K Number
K202268
Device Name
CrossRoads Tray System
Date Cleared
2020-12-30

(141 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The CrossRoads Tray System is used in healthcare facilities to store and organize CrossRoads surgical instruments and components during cleaning/sterilization and during implant/prosthetic treatment. The CrossRoads Tray System are not intended on their own to maintain sterility; it is intended to be used in conjunction with a legally marketed, validated, FDA-cleared sterilization pouch or sterilization wrap. Sterilization for the worst-case CrossRoads Tray System included surgical instruments such as drills, inserters, reamers, fixation pin, benders, and ratcheting handles. The CrossRoads Tray System were validated for a maximum load of 8.5 lbs (tray + instruments). Method: Steam Sterilization (Moist Heat Sterilization) Cycle Prevacuum Temperature: 270 °F (132 °C) Exposure time: 4 minutes Drying time: 20 minutes The tray is 20.60" length x 9.80" width x 2.00" depth.
Device Description
The subject CrossRoads Tray System is a reusable sterilization tray or organizing tray intended for use in health care facilities for the purpose of containing reusable medical devices for sterilization. It is composed of multiple pieces, designed to be integrated into a single unit which contains and protects the interior components during sterilization. All components are perforated for steam penetration. The tray can hold implants and instruments such as inserters, K-wire guides, fixation pins, reamers and ratcheting handles. The tray is 20.60" length x 9.80" width x 2.00" depth. The CrossRoads Tray System tray is manufactured from aluminum conforming to ASTM B029, silicone, 304 stainless steel conforming to ASTM A240 and ASTM A313, 18-8 stainless steel, 17-4 stainless steel 304 stainless steel, and 316 stainless steel.
More Information

Not Found

No
The device is a physical tray system for organizing and sterilizing surgical instruments. There is no mention of any software, algorithms, or data processing that would indicate the use of AI/ML.

No.
The device is a sterilization tray system designed to hold instruments for sterilization and storage, not to diagnose, treat, or prevent disease.

No

The device is a sterilization tray system used to store and organize surgical instruments for cleaning and sterilization, not for diagnostic purposes.

No

The device description clearly states it is a reusable sterilization tray made of physical materials (aluminum, silicone, stainless steel) and is intended for containing and protecting physical medical devices during sterilization. There is no mention of software components.

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

Here's why:

  • Intended Use: The intended use clearly states that the CrossRoads Tray System is used for storing and organizing surgical instruments and components during cleaning/sterilization and during implant/prosthetic treatment. This is a function related to the preparation and handling of surgical tools, not for performing diagnostic tests on samples taken from the human body.
  • Device Description: The description reinforces its purpose as a reusable sterilization tray or organizing tray for containing reusable medical devices for sterilization.
  • Lack of Diagnostic Function: There is no mention of the device being used to analyze biological samples (blood, urine, tissue, etc.) or to provide information about a patient's health status or disease.
  • Performance Studies: The performance studies focus on sterilization efficacy, reprocessing (cleanability), and biocompatibility, which are all relevant to surgical instrument trays but not to IVD devices.

IVD devices are specifically designed to be used in vitro (outside the body) to examine specimens derived from the human body to provide information for diagnostic, monitoring, or screening purposes. The CrossRoads Tray System does not fit this definition.

N/A

Intended Use / Indications for Use

The CrossRoads Tray System is used in healthcare facilities to store and organize CrossRoads surgical instruments and components during cleaning/sterilization and during implant/prosthetic treatment. The CrossRoads Tray System are not intended on their own to maintain sterility; it is intended to be used in conjunction with a legally marketed, validated, FDA-cleared sterilization pouch or sterilization wrap. Sterilization for the worst-case CrossRoads Tray System included surgical instruments such as drills, inserters, reamers, fixation pin, benders, and ratcheting handles. The CrossRoads Tray System were validated for a maximum load of 8.5 lbs (tray + instruments).

Method: Steam Sterilization (Moist Heat Sterilization) Cycle Prevacuum
Temperature: 270 °F (132 °C)
Exposure time: 4 minutes
Drying time: 20 minutes

The tray is 20.60" length x 9.80" width x 2.00" depth.

