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    Why did this record match?
    510k Summary Text (Full-text Search) :

    Calypso); PGLA90 Poly(glycolide-co-L-lactide) Surgical Sutures (Odysseus)
    Regulation Number: 21 CFR 878.4493
    Surgical Sutures
    Review Panel: General & Plastic Surgery Devices Panel
    Regulation Number: 878.4493
    Calypso) | ATRAMAT®PGLA90 (Odysseus) | Atramat®PGLA90 | | |
    | Product Code / Regulation | GAM/ 21 CFR 878.4493
    | GAM/ 21 CFR 878.4493 | GAM/ 21 CFR 878.4493 | Same |
    | Intended Use | Absorbable surgical sutures

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

    Atramat® PGLA90 Poly(glycolide-co-L-lactide) Surgical Sutures are indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular and neurological tissues.

    Device Description

    The subject devices, ATRAMAT® PGLA90 (Calypso/Odysseus), are modifications to the previously cleared Atramat® PGLA90 Poly(glycolide-co-L-lactide) Surgical Suture (K072859). The predicate device is a synthetic, absorbable, sterile surgical suture composed of a copolymer of glycolide and L-lactide, which is indicated for soft tissue approximation.

    ATRAMAT® PGLA90 (Calypso/Odysseus) devices integrate the predicate suture into a metal part with a pre-tied knot mechanism. This modification changes the operating method from traditional hand-tying to a pre-tied knot closure.

    AI/ML Overview

    N/A

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    K Number
    K233265
    Manufacturer
    Date Cleared
    2024-10-11

    (378 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Boulogne-Billancourt, Hauts-De-Seine 92100 France

    Re: K233265

    Trade/Device Name: Optime® R Regulation Number: 21 CFR 878.4493
    withfast resorption | AbsorbablePoly(glycolide/l-lactide) SurgicalSuture (21 CFR878.4493
    |
    | Regulation | 21 CFR 878.4493
    | 21 CFR 878.4493

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

    OPTIME® R sutures are intended for use in general soft tissue approximation including ophthalmic procedures, but not in cardiovascular or neurological procedures.

    Device Description

    OPTIME®R sutures are intended to be used in suturing in open or laparoscopic surgery. These sutures are available with a disposable needle attachment. OPTIME®R is a sterile, multiple-stranded (multifilament), synthetic bioabsorbable thread made from a polymerization of polyglycolic acid (PGA) used in suturing when short-term support and rapid strength loss are needed. To perform suturing on soft tissue wounds involves a series of precise steps. The surgeon grasps the needle, pushes it through tissue, pulls it through and repeats for continuous suturing. Further, knots are tied, excess thread is cut, and used needles are single use and safely disposed in accordance with hospital procedure.

    AI/ML Overview

    The provided text is an FDA 510(k) Pre-Market Notification for a medical device called OPTIME® R, which is an absorbable surgical suture. The document primarily focuses on establishing substantial equivalence to a predicate device (Safil Quick Aesculap, K031286) based on technological characteristics and performance testing.

    Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:

    1. A table of acceptance criteria and the reported device performance:

    The document states that the OPTIME® R suture was subjected to the requirements of the United States Pharmacopeia (U.S.P) monograph for Synthetic Absorbable Sutures. The following tests and their corresponding USP standards are mentioned:

    Acceptance Criteria / TestReported Device Performance
    Diameter (following USP 43 <861>)Meets USP performance requirements for absorbable sutures
    Tensile strength (following USP 43 <881>)Meets USP performance requirements for absorbable sutures
    Needle attachment (following USP 43 <871>)Meets USP performance requirements for absorbable sutures
    Length (following USP 43 - Absorbable surgical suture)Meets USP performance requirements for absorbable sutures
    Resorption propertiesEssentially complete at 42 days (matches predicate's absorption time)
    Biocompatibility (following ISO 10993)Biocompatibility tests performed and results indicate compliance
    Sterilization methodsGamma sterilization (matches predicate)
    Shelf-life5 years
    Ideal storageStored in original packaging, <25°C, dry, protected from light
    Packaging36 units/carton, individual units in tearable aluminum pouch, then secondary pouch

    Specific details about the exact numerical acceptance criteria (e.g., minimum tensile strength in Newtons, acceptable diameter range in mm) are not explicitly provided in this document beyond stating compliance with USP standards. The document broadly indicates that the device "meets USP performance requirements."

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

    • The document does not specify the sample sizes used for the Diameter, Tensile Strength, Needle Attachment, Length, or Resorption testing.
    • The data provenance is from Peters Surgical, a French company (Immeuble Aurélium, 1 course de l'Ile Seguin, Boulogne-Billancourt, Hauts-De-Seine 92100 France). The studies appear to be prospective testing conducted by the manufacturer to demonstrate compliance. There is no mention of country of origin of the data beyond the manufacturer's location.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience):

    • This information is not applicable in this context. The "ground truth" for a medical device like a surgical suture is established by objective engineering and biological performance standards (USP, ISO) rather than expert consensus on interpretation. There are no images or subjective assessments involved that would require expert adjudication or establishing ground truth in the way it's typically described for AI/diagnostic devices.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • This is not applicable. As mentioned above, the tests are objective measurements against predefined standards. There is no subjective assessment requiring adjudication.

    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:

    • This is not applicable. OPTIME® R is an absorbable surgical suture, a physical medical device, not an AI or diagnostic software. Therefore, MRMC studies are not relevant.

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

    • This is not applicable. OPTIME® R is a physical surgical suture, not an algorithm or AI product.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The "ground truth" for this device's performance is based on established national and international standards for absorbable sutures. Specifically:
      • United States Pharmacopeia (USP) monographs for physical and mechanical properties (Diameter, Tensile Strength, Needle Attachment, Length).
      • ISO 10993 series for biocompatibility (Cytotoxicity, Sensitization, Irritation, Material mediated pyrogenicity, Acute Systemic Toxicity, Sub-acute/sub-chronic Toxicity, Genotoxicity, Chemical characterization and toxicological risk assessment, Implantation, Degradation).
      • Resorption time is a characteristic feature verified against the predicate and established through testing.

