(146 days)
Not Found
No
The summary describes patient-specific guides and models generated from CT data, but there is no mention of AI or ML being used in the design or manufacturing process. The performance studies focus on the equivalence of the guides to existing instrumentation and debris generation, not on the performance of any AI/ML algorithm.
No
The device is described as surgical planning and instrumentation to assist in the positioning of total ankle replacement components and guiding bone cutting, which means it aids a surgical procedure rather than directly treating a medical condition or disease.
No
Explanation: The device is described as "patient specific surgical planning and instrumentation to assist in the positioning of total ankle replacement components intraoperatively, and in guiding bone cutting." It focuses on guiding surgical procedures rather than diagnosing a medical condition.
No
The device description explicitly states that the system produces "surgical guides" and "anatomic models" which are "designed and manufactured from patient imaging data (CT) and are made from biocompatible nylon." These are physical components, not solely software.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, treatment, or prevention of disease.
- Device Function: The OPTIX H2 Patient Specific Instrument System is a surgical planning and instrumentation system. It uses patient imaging data (CT scans) to create physical guides and models that assist a surgeon during a total ankle replacement procedure. It is used intraoperatively to guide bone cutting and component positioning.
- Lack of Specimen Analysis: The device does not involve the analysis of any biological specimens taken from the patient. Its function is based on anatomical imaging data and physical guides used during surgery.
Therefore, the device's intended use and function clearly fall outside the scope of an In Vitro Diagnostic device.
N/A
Intended Use / Indications for Use
The OPTIX H2 Patient Specific Instrument System is intended to be used as patient specific surgical planning and instrumentation to assist in the positioning of total ankle replacement components intraoperatively, and in guiding bone cutting. The OPTIX H2 Patient Specific Instrument System is intended for use with Vilex's Hintermann Series H2 Total Ankle System and its cleared indications for use. The OPTIX H2 Patient Specific Instrument System is indicated for single use only and is generated from CT imaging data.
Product codes
HSN, OYK
Device Description
OPTIX H2 Patient Specific Instrument System is patient-specific guides created to fit the contours of the patient's distal tibial and proximal talar anatomy. The guides and models are designed and manufactured from patient imaging data (CT) and are made from biocompatible nylon. The surgical guides in combination with Hintermann reusable instruments, facilitate the positioning of the Hintermann Series H2 Total Ankle implants. Vilex's OPTIX H2 PSI System produces a variety of patient specific outputs including surgical guides, anatomic models, and case reports.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
CT imaging data
Anatomical Site
distal tibial and proximal talar anatomy (for total ankle replacement components)
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
Validation testing was performed for the OPTIX H2 PSI System in comparison with the Hintermann H2 System. The objective of this testing was to demonstrate that the OPTIX H2 PSI System allows for an equivalent implantation of the Hintermann Series H2 Total Ankle System implants as compared to the Hintermann instrumentation. To accomplish this objective, Hintermann H2 Total Ankle surgical procedures were performed head-to-head using the OPTIX H2 PSI System and the Hintermann H2 Total Ankle System instrumentation.
An analysis of the surgical procedures performed during the validation lab showed that the OPTIX H2 PSI System does provide an equivalent implantation of the Hintermann Series H2 Total Ankle implants as compared to the Hintermann Series H2 instrumentation. In addition, the OPTIX H2 PSI System is shown to satisfy the clinically justified acceptance criteria of the Hintermann Series H2 Total Ankle System. Therefore, it is concluded that the subject device is substantially equivalent to the predicate device with respect to its mechanical performance.
Debris generation testing was performed for the OPTIX H2 PSI guides in a benchtop setting. The results were compared against a legally marketed device composed of a similar patientspecific instrumentation system. The debris generated by the OPTIX H2 PSI System was found to be acceptable compared to the legally marketed device.
Key Metrics
Not Found
Predicate Device(s)
Hintermann Series H2 Total Ankle System, K171004
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 888.3110 Ankle joint metal/polymer semi-constrained cemented prosthesis.
(a)
Identification. An ankle joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace an ankle joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces and has no linkage across-the-joint. This generic type of device includes prostheses that have a talar resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a tibial resurfacing component made of ultra-high molecular weight polyethylene and is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.
0
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July 17, 2023
Vilex, LLC Brock Johnson President, Vilex, LLC 111 Moffitt Street McMinnville, Tennessee 37110
Re: K230462
Trade/Device Name: OPTIX H2 Patient Specific Instrument System Regulation Number: 21 CFR 888.3110 Regulation Name: Ankle joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: HSN, OYK Dated: April 19, 2023 Received: April 21, 2023
Dear Brock Johnson:
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.
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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 mediation-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.
