K Number
K222971
Device Name
ULTRABUTTON QUAD Adjustable Fixation Device; ULTRABUTTON BB Adjustable Fixation Device; ULTRABUTTON TIB SMALL Adjustable Fixation Device; ULTRABUTTON TIB MEDIUM Adjustable Fixation Device; ULTRABUTTON TIB LARGE Adjustable Fixation Device
Manufacturer
Date Cleared
2023-02-17

(143 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are indicated for soft tissue to bone or bone-tendon to bone fixation for: ACL/PCL Repair/Reconstruction and soft tissue to bone fixation for Extracapsular Repair: MCL, LCL.
Device Description
The Smith & Nephew ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices consist of an ultra-high molecular weight polyethylene graft suspension loop and a titanium cortical button. The devices facilitate knee ligament repair/reconstruction through placement and retention of soft tissue or bone-tendon within bone. The ULTRABUTTON QUAD Adjustable Fixation Device and the ULTRABUTTON BB Adjustable Fixation Device is available in one size. The UTLRABUTTON TIB Adjustable Fixation Device is available in a small, medium, or large size.
More Information

Not Found

No
The summary describes a mechanical fixation device and does not mention any software, algorithms, or data processing that would indicate the use of AI/ML.

No.
A therapeutic device is one that treats or prevents a disease or condition. This device is an implant for mechanical fixation of soft tissue to bone, which is a structural repair rather than a therapeutic treatment.

No

Explanation: The device description and intended use clearly state that it is a fixation device used for repair/reconstruction of soft tissue or bone-tendon within bone, specifically for knee ligaments like ACL/PCL. There is no mention of diagnostic functions.

No

The device description explicitly states it consists of physical components: an ultra-high molecular weight polyethylene graft suspension loop and a titanium cortical button.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "soft tissue to bone or bone-tendon to bone fixation for: ACL/PCL Repair/Reconstruction and soft tissue to bone fixation for Extracapsular Repair: MCL, LCL." This describes a surgical procedure to repair or reconstruct ligaments in the knee.
  • Device Description: The device description details a physical implantable device consisting of a loop and a button used to secure tissue within bone.
  • Lack of Diagnostic Function: There is no mention of the device being used to test samples (like blood, urine, or tissue) to diagnose a condition, monitor a disease, or screen for a health issue. IVDs are used in vitro (outside the body) to provide information about a patient's health status. This device is used in vivo (inside the body) as a surgical implant.

The information provided describes a surgical implant used for orthopedic repair, not a diagnostic test.

N/A

Intended Use / Indications for Use

The ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are indicated for soft tissue to bone or bonetendon to bone fixation for: ACL/PCL Repair/Reconstruction and soft tissue to bone fixation for Extracapsular Repair: MCL, LCL.

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

MBI

Device Description

The Smith & Nephew ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices consist of an ultra-high molecular weight polyethylene graft suspension loop and a titanium cortical button. The devices facilitate knee ligament repair/reconstruction through placement and retention of soft tissue or bone-tendon within bone.

The ULTRABUTTON QUAD Adjustable Fixation Device and the ULTRABUTTON BB Adjustable Fixation Device is available in one size. The UTLRABUTTON TIB Adjustable Fixation Device is available in a small, medium, or large size.

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

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)

  • Device cyclic displacement, device repair strength, and construct stiffness met the ● acceptance criteria established by the predicate device (K153186).
  • Biocompatibility testing per ISO 10993-1:2018 demonstrated passing results. ●
  • Bacterial endotoxin testing was completed and met acceptable limits per ANSI/AAMI ST72:2019.
  • The devices have a three (3) year shelf-life. Storage and stability is based on completed ● packaging material storage stability testing, device storage stability testing, and distribution testing. Packaging testing per ISO 11607-1:2019 demonstrated passing results.
  • Sterile adoption was completed per ISO 11135:2014+A1:2018. ●

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K153186

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

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February 17, 2023

Image /page/0/Picture/1 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 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.