Product codes

KCT

Device Description

The subject CrossRoads Tray System is a reusable sterilization tray or organizing tray intended for use in health care facilities for the purpose of containing reusable medical devices for sterilization. It is composed of multiple pieces, designed to be integrated into a single unit which contains and protects the interior components during sterilization. All components are perforated for steam penetration. The tray can hold implants and instruments such as inserters, K-wire guides, fixation pins, reamers and ratcheting handles.

The tray is 20.60" length x 9.80" width x 2.00" depth.

The CrossRoads Tray System tray is manufactured from aluminum conforming to ASTM B029, silicone, 304 stainless steel conforming to ASTM A240 and ASTM A313, 18-8 stainless steel, 17-4 stainless steel 304 stainless steel, and 316 stainless steel.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

healthcare facilities

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)

ER20-0010 Sterilization Efficacy

  • Purpose of Testing: To verify the CrossRoads Tray System 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 biological indicators (BI) Overkill method provided a six-log reduction of the indicator organism.
  • Acceptance Criteria: No growth on half cycles. No moisture on full drying cycle.
  • Results: In the three pre-vacuum autoclave cycles, 2 minutes at 270°F was sufficient to sterilize the BI's in the DynaBunion Non-Sterile Set, 15NS-4800, when seeded with (8) BI carriers impregnated with Geobacillus stearothermophilus and (2) SporView self-contained BI's. Since this is a half-cycle validation, the 4-minute full cycle exposure time will provide the required Sterility Assurance Level (SAL) of 10-6. Positive controls showed growth for all three cycles. Negative controls remained negative (no growth) for all three cycles. There was no evidence of moisture on or within the sterilized package, wrap, and instruments. There was no recorded weight gain after each of the pre-vacuum sterilization cycles.

20-0963 CREX Reprocessing

  • Purpose of Testing: To verify the instruments in the CrossRoads Tray System for cleanability according to the user instructions.
  • Acceptance Criteria: Meets the AAMI TIR-30 guideline acceptance criteria of

§ 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).

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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 and Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 30, 2020

CrossRoads Extremity Systems, LLC Kim Strohkirch Sr. Director, QA/RA/Compliance 6055 Primacy Pkwy, Suite 140 Memphis, Tennessee 38119

Re: K202268

Trade/Device Name: CrossRoads Tray System Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization wrap Regulatory Class: Class II Product Code: KCT Dated: December 1, 2020 Received: December 2, 2020

Dear Kim Strohkirch:

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 Clarence W. Murray, III, Ph.D. 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

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Indications for Use

510(k) Number (if known) K202268

Device Name CrossRoads Tray System

Indications for Use (Describe)

The CrossRoads Tray System is used in healthcare facilities to store and organize CrossRoads surgical instruments and components during cleaning/sterilization and during implant/prosthetic treatment. The CrossRoads Tray System are not intended on their own to maintain sterility; it is intended to be used in conjunction with a legally marketed, validated, FDA-cleared sterilization pouch or sterilization wrap. Sterilization for the worst-case CrossRoads Tray System included surgical instruments such as drills, inserters, reamers, fixation pin, benders, and ratcheting handles. The CrossRoads Tray System were validated for a maximum load of 8.5 lbs (tray + instruments).

Method:Steam Sterilization (Moist Heat Sterilization) Cycle Prevacuum
Temperature:270 °F (132 °C)
Exposure time:4 minutes
Drying time:20 minutes

The tray is 20.60" length x 9.80" width x 2.00" depth.

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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Image /page/3/Picture/0 description: The image shows the logo for CrossRoads Extremity Systems. The logo consists of a grid of four squares in the colors blue and green, followed by the text "CrossRoads" in gray. Below the text "CrossRoads" is the text "Extremity Systems" in a smaller font size, also in gray.

510(k) Summary K202268

Date:December 27, 2020
Device Name:CrossRoads Tray System
Establishment
Registration:3011421599
Company:CrossRoads Extremity Systems
6055 Primacy Parkway, Suite 140
Memphis, TN 38119 USA
Contact Person:Kim Strohkirch
Sr. Director, QA/RA/Compliance
CrossRoads Extremity Systems
901.221.8406
kstrohkirch@crextremity.com
Trade Name:CrossRoads Tray System
Common Name:Sterilization Tray
Classification:Class II
Regulation Number:21 CFR 880.6850 Sterilization Wrap Containers, Trays,
Cassettes & other Accessories
Panel:General Hospital
Product Code:KCT
Predicate Devices:K200632 TCAT TKA Instrument Tray Set
Device Description:The subject CrossRoads Tray System is a reusable
sterilization tray or organizing tray intended for use in
health care facilities for the purpose of containing reusable
medical devices for sterilization. It is composed of multiple
pieces, designed to be integrated into a single unit which
contains and protects the interior components during
sterilization. All components are perforated for steam
penetration. The tray can hold implants and instruments
such as inserters, K-wire guides, fixation pins, reamers and
ratcheting handles.

