(90 days)
Transorb™ Self-Gripping Resorbable Mesh is intended to be used for the reinforcement of abdominal wall soft tissues where weakness exists in open procedures involving ventral hernia repair.
Transorb™ Self-Gripping Resorbable Mesh is designed for ventral hernia repair when placed in an extraperitoneal space by open surgical approach. Transorb™ Self-Gripping Resorbable Mesh is made of a fully resorbable bi-dimensional Poly-L-lactide, poly-trimethylene carbonate copolymer (PLLA/TMC) monofilament textile with monofilament PLLA/TMC absorbable grips on one side. Transorb™ Self-Gripping Resorbable Mesh is available in different shapes and sizes. Transorb™ Self-Gripping Resorbable Mesh is a macro-porous mesh knitted from resorbable monofilament PLLA/TMC yarns. It has been designed to reinforce soft tissues where weakness exists by providing strength and tissue integration throughout the expected healing period. Transorb™ Self-Gripping Resorbable Mesh has absorbable PLLA/TMC grips on one side that facilitate positioning and contribute to fixation. The PLLA/TMC mesh and grips degrade and resorb in vivo by hydrolysis in 36 to 60 months and are metabolized by the body into CO2 and H₂O.
The provided text describes a 510(k) premarket notification for a medical device called "Transorb™ Self-Gripping Resorbable Mesh." This submission is to demonstrate substantial equivalence to a predicate device, not to prove the device meets specific acceptance criteria for a new claim typically associated with AI/ML devices or novel therapies. Therefore, the information typically requested in your prompt regarding acceptance criteria, study types, ground truth, and expert involvement for AI/ML performance is not present in this regulatory document.
However, I can extract the performance data and "acceptance" (pass/fail) criteria as presented for the biocompatibility and bench testing components of this surgical mesh.
Here's the information based on the provided text, structured as much as possible according to your request, but acknowledging the inherent differences in regulatory submissions for a surgical mesh versus an AI/ML diagnostic tool:
1. Table of Acceptance Criteria and Reported Device Performance
For this medical device (surgical mesh), "acceptance criteria" are implied by compliance with established standards and the outcome of "Pass" for various tests. The reported device performance is that it passed these tests, thus meeting the implied criteria.
| Type of Test | Specific Test / Standard | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|---|
| Biocompatibility | ISO 10993-5 (Cytotoxicity) | Compliance with standard | Pass |
| ISO 10993-10 (Sensitization) | Compliance with standard | Pass | |
| ISO 10993-10 (Intracutaneous irritation) | Compliance with standard | Pass | |
| ISO 10993-11 (Acute systemic toxicity) | Compliance with standard | Pass | |
| ISO 10993-11 (Material mediated pyrogenicity) | Compliance with standard | Pass | |
| ISO 10993-4 (Hemolysis) | Compliance with standard | Pass | |
| ISO10993-3 (Genotoxicity: bacterial reverse mutation -Ames) | Compliance with standard | Pass | |
| ISO10993-3 (Genotoxicity: mouse lymphoma) | Compliance with standard | Pass | |
| ISO 10993-11 (Subacute systemic toxicity) | Compliance with standard | Pass | |
| ISO 10993-11 (Subchronic systemic toxicity) | Compliance with standard | Pass | |
| ISO 10993-6 (Local tissue effects - 28D - 10W - 26W - 52W - 78W) | Compliance with standard | Pass | |
| ISO 10993-9 (In vivo degradation) | Compliance with standard | Pass | |
| Bench Testing | Internal test method (Pore size: 1.4mm x 1.4mm at implantation) | Substantially equivalent to predicate | Substantially equivalent |
| ISO 3801: 1977 (Surface density) | Substantially equivalent to predicate | Substantially equivalent | |
| ISO 9073-2: 1997 (Thickness) | Substantially equivalent to predicate | Substantially equivalent | |
| ASTM 06797-15 (Bursting strength and deflection) | Substantially equivalent to predicate | Substantially equivalent | |
| ISO 13934-1: 2013 (Breaking strength and elongation at break) | Substantially equivalent to predicate | Substantially equivalent | |
| ISO 4674:1977 - method A2 (Tear strength) | Substantially equivalent to predicate | Substantially equivalent | |
| Internal test method (Suture pull-out strength) | Substantially equivalent to predicate | Substantially equivalent | |
