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510(k) Data Aggregation
(59 days)
The Freedom® Total Knee System is indicated for the following:
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present (For PCK Components, and Primary PCK Components, and Metaphyseal Cones only).
The Freedom Porous Tibial Base Plate, and Cementless Femoral Components, and Metaphyseal Cones are indicated for Cemented or Uncemented use. All other components are indicated for cemented use only.
The Freedom Metaphyseal Cones are additionally indicated for use in addressing tibial bone voids and/or metaphyseal reconstruction.
The subject device, Freedom Knee Metaphyseal Cone implants, is a component addition to the cleared Freedom Total Knee System for addressing tibial bone voids and/or metaphyseal reconstruction. The Freedom Knee Metaphyseal Cone implants are designed with an elliptical shape, scaling larger in the Medial-Lateral (ML) direction than the Anterior-Posterior (AP) direction. The sizes are driven by the ML size, ranging from 25mm to 60mm wide in the ML direction and 29mm to 36mm AP in the AP direction. The cones are all 30mm long and feature a stepped design to further enhance the stability in the proximal-distal direction.
The Freedom Knee Metaphyseal Cone implants feature a large internal diameter to accept the largest possible Freedom Knee Stemmed Tibial Baseplate and Stem Extension possible. The internal diameters grow larger with each implant size, and all feature cement pockets to enhance the stability of the eventual TKA construct. The cone implants also feature 12mm wide relief slots to accept the fins/keel of the Freedom Knee Tibial Baseplate.
The AP and ML sides of the cone implants (which contact the metaphyseal bone) feature a 1mm thick proprietary scaffold structure. This structure, only possible via the additive manufacturing process, is designed to mimic the size and porosity of cancellous bone. The implant is comprised of Ti6Al4V ELI metal certified to ASTM F3001 and is manufactured with significant surface roughness to further add to the hydrophilic nature of the implant.
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(29 days)
The Freedom Infinia™ Total Knee System is indicated for the following:
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present. (For PCK Components and Primary PCK Components only)
The Freedom Infinia™ Total Knee System components are intended for cemented and single use only. The Freedom Infinia™ Cementless Femoral (CR and PS) Components and Porous Tibial Base Plates are additionally indicated for cementless biological fixation application.
The Freedom® Total Knee System is comprised of a femoral component, all-poly tibial component, patellar component, tibial base plate and tibial articular surface. The Freedom® Total Knee System's Femoral Component is offered as different versions such as stemmed PCK design, primary PCK, cruciate retaining, posterior stabilizing. The Freedom® Total Knee System's Tibial Base Plate is offered with stemmed design and without stemmed design. The Freedom® Total Knee System was originally cleared under the 510(k) number K082019. Later on, several modifications were made and were cleared under 510(k)s K090411, K091280, K111785, K131481, K150680, K182574, K192148, K241597, K243277, K251717 respectively.
This submission seeks the clearance of an additional brand, Freedom Infinia™ Total Knee System.
Below is the description of the Freedom Infinia™ Total Knee System's components.
Freedom Infinia™ Femoral Component
The Freedom Infinia™ Total Knee System's Femoral Component is offered in both cruciate retaining and posterior stabilizing designs. The Femoral components are available in right and left configurations, and eight sizes to accommodate varying anatomy. The Freedom Infinia™ Total Knee System's Femoral Component is fabricated from Cobalt-Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75 and is intended for cemented application to replace the articulating surface of the distal femur in a measured resection.
Freedom Infinia™ Cementless Femoral Component
The Freedom Infinia™ Total Knee System's Cementless Femoral Component is offered in both cruciate retaining and posterior stabilizing designs. The Cementless Femoral Components are available in right and left configurations, and eight sizes to accommodate varying anatomy. The Freedom Infinia™ Total Knee System's Cementless Femoral Component is fabricated from Cobalt-Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75 and porous coated CoCr beads and is intended for cementless biological fixation application to replace the articulating surface of the distal femur in a measured resection.
Freedom Infinia™ Stemmed Femoral Component
The Freedom Infinia™ Total Knee System's Stemmed Femoral Component with progressive constraint (PCK) is fabricated from Cobalt-Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75, intended for cemented application to replace the articulating surface of the distal femur in a measured resection technique. It is available in left and right configurations. Each configuration is further available in 8 different sizes (A to H) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions. Thus total of 16 models are available for the Stemmed Femoral Component.
Freedom Infinia™ Femoral Augments
The Freedom Infinia™ Total Knee System's Femoral Augments are fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136. These augments are intended to be screwed to the internal distal and posterior surfaces of Freedom Infinia™ PCK Stemmed Femoral Component when required in cases of significant bone loss. The augments are designed to be stackable and for use on either the medial or lateral side.
Augment Screws, fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136, are available as an accessory to the system to fix the augments to the Freedom Infinia™ Stemmed Femoral Component and other augments.
The Freedom Infinia™ Femoral Augments is available in distal and posterior design configuration. Each configuration is further available in 6 different sizes.
Freedom Infinia™ Primary PCK Femoral Component
Freedom Infinia™ Total Knee System's Primary PCK Femoral Component is designed to be used with the Freedom Infinia™ Stemmed Tibial Components. It is fabricated from Cobalt- Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75 and is intended for cemented application.
Freedom Infinia™ Tibial Base Plate
The Freedom Infinia™ Total Knee System's Tibial Base Plate is fabricated from Cobalt- Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection technique. The Tibial Base Plates are available in 8 different sizes (1 to 8) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions.
Freedom Infinia™ Titanium Tibial Base Plate
The Freedom Infinia™ Total Knee System's Titanium Tibial Base Plate is fabricated from Wrought Titanium alloy Ti-6Al-4V ELI, compliant with ASTM F136-13 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection technique. The Titanium Tibial Base Plates are available in 8 different sizes (1 to 8) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions.
