INNOVASIVE 2.8MM AND 3.5MM ROC EZ SUTURE BONE FASTENER
K971922 · Innovasive Devices, Inc. · MBI · Aug 7, 1997 · Orthopedic
Device Facts
Record ID
K971922
Device Name
INNOVASIVE 2.8MM AND 3.5MM ROC EZ SUTURE BONE FASTENER
Applicant
Innovasive Devices, Inc.
Product Code
MBI · Orthopedic
Decision Date
Aug 7, 1997
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3040
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The 2.8mm and 3.5mm ROC EZ Suture Bone Fasteners are intended for the reattachment of soft tissue to bone for the following indications: SHOULDER - 1. Repair of rotator cuff tears - 2. capsular instability - 3. slap lesion repair - 4. acromio-clavicular separation - 5. capsule shift/capsulolabral reconstruction - 6. biceps tenodesis - 7. deltoid repair KNEE 1. Extra-capsular repairs, and reattachment of medial collateral ligament, lateral collateral ligament, posterior oblique ligament, joint capsule closure. 2. Patellar ligament and tendon avulsion repairs. 3. Extra-capsular reconstruction, ITB tenodesis ANKLE - 1. Lateral instability - 2. Medial instability - 3. Achilles tendon reconstruction and repair - 4. Mid-foot reconstructions FOOT - 1. Hallux valgus reconstruction ELBOW - Tennis elbow repair 1. Biceps tendon reattachment 2. Medial and lateral repairs 3. BLADDER NECK SUSPENSION 1. Bladder neck suspension for female urinary incontinence due to urethral hypermobility.
Device Story
Bone fastener implant for soft tissue-to-bone reattachment; consists of shear pin, expander, and sleeve. Deployment: expander drawn into sleeve via shear pin pull; sleeve expands to create radial compression against bone hole; shear pin breaks off upon seating. Used in orthopedic/surgical procedures (shoulder, knee, ankle, foot, elbow, bladder neck suspension). Operated by surgeons. Instrumentation includes stainless steel drill, drill guide, obturator, deployment handle, and hole finder. Available in sterile, single-use versions (open/arthroscopic, sutured/sutureless). Benefits: secure fixation of soft tissue to bone.
Clinical Evidence
Bench testing only. Bone model testing compared ultimate holding strength of modified device to predicate device. Results confirmed equivalent holding strength.
Technological Characteristics
Materials: high density polyethylene and polysulfone. Principle: radial compression via mechanical expansion of sleeve. Dimensions: 2.8mm and 3.5mm. Connectivity: none. Sterilization: autoclave for reusable instrumentation; sterile for single-use fastener.
A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.
Predicate Devices
Innovasive Devices ROC EZ Suture Bone Fastener (K971922)
Submission Summary (Full Text)
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K971922 1 of 2
### 510(K) SUMMARY
AUG - 7 1997
### 1. SUBMITTER:
Innovasive Devices, Inc. 734 Forest St. Marlborough, MA 01752 Telephone: 508-460-8229
Contact: Stephen M. Page, Manager of Regulatory Affairs Date Prepared: May 21, 1997
### 2. DEVICE:
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Innovasive 2.8mm and 3.5mm ROC EZ Suture Bone Fastener Classification Name: Single/multiple component bone fixation appliances and accessories. Trade Name: Innovasive Devices ROC EZ Suture Bone Fastener
#### 3. PREDICATE DEVICE:
The predicate device used to determine substantial equivalence for the modified Innovasive Devices ROC EZ Suture Bone Fastener was the 2.8mm and 3.5mm Innovasive Devices ROC EZ Suture Bone Fastener, marketed by Innovasive Devices, Marlborough, MA.
#### 4. DEVICE DESCRIPTION:
The ROC EZ suture bone fastener implant tip portion consists of a shear pin, expander and sleeve. The expander and sleeve is fitted onto the shear pin component such that the expander component is located below the sleeve on the shear pin. As the shear pin is pulled up during the device deployment, the expander engages the sleeve. The expander is tapered such that it will fit into the sleeve component as the deployment action progresses. As the expander is drawn into the sleeve, the sleeve expands to make contact with the surrounding bone. This expanding sleeve results in the final fixation properties of the device. Once the expander is completely seated inside the sleeve, the shearing pin shears from the fastener assembly resulting in the device being fixated into the bone hole.
In addition to the Fastener, a stainless steel drill and drill guide is available to establish the proper hole in the bone for the Fastener along with an obturator, deployment handle and hole finder. All of the instrumentation except the Fastener will be offered as reusable devices and can be autoclaved in the sterilization tray provided for this purpose.
