(25 days)
The Corin Optimized Positioning System Plan (OPS™ Plan) is indicated for pre-operative planning for primary total hip arthroplasty. OPS™ Plan is intended to be used as a pre-operative tool to assist the Surgeon in the selection (for example, lateralised or standard stem), sizing and positioning of components of primary total hip arthroplasty.
The Corin OPS™ Plan is intended to be used with the Corin TriFit TS (K121563, K153772), MetaFix (K082525, K121439, K131952, K153381), TaperFit (K142761, K153725), MiniHip (K083312, K11046, K131986) and TriFit CF (K173880) Femoral Hip Stems.
The Corin Optimized Positioning System™ Plan (OPS™ Plan) is a pre-operative templating tool to assist the Surgeon in the planning of primary total hip arthroplasty using any Corin femoral stem. The Corin OPS™ Plan assists in selection (for example, lateralised or standard stem), sizing and placement of implant components (stem, head, cup) using anatomical landmarks of the femur and pelvis obtained from pre-operative CT scan and AP X-ray. The OPS™ Plan consists of the OPS™ Plan Report and the OPS™ Plan Appendix. The OPS™ Plan report is a static report which displays the selection (for example, lateralised or standard stem), sizing and placement of implant components. OPS™ Plan Appendix presents the steps taken by the Engineer on behalf of the Surgeon during the preoperative planning process, which include the identification of anatomical landmarks as well as sizing and positioning of the implants.
The Corin OPS™ Plan process begins with booking the OPS case to final release of the OPS Plan Report. OPS™ case booking details and required CT and X-ray imaging in DICOM format are electronically transferred to the manufacturer via the online end-user interface, the OPS™ Portal. Image processing is completed by an Corin Simulation Engineer with results of the OPS™ analysis provided in the OPS™ Plan Report. The Surgeon does not actively interact with the image processing, implant positioning and/or report generation. Final acceptance of the OPS™ Plan by the Surgeon is confirmed following any modifications or clarifications of the reported results.
The OPS™ Plan was originally cleared in K171847. The purpose of this submission is to include TriFit CF (K173880) to the Femoral Hip systems intended to be used with the OPS™ Plan.
The design and all the other compatible components for use with the OPS™ Plan subject of this submission are identical to that of the predicate device K171847.
The provided text describes the Corin Optimized Positioning System (OPS) Plan, a pre-operative planning tool for total hip arthroplasty. However, it explicitly states that clinical testing was not necessary for this Traditional 510(k) submission. Instead, the submission relies on non-clinical testing to demonstrate safety and effectiveness.
Therefore, the following information, which typically relies on clinical or comparative studies, is either not applicable or not detailed in the provided document:
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A table of acceptance criteria and the reported device performance: The document does not provide a table with specific acceptance criteria (e.g., minimum accuracy percentages, error margins) and reported performance against those criteria as would be found in a clinical study report. It generally states that "accuracy and performance of the system is adequate to perform as intended."
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Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective): No details on sample size, data provenance, or whether data was retrospective or prospective from a test set for clinical performance are provided, as no clinical testing was performed for this submission.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience): Not applicable, as no external expert-validated test set for clinical performance is described.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable, as no clinical test set requiring adjudication is described.
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If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. The device is a planning tool, and a clinical MRMC study evaluating human reader improvement with AI assistance is not mentioned. The "Surgeon does not actively interact with the image processing, implant positioning and/or report generation" (page 4), suggesting a standalone planning process rather than an AI-assisted reading scenario for the surgeon.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: The document mentions "Image processing is completed by an Corin Simulation Engineer with results of the OPS™ analysis provided in the OPS™ Plan Report. The Surgeon does not actively interact with the image processing, implant positioning and/or report generation. Final acceptance of the OPS™ Plan by the Surgeon is confirmed..." This describes a process where the engineer uses the system to generate a plan, which the surgeon then approves. While not a fully automated 'algorithm only' in the sense of no human intervention, it is a standalone planning tool that an engineer operates, rather than direct human-in-the-loop diagnostic assistance. The non-clinical testing assessed the "processing of patient imaging to produce accurate, repeatable and reproducible implant selection, sizing and placement of components," which supports a standalone performance claim for the system's output.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc): Since clinical testing was not performed and no direct ground truth for a clinical comparison is mentioned, the ground truth for the non-clinical testing would likely be based on engineering benchmarks, simulated scenarios, or established anatomical measurements against which the system's output (implant selection, sizing, placement) could be validated for accuracy, repeatability, and reproducibility. These details are not elaborated in the provided text.
