(276 days)
Synthetic Mineral – Collagen Bone Graft Matrix, combined with autogenous bone marrow, is intended for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Synthetic Mineral - Collagen Bone Graft Matrix is indicated to be packed gently into bony voids or gaps of the skeletal system, i.e., extremities and pelvis. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone.
Synthetic Mineral – Collagen Bone Graft Matrix is a composite of synthetic calcium phosphate based granules and type I collagen. The calcium phosphate mineral has an apatite structure similar to that of natural bone. The type I collagen is derived from bovine Achilles tendon. The composite material is a resorbable, porous, osteoconductive bone graft matrix. The product is supplied dry in granular (putty) or block/strip form that is hydrated with autogenous bone marrow at the point of use. The product is sterile, non-pyrogenic, and for single use only.
The provided text describes a 510(k) summary for the "Synthetic Mineral – Collagen Bone Graft Matrix" device. This is a medical device submission, and the "acceptance criteria" and "device performance" in this context refer to demonstrating substantial equivalence to a predicate device, rather than a quantifiable performance metric against a specific threshold as might be found in a diagnostic AI study.
Therefore, the requested table of acceptance criteria and reported device performance will be structured to reflect the substantial equivalence claim.
Here's the breakdown of the information based on your request:
Description of the Acceptance Criteria and Study
The "Synthetic Mineral – Collagen Bone Graft Matrix" is a Class II medical device, granted 510(k) clearance by demonstrating substantial equivalence to a predicate device (OssiMend™ Bone Graft Material, K052812). The "acceptance criteria" for this type of submission are not presented as numerical thresholds for specific performance metrics (like sensitivity/specificity for an AI device) but rather as an assurance that the new device is as safe and effective as the predicate device based on similar technological characteristics, materials, and intended use. The "study" described focuses on non-clinical performance data (animal studies) and comparison of technological characteristics.
1. Table of Acceptance Criteria and Reported Device Performance
| Feature/Criterion for Substantial Equivalence | Acceptance Method/Comparison | Reported Device Performance/Conclusion |
|---|---|---|
| Intended Use | Comparison with predicate device's intended use. | Intended use is the same: "for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure... indicated to be packed gently into bony voids or gaps of the skeletal system, i.e., extremities and pelvis. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone." |
| Technological Characteristics | Comparison of design, materials, material characterization, and product forms with predicate device. Bench tests included mineral structure analysis, collagen purity, and resorption studies. | "Synthetic Mineral - Collagen Bone Graft Matrix and its predicates have the same key technological characteristics. In particular, the Synthetic Mineral – Collagen Bone Graft Matrix and its predicates are the same with respect to intended use, design, materials, material characterization, and product forms." |
| Biocompatibility | Evaluation using selected FDA Blue Book Memorandum G95-1 and ISO 10993-1 testing. | "The device passed all selected FDA Blue Book Memorandum G95-1 and ISO 10993-1 testing for the biological evaluation of medical devices." |
| Performance (Bone Ingrowth) | Animal studies: a rabbit round femur defect model and a segmental radial defect model. Endpoint measurements included radiographs and histology. Comparison was made "with respect to predicate device." | "These studies demonstrated with respect to predicate device the safety and performance of the Synthetic Mineral and Mineral - Collagen Composite materials in supporting bone ingrowth in orthopaedic applications." |
| Safety and Effectiveness | Overall conclusion based on in vitro product characterization, in vitro and in vivo biocompatibility studies, animal performance studies, and clinical experience with predicate devices. | "The results... show that the Synthetic Mineral - Collagen Bone Graft Matrix is safe with respect to predicate device and substantially equivalent to its predicate device." |
2. Sample size used for the test set and the data provenance
- Test Set Sample Size: The document mentions "a rabbit round femur defect model and a segmental radial defect model." Specific numbers of animals per model are not provided in the summary.
- Data Provenance: The animal studies were likely conducted within the US, as is common for submissions to the FDA, but the country of origin is not explicitly stated. The studies are prospective in nature, as they involve performing procedures on animals and observing outcomes.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- The document does not specify the number of experts or their qualifications for establishing ground truth in the animal studies.
- For histological and radiological evaluations, it is implied that qualified personnel (e.g., veterinary pathologists, radiologists) would have interpreted the results, but no details are given.
4. Adjudication method for the test set
- The document does not mention any explicit adjudication method for the interpretation of the animal study results (e.g., 2+1, 3+1 consensus). It's typically assumed that such reports are generated by a single qualified expert in each domain (histology, radiology).
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, an MRMC comparative effectiveness study was not done. This type of study is relevant for AI-assisted diagnostic devices. The submission concerns a bone graft matrix, not an AI diagnostic algorithm.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No, a standalone algorithm performance study was not done. This concept is not applicable to a physical medical device like a bone graft matrix.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the animal studies, the "ground truth" and endpoint measurements included:
- Radiographs (imaging evidence of bone formation/repair).