Freedom Infinia™ Porous Tibial Base Plate
The Freedom Infinia™ Total Knee System's Porous Tibial Base Plate is intended for use with existing, compatible Femoral Components and Tibial Liner Components. Freedom Infinia™ Porous Tibial Base Plates are additively manufactured from Ti-6Al-4V ELI Grade 23 and include a porous lattice structure on the distal face. Freedom Infinia™ Porous Tibial Base Plates are available in eight asymmetric design offerings (Sizes 1 – 8, Left / Right configurations), based on anterior / posterior (A/P) and medial / lateral (M/L) dimensions.
Freedom Infinia™ Stemmed Tibial Base Plate
The Freedom Infinia™ Total Knee System's Stemmed Tibial Base Plate is fabricated from Cobalt-Chromium-Molybdenum (CoCrMo) alloy complying with ASTM F75 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection technique. The Stemmed Tibial Base Plates are available in 8 different sizes (1 to 8) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions and are supplied with UHMWPE plugs to close off augment screw holes and distal taper when not used and with a set screw to provide additional locking to the stem or offset junction during extraction.
Freedom Infinia™ Tibial Augments
The Freedom Infinia™ Total Knee System's Tibial Augments are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136. These augments are intended to be screwed to the distal surface Freedom Infinia™ Stemmed Tibial Base Plate when required in cases of significant bone loss. The augments are designed to be stackable, using a system of pins, bosses and screws, and reversible for use on either the medial or lateral side. Augment Screws, fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136, are available as an accessory to the system to fix the augments to the Stemmed Tibial Base Plate and other augments.
Freedom Infinia™ Stem Extension
The Freedom Infinia™ Total Knee System's Stem Extensions are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136. The Freedom Infinia™ Stem Extensions are intended for use with Freedom Infinia™ Stemmed Tibial Base Plate. The Freedom Infinia™ Stem Extensions are available in a range of diameters and lengths and are fluted distally with a distal slot in the larger lengths and diameters.
Freedom Infinia™ Offset Junction
The Freedom Infinia™ Total Knee System's Offset Junctions are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136, are intended to be used with the Freedom Infinia™ Stemmed Tibial Base Plate to provide an additional 4mm or 6mm offset between the tibial keel and stem. Freedom Infinia™ The Offset Junction is attached to the tibial component and stem through taper junctions. A set-screw is supplied with the Offset Junction to provide additional locking during extraction.
Freedom Infinia™ Tibial Liner
The Freedom Infinia™ Total Knee System's Tibial Liner is available in two designs i.e. posterior stabilizing (PS) and cruciate retaining (CR). Based on the Tibial Liner compatibility with Femoral Component configurations, each PS and CR designs are available various sizes with different anterior/posterior (A/P) and medial/lateral (L/P) dimensions, and each size is further bifurcated as on thickness. Tibial liner is fabricated from Ultra High Molecular Weight Polyethylene (UHMWPE) complying with ASTM F648 and is intended for cemented application along Tibial Base Plate to replace the articulating surface of the proximal tibia in a measured resection. Both the CR and PS Tibial Liners have identical locking mechanisms to mate with the Tibial Base Plate.
Freedom Infinia™ Medial Congruent Liner
The Freedom Infinia™ Total Knee System's Medial Congruent Liners have been developed with the desire to achieve a higher level of constraint than typically achieved in a traditional CR knee design while also providing the femoral component with a medial-pivoting motion throughout a range of motion. They possess an anterior and buildup and a higher sagittal conformity of the medial compartment that interact with the femoral component, to provide additional constraint. Designed to be used with the CR Femoral Component. Eliminates the need to remove bone for a PS box. Designed to allow high flexion. Includes a deep anterior patellar cut- out to allow for tendon clearance. Facilitates intraoperative flexibility, given compatibility with existing femoral and tibial baseplate options.
Freedom Infinia™ Ultra-Congruent CR Tibial Liner
The Freedom Infinia™ Total Knee System's Ultra-Congruent CR Tibial Liner consists of an ultra-high molecular weight polyethylene (UHMWPE) liner complies with ASTM F648 that is designed to be used with the Freedom Infinia™ Total Knee Cruciate Retaining (CR) Femoral Components in the Freedom Infinia™ Total Knee System.
Freedom Infinia™ PCK Tibial Liner
The Freedom Infinia™ Total Knee System's PCK Tibial Liner is fabricated from Ultra High Molecular Weight Polyethylene (UHMWPE) complies with ASTM F648. Based on the Tibial liner compatibility with PCK femoral component configurations, each PCK tibial liner design is available different sizes with different anterior/posterior (A/P) and medial/lateral (L/P) dimensions, and each size is further bifurcated on thickness variants.
The PCK Tibial Liners consist of the same articulating surface of existing Tibial liner components and have a same locking mechanism on the peripheral edge of the distal surface to lock into the Tibial / Stemmed Tibial Base Plate. The PCK tibial liner supplied with a liner securing pin manufactured from Ti-6Al-4V ELI to provide additional locking with stemmed tibial base plate.
Freedom Infinia™ All Poly Tibial Component
The Freedom Infinia™ Total Knee System's All Poly Tibial Component is fabricated from ultra high molecular weight polyethylene (UHMWPE) complying with ASTM F648 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection. Both the Total Knee System CR and PS Tibial Inserts have identical locking mechanisms to mate with the Tibial Base Plate.
Freedom Infinia™ All Poly Patella
The Freedom Infinia™ Total Knee System's All Poly Patella is available in symmetrical single radius design. Based on different diameter and thickness different models are available. All Poly Patella is fabricated from Ultra High Molecular Weight Polyethylene (UHMWPE) complying with ASTM F648.
The symmetric design features a central cement recess, and three pegs on the bone interface surface. The symmetric patellar component is intended for cemented application via an onset resurfacing surgical technique.
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(27 days)
The Freedom® Total Knee System is indicated for patients with severe knee pain and the disability due to:
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present. (For PCK Components and Primary PCK Components only)
The Freedom® Total Knee System – Titan PCK Components are intended for cemented and single use only.
