Force Fiber White and White/Blue, White/Black, Blue, and White/Green sutures; Force Fiber OrthoTape suture; Bondek suture and Bondek Plus suture; Monodek suture; Polyglytone*6211 suture
K181774 · Teleflex Medical Incorporated · GAT · Oct 10, 2018 · General, Plastic Surgery
Device Facts
Record ID
K181774
Device Name
Force Fiber White and White/Blue, White/Black, Blue, and White/Green sutures; Force Fiber OrthoTape suture; Bondek suture and Bondek Plus suture; Monodek suture; Polyglytone*6211 suture
Applicant
Teleflex Medical Incorporated
Product Code
GAT · General, Plastic Surgery
Decision Date
Oct 10, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.5000
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
Force Fiber® Non-absorbable Surgical Sutures are indicated for use in approximation and/or ligation of soft tissues, including use in cardiovascular surgeries and the use of allograft tissue for orthopedic surgeries. Force Fiber®OrthoTape® Suture is indicated for use in approximation and/or ligation of soft tissues, including use of allograft tissue for orthopedic surgeries. Bondek® and Bondek® Plus Synthetic Absorbable Surgical Sutures are intended for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in and neurological procedures. Monodek Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in all types of soft tissue approximation, including use in pediatric cardiovascular tissue where growth is expected to occur and ophthalmic surgery. Monodek® suture is not indicated in adult cardiovascular tissue, microsurgery and neural tissue. These sutures are particularly useful where the combination of an absorbable suture and extended wound support (up to six weeks) is desirable. Polyglytone*6211™ Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular surgery, neurological surgery, or microsurgery.
Device Story
Surgical sutures for soft tissue approximation/ligation; includes non-absorbable UHMWPE (Force Fiber/OrthoTape) and absorbable synthetic (Bondek, Monodek, Polyglytone 6211) variants. Devices provided sterile (EO), single-use; available in various USP sizes, colors, and needle attachments. Used by surgeons in OR settings. Function via mechanical tissue approximation; provide wound support. MR Safe status confirmed via non-clinical testing. No changes to fundamental design or technology compared to predicates; labeling updated to include MR Safe claim.
Clinical Evidence
Bench testing only. Non-clinical testing performed to validate MR Safe claim for permanently implanted devices.
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
Force Fiber White and White Blue Co-Braid Polyethylene Non-Absorbable Surgical Suture (K063778)
Force Fiber Black Co-Braid Polyethylene Non-Absorbable Surgical Suture (K070673)
Force Fiber Blue Ultra High Molecular Weight Polyethylene Non Absorbable Sutures (K092533)
Force Fiber Green Ultra High Molecular Weight Polyethylene Non Absorbable Sutures (K100506)
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Image /page/0/Picture/0 description: The image shows 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.
October 10, 2018
Teleflex Medical Incorporated Ms. Andrea Curria Regulatory Affairs Specialist 375 Forbes Boulevard Mansfield, Massachusetts 02048
Re: K181774
Trade/Device Name: Force Fiber White and White/Blue, White/Black, Blue, and White/Green sutures: Force Fiber OrthoTape suture: Bondek suture and Bondek Plus suture; Monodek suture; Polyglytone*6211 suture Regulation Number: 21 CFR 878.5000 Regulation Name: Nonabsorbable Poly (Ethylene Terephthalate) Surgical Suture Regulatory Class: Class II Product Code: GAT, GAM, NEW Dated: June 25, 2018 Received: July 3, 2018
Dear Ms. Curria:
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.
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Peter L. Hudson -S 2018.10.10 15:42:23 -04'00'
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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510(k) Number (if known) K181774
Device Name Force Fiber® Suture
Indications for Use (Describe)
Force Fiber® Non-absorbable Surgical Sutures are indicated for use in approximation and/or ligation of soft tissues, including use in cardiovascular surgeries and the use of allograft tissue for orthopedic surgeries.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <input type="checkbox"/> Prescription Use (Part 21 CFR 201 Subpart D) | <input type="checkbox"/> Over-The-Counter Use (21 CFR 201 Subpart C) |
|-----------------------------------------------------------------------|----------------------------------------------------------------------|
|-----------------------------------------------------------------------|----------------------------------------------------------------------|
> Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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{3}------------------------------------------------
510(k) Number (if known) K181774
Device Name Force Fiber®OrthoTape® Suture
Indications for Use (Describe)
Force Fiber®OrthoTape® Suture is indicated for use in approximation and/or ligation of soft tissues, including use of allograft tissue for orthopedic surgeries.
