Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II

K221128 · Arthrex, Inc. · MAI · Oct 5, 2022 · Orthopedic

Device Facts

• Record ID: K221128
• Device Name: Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II
• Applicant: Arthrex, Inc.
• Product Code: MAI · Orthopedic
• Decision Date: Oct 5, 2022
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3030
• Device Class: Class 2
• Attributes: Therapeutic, Pediatric

Intended Use

The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are intended to be used for fixation of bone to bone or soft tissue to bone, and are intended as fixation bridge, or for distributing suture tension over areas of ligament or tendon repair. Specifically, Arthrex will be offering these devices for ACL/PCL repair and reconstruction for the adult and pediatric patient population.

Device Story

Device consists of braided nonabsorbable surgical suture loop, passing sutures, and titanium button; used for bone-to-bone or soft tissue-to-bone fixation during ACL/PCL repair and reconstruction. Surgeon implants device to secure ligament/tendon grafts; button distributes suture tension. Used in surgical settings. Benefits include stable fixation for ligament/tendon repair in both adult and pediatric patients.

Clinical Evidence

Evidence includes clinical literature review and real-world data from the Surgical Outcomes System registry. Registry data compared outcomes in patients <22 years vs. >22 years, showing no statistical differences. Bench testing included ultimate load and cyclic displacement testing compared to predicates, and bacterial endotoxin testing per EP 2.6.14/USP <85>.

Technological Characteristics

Materials: Titanium button, braided nonabsorbable surgical suture. Principle: Mechanical fixation via suture loop and button. Form factor: Various models (e.g., TightRope ABS, ACL TightRope RT). Sterilization: Not specified. Connectivity: None. Software: None.

Indications for Use

Indicated for fixation of bone-to-bone or soft tissue-to-bone, and as a fixation bridge or for distributing suture tension during ligament or tendon repair, including ACL/PCL repair and reconstruction in adult and pediatric populations.

Regulatory Classification

Identification

Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.

Predicate Devices

• Arthrex TightRope II (K202581)
• ACL TightRope (K112990)
• PCL TightRope (K110123)

Reference Devices

• Orthopediatrics ACL Reconstructive System (K130217)
• Arthrex Syndesmosis TightRope XP Buttress Plate Implant System (K201522)

Submission Summary (Full Text)

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October 5, 2022

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a seal with an abstract design. To the right of the seal, there is a blue square with the letters "FDA" in white. Next to the blue square, the words "U.S. FOOD & DRUG" are written in blue, with the word "ADMINISTRATION" written in a smaller font size below.

Lai Saeteurn Regulatory Affairs Specialist II 1370 Creekside Boulevard Naples, Florida 34108-1945

Re: K221128

Trade/Device Name: Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II Regulation Number: 21 CFR 888.3030 Regulation Name: Single/Multiple Component Metallic Bone Fixation Appliances And Accessories Regulatory Class: Class II Product Code: MAI, MBI Dated: April 14, 2022 Received: April 18, 2022

Dear Lai Saeteurn:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 and Part 809; medical device reporting of medical device-related adverse events) (21 CFR

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803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely.

For:

Laura C. Rose, Ph.D. Assistant Director DHT6C: Division of Restorative, Repair, and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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## Indications for Use

510(k) Number (if known) K221128

Device Name Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II

Indications for Use (Describe)

The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are intended to be used for fixation of bone to bone or soft tissue to bone, and are intended as fixation bridge, or for distributing suture tension over areas of ligament or tendon repair. Specifically, Arthrex will be offering these devices for ACL/PCL repair and reconstruction for the adult and pediatric patient population.

| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |

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## 510(k) Summary

| Date Prepared | October 5, 2022 |
|--------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter | Arthrex Inc.<br>1370 Creekside Boulevard<br>Naples, FL 34108-1945 |
| Contact Person | Lai Saeteurn<br>Regulatory Affairs Specialist II<br>1-239-598-4302, ext. 71764<br>[e-mail] |
| Name of Device | Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II |
| Common Name | Smooth or threaded metallic bone fixation fastener |
| Product Code | MAI – Single/Multiple component metallic bone fixation appliances and accessories<br>MBI – Smooth or threaded metallic bone fixation fastener |
| Classification Name | 21 CFR 888.3040: Smooth or threaded metallic bone fastener<br>21 CFR 888.3030: Single/multiple component metallic bone fixation appliances and accessories |
| Regulatory Class | II |
| Predicate Device | K202581: Arthrex TightRope II<br>K112990: ACL TightRope<br>K110123: PCL TightRope |
| Reference Device | K130217: Orthopediatrics ACL Reconstructive System<br>K201522: Arthrex Syndesmosis TightRope XP Buttress Plate Implant System |
| Purpose of Submission | This Traditional 510(k) premarket notification is submitted to obtain pediatric indications for the Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices cleared under K112990, K110123, and K202581. |
| Device Description | The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are comprised of a suture loop that may include passing sutures and/or metallic button. The suture loop and passing sutures are braided nonabsorbable surgical sutures. The button is made of titanium with holes to permit suture passage and assembly with Arthrex sutures.<br><br>The proposed devices are available in various device models referred to as TightRope® ABS, Implant; TightRope®, PCL; ACL TightRope® RT; ACL TightRope® II RT; ACL TightRope® II RT, Double Loaded Passing Sutures; BTB TightRope® II; BTB TightRope® II, Double Loaded Passing Sutures; and TightRope® II ABS, Implant Open. |
| Comparison Summary of Technological Characteristics and Modifications Proposed | The proposed devices have the same technological characteristics (device design, material, sterilization method, and biocompatibility profile). The proposed device modification is the addition of the pediatric patient population.<br><br>The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are substantially equivalent to the predicate device in which the design features and intended uses are the same. Any differences between the proposed device and the predicate devices are considered minor and do not result in new or different questions concerning safety or effectiveness |
| Indications for Use | The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are<br>intended to be used for fixation of bone to bone or soft tissue to bone, and are<br>intended as fixation posts, a distribution bridge, or for distributing suture<br>tension over areas of ligament or tendon repair. Specifically, Arthrex will be<br>offering these devices for ACL/PCL repair and reconstruction for the adult and<br>pediatric patient population. |
| Performance Data | Ultimate load testing and cyclic displacement was performed on the proposed<br>devices and compared to the predicate device. The test results demonstrate<br>that the proposed and predicate devices are equivalent.<br>Bacterial endotoxin per EP 2.6.14/USP <85> was conducted to demonstrate<br>that the device meets pyrogen limit specifications. |
| Clinical Literature | Clinical literature was provided on the subject devices involving the proposed<br>patient population of pediatric patients. The reviewed literature shows the<br>device is effective when used in the proposed patient population. |
| Real World<br>Data/Evidence | Real World Data/evidence is provided from the Surgical Outcomes System<br>registry. Based on the patient outcomes, there are no statistical differences in<br>patients less than 22 years of age versus patients greater than 22 years of age. |
| Conclusion | The Arthrex ACL TightRope®, PCL TightRope®, and TightRope® II devices are<br>substantially equivalent to the predicate devices in which the basic design<br>features and intended use are the same. Any differences between the<br>proposed device and the predicate devices are considered minor and do not<br>result in new or different questions concerning safety or effectiveness. Based<br>on the indications for use, technological characteristics, and the summary of<br>data submitted, Arthrex has determined that the proposed devices are<br>substantially equivalent to the currently marketed predicate device. |

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