    8. The sample size for the training set:

    • This is not applicable. There is no "training set" as this is a physical device, not a machine learning model.

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

    • This is not applicable for the same reason as point 8.
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    K Number
    K232372
    Manufacturer
    Date Cleared
    2024-07-12

    (339 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Trade/Device Name: Peters Surgical ADVANTIME Absorbable Suture (ADVANTIME) Regulation Number: 21 CFR 878.4493
    ADVANTIME Absorbable Suture (ADVANTIME) Panel: General and Plastic Surgery Regulatory Number: 21 CFR 878.4493
    neurological tissue. |
    | Regulation Number | 21 CFR 878.4493
    | 21 CFR 878.4493

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

    ADVANTIME® synthetic absorbable surgical sutures are intended for use in general soft tissue approximation and/or ligation, but not for use cardiovascular surgery, microsurgery, ophthalmic surgery, and neurological tissue.

    Device Description

    ADVANTIME® sutures are intended to be used in suturing and/or tissue ligation in open or laparoscopic surgery. These sutures are available with a disposable needle attachment.

    ADVANTIME® is a single use, sterile, single-stranded (monofilament), synthetic bioabsorbable thread made of a poliglecaprone (a copolymer of glycolide and E- caprolactone of low tissue reactivity). Sutures are commonly used in digestive, urological, aesthetic, gynecological and intradermal surgery. To perform suturing on soft tissue wounds involves a series of precise steps. The surgeon grasps the needle, pushes it through tissue, pulls it through and repeats for continuous suturing. The same applies to double-armed needles. Further, knots are tied, excess thread is cut, and used needles are single use and safely disposed in accordance with hospital procedure.

    AI/ML Overview

    The provided document is a 510(k) summary for a surgical suture device (ADVANTIME Absorbable Suture) and does not describe an AI/ML powered device. Therefore, the questions regarding acceptance criteria, study details, and performance measures (such as sample size for test/training sets, expert ground truth, adjudication methods, MRMC studies, or standalone performance of an algorithm) related to AI/ML devices are not applicable.

    The document discusses the substantial equivalence of the ADVANTIME Absorbable Suture to a predicate device based on physical and biological performance testing for a medical device that is not an AI/ML device.

    Here's the information that is relevant from the provided text regarding this medical device:

    1. Acceptance Criteria and Reported Device Performance (Non-AI/ML Device)

    The device was subjected to the requirements of the United States Pharmacopeia (U.S.P.) monograph for Synthetic Absorbable Sutures.

    Acceptance Criteria (USP 43)Reported Device Performance
    Diameter (<861>)Meets USP requirements with minor variations (within FDA guidance allowance)
    Tensile strength (<881>)Meets USP requirements
    Needle attachment (<871>)Meets USP requirements
    Length (Absorbable surgical suture)Meets USP requirements
    Extractable color (Absorbable surgical suture)Meets USP requirements
    Resorption profilesEvaluated for each material; data provided in-vitro
    StabilityTesting completed
    Biocompatibility (ISO 10993-1)All tested aspects met (Cytotoxicity, Sensitization, Irritation, Material mediated pyrogenicity, Acute Systemic Toxicity, Sub-acute/sub-chronic/chronic toxicity, Genotoxicity, Carcinogenicity, Chemical characterization and toxicological risk assessment, Implantation, Degradation, Sterilization residue testing)

    2. Sample size used for the test set and the data provenance: Not applicable as this is not an AI/ML device study. Performance was evaluated based on physical and biological tests according to USP standards and ISO 10993-1.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable as this is not an AI/ML device. Ground truth for physical properties is defined by USP standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable as this is not an AI/ML device. Performance is objectively measured against USP standards.

    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 as this is not an AI/ML device.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable as this is not an AI/ML device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For the physical characteristics, the ground truth is defined by the United States Pharmacopeia (USP) standards and test methodologies. For biological evaluation, the ground truth is established by standardized testing protocols detailed in ISO 10993-1.

    8. The sample size for the training set: Not applicable as this is not an AI/ML device.

    9. How the ground truth for the training set was established: Not applicable as this is not an AI/ML device.

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    Why did this record match?
    510k Summary Text (Full-text Search) :

    | GAM |
    | Regulation Number | 21 CFR 878.4493
    | Regulation | 21 CFR 878.4493
    | 21 CFR 878.4493
    | 21 CFR 878.4493

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    1. PINION™ PDO Knotless Sutures are indicated for use in general soft tissue approximation where use of an absorbable suture is appropriate.

    2. PINION™ PGA-PCL Knotless Sutures are indicated for use in general soft tissue approximation where use of an absorbable suture is appropriate.

    Device Description

    The PINION™ PDO Knotless Suture consists of barbed suture material armed with a surgical needle on each end. Barbs allow for tissue approximation without the need to tie surgical knots. PINION™ PDO Knotless Suture is a sterile, synthetic, absorbable monofilament suture comprised of Poly (p- Polydioxanone). The empirical molecular formula of which is (G.HგO3)x. PINION™ PDO Knotless Sutures are available in undyed or dyed with D & C violet No.2 (21 CFR 74. 3602) at a level not exceeding 0.3 % by weight of the suture in sizes USP (EP) 3-0 (2), 2-0 (3) & 0 (3.5). It is supplied with the attached stainless steel surgical needles. Polydioxanone has been found to be nonantigenic, nonpyrogenic and to elicit only a slight tissue reaction during absorption. The PINION™ PDO Knotless Suture is designed with small unidirectional and bidirectional barbs along the length of the device. It consists of an absorbable thread with unidirectional anchors, equipped with a surgical needle at one end and a fixation tab at the other while the bidirectional anchors equipped with a surgical needle at both end. The anchors and fixation tab design allows for tissue approximation without the need to tie surgical knots.

