K Number
K111232
Device Name
GAP ENDO-EXO MEDULLARY SYSTEM
Manufacturer
Date Cleared
2012-01-26

(269 days)

Product Code
Regulation Number
888.3020
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The GAP Endo-Exo Medullary System is indicated as a temporary implant to assure alignment, stabilization and fixation of: long bones that have been surqically prepared (osteotomy) for correction of deformities or fractures caused by trauma or disease. The GAP Endo-Exo Medullary System is used for pediatric patients (child and adolescent) age 2 to 21. It can be used to correct the following conditions: - Diaphyseal facture of the femur, tibia and humerus . - Fractures of the femoral neck . - . Subtrochanteric, intertrochanteric and combination fractures - . Correction of deformities (OI, Coxa vara, Coxa valga) - . Nonunions and malunions
Device Description
The GAP Endo-Exo Medullary System consists of an intramedullary cannulated nail linked to various types of plates via and/or mechanical screws creating a a combined laq Endoamedullary/ Exomedullary osteosythesis device. 3 and 4mm cortical screws are used to secure the nail to the bone.
More Information

Not Found

No
The device description and performance studies focus on mechanical properties and surgical application, with no mention of AI or ML.

No
Explanation: This device is an implantable medical device used for fixation and stabilization of bones after surgery due to trauma or disease. It is not designed to treat a disease or condition itself, but rather to support the bone's natural healing process.

No

The device description indicates it is an implant system used for fixation and stabilization of long bones after osteotomy. Its purpose is to correct deformities or fractures, not to diagnose them.

No

The device description clearly states it consists of physical components like an intramedullary cannulated nail, plates, and screws, which are hardware.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples such as blood, urine, or tissue taken from the human body to detect diseases, conditions, or infections.
  • Device Description and Intended Use: The description clearly states that the GAP Endo-Exo Medullary System is a surgical implant used to stabilize and fix long bones. It is a physical device inserted into the body, not a test performed on a sample outside the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, detecting biomarkers, or providing diagnostic information based on laboratory testing.

Therefore, the GAP Endo-Exo Medullary System falls under the category of a surgical implant or orthopedic device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The GAP Endo-Exo Medullary System is indicated as a temporary implant to assure alignment, stabilization and fixation of: long bones that have been surqically prepared (osteotomy) for correction of deformities or fractures caused by trauma or disease. The GAP Endo-Exo Medullary System is used for pediatric patients (child and adolescent) age 2 to 21. It can be used to correct the following conditions:

  • Diaphyseal facture of the femur, tibia and humerus .
  • Fractures of the femoral neck .
  • . Subtrochanteric, intertrochanteric and combination fractures
  • . Correction of deformities (OI, Coxa vara, Coxa valga)
  • . Nonunions and malunions

Product codes

HSB

Device Description

The GAP Endo-Exo Medullary System consists of an intramedullary cannulated nail linked to various types of plates via and/or mechanical screws creating a a combined laq Endoamedullary/ Exomedullary osteosythesis device. 3 and 4mm cortical screws are used to secure the nail to the bone.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

long bones (femur, tibia, humerus, femoral neck)

Indicated Patient Age Range

pediatric patients (child and adolescent) age 2 to 21

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Biomechanical Testing: A static 4 point bending test, torsion test and 4 point bending fatique test based on the ASTM standard 1264 "Standard Specifications and Test Method L for Intramedullary Fixation Devices" were performed to demonstrate safety. The results indicated that the GAP Endo-Exo Medullary System is functionally safe for its intended use.
Clinical Testing: No clinical testing was provided as a basis for substantial equivalence. A clinical data report based on equivalent products can be found in Appendix H.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K041393, K020885, K070843, K993956

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

JAN 2 6 2012

K111232

Montreal, January 16th, 2012

510 (k) SUMMARY OF SAFETY AND EFFECTIVENESS

Applicant: Pega Medical Inc. 1111 Autoroute Chomedey Laval, Quebec H7W 5J8 Canada

