Medline UNITE REFLEX Nitinol Staple System

{0}------------------------------------------------ April 22. 2021 Image /page/0/Picture/1 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. Medline Industries, Inc. Jennifer Mason Regulatory Affairs Senior Specialist Three Lakes Drive Northfield, Illinois 60093 Re: K210482 Trade/Device Name: Medline UNITE REFLEX Nitinol Staple System Regulation Number: 21 CFR 888.3030 Regulation Name: Single/Multiple Component Metallic Bone Fixation Appliances And Accessories Regulatory Class: Class II Product Code: JDR Dated: February 5, 2021 Received: February 19, 2021 Dear Jennifer Mason: 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); medical device reporting of medical device-related adverse events) (21 CFR 803) for {1}------------------------------------------------ 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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100). Sincerely. Vesa Vuniqi Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration # Indications for Use Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below. 510(k) Number (if known) #### K210482 Device Name Medline UNITE® REFLEX™ Nitinol Staple System Indications for Use (Describe) The Medline UNITE REFLEX Nitinol Staples are intended to provide fixation for fractures, fusions or osteotomies of the bones of the hand and foot such as : LisFranc arthrodesis, Akin Osteotomy, Scarf and Chevron osteotomies. Staples are intended for single use only. | 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 "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ K210482 Page 1 of 5 Image /page/3/Picture/1 description: The image shows the Medline logo. The logo features the word "MEDLINE" in white, bold, sans-serif font, stacked on top of a white abstract star shape. The background is a solid dark blue color. There is a small gray rectangle in the upper right corner of the image. Medline Industries, Inc. Three Lakes Drive Northfield. IL 60093 # 510(k) SUMMARY [AS REQUIRED BY 21CFR807.92(c)] ## Submitter / 510(k) Sponsor Medline Industries, Inc. Three Lakes Drive Northfield, IL 60093 Registration Number: 1417592 ## Contact Person Jennifer Mason Senior Regulatory Affairs Specialist Phone: 847-643-3652 Email: jamason@medline.com Summary Preparation Date March 2, 2021 Type of 510(k) Submission Traditional # Device Name / Classification Trade Name: Medline UNITE® REFLEX™ Nitinol Staple System Common Name: Staple, Fixation, Bone Classification Name: Single/multiple component metallic bone fixation appliances and accessories Product Code: JDR Classification Panel: Orthopedics Regulatory Class: Class II Regulation Number: 21 CFR 888.3030 # Predicate Device FuseForce Implant System K124045 ## Device Description The Medline UNITE® REFLEX™ Nitinol Staples are manufactured from nickel titanium alloy (Nitinol). The staples utilize chemical etching and passivation to form a protective oxidation layer on the outer surface. The system includes staples offered in a range of sizes from 8mm x 8mm to 25mm x {4}------------------------------------------------ Image /page/4/Picture/1 description: The image shows the Medline logo. The logo is set against a blue square background. The word "MEDLINE" is written in white, with a stylized white graphic above it that resembles a star or an abstract medical symbol. edline Industries. Inc Three Lakes Drive Northfield, IL 60093 27mm. The Medline UNITE® REFLEX™ Nitinol Staples are offered in three different bridge widths. The MNI features a 1.5mm bridge width, the MAX has a 4.0mm bridge width and the ULTRA has a 5.0mm bridge width. Table 1 below has a description of the staple sizes. #### TABLE 1: Staple Descriptions | Staple | Bridge Widths | Bridge Lengths | |--------------------------------------------|---------------|----------------| | Medline UNITE®<br>REFLEX™ MINI Staples | 1.5mm | 8 x 8mm | | | | 10 x 10mm | | | | 12 x 12mm | | Medline UNITE®<br>REFLEX™ MAX Staples | 4.0mm | 15 x 15mm | | | | 15 x 18mm | | | | 18 x 18mm | | | | 18 x 20mm | | | | 20 x 20mm | | Medline UNITE®<br>REFLEX™ ULTRA<br>Staples | 5.0mm | 20 x 20mm | | | | 25 x 20mm | | | | 25 x 25mm | | | | 25 x 27mm | The MAX and ULTRA staples have a chamfer on the bridge that is not present on the MINI version of the staples. A comparison of the proposed and predicate staples is included below in Tables 2 and 3. The system includes reusable instrumentation necessary to implant the staples, e.g. drill guides, drill bits, pins and an inserter. ## Indications for Use The Medline UNITE® REFLEX™ Nitinol Staples are intended to provide fixation for fractures, fusions or osteotomies of the bones of the hand and foot such as LisFranc arthrodesis, Akin osteotomy, Scarf and Chevron osteotomies. Staples are intended for single use only. # Summary of Technological Characteristics | Device Characteristic | Medline UNITE® REFLEX™<br>Nitinol Staples (Proposed) | FuseForce Implant System<br>(Predicate) | |-----------------------|------------------------------------------------------|-----------------------------------------| | 510(k) | TBD | K124045 | | Product Owner | Medline Industries, Inc. | Wright Medical Technology | #### TABLE 2: Comparison of Proposed and Predicate Devices {5}------------------------------------------------ Image /page/5/Picture/1 description: The image is a logo for Medline. The logo features the word "MEDLINE" in bold, white letters, stacked on top of a white, stylized starburst shape. The background is a solid, dark blue color. The logo is simple and clean, with a focus on the company name and a memorable graphic element. Medline Industries, Inc. Three Lakes Drive Northfield, IL 60093 | | | (previously Solana Surgical, LLC) | |---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Product Code | JDR | JDR | | Regulation Number | 21 CFR 880.3030 | 21 CFR 880.3030 | | Indications for Use | The Medline