K Number
K163014
Device Name
AOS Small Bone Nailing System
Date Cleared
2017-01-24

(88 days)

Product Code
Regulation Number
888.3020
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The AOS Small Bone Nail System is intended for fixation of fractures and osteotomies of the fibula, radius and ulna, including fractures where the medullary canal is narrow or flexibility of the implant is paramount.
Device Description
The AOS Small Bone Nail is a titanium alloy (Ti-6Al-4V) intramedullary nail available in various lengths (110mm to 260mm) and diameters (2.5mm to 5.0mm). The nail is compatible with use of 3.5mm and 2.7mm cortical locking screws that allow for additional fracture fixation and locking capabilities.
More Information

Not Found

No
The summary describes a mechanical implant (intramedullary nail) and its physical properties and testing. There is no mention of software, algorithms, image processing, or any terms related to AI/ML.

No
The device is described as an intramedullary nail system intended for the fixation of fractures and osteotomies, which is a structural support function rather than a therapeutic or treatment function.

No

The device description clearly states "The AOS Small Bone Nail System is intended for fixation of fractures and osteotomies...", indicating it is a therapeutic device used for treatment, not diagnosis. There is no mention of it being used to identify or determine medical conditions.

No

The device description clearly states it is a titanium alloy intramedullary nail, which is a physical implant, not software.

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

Here's why:

  • Intended Use: The intended use clearly states that the device is for the "fixation of fractures and osteotomies of the fibula, radius and ulna." This describes a surgical implant used to treat bone injuries.
  • Device Description: The description details a "titanium alloy intramedullary nail" and "cortical locking screws." These are physical devices implanted into the body.
  • 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 screening.

IVD devices are used in vitro (outside the body) to analyze biological samples. This device is used in vivo (inside the body) as a surgical implant.

N/A

Intended Use / Indications for Use

The AOS Small Bone Nail System is intended for fixation of fractures and osteotomies of the fibula, radius and ulna, including fractures where the medullary canal is narrow or flexibility of the implant is paramount.

Product codes

HSB

Device Description

The AOS Small Bone Nail is a titanium alloy (Ti-6Al-4V) intramedullary nail available in various lengths (110mm to 260mm) and diameters (2.5mm to 5.0mm). The nail is compatible with use of 3.5mm and 2.7mm cortical locking screws that allow for additional fracture fixation and locking capabilities.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

fibula, radius and ulna

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Prescription Use

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

PRECLINICAL TESTING: The AOS Small Bone Nail System was subjected to comparative mechanical testing per a four point bend test based on ASTM F1264-14. The results demonstrate that the AOS Small Bone Nail are substantially equivalent to the predicates.
CLINICAL DATA: There is no clinical data referenced in this 510(k)

Key Metrics

Not Found

Predicate Device(s)

Synthes Elastic Intramedullary Nail (EIN) K971783, Acumed Small Bone Locking Rod System II K031438, Acumed Small Bone IM Nail System K143276, Smith & Nephew Intramedullary Nail System K983942

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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.

0

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 text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, with three human profiles forming the staff and a wing-like shape above them.

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

Advanced Orthopaedic Solutions, Inc. (AOS) Alex Bhaskarla Regulatory Affairs Manager 3203 Kashiwa St. Torrance, California 90505

January 24, 2017

Re: K163014

Trade/Device Name: AOS Small Bone Nailing System Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary Fixation Rod Regulatory Class: Class II Product Code: HSB Dated: October 7, 2016 Received: October 28, 2016

Dear Alex Bhaskarla:

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 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.

1

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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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 below.
510(k) Number (if known)K163014
Device NameAOS Small Bone Nailing System
Indications for Use (Describe)The AOS Small Bone Nail System is intended for fixation of fractures and osteotomies of the fibula, radius and ulna, including fractures where the medullary canal is narrow or flexibility of the implant is paramount.
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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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FORM FDA 3881 (8/14)Page 1 of 1
PSC Publishing Services (301) 443-6740EF

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Image /page/3/Picture/1 description: The image shows the logo for Advanced Orthopaedic Solutions. The logo consists of the letters "AOS" in a stylized font, with the "A" in a dark teal color, the "O" in a light gray color, and the "S" in a dark teal color. Below the letters, the words "ADVANCED ORTHOPAEDIC SOLUTIONS" are written in a smaller, sans-serif font.

6. TRADITIONAL 510(K) SUMMARY

DATE PREPARED:October 7, 2016
SUBMITTED BY:Advanced Orthopaedic Solutions, Inc.
3203 Kashiwa Street
Torrance, CA 90505
Phone: (310) 533-9966
Establishment Registration #: 2032480
Owner Operator Number: 9046896
CONTACT PERSON:Alex Bhaskarla
Advanced Orthopaedic Solutions, Inc.
3203 Kashiwa Street
Torrance, CA 90505
Phone: (310) 533-9966
DEVICE NAME:AOS Small Bone Nail System
COMMON NAME:Intramedullary Fixation Rod/Pin
CLASSIFICATION:Class II, 21 CFR 888.3020, Intramedullary Fixation
Rod/Pin
DEVICE CODE:HSB
SUBSTANTIALLY
EQUIVALENT DEVICES:Synthes Elastic Intramedullary Nail (EIN) K971783
Acumed Small Bone Locking Rod System II K031438
Acumed Small Bone IM Nail System K143276
Smith & Nephew Intramedullary Nail System K983942
DEVICE DESCRIPTION:The AOS Small Bone Nail is a titanium alloy (Ti-6Al-
4V) intramedullary nail available in various lengths
(110mm to 260mm) and diameters (2.5mm to
5.0mm). The nail is compatible with use of 3.5mm
and 2.7mm cortical locking screws that allow for
additional fracture fixation and locking capabilities.
INDICATIONS FOR USE:The AOS Small Bone Nail System is intended for
fixation of fractures and osteotomies of the fibula,
radius and ulna, including fractures where the
medullary canal is narrow or flexibility of the implant
is paramount.

4

SUBSTANTIAL EQUIVALENCE:Information presented supports substantial equivalence of the AOS Small Bone Nail System to the predicate devices. The proposed system has the same indications for use, is similar in shape and design, and has the same fundamental technology.
BASIS FOR SUBSTANTIAL EQUIVALENCE:The AOS Small Bone Nailing System has the

AOS Small Bone Nailing System has the following similarities to the predicates:

  • same device classification ●
  • same lengths
  • same material .
  • same anatomical sites
  • same intended use ●
  • same biocompatibility
  • same shaft diameter
  • same locking screw diameters ●

The AOS Small Bone Nailing System has longer cortical screws. Longer screw lengths provide more engagement with the bone. Mechanically, the subject nail proved stronger than the predicate device used for testing.

  • PRECLINICAL TESTING: The AOS Small Bone Nail System was subjected to comparative mechanical testing per a four point bend test based on ASTM F1264-14. The results demonstrate that the AOS Small Bone Nail are substantially equivalent to the predicates.
  • STANDARDS: Recognized industry standards are cited in the Standards Report
  • CLINICAL DATA: There is no clinical data referenced in this 510(k)

PERFORMANCE TESTING

No performance standards applicable to this device have been adopted under Section 514 of the Food, Drug and Cosmetic Act. Performance testing of the AOS Small Bone Nail System was conducted in accordance with various international standards and internal AOS methods.