The Freedom® Total Knee System is comprised of a femoral component, all-poly tibial component, patellar component, tibial base plate and tibial articular surface. The Freedom® Total Knee System's Femoral Component is offered as different versions such as stemmed PCK design, primary PCK, cruciate retaining, posterior stabilizing. The Freedom® Total Knee System's Tibial Base Plate is offered with stemmed design and without stemmed design. The Freedom® Total Knee System was originally cleared under the 510(k) number K082019. Later on, several modifications were made and were cleared under 510(k)s K091280, K192148, K090411, K182574, K131481, K111785, K200912, and K240863 respectively.
This submission seeks the clearance of Titanium Niobium Nitride (TiNbN) coated version of previously cleared Femoral Augment (non-coated version cleared in K131481), Tibial Augments, Stem Extension & Offset Junction (non-coated versions cleared in K111785). The coated versions are now branded as Freedom® Total Knee System – Titan PCK Components.
Below is the description of the coated components.
Freedom® Titan Femoral Augments
The Freedom® Titan Femoral Augments are fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN). These augments are intended to be screwed to the internal distal and posterior surfaces of the previously cleared PCK Stemmed Femoral Component (K131481) and Titan PCK Stemmed Femoral Component (K240863) when required in cases of significant bone loss. The augments are designed to be stackable and for use on either the medial or lateral side.
Augment Screws, fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN), are available as an accessory to the system to fix the augments to the Stemmed Femoral Component and other augments.
The Freedom® Titan Femoral Augments is available in distal and posterior design configuration. Each configuration is further available in 6 different sizes.
Freedom® Titan Tibial Augments
The Freedom® Titan Tibial Augments are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN). These augments are intended to be screwed to the distal surface of the previously cleared Stemmed Tibial Base Plate (K111785) & Titan Stemmed Tibial Base Plate (K240863) when required in cases of significant bone loss. The augments are designed to be stackable, using a system of pins, bosses and screws, and reversible for use on either the medial or lateral side.
Augment Screws, fabricated from Titanium-6Aluminum-4Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN), are available as an accessory to the system to fix the augments to the Stemmed Tibial Base Plate and other augments.
Freedom® Titan Offset Junction
The Freedom® Titan Offset Junctions are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN). Offset Junctions are intended to be used with the previously cleared Stemmed Tibial Base Plate (K111785) & Titan Stemmed Tibial Base Plate (K240863) to provide an additional 4mm or 6mm offset between the tibial keel and stem. The Offset Junction is attached to the tibial component and stem through taper junctions. A set-screw is supplied with the Offset Junction to provide additional locking during extraction.
Freedom® Titan Stem Extension
The Freedom® Titan Stem Extensions are fabricated from Titanium-Aluminum-Vanadium (Ti-6A1-4V), complaint with ASTM F136, and are coated with Titanium Niobium Nitride (TiNbN). The Titan Stem Extensions are intended for use with the previously cleared Stemmed Tibial Base Plate (K111785) & Titan Stemmed Tibial Base Plate (K240863). The Stem Extensions are available in a range of diameters and lengths and are fluted distally with a distal slot in the larger lengths and diameters.
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(22 days)
The Freedom® Total Knee System is indicated for the following:
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present (For PCK Components and Primary PCK Components only).
The Freedom® Total Knee System – Titanium Tibial Base Plate is intended for cemented and single use only.
The Freedom® Total Knee System is comprised of a femoral component, all-poly tibial component, patellar component, tibial base plate and tibial articular surface. The Freedom® Total Knee System's Femoral Component is offered as different versions such as stemmed PCK design, primary PCK, cruciate retaining, posterior stabilizing. The Freedom® Total Knee System's Tibial Base Plate is offered with stemmed design and without stemmed design. The Freedom® Total Knee System was originally cleared under the 510(k) number K082019. Later on, several modifications were made and were cleared under 510(k)s K091280, K192148, K090411, K182574, K131481, K111785 and K200912 respectively.
The primary purpose of this special 510(k) Device Modification to the Freedom® Metal Backed Tibial Component (K090411) is to notify the FDA of the change in materials used to manufacture the tibial base plate from CoCrMo to Wrought Titanium-6Aluminium-4Vanadium ELI Alloy (Ti6Al4V ELI, ASTM F136-13) as an alternative material option for the tibial base plate.
The Titanium Tibial Base Plate is fabricated from Titanium alloy Ti-6Al-4V ELI, compliant with ASTM F136 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection technique.
The Titanium Tibial Base Plates are available in 8 different sizes (1 to 8) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions.
This 510(k) clearance letter pertains to a Class II medical device, specifically the Freedom® Total Knee System - Titanium Tibial Base Plate (K251717). The submission is a special 510(k) Device Modification, indicating that the changes made to the device are well-defined and do not significantly alter the indications for use or raise new questions of safety and effectiveness.
The core change is the material of construction for the tibial base plate, shifting from CoCrMo to Wrought Titanium-6Aluminium-4Vanadium ELI Alloy (Ti-6Al-4V ELI). The design, geometry, surfaces, and locking features remain identical to the previously cleared predicate device (K090411).
Therefore, the acceptance criteria and the study proving the device meets these criteria primarily focus on mechanical performance and biocompatibility related to this material change, rather than extensive clinical efficacy studies or comparative effectiveness studies involving human readers, as would be typical for AI/software devices.
Acceptance Criteria and Reported Device Performance
Given the nature of this submission (a material change for an orthopedic implant with identical design), the acceptance criteria are not explicitly numerical thresholds like sensitivity/specificity, but rather involve demonstrating mechanical equivalence to the predicate device and biocompatibility of the new material.