The tray is 20.60" length x 9.80" width x 2.00" depth.

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Image /page/4/Picture/0 description: The image shows the logo for "CrossRoads Extremity Systems". The logo consists of four squares in the colors blue and green, arranged in a 2x2 grid. To the right of the squares is the text "CrossRoads" in a gray, sans-serif font, with the trademark symbol. Below the text "CrossRoads" is the text "Extremity Systems" in a smaller, gray, sans-serif font.

The CrossRoads Tray System is used in healthcare Indications for Use: facilities to store and organize CrossRoads surgical instruments and components during cleaning/sterilization and during implant/prosthetic treatment. The CrossRoads Tray System are not intended on their own to maintain sterility; it is intended to be used in conjunction with a legally marketed, validated, FDA-cleared sterilization pouch or sterilization wrap. Sterilization validations for the worst-case CrossRoads Tray System included surgical instruments such as drills, inserters, reamers, fixation pin, benders, and ratcheting handles. The CrossRoads Tray System were validated for a maximum load of 8.5 lbs (tray + instruments).

MethodSteam Sterilization (Moist Heat Sterilization)
CyclePrevacuum
Temperature270 °F (132 °C)
Exposure time4 minutes
Drying time20 minutes

The tray is 20.60" length x 9.80" width x 2.00" depth.

The CrossRoads Tray System tray is manufactured from Materials: aluminum conforming to ASTM B029, silicone, 304 stainless steel conforming to ASTM A240 and ASTM A313, 18-8 stainless steel, 17-4 stainless steel 304 stainless steel, and 316 stainless steel.

Technology Characteristics:

Shown below is a Technological Characteristics Comparison Table that compares the subject device and the predicate device in this submission:

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Image /page/5/Picture/0 description: The image shows the logo for "CrossRoads Extremity Systems". The logo consists of four squares in the colors blue and green, followed by the text "CrossRoads" in a gray sans-serif font. Below the text "CrossRoads" is the text "Extremity Systems" in a smaller, lighter gray font. The logo is simple and modern, and the colors are calming and professional.

Subject DevicePredicate DeviceComparison
510(k)K202268K200632Different
NameCrossRoads Tray SystemTHINK Surgical TCAT TKA
InstrumentDifferent
Product CodeKCTKCTSame
Intended UseThe CrossRoads Tray System
is designed to hold various
surgical instruments in order to
organize, steam sterilize, and
transport the instruments
between uses. The trays are
wrapped with an FDA- cleared
sterilization wrap during the
pre- vacuum autoclave
sterilization process.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 allowaccessories, 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.Similar
Intended
Instrument
Tray Set
Content
Maximum
LoadMedical devices/ instruments
weighing no more than 8.5 lbs
(tray
  • instruments). | Medical devices/ instruments weighing no
    less than 7.5lbs-18.0lbs. total including
    the weight of the trays. | Different |
    | Material | Lid/base/Lift out tray -
    Aluminum Inserts - Silicone,
    aluminum, stainless steel
    Latch - Stainless steel | Lid/base/Lift out tray - Aluminum
    Inserts - Silicone, aluminum,
    stainless steel, nylon
    Latch - Stainless steel | Similar |
    | Design | Base and lid | Base, lift out tray, lid | Similar |
    | Insert | Yes | Yes | Same |
    | Dimensions | 20.60 length x 9.80 width x
    2.00 inches depth | 20 length x 9.8 width x 4.5 inches
    depth | Similar |
    | | Sterilization | | |
    | Sterilization
    Method | Pre-vacuum (Steam) | Pre-vacuum (Steam) | Same |
    | Cycle
    Temperature | 270 °F (132 °C) | 270 °F (132 °C) | Same |
    | Cycle Time | 4 minutes | 4 minutes | Same |
    | Drying Time | 20 minutes | 45 minutes | Different |
    | Non-Clinical
    Performance
    Test | • Sterilization Efficacy
    • Cleaning
    • Biocompatibility | • Sterilization Efficacy
    • Packaging
    • Cleaning
    • Biocompatibility
    • Use and Sterile Processing
    • Guide | Similar |

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Image /page/6/Picture/0 description: The image shows the logo for "CrossRoads Extremity Systems". The logo consists of four squares in the colors blue and green, followed by the text "CrossRoads" in gray. Below the text "CrossRoads" is the text "Extremity Systems" in a smaller font, also in gray. The logo is simple and modern, with a focus on the company name.

