K Number
K231708
Device Name
Axoguard HA+ Nerve Protector (AGHA12); Axoguard HA+ Nerve Protector (AGHA22); Axoguard HA+ Nerve Protector (AGHA24); Axoguard HA+ Nerve Protector (AGHA36); Axoguard HA+ Nerve Protector (AGHA48)
Manufacturer
Date Cleared
2023-10-12

(122 days)

Product Code
Regulation Number
882.5275
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Axoguard HA+ Nerve Protector is indicated for the management and peripheral nerve injuries where there is no gap, or following closure of the gap.
Device Description
Axoguard HA+ Nerve Protector is a surgical implant that provides non-constricting protection for peripheral nerve injuries. Axoguard HA+ Nerve Protector is designed to aid in coaptation and protection of peripheral nerve injuries by serving as an interface between the nerve and the surrounding tissue and also providing tension relief when used as a coaptation aid. Axoguard HA+ Nerve Protector is comprised of an extracellular matrix (ECM) and is fully remodeled during the healing process. When hydrated, Axoguard HA+ Nerve Protector is easy to handle, soft, pliable, nonfriable, and porous. The lubricant coating on Axoguard HA+ Nerve Protector is composed of sodium hyaluronate and sodium alginate. When hydrated, the lubricant coating reduces friction between the nerve and the surrounding tissue. Axoguard HA+ Nerve Protector is flexible to accommodate movement of the joint and has sufficient mechanical strength to hold sutures. Axoguard HA+ Nerve Protector is provided sterile, for single use only, and in a variety of sizes to meet the surgeon's needs.
More Information

Not Found

No
The device description and performance studies focus on the physical properties, biocompatibility, and biological interaction of a surgical implant for nerve repair. There is no mention of AI, ML, image processing, or any computational analysis of data.

Yes
The device is indicated for the management and protection of peripheral nerve injuries by serving as an interface between the nerve and surrounding tissue and providing tension relief, thus directly contributing to the healing process.

No
The device, Axoguard HA+ Nerve Protector, is a surgical implant designed to protect and aid in the coaptation of peripheral nerve injuries by serving as an interface between the nerve and surrounding tissue. Its function is interventional and restorative, not diagnostic.

No

The device description clearly states it is a surgical implant comprised of an extracellular matrix (ECM) and a lubricant coating, indicating it is a physical medical device, not software.

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

Here's why:

  • Intended Use: The intended use is for the "management and peripheral nerve injuries where there is no gap, or following closure of the gap." This describes a surgical intervention and protection of tissue, not a diagnostic test performed on samples outside the body.
  • Device Description: The device is described as a "surgical implant" that provides "non-constricting protection for peripheral nerve injuries." It's a physical barrier and aid in healing, not a tool for analyzing biological samples to diagnose a condition.
  • Lack of Diagnostic Elements: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting biomarkers, or providing diagnostic information about a patient's condition.
  • Performance Studies: The performance studies focus on the device's mechanical properties, biocompatibility, and its effect on nerve regeneration in an animal model. These are relevant to the safety and efficacy of a surgical implant, not the performance of a diagnostic test.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The Axoguard HA+ Nerve Protector does not fit this description.

N/A

Intended Use / Indications for Use

Axoguard HA+ Nerve Protector is indicated for the management and protection of peripheral nerve injuries where there is no gap, or following closure of the gap.

