K Number
K213104
Date Cleared
2022-07-29

(308 days)

Product Code
Regulation Number
888.3040
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Auxilock Titanium Screw-In Suture Anchor is intended to be used with #2 Biobraid suture with white, blue, black colors for use for the reattachment of soft tissue to bone for the following indications:

Shoulder:
Bankart lesion repairs, SLAP lesion repairs, Acromiolavicular separation repairs, Rotator cuff tear repairs, Capsular shift or Capsutolabral reconstructions, Biceps tenodesis, and Deltoid Repairs, Anterior Shoulder Instability Repair.

Foot and Ankle:
Hallux valgus reconstruction, Medial or Lateral instability repairs/reconstructions, Achilles tendon repair/reconstructions, Mid-foot reconstruction, Metatarsal ligament/tendon repairs/reconstructions, Bunionectomy.

Elbow, Wrist and Hand:
Scapholunate ligament reconstruction, Unar or radial collateral ligament reconstructions, Lateral epicondylitis repair, Biceps tendon reattachment, Tennis elbow repair.

Knee:
Extra-capsular repairs: Medial collateral ligament repair. Lateral ligament repair. Posterior oblique ligament. Iliotibial band tenodesis, Patellar tendon repair - Vastus medialis obliquous advancement.

Hip:
Capsular repair, Acetabular labral repair.

Device Description

The Titanium Screw-In Suture Anchor is a threaded, tapered fastener for use in attachment of soft tissue to bone. The self-tapping AUXILOCK® Titanium screw-in suture anchor is mostly used as a medial row anchor in rotator cuff repair surgery, Bankart or SLAP surgeries. It is recommended for use in small and large-joint repairs without the need for tapping or drilling. AUXILOCK® Titanium screw-in anchors are available in diameter of 2.8mm, 3.5mm, 5.0mm and 6.5mm. The anchor design incorporates a cancellous thread with a tiny core diameter to maximize pull-out strength in cancellous or osteoporotic bone. The AUXILOCK® Titanium screw-in anchor is designed for ultimate mechanical properties (pull-out strength, tensile strength, etc.) and ease-of-use. The anchor design incorporates a cortical thread with a small core diameter to maximize pull-out strength in a cortical or hard bone. The drill guide and drill bit are provided in the instrument set for the accurate placement of the anchor. It in turn minimizes the anchor slippage or breakage during the surgery.

All of the Auxein's Non-Absorbable Suture Anchors are provided sterile, for single use only. All Non-Absorbable Suture Anchors are preassembled onto an inserter, sized appropriately to accommodate the indicated procedures. Auxein's Non-Absorbable Suture Anchors come in various configurations, including: with attached non-absorbable suture(s). In certain configurations, the Non-Absorbable Suture Anchors are packaged with a guide and awl. All configurations of the Non-Absorbable Suture Anchors are identical to the identified predicate devices.

The device is made from a Titanium alloy, Ti-6Al-4V (ASTM F136) as per grade 5.

Note: The #2 Biobraid Suture is not to be used as a stand-alone. It should be used only with the assembled implant.

These implants are sold in sterile conditions (Ethylene Oxide Sterilization). The system is indicated for use in adult patients only. All implants are for single use only.

AI/ML Overview

The provided text is a 510(k) premarket notification for a medical device called "Auxilock Titanium Screw-In Suture Anchor." It details the device's characteristics, intended use, and a comparison to predicate devices to demonstrate substantial equivalence.

However, this document does not contain information about acceptance criteria and a study that proves the device meets those criteria, specifically concerning an AI/ML-based medical device performance study. The document focuses on demonstrating substantial equivalence for a physical implantable device based on material standards, sterilization, mechanical performance (insertion, pull-out tensile static/fatigue), dimensional verification, shelf-life, and biocompatibility.

Therefore, I cannot fulfill your request to describe acceptance criteria and a study proving device performance for an AI/ML device, as the provided text pertains to a traditional medical implant and lacks any mention of AI/ML components or associated performance studies.

