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510(k) Data Aggregation

    K Number
    K230094
    Date Cleared
    2023-08-25

    (225 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Responsive Arthroscopy Stealth and Mini Stealth All-Suture Anchors

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Responsive Arthroscopy Stealth and Mini Stealth All-Suture Anchors are intended to be used for fixation of soft tissue to bone in the shoulder, foot/ankle, knee, hand/wrist, elbow, and hip in the following procedures:

    Shoulder: Rotator Cuff Repair, Bankart Repair, SLAP Lesion Repair, Biceps Tenodesis, Acromio-Clavicular Separation Repair, Deltoid Repair, Capsular Shift or Repair.

    Foot/Ankle: Lateral Stabilization, Medial Stabilization, Achilles Tendon Repair, Hallux Valgus Reconstruction, Mid-foot Reconstruction, Metatarsal Ligament Repair, Digital Tendon Transfers.

    Knee: Medial Collateral Ligament Repair, Lateral Ligament Repair, Patellar Tendon Repair, Posterior Oblique Ligament Repair, Iliotibial Band Tenodesis.

    Hand/Wrist: Scapholunate Ligament Reconstruction of Collateral Ligaments, Carpal Ligament Reconstruction, Repair of Flexor and Extensor Tendons at the PIP, DIP, and MCP Joints for all Digits, Digital Tendon Repairs.

    Elbow: Biceps Tendon Reattachment, Ulnar or Radial Collateral Ligament Reconstruction.

    Hip: Capsular Repair, Acetabular Labral Repair, Gluteal Tendon Repair.

    Device Description

    The Stealth and Mini Stealth All-Suture Anchors intended for the fixation of soft tissue to bone. The All-Suture Anchors feature a push-in design and are comprised entirely of suture material configured to provide an anchor in bone. The anchors create a secure fixation point for the reattachment of soft tissue to bone when they are inserted through a pilot hole and deployed against the inserter tip below cortical bone in the desired anatomy. The All-Suture Anchors feature four longitudinally arranged round bundles that bunch together and expand radially when deployed to achieve fixation. The All-Suture Anchors may be delivered arthroscopically using inserters and surgical instruments such as drills, guide tubes, and probes.

    The subject device systems include two anchor sizes, the Stealth All-Suture Anchor which is designed for a 3.0mm diameter pilot hole and the Mini Stealth All-Suture Anchor which is designed for a 2.1mm diameter pilot hole. Both anchor systems are comprised of braided nonabsorbable ultra-high molecular weight polyethylene (UHMWPE) material and are available in a variety of configurations containing one or more working USP #2 sutures or 1.5mm suture tapes to facilitate a repair.

    The Stealth and Mini Stealth All-Suture Anchors are pre-loaded on disposable inserters and provided sterile via ethylene oxide (EO), while the reusable instruments are non-sterile and are intended to be sterilized by the end user.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Responsive Arthroscopy Stealth and Mini Stealth All-Suture Anchors, which are intended for the fixation of soft tissue to bone.

    Here's the breakdown of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    Test TypeAcceptance CriteriaReported Device Performance
    Insertion Force TestingNot explicitly stated, but implied to meet design specifications and intended performance (likely related to ease/safety of insertion)."All testing met acceptance criteria and demonstrated that the devices met design specifications and performed as intended." The subject devices' insertion method is similar to the predicate devices, with slight differences in implant deployment method which are deemed equivalent and have no impact on intended use.
    Cyclic Pullout Force TestingNot explicitly stated, but implied to demonstrate sufficient fixation strength and durability compared to predicate devices."All testing met acceptance criteria and demonstrated that the devices met design specifications and performed as intended." The study included "side-by-side comparative testing with the predicate devices," suggesting the pullout forces were comparable or superior.
    Shelf-life Testing (ASTM F1980)Not explicitly stated, but implied to demonstrate the device maintains its properties and sterility over the specified shelf life."All testing met acceptance criteria and demonstrated that the devices met design specifications and performed as intended." The shelf-life validation was successfully completed.
    Extractable Residue Testing (ASTM F2459)Not explicitly stated, but implied to demonstrate that extractable residues from the device are below specified safety limits."All testing met acceptance criteria and demonstrated that the devices met design specifications and performed as intended." The extractable residue testing was successfully completed.
    MEM Elution Testing (ISO 10993-5)Not explicitly stated, but implied to demonstrate the device is non-cytotoxic."All testing met acceptance criteria and demonstrated that the devices met design specifications and performed as intended." The cytotoxicity testing was successfully completed.

    2. Sample size used for the test set and the data provenance

    The document does not specify the exact sample sizes used for each performance test (e.g., number of anchors tested for insertion force or cyclic pullout). It also does not mention the country of origin of the data or whether the studies were retrospective or prospective. The testing was non-clinical, meaning it was likely conducted in a lab setting rather than involving human or animal subjects in a clinical trial.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not applicable. The studies described are non-clinical performance and design verification tests, not studies requiring expert interpretation of diagnostic data to establish ground truth.

    4. Adjudication method for the test set

    This information is not applicable, as the tests are non-clinical performance evaluations with predefined pass/fail criteria rather than requiring expert adjudication of results.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The studies were non-clinical performance tests comparing the subject devices to predicate devices.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done

    This concept is not applicable as the device is a medical implant (suture anchor), not an AI algorithm. The performance tests were conducted on the physical device itself.

    7. The type of ground truth used

    The "ground truth" for the non-clinical performance tests was established by predefined engineering specifications, design requirements, and established standards (e.g., ASTM, ISO guidelines), as well as comparative performance to legally marketed predicate devices. For instance, for pullout strength, the ground truth would be a defined force threshold or equivalency to predicate device performance.

    8. The sample size for the training set

    This information is not applicable. This is a medical device approval based on non-clinical performance testing and substantial equivalence to predicate devices, not an AI model requiring a training set.

    9. How the ground truth for the training set was established

    This information is not applicable for the same reason as above.

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