Product codes

JXI

Device Description

Axoguard HA+ Nerve Protector is a surgical implant that provides non-constricting protection for peripheral nerve injuries. Axoguard HA+ Nerve Protector is designed to aid in coaptation and protection of peripheral nerve injuries by serving as an interface between the nerve and the surrounding tissue and also providing tension relief when used as a coaptation aid. Axoguard HA+ Nerve Protector is comprised of an extracellular matrix (ECM) and is fully remodeled during the healing process. When hydrated, Axoguard HA+ Nerve Protector is easy to handle, soft, pliable, nonfriable, and porous. The lubricant coating on Axoguard HA+ Nerve Protector is composed of sodium hyaluronate and sodium alginate. When hydrated, the lubricant coating reduces friction between the nerve and the surrounding tissue. Axoguard HA+ Nerve Protector is flexible to accommodate movement of the joint and has sufficient mechanical strength to hold sutures. Axoguard HA+ Nerve Protector is provided sterile, for single use only, and in a variety of sizes to meet the surgeon's needs.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

peripheral nerve

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)

7.1 Bench testing: The following performance data are provided in support of the substantial equivalence determination: biocompatibility testing in compliance with ISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process (FDA Recognized Consensus Standard 2-258), and bench testing including coefficient of friction, suture retention, ultimate tensile strength, bubble emission (packaging), seal strength (packaging). Testing performed included Coefficient of Friction, Suture Retention Strength, Ultimate Tensile Strength, Bubble Emission (Packaging), and Seal Strength (Packaging). All test articles met the acceptance criteria.

7.2 Biocompatibility: Biocompatibility endpoints for the subject device are in compliance with ISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing within risk management process (FDA Recognized Consensus Standard 2-258) was assessed. All necessary endpoints according to the standard were met. Tests included Sensitization, Irritation, Acute Systemic Toxicity, Pyrogenicity, Genotoxicity (Ames), Genotoxicity (Mouse Lymphoma Assay), and Endotoxin, and Cytotoxicity. All tests met acceptance criteria and showed no adverse effects.

7.3 Non-Clinical GLP Studies: The objective of this GLP study was to evaluate the effects of the Axoguard HA+ Nerve Protector (Next Generation Protection device or NGP) device on nerve regeneration after implantation in a rat sciatic nerve transection injury model. A total of sixty (60) Lewis Rats, were enrolled and divided between three (3) groups of 20 (10 males and 10 females). The 3 groups were Sham device, Test device, and Control device, groups. Animals underwent a single surgical procedure on Day 0 in which the right sciatic nerve was exposed and transected. Following transection, the two nerve ends were loosely approximated using two non-resorbable 10-0 Nylon sutures approximately 180 degrees apart, creating a standard direct nerve repair (neurorrhaphy). Animals were allowed to heal for six or twelve weeks post-implantation. All animals were successfully implanted and survived until appointed endpoints. Most animals maintained or gained body weight except three (3) that lost a small percentage (≤ 7%) of weight in Sham and Control device groups. There were no significant abnormal clinical observations for any animal in any group. There were no systemic effects to Axoguard HA+ Nerve Protector as indicated by animal health observations, body weight, hematology, serum chemistry or necropsy. Based on the histology endpoints for axonal outgrowth, axonal myelination and gastrocnemius muscle weight, the study met set acceptance criteria regarding safety and local effects related to nerve regeneration following implantation of Axoguard HA+ Nerve Protector in a rat sciatic nerve transection and repair model. The nerve regeneration-related outcomes in the Test device, Axoguard HA+ Nerve Protector, the group were not statistically significantly different when compared to the Control device.

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

Not Found

Predicate Device(s)

K223640

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.5275 Nerve cuff.

(a)
Identification. A nerve cuff is a tubular silicone rubber sheath used to encase a nerve for aid in repairing the nerve (e.g., to prevent ingrowth of scar tissue) and for capping the end of the nerve to prevent the formation of neuroma (tumors).(b)
Classification. Class II (performance standards).

0

October 12, 2023

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a seal with a stylized image of a human figure. To the right of the seal, there is the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue. The word "FDA" is in a larger font and is placed inside a blue square.

