K Number
K240113
Date Cleared
2024-03-18

(62 days)

Product Code
Regulation Number
888.3030
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Intended Use
CORIOGRAPH Pre-Op Planning and Modeling Service is intended to provide pre-operative planning for surgical procedures based on patient imaging, provided that anatomic landmarks necessary for alignment and positioning of the implant are identifiable on patient imaging scans.

Indications for Use
The CORIOGRAPH Pre-op Planning and Modeling Service is indicated for use for the following procedures:

  • unicondylar knee replacement (UKR)
  • . total knee arthroplasty (TKA)
Device Description

The subject CORIOGRAPH Knee Pre-Op Plan is a medical function module within the CORIOGRAPH Pre-Op Planning and Modeling Service. This service is an additional offering being introduced by Smith & Nephew to allow for preoperative planning for surgical procedures based on patient imaging for total knee arthroplasty (TKA) and unicondylar knee replacement (UKR). The CORIOGRAPH Knee Pre-Op Plans will be generated for specific patients and anatomy by Smith and Nephew personnel using the CORIOGRAPH Knee Pre-Op Plan Software System V1.0, which is the subject of this submission. The CORIOGRAPH Knee Pre-Op Plans will output bone models of the patient anatomy and will generate patient-specific pre-operative plans which may be used on the REAL INTELLIGENCE CORI Surgical System.

AI/ML Overview

The provided text is a 510(k) summary for the CORIOGRAPH Knee Pre-Op Plan. It discusses the device's substantial equivalence to a predicate device and details non-clinical testing. However, it does not contain the specific information required to complete all sections of your request regarding acceptance criteria and a study proving those criteria are met.

Here's a breakdown of what can be answered and what information is missing:

1. A table of acceptance criteria and the reported device performance

The document states, "Verification and validation testing demonstrated the safety and effectiveness of the software applications used in the CORIOGRAPH Knee Pre-Op Plan and demonstrated the safety and effectiveness of the generated CORIOGRAPH Knee Pre-Op Plan when used as an input to the CORI Surgical System. Summative usability testing demonstrated that participating surgeons were able use the subject device safely and effectively in a simulated use environment. Smith and Nephew, Inc. has concluded that all design inputs have been met and that the verification and validation testing performed did not raise any new questions of safety or effectiveness."

This is a general statement of compliance, not a detailed table of specific acceptance criteria (e.g., accuracy metrics, specific tolerances) and their corresponding reported performance values. Therefore, a table cannot be fully constructed.

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This information is not provided in the text. The document refers to "verification and validation testing" and "summative usability testing" but does not specify the sample size for these tests or the origin/nature of the data used.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This information is not provided in the text. The document mentions "participating surgeons" in the usability testing, but their number or specific qualifications (beyond being surgeons) are not detailed. It does not mention experts establishing ground truth for a test set in the context of performance metrics.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This information is not provided in the text.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

The document does not describe an MRMC comparative effectiveness study where human readers' performance with and without AI assistance was evaluated. The device is a "Knee Pre-Op Plan" which suggests it aids in surgical planning, not necessarily in interpretation tasks typically associated with MRMC studies with human readers.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

The document states, "Verification and validation testing demonstrated the safety and effectiveness of the software applications used in the CORIOGRAPH Knee Pre-Op Plan and demonstrated the safety and effectiveness of the generated CORIOGRAPH Knee Pre-Op Plan when used as an input to the CORI Surgical System." This implies standalone testing of the software's output, as well as its interaction as an input to another system. However, specific metrics of "algorithm-only" performance are not provided.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

This information is not explicitly provided in the text. Given the device provides "pre-operative planning for surgical procedures based on patient imaging," the ground truth for evaluating its accuracy would likely be related to the accuracy of anatomical landmark identification, implant positioning, or surgical outcomes, but this is not specified.

