Ins Hilden Arzzt Nail Systems, consisting of intramedullary solid and cannulated nails, end cap and locking screws, are intended for fixation of fractures of different types: of the shaft, open and closed shaft fractures; and malunion and non-unions of the Femur, Tibia, and Humerus.

Device Description

Ins Hilden Humeral Arzzt, Ins Hilden Cannulated Tibial Arzzt, Ins Hilden Femoral Arzzt & Ins Hilden Retrograde Femoral Arzzt.

I. The Ins Hilden Humeral Arzzt is a single use system that consist the following components:

i. Nail, is solid and cannulated, with five orifices, two for distal locking and three for the proximal locking. One of the orifices on the proximal locking is for static locking and one for dynamic locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.
ii. End caps.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

II. The Ins Hilden Femoral Arzzt is a single use system that consist the following components:

i. Nail, is solid and cannulated with four orifices, two for distal locking and two for the proximal locking. One of the orifices on the proximal locking is for static locking and one for dynamic locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extractionhole.
ii. End caps.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

III. The Ins Hilden Femoral Retrograde Arzzt is a single use system that consist the following components:

i. Nail, is solid and cannulated, with five orifices, two for distal locking and three for the proximal locking. All three proximal orifices for static locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.
ii. End caps.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

IV. The Ins Hilden Cannulated Tibial Arzzt is a single use system that consist the following components:

i. Nail, is cannulated, with four orifices, two for distal locking and four for the proximal locking. All three proximal orifices for static locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.
ii. End caps.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

AI/ML Overview

The provided document describes the Ins Hilden Humeral Arzzt, Ins Hilden Cannulated Tibial Arzzt, Ins Hilden Femoral Arzzt, and Ins Hilden Retrograde Femoral Arzzt systems, which are intramedullary fixation rods. The document asserts their substantial equivalence to predicate devices.

1. Table of Acceptance Criteria and Reported Device Performance:

The document does not explicitly state "acceptance criteria" in a quantitative manner for specific performance metrics in the way one might expect for a diagnostic or AI-driven device. Instead, it focuses on demonstrating substantial equivalence to predicate devices through engineering analysis and material biocompatibility.

The "acceptance criteria" can be inferred from the comparisons made:

Mechanical Performance: The subject devices must show comparable or superior static bending and torsional yield performance to the predicate devices.
Biocompatibility: The subject devices must be made of materials recognized as safe for medical implants and demonstrate no increased risk due to manufacturing processes.
Intended Use & Design: The subject devices must have similar intended uses (fixation of fractures of different types, malunion, non-unions of Femur, Tibia, and Humerus) and their design differences (angles, curvatures, lengths) should not affect the final result or increase risks.

Category	Acceptance Criteria (Inferred from comparison)	Reported Device Performance
Mechanical Strength	Static bending and torsional yield performance comparable or superior to predicate devices.	Engineering analyses confirmed substantial equivalence and that subject devices are stronger when applying the same force than predicate devices K033878 and K010801 (DEPUY ACE Antegrade Retrograde Humeral Nail System, T2 Femoral Nail).
Biocompatibility	Manufactured from medical-grade materials (Ti6Al4V) with no adverse impact from manufacturing processes.	System is manufactured from Titanium alloy Ti6Al4V, a recognized medical-grade material. Biocompatibility deemed acceptable based on prior FDA submissions (K133166 for Ti6Al4V and K162507 for Stainless Steel AISI 304, though the subject devices are Ti6Al4V).
Intended Use	Similar intended uses as predicate devices (fixation of fractures, malunion, non-unions of Femur, Tibia, Humerus).	Identical intended uses: fixation of fractures of different types; open and closed shaft fractures; and malunion and non-unions of the Femur, Tibia, and Humerus (same as predicate devices).
Design	Design differences (geometry, angles, curvatures, lengths) do not increase risks or complications.	Design differences exist (slight changes in geometry, angles, curvatures, lengths) to fit specific bones, but these "do not affect the final result" and "do not increase risks and complications" as systems are designed to fit specific bones, similar to predicate devices.
Patient Outcome	No complications experienced with either system during the healing process clinically.	"With similar clinical, the patients had no complications with either system during the healing process, after the reduction and fixation of the fracture with the subject devices."
Regulatory Standards	Compliance with relevant ASTM and ISO standards for materials.	The Ins Hilden Nails Arzzt Systems met the requirements of ASTM F-136-13, ASTM F-983-86, and ISO 5832-3:1996.

