K Number
K222005
Device Name
S.I.N. Instrument Kits
Date Cleared
2022-09-29

(84 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices. The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle: Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time. S.I.N. Instrument Kits are intended for sterilization of non-porous loads. S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
Device Description
The subject device includes a total of three (3) instrument trays. The subject device trays are reusable rigid containers, comprising a base (bottom), one or more removable inner trays, and a lid (cover). The subject device trays are to be used to organize and protect the instruments that are sterilized by the healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior components during sterilization. The trays are perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polysulfone (PSU), and holders of various geometries to position instruments in the kits are manufactured from silicone. The subject device includes two (2) sizes (lid, base, and enclosed volume), and a total of three (3) tray configurations.
More Information

No
The device description and intended use clearly define the device as reusable rigid containers for sterilizing medical instruments. There is no mention of any software, algorithms, or data processing capabilities that would indicate the use of AI or ML. The "Mentions AI, DNN, or ML" and "Mentions image processing" sections are explicitly marked as "Not Found".

No
The device is a reusable rigid container intended for the sterilization of other medical devices, not for diagnosing, treating, or preventing disease in a patient.

No

The device is an instrument kit designed to enclose and facilitate the sterilization of other medical devices, not to diagnose medical conditions.

No

The device description explicitly states it includes physical components such as instrument trays, bases, lids, and holders made from polysulfone and silicone. It is a hardware device used for sterilization.

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

Here's why:

  • Intended Use: The intended use clearly states that the S.I.N. Instrument Kits are used to enclose other medical devices for sterilization by a healthcare provider. They facilitate the sterilization process and maintain sterility when used with a cleared wrap. This is a function related to the preparation and handling of medical instruments, not the diagnosis of diseases or conditions based on in vitro examination of specimens.
  • Device Description: The description details reusable rigid containers designed to organize and protect instruments during sterilization. The materials and design are focused on withstanding sterilization cycles and allowing sterilant penetration. This aligns with a device used in a clinical setting for instrument management, not for laboratory testing of biological samples.
  • Lack of IVD Characteristics: There is no mention of the device being used with biological specimens (blood, urine, tissue, etc.), performing tests on these specimens, or providing diagnostic information. The focus is entirely on the physical process of sterilization and instrument handling.

Therefore, the S.I.N. Instrument Kits fall under the category of devices used in the sterilization and handling of medical instruments, not as an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Epikut Long Surgical Kit and the associated instruments is 440 grams.

The weight of the empty Epikut Long Surgical Kit is 310 grams.

Product codes (comma separated list FDA assigned to the subject device)

KCT

Device Description

The subject device includes a total of three (3) instrument trays. The subject device trays are reusable rigid containers, comprising a base (bottom), one or more removable inner trays, and a lid (cover). The subject device trays are to be used to organize and protect the instruments that are sterilized by the healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior components during sterilization. The trays are perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polysulfone (PSU), and holders of various geometries to position instruments in the kits are manufactured from silicone. The subject device includes two (2) sizes (lid, base, and enclosed volume), and a total of three (3) tray configurations.

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

health care provider

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)

Nonclinical Testing:
Test Methodology: Manual Cleaning Validation FDA Guidance Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling (issued March 2015) Referenced from K201688
Purpose: The purpose of this test is to validate that the cleaning instructions provided in the Instructions for Use appropriately clean the tray, and to ensure the sterilization cycle will be effective.
Acceptance Criteria: Protein assay Acceptance criterion: No color change = absence of protein residue; Sensitivity = 1 µg protein residue; Total organic carbon assay Acceptance criterion: results Referenced from K201688
Purpose: The purpose of this test is to validate that the cleaning instructions provided in the Instructions for Use appropriately clean the tray, and to ensure the BET level meets FDA expectation (

§ 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

September 29, 2022

Image /page/0/Picture/1 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is 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.

S.I.N. - Sistema De Implante Nacional S.A. % Kevin Thomas Vice President & Director of Regulatory Affairs PaxMed International, LLC 12264 EL Camino Real. Suite 400 San Diego, California 92130

Re: K222005

Trade/Device Name: S.I.N. Instrument Kits Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: KCT Dated: July 6, 2022 Received: July 7, 2022

Dear Kevin Thomas:

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

Colin O'Neill, M.B.E. Assistant Director DHT6B: Division of Spinal 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) K222005

Device Name

S.I.N. Instrument Kits

Indications for Use (Describe)

Indications for Use for Epikut Long Surgical Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Epikut Long Surgical Kit and the associated instruments is 440 grams.