    The PINION™ PGA-PCL Knotless Suture consists of barbed suture material armed with a surgical needle on each end. Barbs allow for tissue approximation without the need to tie surgical knots. PINION™ PGA-PCL Knotless Suture is a sterile, synthetic, absorbable monofilament suture comprised of poly (glycolide-co-caprolactone). PINION™ PGA-PCL Knotless Suture is provided undyed or dyed with D & C violet No.2 (21 CFR 74. 3602) at a level not exceeding 0.25 % by weight of the suture in sizes USP (EP) 4-0 (1.5), 3-0 (2) & 2-0 (3). It is supplied with the attached stainless steel surgical needles. The polymer has been found to be nonantigenic, nonpyrogenic and eliciting only a slight tissue reaction during absorption. The PINION™ PGA-PCL Knotless Suture is designed with small unidirectional and bidirectional barbs along the length of the device. It consists of an absorbable thread with unidirectional anchors, equipped with a surgical needle at one end and a fixation tab at the other while the bidirectional anchors equipped with a surgical needle at both end. The anchors and fixation tab design allows for tissue approximation without the need to tie surgical knots.

    AI/ML Overview

    The provided text describes the acceptance criteria and the studies performed for two medical devices: PINION™ PDO Knotless Suture and PINION™ PGA-PCL Knotless Suture.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The main acceptance criteria are based on comparison to predicate devices and adherence to USP (United States Pharmacopoeia) and ISO standards. The "Reported Device Performance" column reflects whether the subject device meets these criteria. Since the document states "No change," "Identical," or indicates the subject device provides "more safety" than the predicate device, it implies successful meeting of the criteria.

    PINION™ PDO Knotless Suture

    Acceptance CriteriaReported Device Performance (Subject Device)
    General Characteristics
    Device Name / Manufacturer / 510(K) NumberPINION™ PDO Knotless Suture / Meril EndoSurgery Pvt. Ltd. / K232246 (Identical for these categories when comparing subject to predicate, but these are identifying info specific to the subject device, not performance)
    Common NameAbsorbable Polydioxanone surgical suture (No change from predicate)
    Class / Product Code / Regulation NumberII / NEW / CFR 878.4840 (No change from predicate)
    Intended useIndicated for use in general soft tissue approximation where use of an absorbable suture is appropriate. (Identical to predicate)
    For single use onlySingle use only (No change from predicate)
    Mode of Actions (Tensile strength retention & absorption)Approximately 70-80% of original strength remains after two and four weeks. 40-50% retained at six weeks. Minimal absorption until ~120 days, complete within 180 days (six months). (Identical to predicate's performance)
    Material compositionpoly (p-dioxanone) (No change from predicate)
    Body ContactTissue/Bone/Blood (No change from predicate)
    Shelf Life5 Year (No change from predicate)
    Size availability3-0 to 0 (Covered by the predicate suture range)
    Absorbable/Non AbsorbableAbsorbable (No change from predicate)
    Braided/MonofilamentMonofilament (No change from predicate)
    Dyed / UndyedUndyed or Dyed Suture Strands (No change from predicate)
    ColorantD&C Violet No. 2 (No change from predicate)
    Coated / UncoatedUncoated (No change from predicate)
    Types of BarbsUni-directional, Bi-directional (No change from predicate)
    No. of barbs per linear length of Suture13-17 barbs per cm (More than predicate's 10 barbs per cm, providing "more safety")
    Barb Angle (3-0, 2-0, 0)3-0: 23 -28 (∠°) Different from predicate (40-50, 35-45, 35-45 respectively), but "do not raise new questions of safety and effectiveness as the average barb holding strength for the subject is equivalent to that of the predicate device."
    2-0: 23 -28 (∠°)
    0: 23 -28 (∠°)
    Barb Height (3-0, 2-0, 0)3-0: 0.250-0.350 mm Different from predicate (0.400-0.550, 0.400-0.550, 0.400-0.550 respectively), but "do not raise new questions of safety and effectiveness as the average barb holding strength for the subject is equivalent to that of the predicate device."
    2-0: 0.300-0.400 mm
    0: 0.350-0.450 mm
    Barb ShapeCog Shape (No change from predicate)
    Barb Direction (Bidirectional)A section and B section in opposite direction. (No change from predicate)
    Barb Direction (Unidirectional)A section and B section in same direction. (No change from predicate)
    Complete Absorptionwithin 180 to 210 days (No change from predicate)
    Sterilization methodEthylene Oxide (No change from predicate)
    Needle MaterialStainless Steel (No change from predicate)
    PackagingPrimary and Secondary packaging described are identical to predicate. (Identical)
    Label ClaimComplies with USP for "Synthetic Absorbable Surgical Suture" (except for diameter) (No change from predicate)
    Diameter USP <861>Meets performance requirementsdefined in USP <861>, except for diameter for some oversize suture. (Identical to predicate)
    Tensile strength USP <881>Meets performance requirementsdefined in USP <881>. (No change from predicate)
    Needle attachment USP <871>Meets performance requirementsdefined in USP <871>. (No change from predicate)
    Labeling and Instructions for use (IFU).Conforming to 21CFR 801.109 and USP, includes indications, warnings, adverse reactions, contraindication and precautions. (No change from predicate)
    BiocompatibilityComply with ISO 10993-1 (No change from predicate)