Lixin Liu -S
Lixin Liu, Ph.D. Assistant Director DHT6A: Division of Joint Arthroplasty 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) K230462
Device Name
OPTIX H2 Patient Specific Instrument System
Indications for Use (Describe)
The OPTIX H2 Patient Specific Instrument System is intended to be used as patient specific surgical planning and instrumentation to assist in the positioning of total ankle replacement components intraoperatively, and in guiding bone cutting. The OPTIX H2 Patient Specific Instrument is intended for use with Vilex's Hintermann Series H2 Total Ankle System and its cleared indications for use. The OPTIX H2 Patient Specific Instrument System is indicated for single use only and is generated from CT imaging data.
| 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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510(k) SUMMARY
| Device Trade Name | OPTIX H2 Patient Specific Instrument System |
|---|---|
| Date | 02/17/2023 |
| Sponsor | Vilex, LLC |
| 111 Moffitt Street | |
| McMinnville, TN 37110 | |
| Contact Person | Brock Johnson |
| President | |
| (801)916-4157 | |
| brock.johnson@vilex.com | |
| Device Common Name | OPTIX H2 PSI System |
| Device Classification | Class II |
| Classification Name | Ankle Joint Metal/Polymer Semi-Constrained Cemented |
| Prosthesis | |
| Regulation | 21 CFR 888.3110 |
| Device Regulation Panel | Orthopedic |
| Device Product Code | HSN, OYK |
| Predicate Device | Hintermann Series H2 Total Ankle System, K171004 |
Purpose:
The purpose of this Traditional 510(k) submission is to gain clearance for the OPTIX H2 Patient Specific Instrument System.
Device Description:
OPTIX H2 Patient Specific Instrument System is patient-specific guides created to fit the contours of the patient's distal tibial and proximal talar anatomy. The guides and models are designed and manufactured from patient imaging data (CT) and are made from biocompatible nylon. The surgical guides in combination with Hintermann reusable instruments, facilitate the positioning of the Hintermann Series H2 Total Ankle implants. Vilex's OPTIX H2 PSI System produces a variety of patient specific outputs including surgical guides, anatomic models, and case reports.
Indications for Use:
The OPTIX H2 Patient Specific Instrument System is intended to be used as patient specific surgical planning and instrumentation to assist in the positioning of total ankle replacement components intraoperatively, and in guiding bone cutting. The OPTIX H2 Patient Specific Instrument System is intended for use with Vilex's Hintermann Series H2 Total Ankle System and its cleared indications for use. The OPTIX H2 Patient Specific Instrument System is indicated for single use only and is generated from CT imaging data.
Technological Characteristics:
The OPTIX H2 Patient Specific Instrument System is indicated for use in conjunction with the Hintermann Series H2 Total Ankle System. The OPTIX H2 Patient Specific Instrument System
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is intended to aid with the bone preparation of the H2 System. After bone preparation, the Hintermann H2 Total Ankle System surgical technique is followed for implantation of the Hintermann H2 implants. Therefore, the technological characteristics of the devices implanted with the OPTIX H2 PSI System and the predicate are identical.
The OPTIX H2 PSI System is comprised of single use instruments composed of DuraForm ProX PA® (SLS) and stainless steel. The predicate device uses reusable stainless-steel and polymer instrumentation. The proper biocompatibility endpoints of ISO 10993-1 have been evaluated for DuraForm ProX PA® and have shown no questions with respect to safety. Both the OPTIX H2 PSI System and the predicate device instrumentation are steam sterilized by the end user prior to use.
The OPTIX H2 PSI System is comprised of patient specific instruments generated from CT imaging. The predicate device uses instrumentation that is not patient specific. The OPTIX H2 PSI System allows the surgeon to create an operating plan before the surgery to visualize how the final implants and instruments will interface with patient anatomy. The OPTIX H2 PSI System also provides patient specific bone models to allow the surgeon to confirm the correct placement of the PSI Cut Guides. The preoperative plan and bone models facilitate the preparation of the bone for the Hintermann H2 Total Ankle Implants. The design of the patient specific guides, models, and pre-operative plan is software-assisted. The predicate device does not contain a preoperative plan, bone models, or software-assisted design.
The technological differences between the OPTIX H2 PSI System and the predicate device allow the OPTIX H2 PSI System to facilitate the implantation of the predicate device. These technological differences are considered minor and raise no questions of safety or effectiveness.
Assessment of performance data:
Validation testing was performed for the OPTIX H2 PSI System in comparison with the Hintermann H2 System. The objective of this testing was to demonstrate that the OPTIX H2 PSI System allows for an equivalent implantation of the Hintermann Series H2 Total Ankle System implants as compared to the Hintermann instrumentation. To accomplish this objective, Hintermann H2 Total Ankle surgical procedures were performed head-to-head using the OPTIX H2 PSI System and the Hintermann H2 Total Ankle System instrumentation.
An analysis of the surgical procedures performed during the validation lab showed that the OPTIX H2 PSI System does provide an equivalent implantation of the Hintermann Series H2 Total Ankle implants as compared to the Hintermann Series H2 instrumentation. In addition, the OPTIX H2 PSI System is shown to satisfy the clinically justified acceptance criteria of the Hintermann Series H2 Total Ankle System. Therefore, it is concluded that the subject device is substantially equivalent to the predicate device with respect to its mechanical performance.
Debris generation testing was performed for the OPTIX H2 PSI guides in a benchtop setting. The results were compared against a legally marketed device composed of a similar patientspecific
5
instrumentation system. The debris generated by the OPTIX H2 PSI System was found to be acceptable compared to the legally marketed device.
Conclusion:
Based upon the similarities of the OPTIX H2 Patient Specific Instrument System and the predicate device, the OPTIX H2 Patient Specific Instrument System is substantially equivalent to the predicate device. The similarities in technological characteristics and performance data demonstrate substantial equivalence.