8. The sample size for the training set

This information is not provided in the text. The document discusses "software applications" and "planning tools and processes" but does not detail any machine learning models or training sets.

9. How the ground truth for the training set was established

This information is not provided in the text, as no training set details are given.

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March 18, 2024

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 & Human Services logo. To the right of that 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.

Smith & Nephew, Inc Wilcox Miriam Sr. Regulatory Affairs Specialist 1450 Brooks Road Memphis, Tennessee 38116

Re: K240113

Trade/Device Name: CORIOGRAPH Knee Pre-Op Plan Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: January 16, 2024 Received: January 16, 2024

Dear Wilcox Miriam:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Shumaya Ali-S

Shumaya Ali, M.P.H. 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

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Indications for Use

Submission Number (if known)

K240113

Device Name

CORIOGRAPH Knee Pre-Op Plan

Indications for Use (Describe)

Intended Use

CORIOGRAPH Pre-Op Planning and Modeling Service is intended to provide pre-operative planning for surgical procedures based on patient imaging, provided that anatomic landmarks necessary for alignment and positioning of the implant are identifiable on patient imaging scans.

Indications for Use

The CORIOGRAPH Pre-op Planning and Modeling Service is indicated for use for the following procedures:

  • · unicondylar knee replacement (UKR)
  • · total knee arthroplasty (TKA)

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

ver-The-Counter Use (21 CFR 801 Subpart C)

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Smith & Nephew, Inc.

1450 Brooks Road Memphis, TN 38116 USA

T: + 1-901-396-2121 T: + 1-800-821-5700 (USA toll free) www.smith-nephew.com

Smith Nephew

510(k) Summary

510(k) OwnerSmith & Nephew, Inc.1450 Brooks RoadMemphis, Tennessee 38116
Contact PersonMiriam WilcoxSenior Regulatory Affairs SpecialistEmail: miriam.wilcox@smith-nephew.com
Date Prepared18-March-2023
Classification Reference21 CFR 888.3030
Product CodePBF
Supported CodesJWH, MBH, OOG, HSX
Common/Usual NameOrthopaedic Surgical Planning and Instrument Guides
Trade/Proprietary NameCORIOGRAPH Knee Pre-Op Plan
Predicate Device(s)VISIONAIRE UK Patient Matched Cutting Guides (K211512)
Reason for SubmissionThis Traditional 510(k) submission is seeking clearance for a newoffering, CORIOGRAPH Knee Pre-Op Plan V1.0, a module of theCORIOGRAPH Pre-Op Planning and Modeling Service

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Smith & Nephew, Inc. 1450 Brooks Road Memphis, TN 38116 USA

-821-5700 (USA toll free) -nephew.com

Intended Use

CORIOGRAPH Pre-Op Planning and Modeling Service is intended to provide pre-operative planning for surgical procedures based on patient imaging, provided that anatomic landmarks necessary for alignment and positioning of the implant are identifiable on patient imaging scans.

Indications for Use

The CORIOGRAPH Pre-op Planning and Modeling Service is indicated for use for the following procedures:

  • unicondylar knee replacement (UKR)
  • . total knee arthroplasty (TKA)

Device Description

The subject CORIOGRAPH Knee Pre-Op Plan is a medical function module within the CORIOGRAPH Pre-Op Planning and Modeling Service. This service is an additional offering being introduced by Smith & Nephew to allow for preoperative planning for surgical procedures based on patient imaging for total knee arthroplasty (TKA) and unicondylar knee replacement (UKR). The CORIOGRAPH Knee Pre-Op Plans will be generated for specific patients and anatomy by Smith and Nephew personnel using the CORIOGRAPH Knee Pre-Op Plan Software System V1.0, which is the subject of this submission. The CORIOGRAPH Knee Pre-Op Plans will output bone models of the patient anatomy and will generate patient-specific pre-operative plans which may be used on the REAL INTELLIGENCE CORI Surgical System.