    PINION™ PGA-PCL Knotless Suture

    Acceptance CriteriaReported Device Performance (Subject Device)
    General Characteristics
    Device Name / Manufacturer / 510(K) NumberPINION™ PGA PCL Knotless Suture / Meril EndoSurgery Pvt. Ltd. / K232246 (Identical for these categories when comparing subject to predicate, but these are identifying info specific to the subject device, not performance)
    Common NameAbsorbable poly(glycolide/l-lactide) surgical suture (No change from predicate)
    Class / Product Code / Regulation NumberII / GAM / 21 CFR 878.4493 (No change from predicate)
    Intended useIndicated for use in soft tissue approximation where the use of absorbable suture is appropriate. (Identical to predicate)
    For single use onlySingle use only (No change / Identical)
    Mode of Actions (Tensile strength retention & absorption)Retains approximately 62% of original strength 7 days post implantation. Loses all original tensile strength by 28 days. Absorption essentially completed between 90 and 120 days. (Comparable to predicate performance of 62% at 7 days, 27% at 14 days, and complete absorption by 91 days)
    Material compositionCopolymer of (glycolide and ε caprolactone)(PGA-PCL) (No change from predicate)
    Body ContactTissue/Bone/Blood (No change from predicate)
    Shelf Life5 Year (No change from predicate)
    Size availability4-0 to 2-0 (No change from predicate)
    Absorbable/Non AbsorbableAbsorbable (No change from predicate)
    Braided/MonofilamentMonofilament (No change from predicate)
    Dyed / UndyedUndyed or Dyed Suture Strands (No change from predicate)
    Colorant (if Dyed)D&C Violet No. 2 (No change from predicate)
    Coated / UncoatedUncoated (No change from predicate)
    Types of BarbsUni-directional, Bi-directional (Both types covered by predicate device)
    No. of barbs per linear length of Suture17-22 barbs per cm (More than predicate's 10 barbs per cm, providing "more safety")
    Barb Angle (4-0, 3-0, 2-0)4-0: Not specified, but generally 23-38 (∠°) Different from predicate (whose angles are 23-38 (∠°), but "do not raise new questions of safety and effectiveness as the average barb holding strength for the subject is equivalent to that of the predicate device."
    3-0: Not specified, but generally 23-38 (∠°)
    2-0: Not specified, but generally 23-38 (∠°)
    Barb Height (4-0, 3-0, 2-0)4-0: 0.253-0.283 mm Different from predicate (0.350-0.550 mm), but "do not raise new questions of safety and effectiveness as the average barb holding strength for the subject is equivalent to that of the predicate device."
    3-0: 0.250-0.350 mm
    2-0: 0.300-0.400 mm
    Barb ShapeCog Shape (No change from predicate)
    Barb Direction (Bidirectional)A section and B section in opposite direction. (No change from predicate)
    Barb Direction (Unidirectional)A section and B section in same direction. (No change from predicate)
    Absorption Profilebetween 90 and 120 days (Identical / Comparable to predicate's "essentially complete by 91 days")
    Sterilization methodEthylene Oxide (Identical to predicate)
    Needle MaterialStainless Steel (Identical to predicate)
    Packaging ConfigurationPrimary and Secondary packaging described are identical to predicate. (Identical)
    Label ClaimComplies with USP for "Synthetic Absorbable Surgical Suture" (except for diameter) (Identical to predicate)
    Diameter USP <861>Meets performance requirementsdefined in USP <861>, except for diameter for some oversize suture. (Identical to predicate)
    Tensile strength USP <881>Meets performance requirementsdefined in USP <881>. (Identical to predicate)
    Needle attachment USP <871>Meets performance requirementsdefined in USP <871>. (Identical to predicate)
    Labeling and Instructions for use (IFU).Conforming to 21CFR 801.109 and USP, includes indications, warnings, adverse reactions, contraindication and precautions. (Identical to predicate)
    BiocompatibilityComply with ISO 10993-1 (Identical to predicate)

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document details performance testing for both sutures, including:

    • Diameter USP <861>
    • Tensile strength USP <881>
    • Needle attachment USP <871>
    • Suture Length
    • Number of barbs per linear length of suture
    • Barb size (length)
    • Barb size Direction
    • Barb Angle
    • Barb holding strength
    • Sterility USP <71>
    • Biocompatibility as per ISO 10993-1

    However, the specific sample sizes used for each of these performance tests are not explicitly stated in the provided document.

    The document mentions "implantation studies in animals" for the predicate devices to establish in-vivo tensile strength retention and absorption profiles. For the subject devices, it explicitly mentions "The results of in vitro study using PINION™ PDO Knotless Suture" and "PINION™ PGA-PCL Knotless Suture retains approximately 62 % of its original strength 7 days post implantation," implying similar in-vitro or animal studies were conducted for the subject devices to demonstrate equivalent performance.

    The data provenance is related to the manufacturing country, which is India (M/s. Meril Endo Surgery Private Limited, Gujarat, India). The studies would therefore likely align with standard regulatory practices and be conducted to meet FDA requirements for prospective testing to demonstrate device performance and safety. The document does not specify if any retrospective data was used for direct performance comparison of the subject device, beyond referencing predicate device characteristics.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    This section is not applicable to this type of medical device submission. The devices are surgical sutures, and their performance is evaluated through measurable physical and biological properties against established standards (USP, ISO) and comparison to predicate devices, not through expert-reviewed interpretations of images or clinical outcomes that require "ground truth" established by human experts in the same way an AI diagnostic device would.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This section is not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or studies involving human readers and AI for diagnostic or screening tasks to establish a consensus "ground truth." For surgical sutures, the assessments are based on objective physical measurements and biological tests, not subjective interpretations requiring adjudication.

    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

    This section is not applicable. MRMC studies are relevant for diagnostic or screening devices, particularly those involving AI assistance for human readers. These sutures are physical medical devices, not diagnostic software.

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

    This section is not applicable. This question pertains to AI/software device performance, which is not relevant to surgical sutures.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    For these surgical sutures, the "ground truth" or reference standards are:

    • United States Pharmacopoeia (USP) standards for properties like diameter, tensile strength, and needle attachment.
    • ISO 10993-1 standards for biocompatibility.
    • Established performance profiles of the legally marketed predicate devices (e.g., STRATAFIX™ Symmetric PDS™ Plus Knotless Tissue Control Device and STRATAFIX™ Spiral MONOCRYL™ Knotless Tissue Control Device) for characteristics like tensile strength retention and absorption rates.

    These are objective, quantitative and scientifically established benchmarks or comparisons.

    8. The sample size for the training set

    This section is not applicable. "Training set" refers to data used to train machine learning models. Surgical sutures are physical devices, not AI/ML systems, and therefore do not have training sets.