The document instead describes:

  • Device Type: Auxilock Titanium Screw-In Suture Anchor (a physical implant).
  • Performance Tests per document:
    • Material Standards (ASTM F136, ASTM F2848-17, ASTM F899-20)
    • Biocompatibility (ISO 10993-3)
    • Mechanical Performance (Insertion Test, Pull-Out Tensile Static Test, Pull-Out Tensile Fatigue Test)
    • Sterilization (ETO Sterilization, ISO 11135, ISO 17665, ISO 11140-1, ISO 11737-1, ISO 11737-2)
    • Packaging integrity (ISO 11607-1, ISO 11607-2, ASTM F1980, ASTM F88/F88M, ASTM F1929)
    • Shelf-life (5 years based on stability study)
    • Bacterial Endotoxin testing (USP <85>, USP <161>, ANSI/AAMI ST72:2019)

None of these tests align with the detailed questions regarding AI/ML device performance (like MRMC studies, standalone algorithm performance, ground truth establishment for training/test sets, or expert adjudication).

{0}------------------------------------------------

July 29, 2022

Image /page/0/Picture/1 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left and features a stylized eagle. The FDA logo is on the right and features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Auxein Medical Private Limited Rahul Luthra Director Plot No. 168, 169, 170 Phase-IV, Sector 57, Kundli Industrial Area Sonipat, Haryana 131028 India

Re: K213104

Trade/Device Name: Auxilock Titanium Screw-In Suture Anchor Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: MBI Dated: June 22, 2022 Received: June 27, 2022

Dear Rahul Luthra:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

{1}------------------------------------------------

801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about 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.

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

Enclosure

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K213104

Device Name Auxilock Titanium Screw-In Suture Anchor

Indications for Use (Describe)

Auxilock Titanium Screw-In Suture Anchor:

The Auxilock Titanium Screw-In Suture Anchor is intended to be used with #2 Biobraid suture with white, blue, black colors for use for the reattachment of soft tissue to bone for the following indications:

Shoulder:

Bankart lesion repairs, SLAP lesion repairs, Acromiolavicular separation repairs, Rotator cuff tear repairs, Capsular shift or Capsutolabral reconstructions, Biceps tenodesis, and Deltoid Repairs, Anterior Shoulder Instability Repair.

Foot and Ankle:

Hallux valgus reconstruction, Medial or Lateral instability repairs/reconstructions, Achilles tendon repair/reconstructions, Mid-foot reconstruction, Metatarsal ligament/tendon repairs/reconstructions, Bunionectomy.

Elbow, Wrist and Hand:

Scapholunate ligament reconstruction, Unar or radial collateral ligament reconstructions, Lateral epicondylitis repair, Biceps tendon reattachment, Tennis elbow repair.

Knee:

Extra-capsular repairs: Medial collateral ligament repair. Lateral ligament repair. Posterior oblique ligament. Iliotibial band tenodesis, Patellar tendon repair - Vastus medialis obliquous advancement.

Hip:

Capsular repair, Acetabular labral repair.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

Image /page/3/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a stylized "A" inside of it, followed by the word "Auxein" in blue, sans-serif font. A registered trademark symbol is located to the right of the word.

510(k) Summary

General Company Information as required by 807.92 (a)

Submitter's Name:Auxein Medical Private Limited
Address:Auxein Medical Private LimitedPlot No. 168-169-170, Phase-4, Kundli Industrial Area, HSIIDC,Sector-57, Sonepat-131028, Haryana, India
Contact Person Name:Mr. Rahul Luthra
Title:Director
Phone Number:+91 9560557733
Dated:29.07.2022

Person Responsible for Regulatory Compliance

Name:Mr. Mohit Kumar
Title:Sr. Research Engineer
Email Id:m.kumar@auxein.com
Dated:29.07.2022

Proprietary Name:

Auxilock Titanium Screw-In Suture Anchor

Common or Usual Name:

Soft Tissue Fixation Device

Classification Name:

Fastener, fixation, non-degradable, soft tissue

Product Code: MBI

Device Class: II

Review Panel: Orthopedic

Regulation Number:

21 CFR 888.3040

Primary ProductCodeClassification NameCommon NameRegulation Number
MBIFastener, fixation, non-degradable, soft tissueSoft Tissue FixationDevice21 CFR 888.3040

{4}------------------------------------------------

Image /page/4/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a stylized "A" inside of it, followed by the word "Auxein" in blue, sans-serif font. A small "R" in a circle is located to the upper right of the word "Auxein".

