K Number
K191617
Device Name
Syntec Tibial Nail System
Date Cleared
2019-09-03

(77 days)

Product Code
Regulation Number
888.3020
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Syntec Tibial Nail System is intended to stabilize fractures of the proximal and the tibial shaft; certain pre-and post-isthmic fractures; open and closed tibial shaft fractures; and tibial malunions and non-unions
Device Description
The Syntec Tibial Nail System are manufactured from commercially SUS316L (stainless steel) and Ti-6AL-4V (Titanium alloy). It is an intramedullary (IM) nail with a 12° in the upper third of the reamed Tibial Nail. These nails will use ø5mm internal hex captured screws in various lengths for cross-screw fixation in both the proximal and distal portion of the nail. Also, an End Cap ø8.4 in 15mm lengths is available for proximal closing of the nail. The Syntec Tibial Nail System (nail, screw and end cap) are provided non-sterile and single use only. Also, it is not for spinal use. Associated instrumentation such as aiming device for proximal and distal, insertion guide wire, drill accessories, system and removal instruments are available with the system.
More Information

Not Found

No
The device description focuses on the material and mechanical design of an intramedullary nail and associated hardware. There is no mention of software, algorithms, or data processing that would indicate the use of AI/ML. The performance studies are biomechanical tests, not studies evaluating algorithmic performance.

No.
The device is a non-sterile, single-use intramedullary (IM) nail system designed to stabilize fractures in the tibia, which is an orthopedic implant, not a therapeutic device.

No

The device is an intramedullary nail system used to stabilize bone fractures, not to diagnose medical conditions or diseases.

No

The device description clearly states that the device is an intramedullary nail system made of stainless steel and titanium alloy, which are hardware components.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states the device is for stabilizing fractures of the tibia. This is a surgical procedure performed directly on the patient's body.
  • Device Description: The description details an intramedullary nail, screws, and an end cap made of metal. These are physical implants used in surgery.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens (like blood, urine, or tissue) outside of the body to provide information about a patient's health.

IVD devices are used to perform tests on samples taken from the body to diagnose diseases or conditions. This device is a surgical implant used to treat a physical injury.

N/A

Intended Use / Indications for Use

The Syntec Tibial Nail System is intended to stabilize fractures of the proximal and the tibial shaft; certain pre-and post-isthmic fractures; open and closed tibial shaft fractures; and tibial malunions and non-unions.

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

HSB

Device Description

The Syntec Tibial Nail System are manufactured from commercially SUS316L (stainless steel) and Ti-6AL-4V (Titanium alloy). It is an intramedullary (IM) nail with a 12° in the upper third of the reamed Tibial Nail. These nails will use ø5mm internal hex captured screws in various lengths for cross-screw fixation in both the proximal and distal portion of the nail. Also, an End Cap ø8.4 in 15mm lengths is available for proximal closing of the nail. The Syntec Tibial Nail System (nail, screw and end cap) are provided non-sterile and single use only. Also, it is not for spinal use. Associated instrumentation such as aiming device for proximal and distal, insertion guide wire, drill accessories, system and removal instruments are available with the system.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

proximal and distal tibia and the tibial shaft

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)

Non-Clinical Test: Biomechanical Test: The biomechanical tests ASTM F1264-16e1were performed to determine substantial equivalence for the Syntec Tibial Nail System including the performance of Tibial Nail and Internal Hex Captured Screw. Results indicate that the subject Tibial Nail and Internal Hex Captured Screw are substantially equivalent to legally marketed devices.

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.

K984543, K181296, K040762

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

§ 888.3020 Intramedullary fixation rod.

(a)
Identification. An intramedullary fixation rod is a device intended to be implanted that consists of a rod made of alloys such as cobalt-chromium-molybdenum and stainless steel. It is inserted into the medullary (bone marrow) canal of long bones for the fixation of fractures.(b)
Classification. Class II.

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September 3, 2019

Syntec Scientific Corporation % Kavin Chu Senior Regulatory Affairs Manager Syntec Scientific Corporation - Taipei Office 3F., No.96, Sec. 3, Zhongxio East Road Da'An Dist., TAIPEI 10652 TAIWAN R.O.C

Re: K191617

Trade/Device Name: Syntec Tibial Nail System Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary Fixation Rod Regulatory Class: Class II Product Code: HSB Dated: May 31, 2019 Received: June 18, 2019

Dear Kavin Chu:

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.

1

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 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

Shumaya Ali, MPH Assistant Director DHT6C: Division of Stereotaxic, Trauma and Restorative Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K191617

Device Name

Syntec Tibial Nail System

Indications for Use (Describe)

The Syntec Tibial Nail System is intended to stabilize fractures of the proximal and the tibial shaft; certain pre-and post-isthmic fractures; open and closed tibial shaft fractures; and tibial malunions and non-unions

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/0 description: This image contains the logo for Syntec Scientific Corporation. The logo consists of the text "SYNTEC SCIENTIFIC CORPORATION" in a bold, dark blue font. To the left of the text is a circular graphic with the letters "OS" inside, with the word "SYNTEC SCIENTIFIC" below it. The text "K191617 Page 1/4" is located in the upper right corner of the image.

This summary of 510(k) information is being submitted in accordance with the requirement of SMDA 1990 and 21CFR 807.92.