| Animal Testing | Porcine study - Reinforcement performance (Mechanical performance, tissue repair, integration) | Demonstrated safety/performance and substantial equivalence to predicate | Demonstrated safety/performance and substantial equivalence |
| Rabbit study – Degradation/Integration (Local tissue effects, tissue integration, degradation profile) | Demonstrated safety/performance and substantial equivalence to predicate | Demonstrated safety/performance and substantial equivalence | |
| Porcine study – Gripping performance (Contribution of grips, tissue repair, integration) | Demonstrated safety/performance and substantial equivalence to predicate | Demonstrated safety/performance and substantial equivalence | |
| Human Factors | IEC 62366-1 (Usability) | Substantially equivalent for intended users, uses, environment | Substantially equivalent |
| Shelf-life | Real time studies (mechanical performance, sterile barrier) | Demonstrated 36-month shelf-life | 36 months assigned shelf-life |
Notes on Acceptance Criteria: The primary "acceptance criterion" for this 510(k) submission is to demonstrate substantial equivalence to the predicate device (TIGR® Matrix Surgical Mesh K191749), showing that differences do not raise new questions of safety or effectiveness. For biocompatibility tests, the criterion is to "Pass" the specific ISO 10993 standard. For bench tests, the conclusion is frequently stated as "substantially equivalent" to the predicate.
2. Sample Size for Test Set and Data Provenance
- Test Set Sample Size: Not explicitly stated for each test in terms of a numerical count of units or animals. The text mentions broad categories like "PLLA/TMC monofilament yarn (up to 21g)" for composition and lists different product codes/sizes (e.g., TSB1510, TSB2020, TSB3030, TSB4030) that imply various units were tested across the different evaluations. For animal studies, it mentions "large animal model" (porcine) and "rabbit study."
- Data Provenance: The studies were internal preclinical (bench and animal) tests conducted by the manufacturer or their testing partners. There is no specific country of origin mentioned for the data, beyond the manufacturer being based in France. The studies are prospective in nature, designed specifically for this submission.
3. Number of Experts and Qualifications for Ground Truth
- Not Applicable in the context of your question. This document pertains to a physical medical device (surgical mesh) and its performance in bench and animal studies, not an AI/ML device requiring expert adjudication of outputs to establish ground truth from clinical images or data. The "ground truth" here is the physical and biological reality as measured by the various test methods (e.g., breaking strength, tissue ingrowth observations).
4. Adjudication Method for Test Set
- Not Applicable for the reasons stated above. Adjudication methods like "2+1" or "3+1" are typically used to establish a consensus ground truth in clinical evaluations, especially for AI/ML diagnostic tools. For this surgical mesh, performance is measured against established scientific and engineering principles via tests (e.g., ISO standards, ASTM standards, histological examination).
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, a MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic devices (especially AI/ML-assisted ones) to assess the impact of the device on human reader performance. This submission is for a surgical implant, where such studies are not typically performed or required to demonstrate substantial equivalence. The document explicitly states: "This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence."
6. Standalone (Algorithm Only) Performance Study
- No, a standalone performance study was not done. This concept is specific to AI/ML algorithms evaluated independently of human interaction. The Transorb™ mesh is a physical implant, not a software algorithm. Its performance is evaluated through physical, chemical, and biological testing, outlined as biocompatibility, bench testing, and animal studies.
7. Type of Ground Truth Used
The "ground truth" for this device's performance is established through:
- Compliance with International Standards: For biocompatibility (ISO 10993 series) and some physical properties (e.g., ISO 3801, ISO 9073-2, ISO 13934-1, ISO 4674).
- Predicate Device Comparison: For mechanical properties and physical aspects, the device's performance is compared to the predicate device (TIGR® Matrix Surgical Mesh, K191749), with substantial equivalence being the goal.