Here's a table summarizing the implicit acceptance criteria based on standard regulatory requirements for such a device modification, and how the document indicates they were met:
| Acceptance Criteria Category | Specific Criteria (Implicit from Submission Type) | Reported Device Performance (as per 510(k) Summary) |
|---|---|---|
| Mechanical Performance | The Titanium Tibial Base Plate must demonstrate equivalent or superior mechanical integrity and fatigue resistance compared to the predicate device to ensure durability and prevent failure under intended physiological loads. | Met. "The design, geometry, surface features, locking features and dimensional attributes of the Titanium Tibial Base Plate are identical to those of the previously cleared Freedom® Metal Backed Tibial Base Plate (K090411).""Hence, to evaluate the device function and performance for its intended use, the Freedom® Titanium Tibial Base Plate was subjected to the following mechanical tests:Tibial Tray Fatigue Testing per ASTM F1800Range of Motion & Modular disassembly testing was leveraged from the reference device (K090411) as the subject device uses an identical tibial insert locking mechanism." |
| Material Biocompatibility | The new material (Ti-6Al-4V ELI) must be biocompatible and not elicit adverse biological responses (e.g., toxicity, sensitization, irritation) when implanted in the human body. | Met. "Biocompatibility testing is not required for the subject Titanium Tibial Base Plate device, because the material, Ti-6Al-4V ELI Titanium Alloy is compliant with ASTM F136, is a well-established material with a long history of safe use in orthopedic implants.""This material has been used extensively for many years without any major biocompatibility related safety concerns.""Additionally, the material has been used in multiple components of Maxx Orthopedics' previously cleared Freedom® Total Knee System…""It also complies with the biocompatibility requirements outlined in 'Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses; Guidance for Industry and FDA'"."Furthermore, Ti-6Al-4V ELI Titanium Alloy (ASTM F136) has also been used in similar tibial base plate components from other legally marketed devices, intended for same anatomical location and patient contact type, as demonstrated in K220737.""A risk-based assessment, following the principles outlined in FDA's 2023 Biocompatibility guidance (Use of ISO 10993-1), confirms that the material change does not introduce new types of patient contact, contact duration, or clinical use conditions that would require additional biocompatibility testing." |
| Equivalence in Design/Function | The device design must be substantially equivalent to the predicate, with any minor differences not raising new safety or effectiveness concerns. | Met. "The design, geometry, surface features, locking features and dimensional attributes of the Titanium Tibial Base Plate are identical to those of the previously cleared Freedom® Metal Backed Tibial Base Plate (K090411).""There are no significant technological differences between the subject and predicate device. The subject device uses a similar design and dimensions, geometry and sizing, and achieves its intended use in an identical manner as the primary predicate and both devices are manufactured using similar subtractive manufacturing techniques." |
| Sterilization Method (Minor Change) | If the sterilization method changes, its effectiveness must be validated. | Addressed. "Minor differences in subject device are that it uses different materials of constructions and sterilization method that are addressed via performance testing and similarity to the secondary predicate devices (K241597)." While not explicitly detailed, the mention implies this was covered. |
Study Details (Relevant to Orthopedic Implants, Not AI)
The provided text describes a submission for an orthopedic implant and does not involve an AI/software component, nor does it detail a clinical study with human patients for AI performance evaluation. Therefore, many of the requested points regarding sample sizes for test/training sets, expert readers, ground truth for AI, MRMC studies, etc., are not applicable to this type of device clearance and are consequently not found in the document.
However, based on the information provided, here's what can be inferred/stated:
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Sample size used for the test set and data provenance:
- Test Set: Not applicable in the context of clinical AI performance data. For mechanical testing (ASTM F1800), standard test methods specify the number of samples required (e.g., minimum of 6 samples for fatigue per ASTM F1800-97), but the exact number used in this specific submission is not reported in the summary.
- Data Provenance: Not applicable for AI performance data. For material and design, the device is manufactured by Maxx Orthopedics Inc. (Norristown, PA, USA) and Meril Healthcare Pvt. Ltd. (Vapi, Gujarat, India).
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Number of experts used to establish the ground truth for the test set and qualifications of those experts:
- Not applicable as this is a mechanical and material modification, not an AI diagnostic device requiring expert interpretation of images for ground truth.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable for the type of device/study described.
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If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- No. This type of study (MRMC, AI assistance) is not relevant or performed for this device. The submission is for a physical orthopedic implant with a material change.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable, as there is no algorithm or AI component in this device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the mechanical testing, the "ground truth" would be the engineering specifications and performance of the predicate device, alongside adherence to international standards (e.g., ASTM F1800).
- For biocompatibility, the "ground truth" is established long-term clinical use data, compliance with ASTM F136 (Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI Alloy for Surgical Implant Applications), and prior FDA clearances of devices using this material.
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The sample size for the training set:
- Not applicable (no AI training set).
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How the ground truth for the training set was established:
- Not applicable (no AI training set).
In summary, the FDA clearance for K251717 as a special 510(k) is based on demonstrating that the new Titanium Tibial Base Plate is mechanically equivalent to its predicate and that the new material is biocompatible and has a well-established history of safe use in similar orthopedic applications. The regulatory review focuses on engineering performance criteria and material biocompatibility rather than clinical performance data from patient studies or AI algorithm validation.
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(249 days)
The Signature Orthopaedics Freedom Cervical Screw and Rod System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients (C1 to C7) as an adjunct to fusion in the treatment of the following acute and chronic instabilities and deformities of the cervical spine:
- traumatic spinal fractures and/or traumatic dislocations
- instability or deformity; failed previous fusions (e.g. pseudarthrosis)
- degenerative disease, including neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability, and
- short term stabilization of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom expectancy is of insufficient duration to permit achievement of fusion.
The Freedom™ Posterior Cervical Screw System consists of screws, longitudinal rods and cross connectors in a variety of sizes to accommodate differing anatomic requirements. The cervical screws are inserted into adjacent vertebrae, then rods are clamped into the tulip of the pedicle screw using the cap screw, thus immobilising the instrumented vertebrae. The cross-connector may then be attached between rods to improve stability. The system components are made of Ti6Al4V alloy and are supplied sterile.
The provided FDA 510(k) clearance letter pertains to the Freedom Posterior Cervical Screws, which is a medical device and not an AI/ML-driven software system. As such, the information you've requested regarding acceptance criteria, study details, sample sizes, ground truth, and human reader performance is not applicable to this type of device submission.
