Sandshark Injectable Anchor Kit, Injectroducer Handle, Loading Rod with Anchor, Loading Base

K172644 · Stimwave Technologies Incorporated · GZB · Nov 3, 2017 · Neurology

Device Facts

• Record ID: K172644
• Device Name: Sandshark Injectable Anchor Kit, Injectroducer Handle, Loading Rod with Anchor, Loading Base
• Applicant: Stimwave Technologies Incorporated
• Product Code: GZB · Neurology
• Decision Date: Nov 3, 2017
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 882.5880
• Device Class: Class 2

Intended Use

The SandShark Injectable Anchor (SIA) System is intended to be an accessory to the stimulator component of the Stimwave Freedom Spinal Cord Stimulator (SCS) System to secure the stimulator to the fascia or interspinous/supra-spinous ligament.

Device Story

The SandShark Injectable Anchor (SIA) System is a sterile, single-use accessory designed to fixate the Stimwave Freedom Stimulator to patient tissue. The system consists of a carbothane anchor, an ABS/stainless steel deployment handle (Injectroducer), a loading rod, and a loading base. Used in hospitals or ambulatory surgical centers by orthopedic surgeons, neurosurgeons, or anesthesiologists, the device is introduced percutaneously. The clinician uses the Injectroducer to deploy the anchor onto the stimulator, securing it to the fascia or interspinous/supra-spinous ligament. This fixation ensures the stimulator remains in the intended anatomical position, preventing migration and maintaining the therapeutic efficacy of the spinal cord stimulation system for pain relief.

Clinical Evidence

No clinical data provided. Substantial equivalence is supported by non-clinical bench testing, including biocompatibility (ISO 10993-1), sterilization validation, and mechanical performance testing (AAMI ANSI ISO 14708-3) for temperature and atmospheric pressure changes.

Technological Characteristics

System components: Carbothane 80A anchor; ABS and stainless steel 304V deployment handle (Injectroducer), loading rod, and base. Dimensions: 1.5-inch anchor length, 0.087-inch outer diameter. Sterilization: Ethylene Oxide (EO). Biocompatibility: Complies with ISO 10993-1:2009. Mechanical testing: Complies with AAMI ANSI ISO 14708-3:2008.

Indications for Use

Indicated for use as an accessory to the Stimwave Freedom Spinal Cord Stimulator (SCS) system to secure the stimulator to the fascia or interspinous/supra-spinous ligament in patients undergoing spinal cord stimulation for pain relief.

Regulatory Classification

Identification

An implanted spinal cord stimulator for pain relief is a device that is used to stimulate electrically a patient's spinal cord to relieve severe intractable pain. The stimulator consists of an implanted receiver with electrodes that are placed on the patient's spinal cord and an external transmitter for transmitting the stimulating pulses across the patient's skin to the implanted receiver.

Predicate Devices

• Boston Scientific (Anulex Technologies Inc.) Fixate Suturing Device (K113805)
• Anchor Innovation Medical (A.I.M.) Lead Loop Suturing Device (K150924)

Submission Summary (Full Text)

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

November 3, 2017

Stimwave Technologies Incorporated c/o Elizabeth Greene Vice President of Quality Assurance and Regulatory Affairs 1310 Park Central Boulevard South Pompano Beach, Florida 33064

Re: K172644

Trade/Device Name: Sandshark Injectable Anchor System Regulation Number: 21 CFR 882.5880 Regulation Name: Implanted Spinal Cord Stimulator For Pain Relief Regulatory Class: Class II Product Code: GZB Dated: August 30, 2017 Received: September 1, 2017

Dear Elizabeth Greene:

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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in 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.

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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 (DICE) at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 (DICE) at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely.

William J. Heetderks -S 2017.11.03 08:43:03 -04'00'

for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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### Indications for Use Statement

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

#### Device Name: SandShark Injectable Anchor (SIA) System

#### Indications For Use:

The SandShark Injectable Anchor (SIA) System is intended to be an accessory to the stimulator component of the Stimwave Freedom Spinal Cord Stimulator (SCS) System to secure the stimulator to the fascia or interspinous/supra-spinous ligament.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

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

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

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Image /page/3/Picture/0 description: The image is a logo for Stimwave Technologies. The word "stim" is in dark blue, "wave" is in green, and "TECHNOLOGIES" is in dark blue with a blue line above it. To the right of the word "wave" are several blue concentric arcs.

