(77 days)
The Stryker AxSOS™ Small Fragment Plating System is intended for internal fixation, stabilization and support of fractures as well as bone fixation after osteotomies in the following:
In Adults:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, fibula, distal humerus, clavicle
- 4mm Locking Insert
- 4mm Locking Screws
- 3.5mm Cortical Screws
- 3mm One Third Tubular Plate - fibula, metatarsals, metacarpals
- 4mm Reconstruction Plate - humerus, pelvis
In Pediatrics:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, distal humerus, clavicle
- 4mm Locking Insert
- 4mm Locking Screws
- 3.5mm Cortical Screws
The Stryker AxSOS™ Basic Fragment Plating System is intended for internal fixation, stabilization and support of long bone fractures as well as bone fixation osteotomies in the following:
In Adults:
- 5mm Waisted Compression Plate - Broad -femur, tibia, humerus, pelvis
- 5mm Waisted Compression Plate - Narrow - femur, tibia, humerus, pelvis
- 5mm Locking Insert
- 5mm Locking Screws
- 4.5mm Cortical Screws
- 5mm Reconstruction Plate - femur, tibia, humerus, pelvis
In Pediatrics:
- 5mm Waisted Compression Plate -- Broad -femur, tibia, humerus
- 5mm Waisted Compression Plate - Narrow - femur, tibia, humerus
- 5mm Locking Insert
- 5mm Locking Screws
- 4.5mm Cortical Screws
This Traditional 510(k) submission is being supplied to the U.S. FDA to provide authorization to add the pediatric indication to a specific subset of plates, screws and inserts of the previously cleared Stryker Plating System (K060514). The components from the previously cleared system, some of which carry the pediatric indication, will make-up the system to be marketed as the AxSOS™ Locking Plate System. The indications for use will clarify which components will include the pediatric indication.
The provided text describes a 510(k) submission for the AxSOS™ Locking Plate System. This is a traditional 510(k) to add a pediatric indication to a previously cleared system, making it a medical device submission, not a study of a device employing AI. Therefore, the information requested in your prompt (e.g., acceptance criteria, test set sample size, ground truth, MRMC study, AI improvement effect size, training set, etc.) is not applicable to this document. The document focuses on demonstrating substantial equivalence to predicate devices through non-clinical testing.
Here's an breakdown of the relevant information provided:
1. A table of acceptance criteria and the reported device performance:
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Substantial equivalence to predicate devices for pediatric use, particularly in fatigue resistance for long-term pediatric use. | Non-clinical compression fatigue testing demonstrated that the AxSOS™ Locking Plate Systems are substantially equivalent to devices currently cleared for market with pediatric indications. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Not applicable. This submission relies on non-clinical (laboratory) testing, not clinical data or a test set in the context of an AI/algorithm study.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):
- Not applicable. This is a mechanical device submission, not an AI/algorithm study.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable.
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. This is a medical device submission, not an AI/algorithm study. There is no AI component.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not applicable. There is no algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Not applicable. The "ground truth" equivalent for this type of device submission is the established performance benchmarks and regulatory requirements for similar predicate devices, particularly regarding mechanical integrity and fatigue resistance.
8. The sample size for the training set:
- Not applicable. This is a medical device submission, not an AI/algorithm study.
9. How the ground truth for the training set was established:
- Not applicable. This is a medical device submission, not an AI/algorithm study.
Summary of the study/submission:
The submission focuses on demonstrating substantial equivalence of the AxSOS™ Locking Plate System to previously cleared predicate devices (K082807- Synthes 3.5 and 4.5mm Locking Compression Plate (LCP) System and K060514- Stryker Locked Plating System) to add a pediatric indication.
- Non-Clinical Testing:
- Study performed: An additional compression fatigue testing was conducted for the subject plates, screws, and inserts.
- Purpose: To evaluate the fatigue resistance in long-term pediatric use.
- Conclusion: The testing demonstrated that the AxSOS™ Locking Plate Systems are substantially equivalent to devices currently cleared for market with pediatric indications.
- Clinical Testing: Not required for this submission.
