K Number
K213777
Device Name
Stryker Resorbable Fixation System
Date Cleared
2022-02-04

(63 days)

Product Code
Regulation Number
872.4760
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Dental: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the maxillofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients. Neuro: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the cranial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients.
Device Description
The Stryker Resorbable Fixation System is a cranio-maxillofacial plating system intended for use in the fixation of bones of the craniofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients but is not intended for use in the mandible and/or full load bearing procedures. It consists of resorbable bone fixation plates, meshes, and screws made of a copolymer of poly lactide and poly glycolide.
More Information

Not Found

No
The summary describes a physical fixation system (plates, meshes, screws) and does not mention any software, algorithms, or data processing that would indicate the use of AI/ML. The performance studies are related to sterilization and aseptic transfer, not algorithmic performance.

No
The device is described as a fixation system for bones, which is a structural support rather than a therapeutic treatment for disease or dysfunction.

No
The device description and intended use state that the system is for the fixation of bones, not for diagnosing conditions. It is a surgical implant.

No

The device description explicitly states it consists of resorbable bone fixation plates, meshes, and screws, which are physical hardware components.

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 the "fixation of bones of the maxillofacial, midfacial, and cranial skeleton affected by trauma or for reconstruction." This describes a surgical procedure performed directly on the patient's body.
  • Device Description: The description details resorbable bone fixation plates, meshes, and screws made of a copolymer. These are physical implants used in surgery.
  • Lack of IVD Characteristics: An IVD device is used in vitro (outside the body) to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. The provided information does not mention any such use or interaction with biological specimens.

The device described is a surgical implant used for bone fixation, which falls under the category of medical devices, but not specifically In Vitro Diagnostic devices.

N/A

Intended Use / Indications for Use

The Delta Resorbable Fixation System is intended for use in the fixation of bones of the maxillofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients.

Neuro: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the cranial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients.

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

JEY, GXR, HBW

Device Description

The Stryker Resorbable Fixation System is a cranio-maxillofacial plating system intended for use in the fixation of bones of the craniofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients but is not intended for use in the mandible and/or full load bearing procedures. It consists of resorbable bone fixation plates, meshes, and screws made of a copolymer of poly lactide and poly glycolide.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

bones of the maxillofacial and midfacial skeleton, bones of the cranial skeleton

Indicated Patient Age Range

adult and pediatric patients

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)

Risk analysis was performed, and sterilization testing was performed in support of the substantial equivalence determination.

STERILIZATION AND BIOCOMPATIBILITY TESTING:

  • Characteristic: Sterilization Validation; Test: Product Adoption and Sterility; Result: Passed; Standards: ISO 11135:2014 +AMD1:2018
  • Characteristic: Sterilization / Biocompatibility; Test: EO Residual; Result: Passed; Standards: ISO 10993-7:2008 +AMD1:2019
  • Characteristic: Sterilization / Biocompatibility; Test: Endotoxin Testing; Result: Passed; Standards: ISO 10993-1 +ANSI/AAMI ST72:2019

SUMMATIVE USABILITY VALIDATION OF PACKAGING:

  • Characteristic: Summative Validation; Test: Aseptic transfer performance; Result: Passed
    The human factors testing/study was designed to evaluate in particular possible adverse effects caused by negative transfer. The study was conducted with a sample size of 19 representative users including experienced as well as new users. The full packaging configuration was subjected to test. All test participants were able to perform the aseptic transfer correctly. No use errors or use difficulties were observed. The packaging change was evaluated to be non-critical.

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.

K113109

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

§ 872.4760 Bone plate.

(a)
Identification. A bone plate is a metal device intended to stabilize fractured bone structures in the oral cavity. The bone segments are attached to the plate with screws to prevent movement of the segments.(b)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image contains 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 the FDA logo, which is a blue square with the letters "FDA" in white. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

2/4/2022

Stryker Leibinger Micro Implants Gregory Gohl Senior Regulatory Affairs Specialist 750 Trade Centre Way -Suite 200 Portage, Michigan 49002

Re: K213777

Trade/Device Name: Stryker Resorbable Fixation System Regulation Number: 21 CFR 872.4760 Regulation Name: Bone Plate Regulatory Class: Class II Product Code: JEY, GXR, HBW Dated: January 21, 2022 Received: January 26, 2022

Dear Gregory Gohl:

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,

for Andrew Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known)

K213777

Device Name Stryker Delta Resorbable Fixation System

Indications for Use (Describe)

Dental: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the maxillofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients.