The FDA clearance for this device is based on demonstrating substantial equivalence to a legally marketed predicate device, primarily through non-clinical performance testing and engineering evaluations. These tests focus on the physical and mechanical properties of the screws to ensure they are safe and effective for their intended use as a spinal implant.
Here's a breakdown of the relevant information provided in the document concerning the device's performance:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Tests Performed | Reported Device Performance |
|---|---|---|
| Mechanical Strength & Durability | Static and dynamic compression bending testing | Results demonstrated that the strength of the system is sufficient for its intended use. |
| Static torsion testing | Results demonstrated that the strength of the system is sufficient for its intended use. | |
| Static Flexion-Extension Moment Test | Results demonstrated that the strength of the system is sufficient for its intended use. | |
| Axial Gripping Test | Results demonstrated that the strength of the system is sufficient for its intended use. | |
| Axial Torsional Test | Results demonstrated that the strength of the system is sufficient for its intended use. | |
| Surgical Handling & Integration | Screw insertion testing | Not explicitly detailed performance, but implies successful insertion. |
| Screw pull-out testing | Not explicitly detailed performance, but implies adequate resistance to pull-out. | |
| Screw torque to failure testing | Not explicitly detailed performance, but implies appropriate torque resistance. | |
| Compliance with Standards | Adherence to ASTM-F1717 (Spinal Implant Construct in a Vertebrectomy Model) | Confirmed compliance with relevant standards. |
| Adherence to ASTM-F1798 (Static and Fatigue Properties of Interconnection Mechanisms and Subassemblies Used in Spinal Arthrodesis Implants) | Confirmed compliance with relevant standards. | |
| Adherence to ASTM-F543 (Metallic Medical Bone Screw) | Confirmed compliance with relevant standards. | |
| Substantial Equivalence | Comparison with Predicate Device (Saxxony™ Posterior Cervical Thoracic System - K182508) | Demonstrated "nearly identical technological characteristics" and that "minor differences do not raise any new issues of safety and effectiveness." |
2. Sample size used for the test set and the data provenance:
- The document states that "worst-case sizes of the subject cervical screws" were tested.
- Sample size: Not explicitly quantified with a specific number of units, but implied it was a representative selection of "worst-case sizes."
- Data provenance: The tests were "non-clinical testing and engineering evaluations" conducted by the manufacturer, Signature Orthopaedics Pty Ltd, in Australia. This is a form of prospective testing done specifically for regulatory submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. This is a hardware device where "ground truth" is established through engineering principles and physical testing against established ASTM standards, not through expert human interpretation or diagnosis.
4. Adjudication method for the test set:
- Not applicable. This involves objective mechanical testing, where results are measured directly against predefined acceptance criteria from engineering standards. There is no subjective adjudication process for establishing a "ground truth" as would be the case for image interpretation or diagnostic performance.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- Not applicable. This device is a surgical implant, not an AI-assisted diagnostic tool. Therefore, no MRMC studies or human reader performance evaluations were conducted or are relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is a physical product, not a software algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The "ground truth" for this device's performance is derived from established mechanical and material engineering standards (ASTM standards). The device's components must meet or exceed the performance specifications (e.g., strength, fatigue resistance) outlined in these standards to be deemed safe and effective for their intended surgical purpose.
8. The sample size for the training set:
- Not applicable. This refers to a dataset used to train an AI model. This device is hardware and does not involve a training set.
9. How the ground truth for the training set was established:
- Not applicable. As above, there is no training set for this type of medical device submission.
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(46 days)
The FreedomFlow™ Orbital Circumferential Atherectomy System is indicated for use as therapy in patients with occlusive atherosclerotic disease in peripheral arteries. The therapy is intended for patients who are acceptable candidates for percutaneous transluminal atherectomy.
The FreedomFlow™ Orbital Circumferential Atherectomy System is a flexible over-the-wire rotational device used to ablate atherosclerotic plaque from arterial blood vessels within the body. The FreedomFlow™ Orbital Circumferential Atherectomy System is used together with a compatible introducer sheath and 0.014-inch diameter x 300 cm (minimum length) atherectomy guidewire. The driveshaft is introduced into the patient's vasculature by traditional minimally invasive techniques. The FreedomFlow™ User Handle is available in model numbers that are listed below with vessel size ranges.
The FreedomFlow Orbital Circumferential Atherectomy System - Electric (FreedomFlow™) includes an integrated driveshaft with multiple abrasive spheres on a rotating driveshaft. The abrasive spheres are eccentrically mounted onto the driveshaft so that when the driveshaft is rotated, they move outward due to centrifugal force. These abrasive spheres are spaced along the driveshaft in a spiral configuration to optimize plaque modification within a vessel while still maintaining flexibility for treating tortuous arterial anatomy. The User Handle includes two rotational speeds: low speed at 50,000 revolutions per minute (RPM) and high speed at 76,000 RPM.
The FreedomFlow Orbital Circumferential Atherectomy System - Electric (FreedomFlow™) is powered by Cardio Flow Power Supply H7001, which is a hospital-grade portable, reusable component. H7001 provides DC power to rotate the FreedomFlow™ driveshaft. H7001 also provides DC power to a saline pump integrated into the FreedomFlow™ User Handle. During operation the saline pump delivers saline to the distal tip of the driveshaft.
The FreedomFlow™ orbital atherectomy User Handle is supplied single patient use, sterile. The package contents include the following items.
- FreedomFlow™ orbital atherectomy User Handle with integrated electric motor and saline pump
- Saline infusion tubing set
I'm sorry, but your request cannot be fulfilled. The provided document is an FDA 510(k) clearance letter for a medical device (FreedomFlow™ Orbital Circumferential Atherectomy System), not for an AI/ML-driven medical device.
The document describes the physical characteristics of an atherectomy system, its intended use, and bench testing to demonstrate its mechanical and performance characteristics (like plaque removal efficiency, tensile strength, rotational speed, etc.). It does not involve any AI/ML components, nor does it describe a study involving human readers, ground truth establishment by experts, or MRMC studies, which are typical for validating AI/ML-driven medical devices.