Performance Testing:

Name of TestingPurpose of TestingAcceptance CriteriaResults
ER20-0010
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
CrossRoads Tray
System 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
biological indicators (BI)
Overkill method
provided a six-log
reduction of the
indicator organism.No growth on half
cycles. No moisture
on full drying cycle.In the three pre-vacuum
autoclave cycles, 2 minutes
at 270°F was sufficient to
sterilize the BI's in the
DynaBunion Non-Sterile Set,
15NS-4800, when seeded
with (8) BI carriers
impregnated with
Geobacillus
stearothermophilus and (2)
SporView self-contained
BI's. Since this is a half-
cycle validation, the 4-
minute full cycle exposure
time will provide the required
Sterility Assurance Level
(SAL) of 10-6. Positive
controls showed growth for
all three cycles. Negative
controls remained negative
(no growth) for all three
cycles.
There was no evidence of
moisture on or within the
sterilized package, wrap,
and instruments. There was
no recorded weight gain
after each of the pre-vacuum
sterilization cycles.
20-0963 CREX
Reprocessing
(AAMI TIR12-2010
Designing, testing and
labeling reusable
medical devices for
reprocessing in health
care facilities: A guide
for medical device
manufacturers and
AAMI TIR30-2011 A
compendium of
processes, materials,
test methods and
acceptance criteria for
cleaning reusable
medical devices)To verify the
instruments in the
CrossRoads Tray
System for cleanability
according to the user
instructions.Meets the AAMI TIR-
30 guideline
acceptance criteria of
$\le$ 6.4µg/cm² protein
residuals and $\le$
2.2µg/cm² for
hemoglobin
residuals.Three (3) cleaning cycles
were performed on 5
instruments and meet the
acceptance criteria.
20-2723 CREX
(AAMI TIR12-2010
Designing, testing and
labeling reusableCrossRoads Tray
System for cleanability
according to the userMeets the AAMI TIR-
30 guideline
acceptance criteria of
$\le$ 6.4µg/cm² protein
residuals and $\le$
2.2µg/cm² for
hemoglobin
residuals.Three (3) cleaning cycles
were performed on the tray
and meet the acceptance
criteria.
Name of TestingPurpose of TestingAcceptance CriteriaResults
medical devices for
reprocessing in health
care facilities: A guide
for medical device
manufacturers and
AAMI TIR30-2011 A
compendium of
processes, materials,
test methods and
acceptance criteria for
cleaning reusable
medical devices)instructionsresiduals and ≤
$2.2µg/cm²$ for
hemoglobin
residuals.
ER20-0010
Biocompatibility
(ANSI/AAMI/ISO 10993-
5:2009 - Biological
Evaluation of Medical
Devices - Part 5: Tests
for In Vitro Cytotoxicity)To verify the
CrossRoads Tray
System were
evaluated for
biocompatibility
according to ISO 10993-
  1. The results indicated
    biocompatibility
    requirements were met | Pass is a score of
    less than 2. | There was no cytotoxic
    reaction observed (Grade 0)
    on the ratchet handle, for
    any of the sample extracts at
    24 and 48hrs contact.
    Positive controls were
    positive (Grade 4) at 24 and
    48hrs. |

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Image /page/7/Picture/0 description: The image shows the logo for "CrossRoads Extremity Systems". The logo consists of four squares arranged in a 2x2 grid on the left side. The top left square is dark blue, the top right square is green, the bottom left square is light green, and the bottom right square is light blue. To the right of the squares is the text "CrossRoads" in gray, with "Extremity Systems" in a smaller font below it.

Conclusion:

The conclusions drawn from the nonclinical tests demonstrate that the device is as safe, as effective, and performs as well as or better than the legally marketed predicate device.