The implants of the DePuy Synthes Hammertoe Continuous Compression Implant System are made of biocompatible Nitinol and are designed to exhibit pseudoelastic (superelastic) properties at room temperature. Each implant is supplied pre-loaded on an insertion stick assembly in a constrained state, with the legs parallel. It is inserted into pre-drilled holes and released utilizing the insertion slider and if necessary, impaction on the proximal end of the insertion stick. Upon release, the implants attempt to return to their original unconstrained shape and thus provide compression to the bones across the osteotomy or arthrodesis site. The implants do not require any external heating; they are completely transformed at ambient temperature. In good bone quality, this deflection may not be visible as the legs are constrained by the surrounding tissue. The implant is offered in two (2) sizes to address varying patient anatomy of the foot. The implant is delivered to the operating room in a disposable, sterile kit, preloaded onto a handheld insertion stick assembly along with a drill pin, drill guide, locator pins and K-wires.

AI/ML Overview

The provided text is a 510(k) summary for the DePuy Synthes Hammertoe Continuous Compression Implant. It outlines the device description, indications for use, comparison to predicate devices, and non-clinical performance data.

However, it explicitly states:

"Clinical testing was not necessary for the determination of substantial equivalence."

This means that a study proving the device meets specific acceptance criteria based on clinical performance was not performed, nor was it required for this 510(k) clearance. The clearance was based on demonstrating substantial equivalence to existing legally marketed predicate devices through technological characteristics and non-clinical testing.

Therefore, I cannot provide the requested information, which pertains to clinical acceptance criteria and a study demonstrating their achievement, as such a study was not conducted for this device clearance.

Summary

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February 26, 2020

Image /page/0/Picture/1 description: The image shows 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.

Synthes (USA) Products, LLC Keith Knapp RA Specialist 1301 Goshen Parkway West Chester, Pennsylvania 19380

Re: K191463

Trade/Device Name: DePuy Synthes Hammertoe Continuous Compression Implant Regulation Number: 21 CFR 888.3030 Regulation Name: Single/Multiple Component Metallic Bone Fixation Appliances And Accessories Regulatory Class: Class II Product Code: JDR Dated: January 24, 2020 Received: January 27, 2020

Dear Keith Knapp:

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/cfpmp/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 devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see

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https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

FOR Vesa Vuniqi Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K191463

Device Name

DePuy Synthes Hammertoe Continuous Compression Implant

Indications for Use (Describe)

The DePuy Synthes Hammertoe Continuous Compression Implant is indicated for small bone reconstruction and fusion of the phalanges in the toes.

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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1-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------510(k) Summary

Sponsor	DePuy SynthesKeith Knapp1301 Goshen ParkwayWest Chester, PA 19380Phone: +1-610-719-5942
Date Prepared	February 2020
Proprietary Name	DePuy Synthes Hammertoe Continuous Compression Implant
Device CommonName	Staple, Fixation, Bone
Classification Name	Single/multiple component metallic bone fixation appliances andaccessories.
Classification	Class IIRegulation Number: 21 CFR 888.3030Product Code: JDR
Predicate Devices	Primary Predicate Device:BioMedical Enterprises, Inc. OSStaple (K993714)Secondary Predicate Device:BioMedical Enterprises, Inc. Hammerlock 2(K133520)
Device Description	The implants of the DePuy Synthes Hammertoe Continuous CompressionImplant System are made of biocompatible Nitinol and are designed toexhibit pseudoelastic (superelastic) properties at room temperature. Eachimplant is supplied pre-loaded on an insertion stick assembly in aconstrained state, with the legs parallel. It is inserted into pre-drilled holesand released utilizing the insertion slider and if necessary, impaction on theproximal end of the insertion stick. Upon release, the implants attempt toreturn to their original unconstrained shape and thus provide compressionto the bones across the osteotomy or arthrodesis site. The implants do notrequire any external heating; they are completely transformed at ambienttemperature. In good bone quality, this deflection may not be visible as thelegs are constrained by the surrounding tissue.The implant is offered in two (2) sizes to address varying patient anatomy ofthe foot.
	The implant is delivered to the operating room in a disposable, sterile kit, preloaded onto a handheld insertion stick assembly along with a drill pin, drill guide, locator pins and K-wires.
Indications for use	The DePuy Synthes Hammertoe Continuous Compression Implant is indicated for small bone reconstruction and fusion of the phalanges in the toes.
Comparison toPredicate	The design, features, and specifications of the subject and primary predicate systems compared below. The shared technological characteristics are as follows:Range of staple legs of the subject device are within range of those offered in the predicate device. The material of both the subject device and predicate device is Nitinol.
	Technical characteristics found in the subject implants that are not found in the primary predicate are listed below: The predicate requires the application of an electrical current to the staple after implant placement to heat and transform the nitinol material, the subject device requires no additional steps after implant placement. The principles of operation - compression across the operative site are the same in both devices. The predicate has smooth legs while the subject device features three (3) barbs. This increases the pullout strength of the subject device compared to the predicate.
	The design, features, and specifications of the subject and secondary predicate systems compared below. The shared technological characteristics are as follows: The material of both the subject device and predicate device is Nitinol. Both devices include barbed legs for increased pullout strength Both devices require no external energy source to achieve compression
	Technical characteristics found in the subject implants that are not found in the secondary predicate are listed below: The predicate is inserted in an intramedullary fashion while the subject device in inserted extra-medullary, but both are intended to bridge the fusion site and provide compression. The predicate includes a greater number of legs.
Non-clinicalPerformance Data	The following analysis were conducted:Static Bend according to ASTM F564 Pullout testing was performed according to ASTM F564 Corrosion testing was performed according to ASTM F2129 Dynamic Bend Testing Endotoxin Testing was performed according to AAMI ST72 Other Additional Testing: MRI Conditional analysis has been performed to establish MRConditional parameters for the subject DePuy Synthes HammertoeContinuous Compression Implant
ClinicalPerformance Data	Clinical testing was not necessary for the determination of substantialequivalence.
SubstantialEquivalence	The DePuy Synthes Hammertoe Continuous Compression Implants possessthe equivalent technological characteristics as that of the primary predicatedevice. These include: principles of operation basic design material sizes (dimensions are comparable to those offered by the predicatesystems) The DePuy Synthes Hammertoe Continuous Compression Implants possessthe equivalent technological characteristics as that of the secondarypredicate device. These include: material method of compression design features The proposed device has indications for use that are fully encompassed bythe indications for use of the primary and secondary predicate device andboth the subject and predicate devices are manufactured from the samenitinol material.The mechanical testing and analytical evaluation included in this submissiondemonstrate that any differences in technological characteristics of thesubject devices do not raise any new questions of safety and effectiveness.The proposed devices are at least as safe and effective as the primary andsecondary predicate devices.It is concluded that the information provided in this submission supportssubstantial equivalence.

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Regulation Number and Section

§ 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.