Following are the predicate device 510(k) with which we are declaring substantial equivalence: The following is the range of variants covered with their corresponding predicate devices.

Primary Predicate:

510(k) NumberK152566
ApplicantSmith & Nephew
Common NameSuture Anchor
Device NamePEBA Anchor/Suture Combination

Secondary Predicate:

510(k) NumberK053344
ApplicantSmith & Nephew
Common NameSuture Anchor
Device NameTwinFix 2.8mm, 3.5mm and BioRaptor 2.9mm Suture Anchors

Device Description:

The Titanium Screw-In Suture Anchor is a threaded, tapered fastener for use in attachment of soft tissue to bone. The self-tapping AUXILOCK® Titanium screw-in suture anchor is mostly used as a medial row anchor in rotator cuff repair surgery, Bankart or SLAP surgeries. It is recommended for use in small and large-joint repairs without the need for tapping or drilling. AUXILOCK® Titanium screw-in anchors are available in diameter of 2.8mm, 3.5mm, 5.0mm and 6.5mm. The anchor design incorporates a cancellous thread with a tiny core diameter to maximize pull-out strength in cancellous or osteoporotic bone. The AUXILOCK® Titanium screw-in anchor is designed for ultimate mechanical properties (pull-out strength, tensile strength, etc.) and ease-of-use. The anchor design incorporates a cortical thread with a small core diameter to maximize pull-out strength in a cortical or hard bone. The drill guide and drill bit are provided in the instrument set for the accurate placement of the anchor. It in turn minimizes the anchor slippage or breakage during the surgery.

All of the Auxein's Non-Absorbable Suture Anchors are provided sterile, for single use only. All Non-Absorbable Suture Anchors are preassembled onto an inserter, sized appropriately to accommodate the indicated procedures. Auxein's Non-Absorbable Suture Anchors come in various configurations, including: with attached non-absorbable suture(s). In certain configurations, the Non-Absorbable Suture Anchors are packaged with a guide and awl. All configurations of the Non-Absorbable Suture Anchors are identical to the identified predicate devices.

The device is made from a Titanium alloy, Ti-6Al-4V (ASTM F136) as per grade 5.

Note: The #2 Biobraid Suture is not to be used as a stand-alone. It should be used only with the assembled implant.

These implants are sold in sterile conditions (Ethylene Oxide Sterilization). The system is indicated for use in adult patients only. All implants are for single use only.

{5}------------------------------------------------

Image /page/5/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a stylized "A" inside of it, followed by the word "Auxein" in blue, sans-serif font. The logo is simple and modern, and the blue color gives it a sense of trustworthiness and reliability.

Indications for Use:

Auxilock Titanium Screw-In Suture Anchor:

The Auxilock Titanium Screw-In Suture Anchor is intended to be used with #2 Biobraid suture with white, blue, black colors for use for the reattachment of soft tissue to bone for the following indications:

Shoulder

Bankart lesion repairs, SLAP lesion repairs, Acromiolavicular separation repairs, Rotator cuff tear repairs, Capsular shift or Capsutolabral reconstructions, Biceps tenodesis, and Deltoid Repairs, Anterior Shoulder Instability Repair.

Foot and Ankle

Hallux valgus reconstruction, Medial or Lateral instability repairs/reconstructions, Achilles tendon repair/reconstructions, Mid-foot reconstruction, Metatarsal ligament/tendon repairs/reconstructions, Bunionectomy.

Elbow, Wrist and Hand

Scapholunate ligament reconstruction, Ulnar or radial collateral ligament reconstructions, Lateral epicondylitis repair, Biceps tendon reattachment, Tennis elbow repair.

Knee

Extra-capsular repairs: Medial collateral ligament repair, Lateral ligament repair, Posterior oblique ligament, Iliotibial band tenodesis, Patellar tendon repair - Vastus medialis obliquous advancement.

Hip

Capsular repair, Acetabular labral repair.

