MONOCRYL™ Plus Antibacterial Sutures are indicated for use in general soft tissue approximation and/or ligation, but not for use in cardiovascular or neurological tissues, microsurgery or ophthalmic surgery.

Device Description

MONOCRYL™ Plus Antibacterial Suture is a sterile, monofilament, synthetic, absorbable surgical suture composed of a copolymer of glycolide and (epsilon) s-caprolactone. The empirical formula of the polymer is (C2H2O2)m (C6H102)n.

MONOCRYL™ Plus Antibacterial Suture is available undyed and dyed with D&C Violet No. 2

MONOCRYL™ Plus Antibacterial Suture contains Irgacare®† MP (triclosan), a broad spectrum antibacterial agent, at no more than 2360 µg/m.

AI/ML Overview

This document is a 510(k) premarket notification for a medical device called MONOCRYL™ Plus Antibacterial Suture. It seeks to demonstrate substantial equivalence to a previously cleared device. Therefore, the information provided focuses on the equivalence of the modified device to its predicate, rather than detailing a de novo study to establish acceptance criteria and prove performance against them as would be typical for a novel device or AI/software.

Based on the provided text, here's an analysis of the "acceptance criteria" and "study" as they relate to this specific 510(k) submission:

Understanding the Context:

This submission (K201996) is for a modified device (MONOCRYL™ Plus Antibacterial Suture) that is largely identical to a predicate device (MONOCRYL™ Plus Antibacterial Poliglecaprone – 25 with 510(k) number K050845). The only reported changes are to the labeling, specifically updating in vitro effectiveness against an additional microorganism and including new descriptors/icons.

For a 510(k) involving minor changes, the "acceptance criteria" revolve around demonstrating that the modified device remains as safe and effective as the predicate, or that the changes do not raise new questions of safety or effectiveness. The "study" in this context refers to the data presented to support this claim, rather than a clinical trial for a new product.

1. A table of acceptance criteria and the reported device performance

Since this is a submission for a modified device essentially claiming no change in technological characteristics, the "acceptance criteria" are implicitly that the modified device retains the performance attributes of the predicate. The "reported device performance" is essentially a reaffirmation of the predicate's performance, along with specific in vitro data for the antibacterial claims.

Acceptance Criteria (Implicit for Substantial Equivalence)	Reported Device Performance (Summary from Document)
For Suture Material:
- Same technological characteristics as predicate (composition, structure, absorbability)	"The modified MONOCRYL™ Plus Suture has the same technological characteristics as the predicate device... it is a sterile, monofilament synthetic absorbable suture composed of a copolymer of glycolide and (epsilon) s-caprolactone."
- Compliance with USP standards for absorbable surgical sutures	"complies with the requirements of the United States Pharmacopoeia (USP) for absorbable surgical sutures except for a slight oversize in diameter." (This exception is noted as existing for the predicate as well, implying continued equivalence.)
For Antibacterial Efficacy:
- Contains Irgacare®† MP (triclosan) at specified concentration	"MONOCRYL™ Plus Antibacterial Suture contains Irgacare®† MP (triclosan), a broad spectrum antibacterial agent, at no more than 2360 µg/m."
- Inhibit colonization of specified bacteria	"In vitro efficacy studies were conducted to demonstrate that bacteria will not colonize MONOCRYL™ Plus Antibacterial suture. The in vitro data indicated that MONOCRYL™ Plus suture provides an antibacterial effect sufficient to inhibit colonization of the suture by Staphylococcus aureus, Staphylococcus epidermidis, Methicillin-Resistant S. aureus, Methicillin-Resistant S. epidermidis, Klebsiella pneumoniae, Escherichia coli and Enterobacter cloacae."
For Intended Use/Indications:
- Same intended use and indications for use as predicate	"The modified device has the same intended use and indications for use as the predicate device." (General soft tissue approximation/ligation, not for cardiovascular, neurological, microsurgery, or ophthalmic surgery).

2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

The document mentions "in vitro efficacy studies" for the antibacterial claims. Details on the specific sample sizes (e.g., number of suture samples, number of bacterial cultures) are not provided in this summary. The data provenance is described as "in vitro," implying laboratory studies, rather than patient data. No information on country of origin or retrospective/prospective nature is given, as it's not a clinical study.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This type of information is generally relevant for AI/radiology devices where expert consensus is used to label images. For a physical medical device like a suture, "ground truth" for material properties and antibacterial efficacy is established through standardized laboratory testing and validated analytical methods (e.g., chemical analysis, microbiology assays). The document does not specify the number or qualifications of experts involved in running these in vitro tests, as this is typically handled by qualified laboratory personnel following established protocols.

4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

Not applicable. Adjudication methods like 2+1 or 3+1 are used in clinical studies, particularly for imaging interpretation, to resolve discrepancies between readers. This document describes laboratory in vitro studies for which such an adjudication method is not relevant.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done. If so, what was the effect size of how much human readers improve with AI vs without AI assistance.

Not applicable. This device is a physical surgical suture, not an AI or imaging diagnostic tool. Therefore, MRMC studies and human reader improvement with AI assistance are not relevant.

