NYLON

K993998 · Trading Consultants and Distributors Intl., Inc. · GAR · Feb 4, 2000 · General, Plastic Surgery

Device Facts

• Record ID: K993998
• Device Name: NYLON
• Applicant: Trading Consultants and Distributors Intl., Inc.
• Product Code: GAR · General, Plastic Surgery
• Decision Date: Feb 4, 2000
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.5020
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

NYLON is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.

Device Story

NYLON is a sterile, nonabsorbable surgical suture composed of long-chain aliphatic polymers (Nylon 6 and/or Nylon 6,6). It is provided as a monofilament thread, either coated or uncoated, and may be undyed or dyed with FDA-approved color additives (D&C Blue No. 2 or Logwood extract). The device is available with or without attached surgical needles. It is intended for use by surgeons in clinical settings for soft tissue approximation and ligation. The suture functions by providing mechanical support to tissues; it is not absorbed, though it may undergo progressive in vivo degradation resulting in gradual loss of tensile strength over time. Performance is verified against USP requirements for nonabsorbable surgical sutures. The device is supplied in dry, sterile packaging.

Clinical Evidence

No clinical data. Bench testing only. Conformance to USP standards for nonabsorbable surgical sutures, including physical properties and functionality testing, was used to demonstrate safety and effectiveness.

Technological Characteristics

Material: Nylon 6 and/or Nylon 6,6. Form: Monofilament, coated or uncoated. Sterilization: Gamma irradiation. Standards: USP requirements for nonabsorbable surgical suture; ISO 9002, EN 46002, EN 552. Packaging: Aluminum foil and polyester. Connectivity: None.

Indications for Use

Indicated for general soft tissue approximation and/or ligation in cardiovascular, ophthalmic, and neurological procedures. Prescription use only.

Regulatory Classification

Identification

Nonabsorbable polyamide surgical suture is a nonabsorbable, sterile, flexible thread prepared from long-chain aliphatic polymers Nylon 6 and Nylon 6,6 and is indicated for use in soft tissue approximation. The polyamide surgical suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. monograph for nonabsorbable surgical sutures; it may be monofilament or multifilament in form; 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

• DERMALON Non-Absorbable Polyamide Surgical Sutures (Davis & Geck)
• Ethilon Nonabsorbable Polyamide Surgical Suture (Ethicon, Inc.)

Submission Summary (Full Text)

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FEB. 4 2000 K 493948

T.CAD International 991001/MG-510(k) NYLON

## SECTION III

# 510(K) Summary of Safety and Effectiveness

This summary of safety and effectiveness information is being submitted in accordance with the requirements of the Safe Medical Devices Act (SMDA) of 1990 and Title 21 CFR §807.92

A. Applicant & Submitted By:

Trading Consultants And Distributors International Inc. (T.CAD International) 157 WindDance Dr. Chicago, IL 60046-6681 Telephone: [phone] Fax. : [phone] Contact Person: Main M. Ghazal, President October 1ª 1999. Date Prepared:

#### B. Device Name:

- Trade Name: NYLON ત્વ.
- Common or Usual Name: Polyamide Surgical Suture b.
- Classification Name: Nonabsorbable Polyamide Surgical Suture C. (Per 21CFR878.5020)

### C. Predicate Device:

DERMALON® Non-Absorbable Polyamide Surgical Sutures of Davis & Geck Ethilon® Nonabsorbable Polyamide Surgical Suture (Ethicon, Inc.)

#### D. Device Description:

NYLON is a nonabsorbable sterile surgical suture composed of the long-chain aliphatic polymers Nylon 6 and/or Nylon 6,6.

NYLON meets all requirements established by the United States Pharmacopeia (USP) for Nonabsorbable Surgical Suture. Offered as monofilament in form, it maybe offered coated or uncoated, undyed and dyed with an appropriate FDA listed color additive, D&C Blue No. 2. (21CFR74.3102) or Logwood extract, C.I. Natural Black 1. (21CFR74.1410). NYLON will be offered with or without standard needles attached.

#### E. Intended Use:

NYLON is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.

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T.CAD International
991001/MG-510(k)
NYLON

