(59 days)
BonOs® HV, BonOs® MV and BonOs® LV are intended to be used for the fixation of artificial joint protheses to the host bone.
BonOs® HV, BonOs® MV and BonOs® LV are PMMA, radiopaque bone cements, designed for the fixation of prothesis to the living bone. BonOs® HV, BonOs® MV and BonOs® LV are traditional bone cement products. The bone cement is made of two separate sterile components. When both components are mixed together, they become a self-hardening, radiopaque bone cement which fixes the implant and transfer stresses evenly to the bone. The liguid is contained in a vial and the powder in a pouch: these components are packed in blister with Tyvek lid or an aluminium pouch. The devices are sold disposable, single-use and sterile.
The provided text is a 510(k) Summary for a medical device called BonOs® HV, BonOs® MV, and BonOs® LV, which are PMMA bone cements. This document outlines the general information about the device, its classification, comparison to predicate devices, and performance data.
However, it does not contain information related to a study proving the device meets acceptance criteria concerning AI/ML performance, human readers, or ground truth establishment based on expert consensus/adjudication typical for AI/ML device clearances.
The performance data summarized in this document pertains to traditional medical device testing for bone cements, such as:
- Sterilization and Shelf Life: Validated according to ISO 11135 and ISO 13408-1/2.
- Biocompatibility: Performed according to ISO 10993-1, with identical materials to other bone cements on the market.
- Performance Testing (Chemical, Material, and Mechanical): Included mixing and application characteristics, chemical composition, molecular weight and polymer structure, physical properties, stability of components, thermal properties, and mechanical properties. These tests were conducted in accordance with "FDA Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement; Guidance for Industry and FDA" dated July 17, 2002, and met standards like ASTM F451-16, ISO 5833:2002, etc.
- Bacterial Endotoxins: Evaluated using Recombinant Factor C Assay (EndoZyme) following Ph. Eur. 5.01.10, based on USP <161>, meeting endotoxin limits.
Therefore, I cannot populate the requested table and answer the specific questions about AI/ML device performance, human readers, sample sizes for AI/ML test/training sets, or expert-based ground truth establishment. The document describes a traditional substantial equivalence determination for a physical medical device (bone cement), not an AI/ML powered device.
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March 19, 2021
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 and 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.
OSARTIS GmbH Volker Stirnal Director, Quality Assurance and Regulatory Affairs Auf der Beune 101 Münster, 64839 Germany
Re: K210120
Trade/Device Name: BonOs® HV, BonOs® MV, BonOs® LV Regulation Number: 21 CFR 888.3027 Regulation Name: Polymethylmethacrylate (PMMA) Bone Cement Regulatory Class: Class II Product Code: LOD Dated: January 15, 2021 Received: January 19, 2021
Dear Volker Stirnal:
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 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
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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
Laura C. Rose, Ph.D. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.
510(k) Number (if known) K210120
Device Name BonOs® HV, BonOs® MV, BonOs® LV
Indications for Use (Describe)
BonOs® HV, BonOs® MV and BonOs® LV are intended to be used for the fixation of artificial joint protheses to the host bone.
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)
CONTINUE ON A SEPARATE PAGE IF NEEDED.
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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
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FORM FDA 3881 (6/20)
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| OSARTIS GmbH | BonOs® HV | |
|---|---|---|
| Auf der Beune 101 | BonOs® MV | Date of issue: |
| 64839 Münster | BonOs® LV | Mar 10, 2021 |
| Germany | 5. 510(k) Summary | |
| 510(k) Premarket Notification |
5. 510(k) Summary
1. General Information
Submitter and Owner of the 510(k) 1.1
OSARTIS GmbH Auf der Beune 101 64839 Münster Germany Phone: +49 6071 / 929-0 +49 6071 / 929-100 Fax:
1.2 Contact Person
Volker Stirnal
Devices Subject of this 510(k) 1.3
- BonOs® HV
- BonOs® MV
- BonOs® LV
1.4 Date of Preparation
March 10, 2021
2. Name of the Device and Classification Information
This traditional 510(k) has been submitted for the following devices.
