (lbs) Unloaded:Loaded
TCAT® TKA Base Tray
PN 10773520 x 9.8 x 4.514.21lbs.17.33lbs.
TCAT® TKA Application Tray
PN 10773720 x 9.8 x 4.57.5lbs.18.0lbs.

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Image /page/4/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with a blue triangle replacing the "I". Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. The logo is simple and modern, and the blue triangle adds a touch of color and visual interest.

SECTION 6

K200632 510(k) SUMMARY

This 510(k) summary is submitted in accordance with 21CFR 807.92

Applicant Information:

Owner Name:THINK Surgical, Inc.
Address:47201 Lakeview Blvd.
Fremont, CA 94538
Phone:510-249-2337
Fax510-249-2396
Establishment Registration Number:3000719653
Contact Person:George J. Prendergast
Date Prepared:March 09, 2020
Device Information:
Classification:Class II
Trade Name:TCAT® TKA Instrument Tray Set
Common name:Sterilization Wrap
Classification name:Sterilization Wrap
Regulation number:21 CFR 880.6850
Classification Code:KCT

Predicate Device:

TCAT® THA Instrument Tray Set cleared via K180127.

Device Modification:

The changes to the predicated device allow tools, instruments and accessories to be utilized during a total knee arthroplasty (TKA) procedure. The only modification to this device is one tray set (the Application Tray Set) contains new tools, instruments and accessories for a total knee arthroplasty replace those tools instruments and accessories which were included in the TCAT®THA Instrument Tray Set (the predicate device).

Device Description:

The TCAT® TKA Instrument Tray Set is intended only for use with TSolution One® Total Knee Application instruments, tools and accessories. These trays are used to enclose and hold the instruments tools and accessories in an organized manner during the

5

Image /page/5/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with a blue, triangular shape replacing the "I". Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. The logo is simple and modern, and the blue triangle adds a touch of color and visual interest.

TCAT®TKA Instrument Tray Set Special 510(k) Submission

sterilization process and subsequent storage and transportation to and from the surgical suite. The trays are designed to fit any standard autoclave and are constructed primarily of anodized aluminum meeting biocompatibility requirements and are compatible with repeated steam sterilizations. The trays have perforations to facilitate sterilant penetration, evacuation and drying. Since the trays are perforated, an FDA-cleared sterilization wrap must be used to maintain sterility of the contents.

The trays have the same size and same basic configuration of the predicate device: a rectangular base with a latchable lid. The trays have perforations with an evenly distributed hole pattern on the lid, bottom, and sides to allow sterilant penetration. The bottom surface and interior shelves of the trays contain stanchions designed to separately hold each individual instrument, tool and accessory for effective sterilant exposure, evacuation and drying during the entire duration of the sterilization process, as well as ease of locating each instrument when placing in or removal from the tray.

The sterilization trays have been tested only with THINK Surgical instruments, tools and accessories for a 4 minute sterilization cycle of pre-vacuum steam sterilization at 132°C, with a 45 minute dry time. While reuseable, these trays will not be serviced or repaired. The type and maximum number of instruments, tools and accessories for each of the trays follow:

TCAT® TKA Base Tray (Tray 1 Top)
Part NumberDescriptionQuantity
103426Cutter Motor1
106298-04Digitizer Ball Probe1
106382Digitizer Probe Hub1
103593Recovery Marker Installation Tool1
102940Cutter Verification Gauge1
103636Cutter Wrench Set1
105716Wrench, Hex, 2.5mm1
103279Wrench, Hex, 8mm1
101884Wrench, T-Handle, Square, 8mm1
104948BMM Probe Assembly1
Hospital SuppliedFixation Clamp, Ø4-5mm pin/Ø8mm rod2
Hospital SuppliedFixation Clamp, Ø8mm rod/Ø8mm rod1
Hospital SuppliedFixation Clamp, Ø3-4mm pin/Ø5mm rod1
TCAT ® TKA Base Tray (Tray 1 Bottom)
Part NumberDescriptionQuantity
103205Fixation Arm, Straight1
106219Fixation Adapter Rod, Right-Angle 4 inch1
103414Swivel Block1
100086Wrench, Open End, 1-1/8 inch1
103384Cutter Motor Cable1

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Image /page/6/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in bold, sans-serif font, with a blue vertical line replacing the "I". Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. The logo is simple and modern, and the blue line adds a touch of color and visual interest.