Type of Use (Select one or both, as applicable)|X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
### CONTINUE ON A SEPARATE PAGE IF NEEDED.
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#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{4}------------------------------------------------
510(k) Number (if known) K181774
Device Name Bondek® and Bondek® Plus Suture
Indications for Use (Describe)
Bondek® and Bondek® Plus Synthetic Absorbable Surgical Sutures are intended for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in and neurological procedures.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
|X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{5}------------------------------------------------
510(k) Number (if known) K181774
Device Name Monodek® Suture
Indications for Use (Describe)
Monodek Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in all types of soft tissue approximation, including use in pediatric cardiovascular tissue where growth is expected to occur and ophthalmic surgery. Monodek® suture is not indicated in adult cardiovascular tissue, microsurgery and neural tissue. These sutures are particularly useful where the combination of an absorbable suture and extended wound support (up to six weeks) is desirable.
Type of Use (Select one or both, as applicable)
| <span style="text-decoration: underline;"><b>Prescription Use (Part 21 CFR 801 Subpart D)</b></span> | Over The Counter Use (21 CFR 801 Subpart C) | | |
|------------------------------------------------------------------------------------------------------|---------------------------------------------|-------------------------------------------------------------------------------------|-------------|
| <div> <table border="1"><tbody><tr><td><div></div></td></tr></tbody></table> </div> | <div></div> | <div> <table border="1"><tbody><tr><td><div></div></td></tr></tbody></table> </div> | <div></div> |
| <div></div> | | | |
| <div></div> | | | |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{6}------------------------------------------------
510(k) Number (if known) K181774
Device Name Polyglytone*6211TM Suture
Indications for Use (Describe)
Polyglytone*6211™ Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular surgery, neurological surgery, or microsurgery.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <label> <input checked="checked" type="checkbox"/> Prescription Use (Part 21 CFR 201 Subpart D) </label> |
|----------------------------------------------------------------------------------------------------------------|
| <label> <input type="checkbox"/> Over-The-Counter Use (21 CFR 201 Subpart G) </label> |
| > Prescription Use (Part 21 CFR 801 Subpart D)
|__ Over-The-Counter Use (21 CFR 801 Subpart C)
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
{7}------------------------------------------------
## 510(k) Summary of Safety and Effectiveness
This 510(k) Summary for Teleflex Surgical Sutures is provided as required by section 807.92(c).
| A. Sponsor/Applicant: | Teleflex Medical Inc.<br>375 Forbes Boulevard<br>Mansfield, MA 02048 USA<br>FDA Establishment Registration #: 1221601 |
|-----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------|
| B. Date Prepared: | June 20, 2018 |
| C. Contact: | Andrea Curria<br>Regulatory Affairs Specialist, OEM<br>Phone: 1-508-964-6030<br>Mobile 1-401-529-0233<br>Fax: 1-508-964-6078<br>Andrea.Curria@teleflex.com |
| D. Device Name | |
| Proprietary Name: | Force Fiber® Suture |
| Common Name: | Suture, Nonabsorbable, Synthetic, Polyethylene |
| Classification Name: | Suture, Nonabsorbable, Synthetic, Polyethylene |
| Regulation Number: | 21CFR § 878.5000 |
| Product Code: | GAT |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
| Proprietary Name: | Force Fiber® OrthoTape® Suture |
| Common Name: | Suture, Nonabsorbable, Synthetic, Polyethylene |
| Classification Name: | Suture, Nonabsorbable, Synthetic, Polyethylene |
| Regulation Number: | 21CFR § 878.5000 |
| Product Code: | GAT |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
| Proprietary Name: | Bondek® and Bondek® Plus Suture |
| Common Name: | Suture, Absorbable, Synthetic, Polyglycolic Acid |
