K Number
K140601
Device Name
FLOW-NAIL
Manufacturer
Date Cleared
2014-07-02

(114 days)

Product Code
Regulation Number
888.3020
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Flow-Nail is intended to treat stable and unstable proximal fractures of the femur including pertrochanteric, intertrochanteric, and high subtrochanteric fractures and combinations of these fractures. The Flow-Nail can also be used to deliver injectable bone void fillers to a surgical site.
Device Description
The Flow-Nail is a dynamic compression trochanteric nail system and includes an intramedullary nail, a sliding fenestrated lag screw, anti-rotation screws, a cap and accompanying surgical instruments. The Flow-Nail components are made of titanium alloy (Ti-6Al-4V) conforming to ASTM F136.
More Information

No
The summary describes a mechanical implant and surgical instruments, with no mention of software, algorithms, or AI/ML terms.

Yes
The device is intended to treat fractures, which is a therapeutic purpose.

No
The Flow-Nail is intended to treat fractures and deliver bone void fillers, not to diagnose conditions.

No

The device description explicitly states that the Flow-Nail is a "dynamic compression trochanteric nail system" and lists physical components made of titanium alloy, such as an intramedullary nail, screws, and a cap. This indicates it is a hardware device, not software-only.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the Flow-Nail is for the treatment of bone fractures. This is a therapeutic intervention, not a diagnostic test performed on samples taken from the body.
  • Device Description: The device is a surgical implant (intramedullary nail system) made of titanium alloy. This is a physical device used within the body, not a reagent or instrument used to analyze biological samples.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in those samples
    • Providing information for diagnosis, monitoring, or screening

The Flow-Nail is a surgical device used for orthopedic repair.

N/A

Intended Use / Indications for Use

The Flow-Nail is intended to treat stable and unstable proximal fractures of the femur including pertrochanteric, intertrochanteric, and high subtrochanteric fractures and combinations of these fractures. The Flow-Nail can also be used to deliver injectable bone void fillers to a surgical site.

Product codes (comma separated list FDA assigned to the subject device)

HSB

Device Description

The Flow-Nail is a dynamic compression trochanteric nail system and includes an intramedullary nail, a sliding fenestrated lag screw, anti-rotation screws, a cap and accompanying surgical instruments. The Flow-Nail components are made of titanium alloy (Ti-6Al-4V) conforming to ASTM F136.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Femur

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Mechanical testing demonstrates the substantial equivalence of the Flow-Nail relative to the identified predicates when subjected to static and dynamic compression bending loads.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K120715, K091566, K032244, K103533, K021008

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K062630, K072355, K090242, K101557

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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.

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K140601 Page 1 of 2

510(k) SummaryJUL 02 2014
Device Trade Name:Flow-Nail
Manufacturer:Flow-FX, LLC
19110 Darvin Drive
Mokena, Illinois 60448
708.390.2290
Prepared by:Musculoskeletal Clinical Regulatory Advisers, LLC
1331 H Street NW, 12th Floor
Washington, DC 20005
202.552.5800
Date Prepared:June 4, 2014
Common Name:Intramedullary Fixation Rod
Classification:21 CFR 888.3020
Class:II
Product Code:HSB

Indications for Use:

The Flow-Nail is intended to treat stable and unstable proximal fractures of the femur including pertrochanteric, intertrochanteric, and high subtrochanteric fractures and combinations of these fractures. The Flow-Nail can also be used to deliver injectable bone void fillers to a surgical site.

Device Description:

The Flow-Nail is a dynamic compression trochanteric nail system and includes an intramedullary nail, a sliding fenestrated lag screw, anti-rotation screws, a cap and accompanying surgical instruments. The Flow-Nail components are made of titanium alloy (Ti-6Al-4V) conforming to ASTM F136.

Predicate Devices:

The Flow-Nail was shown to be substantially equivalent to the Zimmer Natural Nail System (K120715 and K091566), Stryker Gamma 3 Nail System (K032244), and AOS Trochanteric Nail (K103533 and K021008). The Flow-Nail is compatible for use with injectable BVFs.

1

Substantial Equivalence:

The table below summarizes the substantial equivalence of the Flow-Nail to predicate devices with respect to its intended use, design, materials, available sizes, mechanical performance, and ability to deliver BVF to a defect site.

