K Number
K210087
Device Name
Athena Surgical RMUS System
Date Cleared
2021-04-12

(89 days)

Product Code
Regulation Number
878.3300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Athena Surgical RMUS System is indicated for use as a pubourethral sling for treatment of female stress urinary incontinence resulting from urethral hypermobility and/or intrinsic sphincter deficiency.
Device Description
The Athena Surgical RMUS System consists of a sterile, single-use Retropubic Mid-Urethral Sling (RMUS) Implant Assembly and a non-sterile, reusable RMUS Handle Assembly. Each RMUS Implant Assembly contains one blue polypropylene mesh sling implant (1.1cm x 46cm), covered by a non-implantable clear plastic sheath and attached on each end to nonimplantable stainless steel needles. The mesh implant is constructed of knitted filaments of extruded polypropylene strands and is approximately 0.63mm thick. The Athena Surgical RMUS Implant Assembly is designed to be used with the non-sterile, reusable Athena Surgical RMUS Handle Assembly, which consists of two parts: the Handle Body and the Handle Insert. The stainless steel needles from the RMUS Implant Assembly are designed to fit inside the RMUS Handle Assembly, which is used to position the implantable mesh in the patient from a vaginal incision up through the abdominal wall.
More Information

Not Found

No
The device description and performance studies focus on the mechanical properties and surgical delivery system of a mesh implant, with no mention of AI or ML.

Yes

The device is indicated for the treatment of female stress urinary incontinence, which is a medical condition, making it a therapeutic device.

No

Explanation: The device is described as a surgical sling system used for treatment of stress urinary incontinence. Its purpose is to physically treat a condition by supporting anatomical structures, not to diagnose a disease or condition.

No

The device description clearly states it consists of a sterile, single-use implant assembly (mesh sling, sheath, needles) and a non-sterile, reusable handle assembly, which are physical hardware components.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. These tests are performed outside the body (in vitro).
  • Device Description and Intended Use: The Athena Surgical RMUS System is a surgical implant (a pubourethral sling) used to treat stress urinary incontinence. It is physically implanted into the patient's body to provide support.
  • Lack of Diagnostic Testing: The description and intended use do not mention any form of testing on biological samples or providing diagnostic information. The device's function is purely mechanical support.

The information provided clearly describes a surgical device for implantation, not a device used for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The Athena Surgical RMUS System is indicated for use as a pubourethral sling for treatment of female stress urinary incontinence resulting from urethral hypermobility and/or intrinsic sphincter deficiency.

Product codes

OTN

Device Description

The Athena Surgical RMUS System consists of a sterile, single-use Retropubic Mid-Urethral Sling (RMUS) Implant Assembly and a non-sterile, reusable RMUS Handle Assembly. Each RMUS Implant Assembly contains one blue polypropylene mesh sling implant (1.1cm x 46cm), covered by a non-implantable clear plastic sheath and attached on each end to nonimplantable stainless steel needles. The mesh implant is constructed of knitted filaments of extruded polypropylene strands and is approximately 0.63mm thick.

The Athena Surgical RMUS Implant Assembly is designed to be used with the non-sterile, reusable Athena Surgical RMUS Handle Assembly, which consists of two parts: the Handle Body and the Handle Insert. The stainless steel needles from the RMUS Implant Assembly are designed to fit inside the RMUS Handle Assembly, which is used to position the implantable mesh in the patient from a vaginal incision up through the abdominal wall.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

pubourethral

Indicated Patient Age Range

female

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 testing:
The subject device was successfully evaluated according to the following:

  • Mechanical performance testing
    • Ultimate tensile strength .
    • . Elongation at break
    • . Stiffness bending strength
    • . Burst strength
    • . Dimensional analysis (monofilament diameter, device width, pore size, mesh thickness, mesh density, mesh weave characteristics)
  • Sterilization validation per ISO 11135:2014
  • Reprocessing validation for reusable instrumentation ■
  • Shelf life testing evaluating packaging integrity and mechanical performance
  • Biocompatibility per ISO 10993-1
    • Implant Sheath and Needles (external communicating device contacting tissue for less than 24 . hours)
      • o Cytotoxicity
      • Sensitization O
      • Irritation O
      • Acute systemic toxicity O
    • Mesh (permanent implant contacting tissue for greater than 30 days) ●
      • Cytotoxicity O
      • Sensitization O
      • Irritation O
      • Acute systemic toxicity O
      • Implantation O
      • Subacute toxicity, subchronic toxicity, genotoxicity, and carcinogenicity through O chemical characterization and toxicological risk assessment
  • . Pyrogenicity testing

Clinical testing:
Clinical testing was not required to demonstrate substantial equivalence in this premarket notification.

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

Not Found

Predicate Device(s)

K132054

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.3300 Surgical mesh.

(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services USA 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 9, 2021

Athena Surgical, LLC % Kellen Hills Biomedical Engineer Medavise Consulting 8725 Columbine Rd. #44952 Eden Prairie, MN 55344

Re: K210087

Trade/Device Name: Athena Surgical RMUS System Regulation Number: 21 CFR& 878.3300 Regulation Name: Surgical Mesh Regulatory Class: II Product Code: OTN Dated: January 11, 2021 Received: January 13, 2021

Dear Kellen Hills:

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.

1

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-regulatoryinformation/postmarketing-safety-reporting-combination-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,

Sharon M. Andrews -S

For

Jessica K. Nguyen, Ph.D. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K210087

Device Name Athena Surgical RMUS System

Indications for Use (Describe)

The Athena Surgical RMUS System is indicated for use as a pubourethral sling for treatment of female stress urinary incontinence resulting from urethral hypermobility and/or intrinsic sphincter deficiency.