The Fastener will be available as a sterile, single use device in both an open and arthroscopic version. Both sutured and sutureless versions will be marketed.
### 5. INTENDED USE:
The 2.8mm and 3.5mm ROC EZ Suture Bone Fasteners are intended for the reattachment of soft tissue to bone for the following indications:
C.P.I.A.
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K971922 2 af 2
### SHOULDER
- 1. Repair of rotator cuff tears
- 2. capsular instability
- 3. slap lesion repair
- 4. acromio-clavicular separation
- 5. capsule shift/capsulolabral reconstruction
- 6. biceps tenodesis
- 7. deltoid repair
### KNEE
1. Extra-capsular repairs, and reattachment of medial collateral ligament, lateral collateral ligament,
posterior oblique ligament, joint capsule closure.
2. Patellar ligament and tendon avulsion repairs.
3. Extra-capsular reconstruction, ITB tenodesis
### ANKLE
- 1. Lateral instability
- 2. Medial instability
- 3. Achilles tendon reconstruction and repair
- 4. Mid-foot reconstructions
### FOOT
- 1. Hallux valgus reconstruction
### ELBOW
、
バ
- Tennis elbow repair 1.
- Biceps tendon reattachment 2.
- Medial and lateral repairs 3.
#### BLADDER NECK SUSPENSION
1. Bladder neck suspension for female urinary incontinence due to urethral hypermobility.
### 6. COMPARISON OF CHARACTERISTICS:
The existing Innovasive Devices ROC EZ Suture Bone Fastener is comprised of two polymer components, high density polyethylene and acetyl plastic. This device is used to secure a suture in a predrilled hole in bone. It remains fixed in the bone through radial compression as the device is deployed. This remains true for all sizes of the device.
The modified ROC EZ device is comprised of high density polyethylene and polysulfone. As with the predicate device, the modified ROC EZ uses an expander fitted on a shear pin which is drawn up into an expandable sleeve. The sleeve expands as the expander is drawn up into it. The shear pin then shears resulting in the device being fixed into the bone site.
### 7. PERFORMANCE DATA:
The following performance data was provided in support of the substantial equivalence determination:
- 1. Bone model testing: Comparison of the ultimate holding strength in a bone model compared to the predicate device. The Innovasive ROC EZ Suture Bone Fastener holding strength was found to be equivalent to the strength of the predicate device.
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
. -
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. Stephen M. Page 'Manager of Regulatory Affairs Innovasive Devices, Inc. 734 Forest Street Marlborough, Massachusetts 01752
Re : K971922 Innovasive 2.8mm and 3.5mm ROC™ EZ Suture Bone Fastener Requlatory Class: II Product Codes: MBI and HRX Dated: May 21, 1997 Received: May 23, 1997
Dear Mr. Page:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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). 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
Image /page/2/Picture/8 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized depiction of an eagle with three heads, symbolizing service to the nation. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged around the eagle in a circular fashion.
AUG - 7 1997
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## Page 2 - Mr. Stephen M. Page
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA findinq of substantial equivalence of your device to a leqally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diaqnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to
premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.qov/cdrh/dsmamain.html".
Sincerely yours,
Celia M. Witten, Ph.D. M.D.
Cella M. Witten, Ph.D., M.D. Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radioloqical Health
Enclosure
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## INDICATIONS FOR USE
### SHOULDER
Bankart repair Repair of rotator cuff tears capsular instability slap lesion repair acromio-clavicular separation capsule shift/capsulolabral reconstruction biceps tenodesis deltoid repair
### KNEE
Extra-capsular repairs reattachment of medial collateral ligament reattachment of lateral collateral ligament reattachment of posterior oblique ligament joint capsule closure patellar ligament and tendon avulsion repairs extra-capsular reconstruction ITB tenodesis.
### ANKLE
Lateral and medial instability : achilles tendon reconstruction and repair mid-foot reconstructions.
### FOOT
Hallux valgus reconstruction
### ELBOW
Tennis elbow repair Biceps tendon reattachment Medial and lateral repairs
## BLADDER NECK SUSPENSION
Bladder neck suspension for temale urinary incontinence due to urethral hypermobility.
bcoello
**Prescription Use**
(Per 21 CFR 801.109)
Division Sign-Off
Division of General Restorative Devices
510(k) Number K971922
0094
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
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Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
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Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
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Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
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Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.