Subject DevicePredicates
Flow-NailZimmer Natural NailStryker Gamma 3 Nail
SystemAOS Trochanteric
Nail System
(K021008)
Intended UseIntended for temporary fracture fixation and stabilization of the bone.
Indications
for UseThe FlowNail is
intended to treat stable
and unstable proximal
fractures of the femur
including
pertrochanteric,
intertrochanteric, and
high subtrochanteric
fractures and
combinations of these
fractures. The Flow-
Nail can also be used to
deliver injectable bone
void fillers to a surgical
site.Indications for the use
of the Cephalomedullary
nails include:
  • Compound and simple
    shaft fractures
  • Proximal, metaphyseal
    and distal shaft
    fractures
  • Segmental fractures
  • Comminuted fractures
  • Fractures involving
    osteopenic and
    osteoporotic bone
  • Pathological fractures
  • Fractures with bone
    loss
  • Pseudoarthrosis, non-
    union, mal-union and
    delayed union
  • Periprosthetic fractures
  • Surgically created
    defects such as
    osteotomies
  • Intertrochanteric and
    subtrochanteric
    fractures | The intended use of the
    subject Trochanteric
    Gamma 3 Nail is identical
    to that of the predicate
    Trochanteric Dyax and
    Gamma Nails. The
    product is intended for use
    in stabilizing various types
    of intertrochanteric
    fractures of the femur. | The AOS Trochanteric
    Nail is intended to treat
    stable and unstable
    proximal fractures of
    the femur including
    pertrochanteric,
    intertrochanteric, and
    high subtrochanteric
    fractures and
    combinations of these
    fractures. |
    | Components | IM Nail; Lag Screw | IM Nail; Lag Screw | IM Nail; Lag Screw | IM Nail; Lag Screw |
    | Materials | Titanium Alloy | Titanium Alloy | Titanium Alloy | Titanium Alloy |
    | Nail Sizes | Within predicate
    range | A range of sizes to
    accommodate various
    patient anatomies | A range of sizes to
    accommodate various
    patient anatomies | A range of sizes to
    accommodate
    various patient
    anatomies |
    | Lag Screw
    Sizes | Within predicate
    range | A range of lengths to
    accommodate various
    patient anatomies | A range of lengths to
    accommodate various
    patient anatomies | A range of lengths to
    accommodate
    various patient
    anatomies |
    | Mechanical
    Performance | Mechanical testing demonstrates the substantial equivalence of the Flow-Nail relative to the
    identified predicates when subjected to static and dynamic compression bending loads. | | | |
    | BVF
    Delivery | Yes | No | No | No |
    | BVF
    Delivery
    System | The qualification testing (i.e., Injectability Testing, Experimental Void Fill Imaging Studies,
    Static Extraction Torque, BVF Property characterization), was performed with ETEX Beta-bsm
    and CarriGen (K062630, K072355, K090242, K101557). | | | |

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Image /page/2/Picture/1 description: The image contains the text 'Public Health Service'. The text is centered and appears to be the title or heading of a document or organization. The font is simple and clear, making the text easily readable.

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

July 2, 2014

Flow-FX. LLC % Ms. Michelle McDonough Senior Associate, Regulatory and Clinical Affairs Musculoskeletal Clinical Regulatory Advisers, LLC 1331 H Street Northwest, 12th Floor Washington, District of Columbia 20005

Re: K140601

Trade/Device Name: Flow-Nail Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary fixation rod Regulatory Class: Class II Product Code: HSB Dated: June 4, 2014 Received: June 5, 2014

Dear Ms. McDonough:

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

3

Page 2 - Ms. Michelle McDonough

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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education 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,

Laurence D. Coyne -A

For Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

4. Indications for Use

K140601 510(k) Number (if known):

Device Name: Flow-Nail

The Flow-Nail is intended to treat stable and unstable proximal fractures of the femur including pertrochanteric. intertrochanteric. and high subtrochanteric fractures and combinations of these fractures. The Flow-Nail can also be used to deliver injectable bone void fillers to a surgical site.

Prescription Use _____________________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart D)

in the color control contrôlean comments of the comments of the comments of the comments of the comments of the comments of the comments of the comments of the comments of

AND/OR

Over-The-Counter Use (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)

Casey L. Hanley, Ph.D.


Division of Orthopedic Devices

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