Therefore, I cannot extract the information required to describe acceptance criteria and a study proving an AI/ML device meets those criteria from this non-AI/ML medical device submission.
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(30 days)
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present (For PCK Components and Primary PCK Components only).
The Freedom Total Knee System, Freedom Stemmed Tibial Components and Freedom PCK Components are indicated for cemented fixation
The Freedom Total Knee System All-Poly Tibial Plate implants have been developed with the desire to expand upon the already clinically successful Freedom® Total Knee System, melding together the best design features of various sub-systems into one. The implants will retain the key benefits of the All-Poly Tibial implant system while leveraging some of the modular, metal-backed systems (K090411, K182574, K243277). Using the All-Poly design, the articular surface, tibial baseplate, and stem are manufactured from a single component. This eliming from modularity, reduces the overall weight and subsidence risk, adds full radiolucency to the tibial implants, and comes at a reduced cost. Like the original All-Poly Implants, these new versions will be manufactured from GUR 1020 (Type 1) UHMWPE per ASTM F648.
To enhance the existing All-Poly Implant designs, the stem of these implants is being upgraded to the larger, finned stem/keel design from the modular Freedom® Total Knee System (K090411). This will provide the new All-Poly Tibial implanted stability post-operatively and allow surgeons to use the same instruments/surgical technique as the modular, metal-backed system. This will improve the harmony between the various Freedom® systems and ensure all produce the same strong clinical results.
This document is a 510(k) Premarket Notification from the FDA regarding a Knee Joint Prosthesis, specifically the Freedom Total Knee System (All-poly Tibial Plate). It does not contain information related to an AI/ML (Artificial Intelligence/Machine Learning) powered medical device. Therefore, I cannot extract the information required to answer your questions regarding acceptance criteria and study data for an AI/ML device.
The document discusses substantial equivalence for a physical medical device (a knee implant) based on mechanical properties, design comparisons, and adherence to existing predicate devices. It does not mention any software, algorithms, or AI components that would require a study with acceptance criteria related to AI performance metrics (like sensitivity, specificity, AUC).
To provide the information you're asking for, I would need a document related to an AI/ML medical device.
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(255 days)
The Freedom® Total Knee System is indicated for the following:
• Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
• Correction of functional deformities.
• Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
• Moderate valgus, varus, or flexion trauma.
• Knee fractures untreatable by other methods.
• Revision surgery where sufficient bone stock and soft tissue integrity are present (For PCK Components and Primary PCK Components only).
The Freedom® Porous Tibial Base Plate and Cementless Femoral Components are indicated for Cemented or Uncemented use. All other components are indicated for cemented use only.
The Freedom® Porous Tibial Base Plate is a line extension of the Freedom® Total Knee System comprising of tibial base plate components for cemented or uncemented use in total knee arthroplasty. Freedom® Porous Tibial Base Plates are intended for use with existing, compatible Freedom® femoral and tibial liner components. Freedom® Porous Tibial Base Plates are additively manufactured from Ti-6Al-4V ELI Grade 23 and include a porous lattice structure on the distal face. Freedom® Porous Tibial Base Plates are available in eight asymmetric design offerings (Sizes 1 – 8, Left / Right configurations), based on anterior / posterior (A/P) and medial / lateral (M/L) dimensions.
The provided document is a 510(k) premarket notification for a medical device, specifically the Freedom® Total Knee System - Porous Tibial Base Plate. This type of regulatory submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than undergoing a de novo clinical study with strict acceptance criteria and performance analysis. Therefore, the information requested about acceptance criteria and a study proving the device meets them, typically found in a clinical trial report or a performance study for novel devices or software, is not directly applicable in the same way.
However, I can extract the information related to the non-clinical performance testing conducted to support the substantial equivalence claim. This testing serves as the "study" demonstrating that the device performs as intended and is similar to the predicate.
Here's an interpretation based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state numerical "acceptance criteria" for each test in the way a clinical trial might. Instead, the "acceptance" is implicitly defined by demonstrating that the subject device's performance is substantially equivalent to established performance standards or the predicate/reference devices. The "reported device performance" is summarized as the satisfactory completion of these tests.
| Acceptance Criteria (Implicit) | Reported Device Performance |
|---|---|
| Tibial Tray Fatigue: Device must withstand fatigue loading per ASTM F1800. | All necessary testing performed. (Implies satisfactory performance meeting the standard). |
| Residual Particle Characterization: Device must meet acceptable levels of residual particles per ASTM F1877, comparable to literature. | Results were shown to be substantially equivalent to values presented in the literature for the reference device (K030623). |
| Porous Surface Characterization: Porous structure must meet specifications for various characteristics per ASTM F1854, F1160, F1044, F1978, F1147. | All necessary testing performed. (Implies satisfactory performance meeting the standards). |
| Sterilization: Device must achieve a sterility assurance level (SAL) of 10^-6 per ISO 11137-2. | Sterilization per ISO 11137-2. (Implies successful sterilization to the required SAL). |
| Endotoxin: Device must meet acceptable endotoxin levels per AAMI ST72. | Endotoxin per AAMI ST72. (Implies acceptable endotoxin levels). |
| Biocompatibility: Device materials must be biocompatible per ISO 10993-1, ISO 10993-5. | Biocompatibility per ISO 10993-1, ISO 10993-5. (Implies successful demonstration of biocompatibility). |
| Modular Disassembly: If applicable, modular components must meet disassembly force requirements (leveraged from reference device). | Modular disassembly testing was leveraged from the reference device (K090411) as the subject device uses an identical tibial insert locking mechanism. (Implies that the design similarity ensures equivalent performance without new testing). |
2. Sample sized used for the test set and the data provenance
- Sample Size: The document does not specify the exact number of implants or test coupons used for each non-clinical test (e.g., how many tibial trays were fatigue tested). It mentions that "All testing was performed on worst case implants or test coupons as dictated by the relevant performance standards."