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The sample size for the training set: The document does not mention a training set size, as it focuses on the regulatory submission and non-clinical testing, not on the underlying machine learning model development (if any, as the system predates this specific submission). The device was originally cleared in K171847, and this submission is for an expanded list of compatible femoral hip stems.
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How the ground truth for the training set was established: Not applicable, as details on a training set are not provided.
Summary from the provided text regarding acceptance criteria and study:
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Acceptance Criteria (Implied / Stated Goals):
- Accuracy: The system must produce accurate implant selection, sizing, and placement of components.
- Repeatability: The system must produce repeatable results.
- Reproducibility: The system must produce reproducible results.
- Usability: The OPS™ Plan provided to the Surgeon must be usable.
- Adequate Performance: The system's accuracy and performance must be adequate to perform its intended use as a pre-operative planning tool.
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Reported Device Performance (from Non-Clinical Testing):
- "Non-clinical testing was performed to assess the safety and effectiveness of the device, to demonstrate the processing of patient imaging to produce accurate, repeatable and reproducible implant selection, sizing and placement of components, and the usability of the OPS™ Plan that is provided to the Surgeon. Testing verified that the accuracy and performance of the system is adequate to perform as intended." (Page 5)
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Study That Proves the Device Meets Acceptance Criteria:
- Title/Type: Non-Clinical Testing.
- Objective: To assess safety and effectiveness by demonstrating accurate, repeatable, and reproducible implant selection, sizing, and placement, and usability of the OPS™ Plan.
- Sample Size (Test Set): Not specified.
- Data Provenance: Not specified.
- Number of Experts for Ground Truth: Not specified.
- Qualifications of Experts: Not specified.
- Adjudication Method: Not specified.
- MRMC Comparative Effectiveness Study: No.
- Standalone Performance: Yes (demonstrated through non-clinical testing assessing the system's processing of patient imaging to produce results).
- Type of Ground Truth: Not explicitly stated but inferred to be engineering benchmarks, simulated scenarios, or established anatomical measurements for validating the accuracy, repeatability, and reproducibility of the system's output.
- Training Set Sample Size: Not specified.
- Ground Truth for Training Set: Not specified.
It is important to note that this submission (K183038) is for an update to an already cleared device (K171847) to include a new femoral hip stem. The non-clinical testing mentioned reaffirms the system's core functionalities in light of this update, rather than being a comprehensive clinical validation of a new or significantly altered device.
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November 26, 2018
Corin USA Martina Cecconi Regulatory and Clinical Affairs Team Leader Corin (Australia) 17 Bridge Street PYMBLE, NEW SOUTH WALES 2073 AUSTRALIA
Re: K183038
Trade/Device Name: Corin Optimized Positioning System (OPS) Plan Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ, LZO, MEH Dated: October 30, 2018 Received: November 1, 2018
Dear Martina Cecconi:
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 mav, 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 avare 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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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requirements, including, but not limited to: registration and listing (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.htm); good manufacturing practice requirements as set forth in the quality systems (OS) 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.
Michael D. O'Hara
Robert A. Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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2. INDICATION FOR USE
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known)
Device Name
Corin Optimized Positioning System (OPS™) Plan
Indications for Use (Describe)
The Corin Optimized Positioning System Plan (OPS™ Plan) is indicated for pre-operative planning for primary total hip arthroplasty. OPS™ Plan is intended to be used as a pre-operative tool to assist the Surgeon in the selection (for example, lateralised or standard stem), sizing and positioning of components of primary total hip arthroplasty.
The Corin OPS™ Plan is intended to be used with the Corin TriFit TS (K121563, K153772), MetaFix (K082525, K121439, K131952, K153381), TaperFit (K142761, K153725), MiniHip (K083312, K11046, K131986) and TriFit CF (K173880) Femoral Hip Stems.