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Smith & Nephew, Inc. 1450 Brooks Road Memphis, TN 38116 USA

: + 1-901-396-2121 T: + 1-800-821-5700 (USA toll free) www.smith-nephew.com

Currently Supported Knee Implants

The CORIOGRAPH Knee Pre-Op Plan is compatible with implant systems aligned to those supported with the REAL INTELLIGENCE CORI Surgical System. Compatible implant systems and clearance numbers are provided in Table 1.

TABLE 1. CURRENTLY SUPPORTED SMITH+ NEPHEW KNEE IMPLANTS FOR THE CORIOGRAPH KNEE PRE-OP PLAN V1.0

Implant Model Name510(k) NumberClassificationProduct Code
JOURNEY II Unicompartmental Knee SystemK191211HSX
JOURNEY UNIK102069HSX
JOURNEY II CRK121443JWH
JOURNEY II BCSK111711JWH
JOURNEY II XRK141471, K152726JWH
LEGION CR/PSK951987, K962557, K093746JWH
LEGION Porous CR Femoral ComponentsK073325, K091543MBH
LEGION Porous CR Narrow Femoral ComponentsK210566MBH
LEGION Porous TibiaK100897MBH
Porous Tibia BaseplateK211221MBH
GENESIS II CR/PSK951987, K962557JWH
ANTHEMK142807JWH
LEGION Knee SystemK180334JWH, MBH

REAL INTELLIGENCE CORI Surgical System Compatibility

The CORIOGRAPH Knee Pre-Op Plan is compatible with the following versions of the REAL INTELLIGENCE CORI surgical system.

TABLE 2. CURRENTLY SUPPORTED SYSTEM COMPATIBILITY FOR THE CORIOGRAPH KNEE PRE-OP PLAN V1.0

Device NameVersion510(k) NumberClassificationProduct Code
REAL INTELLIGENCE CORI3.0K240139HSX

Discussion of Similarities and Differences

The purpose of this Traditional 510(k) submission is to seek clearance for the CORIOGRAPH Knee Pre-Op Plan V1.0, which is a medical function module of the CORIOGRAPH Pre-Op Planning and Modeling Service. This Software as a Medical Device (SaMD) is based on the VISIONAIRE Patient-Matched Technology Software Process also used to generate preoperative plans and physical instruments by the predicate device VISIONAIRE Patient-Matched Cutting Guides (K211512).

The modifications made to the VISIONAIRE Patient-Matched Technology Software Process include an update to a software application to allow for:

  • A new pre-operative planning workflow within the software application. This workflow will use the same implant database used on the CORI Surgical System.
  • Added ability to detect if the case is intended for Visionaire Patient Matched Cutting Guide or for CORIOGRAPH Pre-operative planning from the surgeon inputs.

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1-800-821-5700 (USA toll free) www.smith-nephew.com

  • . Added ability to create a .json file and pre-operative plan images as outputs for pre-operative planning workflow.
  • Implementation of minor bug fixes.

The software planning tools and processes used for the CORIOGRAPH Knee Pre-Op Plan have similar intended use, indications for use and technological characteristics as the software planning tools used for the preoperative plans generated for surgeon concurrence in the predicate VISIONAIRE UK Patient Matched Cutting Guides (K211512).

Smith & Nephew believes that CORIOGRAPH Knee Pre-Op Plan V1.0 is subject to premarket notification requirements under Section 510(k) of the Federal Food, Drug and Cosmetic Act ("FFDCA" or "the Act") and is substantially equivalent to the previously cleared REAL INTELLIGENCE CORI (K221224).

TABLE 3. PREDICATE DEVICE

ManufacturerDescriptionSubmission NumberClearance Date
Smith & Nephew, IncVISIONAIRE UK PatientMatched Cutting GuidesK21151209/16/2021

Substantial equivalence analysis for the CORIOGRAPH Knee Pre-Op Plan is provided in Table 4.