### 510(k) Summary

for

### SandShark Injectable Anchor (SIA) System

### 1. Submission Sponsor

Stimwave Technologies Incorporated 1310 Park Central Boulevard South Pompano Beach FL, 33064 USA Phone: [phone] Fax: [phone] Contact: Elizabeth Greene, Vice President of Quality Assurance and Regulatory Affairs

# 2. Date Prepared

August 30, 2017

# 3. Device Identification

| Trade/Proprietary Name: | SandShark Injectable Anchor System |
|----------------------------|--------------------------------------------------|
| Classification Name: | Stimulator, Spinal-Cord, Implanted (Pain Relief) |
| Classification Regulation: | 882.5880 |
| Product Code: | GZB |
| Device Class: | Class II |
| Classification Panel: | Neurology |

# 4. Legally Marketed Predicate Device(s)

Primary: Boston Scientific (Anulex Technologies Inc.) Fixate Suturing Device (K113805)

Anchor Innovation Medical (A.I.M.) Lead Loop Suturing Device (K150924)

### 5. Device Description

The Stimwave Technologies Incorporated (Stimwave) SandShark Injectable Anchor (SIA) System is used to fixate the Stimwave Freedom Stimulator to surrounding tissue. The System is comprised of a carbothane anchor (SandShark Anchor) that is transferred onto the deployment handle (SandShark Injectroducer) with the Loading Rod and Loading Base. The SIA System is provided sterile. The SandShark Injectroducer is used to deploy the SandShark Anchor onto the Stimulator.

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Image /page/4/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. Below the two words is the word "TECHNOLOGIES" in blue, inside of a blue box with rounded corners. To the right of the words is a blue graphic that looks like a wave.

SandShark Injectable Anchor (SIA) System

| Injectroducer | An acrylonitrile butadiene styrene (ABS) handle and cannula<br>(stainless steel 304V, KR01 Phillips K-Resin) anchor deployment<br>device that is used to secure the SandShark Anchor onto the<br>stimulator to the fascia or interspinous/supra-spinous ligament. |
|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| SandShark<br>Anchor | A carbothane (80A) anchor that is deployed by the Injectroducer onto<br>the stimulator securing the device to the fascia or interspinous/supra-<br>spinous ligament. Four (4) SandShark Anchors are provided in the<br>SIA System, pre-loaded onto the Loading Rod. |
| Loading Rod | An assembly that is used with the Loading Base to transfer the<br>SandShark Anchor onto the cannula of the Injectroducer. The handle<br>is constructed of ABS and the rod is stainless steel 304V. |
| Loading Base | An acrylonitrile butadiene styrene (ABS) base that holds the Loading<br>Rod in place while transferring the SandShark Anchor onto the<br>cannula of the Injectroducer. |

#### 6. Indication for Use Statement

The SandShark Injectable Anchor (SIA) System is intended to be an accessory to the stimulator component of the Stimwave Freedom Spinal Cord Stimulator (SCS) System to secure the stimulator to the fascia or interspinous/supra-spinous ligament.

### 7. Substantial Equivalence Discussion

The following table compares the Stimwave SIA System to the predicate devices with respect to intended use, technological characteristics and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.

| Table SA. Comparison of Characteristics | | | | | |
|-----------------------------------------|-----------------------------------------------------------------------------|----------------------------------------------------------|-----------------------------------------------------|--|--|
| Comparator | Stimwave SandShark<br>Injectable Anchor (SIA)<br>System | Boston Scientific Fixate<br>Suturing Device<br>(K113805) | A.I.M. Lead Loop<br>Suturing Device<br>(K150924) | | |
| Product Code | GZB | GZB | GZB | | |
| Regulation No. | 882.5880 | 882.5880 | 882.5880 | | |
| Regulation Name | Stimulator, Spinal-Cord,<br>Implanted (Pain Relief) | Stimulator, Spinal-Cord,<br>Implanted (Pain Relief) | Stimulator, Spinal-Cord,<br>Implanted (Pain Relief) | | |
| Intended Use | Accessory for securing a<br>spinal cord stimulator to<br>surrounding tissue | Same as SandShark | Same as SandShark | | |
| Implant Site | Fascia or inter-spinous/supra-<br>spinous ligament | Same as SandShark | Same as SandShark | | |
| Environmental Use | Hospital or Ambulatory<br>Surgical Center Only | Same as SandShark | Same as SandShark | | |
| Intended Clinician | Orthopedic, Neurosurgeon,<br>Anesthesiologist | Same as SandShark | Same as SandShark | | |
| Anchor Material | Carbothane 80A | PEEK or PET | PEEK with Polyethylene<br>or Polyester braid | | |
| Cannula Material | Stainless Steel 304V | Stainless Steel | Stainless Steel | | |

| Table 5A. Comparison of Characteristics | | |
|-----------------------------------------|--|--|
|-----------------------------------------|--|--|

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Image /page/5/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is underlined. To the right of the words is a blue circular design that looks like radio waves.

