(134 days)
The Suspension™ Clavicle Fracture Fixation System can be used for adult patients. The Suspension™ Clavicle Fracture Fixation plates and screws are indicated for fixation of clavicle fractures.
The Suspension™ Clavicle Fracture Fixation System is an internal fixation system consisting of various sized plates and screws. The plates and screws are fabricated from 316L Stainless Steel.
The device consists of the following implantable components (some or all of which may be used based on the nature of the injury):
-
- Three (3) Sizes of Clavicle Fracture Plate for Each Shoulder (i.e. small, medium, and large; each with Left & Right).
-
- Eight (8) Lengths each of 2.7mm Non-Locking & Locking Bone Screws.
-
- Eight (8) Lengths each of 3.5mm Non-Locking & Locking Bone Screws.
Implantable components are included in a surgical tray that must be steam sterilized by the hospital or surgical center. These components are intended for re-sterilization, but these components are for single use only.
The implants are used with instrumentation including:
- Hex Driver .
- o Handle and a 2.5mm hex driver for hand tightening bone screws
- Assorted Drill bits .
- o To create pilot holes for bone screws. The drill bits are compatible with most AO connections.
- Drill Guide Assemblies .
Here's an analysis of the provided 510(k) summary regarding the Suspension™ Clavicle Fracture Fixation System, focusing on acceptance criteria and supporting studies.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Test/Standard | Acceptance Criteria | Reported Device Performance | Study Type/Evidence |
|---|---|---|---|---|
| Biocompatibility | Material Selection | Material is commonly used for orthopedic implants with a long history of biocompatibility. | 316L Stainless Steel is commonly used for orthopedic implants with a long history of biocompatibility. | Material analysis, common knowledge in orthopedics |
| Mechanical Performance | Torsional Strength | Equivalent to predicate device. | Performed in a manner equivalent to predicate devices. | Non-clinical testing |
| Mechanical Performance | Torsional Break | Equivalent to predicate device. | Performed in a manner equivalent to predicate devices. | Non-clinical testing |
| Mechanical Performance | Four Point Bending | Equivalent to predicate device. | Performed in a manner equivalent to predicate devices. | Non-clinical testing |
| Mechanical Performance | Screw Driving Torque | Equivalent to predicate device. | Performed in a manner equivalent to predicate devices. | Non-clinical testing |
| Comparative Analysis | Predicate Comparison | Substantially equivalent to predicate device (Smith & Nephew Peri-Loc locking bone plates, locking and non-locking bone screws for the upper extremity - K061352) in materials, sterility, and performance. | "The subject devices are substantially equivalent to the predicate devices. Both the subject device and predicate device have indications for clavicle... The devices are composed of the same materials, and have the same sterility. The devices are used with 3.5mm and 2.7mm locking or non-locking screws." | Predicate Device Comparison Analysis |
2. Sample Size Used for the Test Set and Data Provenance
The provided document describes non-clinical testing (e.g., mechanical tests like torsional strength, bending, screw driving torque) and a predicate device comparison analysis. These types of tests typically do not involve human subject data or "test sets" in the sense of clinical trials. The sample sizes for these mechanical tests are not specified in the summary, but would refer to the number of devices or components tested. The data provenance is internal to the manufacturer's testing facility.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable. The evaluations were based on engineering and material science principles, and comparison to a predicate device, not on expert consensus of clinical data.
4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set
This information is not applicable as there was no clinical test set requiring ground truth 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 information is not applicable. This device is a physical orthopedic implant, not an AI or imaging diagnostic tool. Therefore, an MRMC study is irrelevant to this submission.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
This information is not applicable. This is a physical medical device, not an algorithm.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
For the non-clinical mechanical tests, the "ground truth" is defined by established engineering standards and comparative performance against the legally marketed predicate device. For the predicate comparison, the ground truth is the established safety and effectiveness profile of the predicate device (Smith & Nephew Peri-Loc locking bone plates, locking and non-locking bone screws for the upper extremity - K061352).
8. The Sample Size for the Training Set
This information is not applicable. This is a physical orthopedic implant, not a machine learning algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the same reason as above.
