K Number
K161894
Device Name
SurgTech Trauma System
Manufacturer
Date Cleared
2017-02-21

(225 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The SurgTech Trauma System plates and screws are intended to be used for internal bone fixation for bone fractures, fusions, osteotomies and non-unions appropriate for the size and design of the device. The large plate set components are indicated for the use including the femur and tibia. The small plate set is indicated for use in various bones including the clavicle, scapula, humerus, radius, ulna, pelvis, tibia and fibula. The mini plate set is indicated for use in various small bones including the metacsals, phalanges, calcaneus and those of the ankle. In addition, the SurgTech Trauma System cancellous, cannulated lag, headless compression and non-locking cortical screws are indicated for use in bone reconstruction, arthrodesis, joint fusion, fracture repair and fracture fixation, appropriate for the size of the device.
Device Description
The SurgTech Trauma System is a plate and screw fixation system. Plates are offered in "mini," "small" and "large" set sizes in a variety of shapes based upon the anatomical fixation required. Screws are also offered in "mini" "small" and "large" sets and, in addition, in locking cortical, non-locking cortical, cancellous and headless versions. Screws can also be used for fixation without the plates.
More Information

Not Found

No
The 510(k) summary describes a traditional plate and screw fixation system for bone fractures and fusions. There is no mention of AI, ML, image processing, or any other technology that would suggest the incorporation of AI/ML. The performance studies are mechanical tests, not studies related to algorithmic performance.

Yes
The device is intended for internal bone fixation for fractures, fusions, osteotomies, and non-unions, which are all therapeutic interventions aimed at healing or stabilizing anatomical structures.

No

Explanation: The device is a plate and screw fixation system for internal bone fixation, described as an implantable medical device, not a diagnostic tool.

No

The device description clearly states it is a "plate and screw fixation system," which are physical hardware components used for internal bone fixation. The summary also details mechanical testing of these physical plates and screws.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "internal bone fixation for bone fractures, fusions, osteotomies and non-unions." This is a surgical procedure performed directly on the patient's body.
  • Device Description: The device is described as a "plate and screw fixation system," which are physical implants used in surgery.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or compatibility testing.

IVD devices are used outside the body to analyze samples. This device is used inside the body for structural support and fixation.

N/A

Intended Use / Indications for Use

The SurgTech Trauma System plates and screws are intended to be used for internal bone fixation for bone fractures, fusions, osteotomies and non-unions appropriate for the size and design of the device.
The large plate set components are indicated for the use in various long bones including the femur and tibia. The small plate set is indicated for use in various bones including the clavicle, scapula, humerus, radius, ulna, pelvis, tibia and fibula. The mini plate set is indicated for use in various small bones including the metacarpals, metatarsals, phalanges, calcaneus and those of the ankle.
In addition, the SurgTech Trauma System cancellous, cannulated lag, headless compression and non-locking cortical screws are indicated for use in bone reconstruction, osteotomy, arthrodesis, joint fusion, fracture repair and fracture fixation, appropriate for the size of the device.

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

HWC, HRS

Device Description

The SurgTech Trauma System is a plate and screw fixation system. Plates are offered in "mini," "small" and "large" set sizes in a variety of shapes based upon the anatomical fixation required. Screws are also offered in "mini" "small" and "large" sets and, in addition, in locking cortical, non-locking cortical, cancellous and headless versions. Screws can also be used for fixation without the plates.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

femur, tibia, clavicle, scapula, humerus, radius, ulna, pelvis, fibula, metacarpals, metatarsals, phalanges, calcaneus, ankle

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 of the worst case SurgTech Trauma System plates included static and dynamic bending performed according to ASTM F382. Mechanical testing of the worst case SurgTech Trauma System screws included torsion, insertion/removal and pullout performed according to ASTM F543. All plates and screws met their acceptance criteria.

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.