Therefore, the "study" described is a non-clinical laboratory test specifically for compression fatigue, aimed at showing the new pediatric indications for the AxSOS™ Locking Plate System are as safe and effective as existing legally marketed predicate devices for pediatric use.
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| K | 112926 |
|---|---|
| DEC | 1 9 2011 |
510(k) Summary of Safety and Effectiveness
| Proprietary Name: | AxSOST™ Locking Plate System |
|---|---|
| Common Name: | Bone plates and screws |
| Classification Name and Reference: | Single/multiple component metallic bone fixation appliances and accessories- 21 CFR §888.3030;Smooth or threaded metallic bone fixation fastener- 21 CFR §888.3040 |
| Regulatory Class: | Class II |
| Product Codes: | 87 HRS: Plate, Fixation, Bone;87 HWC: Screw, Fixation, Bone |
| For Information contact: | Kelly Kucharczyk, Regulatory Affairs AssociateHowmedica Osteonics Corp.325 Corporate DriveMahwah, NJ 07430Phone: (201) 831-6455 Fax: (201) 831-3461 |
| Date Prepared: | September 23, 2011 |
Description:
This Traditional 510(k) submission is being supplied to the U.S. FDA to provide authorization to add the pediatric indication to a specific subset of plates, screws and inserts of the previously cleared Stryker Plating System (K060514). The components from the previously cleared system, some of which carry the pediatric indication, will make-up the system to be marketed as the AxSOS™ Locking Plate System. The indications for use will clarify which components will include the pediatric indication.
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K11 2926
Page 2/4
Intended Use:
The Stryker AxSOS™ Small Fragment Plating System is intended for internal fixation, stabilization and support of fractures as well as bone fixation after osteotomies in the following:
In Adults:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, fibula, distal • humerus, clavicle
- 4mm Locking Insert .
- 4mm Locking Screws .
- . 3.5mm Cortical Screws
- 3mm One Third Tubular Plate fibula, metatarsals, metacarpals .
- 4mm Reconstruction Plate humerus, pelvis .
In Pediatrics:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, distal humerus, . clavicle
- 4mm Locking Insert .
- . 4mm Locking Screws
- . 3.5mm Cortical Screws
The Stryker AxSOS™ Basic Fragment Plating System is intended for internal fixation, stabilization and support of long bone fractures as well as bone fixation osteotomies in the following:
In Adults:
- 5mm Waisted Compression Plate Broad -femur, tibia, humerus, pelvis •
- 5mm Waisted Compression Plate Narrow femur, tibia, humerus, pelvis .
- ◆ 5mm Locking Insert
- 5mm Locking Screws
- . 4.5mm Cortical Screws
- 5mm Reconstruction Plate femur, tibia, humerus, pelvis .
In Pediatrics:
- 5mm Waisted Compression Plate Broad -femur, tibia, humerus .
- 5mm Waisted Compression Plate Narrow femur, tibia, humerus .
- . 5mm Locking Insert
- . 5mm Locking Screws
- 4.5mm Cortical Screws .
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11 2926
Page 3/4
Indications:
The Stryker AxSOS™ Small Fragment Plating System is intended for internal fixation, stabilization and support of fractures as well as bone fixation after osteotomies in the following:
In Adults:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, fibula, distal . humerus, clavicle
- 4mm Locking Insert .
- 4mm Locking Screws .
- 3.5mm Cortical Screws .
- 3mm One Third Tubular Plate fibula, metatarsals, metacarpals .
- 4mm Reconstruction Plate humerus, pelvis .
In Pediatrics:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, distal humerus, . clavicle
- . 4mm Locking Insert
- . 4mm Locking Screws
- 3.5mm Cortical Screws .
The Stryker AxSOS™ Basic Fragment Plating System is intended for internal fixation, stabilization and support of long bone fractures as well as bone fixation osteotomies in the following:
In Adults:
- 5mm Waisted Compression Plate Broad-femur, tibia, humerus, pelvis .
- . 5mm Waisted Compression Plate - Narrow - femur, tibia, humerus, pelvis
- 5mm Locking Insert .
