K Number
K182991
Device Name
EPIC Extremity Fusion Plate System
Date Cleared
2019-02-13

(107 days)

Product Code
Regulation Number
888.3030
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The EPIC Extremity Fusion Plate System is indication of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only.
Device Description
The EPIC Extremity Fusion Plate System consists of multiple plate families of various anatomical sizes and shapes, 4.5mm/5.5mm locking and non-locking screws that mate into the plates, 5.5mm fully and partial threaded cancellous, 5.5mm cannulated partial threaded cancellous bone screws as well as various instruments to assist in implanting the system. The EPIC Extremity Fusion Plate System is also designed to be used with various instruments to assist in implanting the system from the previously cleared EPIC Extremity Plate System (K153340).
More Information

No
The summary describes a system of plates and screws for bone fixation and does not mention any software, algorithms, or AI/ML capabilities.

No
The device is described as a system of plates and screws intended for the fixation of fractured or reconstructed bones and joints, which are implants for structural support rather than active therapy.

No
The device, The EPIC Extremity Fusion Plate System, is an implantable system of plates and screws used for joint fusion and reconstruction of small bones, not for diagnosing medical conditions.

No

The device description explicitly states it consists of multiple plate families, screws, and instruments, which are all physical hardware components.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health. This testing is done outside of the body (in vitro).
  • Device Description: The EPIC Extremity Fusion Plate System is a system of plates, screws, and instruments designed to be surgically implanted into the body to treat bone fractures and perform fusions and reconstructions. This is an implantable medical device, not a device used for testing specimens.
  • Intended Use: The intended use clearly describes surgical procedures on bones, not laboratory testing of biological samples.

Therefore, based on the provided information, the EPIC Extremity Fusion Plate System is a surgical implant and not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The EPIC Extremity Fusion Plate System is indication of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only.

Product codes

HRS

Device Description

The EPIC Extremity Fusion Plate System consists of multiple plate families of various anatomical sizes and shapes, 4.5mm/5.5mm locking and non-locking screws that mate into the plates, 5.5mm fully and partial threaded cancellous, 5.5mm cannulated partial threaded cancellous bone screws as well as various instruments to assist in implanting the system.

The EPIC Extremity Fusion Plate System is also designed to be used with various instruments to assist in implanting the system from the previously cleared EPIC Extremity Plate System (K153340).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

feet and ankles, including distal tibia

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)

Non-Clinical Performance Data Summary: Cross-sectional analysis demonstrated substantial equivalence. Through this analysis it was determined that the addition of the EPIC Extremity Fusion Plates are substantially equivalent in bending strength to the predicate and does not introduce a new worse case into the system.

Clinical Performance Data Summary: No clinical testing was required.

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

Not Found

Predicate Device(s)

EPIC Extremity Fracture Plate System (K172441), EPIC Extremity Cannulated Screw System (K153333)

Reference Device(s)

Ortholoc 3DI Ankle Fusion Plating System (K121425), Ortholoc 3DI Ankle Fusion Plating System Line Extension (K163650)

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.

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EPIC Extremity, LLC Randy Schlemmer Director of Product Development 120 Marguerite Drive. Suite 301 Cranberry Twp, Pennsylvania 16066

February 13, 2019

Re: K182991

Trade/Device Name: EPIC Extremity Fusion Plate System Regulation Number: 21 CFR 888.3030 Regulation Name: Single/Multiple Component Metallic Bone Fixation Appliances And Accessories Regulatory Class: Class II Product Code: HRS Dated: January 7, 2019 Received: January 9, 2019

Dear Randy Schlemmer:

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/cdrl/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 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

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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,

Image /page/1/Picture/11 description: The image shows a digital signature. The signature is for Jesse Muir -S. The date of the signature is 2019.02.13 and the time is 10:16:53-05'00'.

For

10:16:53 -05'00' 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

510(k) Number (if known) K182991

Device Name

EPIC Extremity Fusion Plate System

Indications for Use (Describe)

The EPIC Extremity Fusion Plate System is indication of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only.

