(260 days)
Silk sutures are indicated for use as nonabsorbable sutures in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic, and neural tissue.
Silk Non-Absorbable Surgical Sutures are composed of the organic protein fibroin which is derived from the domesticated species Bombyx mori (B.mori) of the family Bombycidae. Silk sutures are braided or twisted and available in white or dyed (black or blue). Braided sutures (except for size 8/0) are coated with silicone. Silk sutures are also available in various lengths, diameters and quantities with or without surgical needles. SILK sutures are not absorbed, progressive degradation of the proteinaceous silk fiber in-vivo may result in gradual loss of all the suture's tensile strength over time. The proposed Silk suture needle will be manufactured using an automated end stiffening process of applying the medical grade adhesive to a portion of the silk strand which is then cured and cut to length.
The provided text describes a 510(k) submission for a Silk Non-Absorbable Surgical Suture with UV-10 adhesive, focusing on the substantial equivalence to a previously cleared device. The key change is an automated needle-end stiffening process compared to a manual one.
Here's an analysis of the acceptance criteria and study information, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance | Comments |
|---|---|---|
| Biocompatibility (tested per ANSI/AAMI 10993 and USP guidelines) | Passed all specified tests: Cytotoxicity, Hemolysis, Sensitization, Acute Systemic Toxicity, Irritation, Intracutaneous. | Indicates the material and design are safe for biological contact. |
| Material Composition (Organic protein fibroin derived from Bombyx mori) | Composed of organic protein fibroin from Bombyx mori. | Confirms the fundamental material is unchanged and consistent with predicate. |
| Sterility | Stated to be sterile sutures. | Implies the sterilization process meets standards. |
| Indications for Use (General soft tissue approximation and/or ligation, including cardiovascular, ophthalmic, and neural tissue) | Same indications for use as the predicate device. | Confirms the intended medical applications remain unchanged. |
| Physical Characteristics (Lengths, diameters, quantities, colors, availability with/without needles) | Available in the same various lengths, diameters, quantities, colors and sizes, with and without surgical needles. | Confirms physical attributes are consistent with predicate. |
| Packaging (Identical Tyvek/Mylar packaging) | Packaged in identical Tyvek/Mylar packaging. | Confirms packaging remains consistent. |
| Tensile Strength Loss (in-vivo degradation) | "Progressive degradation of the proteinaceous silk fiber in-vivo may result in gradual loss of all the suture's tensile strength over time." | This is a known characteristic of silk sutures and is consistent with the predicate. It's not an "acceptance criterion" in the sense of a target value, but rather a descriptive characteristic. The acceptance is likely that this behavior is comparable to the predicate. |
| Performance of automated needle end stiffening process (Implicit: should not negatively impact device performance compared to manual process) | Not explicitly detailed but implied by the "substantially equivalent" claim and the lack of specific performance testing beyond biocompatibility. | The biocompatibility testing likely serves as the primary evidence that the change in manufacturing process for the needle-end stiffening does not introduce new risks or alter fundamental material properties. There is no mention of comparative mechanical testing (e.g., knot strength, needle attachment strength) as an explicit acceptance criterion or reported performance. |
2. Sample size used for the test set and the data provenance
The document does not specify a "test set" in the context of a typical clinical study or a performance study with a defined sample size for the evaluation of the automated needle-end stiffening process. The primary evidence presented is biocompatibility testing.
- Sample size: Not explicitly stated for biocompatibility tests. It's usually a small number of samples required to demonstrate biological compatibility according to standards.
- Data provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). However, biocompatibility testing is typically conducted in a laboratory setting.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This device submission primarily relies on biocompatibility testing and demonstrating substantial equivalence to a predicate device. There is no "ground truth" derived from expert review of cases in the way that might apply to a diagnostic imaging AI algorithm. The "ground truth" for biocompatibility is established by adherence to recognized standards (ANSI/AAMI 10993 and USP guidelines) and passing the specified tests.
4. Adjudication method for the test set
Not applicable. There is no "test set" that requires adjudication (e.g., clinical cases reviewed by experts).
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is a surgical suture, not a diagnostic device with an AI component.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a surgical suture, not a diagnostic device with an AI component.