| | NYLON | Predicate Device |
|-------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | General soft tissue approximation<br>and/or ligation, including use in<br>cardiovascular, ophthalmic and<br>neurological procedures. | General soft tissue approximation<br>and/or ligation, including use in<br>cardiovascular, ophthalmic and<br>neurological procedures. |
| Suture Material | L-chain aliphatic polymers Nylon<br>6 and/or Nylon 6,6. | L-chain aliphatic polymers Nylon<br>6 and/or Nylon 6,6. |
| Suture<br>Characteristics | Not absorbed, progressive<br>degradation of the nylon in vivo<br>may result in gradual loss of all of<br>the suture's tensile strength over<br>time. | Not absorbed, progressive<br>degradation of the nylon in vivo<br>may result in gradual loss of all of<br>the suture's tensile strength over<br>time. |
| Sterilization Method | Gamma Irradiation | Same or equivalent method. |
| How Supplied | Monofilament thread, coated or<br>uncoated, undyed or dyed with an<br>FDA listed color additive.<br>Sterile and offered for Single Use<br>Only. Available with or without<br>surgical needle. | Same of equivalent manner.<br>Monofilament, uncoated, undyed<br>or dyed with the same FDA listed<br>colorants (Blue or Black).<br>Available with or without needles. |
| Suture Diameter,<br>Suture Length,<br>Knot Pull Tensile<br>Strength and Needle<br>Attachment Strength | Meet U.S.P. Requirements | Meet U.S.P. Requirements |
| Packaging | Dry packaged in Aluminum Foil<br>and Polyester tear open packaging. | Same or equivalent manner |
| Labeling | In conformance with CDRH<br>instructions of the "Medical<br>Device Quality Manual" dated<br>December 1996. Package Inserts<br>in accordance with the FDA<br>Guidance documents "Alternate<br>Suture Labeling" Resulting from<br>the January 11th 1993 meeting with<br>HIMA, reformatted on December<br>17th 1997 | Same |

## F. Comparison to Predicate Device:

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T.CAD International 991001/MG-510(K) NYLON

#### G. Clinical & Non-Clinical Testing:

Non-Clinical Testing was conducted on the subject device to prove conformance to the requirements of U.S.P. standards and to demonstrate substantial equivalence to the predicate device. Physical properties and functionality testing assured the safety and effectiveness of the subject device within its intended uses. Results of the non-clinical testing demonstrate conformance with the U.S.P. standards and requirements for Absorbable surgical suture.

Clinical Testing: Not available at the present time.

### H. Conclusion:

Based on the detailed device description, the intended use of the device, the technological characteristics and physical properties of the device, performance testing and conformance with voluntary performance standards like:

- a. United States Pharmacopeia Standards.
- b. ISO 9002, EN 46002 & EN 552 Standards
- FDA Guidance documents " Alternate Suture Labeling" Resulting from c. the January 11th 1993 meeting with HIMA,

T.CAD International believes that the subject device demonstrates a substantial equivalence to the predicate device.

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Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the United States. The seal features a stylized caduceus, a symbol often associated with medicine and healthcare, consisting of a staff with two snakes coiled around it. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

FEB 4 2000

Mr. Main M. Ghazal Trading Consultants and Distributors International, Inc. 157 WindDance Drive Chicago, Illinois 60046-6681

K993998 Re: Trade Name: Nylon Regulatory Class: II Product Code: GAR Dated: November 22, 1999 Received: November 24, 1999

Dear Mr. Ghazal:

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 that were regulated as transitional devices and that have been reclassified into class II. Notice of this reclassification was published in the Federal Register on Friday, May 31, 1991 (Vol. 56, No. 105, Pages 24684 and 24685). A copy of this Federal Register can be obtained by calling the Division of Small Manufacturers Assistance (DSMA) at [phone] or [phone]. You may, therefore, market the device, subject to the general controls provisions of the Federal Food, Drug, and Cosmetic Act (Act) and the following limitations:

- 1. The Nylon Surgical Suture is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.
- 2. This device may not be manufactured from any long chain aliphatic polymers other than nylon 6 and/or nylon 6,6. In addition, you must maintain documentation at your premises regarding vendor certification for raw or semiprocessed source material, all manufacturing and quality control release procedures, and validation of sterilization procedures used in the manufacture of the Nylon surgical suture. Any deviation of the source material or processing as described in this 510(k) notification requires submission of a new premarket notification and Food and Drug Administration (FDA) clearance prior to commercial distribution of the modified device.

The sale, distribution and use of this device are restricted to prescription use in accordance with 21 CFR 801.109.

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Page 2 - Mr. Main M. Ghazal

The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practices, labeling, and prohibition against misbranding and adulteration.

Existing major regulations affecting your device can be found in the Code of Federal Regulations (CFR), Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Good Manufacturing Practices (GMP) for Medical Devices: General GMP regulation (21 CFR Part 820) and that, through periodic GMP 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.

This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally 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 diagnostic devices), please contact the Office of Compliance at [phone]. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at [phone]. 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 [phone] or [phone] or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,

Nat. R.P. Ogden.

James E. Dillard III Acting Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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K993998

T.CAD International 991001/MG-510(k) NYLON

## SECTION II

# Statement of indication for use

Device Name: NYLON

510(k) Number:

Indication for use:

NYLON is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.

(PLEASE DO NOT WRITE BELOW THE LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY)

#### Concurrence of CDRH, Office of Device Evaluation (ODE)

**Prescription Use** √
(Per 21CFR 801.109)

OR Over-the-Counter Use

7

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(Division Sign-Off) (Division of General Restorative Devir" ( 99 3998