2. Sample Size Used for the Test Set and Data Provenance:

The document describes engineering analyses and material testing, not clinical studies with "test sets" in the context of diagnostic performance or AI.

Sample Size for Test Set: Not applicable in the context of this 510(k) submission, as it focuses on non-clinical performance (mechanical and material testing) rather than a clinical "test set" of patient data for a diagnostic device. The "engineering analysis" would involve a specific number of devices or material samples tested per standard protocols, but this number is not specified in the summary.
Data Provenance: Not explicitly stated for the engineering analysis, but typically these tests are conducted in a controlled lab environment. The document refers to "similar clinical" outcomes, implying anecdotal or general clinical experience rather than a formal clinical study used as a "test set."

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

Not applicable. This is not a study requiring expert readers to establish ground truth for a diagnostic test. The "ground truth" for mechanical properties is established by physical testing against engineering standards.

4. Adjudication Method for the Test Set:

Not applicable. There is no diagnostic "test set" requiring adjudication.

5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done:

No. This is a submission for an orthopedic implant (intramedullary fixation rod), not a diagnostic device that would involve human readers or AI assistance in image interpretation.

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

No. There is no algorithm or AI component in these devices. The "standalone" performance refers to the device's mechanical and material properties as an implant.

7. The Type of Ground Truth Used:

Mechanical Performance: "Ground truth" is established by physical testing against established engineering standards (e.g., ASTM, ISO) for static bending and torsional yield, and comparison to the mechanical properties of predicate devices.
Biocompatibility: "Ground truth" is based on the material specification (medical-grade Ti6Al4V) and prior FDA clearances/publications regarding the biocompatibility of this material and manufacturing processes (referenced K133166, K162507).
Clinical Efficacy/Safety (implied): "Ground truth" for clinical outcomes is implied through clinical experience and historical data with predicate devices and similar materials, stating "patients had no complications with either system during the healing process." This is not a formal "ground truth" derivation as in a clinical trial.

8. The Sample Size for the Training Set:

Not applicable. There is no AI or algorithm involved that would require a "training set."

9. How the Ground Truth for the Training Set was Established:

Not applicable. No training set is used.

Summary

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA acronym with the full name of the agency on the right. The symbol on the left is a stylized representation of human services. To the right of the symbol is the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG" in a larger, bold blue font, and the word "ADMINISTRATION" in a smaller, regular blue font.

Truemed Group LLC Nina Galeana Rodriguez Coordinator 2002 Timberloch Place Suite 200 The Woodlands, Texas 77380

January 16, 2018

Re: K172189

Trade/Device Name: Ins Hilden Humeral Arzzt, Ins Hilden Cannulated Tibial Arzzt, Ins Hilden Femoral Arzzt & Ins Hilden Retrograde Femoral Arzzt Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary Fixation Rod Regulatory Class: Class II Product Code: HSB Dated: December 12, 2017 Received: December 14, 2017

Dear Ms. Nina Galeana Rodriguez:

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 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); good

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

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Mark N. Melkerson -S

Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Image /page/2/Picture/1 description: The image contains the logo for TrueMed Group. The logo consists of a teal-colored abstract symbol on the left, resembling a stylized person within a circle. To the right of the symbol, the word "TRUEMED" is written in a bold, dark gray font, with "GROUP" written in teal below it. A horizontal line extends from the word "GROUP" to the right.

2002 Timberloch Pl Suite 200 The Woodlands, Texas 77380

Indications for Use

510(k) Number (if known): K172189

Device Name:

Ins Hilden Humeral Arzzt, Ins Hilden Cannulated Tibial Arzzt, Ins Hilden Femoral Arzzt & Ins Hilden Retrograde Femoral Arzzt.

Indications for use:

Prescription Use: ____________________________________________________________________________________________________________________________________________________________

AND/OR

Over-The-Counter Use: ________________________________________________________________________________________________________________________________________________________

(Part 21 CFR 801 Subpart D)

(21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

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Premarket Notification 510(k) Summary