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

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

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    K Number
    K221527
    Device Name
    StitchKit
    Date Cleared
    2023-02-14

    (264 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Madison, New Jersey 07940

    Re: K221527

    Trade/Device Name: StitchKit Regulation Number: 21 CFR 878.4493
    |
    | Regulation Number: | 21 CFR 878.4493

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

    StitchKit® Suture Delivery Canister facilitates minimally invasive robotic surgery by transporting suture to the operative field and removing used needles after suturing. The suture contained within the device is intended for soft tissue approximation where use of the specific absorbable or non-absorbable sutures contained within it is appropriate.

    Device Description

    StitchKit® is a sterile, single-use plastic canister that is provided pre-loaded with suturing materials with attached needles. The device facilitates endoscopic robotic surgery by introducing multiple strands of suture to the surgical site at one time and allowing for the safe retrieval of the needles. The canister is sized to be passed through a ≥12 mm trocar or passed through an incision sized for an 8 mm trocar under direct endoscopic visualization. As suturing is completed with each strand, the used needle is placed into a compartment within the canister for safekeeping until the entire canister is removed either through the ≥ 12 mm trocar or through the 8mm trocar incision in tandem with the 8mm trocar, also under direct endoscopic visualization using the attached retrieval string. It is supplied sterile.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called StitchKit®. This document primarily focuses on demonstrating substantial equivalence to a predicate device, specifically for a minor modification related to the device's insertion and removal method (allowing use through an 8mm trocar incision in addition to a 12mm trocar).

    Crucially, this document does NOT describe the acceptance criteria or a study proving the device meets performance criteria for a complex AI/ML medical device. The device in question is a suture delivery canister, a physical surgical tool, not an AI or imaging device. Therefore, many of the requested points related to AI/ML device validation (like expert adjudication, MRMC studies, ground truth for training/test sets, effect size of human reader improvement with AI assistance, and standalone AI performance) are not applicable to this submission.

    The "clinical data" mentioned (retrospective case review n=422) is cited in the context of supporting the modification to the instructions for use, not for establishing the core performance of an AI algorithm. The performance data section refers to "functional performance test consisting of simulated surgical testing in an animal model" to demonstrate compatibility with the new insertion/removal technique, which is a physical device test, not an AI/ML study.

    Therefore, I cannot fulfill most of your request for an AI/ML device, as the provided document pertains to a physical surgical device and its minor instruction for use modification.

    However, I can extract the safety and efficacy information relevant to this device (the StitchKit® suture delivery canister) as presented in the document, acknowledging that it doesn't align with the detailed AI/ML validation questions.


    Based on the provided document for the StitchKit® Suture Delivery Canister (a non-AI device):

    1. A table of acceptance criteria and the reported device performance

    The document does not specify formal, quantitative acceptance criteria for device performance in the typical sense of accuracy, sensitivity, or specificity, as it's a physical tool. Instead, the "performance" demonstrated relates to its functional compatibility with a new surgical technique.

    Acceptance Criteria (Implied)Reported Device Performance
    Compatibility with 8 mm trocar site incision insertion/removalDemonstrated through "functional performance test consisting of simulated surgical testing in an animal model." No specific numerical performance metric provided beyond "compatible."
    Maintenance of Substantial Equivalence to PredicateConcluded based on: unchanged Indication for Use and Technological Characteristics, functional test data, clinical data (retrospective case review), and comparison to predicate device including risk analysis.
    Functionality in transporting suture and removing used needles(Presumed to be maintained from the predicate device and inherent to the device's design, as no change to core functionality is described.)

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

    • Test Set (for the modification validity):
      • Sample Size: n=422 (Cited as a "retrospective case review clinical study").
      • Data Provenance: Conducted by "an academic medical center." The country of origin is not specified but is implicitly in the US due to FDA submission. The study was retrospective.
    • Functional Performance Test: Conducted in an "animal model." Sample size for this specific test is not provided.

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

    • Not Applicable. This is a physical device, not an AI/ML diagnostic or image analysis device where "ground truth" would be established by experts interpreting medical data. The "ground truth" for the retrospective case review would likely be the surgical outcomes or successful use reported in the patient records.

    4. Adjudication method for the test set

    • Not Applicable. As above, no expert adjudication process is described or relevant for this type of device and study.

    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. No MRMC study was done, as this is not an AI-assisted diagnostic device.

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

    • Not Applicable. No standalone algorithm performance was evaluated, as this is not an algorithm-based device.

    7. The type of ground truth used

    • For the retrospective case review (n=422), the "ground truth" would be derived from clinical records and surgical outcomes related to the use of the device in actual patient cases, rather than expert interpretation of images or pathology. The document doesn't explicitly state how "success" or "performance" was quantified from these cases, but it supports the safety/effectiveness of the device, particularly with the proposed instruction modification.
    • For the animal model functional test, the "ground truth" was direct observation of the device's physical handling and compatibility with the 8mm trocar site.

    8. The sample size for the training set

    • Not Applicable. There is no "training set" as this is not an machine learning model.

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

    • Not Applicable. No training set was used.
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    K Number
    K221744
    Manufacturer
    Date Cleared
    2022-11-15

    (152 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    510k Summary Text (Full-text Search) :

    STRATAFIX™ Spiral MONOCRYL™ Plus Unidirectional Knotless Tissue Control Device Regulation Number: 21 CFR 878.4493
    |
    | Classification Name: | Suture, Absorbable, Synthetic, Polyglycolic Acid(21 CFR 878.4493

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

    STRATAFIX™ Spiral MONOCRYL™ Plus Unidirectional Knotless Tissue Control Device is indicated for use in soft tissue approximation where the use of absorbable sutures is appropriate.

    Device Description

    The STRATAFIX™ Spiral MONOCRYL™ Plus Unidirectional Knotless Tissue Control Device is an antibacterial monofilament, synthetic absorbable single-use surgical suture device composed of a copolymer of glycolide and (epsilon) s-caprolactone. The device contains IRGACARE®: MP (triclosan), a broad-spectrum antibacterial agent, at no more than 2360 ug/m. The colorant employed is D&C Violet No.2, in <0.050% w/w concentration. Poliglecaprone 25 copolymer has been found to be nonpyrogenic and elicits only a slight tissue reaction during absorption. The subject device is intended for professional use only.