Smith & Nephew Inc Dongeun Lopresti Senior Regulatory Affairs Specialist 150 Minuteman Road Andover, Massachusetts 01810

Re: K222971

Trade/Device Name: ULTRABUTTON OUAD Adjustable Fixation Device: ULTRABUTTON BB Adjustable Fixation Device; ULTRABUTTON TIB Adjustable Fixation Device Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: MBI Dated: September 26, 2022 Received: September 27, 2022

Dear Ms. Dongeun Lopresti:

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,

Sara S. Thompson -S

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

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Indications for Use

510(k) Number (if known) K222971

Device Name

ULTRABUTTON QUAD Adjustable Fixation Device; ULTRABUTTON BB Adjustable Fixation Device; ULTRABUTTON TIB Adjustable Fixation Device

Indications for Use (Describe)

The ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are indicated for soft tissue to bone or bonetendon to bone fixation for: ACL/PCL Repair/Reconstruction and soft tissue to bone fixation for Extracapsular Repair: MCL, LCL.

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)

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510(k) Summary

February 16, 2023

Submitter InformationContact Information
Smith & Nephew, Inc.Ms. Dongeun LoPresti
Endoscopy DivisionSenior Regulatory Affairs Specialist
150 Minuteman Road(412)-683-3844
Andover, MA 01810
Device Name & Classification
Proprietary NameULTRABUTTON ◊ QUAD Adjustable Fixation Device
ULTRABUTTON BB Adjustable Fixation Device
ULTRABUTTON TIB Adjustable Fixation Device
Common NameFastener, Fixation, Nondegradable, Soft Tissue
Classification NameSmooth or threaded metallic bone fixation fastener
Classification Regulation21 CFR 888.3040
Class2
Product CodeMBI
PanelOrthopedic Devices (OHT6)

Legally Marketed Predicate Device

The Smith & Nephew ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation devices are substantially equivalent in intended use and fundamental scientific technology to the following legally marketed predicate device:

DescriptionSubmission NumberClearance Date
Adjustable Fixation DeviceK153186January 1, 2016

Device Description

The Smith & Nephew ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices consist of an ultra-high molecular weight polyethylene graft suspension loop and a titanium cortical button. The devices facilitate knee ligament repair/reconstruction through placement and retention of soft tissue or bone-tendon within bone.

The ULTRABUTTON QUAD Adjustable Fixation Device and the ULTRABUTTON BB Adjustable Fixation Device is available in one size. The UTLRABUTTON TIB Adjustable Fixation Device is available in a small, medium, or large size.

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Intended Use

The ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are intended for soft tissue to bone or bone-tendon to bone fixation.

Indications for Use

The ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are indicated for soft tissue to bone or bone-tendon to bone fixation for: ACL/PCL Repair/Reconstruction and soft tissue to bone fixation for Extracapsular Repair: MCL, LCL.

Technological Characteristics

The Smith & Nephew ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are substantially equivalent to the predicate Smith & Nephew Adjustable Fixation Device (K153186). Technological characteristics such as intended use, indications for use, sterilization method, and shelf-life are identical to the predicate device. There are minor changes in technological characteristics, such as design and material, compared to the predicate device. However, performance data demonstrates that the ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are substantially equivalent to the predicate device in these regards, and raise no new or different questions of safety and effectiveness.

Summary of Performance Data

  • Device cyclic displacement, device repair strength, and construct stiffness met the ● acceptance criteria established by the predicate device (K153186).
  • Biocompatibility testing per ISO 10993-1:2018 demonstrated passing results. ●
  • Bacterial endotoxin testing was completed and met acceptable limits per ANSI/AAMI ST72:2019.
  • The devices have a three (3) year shelf-life. Storage and stability is based on completed ● packaging material storage stability testing, device storage stability testing, and distribution testing. Packaging testing per ISO 11607-1:2019 demonstrated passing results.
  • Sterile adoption was completed per ISO 11135:2014+A1:2018. ●

Conclusion

There is no change in intended use, indications for use, sterilization method, and shelf-life. Changes in design and material are minor, and do not raise new or different questions of safety and effectiveness compared to the predicate device. The non-clinical testing has demonstrated that the ULTRABUTTON QUAD, BB, and TIB Adjustable Fixation Devices are substantially equivalent to their predicate device.