Summary of Technological Characteristics as compared to the predicate devices

A comparison between the Auxilock Titanium Screw-In Suture Anchor and predicate devices has been performed which has resulted in demonstration of similarities in dimensional and performance criteria.

Following is the summary of parameters in which the comparison has been verified:

S.No.CharacteristicsSubject Device (Auxein)Predicate DevicesRemarks
1.Product CodeMBIK152566, PEBAAnchor/Suture Combination,(Primary Predicate)K053344, TwinFix 2.8mm,3.5mm Suture Anchors(Secondary Predicate)Identical
aspredicatedevice.
2.RegulationNumber21 CFR 888.304021 CFR 888.3040Identicalaspredicatedevice.
3.RegulatoryClassClass IIClass IIIdenticalaspredicatedevice.
4.Indicationsfor useAuxilock TitaniumScrew-In Suture AnchorThe Auxilock Titanium Screw-In Suture Anchor isintended to be used with #2 Biobraid suture with white,blue, black colors for use for the reattachment of softtissue to bone for the following indications:Shoulder:Bankart lesion repairs, SLAP lesion repairs,Acromiolavicular separation repairs, Rotatorcuff tear repairs, Capsular shift or Capsutolabralreconstructions, Biceps tenodesis, and DeltoidRepairs, Anterior Shoulder Instability Repair.Foot and Ankle:Hallux valgus reconstruction, Medial orLateral instability repairs/reconstructions,Achilles tendon repair/reconstructions,Mid-foot reconstruction, Metatarsal ligament/tendon repairs/reconstructionsThe PeBA SeriesAnchor/Suture Combination(Primary Predicate) is intendedfor the fixation of surgicalsuture material for thefollowing indications:Shoulder:Bankart lesion repairs, SLAPlesion repairs, Acromio-clavicular separation repairs,Rotator cuff tear repairs,Capsular shift or capsulolabralreconstructions, Bicepstenodesis, Deltoid repairs.Foot and Ankle:Hallux Valgus repairs, Medialor lateral instability repairs,Achilles tendonrepairs/reconstructions, Midfootreconstructions, Metatarsalligament/tendonrepairs/reconstructionsElbow, Wrist, and Hand:Scapholunate ligamentreconstructions, Ulnar or radialcollateral ligamentreconstructions, Tennis elbowrepair, Biceps tendonreattachment.Identicalaspredicatedevices.

{6}------------------------------------------------

Image /page/6/Picture/1 description: The image features the logo for Auxein. The logo consists of a stylized letter "A" inside of a circle, followed by the word "Auxein" in a sans-serif font. The logo and text are both in a light blue color.

{7}------------------------------------------------

Image /page/7/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a stylized "A" inside of it, followed by the word "Auxein" in blue, sans-serif font. A small "R" in a circle is located to the right of the word "Auxein" indicating that the logo is a registered trademark.

Bunionectomy.Knee:Extra-capsular repairs, medialcollateral ligament, lateralcollateral ligament, posterioroblique ligament, Iliotibial bandtenodesis, Patellar realignmentand tendon, repairs, includingvastus medialis, obliquousadvancement.
Elbow, Wrist and Hand:Scapholunate ligamentreconstruction, Ulnar orradial collateral ligamentreconstructions, Lateralepicondylitis repair, Bicepstendon reattachment,Tennis elbow repair.The K053344, TwinFix 2.8mm,3.5mm Suture Anchors(Secondary Predicate) isintended for use for thereattachment of soft tissue tobone for the followingindications:
Knee:Extra-capsular repairs:Medial collateral ligamentrepair, Lateral collateralligament repair, Posterioroblique ligament, Iliotibialband tenodesis, Patellartendon repair - Vastusmedialis obliquousadvancement.ShoulderBankart lesion repairs, SLAPlesion repairs,Acromiolavicular separationrepairs, Rotator cuff tearrepairs, Capsular shift orCapsutolabral reconstructions,Biceps tenodesis, and DeltoidRepairs, Anterior ShoulderInstability Repair.
Hip:Capsular repair, Acetabularlabral repair.Foot and AnkleHallux valgus reconstruction,Medial or Lateral instabilityrepairs/reconstructions,Achilles tendonrepair/reconstructions, Mid-footreconstruction, Metatarsalligament/tendonrepairs/reconstructions,Bunionectomy.
Elbow, Wrist and HandScapholunate ligamentreconstruction, Ulnar or radialcollateral ligament