Neuro: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the cranial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients.

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.

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

This section provides a summary of 510(k) information in accordance with the requirements of 21 CFR 807.92.

  • SUBMITTER [§807.92(a)(1)] I.

| 510(k) Owner: | Stryker Leibinger GmbH& Co. KG
Boetzinger Strasse 41
D-79111 Freiburg, Germany |
|------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| Submitter/ Contact
Person: | Gregory Gohl
Sr. Regulatory Affairs Specialist
Stryker Craniomaxillofacial (CMF)
1941 Stryker Way
Portage, MI 49002 |
| Phone: 269-370-1476
Fax: 877-648-7114 | |
| Date prepared: | February 4, 2022 |

  • DEVICE [§807.92(a)(2)] K213777 II.
Trade Name:Stryker Resorbable Fixation System
Abbreviated Name:Delta System / Delta Resorbable Fixation System
Common or Usual Name:Resorbable Bone Plating System
Device:Stryker Resorbable Fixation System
Classification Name &
Regulation Description:Plate, Fixation, Bone; per 21 CFR §888.3030
Regulation Medical
Specialty & Review Panel:Dental (OHT1/DHT1B – Office of Ophthalmic,
Anesthesia, Respiratory, ENT, & Dental); Neurology
(OHT5/DHT5A – Office of Neurological and Physical
Medicine Devices)
Primary Product Code:JEY
Subsequent Prod. Codes:GXR, HBW
Regulatory Device Class:Class II
*Note the company Stryker or legacy name Stryker Leibinger precedes the
product/trade name and predicate device in some documentation.

4

III. PREDICATE DEVICE [§807.92(a)(3)]

  • A. Submission Branch of Predicate Device: Division of Surgical, Orthopedic, and Restorative Devices; Office of Device Evaluation Center for Devices and Radiological Health
  • B. Predicate Device: Stryker Resorbable Fixation System K113109

IV. DEVICE DESCRIPTION [§807.92(a)(4)]

  • A. Submission Branch of Subject Device: Dental (OHT1/DHT1B-Office of Ophthalmic, Anesthesia, Respiratory, ENT, & Dental); Neurology (OHT5/DHT5A - Office of Neurological and Physical Medicine Devices)
  • B. Subject Device: Stryker Resorbable Fixation System (also referred to as Stryker Delta Resorbable Fixation System or Delta System

The Stryker Resorbable Fixation System is a cranio-maxillofacial plating system intended for use in the fixation of bones of the craniofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients but is not intended for use in the mandible and/or full load bearing procedures. It consists of resorbable bone fixation plates, meshes, and screws made of a copolymer of poly lactide and poly glycolide.

  • V. INDICATIONS FOR USE [§807.92(a)(5)]
Predicate Device - K113109Subject Device
Indications for
UseThe Delta Resorbable Fixation System is
intended for use in the fixation of bones
of the craniofacial and midfacial
skeleton affected by trauma or for
reconstruction. The system can be used
in both adult and pediatric patients but is
not intended for use in the mandible
and/or full load bearing procedures.Dental: The Delta Resorbable Fixation
System is intended for use in the fixation
of bones of the maxillofacial and
midfacial skeleton affected by trauma or
for reconstruction. The system can be
used in both adult and pediatric patients.
Neuro: The Delta Resorbable Fixation
System is intended for use in the fixation
of bones of the cranial skeleton affected
by trauma or for reconstruction. The
system can be used in both adult and
pediatric patients.

TABLE 5-1: COMPARISON OF INDICATIONS FOR USE

5

COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE VI. PREDICATE DEVICE [§807.92(a)(6)]

The subject device is compared to its predicate device for substantial equivalence of technological characteristics based on the following criteria:

  • A. Principles of Operation
  • B. Technological Characteristics

C. Principles of Operation / Operating Principle

The basic operational principle of the Stryker Resorbable Fixation System remains the same as for the predicate: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the craniofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients but is not intended for use in the mandible and/or full load bearing procedures. This submission does not propose a change in the operating principle as there is no change to the implant design. interface with accessories or implant materials.

