K Number
K150073

Validate with FDA (Live)

Date Cleared
2015-02-10

(27 days)

Product Code
Regulation Number
888.3020
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The MICRONAIL® Intramedullary Distal Radius System is intended to be used for the fixation of unstable distal radius fractures in which closed reduction is not suitable:
• Joint destruction and/or subluxation visible on x-ray;

  • · Failed fracture fixation with or without bone graft;
  • · Osteotomy and repair of distal radius malunion with or without bone graft;
  • · Displaced or non-displaced fracture which may or may not involve angulation or fragmentation of bone;
  • · Comminuted articular fractures of the articular surface, severely comminuted extra-articular fractures, and fractures in which reduction has been lost following fixation with or with or with or without an external fixator.
Device Description

The MICRONAIL™ Distal Radius System was cleared (K040938) as a system consisting of a radial nail, cortical bone screws, buttress pins, and buttress screws. All components are manufactured from titanium alloy, Ti 6Al-4V-ELI. Changes to the subject devices include changes made to the radial nail, buttress screws, and cortical bone screws and availability of sterile and non-sterile devices.

AI/ML Overview

This document is a 510(k) summary for the MICRONAIL® Distal Radius System, a medical device used for fixing unstable distal radius fractures. As such, it focuses on demonstrating substantial equivalence to a predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the manner one might find for a novel diagnostic AI algorithm.

Therefore, many of the requested categories regarding acceptance criteria and study details for an AI/diagnostic device are not applicable (N/A) in this context. The document describes a mechanical device (intramedullary fixation rod), and the evaluation is based on non-clinical evidence (mechanical testing and FEA).

Here's the information extracted and categorized as best as possible, with explanations for the parts that are N/A:


1. Table of acceptance criteria and the reported device performance

Since this is a mechanical device submission demonstrating substantial equivalence, the "acceptance criteria" are not reported as specific performance metrics like sensitivity/specificity for a diagnostic. Instead, the acceptance criterion implied is mechanical equivalence or superiority to the predicate device.

Acceptance Criteria (Implied)Reported Device Performance
Mechanical performance statistically equivalent or greater than the predicate device (e.g., Static Bending Strength, FEA analysis)"Mechanical testing, including Static Bending Strength, as well as FEA analysis has shown that the performance of the subject screw is statistically equivalent or greater than the predicate screw."

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Sample Size: Not specified quantitatively. For mechanical testing, this typically refers to the number of devices tested.
  • Data Provenance: Not explicitly stated, but mechanical testing is typically performed in a laboratory setting by the manufacturer (Wright Medical Technology, Inc., Memphis, TN, USA). It's a prospective technical evaluation, not a retrospective analysis of patient data.

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)

  • N/A. Ground truth establishment by experts is relevant for diagnostic performance assessments. For mechanical device testing, the "ground truth" is determined by established engineering principles and measurements against validated test methods.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

  • N/A. Adjudication methods are relevant for expert consensus in diagnostic or clinical interpretations. Mechanical testing uses objective measurements.

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

  • N/A. This is a mechanical device, not an AI-assisted diagnostic tool.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

  • N/A. This is a mechanical device, not an algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

  • N/A. As explained in #3, ground truth in this context refers to objective mechanical properties and performance measurements as determined by standardized testing methods and engineering analysis (FEA).

8. The sample size for the training set

  • N/A. There is no "training set" in the context of mechanical device testing for 510(k) submission, as it's not a machine learning model.

9. How the ground truth for the training set was established

  • N/A. As there is no "training set," this question is not applicable.

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Image /page/0/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 words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

Wright Medical Technology, Incorporated Ms. Jeanine Redden Regulatory Affairs Director 1023 Cherry Road Memphis, Tennessee 38117

February 10, 2015

Re: K150073

Trade/Device Name: MICRONAIL® Distal Radius System Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary fixation rod Regulatory Class: Class II Product Code: HSB Dated: January 8, 2015 Received: January 14, 2015

Dear Ms. Redden:

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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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Page 2 - Ms. Jeanine Redden

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/Resourcesfor You/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/ResourcesforYou/Industry/default.htm.