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K102095 510(k) Summary
DEC - 7 2010
Suspension™ Clavicle Fracture Fixation System
July 23, 2010
Submitter/Regulatory Contact:
Joseph Azarv Orchid Design 80 Shelton Technology Center Shelton, CT 06484 Tel: (203) 922-0105 Email: joseph.azary@orchid-orthopedics.com
Sponsor/Manufacturer:
Suspension Orthopaedic Solutions, LLC 2635 Riva Road, Suite 100 Annapolis, MD 21401
FDA Establishment Registration Number: Pending
Trade Name, Common Name, Classification:
Device Trade Name: Suspension™ Clavicle Fracture Fixation System
Device Common or Usual Names: Bone Plates, Bone Screws
Classification: Class II
Classification Name: Single/Multiple component metallic bone fixation appliances and accessories
Regulation: 21 CFR 888.3030
Product Codes: HRS and HWC
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Predicate Device:
Smith & Nephew Peri-Loc locking bone plates, locking and non-locking bone screws for the upper extremity - K061352
Description of the Device:
The Suspension™ Clavicle Fracture Fixation System is an internal fixation system consisting of various sized plates and screws. The plates and screws are fabricated from 316L Stainless Steel.
The device consists of the following implantable components (some or all of which may be used based on the nature of the injury):
-
- Three (3) Sizes of Clavicle Fracture Plate for Each Shoulder (i.e. small, medium, and large; each with Left & Right).
-
- Eight (8) Lengths each of 2.7mm Non-Locking & Locking Bone Screws.
-
- Eight (8) Lengths each of 3.5mm Non-Locking & Locking Bone Screws.
Implantable components are included in a surgical tray that must be steam sterilized by the hospital or surgical center. These components are intended for re-sterilization, but these components are for single use only.
The implants are used with instrumentation including:
- Hex Driver .
- o Handle and a 2.5mm hex driver for hand tightening bone screws
- Assorted Drill bits .
- o To create pilot holes for bone screws. The drill bits are compatible with most AO connections.
- Drill Guide Assemblies .
Intended Use:
The Suspension™ Clavicle Fracture Fixation System can be used for adult patients. Suspension " Clavicle Fracture Fixation plates and screws are indicated for fixation of clavicle fractures.
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Technological Characteristics:
The subject devices are substantially equivalent to the predicate devices. Both the subject device and predicate device have indications for clavicle. However, the predicate device also has indications for many other bones (including tibia, femur, pelvis, humerus, metacarpals, etc). The devices are composed of the same materials, and have the same sterility. The devices are used with 3.5mm and 2.7mm locking or non-locking screws.
Performance:
The material (316L Stainless Steel) selected is commonly used for orthopedic implants with a long history of biocompatibility.
The devices have been subjected to recognized consensus standards for these types of devices and perform in a manner equivalent to the predicate devices. The device has been subjected to non-clinical testing including Torsional Strength and Break, Four Point Bending, Screw Driving Torque, and Predicate Device Comparison Analysis.
Conclusion:
We believe that based on the predicate device comparison and the non-clinical testing performed the subject devices are substantially equivalent to the predicate devices and conclude that the subject devices are as safe and effective as the predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized human figure or a bird in flight, composed of three curved lines.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Suspension Orthopaedic Solutions, LLC % Mr. Curtis Raymond Senior Regulatory & Quality Consultant Orchid Design, A Division of Orchid Orthopedic Solutions 80 Shelton Technology Center Shelton, Connecticut 06484
DEC - 7 2010
Re: K102095
Trade/Device Name: Suspension™ Clavicle Fracture Fixation System Regulation Number: 21 CFR 888.3030 Regulation Name: Single/multiple component metallic bone fixation appliances and accessories Regulatory Class: Class II Product Code: HRS, HWC Dated: November 24, 2010 Received: November 29, 2010
Dear Mr. Raymond:
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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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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.
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/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Mark N. Melke 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):
DEC - 7 2010
Device Name: Suspension™ Clavicle Fracture Fixation System
Indications For Use:
់
The Suspension™ Clavicle Fracture Fixation System can be used for adult patients. The Suspension™ Clavicle Fracture Fixation plates and screws are indicated for fixation of clavicle fractures.
Prescription Use × (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, Office of Device Evaluation (ODE)
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for M. Mulkerson
(Division Sign-Off)
Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K102095
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N/A