| 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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| 1. | Applicant/SponsorDistributor: | Corin USA LimitedDistributor12750 Citrus Park LaneSuite 120Tampa, Florida 33625Establishment Registration No.: 1056629 |
|---|---|---|
| 2. | Manufacturer: | Optimized Ortho Pty Ltd17 Bridge StreetPymble NSW2073 AustraliaEstablishment Registration No: 3012916784 |
| 3. | Contact Person: | Martina CecconiRegulatory and Clinical Affairs Team LeaderCorin (Australia) Pty LimitedMartina.Cecconi@coringroup.comLucinda GerberGlobal Regulatory Affairs ManagerCorin USA Limited1 (772) 321-2478Lucinda.Gerber@coringroup.com |
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- Date: Tuesday, 30 October 2018
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- Trade Name: Corin Optimized Positioning System (OPS™) Plan
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- Common Name: Image Processing Software
7. Classification Product Code(s): LLZ
Additional Product Code(s): LZO, MEH
8. Classification Name:
21 CFR 892.2050 – Picture archiving and communications system
Additional Classification Names:
21 CFR 888.3353 – Hip joint metal/ceramic/polymer semi-constrained cemented or
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nonporous uncemented prosthesis.
21 CFR 888.3353 – Hip joint metal/ceramic/polymer semi-constrained cemented or nonporous uncemented prosthesis.
9. Substantially Equivalent (predicate) device(s):
- . Corin Optimized Positioning System (OPS™) Plan (K171847)
10. Device Description:
The Corin Optimized Positioning System™ Plan (OPS™ Plan) is a pre-operative templating tool to assist the Surgeon in the planning of primary total hip arthroplasty using any Corin femoral stem. The Corin OPS™ Plan assists in selection (for example, lateralised or standard stem), sizing and placement of implant components (stem, head, cup) using anatomical landmarks of the femur and pelvis obtained from pre-operative CT scan and AP X-ray. The OPS™ Plan consists of the OPS™ Plan Report and the OPS™ Plan Appendix. The OPS™ Plan report is a static report which displays the selection (for example, lateralised or standard stem), sizing and placement of implant components. OPS™ Plan Appendix presents the steps taken by the Engineer on behalf of the Surgeon during the preoperative planning process, which include the identification of anatomical landmarks as well as sizing and positioning of the implants.
The Corin OPS™ Plan process begins with booking the OPS case to final release of the OPS Plan Report. OPS™ case booking details and required CT and X-ray imaging in DICOM format are electronically transferred to the manufacturer via the online end-user interface, the OPS™ Portal. Image processing is completed by an Corin Simulation Engineer with results of the OPS™ analysis provided in the OPS™ Plan Report. The Surgeon does not actively interact with the image processing, implant positioning and/or report generation. Final acceptance of the OPS™ Plan by the Surgeon is confirmed following any modifications or clarifications of the reported results.
The OPS™ Plan was originally cleared in K171847. The purpose of this submission is to include TriFit CF (K173880) to the Femoral Hip systems intended to be used with the OPS™ Plan.
The design and all the other compatible components for use with the OPS™ Plan subject of this submission are identical to that of the predicate device K171847.
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11. Indications for Use / Intended Purpose:
The Corin Optimized Positioning System Plan (OPS™ Plan) is indicated for preoperative planning for primary total hip arthroplasty. OPS™ Plan is intended to be used as a pre-operative tool to assist the Surgeon in the selection (for example, lateralised or standard stem), sizing and positioning of components of primary total hip arthroplasty.
The Corin OPS™ Plan is intended to be used with the Corin TriFit TS (K121563, K153772), MetaFix (K082525, K121439, K131952, K153381), TaperFit (K142761, K153725), MiniHip (K083312, K11046, K131986) and TriFit CF (K173880) Femoral Hip Stems.
12. Summary of Technologies/Substantial Equivalence:
The Corin OPS™ Plan subject of this submission is identical to the predicate Corin OPS™ Plan (K171847) in design, technological characteristics, principles of operation and indication of use, with both the subject device and predicate device utilizing CT scans to generate 2D patient specific bone models and X-Ray imaging to identify bony landmarks. The end user and site of operation (hip) is identical for both the subject device and predicate device. Based on these similarities, Corin believes that the Corin OPS™ Plan is substantially equivalent to the predicate device.
13. Non-Clinical Testing:
Non-clinical testing was performed to assess the safety and effectiveness of the device, to demonstrate the processing of patient imaging to produce accurate, repeatable and reproducible implant selection, sizing and placement of components, and the usability of the OPS™ Plan that is provided to the Surgeon. Testing verified that the accuracy and performance of the system is adequate to perform as intended.
14. Clinical Testing:
Clinical testing was not necessary for this Traditional 510(k).
15. Conclusion:
The subject device has similar intended uses and indications, technological characteristics, and principles of operation as its predicate device. The differences between the device and its predicate devices raise no new issues in terms of safety or effectiveness.
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).