K Number
K111538
Device Name
SKAFFOLD CIS
Date Cleared
2011-10-25

(145 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
CAAP (Calcium Apatite) Bone Wax is indicated to control the bleeding from cut or damaged bone by acting as a mechanical barrier or tamponade.
Device Description
The single use CAAP (Calcium Apatite) Bone Wax sterile kit contains: Calcium Phosphate Powder, Dilute Sodium Silicate Liquid, and a Mixing System (Mixing Bowl, Pestle and Spatula). CAAP Bone Wax is to be mixed immediately prior to use.
More Information

Not Found

No
The device description and performance studies focus on the physical and hemostatic properties of the bone wax, with no mention of AI or ML.

No
The device is described as a mechanical barrier or tamponade to control bleeding, which is a physical action rather than a therapeutic one (e.g., drug delivery, disease treatment).

No
Explanation: The device is indicated to control bleeding by acting as a mechanical barrier or tamponade, which is a therapeutic function, not a diagnostic one. It does not identify or detect a disease or condition.

No

The device description clearly states it is a sterile kit containing physical components (powder, liquid, mixing system) and is intended to be mixed and applied as a physical barrier. It is a physical medical device, not software.

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

Here's why:

  • Intended Use: The intended use is to "control the bleeding from cut or damaged bone by acting as a mechanical barrier or tamponade." This describes a direct interaction with the patient's body to achieve a physical effect (hemostasis).
  • Device Description: The device is a bone wax applied directly to the bone.
  • Lack of In Vitro Testing: The description of the device and its intended use does not involve testing samples (like blood, urine, tissue) outside of the body to provide diagnostic information. The performance studies mentioned are bench testing (likely material properties) and animal studies, not in vitro diagnostic performance studies.

IVD devices are used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This bone wax does not fit that description.

N/A

Intended Use / Indications for Use

CAAP Bone Wax is indicated to control the bleeding from cut or damaged bone by acting as a mechanical barrier or tamponade.

Product codes

MTJ

Device Description

The single use CAAP (Calcium Apatite) Bone Wax sterile kit contains: Calcium Phosphate Powder, Dilute Sodium Silicate Liquid, and a Mixing System (Mixing Bowl, Pestle and Spatula). CAAP Bone Wax is to be mixed immediately prior to use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

bone

Indicated Patient Age Range

Not Found

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

The biocompatibility of CAAP Bone Wax is in accordance with the standard set forth in ISO 10993-1, Biological Evaluation of Medical Devices and the radiation sterilization validation is in compliance to ANSVAAMI/ISO 11137-2:2006, Sterilization of Health Care Products - Radiation - Establishing the Sterilization Dose.

The results of bench testing demonstrated that CAAP Bone Wax remains within the physiological pH and temperature range and would be expected to show no adverse biological consequence when applied as a physical hemostatic material.

The animal study provided substantial data that the use of CAAP Bone Wax as a mechanical tamponade to control bleeding in a bony site results in adequate hemostasis as compared with the predicate devices.
CAAP Bone Wax does not require clinical test.

Key Metrics

Not Found

Predicate Device(s)

K971680, K062280, K791495

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

N/A

0

Image /page/0/Picture/0 description: The image shows handwritten text including "K111538" and "p1/2". Below this, the date "OCT 25 2011" is written. The text appears to be written in black ink on a white background. The handwriting is somewhat stylized, with distinct letter formations.

Image /page/0/Picture/1 description: The image shows a logo with a circular graphic on the left and the words "Skeletal Kinetics" on the right. The circular graphic resembles a globe with intersecting lines. The text "Skeletal Kinetics" is stacked, with "Skeletal" on top of "Kinetics", and both words are in a bold, sans-serif font.