    Same as the currently marketed undyed version, the subject device consists of a unidirectional barbed suture material, armed with a surgical needle on one end and an anchoring fixation loop at the opposite end. The barbs are oriented in one direction to allow tissue approximation without the need to tie surgical knots.

    While the formation of barbs in the subject STRATAFIX™ Spiral MONOCRYL™ Plus Unidirectional Device reduces the tensile strength relative to non-barbed suture material of the same size, tying of knots in non-barbed suture materials also reduces their effective strength. For this reason, the strength of the STRATAFIX™ Spiral MONOCRYL™ Plus Unidirectional Device can be compared to USP knot strength of non-barbed sutures. The actual diameter of the non-barbed section fiber is one size greater than the designated size with a maximum overage of 0.1 mm.

    The subject device is sterilized by Ethylene Oxide, and is available in lengths of 6, 9, and 12 inches, with a USP diameter size 2-0 and 3-0 (metric sizes 3.0 and 2.0), and single armed with various needle sizes.

    AI/ML Overview

    This document describes a 510(k) premarket notification for a medical device, specifically a surgical suture. It does not contain information about an AI/ML medical device, which would typically include acceptance criteria, study details (sample size, data provenance, ground truth establishment, expert qualifications, etc.), or details of human reader studies (MRMC).

    Therefore, I cannot provide the requested information regarding acceptance criteria and the study that proves the device meets them, as the provided text pertains to a traditional medical device (surgical suture) and not an AI/ML device. The document focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance testing rather than the detailed clinical validation studies common for AI/ML products.

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    K Number
    K212810
    Date Cleared
    2022-08-05

    (336 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    : K212810

    Trade/Device Name: MONOFIX PGCL, knotless wound closure device Regulation Number: 21 CFR 878.4493
    surgical suture Product Code: GAM Panel: General and Plastic Surgery Devices Regulation Number: 21 CFR 878.4493

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

    MONOFIX PGCL, knotless wound closure device is indicated for use in soft tissue approximation where the use of absorbable suture is appropriate. MONOFIX PGCL, knotless wound closure device should not be used to approximate tissue under tension and the use of barbed suture has not been shown to be safe in the closure of hernias, laparotomy incisions, bowel anastomosis or suture lines, vascular suture lines, and vaginal cuff closure in controlled clinical or preclinical studies for minimally invasive or open surgery.

    Device Description

    MONOFIX PGCL, knotless wound closure device, comprised of Poly(glycolide-co-carprolactone)(PGA-PCL) is a synthetic absorbable monofilament undyed-suture. It is available sterile, developed by Samyang Holdings Corp., Ltd. The MONOFIX PGCL, knotless wound closure device consists of a Barb-type suture and a surgical needle, with a suture at one end and a stopper shaped end for tissue anchoring at the stopper is attached to the end of the suture and has a triangular shape with one side length of 1.8 to 3.3 mm and a thickness of 0.7 to 1.0 mm. The device is designed with small uni-directional barbs in size 0.18-0.55 mm along the length and stopper that eliminate the need to tie knots during approximation. The device is available in lengths of 15 to 60cm and diameter sizes 1 through 3-0 with needles in 1/2 circle, 5/8 circle, 1/2 curved and straight shapes attached to each end.

    AI/ML Overview

    This appears to be an FDA 510(k) clearance letter and a summary of the predicate device comparison for a surgical suture, not a diagnostic AI/ML device. Therefore, the requested information regarding acceptance criteria, study details (sample size, data provenance, expert consensus, MRMC studies, standalone performance), and ground truth establishment, which are typical for AI/ML device submissions, are not applicable in this context.

    The document describes the non-clinical tests performed to demonstrate the device's compliance with established standards for surgical sutures. These include:

    • Bench tests: To verify design specifications, focusing on:
      • USP <861> Suture Diameter
      • USP <871> Suture-Needle attachment
      • USP <881> Tensile Strength Surgical Suture
      • USP Monographs: Absorbable Surgical Suture
      • EP Monographs: Sutures, Sterile Synthetic Absorbable Monofilament
    • Sterilization validation: ISO 11135:2014, ISO 10993-7
    • Sterile barrier system testing: ASTM F 88
    • Accelerated aging stability testing: ASTM F 1980
    • Biocompatibility testing: A comprehensive suite of ISO 10993 standards (e.g., ISO 10993-5, -10, -11, -4, -12, -3, -6) and ASTM F756-17.
    • In vivo tensile strength: Performed to evaluate tensile strength retention rate.

    The "Acceptance Criteria" in this document would refer to the specific thresholds and performance requirements defined by these standards (e.g., minimum tensile strength, maximum/minimum diameter, acceptable levels of residuals, successful sterilization). The "Reported Device Performance" would be the results from the tests confirming the device met these criteria.

    Therefore, it is impossible to provide the table and study details as requested because this document does not pertain to an AI/ML device. The study outlined is a non-clinical, benchtop and biocompatibility assessment, not a clinical performance study with human readers or AI algorithms.

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    K Number
    K211792
    Device Name
    StitchKit
    Date Cleared
    2021-07-16

    (36 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Madison, New Jersey 07940

    Re: K211792

    Trade/Device Name: StitchKit Regulation Number: 21 CFR 878.4493
    and NAY |
    | Regulation Number: | 21 CFR 878.4493

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

    StitchKit® Suture Delivery Canister facilitates minimally invasive robotic surgery by transporting suture to the operative field and removing used needles after suturing. The suture contained within the device is intended for soft tissue approximation where use of the specific absorbable or non-absorbable sutures contained within it is appropriate.