1.	Submitter's Name:	Trumed Group LLC
2.	Contact Person:	Jorge Trujillo Zavala
		2002 Timberloch Pl Suite 200
		The Woodlands, Texas 77380
		Phone 832 442 2310
3.	Date Prepared:	June 5, 2017
4.	Device Name:	Ins Hilden Humeral Arzzt, Ins Hilden Cannulated Tibial Arzzt, Ins HildenFemoral Arzzt & Ins Hilden Retrograde Femoral Arzzt.
5.	Common Name:	Rod, Fixation, Intramedullary and Accessories
6.	Classification Name:	Rod, Fixation, Intramedullary and Accessories per 21 CFRsection 888.3020
7.	Product Codes:	HSB
8.	Devices Classification:	Class II
9.	Regulation Numbers:	21 CFR 888.3020
10.	Predicate Devices:	Ins Hilden Tibial Arzzt K133166DEPUY ACE Antegrade Retrograde Humeral Nail System K033878DEPUY ACE VERSANAIL TIBIAL NAIL K032097T2 Femoral Nail (K010801)ARZZT 3.5/4.5 Small and Large Fragment System (K162507)Devices Description:I. The Ins Hilden Humeral Arzzt is a single use system that consist thefollowing components:

i. Nail, is solid and cannulated, with five orifices, two for distal locking and three for the proximal locking. One of the orifices on the proximal locking is for static locking and one for dynamic

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locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.

ii. End caps.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

The system is manufactured from titanium alloy Ti6Al4V, a medical-grade material that is recognized as generally accepted for the manufacture of implants for their level of biocompatibility with surrounding tissues. It is intended to be used in adult men and women, and implanted during surgeries performed in hospitals.

II. The Ins Hilden Femoral Arzzt is a single use system that consist the following components:

i. Nail, is solid and cannulated with four orifices, two for distal locking and two for the proximal locking. One of the orifices on the proximal locking is for static locking and one for dynamic locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extractionhole.
End caps. ii.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

The system is manufactured from titanium alloy Ti6Al4V, a medicalgrade material that is recognized as generally accepted for the manufacture of implants for their level of biocompatibility with surrounding tissues. It is intended to be used in adult men and women, and implanted during surgeries performed in hospitals.

III. The Ins Hilden Femoral Retrograde Arzzt is a single use system that consist the following components:

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i. Nail, is solid and cannulated, with five orifices, two for distal locking and three for the proximal locking. All three proximal orifices for static locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.
ii. End caps.
Locking Screws with conical head and self-tapping on the head iii. and blunt.

IV. The Ins Hilden Cannulated Tibial Arzzt is a single use system that consist the following components:

i. Nail, is cannulated, with four orifices, two for distal locking and four for the proximal locking. All three proximal orifices for static locking. Also the nail is milled on the distal end and flat at the proximal end with a threaded insertion/extraction hole.
End caps. ii.
iii. Locking Screws with conical head and self-tapping on the head and blunt.

1. Intended Uses: Ins Hilden Arzzt Nail Systems, consisting of intramedullary solid and cannulated nails, end cap and locking screws, are intended for fixation of fractures of different types: of the shaft; open and closed shaft fractures; and malunion and non-unions of the Femur, Tibia, and Humerus.
1. Analysis Performed: We performed engineering analyses comparing the static bending and

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static torsional yield of the predicate devices with the subject devices confirming substantial equivalence within them.

13. Standards:	· ASTM F-136-13 Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI (Extra Low Interstitial) Alloy for SurgicalImplant Applications.• ASTM F-983-86 Standard Practice for Permanent Marking ofOrthopedic Implant Components• ISO 5832-3:1996. Implants for surgery - Metallic materials - Part 3:Wrought titanium 6-aluminium 4-vanadium alloyThe Ins Hilden Nails Arzzt Systems met the requirements of the abovestandards.
15. Substantial Equivalence:	Comparing the INS HILDEN HUMERAL ARZZT, INS HILDEN CANNULATEDTIBIAL ARZZT, INS HILDEN FEMORAL ARZZT, and the INS HILDENFEMORAL RETROGRADE ARZZT systems with the PREDICATE DEVICES(K133166, K033878, K032097) which have the device names in ordershown INS HILDEN TIBIAL ARZZT, DEPUY ACE Antegrade RetrogradeHumeral Nail System, T2 Femoral Nail (K010801) and ARZZT 3.5/4.5Small and Large Fragment System (K162507) we found the followingconclusion:

13. Standards:

· ASTM F-136-13 Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI (Extra Low Interstitial) Alloy for SurgicalImplant Applications.• ASTM F-983-86 Standard Practice for Permanent Marking ofOrthopedic Implant Components• ISO 5832-3:1996. Implants for surgery - Metallic materials - Part 3:Wrought titanium 6-aluminium 4-vanadium alloyThe Ins Hilden Nails Arzzt Systems met the requirements of the abovestandards.