- Histology (microscopic examination of tissue to assess bone ingrowth, material resorption, and tissue response).
- These are considered objective biological and imaging markers.
8. The sample size for the training set
- This concept is not applicable to this submission. "Training set" refers to data used to train an AI model. This device is a physical bone graft, not an AI algorithm.
9. How the ground truth for the training set was established
- This concept is not applicable to this submission, as there is no "training set" for a physical medical device.
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1092608
510(k) Summary
MAY 2 8 2010
| Applicant Name and Address: | Collagen Matrix, Inc.509 Commerce StreetFranklin Lakes, New Jersey 07417 |
|---|---|
| Contact Person: | Peggy Hansen, RACVP, Clinical, Regulatory, QA, and MarketingTel: (201) 405-1477Fax: (201) 405-1355 |
| Date of Summary: | May 27, 2010 |
| Device Common Name: | Bone Grafting Material |
| Device Trade Name: | Synthetic Mineral - Collagen Bone Graft Matrix |
| Device Classification Name: | Filler, Bone Void, Calcium Compound |
| Regulation Number: | 888.3045 |
| Product Code: | MQV |
| Device Class | Class II |
| Predicate Device(s): | OssiMend™ Bone Graft MaterialK052812 |
Description of the Device
Synthetic Mineral – Collagen Bone Graft Matrix is a composite of synthetic calcium phosphate based granules and type I collagen. The calcium phosphate mineral has an apatite structure similar to that of natural bone. The type I collagen is derived from bovine Achilles tendon. The composite material is a resorbable, porous, osteoconductive bone graft matrix. The product is supplied dry in granular (putty) or block/strip form that is hydrated with autogenous bone marrow at the point of use. The product is sterile, non-pyrogenic, and for single use only.
Intended Use
Synthetic Mineral - Collagen Bone Graft Matrix, combined with autogenous bone marrow, is intended for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Synthetic Mineral – Collagen Bone Graft Matrix is indicated to be packed gently into bony voids or gaps of the skeletal system, i.e., extremities and pelvis. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone.
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Summary/Comparison of Technological Characteristics
- Technological Characteristics (a)
Synthetic Mineral - Collagen Bone Graft Matrix and its predicates have the same key technological characteristics. In particular, the Synthetic Mineral – Collagen Bone Graft Matrix and its predicates are the same with respect to intended use, design, materials, material characterization, and product forms.
Synthetic Mineral - Collagen Bone Graft Matrix and its predicates are designed as 3-dimensional, resorbable, porous, osteoconductive matrices intended to support bone formation in areas of bone deficit. The materials used are a combination of previously cleared and commercially marketed calcium phosphate mineral and type I collagen. The product was characterized by physical and chemical bench tests comparing its characteristics to those of the predicate devices. Such tests included mineral structure analysis, collagen purity, resorption studies,
Synthetic Mineral – Collagen Bone Graft Matrix has been evaluated by a number of tests to assess its safety/biocompatibility. The device passed all selected FDA Blue Book Memorandum G95-1and ISO 10993-1 testing for the biological evaluation of medical devices.
Performance Data (b)
Performance studies supporting the product were a rabbit round femur defect model and a segmental radial defect model. Endpoint measurements included radiographs and histology. These studies demonstrated with respect to predicate device the safety and performance of the Synthetic Mineral and Mineral - Collagen Composite materials in supporting bone ingrowth in orthopaedic applications.
No clinical tests were performed for the premarket submission, however, clinical experience of the predicate devices was presented in support of the candidate device.
- Conclusions Drawn from Nonclinical and Clinical Tests (c)
The results of the in vitro product characterization studies, in vitro and in vivo biocompatibility studies, animal performance studies, and clinical experience with predicate devices show that the Synthetic Mineral - Collagen Bone Graft Matrix is safe with respect to predicate device and substantially equivalent to its predicate device.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Collagen Matrix, Inc % Ms. Peggy Hansen, RAC VP Clinical, Regulatory, QA, and Marketing 509 Commerce Street Franklin Lakes, New Jersey 07417
MAY 2 8 2010
Re: K092608
Trade/Device Name: Synthetic Mineral - Collagen Bone Graft Matrix Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: II Product Code: MQV Dated: May 18, 2010 Received: May 26, 2010
Dear Ms. Hansen:
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, FIA can'y 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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Page 2 - Ms. Peggy Hansen, RAC
forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Sincerely yours,
Mark A. Millman
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): _ K092608
Device Name: _ Synthetic Mineral - Collagen Bone Graft Matrix
Indications for Use:
Synthetic Mineral – Collagen Bone Graft Matrix, combined with autogenous bone marrow, is intended for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Synthetic Mineral - Collagen Bone Graft Matrix is indicated to be packed gently into bony voids or gaps of the skeletal system, i.e., extremities and pelvis. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use _ (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Qffice of Device Evaluation (ODE)
signature
(Division Sign-Off). Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number_
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§ 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.