DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service

Food and Drug Administration

10903 New Hampshire Avenue
Document Control Center - WO66-G609
Silver Spring, MD 20993-0002

September 29, 2017

CPT Sutures Co., Ltd.

℅ Ms. Natalya Valerio
Official Correspondent for CPT Sutures Co., Ltd.
MDI Consultants, Inc.
55 Northern Blvd., Suite 200
Great Neck, New York 11021

Re: K170166
Trade/Device Name: CARESORB® - Polyglactin 910 Surgical Suture, CARESORB
RAPID® - Polyglactin 910 (fast Absorbing) Surgical Suture
Regulation Number: 21 CFR 878.4493
Regulation Name: Absorbable Poly(Glycolide/L-Lactide) Surgical Suture
Regulatory Class: Class II
Product Code: GAM
Dated: August 31, 2017
Received: September 1, 2017

Dear Ms. Valerio:

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. 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
Page 2 – Ms. Natalya Valerio K170166

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 device-
related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product
radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please
contact the Division of Industry and Consumer Education (DICE) at its toll-free number (800)
638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 the CDRH's Office
of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the
Division of Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or
(301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

David Krause -S
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) SUMMARY

The assigned 510(k) number is: K170166

1. Submitter's Identification:

CPT Sutures Co., Ltd.

8 Dao Tri Street
Phu Thuan Ward
District 7, Ho Chi Minh, Vietnam

Date Summary Prepared: August 31, 2017

Contact: Mr. Khoa Do

Vice Director
CPT Sutures Co., Ltd.
e-mail: khoa.do@cpt-medical.com
phone: (+84) 28 38 222 228

2. Name of the Device:

Trade Name: CARESORB® - Polyglactin 910 Surgical Suture and

CARESORB® RAPID - Polyglactin 910 fast absorbing
Surgical Suture
Common Name: Suture, Absorbable, Synthetic, Polyglycolic Acid
Regulation Number: 21CFR 878.4493
Regulation Name: Absorbable Poly(glycolide/L-lactide) Surgical Suture
Regulatory Class: Class II
Product Code: GAM

3. Information for the 510(k) Cleared Device (Predicate Device):

Ethicon’s Coated VICRYL™ (Polyglactin 910) Synthetic Absorbable Suture,

510(k) # K022269

Ethicon’s Coated VICRYL™ Rapide (Polyglactin 910) Synthetic Absorbable Suture,

510(k) # K033746

4. Device Description:

The CARESORB® - Polyglactin 910 and CARESORB® RAPID - Polyglactin 910 are
multifilament, braided, sterile synthetic absorbable surgical sutures composed of a
copolymer of 90% glycolide and 10% L-lactide. The CARESORB® - Polyglactin 910
and CARESORB® RAPID - Polyglactin 910 are coated with copolymer of
Poly(glycolide-co-L-lactide) (30/70) and calcium stearate.

The CARESORB® - Polyglactin 910 suture is available dyed with FDA-approved

color additive D&C Violet No. 2 - CI 60725 or undyed in the natural beige color.

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The CARESORB® RAPID - Polyglactin 910 suture is available undyed in the natural
beige color only.

The CARESORB® sutures are available in USP sizes 6-0 through 1 and
CARESORB® RAPID sutures in USP sizes 4-0 through 2-0, in different lengths, with
or without a standard needle attached.

The CARESORB® and CARESORB® RAPID sutures meet USP Monograph for
Synthetic Absorbable Sutures, except for diameter.

5. Indications for Use:

CARESORB® - Polyglactin 910 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 or neurological tissues.

CARESORB® RAPID - Polyglactin 910 (fast absorbing) Surgical Sutures are

indicated for use in superficial soft tissue approximation of the skin and mucosa,
where only short-term wound support (7-10 days) is required, but not for use in
ligation, ophthalmic, cardiovascular or neurological procedures.

6. Comparison to the 510(k) Cleared Devices (Predicate Devices):

Comparison New Device New Device Predicate

Criteria CARESORB® - CARESORB® RAPID - Device(s)
Polyglactin 910 Polyglactin 910
Surgical Suture Surgical Suture
Predicate Device Ethicon’s Coated Ethicon’s Coated
VICRYL™ (Polyglactin VICRYL™ Rapide
910) Synthetic (Polyglactin 910)
Absorbable Suture, Synthetic
510(k) # K022269 Absorbable Suture,
510(k) # K033746
Classification Synthetic Synthetic Same
Absorbable Absorbable
Surgical Suture Surgical Suture

Indications General soft tissue Superficial soft tissue Same for each
for Use approximation and / or approximation of the skin respective
ligation, including use in and mucosa, where only predicate
ophthalmic procedures, short-term wound
but not in cardiovascular support (7-10 days) is
or neurological tissues required but not for use
in ligation, ophthalmic,
cardiovascular or
neurological procedures