AxoGen Corporation Shravani Shastry Senior Regulatory Affairs Specialist 13631 Progress Blvd. Suite 400 Alachua. FL 32615-9409

Re: K231708

Trade/Device Name: Axoguard HA+ Nerve Protector (AGHA12); Axoguard HA+ Nerve Protector (AGHA22); Axoguard HA+ Nerve Protector (AGHA24); Axoguard HA+ Nerve Protector (AGHA36); Axoguard HA+ Nerve Protector (AGHA48) Regulation Number: 21 CFR 882.5275 Regulation Name: Nerve Cuff Regulatory Class: Class II Product Code: JXI Dated: September 11, 2023 Received: September 11, 2023

Dear Shravani Shastry:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"

1

(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.

Image /page/1/Picture/7 description: The image shows the name "Adam D. Pierce -S" in large, bold font on the left side. On the right side, it says "Digitally signed by Adam D. Pierce -S" in a smaller font. Below that, it says "Date: 2023.10.12 09:41:27 -04'00'".

Adam D. Pierce, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices

2

OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

510(k) Number (if known) K231708

Device Name

Axoguard HA+ Nerve Protector (AGHA12); Axoguard HA+ Nerve Protector (AGHA22); Axoguard HA+ Nerve Protector (AGHA24); Axoguard HA+ Nerve Protector (AGHA36); Axoguard HA+ Nerve Protector (AGHA48)

Indications for Use (Describe)

Axoguard HA+ Nerve Protector is indicated for the management and peripheral nerve injuries where there is no gap, or following closure of the gap.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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4

510(k) Summary: K231708

1. Submitter

Name:Axogen Corporation
13631 Progress Blvd, Ste 400
Alachua, FL, 32615
Contact Person:Shravani Shastry
Contact Title:Senior Regulatory Affairs Specialist
Phone (office):888-296-4361
Email:ra@axogeninc.com
Date Prepared:October 12th, 2023
2. Device InformationAxoguard HA+ Nerve Protector
Trade/Device Name:Nerve Cuff
Common/Usual Name:Nerve Cuff
Classification Name:Class II
Regulatory Class:JXI
Product Code:21 CFR 882.5275
Regulation Number:

3. Predicate Device

DeviceCompanyPredicate 510(k)Clearance date
Axoguard HA+
Nerve ProtectorAxogenK223640April 7, 2023

4. Device Description

Axoguard HA+ Nerve Protector is a surgical implant that provides non-constricting protection for peripheral nerve injuries. Axoguard HA+ Nerve Protector is designed to aid in coaptation and protection of peripheral nerve injuries by serving as an interface between the nerve and the surrounding tissue and also providing tension relief when used as a coaptation aid. Axoguard HA+ Nerve Protector is comprised of an extracellular matrix (ECM) and is fully remodeled during the healing process. When hydrated, Axoguard HA+ Nerve Protector is easy to handle, soft, pliable, nonfriable, and porous. The lubricant coating on Axoguard HA+ Nerve Protector is composed of sodium hyaluronate and sodium alginate. When hydrated, the lubricant coating reduces friction between the nerve and the surrounding tissue. Axoguard HA+ Nerve Protector is flexible to accommodate movement of the joint and has sufficient mechanical strength to hold sutures. Axoguard HA+ Nerve Protector is provided sterile, for single use only, and in a variety of sizes to meet the surgeon's needs.

5. Indications for Use

Axoguard HA+ Nerve Protector is indicated for the management and protection of peripheral nerve injuries where there is no gap, or following closure of the gap.

5

6. Comparison of Technological Characteristics with the Predicate Device

Axoguard HA+ Nerve Protector is similar in intended use, design, principle of operation, and material (ECM base membrane) as Axoguard HA+ Nerve Protector. Table 7-1 below summarizes the comparison between Axoguard HA+ Nerve Protector and its predicate.