D. Technological Characteristics

The technological characteristics remain the same as the predicate:

  • -Same Intended Use: The Delta Resorbable Fixation System is intended for use in the fixation of bones of the craniofacial and midfacial skeleton affected by trauma or for reconstruction. The system can be used in both adult and pediatric patients but is not intended for use in the mandible and/or full load bearing procedures.
  • -Same Mode of Fixation: fixated to the native bone with Stryker Delta Resorbable screws.
  • Same Materials of Construction: Implants are made of a copolymer of poly lactide and poly glycolide. No change to the formulation of the polymer.
  • -Same Design: The change of the sterilization supplier and location does not change the implant design by any means.

VII. PERFORMANCE DATA [§807.92(b)(7)]

The modifications described in this submission are the change to a new Ethylene Oxide (EO) sterilization supplier and location and a modification to the packaging. The new EO sterilization cycle is equivalent to the predicate device sterilization cycle operating at lower EO gas concentrations. There is no change to the sterilization method regarding the final end-product. The new supplier location and cycle were proven to be as substantially equivalent for sterilization as the predicate location.

Packaging components, design, and materials remain the same. Labeling requirements also remain unchanged. The modification of the packaging is an update of the sterile barrier layout of the double pouch packaging system (i.e., only the inner pouch is the sterile barrier instead of the outer and inner pouch as for the predicate devices). This change is

6

communicated to the customer through an inclusion of a warning sticker in regard. Useability validation confirms the warning sticker label mitigates the risk associated with the change in the sterile barrier packaging.

A risk analysis was performed, and sterilization testing was performed in support of the substantial equivalence determination.

There is no change in the design, material, manufacturing process, or duration/location of contact. The tests necessary to evaluate the change regarding the new sterilization location and supplier are listed below. The following tests were performed to adopt the Stryker Resorbable Fixation System plates and meshes into the existing EO Cycle.

CharacteristicTestResultStandards
Sterilization
ValidationProduct Adoption and
SterilityPassedISO 11135:2014
+AMD1:2018
Sterilization /
BiocompatibilityEO ResidualPassedISO 10993-7:2008
+AMD1:2019
Sterilization /
BiocompatibilityEndotoxin TestingPassedISO 10993-1
+ANSI/AAMI ST72:2019

TABLE 5-2: STERILIZATION AND BIOCOMPATIBILITY TESTING

The aseptic transfer (i.e., the transfer of the devices from the non-sterile field into the sterile field during surgery) is modified by the change in the sterile barrier declaration. The aseptic transfer has been identified as the only critical task to be subjected to a summative usability validation of packaging. The human factors testing/study was designed to evaluate in particular possible adverse effects caused by negative transfer. The study was conducted with a sample size of 19 representative users including experienced as well as new users. The full packaging configuration was subjected to test. All test participants were able to perform the aseptic transfer correctly. No use errors or use difficulties were observed. The packaging change was evaluated to be non-critical.

TABLE 5-3: SUMMATIVE USABILITY VALIDATION OF PACKAGING

CharacteristicTestResult
Summative ValidationAseptic transfer
performancePassed

Performance Bench Testing

Performance bench testing was not required as a basis for substantial equivalence.

7

Animal Testing

Animal testing was not required as a basis for substantial equivalence.

Clinical Testing [§807.92(b)(2)]

Clinical testing was not required as a basis for substantial equivalence.

VIII. CONCLUSION [§807.92(b)(3)]

In summary, the Stryker Resorbable Fixation System is substantially equivalent to its predicate device. The design of implants has not changed, nor has the manufacturing of them changed. There is no change to the sterilization method, and the sterilization cycles of the subject and predicate device are evaluated to be equivalent throughout this submission. The fundamental scientific technology has not changed from the predicate device since the design of the implants or subcomponents has not changed. The intended use, principle of operation, mechanism of action, technological characteristics, and materials of construction also have not changed. In reference to packaging and labeling, specifically, the packaging components, design, and materials remain the same. The moisture barrier change in packaging of the subject devices led to change in labeling. Human factors data supports that the modified packaging, including the change in labeling, is substantially equivalent to the predicate. Overall, the modifications do not raise new questions of safety or effectiveness. According to the comparison based on the requirements of 21 CFR 807.87 and the information provided herein. it is concluded that the information included in this submission supports substantial equivalence to the predicate device.