K Number
K170214
Device Name
Additive Orthopaedics Locking Lattice Plate
Date Cleared
2017-04-13

(79 days)

Product Code
Regulation Number
888.3030
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Additive Orthopaedics Locking Lattice Plate is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle.
Device Description
The Additive Orthopaedics Lattice Locking Plates consist of a plate and locking and non-locking screws with surgical site preparation and insertion instruments. It is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle. The plates are additively manufactured from medical grade titanium alloy (Ti-6AL-4V Eli). The screws are manufactured from medical grade titanium alloy. (Ti-6AL-4V Eli). The implants are provided sterile and intended for single use only. The locking lattice plate and screws come in multiple sizes.
More Information

No
The description focuses on the material, manufacturing process (additive manufacturing), and mechanical properties of the plate and screws. There is no mention of any software, algorithms, or data processing that would indicate the use of AI or ML. The performance studies are mechanical and biological, not related to algorithmic performance.

No.
The device is an orthopedic implant for stabilization and fusion of fractures, not a therapeutic device in the sense of actively treating or curing a disease through direct therapeutic action.

No

The device is an orthopedic implant (plate and screws) used for alignment, stabilization, and fusion of bones, which is a therapeutic rather than a diagnostic function.

No

The device description clearly states it consists of a plate, screws, and surgical instruments, which are physical hardware components. It is also additively manufactured from titanium alloy.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health.
  • Device Description and Intended Use: The description clearly states that the Additive Orthopaedics Locking Lattice Plate is an implantable device used for the physical alignment, stabilization, and fusion of bones during surgery. It is a physical device used in the body, not a test performed on samples from the body.

The information provided describes a surgical implant, not a diagnostic test.

N/A

Intended Use / Indications for Use

The Additive Orthopaedics Locking Lattice Plate is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle.

Product codes

HRS, HWC

Device Description

The Additive Orthopaedics Lattice Locking Plates consist of a plate and locking and non-locking screws with surgical site preparation and insertion instruments. It is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle. The plates are additively manufactured from medical grade titanium alloy (Ti-6AL-4V Eli). The screws are manufactured from medical grade titanium alloy. (Ti-6AL-4V Eli). The implants are provided sterile and intended for single use only. The locking lattice plate and screws come in multiple sizes.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

foot and 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 including 4 point bending (static and dynamic) per ASTM F382 as well as static torsion, static driving torque and removal torque, and static axial pullout per F543 for the proposed device. Bacterial endotoxin levels on the device were also evaluated by LAL pyrogen testing. Pyrogen levels for the device system were below the 20 EU/device limit. The results of these verification activities demonstrate that the Additive Orthopaedics Locking Lattice Plate is substantially equivalent to the predicate device identified.

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

Not Found

Predicate Device(s)

K131061, K140397

Reference Device(s)

K153207, K160264

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

Public Health Service

April 13, 2017

Image /page/0/Picture/2 description: The image shows the logo for the U.S. Department of Health and 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 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

Additive Orthopaedics, LLC Greg Kowalczyk President 83 Amelia Circle Little Silver. New Jersey 07739

Re: K170214

Trade/Device Name: Additive Orthopaedics Locking Lattice Plate 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: January 23, 2017 Received: March 23, 2017

Dear Greg Kowalczyk:

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

1

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.

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

2

Indications for Use

510(k) Number (if known) K170214

Device Name

Additive Orthopaedics Locking Lattice Plate

Indications for Use (Describe)

The Additive Orthopaedics Locking Lattice Plate is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle.

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)

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3

510K Summary (Per 21 CFR 807.92)

| General Company Information: | Additive Orthopaedics, LLC.
Gregory Kowalczyk
President
83 Amelia Circle
Little Silver, NJ 07739
Phone: (732) 882-6633
greg@additiveorthopaedics.com |
|------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date Prepared: | March 29, 2017 |
| General Device Information: | |
| Proprietary Name: | Additive Orthopaedics Locking Lattice Plate |
| System Classification: | Common Name: Plate, Fixation, Bone |
| | Regulation Name: Single/multiple component metalli
bone fixation appliances and accessories;
Product Code: HRS- Class II
Classification Name and Reference: 21 CFR 888.3030 |
| | Regulation Name: Smooth or Threaded metallic bone
fixation fastener and accessories;
Product Code: HWC- Class II
Classification Name and Reference: 21 CFR 888.3040 |

Predicate Devices:

CompanyProduct Name510K Number
Primary: Nextremity Solutions, Inc.Restore Fixation SystemK131061
Additional: Paragon 28, Inc.Paralock Plating SystemK140397
Reference: Additive Orthopaedics, LLCHammertoe Correction SystemK153207
Reference: Additive Orthopaedics, LLCBone Wedge SystemK160264

4

Description

The Additive Orthopaedics Lattice Locking Plates consist of a plate and locking and non-locking screws with surgical site preparation and insertion instruments. It is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle. The plates are additively manufactured from medical grade titanium alloy (Ti-6AL-4V Eli). The screws are manufactured from medical grade titanium alloy. (Ti-6AL-4V Eli). The implants are provided sterile and intended for single use only. The locking lattice plate and screws come in multiple sizes.

Intended Use (Indications)

The Additive Orthopaedics Locking Lattice Plate is indicated for alignment, stabilization and fusion of fractures, osteotomies and arthrodesis of small bones such as the foot and ankle.

(a) (6) Technological Characteristics Comparison

The Additive Orthopaedics Locking Lattice Plate and the legally marketed predicated devices have similar indications, dimensions, geometry, materials and manufacturing process. The Additive Orthopaedics Locking Lattice Plate is technologically substantially equivalent to the predicate devices.

(b) (1) Substantial Equivalence- Non-Clinical Evidence

Mechanical testing including 4 point bending (static and dynamic) per ASTM F382 as well as static torsion, static driving torque and removal torque, and static axial pullout per F543 for the proposed device. Bacterial endotoxin levels on the device were also evaluated by LAL pyrogen testing. Pyrogen levels for the device system were below the 20 EU/device limit. The results of these verification activities demonstrate that the Additive Orthopaedics Locking Lattice Plate is substantially equivalent to the predicate device identified.

(b) (3) Substantial Equivalence - Conclusions

The Additive Orthopaedics Locking Lattice Plate possesses the same technologic characteristics of the predicate devices. These characteristics include the intended use, basic design, material, manufacturing process, size and fundamental technology. The design characteristics of the subject system raises no new safety and effectiveness questions. From the evidence submitted in this 510(k), the subject devices can be expected to perform at least as well as the predicate device.