Contact Person: Ariel R. Duiovne

Proprietary Name: GAP Endo-Exo Medullary System

Common Name: Intramedullary Nail

Device Classification: Class II

Classification Name: Rod, Fixation, Intramedullary And Accessories 21 CFR 888-3020

Device Product Code: HSB

Establishment Reqistration Number: 9048931

Intended Use: The GAP Endo-Exo Medullary System is indicated as a temporary implant to assure alignment, stabilization and fixation of: long bones that have been surqically prepared (osteotomy) for correction of deformities or fractures caused by trauma or disease. The GAP Endo-Exo Medullary System is used for pediatric patients (child and adolescent) age 2 to 21. It can be used to correct the following conditions:

  • Diaphyseal facture of the femur, tibia and humerus .
  • Fractures of the femoral neck .
  • . Subtrochanteric, intertrochanteric and combination fractures
  • . Correction of deformities (OI, Coxa vara, Coxa valga)
  • . Nonunions and malunions

Page 1 of 2

1

K111232

Description: The GAP Endo-Exo Medullary System consists of an intramedullary cannulated nail linked to various types of plates via and/or mechanical screws creating a a combined laq Endoamedullary/ Exomedullary osteosythesis device. 3 and 4mm cortical screws are used to secure the nail to the bone.

Basis for substantial equivalent:

The GAP Endo-Exo Medullary System is claimed to be substantially equivalent in design and function to the following predicate devices:

  • Fassier-Duval Telescopic IM System (Stainless steel or Ti 1. pediatric nail), Pega Medical Inc. (K041393/K020885)
    1. Synthes Adolescent Lateral Entry Femoral Nail System (Ti alloy nail and screws), Synthes USA. (K070843)
    1. Titanium Pediatric Femoral Nail (Ti alloy nail and screws) Biomet Inc. (K993956)

The intended uses of these devices are the same as the GAP Endo-Exo Medullary System

Summary of Technologies: The technological characteristics of the GAP Endo-Exo Medullary System are the same or similar to the ones of the predicate devices.

Biomechanical Testing: A static 4 point bending test, torsion test and 4 point bending fatique test based on the ASTM standard 1264 "Standard Specifications and Test Method L for Intramedullary Fixation Devices" were performed to demonstrate safety. The results indicated that the GAP Endo-Exo Medullary System is functionally safe for its intended use.

Clinical Testing: No clinical testing was provided as a basis for substantial equivalence. A clinical data report based on equivalent products can be found in Appendix H.

Page 2 of 2

2

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three stripes representing the three levels of government: federal, state, and local. The eagle is encircled by the words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" in a circular arrangement.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Pega Medical Inc % Mr. Ariel R. Dujovne 1111 Autoroute Chomedey Laval, Quebec H7W 5J8 Canada

JAN 2 6 2012

Re: K111232

Trade/Device Name: GAP Endo-Exo Medullary System Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary Fixation Rod Regulatory Class: Class II Product Code: HSB Dated: January 16. 2012 Received: January 18, 2012

Dear Mr. Dujovne:

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

3

Page 2 - Mr. Ariel R. Dujovne

device-related adverse events) (21 CFR 803); good 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.

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/CDRHQffices/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 Melkerson Director Division of Surgical, Orthopedic & Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

Indications for Use Statement

510(k) Number (if known):

Device Name: GAP ENDO-EXO MEDULLARY SYSTEM

Indications for Use:

The GAP Endo-Exo Medullary System is indicated as a temporary implant to assure alignment, stabilization and fixation of: long bones that have been surgically prepared (osteotomy) for correction of deformities or fractures caused by trauma or disease. The GAP Endo-Exo Medullary System is used for pediatric patients (child and adolescent) age 2 to 21. It can be used to correct the following conditions:

  • Diaphyseal facture of the femur, tibia and humerus .
  • Fractures of the femoral neck .
  • Subtrochanteric, intertrochanteric and combination fractures .
  • Correction of deformities (OI, Coxa vara, Coxa valga) ●
  • Nonunions and malunions .

Over-The-Counter Use _ Prescription Use no AND/OR (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Tan N. Phyp

Page 1 of 1

for (Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K\1232