TABLE 4. SUBSTANTIAL EQUIVALENCE TABLE

Design AspectReviewedCORIOGRAPH Knee Pre-OpPlan(Subject Device)VISIONAIRE UK PatientMatched Cutting Guides(Predicate Device)Comparison
510(k) NumberK240113K211512S.E. 09/16/2021N/A
ManufacturerSmith & Nephew, Inc.Smith & Nephew, Inc.Same as predicate
Design AspectReviewedCORIOGRAPH Knee Pre-OpPlan(Subject Device)VISIONAIRE UK PatientMatched Cutting Guides(Predicate Device)Comparison
Indications forUseIntended UseCORIOGRAPH Pre-operativePlanning Service is intendedto provide pre-operativeplanning for surgicalprocedures based on patientimaging, provided thatanatomic landmarksnecessary for alignment andpositioning of the implantare identifiable on patientimaging scans.Indications for UseThe CORIOGRAPH Pre-operative Planning Service isindicated for use for thefollowing procedures:unicondylar kneereplacement (UKR)total knee arthroplasty(TKA)Smith & Nephew'sVISIONAIRE UK PatientMatched Cutting Guides areintended to be used aspatient-specific surgicalinstrumentation to assist inthe positioning of kneereplacement componentsintra-operatively and inguiding the marking of bonebefore cutting provided thatanatomic landmarksnecessary for alignment andpositioning of the implantare identifiable on patientimaging scans.The Smith & NephewVISIONAIRE UK PatientMatched Cutting Guides areintended for use with thefollowing existing Smith &Nephew, Inc. Knee Systemsand their cleared indicationsfor use:Genesis II Knee SystemLegion Knee SystemJourney BCS KneeSystemJourney II Knee SystemJOURNEY IIUnicompartmental Knee(JOURNEY II UK) System(K190085)The Smith & NephewVISIONAIRE UK PatientMatched Cutting Guides areintended for single use only.Substantially equivalent -Intended use is modified toreflect that the output is asoftware file instead of aphysical patient-matchedpart. The indications for useare updated to reflect thesurgical procedures insteadof the specific implantsystems. As the softwareoutput is used within theCORI surgical system, thedevice is not limited bymanufacture of physicalparts. Compatible ImplantSystems will be disclosed inthe case management portal
TargetPopulationPatients who are able toundergo an MRI safely, fitthe indications, and do notpresent anycontraindications for theexisting knee implant systemto which it is designed.Patients who are able toundergo an MRI safely, fitthe indications, and do notpresent anycontraindications for theexisting knee implant systemto which it is designed.Same as predicate
TargetAnatomyKneeKneeSame as predicate
CORIOGRAPH Knee Pre-OpPlan(Subject Device)VISIONAIRE UK PatientMatched Cutting Guides(Predicate Device)Comparison
Design AspectReviewed
Where usedProfessional healthcare facilityProfessional healthcare facilitySame as predicate
CompatibleTotal KneeSystemsGenesis II CRGenesis II PSLEGION CRLEGION CR PorousLEGION CR Narrow PorousLEGION PSJourney II BCSJourney II CRJourney II XRJourney II BCS ROXJourney II CR ROXJourney II UKJourney UniGenesis II CRGenesis II PSLEGION CRLEGION PSJourney II BCSJourney II CRJourney II XRJOURNEY IIUnicompartmental Knee(JOURNEY II UK)Substantially equivalent - Asa software device,compatible implant systemsfor the subject device arealigned with implants clearedfor use with the CORISurgical System, whilecompatible implants for thepredicate device weredefined by cleared productofferings for physical patientmatched guides.
Design TypeOutputPatient MatchedPreoperative surgical planprovided in PDF for surgeonreview. After surgeonacceptance of the planparameters, PDF and/orsoftware file is provided tobe used as an input torobotic surgical system.Patient MatchedPreoperative surgical planprovided in PDF for surgeonreview. After surgeonacceptance of the planparameters, Physical PatientMatched Cutting Block isprovided.Same as predicateSubstantially equivalent -Final output is a software fileinstead of a physical patient-matched cutting guide
Common NameOrthopaedic SurgicalPlanning and InstrumentGuidesKnee ProsthesisSubstantially Equivalent -Output of Pre-Operative planis SaMD instead of a physicalguide, therefore productcode is updated to reflectoutput.
Device ClassClass IIClass IISame as predicate
DeviceClassificationName andReference21 CFR 888.3030 -Single/multiple componentmetallic bone fixationappliances and accessories.21 CFR 888.3520- Knee JointFemorotibial metal/polymernonconstrained cementedprosthesis21 CFR 888.3560- Knee JointPatellofemorotibialpolymer/metal/polymersemi-constrained cementedprosthesisSubstantially Equivalent -Output of Pre-Operative planis SaMD instead of a physicalguide, therefore productcode is updated to reflectoutput.
Panel CodeOrthopaedics/87Orthopaedics/87Same as predicate
Product CodePBFHSXOOGSubstantially Equivalent -Output of Pre-Operative planis SaMD instead of a physicalguide, therefore productcode is updated to reflectoutput.
Design AspectReviewedCORIOGRAPH Knee Pre-OpPlan(Subject Device)VISIONAIRE UK PatientMatched Cutting Guides(Predicate Device)Comparison
SupportedProduct CodeJWHMBHOOGHSXJWHMBHOOGHSXSame as predicate