Sincerely vours.

Mark N. Melkerson -S

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

Enclosure

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Indications for Use

510(k) Number (if known)

K150073

Device Name MICRONAIL® Distal Radius System

Indications for Use (Describe)

The MICRONAL® Intramedulary Distal Radius System is intended to be used for the fixation of unstable distal radius fractures in which closed reduction is not suitable:

• Joint destruction and/or subluxation visible on x-ray;

  • · Failed fracture fixation with or without bone graft;
  • · Osteotomy and repair of distal radius malunion with or without bone graft;
  • · Displaced or non-displaced fracture which may or may not involve angulation or fragmentation of bone;
  • · Comminuted articular fractures of the articular surface, severely comminuted extra-articular fractures, and

fractures in which reduction has been lost following fixation with or with or with or without an external fixator.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

Expiration Date: January 31, 2017 See PRA Statement on last page.

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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

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K150073 Page 1 of 2

Headquarters Wright Medical Technology, Inc.

1023 Cherry Road Memphis, TN 38117

901 867 9971 wmt.com

Image /page/4/Picture/4 description: The image shows the Wright logo. The logo consists of two overlapping trapezoids, one red and one orange, to the left of the word "WRIGHT" in red, sans-serif font. Below the word "WRIGHT" is the phrase "FOCUSED EXCELLENCE" in a smaller, gray, sans-serif font. The logo is clean and modern, with a focus on the company name and a tagline that emphasizes quality.

510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

In accordance with the Food and Drug Administration Rule to implement provisions of the Safe Medical Devices Act of 1990 and in conformance with 21 CFR 807.92, this information serves as a Summary of Safety and Effectiveness for the use of the MICRONAIL™ Distal Radius System.

1. Submitted By:Wright Medical Technology, Inc. 1023 Cherry Rd. Memphis, TN 38117
Date:February 9, 2015
Contact Person:Jeanine Redden Director, Regulatory Affairs Phone: 901.867.4522 Fax: 901.687.4190 jeanine.redden@wmt.com
2. Proprietary Name:MICRONAIL TM Distal Radius System
Common Name:Intramedullary fixation rod
Classification Name and Reference:21 CFR 888.3020- Class II
Device Product Code, Device Panel:HSB - Orthopedic

3. Predicate Device:

K040938 Radial Nail System

Device Description 4.

The MICRONAIL™ Distal Radius System was cleared (K040938) as a system consisting of a radial nail, cortical bone screws, buttress pins, and buttress screws. All components are manufactured from titanium alloy, Ti 6Al-4V-ELI. Changes to the subject devices include changes made to the radial nail, buttress screws, and cortical bone screws and availability of sterile and non-sterile devices.

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5. Intended Use

The MICRONAIL® Intramedullary Distal Radius System is intended to be used for the fixation of unstable distal radius fractures in which closed reduction is not suitable:

  • · Joint destruction and/or subluxation visible on x-ray;
  • · Failed fracture fixation with or without bone graft;
  • · Osteotomy and repair of distal radius malunion with or without bone graft;
  • · Displaced or non-displaced fracture which may or may not involve angulation or fragmentation of bone;
  • · Comminuted articular fractures, shearing fractures of the articular surface, severely comminuted extra-articular fractures, and fractures in which reduction has been lost following fixation with percutaneous pins with or without an external fixator.

Technological Characteristics Comparison 6.

The MICRONAIL™ Distal Radius System and the legally marketed predicate Radial Nail System have identical indications, utilize the same instrumentation, and are identical in material. Sterilization methods have been updated to reflect the addition of products that are provided sterile.

7. Substantial Equivalence- Non-Clinical Evidence

Mechanical testing, including Static Bending Strength, as well as FEA analysis has shown that the performance of the subject screw is statistically equivalent or greater than the predicate screw.

8. Substantial Equivalence- Clinical Evidence

N/A

9. Substantial Equivalence- Conclusions

The design characteristics of the subject devices do not raise any new types of questions of safety or effectiveness. From the evidence submitted in this 510(k), the subject devices can be expected to perform at least as well as the predicate systems and are substantially equivalent.

§ 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.