(78 days)
The Universal Drive System functions as a powered instrument system consisting of drills, saws, and associated handpieces to perform cutting of soft tissue and bone. The fields of application include: Orthopedic, Oral/Maxillofacial, Otolaryngological, Arthroscopic, Hand, Foot, Neuro, and Plastic/Reconstructive surgical procedures.
The Linvatec Universal Drive System is a modification of the Universal Drive System with the addition of three new handpieces used in large bone orthopedic procedures. The Universal Drive System was cleared under 510 (k) #K971059 on 6/18/97 for the following intended uses: Cutting of soft tissue and bone in Orthopedic, Oral/Maxillofacial, Otolaryngological, Arthroscopic, Hand, Foot, Neuro, and Plastic/Reconstructive surgical procedures.
The Universal Drive System consists of an AC powered drive console, a sterilizable handpiece cord, various motorized handpieces, various shavers, blades, burrs, drills, routers, and a foot switch.
The modification will take place within the Universal drive console power unit. A software computer chip will be upgrade to allow the use of additional motorized handpieces for large in order to have more available current to drive the large bone handpieces.
Three handpieces used in large bone orthopedic procedures will be added to the system. The new handpieces include single trigger modular, dual trigger modular handpiece and an oscillating saw. These handpieces are similar in design to the Hall® Versipower® Plus handpieces. The handpieces will be sold with a detachable handpiece cord. The detachable handpiece cord will allow the handpieces run on the same console. The new handpieces will to perform as the Versipower® Plus handpieces described in the predicate information.
The accessories used with the system include shavers, blades, burrs, drills, and routers as described in 510(k)# K971059.
The Linvatec Universal Drive System's 510(k) submission (K981269) does not provide a table of acceptance criteria, device performance, or details about a specific study designed to prove the device meets acceptance criteria in the manner typically expected for AI/ML medical devices. This document is a premarket notification for a traditional medical device (a surgical drive system) submitted in 1998, long before AI/ML-driven device evaluation frameworks were established.
Instead, the submission focuses on demonstrating substantial equivalence to legally marketed predicate devices, which is the primary regulatory pathway for devices of this type at that time.
Here's an analysis based on the provided text, addressing the points where information is available or applicable:
1. Table of Acceptance Criteria and Reported Device Performance
Not applicable in the context of this 510(k) submission. The document states: "Testing has been done to prove safety and effectiveness of the devices," but it does not present a table of specific acceptance criteria (e.g., accuracy, sensitivity, specificity thresholds) or quantifiable performance metrics for the Universal Drive System. The "performance" in this context refers to its ability to perform its intended function similarly to predicate devices.
2. Sample Size Used for the Test Set and Data Provenance
Not applicable. This is a mechanical surgical device, not a diagnostic or prognostic AI/ML device that would typically involve test sets of patient data. The "testing" mentioned would likely refer to engineering verification and validation tests (e.g., torque, speed, durability) in a lab setting, not a "test set" of patient data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
Not applicable. As above, this type of ground truth establishment is not relevant for a surgical drive system.
4. Adjudication Method for the Test Set
Not applicable.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not applicable. This type of study is relevant for AI-assisted diagnostic or prognostic tools where human readers interpret medical images or data. The Universal Drive System is a surgical instrument.
6. Standalone (Algorithm Only) Performance Study
Not applicable. The device is a physical instrument, not an algorithm.
7. Type of Ground Truth Used
Not applicable in the AI/ML sense. The "ground truth" for a device like this would be established through engineering specifications, performance standards, and comparison to the functional capabilities of the predicate devices. For example, if the device is spec'd to provide a certain RPM or torque, the ground truth is that it should meet or exceed that.
8. Sample Size for the Training Set
Not applicable. A "training set" is a concept for AI/ML model development, not for a traditional mechanical surgical tool.
9. How the Ground Truth for the Training Set Was Established
Not applicable.
Summary of Device-Specific Information from the Text:
The document primarily focuses on demonstrating substantial equivalence to existing predicate devices (Linvatec Universal Drive System K971059, Hall® Versipower® Plus Large Bone Instrument System K895198, and 3M™ Maxi-Driver™ Electric Powered Instrument System K951118).
- Device Description: The Universal Drive System is a modification of an existing Linvatec system (cleared under K971059) with the addition of three new handpieces (single trigger modular, dual trigger modular, oscillating saw) and a software upgrade to the console to provide more current for large bone handpieces.