TCAT® TKA Application Tray (Tray 2 top)
Part NumberDescriptionQuantity
106219Fixation Adapter Rod, Right Angle1
104948BMM Probe Assembly1
106825Spiked Disk, Femoral Epicondylar Clamp2
102613Recovery Marker, Tack, Ø1.5x11mm2
106413Cutter Bearing Sleeve, 120mm1
106298-03Digitizer Percutaneous Probe1
107720Recovery Marker, Groove, Ø4x125mm2
Hospital SuppliedFixation Pin, Self-Drilling, Ø3x125mm1
Hospital SuppliedFixation Pin, Self-Drilling, Ø4x125mm2
103454-NSCutter, Ø2.0x159mm1
103455Cutter, Ball Probe, 151mm1
106428Cutter, Flat, Ø6.2x144mm1
103450Fixation Adapter Rod, Straight2
TCAT® TKA Application Tray (Tray 2 Bottom)
Part NumberDescriptionQuantity
107714Cutter Drive Assembly, TKA1
103206Fixation Arm, Straight1
103414Swivel Block1
Hospital SuppliedWrench, Nut Driver, 5mm1
106824Clamp, Femoral Epicondylar1

Indications for Use:

The THINK Surgical TCAT®TKA Instrument Tray Set is intended to protect, organize, and deliver to the surgical field TCAT tools, instruments and accessories. The trays allow sterilization of tools, instruments and accessories and maintain sterility of the enclosed devices until used. The trays are wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.

Technological Characteristics Comparison Table

Three fundamental characteristics are the same between the two devices:

    1. Basic design: Both the TCAT®TKA Instrument Tray Set and the predicate device have a basic lid/base design with latches, handles, perforations, and contoured inserts or sections for containing items for sterilization, storage and transport. General size, shape, weight and materials are the same.
    1. Role in sterile barrier system: The TCAT® TKA Instrument Tray Set and the predicate device must be wrapped with an FDA-cleared sterilization wrap to maintain sterility. Neither the subject device or the predicate contains gaskets, valves nor filters.
    1. Fundamental technology: The TCAT®TKA Instrument Tray Set and the predicate device allow the sterilant (steam) to penetrate and render its contents sterile by relying on surface perforations.

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Image /page/7/Picture/1 description: The image shows the logo for "THINK Surgical". The word "THINK" is written in large, bold, sans-serif letters, with the "I" in "THINK" being a blue, elongated triangle. Below the word "THINK" is the word "SURGICAL" in smaller, sans-serif letters. The logo is simple and modern, and the blue "I" adds a touch of color and visual interest.

The following tables provide a comparison of technological characteristics between the subject device and the predicate device (Table 4) and a summary of non-clinical performance testing (Table 5).

| Characteristic | TCAT® TKA Instrument
Tray Set
(Subject Device) | TCAT® THA Instrument
Tray Set (Predicate
Device) | Comparison |
|-------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| 510(k) number | K200632 | K180127 | |
| Manufacturer | THINK Surgical Inc. | THINK Surgical Inc. | |
| Intended Use | The THINK Surgical
TCAT® TKA Instrument
Tray Set is intended to
protect, organize and
deliver to the surgical field
TCAT® tools, instruments
and accessories. The
trays allow sterilization of
tools, instruments and
accessories, and maintain
sterility of the enclosed
devices until used. The
trays are wrapped with an
FDA-cleared sterilization
wrap during the pre-
vacuum autoclave
sterilization process. | The THINK Surgical
TCAT® THA Instrument
Tray Set is intended to
protect, organize and
deliver to the surgical field
TCAT® tools, instruments
and accessories. The trays
allow sterilization of tools,
instruments and
accessories, and maintain
sterility of the enclosed
devices until used. The
trays are wrapped with an
FDA-cleared sterilization
wrap during the pre-
vacuum autoclave
sterilization process. | Same |
| Intended
Instrument Tray
Contents | TCAT® General
Instrument, Tools and
Accessories:
Instruments, tools and
accessories intended for
general use with the
TCAT® TSolution One®
Total Knee Application.
TCAT® TKA Instruments,
Tools and Accessories:
Instruments, tools and
accessories intended for
use with the TCAT®
TSolution One® Total
Knee Application. | TCAT® General
Instrument, Tools and
Accessories:
Instruments, tools and
accessories intended for
general use with the
TCAT® Surgical System.
TCAT® THA Instruments,
Tools and Accessories:
Instruments, tools and
accessories intended for
use with the TCAT®
Surgical System. | Identical |
| Intended
Instrument Tray
Set Contents
Maximum Load | Medical devices/
instruments weighing no
less than 7.5lbs-18.0lbs.
total including the weight
of the trays. | Medical devices/
instruments weighing no
less than 14.21lbs-
14.39lbs. total including
the weight of the trays. | Similar |
| Design Characteristics | | | |
| Device
Composition | Base, lift out tray, lid | Base, lift out tray, lid | Same |
| Inserts | Yes | Yes | Same |
| Characteristic | TCAT® TKA Instrument
Tray Set
(Subject Device) | TCAT® THA Instrument
Tray Set (Predicate
Device) | Comparison |
| 510(k) number | TBD | K180127 | |
| Manufacturer | THINK Surgical Inc. | THINK Surgical Inc. | |
| Handles | Yes | Yes | Same |
| Latches | Yes | Yes | Same |
| Reusable | Yes | Yes | Same |
| Materials | | | |
| Lid/base/Lift out
tray, not including
inserts | Aluminum | Aluminum | Same |
| Inserts | Silicone, aluminum,
stainless steel, nylon | Silicone, aluminum,
stainless steel, nylon | Same |
| Latch | Stainless steel | Stainless steel | Same |
| Assembled
Dimensions | 20" x 9.8" x 4.5" | 20" x 9.8" x 4.5" | Same |
| Weight containing
max load | 18.0lbs. | 19.5lbs. | Similar |
| Sterilization | | | |
| Percent of surface perforations | | | |
| -lid | 21% | 21% | Same |
| -base | 19% | 19% | Same |
| -lift out tray | 22% | 22% | Same |
| Sterilization
Method | Pre-Vacuum (Steam) | Pre-Vacuum (Steam) | Same |
| Cycle | 132°C (270°F) | 132°C (270°F) | Same |
| Temperature | | | |
| Cycle Time | 4 minutes | 4 minutes | Same |
| Drying Time | 45 minutes | 45 minutes | Same |