X 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/1 description: The image shows the logo for Athena Surgical. The word "ATHENA" is written in large, yellow, sans-serif font. Below the word "ATHENA" is the word "SURGICAL" written in a smaller, blue, sans-serif font.

510(k) Summary
[As Required by 21 CFR 807.92]

(a)(1) Date Prepared:January 11, 2021
Submitted By:Athena Surgical, LLC
6110 Blue Circle Drive, Suite 280
Minnetonka, MN 55343
Phone:612.888.9394
Contact:Greg Slusser
Prepared By:Medavise, LLC
8725 Columbine Rd. #44952
Eden Prairie, MN 55344
Phone:612.405.4059
(a)(2) Proprietary Name:Athena Surgical RMUS System
Common Name:Urinary sling
Classification Regulation:
Class:
Product Code:21 CFR 878.3300 - Surgical Mesh
ll
OTN - Mesh, Surgical, Synthetic,
Urogynecologic, For Stress Urinary
Incontinence, Retropubic Or
Transobturator
(a)(3) Predicate Devices:
Primary:Ethicon GYNECARE TVT EXACT™

*No predicate has been subject to a design related recall.

(a)(4) Device Description:

The Athena Surgical RMUS System consists of a sterile, single-use Retropubic Mid-Urethral Sling (RMUS) Implant Assembly and a non-sterile, reusable RMUS Handle Assembly. Each RMUS Implant Assembly contains one blue polypropylene mesh sling implant (1.1cm x 46cm), covered by a non-implantable clear plastic sheath and attached on each end to nonimplantable stainless steel needles. The mesh implant is constructed of knitted filaments of extruded polypropylene strands and is approximately 0.63mm thick.

(K132054);

The Athena Surgical RMUS Implant Assembly is designed to be used with the non-sterile, reusable Athena Surgical RMUS Handle Assembly, which consists of two parts: the Handle Body and the Handle Insert. The stainless steel needles from the RMUS Implant Assembly

6110 Blue Circle Drive | Suite 280 | Minnetonka, MN 55343

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Image /page/4/Picture/1 description: The image shows the logo for Athena Surgical. The word "ATHENA" is written in large, gold, sans-serif font. Below the word "ATHENA" and slightly to the left is the word "SURGICAL" in a smaller, sans-serif font.

are designed to fit inside the RMUS Handle Assembly, which is used to position the implantable mesh in the patient from a vaginal incision up through the abdominal wall.

The purpose of this submission is to gain initial marketing authorization in the United States.

  • (a)(5) Indications for Use:
    The Athena Surgical RMUS System is indicated for use as a pubourethral sling for treatment of female stress urinary incontinence resulting from urethral hypermobility and/or intrinsic sphincter deficiency.

  • (a)(6) Comparison of Technological Characteristics:
    The Athena Surgical RMUS System is substantially equivalent to the identified predicate based on similarities in intended use, design, materials, sterilization and performance. The technological characteristics do not raise any new questions of safety and efficacy.

Subject Athena Surgical RMUS SystemPredicate Ethicon GYNECARE TVT™
510(k)TBDK132054
Regulation and
Product Code21 CFR 878.3300 - OTNSame
Intended UseThe Athena Surgical RMUS System is
intended to treat female stress urinary
incontinence.Same
IndicationsThe Athena Surgical RMUS System is
indicated for use as a pubourethral sling
for treatment of female stress urinary
incontinence resulting from urethral
hypermobility and/or intrinsic sphincter
deficiency.The GYNECARE TVT EXACT Continence
System is intended to be used as a pubo-
urethral sling for treatment of female
Stress Urinary Incontinence, resulting
from urethral hypermobility and/or
intrinsic sphincter deficiency.
MaterialsMesh - Polypropylene
Sheath - Low Density Polyethylene
Needle - Stainless SteelSame
Delivery System
DesignHandle with detachable curved NeedleHandle with fixed curved Needle
Entry MethodTransvaginal RetropubicSame
SterilityEtO, SAL 10-6, single-useSame
PerformanceUltimate Tensile Strength
Elongation at Break
Stiffness Bending LengthSame

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K210087 Page 3 of 3

Image /page/5/Picture/1 description: The image shows the word "ATHENA" in a stylized, sans-serif font. The letters are a golden color. Below the word "ATHENA" is the word "SURGICAL" in a smaller, sans-serif font. The word "SURGICAL" is a light blue color.

(b)(1) Non-clinical testing:

i

The subject device was successfully evaluated according to the following:

  • Mechanical performance testing
    • Ultimate tensile strength .
    • . Elongation at break
    • . Stiffness bending strength
    • . Burst strength
    • . Dimensional analysis (monofilament diameter, device width, pore size, mesh thickness, mesh density, mesh weave characteristics)
  • 트 Sterilization validation per ISO 11135:2014
  • Reprocessing validation for reusable instrumentation ■
  • I Shelf life testing evaluating packaging integrity and mechanical performance
  • 트 Biocompatibility per ISO 10993-1
    • Implant Sheath and Needles (external communicating device contacting tissue for less than 24 . hours)
      • o Cytotoxicity
      • Sensitization O
      • Irritation O
      • Acute systemic toxicity O
    • Mesh (permanent implant contacting tissue for greater than 30 days) ●
      • Cytotoxicity O
      • Sensitization O
      • Irritation O
      • Acute systemic toxicity O
      • Implantation O
      • Subacute toxicity, subchronic toxicity, genotoxicity, and carcinogenicity through O chemical characterization and toxicological risk assessment
  • . Pyrogenicity testing

(b)(2) Clinical testing:

Clinical testing was not required to demonstrate substantial equivalence in this premarket notification.

(b)(3) Conclusions:

Based on the information provided in this premarket notification the subject Athena Surgical RMUS System demonstrates substantial equivalence to the identified predicate device.