Suture Material Copolymer of 90% Copolymer of 90% Same

glycolide and 10% glycolide and 10%
L-lactide L-lactide

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Material Multifilament, braided Multifilament, braided Same for each

Presentation respective
predicate

Coating Coated with copolymer Coated with copolymer Same

of Poly(glycolide-co-L- of Poly(glycolide-co-L-
lactide) (30/70) and lactide) (30/70) and
calcium stearate calcium stearate

Color Additive Available dyed with FDA- Available undyed only Same for each
approved color additive respective
D&C Violet No. 2 - CI predicate
60725 as well as undyed
in natural beige color

Sterilization Sterilized by Sterilized by VICRYL™ is

Ethylene Oxide Ethylene Oxide sterilized by
Ethylene Oxide

VICRYL™ Rapide
is sterilized by
Gamma Irradiation

Single Use Yes Yes Same

How Supplied Sutures of various Sutures of various Sutures of various

lengths and gauge sizes lengths and gauge sizes gauge sizes and
of USP 6-0 to 1, with or of USP 4-0 to 2-0, with lengths, with or
without the standard or without the standard without standard
stainless steel needle stainless steel needle stainless steel
(series 302 with silicon (series 302 with silicon needle attached.
coating) attached. coating) attached. Available as one-
Available as one-dozen Available as one-dozen dozen and three-
and three-dozen boxes. and three-dozen boxes. dozen boxes.

Absorption Suture absorption begins Suture absorption begins Same for each
Profile as a loss of tensile as a loss of tensile respective
strength followed by strength followed by predicate
eventual absorption by eventual absorption by
hydrolysis. Complete hydrolysis. Complete
absorption occurs absorption occurs in 42
between 56-70 days. days.

Breaking Percent Breaking Percent Breaking Same for each

Strength Strength Retention (% Strength Retention (% respective
Retention Profile BSR): > 65% at 14 days; BSR): 50% at 5 days; predicate
> 40% at 21 days. 0% at 14 days.

Suture Diameter Complies with Complies with Same

USP <861> except for USP <861> except for
slight oversize in the slight oversize in the
suture diameter suture diameter

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Suture Length ≥ 95% of the claimed ≥ 95% of the claimed Same

label length as required label length as required
by USP by USP

Needle Complies with Complies with Same

Attachment USP <871> USP <871>

Tensile Strength Complies with Complies with Same

USP <881> USP <881>

Biocompatibility Complies with all ISO Complies with all ISO Same
10993-1 required tests 10993-1 required tests
for absorbable surgical for absorbable surgical
sutures sutures

Packaging Validated sterile barrier Validated sterile barrier Same

packaging system packaging system

7. Discussion of Non-Clinical Tests Performed for Determination of Substantial

Equivalence:

The below referenced testing demonstrated substantial equivalence of the

CARESORB® - Polyglactin 910 Surgical Suture and CARESORB® RAPID -
Polyglactin 910 (fast absorbing) Surgical Suture to the Ethicon’s Coated VICRYL™
and Ethicon’s Coated VICRYL™ Rapide predicate devices respectively. The testing
was conducted on the final sterilized devices in accordance with the FDA Class II
Special Controls Guidance Document: Surgical Sutures.

Performance Testing:

1) ISO 10993-3 Biological Evaluation of Medical Devices – Part 3: Tests for

Genotoxicity, Carcinogenicity, and Reproductive Toxicity, 2014

2) ISO 10993-5 Biological Evaluation of Medical Devices – Part 5: Tests for In

Vitro Cytotoxicity, 2009 (R) 2014

3) ISO 10993-6 Biological Evaluation of Medical Devices – Part 6: Tests for Local
Effects after Implantation, 2007 (R) 2014

4) ISO 10993-7 Biological Evaluation of Medical Devices – Part 7: Ethylene Oxide

Sterilization Residuals, 2008 (R) 2012

5) ISO 10993-10 Biological Evaluation of Medical Devices – Part 10: Tests for
Irritation and Skin Sensitization, 2010 (R) 2014

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6) ISO 10993-11 Biological Evaluation of Medical Devices – Part 11: Tests for
Systemic Toxicity, 2006 (R) 2010

7) USP 39-NF33 Absorbable Surgical Suture, 2016

8) USP 39-NF33 <861> Sutures – Diameter, 2016

9) USP 39-NF33 <871> Sutures – Needle Attachment, 2016

10) USP 39-NF33 <881> Tensile Strength, 2016

11) ISO 11607-1 Section 5.2 Whole package microbial aerosol challenge test, 2014

12) ASTM F88/F88M-15 Standard Test Method for Seal Strength of Flexible Barrier
Materials, 2015