GPC Medical K092493, Zimmer Inc. K100111, I.T.S. GmbH K060156, I.T.S. GmbH K033756, I.T.S. GmbH K052368, Synthes, K120070, I.T.S. GmbH K080184, I.T.S. GmbH K060156, I.T.S. GmbH K050852, Synthes, K031677, Synthes K041860, I.T.S. GmbH K063166, I.T.S. GmbH K063672, DePuy Orthopaedics K082300, Acumed LLC K141383, Synthes K991407, I.T.S. GmbH K051642, Synthes K100776, Medartis K091479, Synthes K915818, Synthes K000682, K000684, Synthes K090047, OsteoMed LP K063298, Treu Instrumente GmbH K083912, Synthes K112583, Synthes K050636, Synthes K080943, Vilex K014154, Synthes K962011, Small Bone Innovations K092754

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.

Not Found

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

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.

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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 features a stylized caduceus symbol, which is a staff with two snakes coiled around it. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus symbol.

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

February 21, 2017

SurgTech Inc Karen E. Warden, Ph.D. President Backroads Consulting Inc. PO Box 566 Chesterland, Ohio 44026-0566

Re: K161894

Trade/Device Name: SurgTech Trauma System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: HWC, HRS Dated: January 23, 2017 Received: January 25, 2017

Dear Dr. Warden:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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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 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" (21 CFR 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,

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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Pg.1/2

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.

510(k) Number (if known) K161894

Device Name SurgTech Trauma System

Indications for Use (Describe)

The SurgTech Trauma System plates and screws are intended to be used for internal bone fixation for bone fractures, fusions, osteotomies and non-unions appropriate for the size and design of the device.

The large plate set components are indicated for the use including the femur and tibia. The small plate set is indicated for use in various bones including the clavicle, scapula, humerus, radius, ulna, pelvis, tibia and fibula. The mini plate set is indicated for use in various small bones including the metacsals, phalanges, calcaneus and those of the ankle.

In addition, the SurgTech Trauma System cancellous, cannulated lag, headless compression and non-locking cortical screws are indicated for use in bone reconstruction, arthrodesis, joint fusion, fracture repair and fracture fixation, appropriate for the size of the device.

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

× 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)

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This section applies only to requirements of the Paperwork Reduction Act of 1995.

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:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