- Histology/Pathology: For animal studies, tissue repair, tissue integration, local tissue effects, and degradation profile were assessed via histological examination.
- Direct Measurement: For parameters like pore size, surface density, thickness, bursting strength, suture pull-out strength, etc., direct measurements are taken.
8. Sample Size for the Training Set
- Not Applicable. This device is a physical surgical mesh, not an AI/ML algorithm that requires a training set. The term "training set" is not relevant in this context.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As there is no training set for this device, the question of how its ground truth was established is not relevant.
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February 13, 2024
Sofradim Production Mickaël Nicolas Principal Regulatory Affairs Specialist 116, Avenue du Formans Trévoux, 01600, France
Re: K233661
Trade/Device Name: Transorb™ Self-Gripping Resorbable Mesh Regulation Number: 21 CFR 878.3300 Regulation Name: Surgical Mesh Regulatory Class: Class II Product Code: OWT, OOD, FTL Dated: November 14, 2023 Received: November 15, 2023
Dear Mickael Nicolas:
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).
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Your device is also subject to, among other requirements, the Quality System (OS) 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 QS 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,
Digitally signed by Tek Tek N. N. Lamichhane -S Lamichhane -S Date: 2024.02.13 07:48:57 -05'00' Tek N. Lamichhane, Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic and Reconstructive Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Indications for Use
510(k) Number (if known) K233661
Device Name Transorb™ Self-Gripping Resorbable Mesh
Indications for Use (Describe)
Transort™ Self-Gripping Resorbable Mesh is intended to be used for the reinforcement of abdominal wall soft tissues where weakness exists in open procedures involving ventral hernia repair.
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary
| 510(k) Number | K233661 |
|---|---|
| Date Prepared: | January 11, 2024 |
| Submitter: | Sofradim Production (subsidiary of Covidien IIc) |
| 116, avenue du Formans | |
| 01600 Trevoux, France | |
| Telephone: +33 (0)4 74 08 90 00 | |
| Fax: +33 (0) 4 74 08 90 02 | |
| Contact: | Mickaël Nicolas |
| Regulatory Affairs Principal Specialist | |
| 116, avenue du Formans | |
| 01600 Trevoux, France | |
| Phone: +33 (0)4 74 08 90 00 | |
| Email: mickael.nicolas@medtronic.com | |
| Name of device: | |
| Trade/Proprietary name: | Transorb™ Self-Gripping Resorbable Mesh |
| Common name: | Surgical Mesh |
| Classification name: | General And Plastic Surgery Panel number |
| Product code: OWT, FTL, OOD | |
| Regulation number: 21 CFR 878.3300 | |
| Predicate Device: | |
| Trade/Proprietary name: | TIGR® Matrix Surgical Mesh |
| Common name: | Surgical Mesh |
| Classification name: | General And Plastic Surgery Panel number and product code: OWT, FTL,OOD |
| Regulation number: 21 CFR 878.3300 | |
| 510(k) Number: | K191749 |
| Manufacturer: | Novus Scientific AB, Virdings Alle 2, Uppsala, SE Se-754 50 |
| Reference Device 1: | |
| Trade/Proprietary name: | ProGrip™ Self-Gripping Polyester Mesh |
| Common name: | Surgical Mesh |
| Classification name: | General And Plastic Surgery Panel number and product code: FTL |
| Regulation number: 21 CFR 878.3300 | |
| 510(k) Number: | K220586 |
| Manufacturer: | Sofradim Production (subsidiary of Covidien IIc) |
| 116, avenue du Formans | |
| 01600 Trevoux, France |
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Reference Device 2:
| Trade/Proprietary name: | Phasix™ Mesh |
|---|---|
| Common name: | Surgical Mesh |
| Classification name: | General And Plastic Surgery Panel number and product code: OODRegulation number: 21 CFR 878.3300 |
| 510(k) Number: | K161424 |
| Manufacturer: | Davol Inc. |
| 100 Crossings Boulevard | |
| Warwick, RI 02886 | |
| Device Description: | Transorb™ Self-Gripping Resorbable Mesh is designed for ventralhernia repair when placed in an extraperitoneal space by open surgicalapproach. |
| Transorb™ Self-Gripping Resorbable Mesh is made of a fully resorbablebi-dimensional Poly-L-lactide, poly-trimethylene carbonate copolymer(PLLA/TMC) monofilament textile with monofilament PLLA/TMC |
Transorb™ Self-Gripping Resorbable Mesh is available in different shapes and sizes.