7. The type of ground truth used
For the safety assessment, the "ground truth" is based on:
- Biological standards: Adherence to ANSI/AAMI 10993 and USP guidelines for biocompatibility.
- Predicate device characteristics: The known safety and performance profile of the legally marketed predicate Silk Non-Absorbable Surgical Suture (K930590). The new device is considered "substantially equivalent" if it shares the same safety and effectiveness profile.
8. The sample size for the training set
Not applicable. This is a physical medical device (suture), not a machine learning model.
9. How the ground truth for the training set was established
Not applicable. This is a physical medical device (suture), not a machine learning model.
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4/30/99
510k Summary of Safety and Effectiveness
SILK NON-ABSORBABLE SURGICAL SUTURE (w/UV-10 adhesive)
Submitted by: Sherwood-Davis & Geck 444 McDonnell Blvd. Hazelwood, MO 63042-2516
Contact: Vanada Johnson Sr. Regulatory Affairs Specialist
Date of Summary: May 7, 1998
Silk Non-Absorbable Surgical Sutures are composed of the organic protein fibroin which is derived from the domesticated species Bombyx mori (B.mori) of the family Bombycidae. Silk Surgical Sutures were initially cleared, via the Premarket Notification process and assigned 510(k) file number K930586. Silk Non-Absorbable Surgical Sutures are a class II device, per 21 CFR Section 878.5030, with the Classification Code 80GAP.
Silk sutures are indicated for use as nonabsorbable sutures in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic, and neural tissue. Silk sutures are braided or twisted and available in white or dyed (black or blue). Braided sutures (except for size 8/0) are coated with silicone. Silk sutures are also available in various lengths, diameters and quantities with or without surgical needles. SILK sutures are not absorbed, progressive degradation of the proteinaceous silk fiber in-vivo may result in gradual loss of all the suture's tensile strength over time.
Similarities between the proposed Silk suture and the currently marketed Silk Non-Absorbable Surgical are 1) both are composed of the organic protein fibroin_ 2) both are sterile sutures, 3) both share the same indications for use, 4) both are available in the same various lengths, diameters, quantities, colors and sizes, 5) both are available with and without surgical needles and 6) both are packaged in identical Tyvek/Mylar packaging
The only difference between the proposed vs. the predicate Silk suture is an automated vs. a manual needle end stiffening process. The proposed Silk suture needle will be manufactured using an automated end stiffening process of applying the medical grade adhesive to a portion of the silk strand which is then cured and cut to length. The predicate Silk suture needle is currently manufactured using a manual end stiffening process of winding the suture material onto racks and dipping the end in a nylon resin bath, curing then cutting the suture to length.
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Summary of Safety and Effectiveness SILK NON-ABSORBABLE SURGICAL SUTURE
Silk Non-Absorbable Surgical Sutures, with adhesive, were tested for biocompatibility in Silk Non-Austradic Burgroal Battleon, Wall actor of Medical Devices Part-1 : Evaluation
accordance to ANSI/AAMI 10993. Biological Evaluation of Medical Devices Parts USD accordance to ARGBARNI 10995. Destery of tests were performed in accordance to USP guidelines - Cytotoxicity, Hemolysis, Sensitization, Acute Systemic Toxicity, Irritation, Intracutaneous.
Sherwood-Davis & Geck considers the proposed Silk Surgical Suture (w/adhesive) to be substantially equivalent in design, composition and intended use, to the currently marketed Silk Suture covered under K930590.
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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized depiction of an eagle or bird with three wing-like shapes, suggesting movement or flight. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR 3 0 1999
Ms. Vanada Johnson Scnior Regulatory Affairs Specialist Sherwood-Davis & Geck 444 McDonnell Boulevard Hazelwood, Missouri 63042
Re: K982853 Trade Name: Silk Suture Regulatory Class: II Product Code: GAP Dated. December 29, 1998 Received: February 12, 1999
Dear Ms. Johnson:
We have reviewed your Scction 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent for the incentions for use stated in the enclosure to devices that were regulated as transitional devices and that have been reclassified into class II. Notice of this reclassification was published in the Federal Register on Tuesday, October 26, 1993 (Vol. 58, No. 205, Pages 57557 and 57558). A copy of this Federal Register can be obtained by calling the Division of Small Manufacturers Assistance (DSMA) at (800) 638-2041 or (301) 443-6597. You may, therefore, market the device, subject to the general controls provisions of the Federal Food, Drug, and Cosmetic Act (Act) and the following limitations:
-
- The Silk Suture is indicated for use in gencral soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological fronedures.