13) ASTM F1140/F1140M-13 Standard Test Methods for Internal Pressurization

Failure Resistance of Unrestrained Packages, 2013

14) ASTM F2096-11 Standard Test Method for Detecting Gross Leaks in Packaging
by Internal Pressurization (Bubble Test), 2011

15) USP39-NF 34 <71> Sterility Test, 2016

16) USP39-NF 34 <85> Bacterial Endotoxins Test, 2016

17) ISO 15223-1 Third Edition 2016-11-01, Medical Devices - Symbols To Be Used
With Medical Device Labels, Labelling, And Information To Be Supplied - Part 1:
General Requirements. (General I (QS/RM))

The biocompatibility test results demonstrated no evidence of cytotoxicity, irritation,

delayed dermal sensitization or acute systemic toxicity for CARESORB® Surgical
Suture. In the short-term, mid-term and long-term Intramuscular Implantation Tests
with Histopathology, the CARESORB® Surgical Suture was considered a non-irritant
as compared to the predicate VICRYL™ used as a control. In the mid-term
Intramuscular Implantation Test with Histopathology, the CARESORB® Rapid
Surgical Suture was considered a non-irritant as compared to the predicate
VICRYL™ Rapide used as a control.

The CARESORB® Suture was also found to be non-pyrogenic, non-mutagenic and

non-genotoxic.

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Resorption Profile:

The resorption profiles of the final sterilized sutures were demonstrated in vivo.

The CARESORB® sutures were compared to the predicate VICRYL™ sutures in

the in-vivo implantation study. The study results demonstrated that CARESORB®
sutures have similar tensile strength retention profile in comparison to the marketed
predicate VICRYL™ sutures.

The in-vivo breaking strength retention profile of CARESORB® RAPID was based
on the data provided by the suture material supplier from the in-vivo implantation
study. The resorption profile of CARESORB® RAPID was determined to be similar
to that of the marketed predicate VICRYL™ Rapide.

The resorption profile of the final sterilized CARESORB® RAPID suture was also
demonstrated in vitro.

The CARESORB® RAPID, sterilized by EtO, were compared to the predicate

VICRYL™ Rapide sutures, sterilized by gamma irradiation, and to the raw material
supplier’s sutures, sterilized by gamma irradiation. All sutures were immersed in
the phosphate buffer solution (pH 7.4) for 5, 14, 21 and 28 days and then tested for
breaking strength retention at each time point. The study results demonstrated that
all three sutures had essentially identical resorption profiles under the same study
conditions and that tensile strength and tensile strength retention of CARESORB®
RAPID was comparable to those of VICRYL™ Rapide and the raw material
supplier’s sutures.

Additionally, the rate of absorption of CARESORB® sutures was compared to that of

predicate VICRYL™ sutures in the in-vivo implantation study. The study results
demonstrated that CARESORB® sutures and VICRYL™ sutures have very similar
absorption in tissue.

The rate of absorption of CARESORB® RAPID was based on the data provided by
the suture material supplier from the in-vivo implantation study. The CARESORB®
RAPID rate of absorption in tissue was determined to be similar to that of the
marketed predicate VICRYL™ Rapide.

Shelf Life:

CARESORB® and CARESORB® RAPID sutures have been tested in real time
stability studies as well as in the accelerated aging studies.

The real time stability studies for both sutures were performed at 18°C to 26°C
temperature and relative humidity of no more than 65%. The accelerated aging
stability studies were performed at 68°C to 72°C temperature and relative humidity
of no more than 65% for CARESORB® and at 53°C to 57°C temperature and
relative humidity of no more than 65% for CARESORB® RAPID.

The aged sutures were tested for parameters specified in the USP Monograph for
Absorbable Surgical Sutures and other applicable requirements:

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• Diameter, USP 39 <861>

• Needle Attachment, USP 39 <871>
• Tensile Strength, USP 39 <881>
• In vitro Breaking Strength Retention (BSR)
• Visual Inspection
• Moisture content
• Sterility Testing, USP 39-NF34 <71>

The study results demonstrated conformance to the specified acceptance criteria

and supported the 5 year expiration date assignment for CARESORB® and
CARESORB® RAPID sutures.

8. Discussion of Clinical Tests Performed:

Not Applicable

9. Conclusions:

The CARESORB® - Polyglactin 910 and CARESORB® RAPID - Polyglactin 910

Surgical Sutures are composed of the same material, have the same intended use
and main technological characteristics as their respective predicate devices
Ethicon’s Coated VICRYL™ and Ethicon’s Coated VICRYL™ Rapide Surgical
Sutures.

Based on the results of completed performance testing inclusive of physical testing,

biocompatibility testing and absorption profile, it can be concluded that
CARESORB® - Polyglactin 910 and CARESORB® RAPID - Polyglactin 910 are
substantially equivalent in terms of safety and effectiveness to Ethicon’s Coated
VICRYL™ and Ethicon’s Coated VICRYL™ Rapide respectively.