- Data Provenance: The tests are non-clinical (laboratory/mechanical testing), not human clinical data. Thus, terms like "country of origin" or "retrospective/prospective" are not applicable. The data originates from laboratory testing conducted by or for the manufacturer (Maxx Orthopedics, Inc.).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable. The "test set" here refers to physical specimens (implants/coupons) for non-clinical testing, not patient data requiring expert interpretation or ground truth establishment. The "ground truth" for these tests is defined by the technical specifications and requirements of the referenced ASTM and ISO standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable as the tests are non-clinical, mechanical, and material evaluations performed against established standards, not clinical data requiring adjudication by experts.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This is not applicable. The device is a physical knee implant, not an AI software or diagnostic tool used by human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device is a physical knee implant, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical performance tests, the "ground truth" is defined by the technical specifications and requirements outlined in the referenced ASTM and ISO standards. For example, the acceptable number of cycles for fatigue testing is defined by ASTM F1800. For residual particles, the "ground truth" is the acceptable range established in the literature for the reference device, as evaluated against ASTM F1877.
8. The sample size for the training set
This is not applicable. The device is a physical knee implant. There is no "training set" in the context of machine learning or AI. The manufacturing process is validated, and the device's design is based on engineering principles and existing predicate designs, not a data-driven training set.
9. How the ground truth for the training set was established
This is not applicable for the reasons stated above.
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(34 days)
The Freedom® Medial Congruent Liner consists of an ultra-high molecular weight polyethylene (UHMWPE) liner that is designed to be used with the Freedom® Total Knee Cruciate Retaining (CR) Femoral Components in the Freedom® Total Knee System. The Freedom® Total Knee System is indicated for the following:
- · Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, and polyarthritis.
- · Correction of functional deformities.
- · Post-traumatic loss of knee ioin contour, particularly when there is patellofemoral erosion.
- dysfunction, and/or prior patellectomy.
- · Moderate valqus, varus, or flexion trauma.
- · Knee fractures untreatable by other methods.
The Freedom® Medial Congruent Tibial Liner is intended for cemented use only. This device is for single use only.
Freedom® Medial Congruent Liners have been developed with the desire to achieve a higher level of constraint than typically achieved in a traditional CR knee design while also providing the femoral component with a medial-pivoting motion throughout a range of motion. They possess an anterior and buildup and a higher sagittal conformity of the medial compartment that interact with the femoral component, to provide additional constraint.
Designed to be used with the Freedom CR Femoral Component.
Eliminates the need to remove bone for a PS box.
Designed to allow high flexion.
Includes a deep anterior patellar cut-out to allow for tendon clearance.
Facilitates intraoperative flexibility, given compatibility with existing femoral and tibial baseplate options
The provided text is a 510(k) summary for a medical device called the "Freedom® Medial Congruent Liner." This document describes the device, its intended use, and the non-clinical tests performed to demonstrate its substantial equivalence to a predicate device.
Based on the provided text, here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for this device are established by demonstrating substantial equivalence to a predicate device (Freedom Ultracongruent CR Tibial Liner, K182574) through non-clinical testing. Instead of specific numerical thresholds for performance, the acceptance is based on demonstrating equivalency or satisfactory performance relative to the predicate.
| Acceptance Criterion (Demonstrating Substantial Equivalence to Predicate) | Reported Device Performance |
|---|---|
| Tibiofemoral Range of Motion (ASTM F2083 6.2.3): Equivalent maximum flexion angle. | Simulated Computer-Aided-Design software determined the range of motion (maximum flexion angle) of the Subject Device was equivalent to the Predicate Device. |
| Tibiofemoral Constraint Characterization (ASTM F1223 and F2083): Satisfy preestablished benchmark performance in comparison to the Predicate Device for anterior (A/P), medial/lateral (M/L), and internal/external constraint of the articular surface through various degrees of flexion. | The results satisfied the preestablished benchmark performance in comparison to the Predicate Device. |
| Tibiofemoral Contact Area and Contact Pressure (ASTM 2083 6.2.2): Equivalent throughout a range of motion compared to the Predicate Device. | The contact area and contact pressure was found to be equivalent throughout a range of motion compared to the Predicate Device. |
| Material: Identical to current Freedom UC tibial insert. | The material... of the MC tibial insert are identical to the current Freedom UC tibial insert. |
| Locking Tab Geometry: Identical to current Freedom UC tibial insert. | The... locking tab geometry of the MC tibial insert are identical to the current Freedom UC tibial insert. |
| Tibial Insert-Tray Disassembly Forces: Considered the same as for the MC tibial insert due to identical material and locking tab geometry. (No specific test reported, but inferred equivalence) | Given the identical material and locking tab geometry, disassembly testing is needed [to confirm, but implies expectation of equivalence]. |
| Sizing and Compatibility with Freedom CR Femoral Components: Same as for existing UC tibial inserts and femoral components. | The sizing and compatibility of the MC tibial inserts and the Freedom CR femoral components is therefore the same as for the existing UC tibial inserts and femoral components. |
2. Sample Size and Data Provenance
- Sample Size for Test Set: The document indicates that the tests were performed on "the Subject Device." It does not specify a numerical sample size for the devices tested. Given that these are non-clinical (mechanical/simulation) tests, the "sample size" might refer to the number of simulations or physical prototypes tested, which is not stated.
- Data Provenance: The tests are non-clinical studies (simulations and characterization tests) rather than human subject data. Therefore, concepts like "country of origin" or "retrospective/prospective" do not apply. The data is generated from laboratory testing and computational modeling.
3. Number of Experts and Qualifications for Ground Truth
- This device's substantial equivalence is demonstrated through non-clinical engineering testing and simulation, not clinical data requiring expert review for "ground truth." Therefore, the concept of "experts" establishing ground truth in the radiological sense is not applicable here. The "experts" involved would be the engineers and scientists conducting and reviewing the test methods and results.