The weight of the empty Epikut Long Surgical Kit is 310 grams.

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

Indications for Use

510(k) Number (if known) K222005

Device Name

S.I.N. Instrument Kits

Indications for Use (Describe)

Indications for Use for Epikut Surgical Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Epikut Surgical Kit and the associated instruments is 612 grams.

The weight of the empty Epikut Surgical Kit is 554 grams.

Type of Use (Select one or both, as applicable)
☒ Residential Use (Part 21 CFR 601 Subpart D) □ Over-The-Counter Use (21 CFR 201.66)☒ Residential Use (Part 21 CFR 601 Subpart D)□ Over-The-Counter Use (21 CFR 201.66)
☒ Residential Use (Part 21 CFR 601 Subpart D)□ Over-The-Counter Use (21 CFR 201.66)

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."

4

Indications for Use

510(k) Number (if known) K222005

Device Name

S.I.N. Instrument Kits

Indications for Use (Describe)

Indications for Use for Orthodontic Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Orthodontic Kit and the associated instruments is 430 grams.

The weight of the empty Orthodontic Kit is 310 grams.

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)

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."

5

510(k) Summary K222005 S.I.N. - Sistema de Implante Nacional S.A. S.I.N. Instrument Kits

August 19, 2022

ADMINISTRATIVE INFORMATION

| Manufacturer Name | S.I.N. - Sistema de Implante Nacional S.A.
Avenida Vereador Abel Ferreira, 1100
São Paulo, São Paulo
03340-000 Brazil
Telephone +55-11-21693000 ext 3236 |
|---------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Official Contact | Denise Domiciano, Quality and Regulatory Manager |
| Representative/Consultant | Kevin A. Thomas, PhD
Floyd G. Larson, MS, MBA
PaxMed International, LLC
12264 El Camino Real, Suite 400
San Diego, CA 92130
Telephone +1 858-792-1235
Fax +1 858-792-1236
Email kthomas@paxmed.com
flarson@paxmed.com |

DEVICE NAME AND CLASSIFICATION

Trade/Proprietary NameS.I.N. Instrument Kits
Common NameInstrument sterilization trays
Regulation Number21 CFR 880.6850
Regulation NameSterilization Wrap Containers, Trays, Cassettes & Other Accessories
Regulatory ClassClass II
Product CodeKCT
Classification PanelGeneral Hospital
Reviewing OfficeOffice of Surgical and Infection Control Devices (OHT4)
Reviewing DivisionDivision of Infection Control and Plastic Surgery Devices (DHT4B)

PREDICATE DEVICE INFORMATION

Primary predicate device is: K201688, S.I.N. Instrument Kits, S.I.N. - Sistema de Implante Nacional S.A. Reference device: K212404, S.I.N. Instrument Kits, S.I.N. – Sistema de Implante Nacional S.A.

6

SUBJECT DEVICE INDICATIONS FOR USE STATEMENTS

Indications for Use for Epikut Long Surgical Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Epikut Long Surgical Kit and the associated instruments is 440 grams.

The weight of the empty Epikut Long Surgical Kit is 310 grams.

Indications for Use for Orthodontic Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Orthodontic Kit and the associated instruments is 430 grams.

The weight of the empty Orthodontic Kit is 310 grams.

Indications for Use for Epikut Surgical Kit

S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow sterilization of the enclosed medical devices. S.I.N. Instrument Kits require the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.

The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:

Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.

S.I.N. Instrument Kits are intended for sterilization of non-porous loads.

S.I.N. Instrument Kits are recommended not to be stacked during sterilization.

The combined weight of the Epikut Surgical Kit and the associated instruments is 612 grams. The empty Epikut Surgical Kit is 554 grams.

SUBJECT DEVICE DESCRIPTION

The subject device includes a total of three (3) instrument trays. The subject device trays are reusable rigid containers, comprising a base (bottom), one or more removable inner trays, and a lid (cover). The subject device trays are to be used to organize and protect the instruments that are sterilized by the healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior components during sterilization. The trays are perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polysulfone (PSU), and holders of various geometries to position instruments in the kits are manufactured from silicone. The subject device includes two (2) sizes (lid, base, and enclosed volume), and a total of three (3) tray configurations.