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)

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Image /page/3/Picture/1 description: The image shows the word "EPIC" in large, bold, black letters. Below the word "EPIC" is the word "EXTREMITY" in smaller, white letters against a blue and gray gradient background. The word "EPIC" is the main focus of the image, and the word "EXTREMITY" appears to be a secondary element.

EPIC Extremity Fusion Plate System

Submitter Information

| Applicant: | EPIC Extremity, LLC
120 Marguerite Dr., Ste 301
Cranberry Twp., PA 16066 |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Randy Schlemmer
EPIC Extremity, LLC
120 Marguerite Dr., Ste 301
Cranberry Twp., PA 16066
(574)248-0060 |
| Date Prepared: | October 15th, 2018 |
| Name of Device: | EPIC Extremity Fusion Plate System |
| Common Name: | Bone Fixation Plate |
| Classification Name | Single/Multiple component metallic bone fixation appliances and
accessories (per 21 CFR 888.3030) - Class II |
| Product Code/Panel: | HRS/Orthopedics |
| Predicate Devices: | EPIC Extremity Fracture Plate System (K172441)
EPIC Extremity Cannulated Screw System (K153333)
Ortholoc 3DI Ankle Fusion Plating System (K121425) Reference
Ortholoc 3DI Ankle Fusion Plating System
Line Extension (K163650) Reference |

Indications for Use:

The EPIC Extremity Fusion Plate System is indicated for use in stabilization of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only.

Device Description

The EPIC Extremity Fusion Plate System consists of multiple plate families of various anatomical sizes and shapes, 4.5mm/5.5mm locking and non-locking screws that mate into the plates, 5.5mm fully and partial threaded cancellous, 5.5mm cannulated partial threaded cancellous bone screws as well as various instruments to assist in implanting the system.

The EPIC Extremity Fusion Plate System is also designed to be used with various instruments to assist in implanting the system from the previously cleared EPIC Extremity Plate System (K153340).

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Image /page/4/Picture/1 description: The image shows the logo for EPIC Extremity. The word "EPIC" is written in large, bold, black letters. Below the word "EPIC" is a blue and gray graphic with the word "EXTREMITY" written in smaller, white letters. The logo is simple and modern.

EPIC Extremity Fusion Plate System

Technological Characteristics

The EPIC Extremity Fusion Plate System has the same intended use as the predicate devices. The EPIC Extremity Fusion Plate System has identical indications for use as the predicate devices. The EPIC Extremity Fusion Plate System is manufactured from the same materials as the predicate devices. The EPIC Extremity Fusion Plate System has the following differences from the predicate device:

  • a. Introduction larger 4.5mm & 5.5mm screw diameters
  • b. Introduction of cannulated 5.5mm screw diameter
  • c. Introduction of anatomic specific plate families

Any differences between the EPIC Extremity Fusion Plate System and the predicates are considered minor and do not raise questions concerning safety and effectiveness.

Non-Clinical Performance Data Summary

Cross-sectional analysis demonstrated substantial equivalence. Through this analysis it was determined that the addition of the EPIC Extremity Fusion Plates are substantially equivalent in bending strength to the predicate and does not introduce a new worse case into the system.

Based on the analysis results and the comparisons provided, the EPIC Extremity Fusion Plate System is considered substantially equivalent to the EPIC Extremity Fracture Plate System (K172441), Ortholoc 3DI Ankle Fusion Plating System (K121425), Ortholoc 3DI Ankle Fusion Plating System Line Extension (K163650) and EPIC Extremity Cannulated Screw System (K153333) in material, construction, size, anatomic location and performance characteristics.

Clinical Performance Data Summary

No clinical testing was required.

Non-Clinical and Clinical Performance Data Conclusions

Based on the analysis results and the comparisons provided, the EPIC Extremity Fusion Plate System is considered substantially equivalent to the EPIC Extremity Fracture Plate System (K172441), Ortholoc 3DI Ankle Fusion Plating System (K121425), Ortholoc 3DI Ankle Fusion Plating System Line Extension (K163650) and EPIC Extremity Cannulated Screw System (K153333) in material, construction, size, anatomic location and performance characteristics.