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510(k) Data Aggregation

    K Number
    K242671

    Validate with FDA (Live)

    Date Cleared
    2024-10-04

    (28 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The TMC Screw Fixation System is intended for use for adult and pediatric patients aged >12 years, and indicated for small or long bones requiring fixation of fractures, fracture repair, revision procedures, joint fusions (arthrodesis), bone reconstructions, osteotomy, ligament fixation, and pseudoarthrosis (non-unions) of bones, including scaphoid and other carpal bones, metacarpals, tarsals, metatarsals, phalanges, patella, ulnar styloid, capitellum, radial styloid.

    In the foot, the following specific examples are indicated with screws appropriate for the size of the device:

    • · mono or bicortical osteotomies
    • · distal or proximal metatarsal osteotomies
    • · weil osteotomy
    • · fusion of the metatarsalphalangeal joint
    • · fixation of osteotomies for Hallux Valqus treatment (such as Scarf, Chevron, etc.)
    • · Akin type osteotomy
    • · talonavicular fusions
    • · cuboid fusions

    Not for sninal use

    Device Description

    Treace Medical Concepts (TMC) Screw Fixation System includes headed and headless cannulated screws. The TMC Screw Fixation System is intended for use for adult and pediatric patients aged >12 years, and indicated for small or long bones requiring fixation of fractures, fracture repair, revision procedures, joint fusions (arthrodesis), bone reconstructions, osteotomy, ligament fixation, and pseudoarthrosis (non-unions) of bones, including scaphoid and other carpal bones, metacarpals, tarsals, phalanges, patella, ulnar styloid, capitellum, radial head and radial styloid, appropriate for the size of the device.

    All implantable components are manufactured from implant grade titanium alloy (Ti6Al4V-ELI) per ASTM F136 and are provided sterile by gamma irradiation.

    The primary purpose of this Special 510(k) submission is to introduce additional screw options and accompanying instrumentation within the Treace Medical Concepts (TMC) Screw Fixation System. Secondly, Treace is providing the Agency notification regarding minor modifications implemented for the TMC Screw Fixation System via internal documentation.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Treace Medical Concepts (TMC) Screw Fixation System. It does not contain information about a study proving the device meets acceptance criteria in the context of clinical performance or AI/software analysis.

    The document states:

    • "Mechanical testing and analysis per ASTM F543-17 Standard Specification and Test Methods for Metallic Medical Bone Screws was performed on the subject screws to evaluate torsional strength, driving and removal torque, and axial pullout strength."
    • "The subject screws were assessed under the FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers - Performance Criteria for Safety and Performance Based Pathway, issued December 11, 2020."
    • "The subject screws met all acceptance criteria and can be considered substantially equivalent to predicate screws."

    This indicates that the "study" conducted was primarily mechanical bench testing of the screws themselves against established engineering standards and FDA guidance for metallic bone screws. It is not a clinical study involving human subjects, nor does it involve AI algorithms with associated performance metrics like sensitivity, specificity, or reader studies.

    Therefore, most of the requested information (items 2-9 about sample size, data provenance, experts, adjudication, MRMC, standalone performance, and ground truth for training) are not applicable to the type of device and testing described in this document.

    However, based on the provided text, here is the information that can be extracted:

    1. Table of acceptance criteria and the reported device performance

    Acceptance Criteria (Type of Test)Reported Device Performance (Met/Compared Against)
    Torsional strengthMet all acceptance criteria per ASTM F543-17 and FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers
    Driving torqueMet all acceptance criteria per ASTM F543-17 and FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers
    Removal torqueMet all acceptance criteria per ASTM F543-17 and FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers
    Axial pullout strengthMet all acceptance criteria per ASTM F543-17 and FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample size: Not specified. (Refers to mechanical test samples, not clinical data).
    • Data provenance: Mechanical bench testing. Not applicable in the context of clinical data provenance.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not applicable. Ground truth was established by engineering standards (ASTM F543-17) and FDA guidance for mechanical properties, not expert clinical consensus.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. This concept pertains to clinical or imaging ground truth establishment, not mechanical testing.

    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

    • No. This is a medical device for bone fixation, not an AI or imaging diagnostic device.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    • No. This is a physical medical device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • Engineering standards and FDA guidance for mechanical properties of metallic bone screws.

    8. The sample size for the training set

    • Not applicable. There is no "training set" as this is not an AI/software device.

    9. How the ground truth for the training set was established

    • Not applicable.
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