- Intended Use: Cutting of soft tissue and bone in Orthopedic, Oral/Maxillofacial, Otolaryngological, Arthroscopic, Hand, Foot, Neuro, and Plastic/Reconstructive surgical procedures. The new handpieces specifically target "Large Bone Orthopedic Procedures."
- Substantial Equivalence Justification: The new handpieces are described as similar in design and performance to the Hall® Versipower® Plus handpieces. The document implicitly asserts the safety and effectiveness through this substantial equivalence claim and states that "Testing has been done to prove safety and effectiveness of the devices," without providing further details on the nature or results of these tests within the provided text.
In essence, the "study" proving the device meets acceptance criteria in this context is the company's internal engineering verification and validation testing, which supports the claim of substantial equivalence to already cleared devices. The FDA's acceptance of the 510(k) (K981269 letter) confirms that the device is substantially equivalent and can be marketed subject to general controls.
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981/269
JUN 24 1998
Image /page/0/Picture/2 description: The image shows the logo for Linvatec. To the left of the company name is a geometric shape that looks like three arrows pointing to the left. The company name is in bold, black font.
11311 Concept Boulevard Largo, Florida 33773 813 399-5334 Fax 813 399-5264
Carol A. Weideman, Ph.D.
Compliance and Regulatory Affairs
April 6, 1998
510 (k) SUMMARY OF SAFETY AND EFFECTIVENESS
In accordance with the requirements of the Safe Medical Device Act of 1990 and 21 CFR 807.92, Linvatec Corporation is Safety the 510(k) Summary of and hereby submittinq Effectiveness for the Universal Drive System, 510(k) Number
A. Submitter
Linvatec Corporation 11311 Concept Boulevard Largo, Florida 33773-4908
Company Contact B.
Carol A. Weideman, Ph.D. Director, Regulatory and Clinical Affairs
c. Device Name
Trade Name: Common Name Classification Name
Universal Drive System : Drive System . Instrument, Surgical, . . Powered Motor Orthopedic, AC cessory/Attachment
Predicate/Legally Marketed Devices D.
Universal Drive System Linvatec Corporation
Hall® Versipower® Plus Large Bone Instrument System Linvatec Corporation
ЗМТМ Maxi-Driver™ Electric Powered Instrument System 3M Health Care
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Summary of Safety and Effectiveness Universal Drive System 510 (k) # April 6, 1998 Page 2 of 4
Device Description E .
System is a modification of the Universal Drive The Linvatec Universal Drive System with the addition of three new handpieces used in large bone orthopedic procedures. The Universal Drive System was cleared under #K971059 on 6/18/97 for the following intended 510 (k) Cutting of soft tissue and bone in Orthopedic, uses: Oral/Maxillofacial, Otolaryngological, Arthroscopic, Foot, Neuro, and Plastic/Reconstructive surgical Hand, procedures.
Universal Drive System consists of an AC powered The drive console, a sterilizable handpiece cord, various motorized handpieces, various shavers, blades, burrs, drills, routers, and a foot switch.
The modification will take place within the Universal drive console power unit. A software computer chip will be upgrade to allow the use of additional motorized handpieces for large in order to have more available current to drive the large bone handpieces.
Three handpieces used in large bone orthopedic procedures will be added to the system. The new handpieces include single trigger modular, dual trigger modular handpiece and an oscillating saw. These handpieces are similar in design to the Hall® Versipower® Plus handpieces. The handpieces will be sold with a detachable handpiece cord. The detachable handpiece cord will allow the handpieces run on the same console. The new handpieces will to perform as the Versipower® Plus handpieces described in the predicate information.
accessories used with the system include shavers, The as described in blades, burrs, drills, and routers 510(k)# K971059.
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Summary of Safety and Effectiveness Universal Drive System 510(k) # April 6, 1998 Page 3 of 4
Intended Use r.
System functions as a powered Drive The Universal system consisting of drills, saws, and instrument associated handpieces to perform cutting of soft tissue and bone. The fields of application include: Orthopedic, Oral/Maxillofacial, Otolaryngological, Arthroscopic, Hand, Foot, Neuro, and Plastic/Reconstructive surgical procedures.
Substantial Equivalence G.