| Comparator | Stimwave SandShark<br>Injectable Anchor (SIA)<br>System | Boston Scientific Fixate<br>Suturing Device<br>(K113805) | A.I.M. Lead Loop<br>Suturing Device<br>(K150924) |
|---------------------------|---------------------------------------------------------|----------------------------------------------------------|--------------------------------------------------|
| Anchor Length | 1.5 inch | NA | NA |
| Anchor Outer Diameter | 0.087 inch | N/A | N/A |
| Method of Introduction | Percutaneous and Anchor<br>Incision | Percutaneous and Anchor<br>Incision | Percutaneous and Anchor<br>Incision |
| Tissue Contact | Yes | Same as SandShark | Same as SandShark |
| Sterilization | Ethylene Oxide (EO) | Same as SandShark | Same as SandShark |
| Labeling | Labeled as Sterile, Single<br>Use, Prescription Device | Same as SandShark | Same as SandShark |
| Sterile | Yes - ethylene oxide | Same as Freedom | Same as Freedom |
| Single-Use | Yes | Yes | Yes |
| Shelf Life | 1 year | Unknown | Unknown |
| Complies with ISO 10993-1 | Yes | Yes | Yes |
| Safety Testing Passed | Yes | Yes | Yes |

(*) asterisk denotes that formulas were used for the calculations.

### 8. Biocompatibility Data

The materials, construction and intended use of the SIA System is comparable to the predicate device, and have a long history of safety with respect to biocompatibility. The biological safety of the SandShark Anchor was evaluated in accordance to ISO 10993-1:2009, guidance document Use of International Standard ISO 10993-1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process and Blue Book Memorandum G95-1 Use of International Standard ISO-10993, and Biological Evaluation of Medical Devices: Part 1: Evaluation and Testing. Under these, for the stated indications for use, the device was classified as a (C), implant device in contact with tissue/bone. The results for the biocompatible testing for cytotoxicity. sensitization, irritation or intracutaneous reactivity, acute systemic toxicity, implantation (4, 8, and 13 weeks), subacute and subchronic toxicity, chronic toxicity, carcinogenicity, extractables and leechables demonstrated no negative impacts from the materials that are used in the SIA System. The SIA System meets biological safety and compatibility requirements of ISO 10993-1:2009 and Blue Book Memorandum G95-1.

### 9. Non-Clinical Performance Data

The SIA System was tested to verify that the performance meets the system design requirements as well as all applicable voluntary standards. The SIA System complies with all design requirements and applicable voluntary standards.

AAMI ANSI ISO 14708-3:2008 - For protection from temperature change including shipping and storage temperature ranges, the SIA System was functional, receiving a safe rating following post visual inspection and passed the change of temperature testing performed as specified by AAMI ANSI ISO 14708-3:2008. For atmospheric pressure change, the SIA System was functional following post testing functionality inspection and passed atmospheric pressure change testing as specified by AAMI ANSI ISO 14708-3:2008.

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Image /page/6/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in a dark blue font, and the word "wave" is in a green font. Below the words "stim wave" is the word "TECHNOLOGIES" in a smaller, dark blue font. To the right of the words is a graphic of concentric circles in a light blue color.

Stimwave Technologies Incorporated Traditional 510(k) Premarket Submission SandShark Injectable Anchor (SIA) System

Stimwave completed a number of tests for the SIA System that demonstrates substantial equivalence to the legally marketed predicate devices. The SIA System meets all the requirements for overall design, sterilization, and biocompatibility confirms that the output meets the design inputs and specifications. The SIA System passed all testing stated above as shown by the acceptable results obtained.

# 10. Clinical Performance Data

There was no clinical testing required to support the medical device, as the indications for use are equivalent to the legally marketed predicate devices. These types of devices, including the legally marketed predicate devices, have been on the market for many years with a proven safety and efficacy for the use of the device. The non-clinical testing detailed in this submission supports the substantial equivalence of the device.

# 11. Statement of Substantial Equivalence

By definition, a device is substantially equivalent to legally marketed predicate devices when the device has the same intended use and the same technological characteristics as the previously cleared predicate device. The SIA System has the same intended use as the legally marketed predicates devices. Performance tested verified that the SIA System complies with all applicable voluntary standards such as AAMI ANSI ISO 14708-3. The SIA System also meets the design requirements where no applicable standard could be used. This included anchor durability testing, as well as biocompatibility and sterilization validation of the SIA System. There were no recognized performance standards for this device. There was no clinical testing performed on this device since performance testing demonstrated similar performance as the legally marketed predicate devices, and materials for the SIA System are the same as the legally marketed predicate devices.

It has been shown in this 510(k) submission that the difference between the SIA System and the legally marketed predicate devices do not raise any questions regarding its safety and effectiveness as compared to legally marketed predicate devices. The SIA System, as designed and manufactured, is determined to be substantially equivalent to the referenced legally marketed predicate devices.