- BonOs® HV
- BonOs® MV
- BonOs® LV
2.1 Trade/Proprietary Name
- BonOs® HV
- BonOs® MV
- BonOs® LV
Common/Usual Name 2.2
PMMA bone cement for orthopedics
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| OSARTIS GmbH | BonOs® HV | |
|---|---|---|
| Auf der Beune 101 | BonOs® MV | Date of issue: |
| 64839 Münster | BonOs® LV | Mar 10, 2021 |
| Germany | 5. 510(k) Summary | |
| 510(k) Premarket Notification |
2.3 Classification Information
Classification Name: Polymethylmethacrylate (PMMA) Bone Cement
Classification Regulation: 21 CFR § 888.3027
Regulatory Class: Class II
Product Code: LOD - Bone Cement
Panel: Orthopedic
3. Predicate Device
The predicate devices are as follows:
4. Device Description
BonOs® HV, BonOs® MV and BonOs® LV are PMMA, radiopaque bone cements, designed for the fixation of prothesis to the living bone. BonOs® HV, BonOs® MV and BonOs® LV are traditional bone cement products. The bone cement is made of two separate sterile components. When both components are mixed together, they become a self-hardening, radiopaque bone cement which fixes the implant and transfer stresses evenly to the bone. The liguid is contained in a vial and the powder in a pouch: these components are packed in blister with Tyvek lid or an aluminium pouch. The devices are sold disposable, single-use and sterile.
5. Indication for Use
Below is the indication for use:
BonOs® HV, BonOs® MV and BonOs® LV are intended to be used for the fixation of artificial joint protheses to the host bone.
6. Comparison of the technological Characteristics with the Predicate Device
BonOs® HV, BonOs® MV and BonOs® LV share many of the same technological characteristics compared to the predicate Rally™ HV Bone Cement, including important considerations such as materials, mechanical performance and chemical-physical performances. There are, however, some differences in technological characteristics, such as the radiopacifier and method of sterilization, for this reason, a second predicate (Palacos®) was included.
These comparisons are summarized in Table 2.
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| OSARTIS GmbHAuf der Beune 10164839 MünsterGermany | BonOs® HVBonOs® MVBonOs® LV5. 510(k) Summary510(k) Premarket Notification | Date of issue:Mar 10, 2021 |
|---|---|---|
| --------------------------------------------------------------- | ------------------------------------------------------------------------------------------- | -------------------------------- |
Table 2: Comparison of the Technological Characteristics with the Predicate Devices
| Characteristics | BonOs® HVBonOs® MVBonOs® LV | Rally™ HV BoneCementK143134 | Palacos® RK030902 | |
|---|---|---|---|---|
| Materialpowder | Polymer | Poly(methylacrylate/methylmethacrylate)(PMA/PMMA) | Poly(methylacrylate/methylmethacrylate)(PMA/PMMA) | Poly(methylacrylate/methylmethacrylate)(PMA/PMMA) |
| Initiator | Benzoyl peroxide | Benzoyl peroxide | Benzoyl peroxide | |
| Radio-pacifier | Zirconium dioxide | Barium sulfate | Zirconium dioxide | |
| ColorAdditives | None | Pigments (FD&CBlue No. 1 andFD&C Yellow No.5) | Chlorophyll VIII | |
| MaterialLiquid | Monomer | Methylmethacrylate (MMA) stabilizedwith Hydroquinone | Methylmethacrylate (MMA) stabilizedwith Hydroquinone | Methylmethacrylate (MMA) stabilizedwith Hydroquinone |
| Activator | N,N-Dimethyl-p-toluidine | N,N-Dimethyl-p-toluidine | N,N-Dimethyl-p-toluidine | |
| ColorAdditives | None | None | Chlorophyll VIII inoil solution | |
| Powder SterilizationMethod | Ethylene oxide | Gamma-rayirradiation | Ethylene oxide | |
| Liquid SterilizationMethod | Aseptic processing | Aseptic processing | Aseptic processing | |
| Terminal Liquid | Sterilization Method | Ethylene oxide | Ethylene oxide | Ethylene oxide |
7. Performance Data
This 510(k) notification provided performance data to establish the substantial equivalence of the new bone cements to the predicate bone cement. Performance testing was conducted in accordance with the "FDA Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement; Guidance for Industry and FDA" dated July 17, 2002. The following is a summary of the performance data.