The Universal Drive System is substantially equivalent in design, function and intended use to the Universal Drive System (Linvatec Corporation), Hall® Versipower® Plus Large Bone Instrument System (Linvatec Corporation), and the 3M™ Maxi-Driver™ Eyectmin Powered Instrument System (3M Health Care) .
Testing has been done to prove safety and effectiveness of the devices.
The similarities/dissimilarities to the predicates are shown in the attached table.
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Summary of Safety and Effectiveness Universal Drive System 510 (k)
April 6, 1998 Page 4 of 4
CHART OF SIMILARITIES AND DISSIMILARITIES
| Company | Device Name | Intended Use | System Components and Design |
|---|---|---|---|
| NEWPRODUCTLinvatec | Universal DriveSystem | Cut Soft Tissue & Bone duringLarge Bone OrthopedicProcedures. | System consists of: Universal Controller, Single TriggerModular Handpiece, Dual Trigger Modular Handpiece, OscillatingSaw, Power Cord and Handpiece Cord. |
| PREDICATELinvatec510 (k)#K971059 | Universal DriveSystem | Cut Soft Tissue & Bone duringOrthopedic,Oral/Maxillofacial, Hand, Foot,Neuro andPlastic/Reconstructive surgicalprocedures. | System consists of: Universal Controller, Foot Control,Sagittal Saw, Oscillating Saw, Reciprocating Saw, High SpeedDrill, Medium Speed Drill, Low Speed Drill,Wiredriver/Fixation Drill and associated attachments, blades,and burs. |
| To perform cutting of softtissue and bone in theapplications of :Arthroscopic/Orthopedic,Otolaryngological andReconstructive Surgery. | System consists of: Universal Controller, Foot Control, "Apexstyle" Handpieces and associated attachments, blades, andburrs.Shaver blades & burrs: length 75-200mm, diameter 2.0-6.0mm. | ||
| PREDICATELinvatec510 (k)#K895198 | Hall®Versipower® PlusLarge BoneInstrumentSystem | Drill, Ream, and Cut large boneduring Orthopedic Procedures. | System consists of: drills and saws which are powered eitherby battery or electric console. |
| PREDICATE3M HealthCare510 (k)K951118 | 3M Maxi-DriverElectric PoweredInstrumentSystem | Drill, Ream, and Cut large boneduring Orthopedic Procedures | System consists of: Controller, handpiece, and interchangeableattachments. |
7
Comments of the
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines representing hair or clothing.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JUN 2 4 1998
Carol A. Weideman, Ph.D. ·Linvatec Corporation 11311 Concept Boulevard Largo, Florida 33773
Re: K981269 Trade Name: Universal Drive System Regulatory Class: II Product Code: HRX Dated: April 6, 1998 Received: April 7, 1998
Dear Dr. Weideman:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (OS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (OS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
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Page 2 - Carol Weideman, Ph.D.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4595. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
Colin M. Witwer, Ph.D., M.D.
Celia M. Witten, Ph.D., M.D. Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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11311 Concept Boulevard Largo, Florida 33773-4908 813 392-6464
April 6, 1998
Page 1 of 1
510 (k) Number (if known) : Universal Drive System Device Name:
Indications for Use:
The Universal Drive System functions as a powered instrument system consisting of drills, saws, and associated handpieces to perform cutting of soft tissue and bone. The fields of Orthopedic, Arthroscopic, include: application Otolaryngological, Oral/Maxillofacial, Hand, Foot, Neuro, and Plastic/Reconstructive surgical procedures.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
| Proleps | |
|---|---|
| (Division Sign-Off) | |
| Division of General Restorative Devices | |
| 510(k) Number | K981269 |
Prescription Use
(Per 21 CFR 801.109)
OR
Over-the-Counter Use
(Optional Format 1-2-96)
§ 888.1100 Arthroscope.
(a)
Identification. An arthroscope is an electrically powered endoscope intended to make visible the interior of a joint. The arthroscope and accessories also is intended to perform surgery within a joint.(b)
Classification. (1) Class II (performance standards).(2) Class I for the following manual arthroscopic instruments: cannulas, currettes, drill guides, forceps, gouges, graspers, knives, obturators, osteotomes, probes, punches, rasps, retractors, rongeurs, suture passers, suture knotpushers, suture punches, switching rods, and trocars. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 888.9.