| Classification Name: | Suture, Absorbable, Synthetic, Polyglycolic Acid |
| Regulation Number: | 21CFR § 878.4493 |
| Product Code: | GAM |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
| Proprietary Name: | Monodek® Suture |
| Common Name: | Suture, Surgical, Absorbable, Polydioxanone |
| Classification Name: | Suture, Surgical, Absorbable, Polydioxanone |
| Regulation Number: | 21CFR § 878.4840 |
| Product Code: | NEW |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
| Proprietary Name: | Polyglytone*6211TM Suture |
| Common Name: | Suture, Absorbable, Synthetic, Polyglycolic Acid |
| Classification Name: | Suture, Absorbable, Synthetic, Polyglycolic Acid |
| Regulation Number: | 21CFR § 878.4493 |
| Product Code: | GAM |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
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## E. Device Descriptions
Force Fiber Suture is a non-absorbable, sterile, surgical suture composed of Ultra High Molecular Weight Polyethylene (UHMWPE). It is available as follows:
| Force Fiber<br>color | Material | Available<br>USP sizes |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|
| White | Braided undyed (white) UHMWPE fibers. | 5-0<br>through 5 |
| Blue | Braided blue UHMWPE fibers. The blue colorant is Chromium-cobalt-<br>aluminum oxide < 2.0% by weight per 21 CFR 73.1015. | 0, 1, 2 |
| White/Blue | Co-braid of white UHMWPE and blue polypropylene (PP)<br>monofilament strands. The blue colorant is [phthalocyaninato (2-)]<br>copper < 0.5% by weight per 21 CFR 74.3045. | 5-0<br>through 5 |
| White/Black | Co-braid of white UHMWPE fibers and black Nylon monofilament<br>strands. The black colorant is logwood extract < 1.0% by weight per 21<br>CFR §73.1410. | 5-0<br>through 5 |
| White/Green | Co-braid of white UHMWPE fibers and green polyester (PET)<br>fibers. The green colorant is D&C Green #6 < 0.75% by weight<br>per 21 CFR 74.3206. It should be noted that Force Fiber® Green<br>Co-braid may appear blue in color under certain lighting<br>conditions. | 0, 1, 2 |
Table 1: Force Fiber suture available configurations
Force Fiber surgical sutures meet all surgical suture requirements established by the USP for non-absorbable surgical sutures except for oversized diameter.
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Force Fiber OthoTape Suture is an uncoated braid that is flat in shape and differs from USP requirements (not USP). It is available in 1mm, 1.5mm, 2.5mm, 3.5mm, 4mm and 5mm tape sizes and composed of undyed or blue Ultra High Molecular Weight Polyethylene (UHMWPE), or UHMWPE/ Green Polyester co-braid. Force Fiber OrthoTape suture sizes meet USP tensile strength requirements and USP needle attachment requirements for USP size #2 suture.
Bondek and Bondek Plus Suture is an absorbable, braided multifilament suture composed of a homopolymer of glycolic acid, polyglycolic acid. The Bondek suture material is coated with polycaprolactone-glycerol monostearate solution, and is available in green and beige (undyed) USP sizes 8-0 through 2. The Bondek Plus suture material is coated with polycaprolactone-co-polygolycolic acid, and is available in violet, green or beige (undyed) USP sized 6-0 through2.
Monodek Absorbable Surgical Suture is a monofilament suture that meets all USP requirements except for oversize diameter. Monodek is available in sizes 6-0 through 0 (metric sizes 0.7 through 3.5), undyed and dyed (violet). The suture may be supplied on ligating reels.
Polyglytone* 6211 suture, U.S.P size 2-0, is available, undyed (natural). The suture is monofilament, and may be provided with or without plegets.
The Teleflex surgical sutures are provided sterile (EO), for singe use only and may be provided in a variety of cut lengths with or without needles. A variety of attached needles are available from either 300 or 400 series stainless steel.
## F. Indications for Use
Indications for Use: Force Fiber® Non-absorbable Surgical Sutures are indicated for use in approximation and/or ligation of soft tissues, including use in cardiovascular surgeries and the use of allograft tissue for orthopedic surgeries.