{8}------------------------------------------------

Image /page/8/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a blue triangle inside of it, followed by the word "Auxein" in blue font. There is a registered trademark symbol to the right of the word.

reconstructions, Lateralepicondylitis repair, Bicepstendon reattachment, Tenniselbow repair.
KneeExtra-capsular repairs: Medialcollateral ligament repair,Lateral collateral ligamentrepair, Posterior obliqueligament, Iliotibial bandtenodesis, Patellar tendon repair- Vastus medialis obliquousadvancement.
HipCapsular repair, Acetabularlabral repair.
5.MaterialTitanium Alloy as perASTM F136 andUHMWPE Suture as perASTM F2848-17.Titanium Alloy as per ASTMF136 and and UHMWPESuture as per ASTM F2848-17.Conformsto Identicalstandard aspredicatedevice.
6.PerformanceStandardsMechanical TestingProtocol AMPL-MT-PRT-002, Rev. 01. was used inthe scoped Device.Mechanical Testing ProtocolAMPL-MT-PRT-002, Rev. 01.was used in the predicateDevice.Identicalaspredicatedevice.
7.SterilizationEthylene OxideSterilization Method wasused in the subject device.Ethylene Oxide SterilizationMethod was used in thepredicate devices.Identical inpredicatedevice.
8.DimensionalVerificationSame dimension as of Predicate device.Identicalaspredicatedevice.
9.Shelf-life5 Years5 YearsIdenticalaspredicatedevice.
10.SingleUse/ReuseSingle UseSingle UseIdenticalaspredicatedevice.
11.Operating PrincipleSecure tendon and ligament reconstructions with increased boney ingrowth at the anchor site with minimal invasive technique.Secure tendon and ligament reconstructions with increased boney ingrowth at the anchor site with minimal invasive technique.Identical as predicate device.

{9}------------------------------------------------

Image /page/9/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a stylized "A" inside of it, followed by the word "Auxein" in blue, with a registered trademark symbol next to it. The logo is simple and modern, and the blue color gives it a sense of trust and reliability.

Discussion on the non-clinical testing performed

Following are the applicable product standards considered for non-clinical standards:

  • Material Standards. ●
  • . Biocompatibility Standards
  • Performance Standards.
  • Sterilization, shelf-life and packaging for sterile product.
  • . Bacterial Endotoxin

Non-Clinical Test Summary:

Bench tests were conducted to verify that the subject device met all design specifications. The test results demonstrated that the subject device complies with the following standards:

Material Standards:

The material standards are the essential part to be complied with first, as it is the basis of manufacturing metallic surgical implants.

We have complied with the following material standards:

  • ASTM F136/ISO 5832-3: Standard specification for wrought Titanium-6 Vanadium . ELI (Extra low interstitial) Alloy for surgical implant applications.
  • · ASTM F2848-17: Standard Specification for Medical-Grade Ultra-High Molecular Weight Polyethylene Yarns.
  • ASTM F899-20: Standard Specification for Wrought Stainless Steels for surgical instruments.

Note: We have used Grade 304 of Stainless steel (SS 304) Material for instruments as per ASTM F899-20, UHMWPE for Suture as per ASTM F2848-17 and Titanium Alloy (Ti- 6Al-4V) Grade 5 for Titanium Implants.

Summary of Biocompatibility

The device in its final finished form has been evaluated for biocompatibility according to ISO 10993-3.

Conclusion of Mechanical performance

The following are the mechanical tests that have been performed on the Subject device (i.e. Auxilock Titanium Screw-In Suture Anchor) and Predicate device (i.e. Smith & Nephew's Twinfix Suture Anchor):

    1. Insertion Test
    1. Pull-Out Tensile Static Test and Pull-Out Tensile Fatigue Test.

{10}------------------------------------------------

Image /page/10/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a white "A" inside of it, followed by the word "Auxein" in blue. There is a registered trademark symbol next to the "n" in "Auxein".