-
- This device may not be manufactured from any material other than multifilamentous fibers composed of fibroin, an organic protein that is derived from the domesticated species Bombyx mori (B. mori) of the family Bombycidae. In addition, you must maintain documentation at your premises regarding vendor certification for raw or semiprocessed source material, all manufacturing and quality control release procedures, and validation of sterilization procedures used in the manifacture of the Silk Suture. Any deviation of the source material or processing as described in this 510(k) notification requires submission of a new premarket notification and Food and Drug Administration (FDA) clearance prior to commercial distribution of the modified device.
The sale, distribution and use of this device are restricted to prescription use in accordance with 21 CFR 801.109.
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Page 2 – Ms. Vanada Johnson
The general controls provisions of the Act include requirements for annual registration, The general controls provisions of the Act merade reques and prohibition against
listing of devices, good manufacturing practices, labeling, and prohibition against misbranding and adultcration.
Existing major regulations affecting your device can be found in the Code of Federal Existing major regulations arrecting your areas. A substantially equivalent determination Regulations (CFR), Title 21, Paris 800 to 872. Presctices (GMP) for Medical Dovices:
assumes compliance with the Good Manufacturing Practices (GMP inspections assumes compliance with the CFR Part 820) and that, through periodic GMP inspections,
General GMP regulation (21 CFR Part 820) and that, through periodic GMP regulations Fa General GMP regulation (21 CFR Fall 820) and may motions. Failure to comply
The Food and Drug Administration (FDA) will verify such assumptions. Frances The Food and Drug Administration (I'DA) wint venty on. In addition, FDA may publish
with the GMP regulation may result in regulatory action. In addition, Flease note: this with the GMP regulation may result in regulatory and Register. Please note: this further announcements concerning your device in taffect any obligation you might
response to your premarket notification submission does and a Flectronic Product response to your premarket notheation stimmission devices under the Electronic Product Radiation Control Provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your $10(k)
to be This letter will allow you to begin maticemig your device of your device and thus, ne premarket notification. The FDA miding of substablial of your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 If you desire Specific advice for your agains devices), please contact the Office of and additionally 607.10 for in this attistions on the promotion and Compliance at (301) 594-4323. Auditional (1871) of Compliance at (30) 594-4595.
advertising of your device, please contact the Office of Compliance at advertising of your deview, production catiled, "Misbranding by reference to premarket Also, please hote the regulation entitions, Trinitial on your responsibilities under the hottication (21 CFTN 807.77). Other golfSmall Manufacturers Assistance at its toll-free number (800) 638-2041 or 301-443-6597, or at its internet address http://www.fda.gov/cdrh/dsmamain.html.
Sincerely yours,
Celia M. Witten, Ph.D., M.D. Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Page 1 of 1
510(k) Number (if known)
Device Name: Sherwood-Davis & Geck Silk Nonabsorbable Surgical Suture
Indications for Use:
Silk sutures are indicated for use as nonabsorbable sutures in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic, and neural tissue.
(PLEASE DO NO WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE! IF NEEDED)
Concurrenc of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-the-Counter Use _
(Division Sign-off)
Division Sign-Off)
(Division Division of General Restorative D 510(k) Number
510(k) Number -
Sherwood-Davis & Geck Silk Nonabsorbable Surgical Suture
§ 878.5030 Natural nonabsorbable silk surgical suture.
(a)
Identification. Natural nonabsorbable silk surgical suture is a nonabsorbable, sterile, flexible multifilament thread composed of an organic protein called fibroin. This protein is derived from the domesticated speciesBombyx mori (B. mori ) of the familyBombycidae. Natural nonabsorbable silk surgical suture is indicated for use in soft tissue approximation. Natural nonabsorbable silk surgical suture meets the United States Pharmacopeia (U.S.P.) monograph requirements for Nonabsorbable Surgical Suture (class I). Natural nonabsorbable silk surgical suture may be braided or twisted; it may be provided uncoated or coated; and it may be undyed or dyed with an FDA listed color additive.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.