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Smith Nephew

Smith & Nephew, Inc.

1450 Brooks Road Memphis, TN 38116
USA T: + 1-901-396-2121 T: + 1-800-821-5700 (USA toll free) www.smith-nephew.com

{8}------------------------------------------------

Smith Nephew

Smith & Nephew, Inc.

1450 Brooks Road Memphis, TN 38116
USA T: + 1-901-396-2121 T: + 1-800-821-5700 (USA toll free) www.smith-nephew.com

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Smith & Nephew, Inc. 1450 Brooks Road Memnhis TN 38116

USA

5700 (USA toll free) ephew.com

Non-Clinical Testing (Bench)

Verification and validation testing demonstrated the safety and effectiveness of the software applications used in the CORIOGRAPH Knee Pre-Op Plan and demonstrated the safety and effectiveness of the generated CORIOGRAPH Knee Pre-Op Plan when used as an input to the CORI Surgical System. Summative usability testing demonstrated that participating surgeons were able use the subject device safely and effectively in a simulated use environment. Smith and Nephew, Inc. has concluded that all design inputs have been met and that the verification and validation testing performed did not raise any new questions of safety or effectiveness.

Conclusion

The software tools and process used for CORIOGRAPH Knee Pre-Op Plan have similar intended use and indications for use and the same technological characteristics used in the software planning tools and processes used for the preoperative plans generated for the predicate VISIONAIRE UK Patient Matched Cutting Guides (K211512). The differences between the two systems include an update to support the implant database used by the CORI Surgical System as well as a modification of the output to include a JSON file and preoperative plan images for use on the CORI Surgical System.

Verification testing demonstrated that the system meets required design inputs. Summative usability testing results demonstrate that representative users can use the safely and effectively in a simulated use environment. The information presented in this 510(k) premarket notification demonstrates that the CORIOGRAPH Knee Pre-Op Plan System may be used to generative plans for surgical procedures based on patient imaging. This information also demonstrates that the CORIOGRAPH Knee Pre-Op Plan system is as safe and effective as the software and planning process used in the predicate VISIONAIRE UK Patient Matched Cutting Guides (K211512). Smith and Nephew, Inc. believes that FDA can find CORIOGRAPH Knee Pre-Op Plan V1.0 to be substantially equivalent to the predicate device.

§ 888.3030 Single/multiple component metallic bone fixation appliances and accessories.

(a)
Identification. Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.