IvyAIR Meniscus System, Curved, IvyAIR Meniscus System, Straight, IvyAIR Meniscus System, Reverse Curved

K153087 · Ivy Sports Medicine, LLC · GAT · Jul 14, 2016 · General, Plastic Surgery

Device Facts

• Record ID: K153087
• Device Name: IvyAIR Meniscus System, Curved, IvyAIR Meniscus System, Straight, IvyAIR Meniscus System, Reverse Curved
• Applicant: Ivy Sports Medicine, LLC
• Product Code: GAT · General, Plastic Surgery
• Decision Date: Jul 14, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.5000
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The IvyAIR Meniscus System is intended for use as a suture retention device to facilitate percutaneous or endoscopic soft tissue procedures. The IvyAIR Meniscus System is indicated for use in meniscal repairs and allograft transplant procedures. The IvyAIR Meniscus System device is intended to be used for anchoring the allograft to the meniscal rim during allograft transplant procedures.

Device Story

All-inside meniscus repair device; consists of two non-absorbable polymer implants pre-tied with 2-0 non-absorbable suture; pre-loaded into needle delivery system. Available in curved, straight, and reverse-curved configurations for surgical access to specific meniscus zones. Used by surgeons during percutaneous or endoscopic procedures to anchor soft tissue or allografts to the meniscal rim. Device is sterile and single-use. Provides mechanical fixation to facilitate tissue healing/transplant stability.

Clinical Evidence

No clinical data. Bench testing only. Testing included implant strength to failure, dynamic and static tensile loading, and comprehensive biocompatibility testing per ISO 10993-1 (cytotoxicity, sensitization, reactivity, systemic toxicity, pyrogenicity, genotoxicity, and intramuscular implantation). All acceptance criteria met.

Technological Characteristics

Non-absorbable polymer implants; 2-0 non-absorbable suture; needle delivery system. Available in curved, straight, and reverse-curved configurations. Biocompatibility per ISO 10993-1. Sterile, single-use.

Indications for Use

Indicated for patients undergoing meniscal repair or meniscal allograft transplant procedures requiring soft tissue anchoring to the meniscal rim.

Regulatory Classification

Identification

Nonabsorbable poly(ethylene terephthalate) surgical suture is a multifilament, nonabsorbable, sterile, flexible thread prepared from fibers of high molecular weight, long-chain, linear polyesters having recurrent aromatic rings as an integral component and is indicated for use in soft tissue approximation. The poly(ethylene terephthalate) surgical suture meets U.S.P. requirements as described in the U.S.P. Monograph for Nonabsorbable Surgical Sutures; it may be provided uncoated or coated; and it may be undyed or dyed with an appropriate FDA listed 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

• Smith & Nephew FAST-FIX 360 Meniscal Repair System (K121861)

Submission Summary (Full Text)

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

July 14, 2016

Ivy Sports Medicine, LLC Mr. John Dichiara Senior Vice President Quality Assurance, Clinical and Regulatory Affairs 545 Penobscot Drive Redwood City, California 94063

Re: K153087

Trade/Device Name: Ivyair Meniscus System, Curved, Ivyair Meniscus System, Straight, Ivyair Meniscus System, Reverse Curved Regulation Number: 21 CFR 878.5000 Regulation Name: Nonabsorbable Poly(Ethylene Terephthalate) Surgical Suture Regulatory Class: Class II Product Code: GAT Dated: October 21, 2015 Received: October 26, 2015

Dear Mr. Dichiara:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (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, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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" (21 CFR 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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SECTION 5

## INDICATIONS FOR USE

510(k) Number (if known): K153087

Device Name: IvyAIR Meniscus System

#### Indications for Use:

The IvyAIR Meniscus System is intended for use as a suture retention device to facilitate percutaneous or endoscopic soft tissue procedures. The lvyAIR Meniscus System is indicated for use in meniscal repairs and allograft transplant procedures. The lvyAlR Meniscus System device is intended to be used for anchoring the allograft to the meniscal rim during allograft transplant procedures.