4. Adjudication Method for Test Set
- As this is non-clinical testing, there is no "adjudication method" in the sense of clinician review or consensus. The results are based on objective measurements and computational outcomes compared against predefined standards (ASTM standards) and the predicate device's performance.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC comparative effectiveness study was not conducted or reported. This filing is for a medical implant (knee liner), not a software or AI product that assists human readers in diagnosis. The evaluation focuses on the mechanical and design properties of the implant itself.
6. Standalone (Algorithm Only) Performance
- No, this concept is not applicable. The device is a physical knee implant component, not a software algorithm.
7. Type of Ground Truth Used
- For the non-clinical tests, the "ground truth" is derived from:
- Engineering Principles and Benchmarks: Adherence to established ASTM (American Society for Testing and Materials) standards (F2083, F1223).
- Computational Simulations: Computer-AAided-Design (CAD) software for range of motion.
- Direct Mechanical Comparison to Predicate Device: Physical and performance characteristics of the subject device are directly compared to those of the legally marketed predicate device.
8. Sample Size for the Training Set
- Not applicable. There is no "training set" as this is not an AI/machine learning device. The design and testing are based on engineering principles and comparison to a predicate, not data-driven model training.
9. How the Ground Truth for the Training Set was Established
- Not applicable, as there is no training set.
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(41 days)
The FreedomFlow™ Orbital Circumferential Atherectomy System is indicated for use as a therapy in patients with occlusive atherosclerotic disease in peripheral arteries. The therapy is intended for patients who are acceptable candidates for percutaneous transluminal atherectomy.
The FreedomFlow™ Orbital Circumferential Atherectomy System is a flexible over-the-wire rotational device used to ablate atherosclerotic plaque from peripheral arterial blood vessels within the body. The FreedomFlow™ System consists of three components: User Handle with integrated driveshaft, Tubing Set, and Power Supply. The User Handle with the integrated driveshaft is sterile, single use, and disposable. The User Handle provides the operator interface to control driveshaft rotation (with two speed options) and translation within the vessel. The User Handle also incorporates a guidewire mechanical clamp. The User Handle controls the saline fluid flow down the driveshaft catheter. The User Handle utilizes firmware and hardware to perform these functions. The Tubing Set is sterile, single use, and disposable. The Tubing Set connects a user provided sterile saline supply to the User Handle. The Tubing Set is connected by the operator to the User Handle. The Power Supply is a medical grade AC powered transformer, supplying DC electrical energy to the User Handle. The power supply is reusable.
This looks like a 510(k) summary for a medical device called the "FreedomFlow™ Orbital Circumferential Atherectomy System". This document focuses on demonstrating substantial equivalence of a modified device to a previously cleared predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the way one might for a novel AI/software device.
The premise of a 510(k) is that if a new device is shown to be substantially equivalent to a legally marketed predicate device, it does not require a new Pre-Market Approval (PMA) application. Substantial equivalence is often established by demonstrating that the device has the same intended use, similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness.
Therefore, the requested information about acceptance criteria, study design parameters (sample size, data provenance, expert adjudication, MRMC, standalone performance, training set details), which are common for AI/software device submissions, are largely not applicable in the context of this specific 510(k) submission.
Here's a breakdown of why this information is largely absent and what is provided:
1. A table of acceptance criteria and the reported device performance:
- Acceptance Criteria/Performance: This document does not provide a table of acceptance criteria and reported device performance in the form typically expected for AI/software evaluations (e.g., sensitivity, specificity, AUC). Instead, it establishes "substantial equivalence" to predicate devices. The "performance" being evaluated here relates to the manufacturing process change (soldering to welding) and a pump head change. The document states: "There are no performances differences incurred as a result of this change." and "Testing verifies all pump related specifications."
- Table of Comparison (from the document): The document includes a large table on pages 6-7 comparing the subject devices (H6001 & H6004 with changes) to predicate devices (H6001 [K231538] & H6004 [K233483]). This table highlights that all key characteristics, including Product Code, Classification, Intended Use, Indications for Use, Mechanism of Operation, System Components, Driveshaft Variations, Rotational Speed, Saline flow rate, Shelf life, Sterility, etc., are "Same." The core acceptance criterion for this 510(k) is demonstrating that these characteristics remain equivalent despite the manufacturing changes.
2. Sample size used for the test set and the data provenance:
- Not Applicable in this context: The document does not describe a "test set" in the sense of a clinical or image dataset for an AI algorithm. The evaluations conducted are likely engineering bench tests, biocompatibility tests, and potentially functional tests related to the manufacturing processes. Details on sample sizes for these types of tests are not typically included in the 510(k) summary provided to the public.
- Data Provenance: Not applicable as there isn't a "data set" originating from specific countries or clinical studies as would be for an AI device. The data provenance would be internal engineering and manufacturing quality control data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable: There is no "ground truth" established by experts in this context. The evaluation is against engineering specifications and the established performance of the predicate device.
4. Adjudication method for the test set:
- Not Applicable: There is no "adjudication method" as this is not a subjective diagnostic or interpretative task.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- Not Applicable: This device is a physical medical device (atherectomy system) and does not involve AI or human readers for diagnostic interpretation. Therefore, an MRMC study is completely irrelevant.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not Applicable: This is a physical atherectomy system; it is not an algorithm.
7. The type of ground truth used:
- Ground Truth: In the context of this 510(k), the "ground truth" for the device's performance is its adherence to engineering specifications, functional requirements, and safety standards, which are themselves benchmarked against the predicate device. For example, biocompatibility testing would be compared against ISO standards, and functional tests (like rotational speed, saline flow) would be compared against their defined operational parameters.
8. The sample size for the training set:
- Not Applicable: There is no "training set" as this is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not Applicable: There is no "training set."
In summary:
This 510(k) pertains to a manufacturing process change and a component change for a physical medical device (Atherectomy System). The regulatory submission demonstrates substantial equivalence to existing predicate devices by showing that these changes do not alter the intended use, indications for use, or fundamental technological characteristics, and do not raise new questions of safety or effectiveness. The detailed study parameters typically associated with AI/software device evaluation are not relevant to this type of submission.
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