Contraindications: None known.
Indications for Use: Bondek® Synthetic Absorbable Surgical Sutures are intended for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular and neurological procedures. Contraindications: None known.
Indications for Use: Bondek® and Bondek® Plus Synthetic Absorbable Surgical sutures are intended for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular and neurological procedures.
{10}------------------------------------------------
Contraindications: This suture, being absorbable, should not be used where extended approximation of tissue is required.
Indications for Use: Monodek® Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in all types of soft tissue approximation, including use in pediatric cardiovascular tissue where growth is expected to occur and ophthalmic surgery. Monodek® suture is not indicated in adult cardiovascular tissue, microsurgery and neural tissue. These sutures are particularly useful where the combination of an absorbable suture and extended wound support (up to six weeks) is desirable.
Contraindications: These sutures, being absorbable, are not to be used where prolonged (beyond six weeks) approximation of tissues under stress is required and are not to be used in conjunction with prosthetic devices, i.e. heart valves or synthetic grafts.
Indications for Use: Polyglytone*6211™ Monofilament Synthetic Absorbable Surgical Sutures are indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular surgery, neurological surgery, or microsurgery.
## Contraindications
This suture, being absorbable, should not be used where extended approximation of tissue is required
## G. Substantial Equivalence
The proposed Teleflex Nonabsorbable and Absorbable Surgical Sutures are substantially equivalent to the predicate devices:
| Predicate Device | Manufacturer | 510(k) No. | Date Cleared |
|------------------------------------------------------------------------------------------|------------------|------------|--------------|
| Force Fiber White and White Blue Co-Braid<br>Polyethylene Non-Absorbable Surgical Suture | Teleflex Medical | K063778 | 2/09/2007 |
| Force Fiber Black Co-Braid Polyethylene Non-<br>Absorbable Surgical Suture | Teleflex Medical | K070673 | 4/2/2007 |
| Force Fiber Blue Ultra High Molecular Weight<br>Polyethylene Non Absorbable Sutures | Teleflex Medical | K092533 | 9/15/2009 |
| Force Fiber Green Ultra High Molecular Weight<br>Polyethylene Non Absorbable Sutures | Teleflex Medical | K100506 | 3/10/2010 |
| Force Fiber OrthoTape Suture | Teleflex Medical | K150438 | 04/02/2015 |
| Bondek Polyglycolic Acid Synthetic<br>Absorbable Surgical Suture | Teleflex Medical | K991191 | 06/22/1999 |
| Bondek Plus Polyglycolic Acid Synthetic<br>Absorbable Surgical Suture | Teleflex Medical | K992088 | 09/03/1999 |
| Monodek Synthetic Absorbable Surgical Suture | Teleflex Medical | K030212 | 03/27/2003 |
| Polyglytone 6211 Synthetic Absorbable Suture | Teleflex Medical | K042141 | 09/28/2004 |
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## H. Technological Characteristics
Teleflex Surgical Sutures are equivalent to the marketed predicate devices because there are no differences in technological characteristics and performance characteristics between the proposed and predicate devices. The proposed sutures have the same fundamental design and intended use as the predicate devices. The addition of an MR Safety statement does not raise new questions of safety or efficacy. The proposed Teleflex Surgical Sutures are substantially equivalent in intended use and fundamental scientific technology to their predicate devices.
## I. Summary of Testing
Teleflex Surgical Sutures are not intended for use in the MR Environment. However, permanently implanted devices are subject to MR conditions. Non-clinical testing was completed to demonstrate the "MR Safe" claim. Teleflex Surgical Sutures are "MR Safe" and pose no known hazards in MR environments. The Indication for Use (IFU) inserts are being updated to include the "MR Safe" claim.
## Conclusion
Based upon the comparative test results, the proposed Teleflex Surgical Sutures are substantially equivalent in performance to the legally marketed predicate devices.
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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).
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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.
Where do you find a device's intended use without opening the PDF?
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.
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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.
3. Judging fuzzy relevance
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 a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
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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.
What does the side-by-side PDF viewer mode do?
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Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
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.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
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.