K Number
K211789
Device Name
restor3d Pin Implants
Manufacturer
Date Cleared
2022-01-04

(208 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
restor3d Pin Implants are indicated for maintenance of alignment and fixation of bone fractures, arthrodesis, and bone grafts in the presence of appropriate additional immobilization (e.g. rigid fixation implants, cast, brace).
Device Description
restor3d pin implants are made from implant grade titanium alloy using an additive manufacturing process and possess a porous surface structure of unique topology. Pin implants are designed for use in a variety of surgical procedures including fixation of fractures, osteotomies, arthrodesis and as bone graft in the presence of additional immobilization. The pin implants are offered in a range of diameters, permitting surgeons to choose a relevant size for the affected anatomy.
More Information

No
The summary describes a physical implant device made with additive manufacturing and tested for mechanical properties. There is no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is indicated for fixation of bone fractures, arthrodesis, and bone grafts, which addresses a medical condition or ailment.

No

The device is indicated for fixation of bone fractures, arthrodesis, and bone grafts, which are treatment or support functions, not diagnostic.

No

The device description explicitly states the device is a physical implant made from titanium alloy using additive manufacturing.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "maintenance of alignment and fixation of bone fractures, arthrodesis, and bone grafts." This describes a surgical implant used directly on the patient's body to support bone structure.
  • Device Description: The description details a physical implant made from titanium alloy, designed for surgical procedures involving bone.
  • 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. IVDs are used for diagnosis, monitoring, or screening based on analysis of these specimens.

Therefore, the restor3d Pin Implants are a surgical implant, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

restor3d Pin Implants are indicated for maintenance of alignment and fixation of bone fractures, arthrodesis, and bone grafts in the presence of appropriate additional immobilization (e.g. rigid fixation implants, cast, brace).

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

HTY

Device Description

restor3d pin implants are made from implant grade titanium alloy using an additive manufacturing process and possess a porous surface structure of unique topology. Pin implants are designed for use in a variety of surgical procedures including fixation of fractures, osteotomies, arthrodesis and as bone graft in the presence of additional immobilization. The pin implants are offered in a range of diameters, permitting surgeons to choose a relevant size for the affected anatomy.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

bone fractures, osteotomies, arthrodesis, and bone grafts

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)

The proposed restor3d device was subject to the following benchtop performance tests to support the assertion of substantial equivalence:

  • Bending Testing
  • Shear Testing
  • Pullout Testing

No new questions of safety or effectiveness were identified during device testing; therefore, the restor3d Pin Implants are considered substantially equivalent to the predicate 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.

K181180

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.

K050259, K191047, K143618

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

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.

0

January 4, 2022

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

restor3d Lexi Lewis Director of Extremity 311 West Corporation Street Durham, North Carolina 27701

Re: K211789

Trade/Device Name: restor3d Pin Implants Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: HTY Dated: December 3, 2021 Received: December 7, 2021

Dear Ms. Lewis:

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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for

1

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,

Colin O'Neill, MBE Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K211789

Device Name restor3d Pin Implants

Indications for Use (Describe)

restor3d Pin Implants are indicated for maintenance of alignment and fixation of bone fractures, arthrodesis, and bone grafts in the presence of appropriate additional immobilization (e.g. rigid fixation implants, cast, brace).

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

510(k) Summary

510(k) Number: K211789

Date Prepared: December 3, 2021

This 510(k) summary is being submitted in accordance with the requirements of 21 CFR 807.92.

  • A. 510(k) Submitter: restor3d, inc. 311 W. Corporation St. Durham, NC 27701
  • B. Primary Correspondent: Lexi Lewis Director of Extremity 317-287-4311 lexi@restor3d.com
  • C. Device Information:
Trade Name:restor3d Pin Implant
Common Name:fixation, pin, smooth
  • D. Classification:
    Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or Threaded Metallic Bone Fixation Fastener Regulation Class: Class II Product Code: HTY

  • E. Predicate Devices:

Primary Predicate:OSSIO™ Pin Product Family (K181180)
Reference Predicates:Arthrex Bio-Pin (K050259)
ADI TIDAL Osteotomy Wedge (K191047)
Zimmer Kirschner Wires and Steinmann Pins (K143618).

F. Physical Description: restor3d pin implants are made from implant grade titanium alloy using an additive manufacturing process and possess a porous surface structure of unique topology. Pin

4

implants are designed for use in a variety of surgical procedures including fixation of fractures, osteotomies, arthrodesis and as bone graft in the presence of additional immobilization. The pin implants are offered in a range of diameters, permitting surgeons to choose a relevant size for the affected anatomy.

  • G. Indications for Use:
    restor3d Pin Implants are indicated for maintenance of alignment and fixation of bone fractures, osteotomies, arthrodesis, and bone grafts in the presence of appropriate additional immobilization (e.g. rigid fixation implants, cast, brace).

  • H. Comparison of Characteristics / Performance Testing / Substantial Equivalence:
    The restor3d Pin Implants are substantially equivalent to the predicate devices in intended use and performance specifications. The devices have similar design/physical characteristics (i.e., similar sizing and mechanism of fixation) and the same indications for use. The proposed restor3d device was subject to the following benchtop performance tests to support the assertion of substantial equivalence:

  • . Bending Testing

  • . Shear Testing

  • . Pullout Testing

No new questions of safety or effectiveness were identified during device testing; therefore, the restor3d Pin Implants are considered substantially equivalent to the predicate devices.

A. Lewis

Date: Dec. 3, 2021

Lexi Lewis Director of Extremity lexi@restor3d.com

Image /page/4/Picture/13 description: The image shows the word "restor3d" in a bold, sans-serif font. The first part of the word, "restor", is filled in with black, while the "3d" part is outlined in black, creating a contrast between the two parts of the word. The overall design is simple and modern.