K Number
K171715
Device Name
HammerTube System
Manufacturer
Date Cleared
2018-03-05

(269 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The HammerTube™ System is indicated for fixation of reconstruction and fusion of toes during correction procedures for hammertoe deformity, claw toe deformity, shortening osteotomies of the phalanges and mallet toe deformity as well as revision hammertoe procedures. The cannulated and solid HammerTube™ implants may be used without any other additional device. The cannulated implants may be used with K-wires for delivery of implants or for the temporary stabilization of nearby joints, such as the metatarsophalangeal joint. The implantable K-wires are indicated for use in the stabilization and fixation of small bones for use in bone reconstruction, osteotomy, arthrodesis, fracture repair and fixation, appropriate for the size of the joint. Additionally, the implantable K-wires are indicated as guide pins for insertion of instruments and implants in the HammerTube™ System
Device Description
The HammerTube™ System includes HammerTube™ and K-wire implants. the HammerTube™ is a commercially pure titanium plasma sprayed PEEK cylinder in varying diameters and lengths. The K-wires are stainless steel and double trocar pointed.
More Information

No
The 510(k) summary describes a mechanical implant system for toe fixation and does not mention any software, algorithms, or AI/ML capabilities.

Yes.
The device is used for fixation of reconstruction and fusion of toes during correction procedures for hammertoe deformity, claw toe deformity, shortening osteotomies of the phalanges and mallet toe deformity, and revision hammertoe procedures, indicating a therapeutic purpose.

No

Explanation: The device is an implantable system (HammerTube™) used for fixation and fusion during toe correction procedures. Its purpose is therapeutic/surgical, not to diagnose a condition.

No

The device description explicitly states that the system includes "HammerTube™ and K-wire implants," which are physical hardware components (titanium and stainless steel). There is no mention of software being the primary or sole component of the device.

Based on the provided information, 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.
  • HammerTube™ System Function: The HammerTube™ System is described as a system for fixation and stabilization of bones during surgical procedures on toes. It involves implants (HammerTube™ and K-wires) that are physically inserted into the body.
  • Lack of Diagnostic Testing: There is no mention of this device being used to analyze biological samples or provide diagnostic information about a patient's condition. Its purpose is purely structural support and fixation.

Therefore, the HammerTube™ System falls under the category of a surgical implant or orthopedic device, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The HammerTube™ System is indicated for fixation of reconstruction and fusion of toes during correction procedures for hammertoe deformity, claw toe deformity, shortening osteotomies of the phalanges and mallet toe deformity as well as revision hammertoe procedures.

The cannulated and solid HammerTube™ implants may be used without any other additional device. The cannulated implants may be used with K-wires for delivery of implants or for the temporary stabilization of nearby joints, such as the metatarsophalangeal joint.

The implantable K-wires are indicated for use in the stabilization and fixation of small bones for use in bone reconstruction, osteotomy, arthrodesis, fracture repair and fixation, appropriate for the joint. Additionally, the implantable K-wires are indicated as guide pins for insertion of instruments and implants in the HammerTube™ System.

Product codes

HTY

Device Description

The HammerTube™ System includes HammerTube™ and K-wire implants. the HammerTube™ is a commercially pure titanium plasma sprayed PEEK cylinder in varying diameters and lengths. The K-wires are stainless steel and double trocar pointed.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

toes, phalanges, small bones, metatarsophalangeal joint

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)

Static and dynamic cantilever bending, and static pullout testing was performed.

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

Not Found

Predicate Device(s)

K131459

Reference Device(s)

K150394

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/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

March 5, 2018

Paragon 28 % Karen Warden Representative/Consultant BackRoads Consulting, Inc PO Box 566 Chesterland, Ohio 44026-0566

Re: K171715

Trade/Device Name: HammerTube System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: HTY Dated: January 22, 2018 Received: January 23, 2018

Dear Karen 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 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);

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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

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 on last page.

510(k) Number (if known)

K171715

Device Name HammerTube™ System

Indications for Use (Describe)

The HammerTube™ System is indicated for fixation of reconstruction and fusion of toes during correction procedures for hammertoe deformity, claw toe deformity, shortening osteotomies of the phalanges and mallet toe deformity as well as revision hammertoe procedures.

The cannulated and solid HammerTube™ implants may be used without any other additional device. The cannulated implants may be used with K-wires for delivery of implants or for the temporary stabilization of nearby joints, such as the metatarsophalangeal joint.

The implantable K-wires are indicated for use in the stabilization and fixation of small bones for use in bone reconstruction, osteotomy, arthrodesis, fracture repair and fixation, appropriate for the joint. Additionally, the implantable K-wires are indicated as guide pins for insertion of instruments and implants in the HammerTube™ System.

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

区 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

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Date:8 June 2017
Sponsor:Paragon 28, Inc.
4B Inverness Ct. E., STE 280
Englewood, Colorado 80112
Phone: (888) 728-1888
Facsimile: (888) 728-1220
Sponsor Contact:Frank S. Bono, Chief Technology Officer
510(k) Contact:Karen E. Warden, PhD
BackRoads Consulting
PO Box 566
Chesterland, OH 44026
Office: 440.729.8457
Trade Names:HammerTube™ System
Common Name:Fixation pin
Regulatory Class:Class II
Classification Name /
Regulation / Product
Code:Pin, Fixation, Smooth / 888.3040 / HTY
Device Description:The HammerTube™ System includes HammerTube™ and K-wire
implants. the HammerTube™ is a commercially pure titanium plasma
sprayed PEEK cylinder in varying diameters and lengths. The K-wires are
stainless steel and double trocar pointed.
Indications for Use:The HammerTube™ System is indicated for fixation of reconstruction and
fusion of toes during correction procedures for hammertoe deformity,
claw toe deformity, shortening osteotomies of the phalanges and mallet
toe deformity as well as revision hammertoe procedures.
The cannulated and solid HammerTube™ implants may be used without
any other additional device. The cannulated implants may be used with
K-wires for delivery of implants or for the temporary stabilization of
nearby joints, such as the metatarsophalangeal joint.
The implantable K-wires are indicated for use in the stabilization and
fixation of small bones for use in bone reconstruction, osteotomy,
arthrodesis, fracture repair and fixation, appropriate for the size of the
joint. Additionally, the implantable K-wires are indicated as guide pins for
insertion of instruments and implants in the HammerTube™ System
Materials:HammerTube™ System implants are manufactured from
polyetheretherketone (VESTAKEEP, Evonik per ASTM F2026) having a
commercially pure titanium plasma spray coating as described by ASTM
F1580 or from stainless steel per ASTM F138.
Primary Predicate:aap Wire Bone (aap Implante AG – K131459)
Reference Device:Tyber Medical Wedge System (Tyber Medical LLC – K150394)
Performance Data:Static and dynamic cantilever bending, and static pullout testing was
performed.
Technological
Characteristics:The HammerTube™ System K-wire implants possesses the same
technological characteristics as the predicate device. These include:
• performance,
• basic design,
• material and
• sizes (dimensions are comparable to those offered by the
predicate systems).
Differences between the HammerTube™ implants (material, design,
sizes) were shown not to raise new questions of safety or effectiveness.
Therefore the fundamental scientific technology of the HammerTube™
System is similar to the predicate.
Conclusion:The HammerTube™ System possesses indications for use and
technological characteristics similar to the predicate device. Therefore the
HammerTube™ System is substantially equivalent to the predicate.

510(k) Summary

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