15. Substantial Equivalence:

Comparing the INS HILDEN HUMERAL ARZZT, INS HILDEN CANNULATEDTIBIAL ARZZT, INS HILDEN FEMORAL ARZZT, and the INS HILDENFEMORAL RETROGRADE ARZZT systems with the PREDICATE DEVICES(K133166, K033878, K032097) which have the device names in ordershown INS HILDEN TIBIAL ARZZT, DEPUY ACE Antegrade RetrogradeHumeral Nail System, T2 Femoral Nail (K010801) and ARZZT 3.5/4.5Small and Large Fragment System (K162507) we found the followingconclusion:

SUBSTANTIAL EQUIVALENCE CONCLUSION

SIMILARITIES

Stabilization of fractures, osteotomies and non-unions of long bones. Intended Uses:

Once the nail is inside the bone, the fixation of the fracture is the same, since the limb is Fixation: immobilized.

Types of fractures: Closed and open fractures type A, B and C from AO classification.

O Target Population: Men and Women in adulthood.
O Material: Same Titanium alloy Ti6Al4V
Implant technique: All nails use the same principle of attaching to a O

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modular assembly to insert the nail.

PERFORMANCE

All systems are intended for fixation of fractures, of long bones, closed and open fractures type A, B and C from AO classification, with delay or without consolidation and bones osteotomies and non-unions.

With similar clinical, the patients had no complications with either system during the healing process, after the reduction and fixation of the fracture with the subject devices, we can conclude substantial equivalence between the predicate K133166 Ins Hilden Tibial Arzzt and the subject devices.

According to the engineering analysis, the subject devices are stronger when applying the same force than the predicate devices K033878, K010801 which has the device name in the same order as shown, DEPUY ACE Antegrade Retrograde Humeral Nail System, DEPUY ACE VERSANAIL TIBIAL NAIL and T2 Femoral Nail. For this reason, when patients are recovering, the nail is strong enough to support them as the predicate devices do.

BIOCOMPATIBILITY

The system is made of TAV (Ti6Al4V), titanium alloy implant medical grade, which is considered as a biomaterial and is according to the ISO 5832- 03: Implants for surgery - Metallic materials - wrought titanium 6- aluminum 4-vanadium alloy.

There is no potential impact of the manufacturing processes when using titanium alloy Ti6Al4V on the biocompatibility of the final device according FDA submission K133166. It provides scientific information to demonstrate that the formulation change does not alter the chemical or physical properties of the medical device in its final finished form, and therefore, results from the Ins Hilden Tibial Arzzt PREDICATE DEVICE (K133166) can be applied to the medical devices in its final finished form.

There is no potential impact of the manufacturing processes when using titanium alloy Stainless Steel AISI 304 on the biocompatibility of the final device according FDA submission K162507. It provides scientific information to demonstrate that the formulation change does not alter the chemical or physical properties of the medical device in its final finished form, and therefore, results from the ARZZT 3.5/4.5 Small and Large Fragment System can be applied to the medical device in its final finished form, since both predicate and subject devices manufactured from the same material with the same manufacturing process with similar body contact and duration to each of the patient contacting instruments and the titanium screw.

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DIFFERENCES

Design: Each design has slightly different geometry, with slight differences in angles, curvatures, and different lengths to fit the different long bones. These differences do not affect the final result, since each nail fits a specific bone, helping the stabilization and healing of the fracture.

REASONS WHY EACH DIFFERENCE DOES OR DOES NOT ADD NEW OR INCREASED RISKS AND COMPLICATIONS

Design

The design differences do not increase risks and complications. Since the systems designed to fit specific bones, so as the predicate devices are designed to fit a specific bone. The performance of all, is according.

POTENTIAL BENEFITS

Each system is designed to fit the specific type of bone.

FINAL CONCLUSION

Based on the technological properties of the subject devices as compared to the predicate devices, we understand that no new questions of safety and effectiveness have been raised, and that the subject devices are substantially equivalent to the predicate devices.

Regulation Number and Section

§ 888.3020 Intramedullary fixation rod.

(a)
Identification. An intramedullary fixation rod is a device intended to be implanted that consists of a rod made of alloys such as cobalt-chromium-molybdenum and stainless steel. It is inserted into the medullary (bone marrow) canal of long bones for the fixation of fractures.(b)
Classification. Class II.