Table 6-1: Device Technological Characteristics Comparison Summary
NameAxoguard HA+ Nerve Protector
(This submission)Axoguard HA+ Nerve Protector
(Predicate)
510(k)#K231708K223640
ManufacturerAxogen CorporationCook Biotech Inc.
Common NameNerve CuffNerve Cuff
Device ClassClass IIClass II
Classification Name and NumberNerve Cuff; 21 CFR 882.5275Nerve Cuff; 21 CFR 882.5275
Classification Product CodeJXIJXI
Prescription/Over
the Counter UseRx onlyRx only
Intended UseDesigned to be an interface
between the peripheral nerve
and the surrounding tissue.Designed to be an interface between the
peripheral nerve and the surrounding tissue.
Indications for UseAxoguard HA+ Nerve
Protector is indicated for the
management and protection of
peripheral nerve injuries where
there is no gap, or following
closure of the gap.Axoguard HA+ Nerve Protector is indicated
for the management of peripheral nerve
injuries where there is no gap
DimensionsWidth
(cm) Length
(cm) Area
(cm2) 1 2 2 2 2 4 2 4 8 3 6 18 4 8 32Width
(cm) Length
(cm) Area
(cm2) 1 2 2 2 2 4 2 4 8 3 6 18 4 8 32

6

| | Thickness: 100µm to 1000µm
SIS thickness range
(manufacturing specification). | Thickness: 100µm to 1000µm SIS thickness
range (manufacturing specification). |
|----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Material | Porcine SIS 2.0 decellularized
extracellular matrix supplied
by Cook Biotech, Inc., with a
2.2mg/cm² dry coating of
sodium hyaluronate and
sodium alginate applied to both
sides of the device in a 1:1
ratio. | Porcine SIS 2.0 decellularized extracellular
matrix supplied by Cook Biotech, Inc., with
a 2.2mg/cm² dry coating of sodium
hyaluronate and sodium alginate applied to
both sides of the device in a 1:1 ratio. |
| Configuration | Flat Sheet | Flat Sheet |
| Sterile/Single
Use | Single use only | Single use only |
| Sterility /
Sterilization
Method | SAL 10-6 / Ethylene Oxide | SAL 10-6 / Ethylene Oxide |

7. Performance Data

7.1 Bench testing

The following performance data are provided in support of the substantial equivalence determination: biocompatibility testing in compliance with ISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process (FDA Recognized Consensus Standard 2-258), and bench testing including coefficient of friction, suture retention, ultimate tensile strength, bubble emission (packaging), seal strength (packaging). Table 7.1-1 summarizes the testing performed for the Axoguard HA+ Nerve Protector.

Table 7.1-1: Axoguard HA+ Nerve Protector Testing Summary
TestTest Method SummarySummary Result
Coefficient of FrictionAged and unaged devices were evaluated for
their static coefficient of friction (lubricity)
based on ASTM D1894-14.Test articles met the
acceptance criteria.
Suture Retention StrengthAged and unaged devices were evaluated for
their suture retention strength by placing a
suture through the devices and the force required
to pull free was measured, based on
ANSI/AAMI/ISO 7198.Test articles met the
acceptance criteria.
Ultimate Tensile StrengthAged and unaged devices were evaluated for
their ultimate tensile strength by placing the
devices between two grips. The separation force
required resulting in device failure was
measured, based on ASTM D882-18.Test articles met the
acceptance criteria.

7

| Bubble Emission
(Packaging) | Aged and unaged devices underwent ethylene
oxide sterilization, and visual inspection prior to
bubble leak testing. The test articles underwent
evaluation in accordance with ASTM F2096-
11(2019). | Test articles met the
acceptance criteria. |
|--------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|
| Seal Strength (Packaging) | Aged and unaged devices underwent ethylene
oxide sterilization, and visual inspection prior to
seal strength testing. The test article sample sets
were subjected to seal strength testing in
accordance with ASTM F88/F88-21. | Test articles met the
acceptance criteria. |

7.2 Biocompatibility

Biocompatibility endpoints for the subject device are in compliance with ISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing within risk management process (FDA Recognized Consensus Standard 2-258) was assessed. All necessary endpoints according to the standard were met (Table 8.2-1).

