K Number
K232492
Device Name
2.7 mm GRYPHON™ Flex Knotless PEEK Anchor; 2.7 mm GRYPHON™ Flex Knotless Biocomposite Anchor
Date Cleared
2023-10-06

(50 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The GRYPHON™ Flex Knotless Anchor is indicated for use for reattachment of soft tissue to bone for the following procedures: Shoulder: Bankart Repair, SLAP Lesion Repair, Capsular Shift or Capsulolabral Reconstruction, Superior Capsule Reconstruction (Glenoid Only) Hip: Acetabular Labral Repair Knee: MCL, LCL, Iliotibial Band Tenodesis Foot/Ankle: Lateral Stabilization, Medial Stabilization
Device Description
The proposed GRYPHON™ Flex Knotless PEEK and BIOCOMPOSITE Anchors is a line extension to the currently marketed GRYPHON Anchor family. The proposed product is a knotless anchor intended for fixation of soft tissue to bone in various soft tissue repair procedures. In its finished good configuration, the proposed device is a two-piece design; comprised of a permanent implant (anchor) component and a disposable (inserter) component. The 2.7mm anchor implant is preloaded on the inserter and a Nitinol distal tip retains the suture and the anchor while the device is malleted into the bone. The design offers surgeons maneuverability within the joint space. The disposable inserter will be offered in two design configurations, straight or curved to accommodate varying anatomies. The proposed GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors will be available in a 2.7 mm size, molded from either Polyetheretherketone (PEEK) material or Absorbable Biocryl Biocomposite ((Polylactic Acid (PLA) and Tricalcium Phosphate (TCP)) material. Both the GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors are provided sterile via Ethylene Oxide (EO) sterilization and are for single use only.
More Information

No
The device description and performance studies focus on the mechanical properties and materials of a surgical anchor, with no mention of AI or ML capabilities.

Yes
The device is described as an "anchor intended for fixation of soft tissue to bone in various soft tissue repair procedures" such as Bankart Repair, SLAP Lesion Repair, and Acetabular Labral Repair, which are therapeutic interventions.

No

The GRYPHON™ Flex Knotless Anchor is an implantable device used for surgical fixation of soft tissue to bone, not for diagnostic purposes.

No

The device description clearly states it is a physical implant (anchor) and an inserter, made of materials like PEEK and Biocryl Biocomposite. It is a hardware device for surgical procedures.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "reattachment of soft tissue to bone for the following procedures: Shoulder, Hip, Knee, Foot/Ankle". This describes a surgical procedure performed directly on the patient's body.
  • Device Description: The description details a physical implant (anchor) and an inserter, designed for surgical fixation.
  • IVD Definition: In Vitro Diagnostics (IVDs) are medical devices used to perform tests on samples taken from the human body (like blood, urine, or tissue) to provide information about a person's health.

This device is a surgical implant, not a diagnostic test performed on samples outside the body.

N/A

Intended Use / Indications for Use

The GRYPHON™ Flex Knotless Anchor is indicated for use for reattachment of soft tissue to bone for the following procedures:

IndicationPEEKBIOCRYL
Shoulder - Bankart RepairXX
Shoulder - SLAP Lesion RepairXX
Shoulder - Capsular Shift or Capsulolabral ReconstructionXX
Shoulder - Superior Capsule Reconstruction (Glenoid Only)XX
Hip - Acetabular Labral RepairXX
Knee - MCLXX
Knee - LCLXX
Knee - Iliotibial Band TenodesisXX
Foot/Ankle - Lateral StabilizationXX
Foot/Ankle - Medial StabilizationXX

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

MBI, MAI

Device Description

The proposed GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors is a line extension to the currently marketed GRYPHON Anchor family. The proposed product is a knotless anchor intended for fixation of soft tissue to bone in various soft tissue repair procedures. In its finished good configuration, the proposed device is a two-piece design; comprised of a permanent implant (anchor) component and a disposable (inserter) component. The 2.7mm anchor implant is preloaded on the inserter and a Nitinol distal tip retains the suture and the anchor while the device is malleted into the bone. The design offers surgeons maneuverability within the joint space. The disposable inserter will be offered in two design configurations, straight or curved to accommodate varying anatomies.

The proposed GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors will be available in a 2.7 mm size, molded from either Polyetheretherketone (PEEK) material or Absorbable Biocryl Biocomposite ((Polylactic Acid (PLA) and Tricalcium Phosphate (TCP)) material.