Sterilization, shelf-life and packaging for sterile product

Sterilization: ETO Sterilization

The ETO sterilization has been performed to sterilize this medical device. EO penetrates the packaging, making contact with all accessible surfaces of the product to deliver the required sterility assurance level (SAL).

Trace levels of EO and ethylene chlorohydrin (ECH) may remain on products after an EO sterilization process. To detect these traces, EO residual test was done. ISO 10993-7 outlines the specific limits of EO and ECH that must not be exceeded in order to ensure product and patient safety.

  • ISO 11135: 2014, Sterilization of health-care products Ethylene oxide Requirements for the ● development, validation and routine control of a sterilization process for medical devices.
  • ISO 17665-1:2006, Sterilization of health care products Moist heat Part 1: Requirements for ● the development, validation and routine control of a sterilization process for medical devices.
  • ISO/TS 17665-2:2009, Sterilization of health care products - Moist heat - Part 2: Guidance on the application of ISO 17665-1.
  • . ISO/TS 17665-3:2013 (en), Sterilization of health care products - Moist heat - Part 3: Guidance on the designation of a medical device to a product family and processing category for steam sterilization.
  • . ISO 11140-1:2014, Sterilization of health care products — Chemical indicators — Part 1: General requirements.
  • . ISO 11737-1:2018 Sterilization of medical devices - Microbiological methods- Part 1: Estimation of population of microorganisms on products.
  • ISO 11737-2:2009 Sterilization of medical devices - Microbiological methods- Part 2: Tests of sterility performed in the validation of a sterilization process.

Packaging of the Product: Tyvek Packaging

The integrity of the final package is maintained at least for the claimed shelf-life of the medical device.

The tyvek pouch is used for the packaging of Auxilock Titanium Screw-In Suture Anchor. The double sterile barrier is used for the packaging.

We have followed the below standards for packaging of the device:

  • · ISO 11607-1:2006/AMD1:2014 Packaging for terminally sterilized medical devices part 1: requirements for materials, sterile barrier systems and packaging system.
  • . ISO 11607-2:2006/AMD1:2014 Packaging for terminally sterilized medical devices - Part 2: Validation requirements for forming, sealing and assembly processes.

Shelf-life: 5 years

The stability study has been done to determine the shelf life.

We have followed the below standards for performing shelf-life of the device:

  • ASTM F1980:2016 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices.
  • ASTM F88/F88M:2015 Standard test method for seal strength of flexible barrier materials.
  • ASTM F1929:2015 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging ●

{11}------------------------------------------------

Image /page/11/Picture/1 description: The image shows the logo for Auxein. The logo consists of a blue circle with a white triangle inside, followed by the word "Auxein" in blue, stylized font. There is a small "R" in a circle to the right of the word "Auxein".

by Dye Penetration.

Safety in MRI Not Evaluated

The Auxilock Titanium Screw-In Suture Anchor has not been evaluated for safety in the MR environment. It has not been tested for heating or unwanted movement in the MR environment. The safety of Auxilock Titanium Screw-In Suture Anchor in the MR environment is unknown. Performing an MR exam on a person who has this medical device may result in injury or device malfunction.

Bacterial Endotoxin

  • USP <85> Bacterial Endotoxin Test. .
  • USP <161> Medical Devices-Bacterial Endotoxin and Pyrogen Tests.

Bacterial Endotoxin Test (BET): We perform Bacterial Endotoxin Test of every sterile batch products by using acceptance criteria as endotoxin testing limit must be <20EU/Device (as the products are general medical devices for implantation). The testing is done by using Limulus amebocyte lysate (LAL) test. The testing procedure is performed as per the standards USP 85 and ANSI/AAMI ST72:2019.

Conclusion:

There are no significant differences between the subject device and the predicate devices that would adversely affect the use of the product. It is substantially equivalent to these devices in design, function, materials, and operational principles as internal fixation components. From the data available we can justify that the Auxilock Titanium Screw-In Suture Anchor is as safe, and as effective and performs the same indications for use as that of already marketed predicate devices identified in 510(k) summary.

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.