Mesh composition:
absorbable grips on one side.
| Product codes | Shape | Dimensions(length x width) |
|---|---|---|
| TSB1510 | Rectangular | 10cm x 15cm |
| TSB2020 | Square | 20cm x 20cm |
| TSB3030 | Square | 30cm x 30cm |
| TSB4030 | Rectangular | 30cm x 40cm |
Poly-L-lactide, poly-trimethylene carbonate copolymer (PLLA/TMC) monofilament yarn (up to 21g).
The detailed composition refers to the estimated maximum amount of each material and substance to which a patient can be exposed when 1 unit of the largest size of Transorb™ Self-Gripping Resorbable Mesh is implanted (i.e 40 x 30 cm). These amounts will be less for smaller sizes or if the mesh is trimmed by the practitioner prior to implantation.
Transorb™ Self-Gripping Resorbable Mesh is a macro-porous mesh knitted from resorbable monofilament PLLA/TMC yarns. It has been designed to reinforce soft tissues where weakness exists by providing strength and tissue integration throughout the expected healing period. Transorb™ Self-Gripping Resorbable Mesh has absorbable PLLA/TMC grips on one side that facilitate positioning and contribute to fixation. The PLLA/TMC mesh and grips degrade and resorb in vivo by hydrolysis in 36 to 60 months and are metabolized by the body into CO2 and H₂O.
The macro-porous textile provides strength required to withstand biomechanical stresses throughout the healing period, while allowing
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for tissue ingrowth. As the textile integrates, host tissue ingrowth is intended to provide strength to the repair.
Preclinical studies showed that the mesh maintains mechanical characteristics to reinforce the abdominal wall in vivo for at least 20 weeks and progressively resorbs.
Preclinical studies showed that the grips contribute to the fixation of the mesh to surrounding tissue in vivo for at least 4 weeks.
At 18 to 24 months, mesh degradation is nearly complete. The remaining mesh fibers are essentially resorbed in 36 to 60 months postimplantation. The total resorption period depends on numerous factors including unique patient physiology.
Intended Use:
Transorb™ Self-Gripping Resorbable Mesh is intended to be used for the reinforcement of abdominal wall soft tissues where weakness exists.
Indications for use:
Summary comparing the technological characteristics of the subject, predicate device and reference devices:
Transorb™ Self-Gripping Resorbable Mesh is intended to be used for the reinforcement of abdominal wall soft tissues where weakness exists in open procedures involving ventral hernia repair.
The subject device Transorb™ Self-Gripping Resorbable Mesh is substantially equivalent to the predicate device TIGR® Matrix Surgical Mesh (K191749) in terms of indications.