Sterilization and Shelf Life: The sterilization process, including the ethylene oxide method and the membrane filter sterilization has been validated and the sterility of the subject devices has been verified according to ISO 11135 and ISO 13408-1/2).
Biocompatibility: The biological evaluation of BonOs® HV, BonOs® MV and BonOs® LV was performed in accordance with ISO 10993-1. BonOs® HV, BonOs® MV and BonOs® LV contain identical materials as other well-known bone cements on the market and shows no additional risks. Evaluation for BonOs® HV, BonOs® MV and BonOs® LV additionally conformed to ISO 10993-1.
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| OSARTIS GmbHAuf der Beune 10164839 MünsterGermany | BonOs® HVBonOs® MVBonOs® LV5. 510(k) Summary510(k) Premarket Notification | Date of issue:Mar 10, 2021 |
|---|---|---|
| --------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------- | -------------------------------- |
Performance Testing (Chemical, Material and Mechanical): Performance testing was performed to characterize the bone cements in accordance with special controls quidance document. This testing included the following:
- Mixing and Application characteristics (e.q. dough time, setting time, viscosity, intrusion)
- Chemical Composition (e.q. trace elements, residual low MW molecules, leachables)
- Molecular weight and Polymer structure (e.g. molecular weight, glass transition temperature)
- Physical Properties (e.g. porosity, shrinkage)
- Stability of Components (e.g. change in monomer viscosity due to artificial aging)
- Thermal Properties (e.g. maximum polymerization temperature)
- Mechanical properties (e.g. cyclic fatique properties, bending properties, compressive properties, tensile properties, fracture toughness)
Results show comparable performances to the predicate device and are in compliance with ASTM F451-16, ISO 5833:2002, ISO 527:1/2, ASTM F2118-14, ASTM D2990-17, ASTM D732-17, ASTM 638-14 and ASTM E399-20.
The performance data demonstrate that the new devices BonOs® HV, BonOs® MV and BonOs® LV are substantially equivalent to the predicate device Rally™ HV Bone Cement 510(k) application K143134 and meet the requirements of the Special Controls Guidance document.
Bacterial endotoxins of BonOs® HV, BonOs® MV and BonOs® LV have been evaluated using Recombinant Factor C Assay (EndoZyme) following Ph. Eur. 5.01.10, based on USP <161>Test results meet the endotoxin limits of 20 endotoxin units (EU)/device as defined in USP and as recommended by the FDA guidance "Submission and Review of Sterlity Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile (2016). This Test for bacterial endotoxins is performed for all produced batches. The device meets the pyrogen limit specifications as described by the FDA quidance "Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile" (2016).
8. Conclusion
BonOs® HV, BonOs® MV and BonOs® LV have been found to be substantially equivalent to the predicate devices with respect to technical characteristics, performance and intended use. The information provided within this premarket notification supports substantial equivalence of the subject to the predicate devices.
§ 888.3027 Polymethylmethacrylate (PMMA) bone cement.
(a)
Identification. Polymethylmethacrylate (PMMA) bone cement is a device intended to be implanted that is made from methylmethacrylate, polymethylmethacrylate, esters of methacrylic acid, or copolymers containing polymethylmethacrylate and polystyrene. The device is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement.”