6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done

Not applicable. This document is about a physical medical device, not an algorithm or AI.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

For the antibacterial claims, the "ground truth" would be established by the results of the microbiological in vitro assays which directly measure the inhibition of bacterial colonization on the suture material. For the material properties, the "ground truth" is established by chemical and physical testing against established standards (e.g., USP monographs). This is empirical data from laboratory studies, not consensus of human experts on subjective interpretations.

8. The sample size for the training set

Not applicable. This is not an AI/machine learning device that requires training data.

9. How the ground truth for the training set was established

Not applicable, as explained in point 8.

Summary

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December 21, 2020

Ethicon Inc. Joice Pappan Regulatory Affairs Manager Route 22 West. P.O. Box 151 Somerville, New Jersey 08876

Re: K201996

Trade/Device Name: Monocryl Plus Antibacterial Suture Regulation Number: 21 CFR 878.4493 Regulation Name: Absorbable Poly(Glycolide/L-Lactide) Surgical Suture Regulatory Class: Class II Product Code: GAM Dated: December 11, 2020 Received: December 14, 2020

Dear Joice Pappan:

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

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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,

Cindy Chowdhury, Ph.D., M.B.A. 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

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Indications for Use

510(k) Number (if known) K201996

Device Name

MONOCRYL™ Plus Antibacterial Poliglecaprone - 25 (Monofilament), Sterile Synthetic Absorbable Surgical Suture

Indications for Use (Describe)

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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ETHICON,INC.

won Johnson company a Joh

510(k) Summary

Submitter:	Ethicon, Inc., a Johnson & Johnson companyP.O. Box 151Route 22 WestSomerville, New Jersey 08876-0151USA
Contact Person:	Joice PappanRegulatory Affairs ManagerEthicon, Inc., a Johnson & Johnson companyPhone: (718) 419-1838Fax: (908) 541-3868E-mail: jpappan@its.jnj.com
Date Prepared:	July 17, 2020
Device Trade Name:	MONOCRYL™ Plus Antibacterial Poliglecaprone - 25(Monofilament), Sterile Synthetic Absorbable Surgical Suture
Device Common Name:	Suture, Absorbable, Synthetic, Polyglycolic Acid
Class:	II
Classification Name:	Absorbable poly(glycolide/l-lactide) surgical suture(21 CFR878.4493)
Product Code:	GAM

Predicate Device:

Predicate Device	510(k) Number
MONOCRYL™ Plus Antibacterial Poliglecaprone – 25	K050845
(Monofilament), Sterile Synthetic Absorbable Surgical Suture

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Device Description:

MONOCRYL™ Plus Antibacterial Suture is available undyed and dyed with D&C Violet No. 2

MONOCRYL™ Plus Antibacterial Suture contains Irgacare®† MP (triclosan), a broad spectrum antibacterial agent, at no more than 2360 µg/m.

Indications for Use:

Summary of Technological Characteristics and Performance:

The modified MONOCRYL™ Plus Suture has the same technological characteristics as the predicate device. Like the currently marketed predicate device, it is a sterile, monofilament synthetic absorbable suture that complies with the requirements of the United States Pharmacopoeia (USP) for absorbable surgical sutures except for a slight oversize in diameter.

Like the current marketed MONOCRYL™ Plus Antibacterial Suture, the modified device will continue to be available as a suture product with Irgacare®† MP, an antibacterial agent.

In vitro efficacy studies were conducted to demonstrate that bacteria will not colonize MONOCRYL™ Plus Antibacterial suture. The in vitro data indicated that MONOCRYL™ Plus suture provides an antibacterial effect sufficient to inhibit colonization of the suture by Staphylococcus aureus, Staphylococcus epidermidis, Methicillin-Resistant S. aureus, Methicillin-Resistant S. epidermidis, Klebsiella pneumoniae, Escherichia coli and Enterobacter cloacae.

Substantial Equivalence:

The modified device has the same intended use and indications for use as the predicate device. There are no material, construction, specification, manufacturing or sterilization process changes to the currently marketed device. The modified device and currently marketed device differ only in the labeling (Instruction for Use and device box) which have been revised for updating invitro effectiveness against an additional microorganism and to include new descriptor and icon to allow customers to easily distinguish between Ethicon MONOCRYL™ suture and Ethicon MONOCRYL™ Plus suture.

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Conclusion:

Since there will be no physical or technological characteristic changes to the currently marketed predicate device, the proposed labeling changes has shown to be appropriate for its intended use. Therefore, the modified device is substantially equivalent to the predicate device.

Trademark

IRGACARE®* MP (triclosan) "Registered Trademark of BASF Group"

Regulation Number and Section

§ 878.4493 Absorbable poly(glycolide/l-lactide) surgical suture.

(a)
Identification. An absorbable poly(glycolide/l-lactide) surgical suture (PGL suture) is an absorbable sterile, flexible strand as prepared and synthesized from homopolymers of glycolide and copolymers made from 90 percent glycolide and 10 percent l-lactide, and is indicated for use in soft tissue approximation. A PGL suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. “Monograph for Absorbable Surgical Sutures;” it may be monofilament or multifilament (braided) in form; it may be uncoated or coated; and it may be undyed or dyed with an FDA-approved color additive. Also, the suture may be provided with or without a standard needle attached.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.