UNITE® REFLEX™<br>Nitinol Staples are intended to<br>provide fixation for fractures, fusions<br>or osteotomies of the bones of the<br>hand and foot such as LisFranc<br>arthrodesis, Akin osteotomy, Scarf<br>and Chevron osteotomies. Staples<br>are intended for single use only. | The Solana Surgical, LLC FuseForce<br>Implant System is intended to<br>provide fixation for fractures, fusions<br>or osteotomies of the bones of the<br>hand and foot such as LisFranc<br>arthrodesis, Akin osteotomy, Scarf<br>and Chevron osteotomies | #### TABLE 3: Comparison of Proposed and Predicate Staples | Device Characteristic | Medline UNITE® REFLEX™ Nitinol Staples (Proposed) | FuseForce Implant System (Predicate) | Comparison | |-------------------------|-------------------------------------------------------------|-------------------------------------------------------------------------------|------------| | Materials | Nickel Titanium Alloy (Nitinol) | Nickel Titanium Alloy (Nitinol) | Identical | | Design Feature | Straight top configuration | Straight top configurations | Identical | | Leg Lengths | 8mm<br>10mm<br>12mm<br>15mm<br>18mm<br>20mm<br>25mm<br>27mm | 8mm<br>10mm<br>12mm<br>13mm and 15mm (offset)<br>15mm<br>16mm<br>20mm<br>22mm | Similar | | Bridge Lengths | 8mm<br>10mm<br>12mm<br>15mm<br>18mm<br>20mm<br>25mm | 8mm<br>10mm<br>12mm<br>15mm<br>18mm<br>20mm<br>25mm | Identical | | Sterile vs. Non-Sterile | Non-sterile | Sterile - gamma | Different | - Indications for Use identical. The indications for use for the Medline UNITE® REFLEX™ . Nitinol Staples are identical to the predicate device. Both staple systems are intended to provide {6}------------------------------------------------ Image /page/6/Picture/1 description: The image features the logo of Medline, a healthcare company. The logo consists of the word "MEDLINE" in bold, white sans-serif font, positioned to the left of a stylized white starburst symbol. The starburst has four points, with the top and bottom points being longer than the side points. The background is a solid dark blue color, providing a strong contrast to the white text and symbol. Medline Industries, Inc. Three Lakes Drive Northfield. IL 60093 fixation for fractures, fusions or osteotomies of the hand and foot such as LisFranc arthrodesis. Akin osteotomy, Scarf and Chevron osteotomies. - Materials identical. Both the subject device and the predicate device are made from nickel ● titanium alloy (Nitinol) per ASTM F2063. - Design Features identical. Both the Medline UNITE® REFLEX™ Nitinol Staples and the . FuseForce staples feature a straight top design. - . Leg Lengths - similar. The subject device will be offered in sizes ranging from 8mm to 27mm. The predicate device leg lengths range from 8mm to 22mm. - Bridge Lengths identical. Both the Medline UNITE® REFLEX™ Nitinol Staples and the . FuseForce staples are offered in the exact same lengths and range from 8mm to 25mm. - . Sterility - the subject device will be offered non-sterile intended to be sterilized by steam sterilization. The predicate FuseForce staples are provided sterile. ## Summary of Non-Clinical Testing The following tests were performed in accordance with ASTM F564 to demonstrate substantial equivalence between the proposed Medline UNITE® REFLEX™ Nitinol Staples and the predicate FuseForce Implant System. ## Performance Testing (Bench) The following tests were performed in accordance with ASTM F2129 to demonstrate substantial equivalence between the proposed Medline UNITE® REFLEX™ Nitinol Staples and the predicate FuseForce Implant System. ## Elastic Static Bend Testing Elastic static bend testing was conducted per ASTM F564.A4. Testing was conducted to ensure that the proposed Medline UNITE® REFLEX™ Nitinol Staples are equivalent to the predicate FuseForce Implant System in bending stiffness. ## Constant Amplitude Bending Fatigue Testing Constant amplitude bend fatigue testing was conducted per ASTM F564.A1. Testing was conducted to ensure that the proposed Medline UNITE® REFLEX™ Nitinol Staples are equivalent to the predicate Fuseforce Implant System in bending fatigue. {7}------------------------------------------------ Image /page/7/Picture/1 description: The image shows the Medline logo. The logo is set against a blue square background. The word "MEDLINE" is written in bold, sans-serif font on the left side of the square. A white, stylized starburst symbol is placed to the right of the word, with its center aligned with the middle of the word. edline Industries. Inc. Three Lakes Drive Northfield. IL 60093 ## Pull-Out Strength Testing Pull-out strength testing was conducted per ASTM F564.A2. Testing was conducted to ensure that the proposed Medline UNITE® REFLEX™ Nitinol Staples are equivalent to the predicate Fuseforce Implant System in pull-out strength. ## Corrosion Susceptibility Testing Corrosion susceptibility testing was conducted per ASTM F2129 and the FDA guidance document Technical Considerations for Non-Clinical Assessment of Medical Devices Containing Nitinol. Testing was conducted to ensure that the proposed Medline UNITE® REFLEX™ Nitinol Staples meet criteria outlined in Corrosion Testing of Medical Implants . The risk based acceptance criteria used to determine acceptable corrosion susceptibility for the proposed device, were that all samples achieved electrostatic breakdown potential(Eb) equal to or greater than +400mV. ## Performance Testing (Animal) This section does not apply. No animal testing was performed. ## Performance Testing (Clinical) This section does not apply. No clinical testing was performed. Summary of Clinical Testing Not applicable. # Conclusion In accordance with 21 CFR Part 807, and based on the information provided in this premarket notification, Medline Industries, Inc. concludes that the Medline UNITE® REFLEX Nitinol Staple System is substantially equivalent to the predicate device, FuseForce Implant System.