| Transorb™ Self-GrippingResorbable Mesh(K233661) | TIGR® (K191749)Predicate device | Comparison | |
|---|---|---|---|
| IntendedUse | Reinforcement ofabdominal wall softtissue whereweakness exists. | Reinforcement ofsoft tissue whereweakness exists. | Similar |
| Indicationsfor use | Transorb™ self-gripping resorbablemesh is intended tobe used for thereinforcement ofabdominal wall softtissues whereweakness exists inopen proceduresinvolving ventralhernia repair. | Procedures involvingsoft tissue repair,such as for the repairof hernias or otherfascial defects thatrequire the additionof a reinforcingmaterial to obtainthe desired surgicalresult | Similar |
| Method ofInsertion | Open | Open andlaparoscopic | Similar |
| Location ofMeshplacement | Extraperitoneal | Extraperitoneal | Same |
| DefectClosure | Recommended | Recommended | Same |
| Classification | OWT, OOD, FTL per21 CFR 878.3300 | OWT, OOD, FTL per21 CFR 878.3300 | Same |
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| Materials | Fully resorbabletextile (polymeric)made of copolymerof polylactide acidand trimethylenecarbonate yarns(PLLA/TMC) | Fully resorbabletextile (polymeric)made of(i) copolymer ofglycolide, lactide andtrimethylenecarbonate(PGA/PLA/TMC) and(ii) copolymer oflactide andtrimethylenecarbonate(PLLA/TMC) | Similar |
|---|---|---|---|
| Shape | Flat SheetSquare, rectangular,with round corners | Flat SheetRectangular | Similar |
| Sizes | 10x15cm, 20x20cm,30x30cm and30x40cmThe mesh may berecut as needed | 10x15cm, 15x20cmand 20x30cmThe mesh may berecut as needed | Different |
| Texture | Two-dimensionalmonofilamenttextile withmonofilamentabsorbable grips onone side of themeshPorosity: pore sizeof 1.4mm x 1.4mmat the time ofimplantation | Two-dimensionalmultifilament textilePorosity: pore size of1.0 mm x 1.0 mm atthe time ofimplantation | Different |
| Sterilization | Ethylene Oxide | Ethylene Oxide | Same |
Both predicate and subject devices are resorbable flat sheet meshes. Differences in terms of material, sizes, and texture (pore size and presence of grips) have been evaluated and do not raise new questions of safety or effectiveness. Performance testing has demonstrated substantial equivalence for biocompatibility, mechanical properties such as strength, human factors evaluation, sterilization, packaging, and transport.
The device ProGrip™ Self-Gripping Polyester Mesh previously cleared under K220586 is introduced as a reference device for its gripping design feature to support the design of the subject device. Both reference and subject devices have resorbable grips on one side and are equivalent in terms of intended use.
The device Phasix™ Mesh previously cleared under K161424 is introduced as a reference device because it includes large sizes (up to 50*50cm) and it is a fully resorbable mesh. Both reference and subject devices are resorbable meshes with large mesh sizes.
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Transorb™ Self-Gripping Resorbable Mesh has been evaluated and Materials: found compliant with ISO Standard 10993-1.
Performance data: The performance of Transorb™ Self-Gripping Resorbable Mesh has been evaluated through bench tests, in vitro and in vivo studies. These studies demonstrate that the subject device and predicate device TIGR® Matrix Surgical Mesh (K191749) have substantially equivalent performance characteristics. The following performance data is provided:
a. Biocompatibility Testing
Biocompatibility testing and classification has been selected and performed in accordance with ISO 10993, Biological evaluation of Medical Devices, Part 1: Evaluation and testing within a risk management process. Transorb™ Self-Gripping Resorbable Mesh is classified as an implant with permanent contact.
A complete chemical characterization was performed in accordance with ISO 10993-18. No risk of chronic toxicity, carcinogenicity or reproductive and developmental toxicity has been identified so nor through literature review and material characterization, nor in Toxicological Risk Assessment performed on finished product extractables profile. Available biological safety data on the Transorb™ Self-Gripping Resorbable Mesh are listed hereafter. Testing was performed on sterilized finished devices.
| Studies | Standards | Conclusion |
|---|---|---|
| Cytotoxicity | ISO10993-5 | Pass |
| Sensitization | ISO 10993-10 | Pass |
| Intracutaneous irritation | ISO10993-10 | Pass |
| Acute systemic toxicity | ISO10993-11 | Pass |
| Material mediated pyrogenicity | ISO10993-11 | Pass |
| Hemolysis | ISO 10993-4 | Pass |
| Genotoxicity: bacterial reverse mutation -Ames | ISO10993-3 | Pass |
| Genotoxicity: mouse lymphoma | ISO10993-3 | Pass |
| Subacute systemic toxicity | ISO 10993-11 | Pass |
| Subchronic systemic toxicity | ISO 10993-11 | Pass |
| Local tissue effects (28D - 10W -26W - 52W - 78W) | ISO 10993-6 | Pass |
| In vivo degradation | ISO 10993-9 | Pass |
Applicable ISO 10993-1 Biocompatibility evaluation was conducted and demonstrates that the subject device is biocompatible for its intended body contact and duration.