Both the GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors are provided sterile via Ethylene Oxide (EO) sterilization and are for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Shoulder, Hip, Knee, Foot/Ankle

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Surgeons / Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical Verification activities were performed on the proposed device and its predicate. Non-Testing clinical performance testing included evaluation of in-vitro fixation strength at zero, six, twelve, thirteen and twenty-six weeks, insertion torque, torque to failure and cyclic & post cyclic fixation at time zero.
Ethylene Oxide Sterilization was validated according to ANSI/AAMI/ISO 11135: 2014 to a SAL of 1 x 10^-6.
EO residuals were tested per AAMI/ANSI/ISO 10993-7:2008.
Biological safety was evaluated according to ISO 10993-1 for devices having direct patient contact, inclusive of raw materials of components, manufacturing processes, sterilization, and primary packaging materials.
The proposed device has been determined to be non-pyrogenic per the requirements set forth in ANSI/AAMI ST-72:2011, United States Pharmacopeia (USP), and European Pharmacopeia (EP) using the bacterial endotoxin testing (BET) method.
Results of non-clinical performance testing have demonstrated that the proposed devices are suitable for their intended use.

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.

K101679, Arthrex PushLock Anchors (BIOCOMPOSITE)

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.

K182941, K201883, K191242, K140643, K040004, K181182

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.

0

October 6, 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.

Medos International SARL % Elizabeth Messana Senior Regulatory Specialist DePuy Synthes Mitek Sports Medicine 325 Paramount Drive Raynham, Massachusetts 02767

Re: K232492

Trade/Device Name: 2.7 mm GRYPHON™ Flex Knotless PEEK Anchor; 2.7 mm GRYPHON™ Flex Knotless Biocomposite Anchor Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI, MAI Dated: August 16, 2023 Received: August 17, 2023

Dear Elizabeth Messana:

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" (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).

1

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 medical devices and radiation-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

Jesse Muir, 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

2

Enclosure

3

Indications for Use

510(k) Number (if known) K232492

Device Name

GRYPHON™ Flex Knotless Anchor

Indications for Use (Describe)

The GRYPHON™ Flex Knotless Anchor is indicated for use for reattachment of soft tissue to bone for the following procedures:

IndicationPEEKBIOCRYL
ShoulderBankart RepairXX
SLAP Lesion RepairXX
Capsular Shift or Capsulolabral ReconstructionXX
Superior Capsule Reconstruction (Glenoid Only)XX
HipAcetabular Labral RepairXX
KneeMCLXX
LCLXX
Iliotibial Band TenodesisXX
Foot/AnkleLateral StabilizationXX
Medial StabilizationXX

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.

4

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5

510(k) SUMMARY GRYPHON™ Flex Knotless Anchors Date Prepared: 8/15/2023

| Submitter's
Name and
Address | DePuy Synthes Mitek Sports Medicine
a Johnson & Johnson company
325 Paramount Drive
Raynham, MA 02767

On behalf of:
Medos International SARL
Chemin-Blanc 38, Le Locle Neuchatel
CH 2400, Switzerland | |
|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|
| Contact Person | Elizabeth P. Messana
Senior Regulatory Affairs Specialist

DePuy Synthes Mitek Sports Medicine
a Johnson & Johnson company
325 Paramount Drive
Raynham, MA 02767 | Telephone: 508-828-3150
Email: emessan1@its.jnj.com |
| Name of Medical
Device | Proprietary Name:
A) GRYPHON™ Flex Knotless PEEK Anchor
B) GRYPHON™ Flex Knotless BIOCOMPOSITE Anchor

Classification Name:
A) Smooth or threaded metallic bone fixation fastener
B) Single/multiple component metallic bone fixation appliances
and accessories

Product Code:
A) MBI
B) MAI

Common Name:
Suture Anchor | |
| Substantial Equivalence | The GRYPHON Flex Knotless PEEK and BIOCOMPOSITE
Anchors are substantially equivalent to:
K101679, Arthrex PushLock Anchors (BIOCOMPOSITE) Reference Devices:
K182941 and K201883- HEALIX ADVANCE™ SP PEEK
Anchor (MEDOS International), K191242 and K201883 HEALIX ADVANCE™ SP
BIOCOMPOSITE Anchor (MEDOS International), K140643 GRYPHON™ Anchor W/ Proknot Technology
(DePuy Mitek), K040004 ORTHOCORD® Suture (DePuy Mitek), K181182 DYNACORD™ Suture (MEDOS International). | |
| Device Classification | GRYPHON Flex Knotless PEEK Anchor is classified as:
Fastener, Fixation, Nondegradable, Soft Tissue, classified as Class
II, product code MBI, regulated under 21 CFR 888.3040.