    Device Description

    StitchKit® is a suture delivery canister which facilitates endoscopic robotic surgery by introducing multiple strands of different suturing materials to the surgical site at one time and allowing for the safe retrieval of the needles. It is sized to be passed through a ≥12 mm trocar. As suturing is completed with each strand, the used needle is placed into a disposal compartment within the canister for safekeeping until the entire canister is removed through the trocar using the attached retrieval string. It is supplied sterile. Each StitchKit® contains strands of existing legally-marketed Suturing Materials, cleared for use within the device.

    AI/ML Overview

    The provided document is a 510(k) summary for the StitchKit® Suture Delivery Canister, which is a Class II medical device. This document details the device's indications for use, technological characteristics, and substantiates its substantial equivalence to predicate devices, rather than presenting a study to prove acceptance criteria in the typical sense of a human-in-the-loop AI effectiveness study.

    The device itself is a delivery system for existing sutures and not an AI-powered diagnostic or assistive device. Therefore, many of the requested criteria related to AI performance, AI effect size on human readers, expert ground truth, and training data are not applicable to this submission.

    Here's an analysis of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the StitchKit® are based on demonstrating substantial equivalence to legally marketed predicate devices. The performance data provided focuses on the physical and chemical properties of the device and its included sutures.

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance / Compliance
    Technological Characteristics- Canister is legally marketed and unchanged. - Sutures are legally marketed and have not been modified, only trimmed to length and packaged within the StitchKit® canister.- Canister is confirmed to be legally marketed and unchanged. - Sutures are confirmed to be legally marketed, not modified other than trimming and packaging for the StitchKit®.
    Performance Testing- Comparative Physico-Chemical analysis - LAL Pyrogen testing - Material Mediated Pyrogen testing - Stability Evaluations (including USP suture tensile strength, diameter, and needle attachment testing) - Comparative in-vitro simulated biodegradation testing for absorbable sutures- Testing performed to verify substantial equivalence to predicate devices. - Specific results or thresholds are not provided in this summary, but the conclusion states that the device "has been shown to be substantially equivalent to its predicate devices" based on this data.
    Indications for Use- Facilitates minimally invasive robotic surgery by transporting suture and removing used needles. - Suture intended for soft tissue approximation where use of specific absorbable/non-absorbable sutures is appropriate.- The device's design directly supports these indications. No performance metrics are given here for success rate of needle removal or ease of transport, rather it's implicit in its design that it fulfills these functions.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a "test set" in the context of an AI study. Instead, it refers to various forms of performance testing on the device and its components. The document doesn't provide specific sample sizes for these tests (e.g., number of sutures tested for tensile strength or number of canisters tested for pyrogenicity). The provenance of the data (e.g., country of origin, retrospective/prospective) is also not specified, as this type of information is typically not included in a 510(k) summary for a physical device.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts

    Not applicable. As this is not an AI or diagnostic device, there is no "ground truth" established by experts in the context of image interpretation or clinical diagnosis. The performance criteria are based on objective physical/chemical tests.

    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    Not applicable. As there are no expert interpretations or subjective assessments requiring adjudication, no such method was used.

    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. The StitchKit® is a physical surgical delivery device and does not involve AI or human readers for diagnostic assistance. Therefore, an MRMC study and AI effect size are irrelevant.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done

    Not applicable. This device does not involve an algorithm.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" for this device's performance validation is based on established engineering and material science standards (e.g., USP standards for suture properties, LAL pyrogen testing standards, physicochemical analysis). It's not clinical "ground truth" derived from patient outcomes or expert consensus on a diagnosis.

    8. The Sample Size for the Training Set

    Not applicable. There is no AI component requiring a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. There is no AI component requiring a training set and associated ground truth.

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    K Number
    K202950
    Device Name
    StitchKit COMBO
    Manufacturer
    Date Cleared
    2021-02-23

    (146 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Dover, Massachusetts 02030

    Re: K202950

    Trade/Device Name: StitchKit COMBO Regulation Number: 21 CFR 878.4493
    Codes: GAP, GCJ and NAY |
    | Regulation Number: | 21 CFR 878.4493

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

    StitchKit® Suture Delivery Canister facilitates minimally invasive robotic surgery by transporting suture to the operative field and removing used needles after suturing. The suture contained within the StitchKit® device is intended for soft tissue approximation where use of the specific absorbable or non-absorbable sutures contained within it is appropriate.

    Device Description

    StitchKit® COMBO is a suture delivery canister which facilitates endoscopic robotic surgery by introducing multiple strands of different suturing materials to the surgical site at one time and allowing for the safe retrieval of the needles. It is sized to be passed through a ≥12 mm trocar. As suturing is completed with each strand, the used needle is placed into a disposal compartment within the canister for safekeeping until the entire canister is removed through the trocar using the attached retrieval string. It is supplied sterile in a foil pouch. Each StitchKit® version contains strands of existing legallymarketed Suturing Materials, cleared for use within the StitchKit®.

    AI/ML Overview

    This looks like a 510(k) summary for a medical device called "StitchKit® COMBO Suture Delivery Canister". Based on the provided text, the device is explicitly a suture delivery system and not an AI or imaging device, so the requested information about AI performance, ground truth, expert adjudication, etc., is not applicable.

    Here's a breakdown of why the requested information cannot be provided given this document:

    • No AI component: The document describes a "suture delivery canister which facilitates minimally invasive robotic surgery by transporting suture to the operative field and removing used needles after suturing." There is no mention of artificial intelligence, machine learning, image analysis, or any diagnostic capabilities.
    • Physical device, not a diagnostic algorithm: The device handles physical sutures and needles. The performance data listed (knot-pull tensile testing, diameter, needle attachment, biodegradation testing, pyrogen testing, physico-chemical analysis, stability evaluations) are all related to the physical properties and safety of the surgical sutures and the delivery system itself, not to the performance of a software algorithm.

    Therefore, since the device is not an AI/ML medical device, the following points from your request are not applicable and cannot be found in the provided text:

    1. A table of acceptance criteria and the reported device performance (The "performance data" mentioned refers to physical product testing, not AI performance metrics)
    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
    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
    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
    8. The sample size for the training set
    9. How the ground truth for the training set was established

    In summary, this document describes a traditional medical device (suture delivery system) and does not provide any information relevant to the performance or validation of an AI/ML component.