b. Bench Testing
Bench tests have been performed in accordance with the FDA Guidance "Guidance for the Preparation of a Premarket Notification Application of a Surgical Mesh" issued March 2, 1999 to evaluate the performance characteristics of the subject device Transorb™ Self-Gripping
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Resorbable Mesh in comparison with the predicate TIGR Matrix Surgical Mesh (K191749). The following finished product physical and mechanical performances were assessed:
| Test method | Applicable standard / Test method | Conclusion |
|---|---|---|
| Pore size | Internal test method.Mesh pore size is measured on aprofile projector. Biggest poresextreme height and width aremeasured, the sample being free ofany stresses. | Regarding physical aspect,the proposed device(Transorb™ Self-GrippingResorbable Mesh) issubstantially equivalent toTIGR® Matrix Surgical Mesh(K191749). |
| Surfacedensity | ISO 3801: 1977 | |
| Thickness | ISO 9073-2: 1997 | |
| Burstingstrength anddeflection | ASTM 06797-15 | |
| Breakingstrength andelongation atbreak | ISO 13934-1: 2013 | Regarding mechanicalaspect in case of 510(k)registration, the proposeddevice (Transorb™ Self-Gripping Resorbable Mesh) is substantially equivalentto TIGR® Matrix SurgicalMesh (K191749). |
| Tear strength | ISO 4674:1977 - method A2 | |
| Suture pull-out strength | Internal test method.Suture pull-out strength ismeasured on a traction testingmachine using dedicated specimensand test conditions |
c. Animal Testing
Porcine study - Reinforcement performance
In vivo pre-clinical tests on large animal model were conducted in comparison with the predicate TIGR Matrix Surgical Mesh (K191749) to evaluate Transorb™ Self-Gripping Resorbable Mesh reinforcement performance during healing period (up to 20 weeks following implantation):
- o Mechanical performance (breaking strength – ball burst) of the repaired abdominal wall defects sites using a ball burst testing method.
- o Quality of tissue repair and of mesh tissue integration was also assessed by histologic examination.
Rabbit study – Degradation/Integration
In vivo testing has been performed in comparison with predicate TIGR Matrix Surgical Mesh (K191749) to evaluate:
- o Local tissue effects per requirements of ISO 10993-6 (2016) and FDA Guidance Use on International Standard ISO 10993-1, "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process"
- Tissue integration and tissue ingrowth; O
- Degradation profile O
Porcine study – Gripping performance
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In vivo testing has been performed in comparison with predicate TIGR Matrix Surgical Mesh (K191749) to evaluate:
- Contribution of the grips to the fixation of the mesh to the o surrounding tissue in early stages after implantation
- Quality of tissue repair and mesh tissue integration by o histologic examination.
These tests demonstrate the safety and performance of the subject device for its intended use and substantial equivalence to the primary predicate device.
d. Human Factors Testing
Usability tests were conducted in accordance with IEC 62366-1 and demonstrate that the subject device Transorb™ Self-Gripping Resorbable Mesh is substantial equivalent for the intended users, uses and use environments.
e. Shelf-life
The shelf-life of the subject Transorb™ Self-Gripping Resorbable Mesh was demonstrated by the results of the real time studies performed on Transorb™ Self-Gripping Resorbable Mesh (representative of final sterile product), that includes testing of the product mechanical performances and the ability of packaging to maintain sterile barrier. Based on these results, a shelf life of 36 months was assigned for the subject Transorb™ Self-Gripping Resorbable Mesh.
f. Clinical data
This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence.
Conclusion:
All testing demonstrates that the subject device Transorb™ Self-Gripping Resorbable Mesh is substantially equivalent to the predicate device, TIGR Matrix Surgical Mesh (K191749).
§ 878.3300 Surgical mesh.
(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.