Table 7.2-1: Axoguard HA+ Nerve Protector Testing Summary
TestTest Method SummarySummary Result
SensitizationTest article extracts of the device were evaluated
for their potential to cause delayed dermal
contact sensitization in a guinea pig
maximization test based on ISO 10993-10.Test article extracts showed no
evidence of causing delayed
dermal contact sensitization in
the guinea pig.
IrritationTest article extracts of the device were evaluated
for their potential to cause irritation following
intracutaneous injection in rabbits based on ISO
10993-23.Test article extracts met the
requirements of the test and
were considered non-irritants.
Acute Systemic ToxicityTest article extracts of the device were evaluated
for acute systemic toxicity in mice based on ISO
10993-11.There was no mortality or
evidence of systemic toxicity
from the test article extracts.
Each test article extract met
the requirements of the study.
PyrogenicityTest article extracts of the device were evaluated
for their potential to induce a pyrogenic
response following intravenous injection in
rabbits based on USP 43- NF38, General
Chapter , ISO 10993-11.The test article met the
requirements for the absence
of pyrogens.
Genotoxicity (Ames)Test article extracts of the device were evaluated
for their mutagenic potential in a tryptophan-
dependent strain of Escherichia coli or in one or
more strains of histidine-dependent Salmonella
typhimurium in the presence or absence of S9
metabolic activation based on ISO 10993-3.Test article extracts met the
requirements of the test and
were considered non-
mutagenic.

8

| Genotoxicity (Mouse
Lymphoma Assay) | Test article extracts of the device were evaluated
for their mutagenic potential using the mouse
lymphoma forward gene mutation assay based
on ISO 10993-3. | Test article extracts met the
requirements of the test and
were considered non-
mutagenic. |
|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------|
| Endotoxin | Test article extracts were evaluated for bacterial
endotoxins using the Kinetic-Turbidimetric test
method in accordance with USP 43- NF38,
General Chapter , USP43-NF38, General
Chapter and ANSI/AAMI ST72. | Test article extracts met USP
requirement. |
| Cytotoxicity | Test article extracts of the device were evaluated
for their potential to cause cytotoxic effects
using an in vitro mammalian cell culture test
based on ISO 10993-5. | Test article extracts showed no
evidence of causing cell lysis
or toxicity and each had a
grade of 0 (no reactivity). |

7.3 Non-Clinical GLP Studies

The objective of this GLP study was to evaluate the effects of the Axoguard HA+ Nerve Protector (Next Generation Protection device or NGP) device on nerve regeneration after implantation in a rat sciatic nerve transection injury model. A total of sixty (60) Lewis Rats, were enrolled and divided between three (3) groups of 20 (10 males and 10 females). The 3 groups were Sham device, Test device, and Control device, groups. Animals underwent a single surgical procedure on Day 0 in which the right sciatic nerve was exposed and transected. Following transection, the two nerve ends were loosely approximated using two non-resorbable 10-0 Nylon sutures approximately 180 degrees apart, creating a standard direct nerve repair (neurorrhaphy). Animals were allowed to heal for sixor twelve weeks post-implantation. All animals were successfully implanted and survived until appointed endpoints. Most animals maintained or gained body weight except three (3) that lost a small percentage (≤ 7%) of weight in Sham and Control device groups. There were no significant abnormal clinical observations for any animal in any group. There were no systemic effects to Axoguard HA+ Nerve Protector as indicated by animal health observations, body weight, hematology, serum chemistry or necropsy. Based on the histology endpoints for axonal outgrowth. axonal myelination and gastrocnemius muscle weight, the study met set acceptance criteria regarding safety and local effects related to nerve regeneration following implantation of Axoguard HA+ Nerve Protector in a rat sciatic nerve transection and repair model. The nerve regenerationrelated outcomes in the Test device, Axoguard HA+ Nerve Protector, the group were not statistically significantly different when compared to the Control device.

Conclusion:

The non-clinical data support the safety of the device and demonstrate that the Axoguard HA+ Nerve Protector performs as intended in its specified use conditions, is substantially equivalent to its predicate device, and does not raise different questions of safety and effectiveness.