7

TECHNOLOGICAL CHARACTERISTICS COMPARISON TABLE

The comparison of the technological characteristics and Indications for Use Statements for the subject devices and the predicate device are provided at the end of this summary on pages 5-8.

The subject device is provided in 2 sizes and 3 configurations; the primary predicate device K201688 is provided in 5 sizes and 14 configurations. The subject device and the predicate device have similar overall dimensions, enclose similar volumes, and have similar vent to volume ratios. Differences in the dimensions and vent to volume ratios between the subject device and the predicate device are mitigated by the sterilization validation performed.

SUMMARY OF NONCLINICAL TESTING

Provided below are the nonclinical test methodologies performed to demonstrate the subject devices met the acceptance criteria of the standard.

Test MethodologyPurposeAcceptance CriteriaResults
Manual Cleaning Validation FDA
Guidance
Reprocessing Medical Devices in
Health Care Settings: Validation
Methods and Labeling
(issued March 2015)

Referenced from K201688 | The purpose of this test is to
validate that the cleaning
instructions provided in the
Instructions for Use appropriately
clean the tray, and to ensure the
sterilization cycle will be effective. | Protein assay Acceptance criterion:
No color change = absence of protein
residue
Sensitivity = 1 µg protein residue

Total organic carbon assay Acceptance
criterion:
results

Referenced from K201688 | The purpose of this test is to
validate that the cleaning
instructions provided in the
Instructions for Use appropriately
clean the tray, and to ensure the
BET level meets FDA expectation
(≤ 20 EU/device) | Acceptance criterion:
Endotoxin results ≤ 20 EU/device | Pass |
| Sterilization Validation
including sterilant penetration and
dry time validation
ANSI/AAMI/ISO 17665-1
ANSI/AAMI/ISO 17665-2

Referenced from K201688 | The purpose of this test is to
validate that the sterilization
instructions listed in the
Instructions for Use appropriately
sterilize the tray and contents. | Acceptance criterion:
3 consecutive half-cycles performed for
each of 3 sizes of trays demonstrate
complete inactivation of all biologic
indicators;
A minimum SAL of 10-6 is achieved if the
Instructions for Use are followed | Pass |
| Dry time
Referenced from K201688 | The purpose of this test is to
validate that the sterilization
instructions listed in the
Instructions for Use appropriately
dry the wrapped tray for storage. | Acceptance criterion:
Using pre-cycle and post-cycle weights, the
weight gain after drying will be ≤ 3% | Pass |

Summary of Nonclinical Testing Table

8

Test MethodologyPurposeAcceptance CriteriaResults
Life Cycle / Simulated Use Life
Validation FDA Guidance
Reprocessing Medical Devices in
Health Care Settings: Validation
Methods and Labeling
(issued March 2015)
Referenced from K201688The purpose of this test is to
validate the service life of the trays
as stated in the Instructions for Use.Acceptance criteria:
Visual inspection, component dimensional
fit verification, functional closure/latch
verification for 250 use cyclesPass
Biocompatibility of Subject
Device
Cytotoxicity testing
ANSI/AAMI/ISO 10993-5
ANSI/AAMI/ISO 10993-12
Referenced from K201688
and K212404The purpose of this test is to
evaluate the cytotoxicity potential
of the test article using an in vitro
cell culture assay.Acceptance criterion:
Non-cytotoxic if ≤ 50% of L-929 cells
exposed to extract of device show rounding
and lysisPass

In summary, the nonclinical testing provided for these devices met the acceptance criteria for each standard and test methodology used to evaluate the devices as shown in the table above.

No clinical data were included in this submission.

CONCLUSION

The conclusions drawn from the nonclinical tests demonstrate that the subject device in this 510(k) submission, S.I.N. Instrument Kits, is as safe, as effective, and perform as well as or better than the legally marketed predicate devices cleared under K201688 and K212404.

