POLYSYN SURGICAL SUTURE

K141625 · Surgical Specialties Corp · GAM · Jul 18, 2014 · General, Plastic Surgery

Device Facts

• Record ID: K141625
• Device Name: POLYSYN SURGICAL SUTURE
• Applicant: Surgical Specialties Corp
• Product Code: GAM · General, Plastic Surgery
• Decision Date: Jul 18, 2014
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 878.4493
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

PolySynTM (Polyglycolic Acid (PGA)) Suture is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in Cardiovascular and Neurological procedures.

Device Story

PolySyn PGA surgical suture; braided or monofilament; dyed (D&C Violet #2) or undyed; coated (polycarpolactone and calcium stearate) or uncoated. Used by surgeons for soft tissue approximation and ligation. Device provides mechanical wound closure. Performance verified via USP monograph testing for absorbable sutures and in vitro post-hydrolysis tensile testing.

Clinical Evidence

Bench testing only. Testing included USP monograph compliance for absorbable sutures and in vitro post-hydrolysis tensile testing to confirm performance of additional suture diameters.

Technological Characteristics

Material: Polyglycolic Acid (PGA). Coating: Copolymer of polycarpolactone and calcium stearate. Form: Braided or monofilament. Sizes: 2 through 10-0. Sterilization: Not specified. Conforms to USP monograph for absorbable sutures.

Indications for Use

Indicated for general soft tissue approximation and/or ligation, including ophthalmic procedures. Contraindicated for cardiovascular and neurological procedures.

Regulatory Classification

Identification

An absorbable poly(glycolide/l-lactide) surgical suture (PGL suture) is an absorbable sterile, flexible strand as prepared and synthesized from homopolymers of glycolide and copolymers made from 90 percent glycolide and 10 percent l-lactide, and is indicated for use in soft tissue approximation. A PGL suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. “Monograph for Absorbable Surgical Sutures;” it may be monofilament or multifilament (braided) in form; it may be uncoated or coated; and it may be undyed or dyed with an FDA-approved color additive. Also, the suture may be provided with or without a standard needle attached.

Special Controls

*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.

Predicate Devices

• PolySynTM Surgical Suture (K965162)

Reference Devices

• Coated VICRYLTM (Polyglactin) Suture (K022269)

Submission Summary (Full Text)

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# JUI. 18 2014

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Page 1 of 2 K141625

# 510(k) Summary

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| Date Prepared: | Jul 17, 2014 |
|--------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company: | Surgical Specialties Corporation<br>100 Dennis Dr.<br>Reading, PA 19606 |
| Contact: | Paul Amudala<br>Regulatory Affairs Specialist<br>Phone: [phone]<br>Fax: [phone]<br>Email: [e-mail] |
| Device trade name: | PolySynTM (PGA) Surgical Suture |
| Device Common Name: | Absorbable Polyglycolic Acid Surgical Suture |
| Device classification: | Suture, Absorbable, Synthetic, Polyglycolic Acid<br>Product code, GAM<br>21 CFR 878.4493<br>Class II |
| Legally marketed device<br>to which the device is<br>substantially equivalent: | K965162: PolySynTM Surgical Suture (primary)<br>K022269 Coated VICRYLTM (Polyglactin) Suture (reference) |
| Description of the<br>device: | PGA Sutures are supplied as braided or monofilament, dyed (violet) or undyed and coated or uncoated. The pigment for the violet is D&C Violet #2. Where applicable, the coating is a copolymer of polycarpolactone and calcium stearate. The PGA Suture is available in Size 2 through Size 10-0. |
| Indications for Use: | PolySynTM (Polyglycolic Acid (PGA)) Suture is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in Cardiovascular and Neurological procedures. |
| Substantial<br>Equivalence: | The proposed additional diameter sizes, USP Size 7-0 through 10-0, of the PolySynTM suture product line have the same material (K965162), design, intended use and technological characteristics as the predicate device. The only difference between the proposed and predicate (K965162) device is the suture diameter. |

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| K<br>4 | 1<br>4 | 1 | 625 | |
|--------|--------|---|-----|--|
| | | | | |

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Page 2 of 2

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| Performance tests: | Non-clinical laboratory performance testing was conducted to<br>confirm that the PolySyn™ suture conforms to the USP<br>monograph for absorbable sutures (as applicable). This testing<br>was performed in accordance with FDA's Class II Special<br>Controls Guidance Document: Surgical Sutures, Issued June 3,<br>2003. Additional performance testing was conducted in order to<br>demonstrate substantial equivalence to the predicate device<br>including <i>in vitro</i> post-hydrolysis tensile testing. |
|--------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | The results of this testing demonstrates that the PolySyn™ suture<br>is substantially equivalent to the predicate devices. |

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#### DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drue Administration 10903 New Hampshire Avenue Document Contral Center - WO66-G609 Silver Spring, MD 20993-0002

July 18, 2014

Surgical Specialties Corporation Mr. Paul Amudala Regulatory Affairs Specialist 100 Dennis Drive Reading, Pennsylvania 19606

Re: K141625

Trade/Device Name: POLYSYN" (Polyglycolic Acid) Surgical Suture Regulation Number: 21 CFR 878.4493 Regulation Name: Absorbable poly(glycolide/L-lactide) surgical suture Regulatory Class: Class II Product Code: GAM Dated: June 18, 2014 Reccived: June 19, 2014

Dear Mr. Amudala:

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 cnactment 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 (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. The general controls provisions of the Act include requirements for annual registration. Ilisting 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,

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complics 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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Page 2 - Mr. Paul Amudala

forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

# David Krause -S

for

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

## Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on fast page.

#### 510(k) Number (if known) K141625

#### Device Name

POLYS YN™ (Polyglycolic Acid) Surgical Suture

#### Indications for Use (Describe)

POLYS YN™ Polyglycolic Acid (PGA) Suture is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in Cardiovascular and Neurological procedures.

Type of Use (Select one or both, as applicable)

[ Prescription Use (Part 21 CFR 801 Subpart D)

O Over-The-Counter Use (21 CFR 801 Subpart C)

## PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

### FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

# Peter L. Hud 2014.07.18 07:27

FORM FDA 3881 (1/14)