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510(k) Summary

Date:14 February 2017
Sponsor:SurgTech Inc.
24600 Center Ridge Road, Suite 195
Westlake, OH 44145
Phone (216) 421-2613
Sponsor Contact:Xuegong Yu, General Manager
510(k) Contact:Karen E. Warden, PhD
BackRoads Consulting Inc.
PO Box 566
Chesterland, OH 44026
Office: 440.729.8457
Trade Name:SurgTech Trauma System
Common Name:Bone plates & screws, Bone screws
Device ClassificationClass II
Classification Name:Smooth or threaded metallic bone fixation fastener & Single/multiple
component metallic bone fixation accessories
Regulation:888.3040, 888.3030
Device Product Code:HWC, HRS
Device Description:The SurgTech Trauma System is a plate and screw fixation system. Plates
are offered in "mini," "small" and "large" set sizes in a variety of shapes
based upon the anatomical fixation required. Screws are also offered in
"mini" "small" and "large" sets and, in addition, in locking cortical, non-
locking cortical, cancellous and headless versions. Screws can also be
used for fixation without the plates.
Indications for Use:The SurgTech Trauma System plates and screws are intended to be used
for internal bone fixation for bone fractures, fusions, osteotomies and non-
unions appropriate for the size and design of the device.
The large plate set components are indicated for the use in various long
bones including the femur and tibia. The small plate set is indicated for use
in various bones including the clavicle, scapula, humerus, radius,
ulna, pelvis, tibia and fibula. The mini plate set is indicated for use in various
small bones including the metacarpals, metatarsals, phalanges, calcaneus
and those of the ankle.
In addition, the SurgTech Trauma System cancellous, cannulated lag,
headless compression and non-locking cortical screws are indicated for use
in bone reconstruction, osteotomy, arthrodesis, joint fusion, fracture repair
and fracture fixation, appropriate for the size of the device.
Materials:The SurqTech Trauma System implants are manufactured from titanium
alloys (Ti6Al4V per ASTM F136 and Ti6Al7Nb per ASTM F1295) and
stainless steel (ASTM F138).
Primary Predicate
(plate & screw system):GPC Bone Plates and Bone Screws (GPC Medical K092493)
Additional Predicates
(plate & screw system):The NCB Periprosthetic Femur Polyaxial Locking Plate System (Zimmer
Inc. K100111), I.T.S. Straight Plate (I.T.S. GmbH K060156), I.TS. Volar
Radius Plate (I.T.S. GmbH K033756), I.T.S. Olecranon Plate (I.T.S. GmbH
K052368), Synthes Variable Angle LCP Elbow System (Synthes, K120070),
I.T.S. Distal Humeral Plates (I.T.S. GmbH K080184), I.T.S. Straight Plate
(I.T.S. GmbH K060156), I.T.S. Claviculatplate (I.T.S. GmbH K050852),
Synthes (USA) Clavicle Hook Plate (Synthes, K031677), Synthes (USA)
LCP® Proximal Humerus Plates (Synthes K041860), the I.T.S. Pelvic
Reconstruction System (I.T.S. GmbH K063166), I.T.S. Fibula Plate (I.T.S.
GmbH K063672), DePuy ALPS (DePuy Orthopaedics K082300), Acumed
Hand Fracture System (Acumed LLC K141383), Synthes Locking
Calcaneal Plates (Synthes K991407), I.T.S. Calcaneus Repair System
(I.T.S. GmbH K051642), Synthes 2.4 mm / 2.7 mm Variable Angle (VA), -
LCP Forefoot /Midfoot System (Synthes K100776) and Medartis APTUS®
Foot System (Medartis K091479), Synthes Titanium Small Reconstruction
Plate (Synthes K915818), Synthes Large Fragment Dynamic Compression
Locking (DCL) System (Synthes K000682), Synthes Small Fragment
Dynamic Compression Locking (DCL) (System K000684), 1.5mm Mini
Fragment LCP System (Synthes K090047).
Primary Predicate
(standalone screws):OsteoMed Headless Cannulated Screw System (OsteoMed LP K063298)
Additional Predicates
(standalone screws):Treu Bone fixation Screws and Pins (Treu Instrumente GmbH K083912),
Synthes Cortical Screws (Synthes K112583), Synthes 3.0 mm Headless
Compression Screws (Synthes K050636), Synthes 4.5 mm and 6.5 mm
Headless Compression Screws (Synthes K080943), Vilex Bone Screw
(Vilex K014154), Synthes 7.0/7.3 mm Cannulated Screws (Synthes
K962011), SBi Foot and Ankle Cannulated Screws (Small Bone Innovations
K092754)
Performance Data:Mechanical testing of the worst case SurgTech Trauma System plates
included static and dynamic bending performed according to ASTM F382.
Mechanical testing of the worst case SurgTech Trauma System screws
included torsion, insertion/removal and pullout performed according to
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |

| Technological
Characteristics: | The SurgTech Trauma System implants possess technological
characteristics similar to one or more of the cited predicate devices. These
include: Mechanical performance (as described above), Basic design (bone plate & screw system), Use of implant grade materials (titanium, titanium alloys & stainless steel), and Dimensional sizes (comparable to those offered by the predicates). Minor dimensional differences between the subject and predicate devices,
such as longer or shorter device lengths, did not raise new questions of
safety and effectiveness. Therefore the fundamental scientific technology of
the SurgTech Trauma System is the same as previously cleared devices. |
| Conclusion: | The SurgTech Trauma System possesses the same intended use and
similar indications for use compared to the cited predicates. The SurgTech
Trauma System technological characteristics are similar to those of the
cited predicate devices. Therefore SurgTech Trauma System is
substantially equivalent for its intended use. |

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