K Number
K180050
Device Name
CurvaFix Intramedullary Rodscrew System
Manufacturer
Date Cleared
2019-03-01

(417 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The CurvaFix® Intramedullary Rodscrew is intended for fixation of fractures of the pelvis.
Device Description
The CurvaFix Intramedullary Rodscrew System is a collection of flexible intramedullary devices for pelvic fracture fixation. The devices have a threaded, self-tapping distal end and a driving torque interface at the proximal end. An integral shape lock feature changes the Rodscrew from a flexible to rigid state after implantation. The Rodscrew can be returned to a flexible state should explantation be required. The implants are available in a single diameter and an assortment of lengths to accommodate a variety of anatomic requirements.
More Information

Not Found

No
The description focuses on the mechanical properties and design of a physical implant, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is intended for fixation of fractures, which is a therapeutic intervention for a medical condition.

No
Explanation: The device is a surgical implant intended for fracture fixation, not for diagnosing medical conditions.

No

The device description clearly describes a physical implantable device (intramedullary rodscrew) made of materials with mechanical properties, not a software-only product.

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

Here's why:

  • Intended Use: The intended use is "fixation of fractures of the pelvis." This is a surgical procedure performed directly on the patient's body to stabilize a broken bone.
  • Device Description: The device is described as a "flexible intramedullary device for pelvic fracture fixation" with features like threading, a driving torque interface, and a shape lock. These are all characteristics of a surgical implant used for internal fixation.
  • Lack of IVD Characteristics: An IVD is a medical device used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. This device does not perform any such tests.

Therefore, based on the provided information, the CurvaFix® Intramedullary Rodscrew is a surgical implant, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The CurvaFix® Intramedullary Rodscrew is intended for fixation of fractures of the pelvis.

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

HWC, HSB

Device Description

The CurvaFix Intramedullary Rodscrew System is a collection of flexible intramedullary devices for pelvic fracture fixation. The devices have a threaded, self-tapping distal end and a driving torque interface at the proximal end. An integral shape lock feature changes the Rodscrew from a flexible to rigid state after implantation. The Rodscrew can be returned to a flexible state should explantation be required. The implants are available in a single diameter and an assortment of lengths to accommodate a variety of anatomic requirements.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

pelvis

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Mechanical testing of worst case CurvaFix Intramedullary Rodscrew was performed according to ASTM F543. Additional mechanical properties were evaluated following ASTM F1264. The mechanical test results demonstrate that CurvaFix Intramedullary Rodscrew performance is substantially equivalent to the predicate.

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.

K043185

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.

0

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 the FDA logo, which 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 1, 2019

CurvaFix, Inc. % Karen Warden President BackRoads Consulting Po Box 566 Chesterland, Ohio 44026-0566

Re: K180050

Trade/Device Name: CurvaFix Intramedullary Rodscrew System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: HWC. HSB Dated: February 22, 2019 Received: February 25, 2019

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,

Vesa
Vuniqi -S
Digitally signed
by Vesa Vuniqi -S
Date: 2019.03.01
17:03:12 -05'00'

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

Enclosure

2

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 6/30/2020 See PRA Statement below.

510(k) Number (if known) K180050

Device Name

CurvaFix® Intramedullary Rodscrew System

Indications for Use (Describe)

The CurvaFix® Intramedullary Rodscrew is intended for fixation of fractures of the pelvis.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

3

510(k) Summary

Date:4 January 2018
Sponsor:CurvaFix, Inc.
1000 124th Ave NE, Suite 100
Bellevue WA 98005
Curvafix.com
Sponsor Contact:Steve Dimmer, CEO
510(k) Contact:Karen E. Warden, PhD
BackRoads Consulting Inc.
PO Box 566
Chesterland, OH 44026
Office: 440.729.8457
Proposed Trade Name:CurvaFix® Intramedullary Rodscrew System
Common Name:Bone screw
Device Classification:Class II
Regulation Name,
Regulation Number,
Product Code:Smooth or threaded metallic bone fixation fastener, 888.3040, HWC
Intramedullary fixation rod, 888.3020, HSB
Device Description:The CurvaFix Intramedullary Rodscrew System is a collection of flexible
intramedullary devices for pelvic fracture fixation. The devices have a
threaded, self-tapping distal end and a driving torque interface at the
proximal end. An integral shape lock feature changes the Rodscrew from a
flexible to rigid state after implantation. The Rodscrew can be returned to a
flexible state should explantation be required. The implants are available in a
single diameter and an assortment of lengths to accommodate a variety of
anatomic requirements.
Indications for Use:The CurvaFix® Intramedullary Rodscrew is intended for fixation of fractures
of the pelvis.
Materials:The CurvaFix Intramedullary Rodscrew System implants are manufactured
from stainless steel (316 LVM per ASTM F138) .
Primary Predicate:Primary: 3.5 mm Pelvic Cortex Screws (Synthes Inc. - K043185)
Performance Data:Mechanical testing of worst case CurvaFix Intramedullary Rodscrew was
performed according to ASTM F543. Additional mechanical properties were
evaluated following ASTM F1264. The mechanical test results demonstrate
that CurvaFix Intramedullary Rodscrew performance is substantially
equivalent to the predicate.
Technological
Characteristics:The CurvaFix Intramedullary Rodscrew System possesses the same
technological characteristics as one or more of the predicate devices. These
include: intended use (as described above), basic design (threaded fixation),
anatomic location (pelvis) and material (stainless steel).
Differences between the subject and predicate devices did not raise new
questions of safety and effectiveness. Therefore the fundamental scientific
technology of the CurvaFix® Intramedullary Rodscrew System is similar to
previously cleared devices.
Conclusion:The CurvaFix Intramedullary Rodscrew System possesses the same
intended use and technological characteristics as the predicate devices.
Therefore CurvaFix Intramedullary Rodscrew System is substantially
equivalent for its intended use.