Prescription Use

AND/OR

Over-The-Counter Use

(Part 21 CFR 801 Subpart D)

(21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

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### SECTION 6

## 510(k) SUMMARY

This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

#### 510(k) Number: K

#### Applicant Information:

| Owner Name: | Ivy Sports Medicine, LLC |
|-------------|-----------------------------------------------|
| Address: | 545 Penobscot Drive<br>Redwood City, CA 94063 |
| Main Phone: | 650-562-0800 |
| Fax: | 650-562-0808 |

Establishment Registration Number: 2956141

| Contact Person: | John Dichiara |
|-----------------|---------------------|
| | Phone: [phone] |
| | Fax: [phone] |

Date Prepared: October 21, 2015

#### Device Information:

- Classification: Class II
- Trade Name: IvyAIR Meniscus System
- Common name: Meniscus Repair Device
- Classification name: Nonabsorbable poly(ethylene terephthalate) surgical suture
- Regulation number: 21 CFR §878.5000
- Product Code: GAT

#### Predicate Device:

The IvyAlR Meniscus System is substantially equivalent in Intended Use, Fundamental Scientific Technology and Performance to the following legally marketed device in commercial distribution: Smith & Nephew FAST-FIX 360 Meniscal Repair System cleared under K121861.

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#### Device Description:

The IvyAIR Meniscus System is an all-inside meniscus repair device. Each device includes two non-absorbable polymer implants, pre-tied with 2-0 non-absorbable suture and pre-loaded into a needle delivery system. The IvyAIR System is available in three needle configurations: Curved. Straight and Reverse Curve to allow the surgeon a choice for access to the desired zone of the meniscus. The IvyAIR Meniscus System is provided sterile for single use only.

#### Intended Use:

The IvyAIR Meniscus System is intended for use as a suture retention device to facilitate percutaneous or endoscopic soft tissue procedures. The IvyAIR Meniscus System is indicated for use in meniscal repairs and allograft transplant procedures. The IvyAIR Meniscus System device is intended to be used for anchoring the allograft to the meniscal rim during allograft transplant procedures.

#### Comparison to Predicate Device(s):

The IvyAIR Meniscus System has a similar intended use and similar technological characteristics to the predicate device: Smith & Nephew FAST-FIX 360 Meniscal Repair System. Any differences identified do not raise new questions of safety or effectiveness, as supported by biomechanical, biocompatibility and bench testing.

#### Technological Characteristics/Performance Data:

The IvyAIR Meniscus System is substantially equivalent to the predicate device in intended use, fundamental scientific technology, and performance specifications. Design verification testing was performed to verify that the performance of the IvvAlR Meniscus System remains substantially equivalent to the predicate device. The device has been tested for biocompatibility according to ISO10993-1 and was determined to be biocompatible. Testing performed on the IvyAIR Meniscus System included the following:

| Bench Testing | Biocompatibility Testing |
|------------------------------------|----------------------------------------------------------|
| Implant strength test to failure | MEM Elution Using L-929 Mouse Fibroblast Cells |
| Dynamic and static tensile loading | Guinea Pig Maximization Sensitization Test |
| | Intracutaneous Reactivity Test |
| | Acute Systemic Injection Test |
| | Material mediated pyrogen |
| | Subacute (14 Day) Intraperitoneal Toxicity Study In Rats |
| | Subchronic (14 Day) Intravenous Toxicity Study In Rats |
| | including histopathology |
| | Bacterial Mutagenicity Test (Ames Assay) |
| | In Vitro Mouse Lymphoma Assay |
| | In Vivo Mouse Micronucleus Assay |
| | Intramuscular Implantation Tests (2 weeks and 13 weeks) |

All of the pre-determined acceptance criteria were met with passing results.

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Image /page/5/Picture/1 description: The image shows the logo for Ivy Sports Medicine, LLC. The logo consists of a stylized green image of leaves on the left, followed by the text "Ivy Sports Medicine, LLC" in black. The text is in a bold, sans-serif font.

#### Clinical Testing:

Clinical evaluation is not required for this device.

#### Substantial equivalence:

The IvyAIR Meniscus System has the following similarities to the Smith & Nephew FAST-FIX 360 Meniscal Repair System predicate device cleared under K121861.

- has the same intended use and indication for use,
- . has the same technological characteristics,
- . has the same principles of operation,
- . has equivalent performance characteristics, and
- . has the same sterilization process.

#### Summary

In summary, the IvyAIR Meniscus System subject to this submission is as safe and effective as the Smith & Nephew FAST-FIX 360 Meniscal Repair System. It has the same indication for use, the same technological characteristics, and the same principles of operation as the Smith & Nephew FAST-FIX 360 Meniscal Repair System. The differences between the IvyAIR Meniscus System and the Smith & Nephew FAST-FIX 360 Meniscal Repair System raise no new issues of safety or effectiveness. Performance data demonstrate that the IvyAlR Meniscus System is as safe and effective as the Smith & Nephew FAST-FIX 360 Meniscal Repair System and is therefore substantially equivalent to the predicate device.