A COLSON ASSOCIATE

Product Code:

510(k) Summary

General Information as required by 21 CFR 807.92 (a) (1)

Christine Kuo, Contact Person: Director, Regulatory Affairs and Quality Assurance Phone: (408) 350-5842, Fax: (408) 366-1077

September 22, 2011 Date Prepared:

Device Name as required by 21 CFR 807.92 (a) (2)

Trade Names:CAAP (Calcium Apatite) Bone Wax
Common Name:Calcium phosphate bone wax
Classification:Unclassified

MTJ

Predicate Devices as required by 21 CFR 807.92 (a) (3)

The subject device is substantially equivalent in safety and effectiveness to the following legally marketed devices (predicates):

I. Auto Suture Bone WaxK971680
II. OsteneK062280
III. Ethicon Bone WaxPreamendment
IV. Lukens Bone WaxK791495

Device Description as required by 21 CFR 807.92 (a) (4)

The single use CAAP (Calcium Apatite) Bone Wax sterile kit contains: Calcium Phosphate Powder, Dilute Sodium Silicate Liquid, and a Mixing System (Mixing Bowl, Pestle and Spatula). CAAP Bone Wax is to be mixed immediately prior to use.

Intended Use as required by 21 CFR 807.92 (a) (5)

CAAP Bone Wax is indicated to control the bleeding from cut or damaged bone by

1

acting as a mechanical barrier or tamponade.

..............................................................................................................................................................................

Summary of Technological Characteristics as required by 21 CFR 807.92 (a) (6)

CAAP Bone Wax is composed of calcium phosphate and sodium silicate solution, when mixed together it forms a paste that can be applied directly to sites of bleeding bone, the resulting hardening material from the paste is composed of hydroxyapatite similar to the mineral phase of native bone tissue.

CAAP Bone Wax is substantially equivalent to previously cleared bone wax devices believed to control the bleeding from cut or damaged bone by acting as a mechanical barrier or tamponade.

Predicate device I, K971680, Auto Suture Bone Wax (U.S. Surgical) is indicated in the control of bleeding from bone surfaces.

Predicate device II, K062280, Ostene (Ceremed) is indicated for use in the control of bleeding from bone surfaces.

Predicate device III, preamendment, Bone Wax (Ethicon Surgical) is to control bleeding from bone.

Predicate device IV, K791495, Lukens Bone Wax (Lukens) is acts as a mechanical barrier in achieving hemostasis in bleeding bone.

Summary of Non-clinical Tests as required by 21 CFR 807.92 (b) (1)

The biocompatibility of CAAP Bone Wax is in accordance with the standard set forth in ISO 10993-1, Biological Evaluation of Medical Devices and the radiation sterilization validation is in compliance to ANSVAAMI/ISO 11137-2:2006, Sterilization of Health Care Products - Radiation - Establishing the Sterilization Dose.

The results of bench testing demonstrated that CAAP Bone Wax remains within the physiological pH and temperature range and would be expected to show no adverse biological consequence when applied as a physical hemostatic material.

The animal study provided substantial data that the use of CAAP Bone Wax as a mechanical tamponade to control bleeding in a bony site results in adequate hemostasis as compared with the predicate devices.

Summary of Clinical Tests as required by 21 CFR 807.92 (b) (2)

CAAP Bone Wax does not require clinical test.

Conclusion as required by 21 CFR 807.92 (3)

The summary demonstrates that CAAP Bone Wax is substantially equivalent to the predicate devices and is as safe, as effective and performs as well as the legally market devices identified.

2

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

OCT 25 2011

Skeletal Kinetics LLC % Ms. Christine Kuo Director, Regulatory Affairs and Quality Assurance 10201 Bubb Road Cupertino, California 95014

Re: K111538

Trade/Device Name: CAAP (Calcium Apatite) Bone Wax Regulatory Class: Unclassified Product Code: MTJ Dated: September 22, 2011 Received: September 23, 2011

Dear Ms. Kuo:

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 devire (ran 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 af the Act or any Federal statutes and regulations administered by other Federal agencies. Your must

3

Page 2 - Ms. Christine Kuo

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 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 note the regalations 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,

Emil Keith

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

Enclosure

4

Section 4: Indications for Use

510(K) Number (if Known): K11538

Device Name:

CAAP (Calcium Apatite) Bone Wax

Indications for Use:

CAAP (Calcium Apatite) Bone Wax is indicated to control bleeding from cut or damaged bone by acting as a mechanical barrier or tamponade.

Prescription Use x (Per 21 CFR 801 Subpart D)

AND/OR

Over-the-Counter Use (21CFR 801 Subpart C

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

E. Keith

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

510(k) Number K111538