9

Indications for Use Statements

Indications for Use Statements
Subject Device – K222005
S.I.N. Instrument Kits
S.I.N. - Sistema de Implante Nacional S.A.
Epikut Long Surgical KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow ste
use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Epikut Long Surgical Kit and the associated instruments is 440 grams.
The weight of the empty Epikut Long Surgical Kit is 310 grams.
Orthodontic KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow ste
use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Orthodontic Kit and the associated instruments is 430 grams.
The weight of the empty Orthodontic Kit is 310 grams.
Epikut Surgical KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow ste
use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Epikut Surgical Kit and the associated instruments is 612 grams.
The weight of the empty Epikut Surgical Kit is 554 grams.
Primary Predicate Device – K201688
S.I.N. Instrument Kits
S.I.N. - Sistema de Implante Nacional S.A.
Safe Drill Unitite KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Safe Drill Unitite Kit and the associated instruments is 304 grams.
The weight of the empty Safe Drill Unitite Kit is 150 grams.
Safe Drill SW KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Safe Drill SW Kit and the associated instruments is 278 grams.
The weight of the empty Safe Drill SW Kit is 138 grams.
Prosthetic KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Prosthetic Kit and the associated instruments is 332 grams.
The weight of the empty Prosthetic Kit is 160 grams.
Rotatory Expanding KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Rotatory Expanding Kit and the associated instruments is 276 grams.
The weight of the empty Rotatory Expanding Kit is 133 grams.
Bone Expander KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Bone Expander Kit and the associated instruments is 974 grams.
The weight of the empty Bone Expander Kit is 367 grams.
Sinus Lift KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Sinus Lift Kit and the associated instruments is 808 grams.
The weight of the empty Sinus Lift Kit is 370 grams.
Osteotome KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Osteotome Kit and the associated instruments is 957 grams.
The weight of the empty Osteotome Kit is 350 grams.
Unitite Surgical KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Unitite Surgical Kit and the associated instruments is 1126 grams.
The weight of the empty Unitite Surgical Kit is 515 grams.
Strong SW Surgical KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Strong SW Surgical Kit and the associated instruments is 698 grams.
The weight of the empty Strong SW Surgical Kit is 130 grams.
Tryon Surgical Kit KCHE 03S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow
the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices.
The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle:
Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time.
S.I.N. Instrument Kits are intended for sterilization of non-porous loads.
S.I.N. Instrument Kits are recommended not to be stacked during sterilization.
The combined weight of the Tryon Surgical Kit KCHE 03 and the associated instruments is 1127 grams.
The weight of the empty Tryon Surgical Kit KCHE 03 is 520 grams.
Tryon Surgical Kit KCHE 04S.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices. The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle: Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time. S.I.N. Instrument Kits are intended for sterilization of non-porous loads. S.I.N. Instrument Kits are recommended not to be stacked during sterilization. The combined weight of the Tryon Surgical Kit KCHE 04 and the associated instruments is 1138 grams. The weight of the empty Tryon Surgical Kit KCHE 04 is 523 grams.
Unitite Surgical Guided KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices. The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle: Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time. S.I.N. Instrument Kits are intended for sterilization of non-porous loads. S.I.N. Instrument Kits are recommended not to be stacked during sterilization. The combined weight of the Unitite Surgical Guided Kit and the associated instruments is 1434 grams. The weight of the empty Unitite Surgical Guided Kit is 650 grams.
Strong SW Surgical Guided KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices. The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle: Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time. S.I.N. Instrument Kits are intended for sterilization of non-porous loads. S.I.N. Instrument Kits are recommended not to be stacked during sterilization. The combined weight of the Strong SW Surgical Guided Kit and the associated instruments is 1399 grams. The weight of the empty Strong SW Surgical Guided Kit is 647 grams.
Zygomatic Surgical KitS.I.N. Instrument Kits are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. S.I.N. Instrument Kits are intended to allow the use of a wrap that is FDA cleared to maintain the sterility of the enclosed devices. The kits are to be enclosed in a sterilization wrap that is FDA cleared for the indicated cycles, and moist heat (steam) sterilized using the following cycle: Gravity displacement - Exposure at 121 °C for 30 minutes and 30 minutes dry time. S.I.N. Instrument Kits are intended for sterilization of non-porous loads. S.I.N. Instrument Kits are recommended not to be stacked during sterilization. The combined weight of the Zygomatic Surgical Kit and the associated instruments is 1150 grams. The weight of the empty Zygomatic Surgical Kit is 464 grams.