510(k) SUMMARY

Submitted By:Syntec Scientific Corporation
Address:No.2, Kung San Road
Chuan Shing Industrial Zone,
Shen Kang, Chang Hua Hsien, Taiwan R.O.C.
TEL: +886-4-798-7099
FAX: +886-4-798-7077
Date of Summary Prepared:2019-05-31
Contact person:Kavin Chu
Name of the device:Syntec Tibial Nail System
Trade or proprietary name:Syntec Tibial Nail System
Common or usual name:Intramedullary Nail
Classification name:Intramedullary Fixation Rod
Produce code:HSB
Regulation number:21CFR888.3020
Class:Class II
Primary Predicate:Syntec-Taichung Non-Sterile Interlocking Nail System
(K984543)
Additional Predicates:Syntec Femoral Nail System (K181296)
Synthes (USA) Tibial Nail System Ex (K040762)

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K191617 Page 2/4

Image /page/4/Picture/1 description: The image contains the logo for Syntec Scientific. The logo consists of a large orange circle overlapping a blue letter "S". To the right of the logo is the text "SYNTEC SCI" in a large, bold, blue font. Below the logo is the text "SYNTEC SCIENTIFIC" in a smaller font.

EC SCIENTIFIC CORPORATION

1. Description of the Device

The Syntec Tibial Nail System are manufactured from commercially SUS316L (stainless steel) and Ti-6AL-4V (Titanium alloy). It is an intramedullary (IM) nail with a 12° in the upper third of the reamed Tibial Nail. These nails will use ø5mm internal hex captured screws in various lengths for cross-screw fixation in both the proximal and distal portion of the nail. Also, an End Cap ø8.4 in 15mm lengths is available for proximal closing of the nail. The Syntec Tibial Nail System (nail, screw and end cap) are provided non-sterile and single use only. Also, it is not for spinal use. Associated instrumentation such as aiming device for proximal and distal, insertion guide wire, drill accessories, system and removal instruments are available with the system.

    1. Indications for Use
      The Syntec Tibial Nail System is intended to stabilize fractures of the proximal and distal tibia and the tibial shaft; certain pre- and post-isthmic fractures; open and closed tibial shaft fractures; and tibial malunions and non-unions.
    1. Technological Characteristics, Comparison to Predicate Device Syntec Tibial Nail System is similar to our previous Syntec-Taichung Non-sterile Interlocking Nail System and Syntec Femoral Nail System; both of systems are cleared for market in 510(k) K984543, K181296 and essentially Equivalent (SE) to the predicate. The indications for the Syntec Tibial Nail System are patterned after the predicate devices and supported by an extensive collection of literature references.

The differences between subject and predicates system as below chart.

Syntec Tibial Nail System and Syntec-Taichung Non-sterile Interlocking Nail System K984543 (Tibial Nail)

Subject devicePredicate Device
Device NameSyntec Tibial Nail SystemSyntec-Taichung Non-sterile
Interlocking Nail System
ApplicantSyntec Scientific CorporationSyntec Scientific Corporation
510(k)K191617K984543

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Image /page/5/Picture/1 description: The image shows a logo for Syntec Scientific. The logo features a large orange circle overlapping a blue letter 'S'. Below the graphic, the words 'SYNTEC SCIENTIFIC' are written in a simple, sans-serif font, with 'SYNTEC' on the top line and 'SCIENTIFIC' on the bottom line.

EC SCIENTIFIC CORPORATION

| Material Comparison | Surgical Stainless Steel (SUS316L)
and
Surgical Titanium Alloy (Ti6AL-4V) | Surgical Stainless Steel (SUS316L) |
|----------------------|---------------------------------------------------------------------------------|-------------------------------------------------------|
| Nail Diameter | ø9, ø10, ø11, ø12, ø13 | ø8, ø9, ø10, ø11, ø12, ø13, ø14 |
| Nail Length | From 270 mm to 345 mm
(in 15 mm increments) | From 270 mm to 420 mm
(in 15 and 20 mm increments) |
| Proximal Shaft Angle | 12° | 15° |

Syntec Tibial Nail System and Syntec Femoral Nail System K181296

Subject devicePredicate Device
Device NameSyntec Tibial Nail SystemSyntec Femoral Nail System
ApplicantSyntec Scientific CorporationSyntec Scientific Corporation
510(k)K181296
Material ComparisonSurgical Stainless Steel (SUS316L)
and
Surgical Titanium Alloy (Ti6AL-4V)Surgical Stainless Steel (SUS316L)
and
Surgical Titanium Alloy (Ti6AL-4V)
Screw Dia.⌀5.0 mm Internal Hex Captured⌀5.0 mm Internal Hex Captured
Screw LengthFrom 30 mm to 100 mm
(in 5 mm increments)From 30 mm to 100 mm
(in 5 mm increments)
End Caps Diameter⌀ 8.4⌀ 13
Nail Cap Lengthin 15 mm lengthsin 3,5, 10,15 mm lengths

(Internal Hex Captured Screw, End Cap)

4. Technological Characteristics:

The Syntec Tibial Nail System is fabricated from stainless steel (SUS316L) per ASTM F138 and ASTM F139, titanium alloy (Ti6AL-4V) per ASTM F136. The design feature for the Syntec Tibial Nail System are similar to the predicate devices including dimensions, shape and sizes.

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'EC SCIENTIFIC CORPORATION

5. Summary of Performance Data (Nonclinical and/or Clinical)

*Clinical Test

Clinical studies are not required to support substantially equivalent.

*Non-Clinical Test

Biomechanical Test: The biomechanical tests ASTM F1264-16e1were performed to determine substantial equivalence for the Syntec Tibial Nail System including the performance of Tibial Nail and Internal Hex Captured Screw. Results indicate that the subject Tibial Nail and Internal Hex Captured Screw are substantially equivalent to legally marketed devices.

6. Substantial Equivalence

The Syntec Tibial Nail System has the same intended uses and indications, technological characteristics, and principles of operation to the predicate device. Thus, the Syntec Tibial Nail System is substantially equivalent in design, configuration, function, and indications for use to the Predicate Device.