- . 5mm Locking Screws
- 4.5mm Cortical Screws .
- 5mm Reconstruction Plate femur, tibia, humerus, pelvis .
In Pediatrics:
- 5mm Waisted Compression Plate Broad -femur, tibia, humerus .
- 5mm Waisted Compression Plate Narrow femur, tibia, humerus .
- . 5mm Locking Insert
- 5mm Locking Screws .
- 4.5mm Cortical Screws .
Summary of Technologies:
Device comparisons showed that the proposed device is substantially equivalent in intended use, design, materials and performance characteristics to the following predicate devices:
K082807- Synthes 3.5 and 4.5mm Locking Compression Plate (LCP) System K060514- Stryker Locked Plating System
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ll 2926
Page 4/4
Non-Clinical Testing:
Non-clinical laboratory testing was performed for the subject plates, screws and inserts to determine substantial equivalence. As there are no additional design, process, material or performance characteristic changes, no general tests for verification and validation are necessary. However, an additional compression fatigue testing was conducted for the subject plates, screws and insert to evaluate the fatigue resistance in long-term pediatric use. The testing demonstrated that the AxSOS™ Locking Plate Systems are substantially equivalent to devices currently cleared for market with pediatric indications.
Clinical Testing:
Clinical testing was not required for this submission.
Conclusion:
The AxSOS™ Locking Plate System is substantially equivalent to the predicate devices identified in this premarket notification.
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Image /page/4/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular emblem with the department's name encircling an abstract symbol. The symbol resembles a stylized caduceus, featuring three parallel lines that curve and converge.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Stryker Corporation % Ms. Kelly Kucharczyk 325 Corporate Drive Mahwah, New Jersey 07430
DEC 1 9 2011
Re: K112926
Trade/Device Name: AxSOS™ Locking Plate 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: September 29, 2011 Received: October 3, 2011
Dear Ms. Kucharczyk:
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
{5}------------------------------------------------
Page 2- Ms. Kelly Kucharczyk
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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Mark N. Mullan
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{6}------------------------------------------------
Indications for Use
510(k) Number (if known):
Device Name: AxSOSTM Locking Plate System
The Stryker AxSOS™ Small Fragment Plating System is intended for internal fixation, stabilization and support of fractures as well as bone fixation after osteotomies in the following:
In Adults:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, fibula, distal humerus, clavicle
- . 4mm Locking Insert
- . 4mm Locking Screws
- 3.5mm Cortical Screws
- . 3mm One Third Tubular Plate - fibula, metatarsals, metacarpals
- . 4mm Reconstruction Plate - humerus, pelvis
In Pediatrics:
- 4mm Waisted Compression Plate radius, ulna, distal tibia, distal humerus, clavicle .
- . 4mm Locking Insert
- 4mm Locking Screws .
- 3.5mm Cortical Screws
The Stryker AxSOS™ Basic Fragment Plating System is intended for internal fixation, stabilization and support of long bone fractures as well as bone fixation osteotomies in the following:
In Adults:
- . 5mm Waisted Compression Plate - Broad -femur, tibia, humerus, pelvis
- . 5mm Waisted Compression Plate - Narrow - femur, tibia, humerus, pelvis
- . 5mm Locking Insert
- . 5mm Locking Screws
- . 4.5mm Cortical Screws
- . 5mm Reconstruction Plate - femur, tibia, humerus, pelvis
In Pediatrics:
- 5mm Waisted Compression Plate -- Broad -femur, tibia, humerus .
- . 5mm Waisted Compression Plate - Narrow - femur, tibia, humerus
- . 5mm Locking Insert
- . 5mm Locking Screws
- 4.5mm Cortical Screws
Prescription Use Over-The-Counter Use X AND/OR (Part 21 CFR 801 Subpart D) (21 CFR 807 Subpart C) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
-
- 13.12 1
Mark Mellekson
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Oft) Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K112926
§ 888.3030 Single/multiple component metallic bone fixation appliances and accessories.
(a)
Identification. Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.