lization of the enclosed medical devices. S.I.N. Instrument Kits require the

lization of the enclosed medical devices. S.I.N. Instrument Kits require the

lization of the enclosed medical devices. S.I.N. Instrument Kits require the

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

10

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

terilization of the enclosed medical devices. S.I.N. Instrument Kits require

11

510(k) Summary Page 7 of 8

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

erilization of the enclosed medical devices. S.I.N. Instrument Kits require

12

Technological Characteristics

Subject DevicePrimary Predicate DeviceComparison
AttributeS.I.N. Instrument Kits
S.I.N. - Sistema de Implante Nacional S.A.K201688
S.I.N. Instrument Kits
S.I.N. - Sistema de Implante Nacional S.A.
Product CodeKCTKCTSame
DesignRigid polymer base, lid, and removable inner trayRigid polymer base, lid, and removable inner traySame
MaterialsPolysulfone (base, tray, lid); Medical grade silicone (grommets)Polysulfone (base, tray, lid); Medical grade silicone (grommets)Same
Materials Compatible with Sterilization
MethodYesYesSame
PerforatedYes; allows moist heat (steam) penetration to achieve sterilizationYes; allows moist heat (steam) penetration to achieve sterilizationSame
ReusableYesYesSame
Number of Sizes/Configurations2 sizes, 3 configurations5 sizes, 14 configurationsSimilar
Dimensions
and
Vent to Volume RatioTrayLength x Width x Height,
mmVent to Volume RatioTrayLength x Width x Height, mmVent to Volume RatioSimilar
COSEL 01, Epikut Long Surgical Tray215 x 100 x 35.5$0.0100 cm^2 / cm^3$COUSD 02, Safe Drill Unitite Tray113.7 x 75.7 x 29.5$0.0089 cm^2 / cm^3$
COOR, Orthodontic Tray215 x 100 x 35.5$0.0100 cm^2 / cm^3$COWSD 02, Safe Drill SW Tray113.7 x 75.7 x 29.5$0.0089 cm^2 / cm^3$
COSE 02, Epikut Surgical Tray165 x 190 x 55$0.0086 cm^2 / cm^3$COTMEC, Prosthetic Tray113.7 x 75.7 x 29.5$0.0089 cm^2 / cm^3$
COER, Rotatory Expanding Tray113.7 x 75.7 x 29.5$0.0089 cm^2 / cm^3$
COEXP, Bone Expander Tray113.7 x 75.7 x 29.5$0.0100 cm^2 / cm^3$
COLEV, Sinus Lift Tray215 x 100 x 33.5$0.0100 cm^2 / cm^3$
COOST, Osteotome Tray113.7 x 75.7 x 29.5$0.0100 cm^2 / cm^3$
COSU 03, Unitite Surgical Tray165 x 190 x 55$0.0086 cm^2 / cm^3$
COSW 02, Strong SW Surgical Tray165 x 190 x 55$0.0086 cm^2 / cm^3$
COHE 03, Tryon Surgical Tray KCHE 03165 x 190 x 55$0.0086 cm^2 / cm^3$
COHE 04, Tryon Surgical Tray KCHE 04165 x 190 x 55$0.0086 cm^2 / cm^3$
COSUG 02, Unitite Surgical Guided Tray142 x 206 x 72$0.0083 cm^2 / cm^3$
COSWG 02, Strong SW Surgical Guided Tray165 x 190 x 55$0.0083 cm^2 / cm^3$
COKZ, Zygomatic Surgical Tray113.7 x 75.7 x 29.5$0.0131 cm^2 / cm^3$
ReusableReusable up to 250 cyclesReusable up to 250 cyclesSame
Use Life TestingDisassembled, cleaned, assembled, sterilized
Visual inspection
Component dimensional fit verification
Functional closure (lid-base latch) verificationDisassembled, cleaned, assembled, sterilized
Visual inspection
Component dimensional fit verification
Functional closure (lid-base latch) verificationSame
Sterilization MethodMoist heat (steam)Moist heat (steam)Same
SterilantMoist heat (steam)Moist heat (steam)Same
CyclesGravity displacementGravity displacementSame
Sterile BarrierSterilization wrap, FDA cleared for indicated method and cycleSterilization wrap, FDA cleared for indicated method and cycleSame