GRYPHON Flex Knotless BIOCOMPOSITE Anchor is classified as:
Single/multiple component metallic bone fixation appliances and
accessories, classified as Class II, product code MAI, regulated
under 21 CFR 888.3030. | |
| Device Panel | Orthopedic Devices | |
| Device Description | The proposed GRYPHON Flex Knotless PEEK and
BIOCOMPOSITE Anchors is a line extension to the currently
marketed GRYPHON Anchor family. The proposed product is a
knotless anchor intended for fixation of soft tissue to bone in
various soft tissue repair procedures. In its finished good
configuration, the proposed device is a two-piece design; comprised
of a permanent implant (anchor) component and a disposable
(inserter) component. The 2.7mm anchor implant is preloaded on
the inserter and a Nitinol distal tip retains the suture and the anchor
while the device is malleted into the bone. The design offers
surgeons maneuverability within the joint space. The disposable
inserter will be offered in two design configurations, straight or
curved to accommodate varying anatomies.

The proposed GRYPHON Flex Knotless PEEK and
BIOCOMPOSITE Anchors will be available in a 2.7 mm size,
molded from either Polyetheretherketone (PEEK) material or | |

6

7

Absorbable Biocryl Biocomposite ((Polylactic Acid (PLA) and Tricalcium Phosphate (TCP)) material.
Both the GRYPHON Flex Knotless PEEK and BIOCOMPOSITE Anchors are provided sterile via Ethylene Oxide (EO) sterilization and are for single use only.
Technological CharacteristicsThe suture anchor design, principal of operation and indications for use are similar when compared to the predicate device- Arthrex PushLock (BIOCOMPOSITE) Anchors, (K101679). A subset of indications will be pursued for the proposed device.
The PEEK material of the proposed device is identical to that present in the reference device- K182941 and K201883- HEALIX ADVANCE™ SP PEEK Anchor.
The Biocomposite material of the proposed device is identical to that present in the reference device- K191242 and K201883- HEALIX ADVANCE™ SP BIOCOMPOSITE Anchor

The GRYPHON™ Flex Knotless Anchor is indicated for use for reattachment of soft tissue Indications for to bone for the following procedures: Use

IndicationPEEKBIOCRYL
ShoulderBankart RepairXX
SLAP Lesion RepairXX
Capsular Shift or Capsulolabral ReconstructionXX
Superior Capsule Reconstruction (Glenoid Only)XX
HipAcetabular Labral RepairXX
KneeMCLXX
LCLXX
Iliotibial Band TenodesisXX
Foot/AnkleLateral StabilizationXX
Medial StabilizationXX

Non-clinical Verification activities were performed on the proposed device and its predicate. Non-Testing clinical performance testing included evaluation of in-vitro fixation strength at zero, six, twelve, thirteen and twenty-six weeks, insertion torque, torque to failure and cyclic & post cyclic fixation at time zero.

8

| Ethylene Oxide Sterilization was validated according to ANSI/AAMI/ISO 11135: 2014 to a

SAL of 1 x 10-6.
EO residuals were tested per AAMI/ANSI/ISO 10993-7:2008.
Biological safety was evaluated according to ISO 10993-1 for devices having direct patient
contact, inclusive of raw materials of components, manufacturing processes, sterilization, and primary
packaging materials.
The proposed device has been determined to be non-pyrogenic per the requirements set forth
in ANSI/AAMI ST-72:2011, United States Pharmacopeia (USP), and European
Pharmacopeia (EP) using the bacterial endotoxin testing (BET) method.
Safety and
PerformanceResults of non-clinical performance testing have demonstrated that the proposed devices are
suitable for their intended use.
Based on similarities in the indications for use, technological characteristics, and
performance testing in comparison to the predicate devices, the proposed GRYPHON Flex
Knotless PEEK and BIOCOMPOSITE Anchors have demonstrated that they are substantially
equivalent to the predicate device under the Federal Food, Drug and Cosmetic Act.