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    K Number
    K201996
    Manufacturer
    Date Cleared
    2020-12-21

    (154 days)

    Product Code
    Regulation Number
    878.4493
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    08876

    Re: K201996

    Trade/Device Name: Monocryl Plus Antibacterial Suture Regulation Number: 21 CFR 878.4493

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

    MONOCRYL™ Plus Antibacterial Sutures are indicated for use in general soft tissue approximation and/or ligation, but not for use in cardiovascular or neurological tissues, microsurgery or ophthalmic surgery.

    Device Description

    MONOCRYL™ Plus Antibacterial Suture is a sterile, monofilament, synthetic, absorbable surgical suture composed of a copolymer of glycolide and (epsilon) s-caprolactone. The empirical formula of the polymer is (C2H2O2)m (C6H102)n.

    MONOCRYL™ Plus Antibacterial Suture is available undyed and dyed with D&C Violet No. 2

    MONOCRYL™ Plus Antibacterial Suture contains Irgacare®† MP (triclosan), a broad spectrum antibacterial agent, at no more than 2360 µg/m.

    AI/ML Overview

    This document is a 510(k) premarket notification for a medical device called MONOCRYL™ Plus Antibacterial Suture. It seeks to demonstrate substantial equivalence to a previously cleared device. Therefore, the information provided focuses on the equivalence of the modified device to its predicate, rather than detailing a de novo study to establish acceptance criteria and prove performance against them as would be typical for a novel device or AI/software.

    Based on the provided text, here's an analysis of the "acceptance criteria" and "study" as they relate to this specific 510(k) submission:

    Understanding the Context:

    This submission (K201996) is for a modified device (MONOCRYL™ Plus Antibacterial Suture) that is largely identical to a predicate device (MONOCRYL™ Plus Antibacterial Poliglecaprone – 25 with 510(k) number K050845). The only reported changes are to the labeling, specifically updating in vitro effectiveness against an additional microorganism and including new descriptors/icons.

    For a 510(k) involving minor changes, the "acceptance criteria" revolve around demonstrating that the modified device remains as safe and effective as the predicate, or that the changes do not raise new questions of safety or effectiveness. The "study" in this context refers to the data presented to support this claim, rather than a clinical trial for a new product.

    1. A table of acceptance criteria and the reported device performance

    Since this is a submission for a modified device essentially claiming no change in technological characteristics, the "acceptance criteria" are implicitly that the modified device retains the performance attributes of the predicate. The "reported device performance" is essentially a reaffirmation of the predicate's performance, along with specific in vitro data for the antibacterial claims.

    Acceptance Criteria (Implicit for Substantial Equivalence)Reported Device Performance (Summary from Document)
    For Suture Material:
    - Same technological characteristics as predicate (composition, structure, absorbability)"The modified MONOCRYL™ Plus Suture has the same technological characteristics as the predicate device... it is a sterile, monofilament synthetic absorbable suture composed of a copolymer of glycolide and (epsilon) s-caprolactone."
    - Compliance with USP standards for absorbable surgical sutures"complies with the requirements of the United States Pharmacopoeia (USP) for absorbable surgical sutures except for a slight oversize in diameter." (This exception is noted as existing for the predicate as well, implying continued equivalence.)
    For Antibacterial Efficacy:
    - Contains Irgacare®† MP (triclosan) at specified concentration"MONOCRYL™ Plus Antibacterial Suture contains Irgacare®† MP (triclosan), a broad spectrum antibacterial agent, at no more than 2360 µg/m."
    - Inhibit colonization of specified bacteria"In vitro efficacy studies were conducted to demonstrate that bacteria will not colonize MONOCRYL™ Plus Antibacterial suture. The in vitro data indicated that MONOCRYL™ Plus suture provides an antibacterial effect sufficient to inhibit colonization of the suture by Staphylococcus aureus, Staphylococcus epidermidis, Methicillin-Resistant S. aureus, Methicillin-Resistant S. epidermidis, Klebsiella pneumoniae, Escherichia coli and Enterobacter cloacae."
    For Intended Use/Indications:
    - Same intended use and indications for use as predicate"The modified device has the same intended use and indications for use as the predicate device." (General soft tissue approximation/ligation, not for cardiovascular, neurological, microsurgery, or ophthalmic surgery).

    2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    The document mentions "in vitro efficacy studies" for the antibacterial claims. Details on the specific sample sizes (e.g., number of suture samples, number of bacterial cultures) are not provided in this summary. The data provenance is described as "in vitro," implying laboratory studies, rather than patient data. No information on country of origin or retrospective/prospective nature is given, as it's not a clinical study.

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

    This type of information is generally relevant for AI/radiology devices where expert consensus is used to label images. For a physical medical device like a suture, "ground truth" for material properties and antibacterial efficacy is established through standardized laboratory testing and validated analytical methods (e.g., chemical analysis, microbiology assays). The document does not specify the number or qualifications of experts involved in running these in vitro tests, as this is typically handled by qualified laboratory personnel following established protocols.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable. Adjudication methods like 2+1 or 3+1 are used in clinical studies, particularly for imaging interpretation, to resolve discrepancies between readers. This document describes laboratory in vitro studies for which such an adjudication method is not relevant.

    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 device is a physical surgical suture, not an AI or imaging diagnostic tool. Therefore, MRMC studies and human reader improvement with AI assistance are not relevant.

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

    Not applicable. This document is about a physical medical device, not an algorithm or AI.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the antibacterial claims, the "ground truth" would be established by the results of the microbiological in vitro assays which directly measure the inhibition of bacterial colonization on the suture material. For the material properties, the "ground truth" is established by chemical and physical testing against established standards (e.g., USP monographs). This is empirical data from laboratory studies, not consensus of human experts on subjective interpretations.

    8. The sample size for the training set

    Not applicable. This is not an AI/machine learning device that requires training data.

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

    Not applicable, as explained in point 8.

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