(63 days)
PolyBone® Granule & Block is indicated for filling bone voids or defects that are not intrinsic to the stability of the bony structure. PolyBone® Granule & Block is to be packed into bony voids or gaps of the skeletal system (such as extremities, spine and the pelvis). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. PolyBone® Granule & Block is a bone graft substitute that resorbs and it replaced with bone during the healing process.
PolyBone® Granule & Block is a synthetic resorbable calcium phosphate bone void filler consisted of 99.99% beta-tricalcium phosphate, and 0.01% polyphosphate. It is an osteoconductive material which provides a porous scaffold upon which bone formation can occur. The multidirectional interconnected porosity ranges from 7585% with a 200500 um pore size. Mechanism of PolyBone® Granule & Block's bone regeneration works by bone cells resorbing polyphosphate, which is a bone regenerating palpation material. Indication for use of PolyBone® Granule & Block is a filler of bone void regions. The device is available in a variety of shape and sizes.
The provided document is a 510(k) summary for a medical device called "PolyBone® Granule & Block," which is a resorbable calcium salt bone void filler. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than clinical efficacy through studies with acceptance criteria for device performance.
Therefore, the document does not contain information related to acceptance criteria, specific device performance metrics, or a study of the device's clinical performance against such criteria. It relies on similarity to predicate devices and biocompatibility testing.
Here's an explanation based on the information provided and what is typically found in a 510(k) for this type of device:
1. Table of acceptance criteria and the reported device performance:
- Not applicable / Not provided. The 510(k) submission for "PolyBone® Granule & Block" does not detail performance acceptance criteria for clinical outcomes (e.g., bone regeneration rate, fusion success rate) or specific device functions beyond its material properties and chemical composition. The "performance properties similarities" section refers to its intended use and material characteristics, not quantitative performance metrics.
2. Sample size used for the test set and the data provenance:
- Not applicable / Not provided. No test set for clinical performance is described as this is a 510(k) submission based on substantial equivalence, not a clinical trial. The "test set" mentioned in typical AI/ML studies is not relevant here.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable / Not provided. Ground truth determination by experts for a test set is specific to studies evaluating diagnostic or predictive algorithms, which is not the nature of this submission.
4. Adjudication method for the test set:
- Not applicable / Not provided. Adjudication methods are used in studies involving expert review of data, which is not described here.
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 / Not provided. MRMC studies are conducted for diagnostic imaging devices or AI-assisted diagnostic tools. "PolyBone® Granule & Block" is a bone void filler, a therapeutic device, thus this type of study is not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable / Not provided. This question pertains to AI/ML algorithms. "PolyBone® Granule & Block" is a physical medical device (bone void filler), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable / Not provided. As no clinical performance study against specific criteria is described, there's no mention of a "ground truth" for clinical outcomes. The "ground truth" for this device largely rests on its chemical composition being consistent, its biocompatibility, and its mechanical properties being suitable for its intended use as a bone void filler, and its similarity to established predicate devices.
8. The sample size for the training set:
- Not applicable / Not provided. This question is relevant for AI/ML models. No training set is mentioned as this is a physical medical device.
9. How the ground truth for the training set was established:
- Not applicable / Not provided. Similar to point 8, this is not relevant for this device.
Summary of the K082338 Submission:
The K082338 submission for PolyBone® Granule & Block primarily focuses on demonstrating substantial equivalence to existing legally marketed predicate devices (Kasios TCP, Vitoss Scaffold) by showing similarities in:
- Components: All devices are packed in a container.
- Indication for Use: All devices have the same indication for use: filling bone voids or defects that are not intrinsic to the stability of the bony structure.
- Chemical Similarities: All devices are made up of the ß-Tricalcium phosphate family. (PolyBone® is 99.99% beta-tricalcium phosphate, and 0.01% polyphosphate).
- Performance Properties Similarities: All devices are for filling bone voids or defects that are not intrinsic to the stability of the bony structure.
- Biocompatibility: The device underwent ISO10993-1:2003 testing (cytotoxicity, sensitization, intracutaneous reactivity, systemic toxicity, subchronic toxicity, genotoxicity, and implantation) and was found to be "biologically safe."
The FDA's review concluded that the device is "safe and effective and substantially equivalent to predicate device." This means it does not present new questions of safety or effectiveness compared to the predicate devices, and therefore does not require extensive new clinical studies to prove efficacy against defined acceptance criteria.
§ 888.3045 Resorbable calcium salt bone void filler device.
(a)
Identification. A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.