Table 4: Comparison of Technological Characteristics Between the Subject Device and the Predicate Device

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Image /page/8/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in bold, sans-serif font, with the "I" in "THINK" being a blue triangle pointing downwards. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font.

Non-Clinical Performance Testing

Table 5 summarizes the non-clinical performance testing of the TCAT® TKA Instrument Tray Set:

  • Sterilization Efficacy
  • . Packaging
  • . Cleaning
  • Biocompatibility .
  • Use and Sterile Processing Guide .

9

Image /page/9/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in bold, sans-serif font, with the "I" represented by a blue, elongated triangle. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font.

TCAT®TKA Instrument Tray Set Special 510(k) Submission

Table 5: Summary of Non-Clinical Performance Testing
--------------------------------------------------------

| Non-Clinical

Performance TestingPurposeAcceptance CriteriaResults
Sterilization Efficacy
(ANSI/AAMI/ISO
14937:2013 -
Sterilization of
Healthcare Product -
General Requirements
for Characterization of a
Sterilizing Agent and
the Development,
Validation and Routine
Control of a Sterilization
Process for Medical
Devices)To verify the TCAT® TKA
Instrument Tray Sets containing
the maximum load were inoculated
with biological indicators placed in
areas of the trays deemed to be
most difficult for sterilant (steam) to
penetrate. Following inoculation,
the trays were wrapped in FDA-
cleared sterilization wraps. The
trays indicated that the BI Overkill
method provided a six-log
reduction of the indicator organism.-All biological indicators
(BIs) must be incubated
for a minimum of 7 days
at 55°C-60°C
-The positive control for
the SAL testing must
show characteristic
growth of the indicator
organism
-Valid temperature data
must be collected for
each product probe
location
-Temperature probes
used during profiling of
the test article must be
within ±0.5°C of at least
one post calibration
reference temperature
that is representative of
the profiling cycles
-All directly-inoculated
test article components
must demonstrate to
contain no bacteriostatic
properties by showing
growth of G.
stearothermophilus
during method suitability
testing
Packaging (ASTM
D4169-16 - Standard
Practice for
Performance Testing of
Shipping Containers
and Systems)To verify the TCAT® TKA
Instrument Tray Sets were
evaluated with maximum load,
wrapped according to use
instructions and in the shipping
configuration
according to a shipping
validation test. The results
indicate packaging
requirements were met.-Is the packaging or parts
of the Application Tray
damaged
-Is the Packaging or parts
of the Base Tray
damaged
-Are the labels and
packing list still affixed
and legiblePASS
ReprocessingTo verify the TCAT® TKA
Instrument Tray Sets were
evaluated for cleanability
according to the user
instructions. The results
indicated cleanability
requirements were met.-Observer shall provide
each participant with an
IFU
-Observer shall ask each
participant to read the IFU
carefully
-Observer shall ask each
user to simulate the
reprocessing steps
according to the IFU
-Observer shall fill out the
data collection sheetPASS
indicates all reprocessing
steps PASS
Biocompatibility
(ANSI/AAMI/ISO 10993-
5:2009 - Biological
Evaluation of Medical
Devices - Part 5: Tests
for In Vitro Cytotoxicity)To verify the TCAT® TKA Instrument
Tray Sets were
evaluated for biocompatibility
according to ISO 10993-
  1. The results indicated
    biocompatibility requirements
    were met. | MEM Elution Study
    -Test article meets a
    passing score of 2 or
    below; test article is not
    considered to have a
    cytotoxic potential | PASS |
    | Use and Sterile
    Processing Guide | To verify the TCAT® TKA Instrument
    Tray Sets were evaluated in
    accordance with the appropriate
    guidances. The results
    indicated use and Sterile
    Processing Guide
    requirements were met. | -Participant is able to load
    components in the tray
    -Participant is able to load
    components in the tray
    with the aid of visual
    indications showing
    storage location of each
    instrument
    -Participant is able to
    carry one Instrument Tray
    -Participant is able to load
    all components in the tray
    without requiring an
    additional tool
    Participant is able to
    remove all components in
    the tray without requiring
    an additional tool | PASS |

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TCAT®TKA Instrument Tray Set Special 510(k) Submission

Clinical and Animal Testing

No clinical or animal testing were required.

Conclusion

The conclusions drawn from the nonclinical and clinical tests demonstrate that the TCAT® TKA Instrument Tray Set is as safe, as effective, and performs as well as or better than the legally marketed device.